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Environmental Assessment and Finding of No Significant Impact for Herbicide Use Within Authorized Power Line Rights-Of-Way on National Forest System Lands in Arizona

Environmental Assessment and Finding of No Significant Impact for Herbicide Use Within Authorized Power Line Rights-Of-Way on National Forest System Lands in Arizona

Department of Agriculture Environmental Assessment and Finding of No Significant Impact for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in

Forest Service Southwestern Region Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests December 2018

Page intentionally left blank For More Information Contact: Thomas Torres, P.E. Deputy Forest Supervisor 2324 East McDowell Road Phoenix, Arizona 85006 Phone: 602.225.5203 Email: [email protected]

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident. Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English. To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: [email protected]. USDA is an equal opportunity provider, employer and lender.

Page intentionally left blank Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Table of Contents CHAPTER 1. Purpose and Need for Action ...... 1 1.1 Location of the Proposed Project Area ...... 1 1.2 Background ...... 8 1.3 Need for the Proposal ...... 9 1.4 Public Involvement and Issues ...... 9 1.5 Decision Framework ...... 10 1.6 Relationships to Statutes, Regulations, and Other Plans ...... 10 CHAPTER 2. Alternatives ...... 13 2.1 Alternative A - No Action Alternative ...... 13 2.2 Alternative B - Proposed Action ...... 22 2.3 Alternatives Considered but Eliminated from Further Analysis ...... 39 CHAPTER 3. Affected Environment and Environmental Consequences ...... 41 3.1 Introduction ...... 41 3.2 Resources Considered for Analysis ...... 41 3.3 Soils...... 41 3.4 Water Resources and Quality (Drinking/Surface/Groundwater) ...... 49 3.5 Wetlands and Riparian Areas ...... 60 3.6 General Vegetation ...... 65 3.7 Federally Listed Species ...... 89 3.8 Forest Service Sensitive Species ...... 121 3.9 Bald and Golden Eagle Protection Act ...... 140 3.10 Migratory Birds and Important Bird Areas ...... 142 3.11 Forest Service Management Indicator Species ...... 149 3.12 Health ...... 156 3.13 Fire and Fuel Management ...... 159 3.14 Human Health and Safety ...... 164 CHAPTER 4. Cumulative Impacts ...... 169 4.1 Geographic and Temporal Scope of Analysis ...... 169 4.2 Timeframe of Effects ...... 171 4.3 Past and Present Actions ...... 171 4.4 Reasonably Foreseeable Future Actions ...... 171 4.5 Cumulative Impacts on Resources ...... 171 4.6 Soils...... 173 4.7 Water Resources and Quality (Drinking/Surface/Groundwater) ...... 174 4.8 Wetlands and Riparian Areas ...... 176 4.9 General Vegetation ...... 177 4.10 Federally Listed Species ...... 178 4.11 Forest Service Sensitive Species ...... 180 4.12 Rangeland Health ...... 181 4.13 Fire and Fuel Management ...... 182 4.14 Human Health and Safety ...... 183 CHAPTER 5. Finding of No Significant Impact ...... 185 CHAPTER 6. List of Preparers and Reviewers ...... 189 6.1 List of Preparers and Reviewers ...... 189 CHAPTER 7. Glossary ...... 193 CHAPTER 8. References ...... 205

i Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

List of Tables Table 1.1-1. Miles of Electrical Lines and Acres of ROW ...... 1 Table 2.2-1. Forest Service-Approved Herbicides List Proposed for Use ...... 23 Table 2.2-2. Forest Service-Approved Herbicides List with Vegetation Treatment Application and Use Descriptions ...... 25 Table 3.3-1. Acres of Soil Orders within APS ROW ...... 43 Table 3.3-2. Soil Orders Properties within ROW ...... 44 Table 3.3-3. Herbicide Characteristics in Water and Soil ...... 48 Table 3.4-1. HUC 8 Subbasin Watersheds within ROW ...... 50 Table 3.4-2. Surface Water within ROW within Apache-Sitgreaves National Forests ...... 51 Table 3.4-3. Surface Water within ROW within ...... 51 Table 3.4-4. Surface Water within ROW within ...... 52 Table 3.4-5 Surface Water within ROW within ...... 52 Table 3.4-6. Surface Water within ROW within Tonto National Forest ...... 53 Table 3.4-7. Groundwater Subbasins within ROW ...... 56 Table 3.5-1. NWI Wetland Type Acres within APS ROW ...... 61 Table 3.5-2. Riparian Vegetation Community Types within APS ROW ...... 62 Table 3.5-3. List of Herbicides Proposed for Use within Riparian and Wetland Vegetation and Adjacent to Aquatic Habitat ...... 63 Table 3.6-1. Forest Vegetation System ERUs ...... 69 Table 3.6-2. Vegetation System ERUs ...... 69 Table 3.6-3. Riparian Vegetation System ERUs ...... 70 Table 3.6-4. Riparian/Wetland Vegetation System ERUs ...... 71 Table 3.6-5. Shrubland Vegetation System ERUs ...... 71 Table 3.6-6. Wetland Vegetation System ERUs ...... 72 Table 3.6-7. Woodland Vegetation System ERUs ...... 72 Table 3.6-8. Human/Other Vegetation System ERUs ...... 73 Table 3.7-1. Federally Listed Threatened, Endangered, and Experimental, Nonessential Population Species within APS ROW - Amphibians ...... 90 Table 3.7-2. Federally Listed Threatened, Endangered, and Experimental, Nonessential Population Species within APS ROW - Birds ...... 90 Table 3.7-3. Federally Listed Threatened, Endangered, and Experimental, Nonessential Population Species within APS ROW - Fish ...... 90 Table 3.7-4. Federally Listed Threatened, Endangered, and Experimental, Nonessential Population Species within APS ROW - Mammals ...... 91 Table 3.7-5. Federally Listed Threatened, Endangered, and Experimental, Nonessential Population within APS ROW - ...... 91 Table 3.7-6. Federally Listed Threatened, Endangered, and Experimental, Nonessential Population Species within APS ROW - Reptiles ...... 91 Table 3.7-7. Acres of APS ROW within MSO Critical Habitat, PACs, and Recovery Habitat by National Forest ...... 93 Table 3.7-8. Summary of Stream or River, and Number of Crossings over Federally Listed Fish Species within APS ROW ...... 112 Table 3.8-1. Forest Service Sensitive Species – Amphibians ...... 122 Table 3.8-2. Forest Service Sensitive Species – Birds ...... 122 Table 3.8-3. Forest Service Sensitive Species – Invertebrates ...... 123 Table 3.8-4. Forest Service Sensitive Species – Fish ...... 123 Table 3.8-5. Forest Service Sensitive Species – Mammals ...... 124 Table 3.8-6. Forest Service Sensitive Species – Reptiles ...... 124 Table 3.8-7. Forest Service Sensitive Species – Plants ...... 125

ii Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Table 3.10-1. Migratory Bird Species that may be Present in the Project Area ...... 143 Table 3.10-2. Important Bird Areas within the ROW ...... 146 Table 3.11-1. MIS and Habitat, Forest-Wide and APS ROW Acres for Coconino National Forest ...... 150 Table 3.11-2. MIS and Habitat, Forest-Wide and APS ROW Acres for Tonto National Forest ...... 150 Table 3.12-1. Grazing Allotment Acreage ...... 157 Table 3.13-1. Scott and Burgan Fuel Types ...... 160 Table 3.13-2. Scott and Burgan Fuel Models within APS ROWs ...... 161 Table 4.1-1. Cumulative Effects Study Area (CESA)a ...... 169 Table 4.5-1. Reasonably Foreseeable Future Projects ...... 172

List of Figures Figure 1-1. Vicinity Map ...... 2 Figure 1-2. ROWs within Forest Boundary, Apache-Sitgreaves National Forests ...... 3 Figure 1-3. ROWs within Forest Boundary, Coconino National Forest ...... 4 Figure 1-4. ROWs within Forest Boundary, Kaibab National Forest ...... 5 Figure 1-5. ROWs within Forest Boundary, Prescott National Forest...... 6 Figure 1-6. ROWs within Forest Boundary, Tonto National Forest ...... 7 Figure 4-1. Power Lines in Arizona – Cumulative Effects Study Area ...... 170

List of Photographs Photograph 2-1. Defensible Space around a Wooden Utility Pole ...... 16 Photograph 2-2. Defensible Space around a Wooden Utility Pole, Christopher Creek, AZ ...... 16 Photograph 2-3. Example of Manual Treatment by Polesaw ...... 17 Photograph 2-4. Example of Manual Treatment by Handsaw ...... 18 Photograph 2-5. Example of Mechanical Treatment by Slashbuster ...... 18 Photograph 2-6. Example of Mechanical Treatment by John Deere 200LC with Shinn Cutter Head ...... 19 Photograph 2-7. Example of Incompatible Brush to Target for Herbicide Treatment ...... 29 Photograph 2-8. Example of Incompatible Pine Seedling to Target for Herbicide Treatment ...... 29 Photograph 2-9. Example of Incompatible Gambel Oak to Target for Herbicide Treatment ...... 30 Photograph 2-10. ATV with Mounted Tanks and Low-Volume Hand Wand ...... 31 Photograph 2-11. Low-Volume Backpack Sprayer ...... 31 Photograph 2-12. Foliar Application of Herbicides Using a Low-Volume Backpack Sprayer ...... 32 Photograph 2-13. Cut-Stump Technique ...... 33 Photograph 2-14. Basal Application ...... 34 Photograph 3-1. Ponderosa Pine Forest ERU - Coconino National Forest in Northern Arizona, near Flagstaff ...... 75 Photograph 3-2. Characteristic Photo of the Colorado Plateau / Grassland ERU ...... 76 Photograph 3-3. Characteristic Photo of the Semi-Desert Grassland ERU ...... 77 Photograph 3-4. Characteristic Photo of the Interior Chaparral ERU ...... 78 Photograph 3-5. Characteristic Photo of the Mojave- Scrub ERU ...... 79 Photograph 3-6. Characteristic Photo of the Juniper Grass ERU ...... 80 Photograph 3-7. Characteristic Photo of the Pinyon Juniper Evergreen ERU ...... 81 Photograph 3-8. Characteristic Photo of the Pinyon-Juniper Woodland ERU ...... 82

iii Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

List of Appendices Appendix A. Conformance with National Forest Land and Resource Management Plans ...... 233 Appendix B. Documents incorporated by reference or used for tiering ...... 243 Appendix C. Applicable Federal Laws, Regulations, and Policies ...... 247 Appendix D. List of Compatible or Incompatible Vegetation ...... 253 Appendix E. Biological Conservation Measures ...... 261 Appendix F. Supplemental Information: Herbicides and Adjuvants (Including Thinvert) ...... 275 Appendix G. Ecotoxicity Ratings for Pesticide Active Ingredients and Various Formulations ...... 303 Appendix H. Resources Considered for Analysis ...... 307 Appendix I. Projects Considered for Cumulative Effects Analysis ...... 315

iv Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

List of Acronyms ADEQ Arizona Department of Environmental Quality ADOT Arizona Department of Transportation ADWR Arizona Department of Water Resources AGFD Arizona Game and Fish Department ANSI American National Standards Institute APE area of potential effect APS Arizona Public Service Company ATV all-terrain vehicle AZ Arizona AZPDES Arizona Pollution Discharge Elimination System BA Biological Assessment BE Biological Evaluation BMP best management practice CAS Chemical Abstracts Service CEQ Council on Environmental Quality CESA cumulative effects study area CFR Code of Federal Regulations CWA Clean Water Act DSAP defensible space around poles EA environmental assessment EIS Environmental Impact Statement EPA U.S. Environmental Protection Agency ERU Ecological Response Unit ESA Endangered Species Act FERC Federal Energy Regulatory Commission FHWA Federal Highway Administration FIFRA Federal Insecticide, Fungicide, and Rodenticide Act FLPMA Federal Land Policy and Management Act of 1976 Forest Service U.S. Department of Agriculture Forest Service FSH Forest Service Handbook FSM Forest Service Manual GIS Geographic Information System GPS Global Positioning System HUC Hydrologic Unit Code IBA Important Bird Area IPaC Information for Planning and Conservation IVM Integrated Vegetation Management LiDAR Light Detection and Ranging

v Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

MA Management Area MBTA Migratory Bird Treaty Act MCS Multiple Chemical Sensitivity MIS management indicator species MSO Mexican spotted owl MVCD minimum vegetation clearance distance MWEPA Mexican Wolf Experimental Population Area National Register National Register of Historic Places NEPA National Environmental Policy Act NERC North American Electric Reliability Corporation NHD National Hydrography Dataset NHPA National Historic Preservation Act NNHPD-TCP Navajo Nation Historic Preservation Department-Traditional Culture Program NOAA National Oceanic and Atmospheric Administration NRCS Natural Resources Conservation Service NWI National Wetlands Inventory Program PAC Protected Activity Center PNVT potential natural vegetation type PUP Pesticide Use Proposal RED Registration Eligibility Decision ROW right-of-way SERA Syracuse Environmental Research Associates, Inc. SHPO State Historic Preservation Office/Officer SIO Scenic Integrity Objective The five forests Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto national forests THPO Tribal Historic Preservation Office/Officer U.S. United States U.S.C. United States Code USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey WAPA Western Area Power Administration WFLC Wildland Fire Leadership Council WRDC Water Resources Development Commission WSA Wilderness Study Area

vi Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

CHAPTER 1. Purpose and Need for Action

The Arizona Public Service Company (APS) is proposing to use a targeted application of United States (U.S.) Department of Agriculture Forest Service (Forest Service)-approved herbicides in addition to existing vegetation treatment methods within the rights-of-way (ROWs). The use of herbicides in combination with currently authorized mechanical and manual treatments would become part of the APS Integrated Vegetation Management (IVM) approach. The introduction of herbicides to APS’s tools would assist with the reduction and control of incompatible vegetation within APS’s ROW in Arizona to ensure the delivery of safe and reliable electricity to the public.

1.1 Location of the Proposed Project Area The Forest Service administers approximately 11.6 million surface acres in Arizona. The Arizona Public Service Company has approximately 1,607 miles of existing distribution and transmission lines crossing National Forest System lands (approximately 13,463 acres of ROW) in five of the six national forests in Arizona. The ROW represents approximately 0.14 percent of the approximately 9.6 million acres managed within the Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto national forests (the five forests; refer to Table 1.1-1 and Figures 1-1 through 1-6). There are no APS ROWs within the remaining national forest in Arizona; therefore, the is not included in this environmental assessment (EA). Additionally, APS is not proposing to use herbicides within congressionally designated wilderness boundaries.

Table 1.1-1. Miles of Electrical Lines and Acres of ROW % of the % of the Five Total Acres of Miles of APS National Forests Acres a of APS National Forest National Electrical Forest that is Combined that ROW Forest Lines APS ROW is APS ROW (acres b) (acres c) Apache-Sitgreaves 2,110,196 131.78 1,814.56 0.09 0.02 Coconinod 1,851,626 437.14 2,024.35 0.11 0.02 Kaibab 1,600,321 264.49 2,300.39 0.14 0.02 Prescott 1,247,328 352.26 2,812.75 0.23 0.03 Tonto 2,873,300 422.76 4,511.24 0.16 0.05 Total 9,682,771 1,607.43 13,463.30 0.14 0.14 Source: Mileage and acreage data provided by APS (APS 2016). Acres of the individual national forest are based on their respective land and resource management plans. a The Forest Service has issued a special use authorization (permit), which provides permission, without conveying an interest in land, for APS to occupy and use Forest Service land for electrical transmission purposes. The special use permits are issued under the authority of 43 United States Code (U.S.C.) 1701 et seq. and 36 Code of Federal Regulations (CFR) 251.53(l)(4) Subpart B. b The percentage of the acres of authorized ROW with respect to the total managed acres within each respective national forest. c The percentage of total acres of authorized ROW with respect to the total managed acres for the five combined national forests. d Acres of APS ROW includes approximately 5.35 acres of ROW within the Sycamore Canyon Wilderness Area where herbicides are not proppsed for use.

1 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Figure 1-1. Vicinity Map

2 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Figure 1-2. ROWs within Forest Boundary, Apache-Sitgreaves National Forests

3 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Figure 1-3. ROWs within Forest Boundary, Coconino National Forest

4 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Figure 1-4. ROWs within Forest Boundary, Kaibab National Forest

5 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Figure 1-5. ROWs within Forest Boundary, Prescott National Forest

6 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Figure 1-6. ROWs within Forest Boundary, Tonto National Forest

7 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

1.2 Background The Arizona Public Service Company is responsible for managing vegetation within APS’s ROW. APS must manage vegetation to protect electrical distribution and transmission lines, to provide reliable energy delivery, to maintain access to the lines, to ensure the safety of the public and electrical workers, and to protect environmental resources in accordance with the following electrical system standards and regulations: . 2012 National Electrical Safety Code (Institute of Electric and Electronics Engineers 2011) . Federal Energy Regulatory Commission’s (FERC’s) Order 785 (FERC 2013) . North American Electric Reliability Corporation’s (NERC’s) reliability standards (NERC 2018): Facilities Design, Connections, and Maintenance standard for Transmission Vegetation Management FAC-003-4 (2016) and Protection and Control standard for Transmission and Generation Protection System Maintenance and Testing PRC-005-1 Vegetation interference with electrical distribution and transmission lines is one of the most common causes of electrical power outages throughout the United States. Outages can occur when vegetation and overhead power lines become too close to each other as a result of vegetation growth; increased electrical loads, which can cause lines to sag and make contact with vegetation, and/or changes in ambient conditions such as increased air temperature or wind speed. Vegetation within ROWs has been implicated in large-scale electric grid failures in the United States and Canada, including a 2003 blackout that affected an estimated 50,000,000 people in eight States and two Canadian provinces (NERC 2004). Additionally, unmanaged vegetation within ROWs, such as and trees, can be more susceptible to wildfire and crowd out native grasses and forbs. Reliability standard FAC-003-4 requires that trees and other vegetation growing in or adjacent to the ROW be trimmed to prevent power outages caused by tree contact with a power line. Any power line contact or arching with a tree can cause a short circuit which may lead to a blackout or threaten public safety. Table 2 in the NERC reliability standard FAC-003-4 identifies the minimum vegetation clearance distance (MVCD) vegetation can be before arching with a power line (NERC 2016, page 16, Table 2). In general, the MVCD ranges between 1.1 and 14.3 feet, depending on the voltage for a particular power line. Trees and other vegetation are regularly pruned or removed well away from MVCD to account for the fact that vegetation continuously grows, sways with the wind, and can hang lower from snow build- up, or that power lines can sag due to high usage, heat, or snow and ice build-up. Each utility develops and implements its own vegetation management plan clearance requirements that accounts for requirements of State or local authorities and any applicable ROW or easement agreement with the property owner as well as multiple factors, such as line condition, vegetation condition, environmental factors, geographic conditions, maintenance cycle, and approved maintenance methods. Therefore, specific clearance distances may vary between power lines, utilities, and landowners, but would always exceed the MVCD established in FAC-003-4. In addition to vegetation interference, wildfires fueled by vegetation within the ROW can be another cause of power outages. In recent years, the severity and intensity of wildfires have dramatically increased partly due to increases in incompatible vegetation identified as hazardous fuels. Additionally, climate change is anticipated to affect fire risk, especially near utility corridors. One study projected a 40 percent increase in the probability of wildfire exposure for some transmission lines (Sathaye et al. 2012). In response to increased wildfire risks, the President and Congress have directed the U.S. Department of the Interior (USDI) and BLM, through implementation of the 2000 National Fire Plan (USDI and Forest Service 2000), Multiple-Use Sustained-Yield Act of 1960 (Forest Service 1960), and the Healthy Forests Restoration Act of 2003, to take more aggressive actions to reduce catastrophic wildfire risk on public lands.

8 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

The Forest Service currently uses herbicides on a project-by-project basis to treat noxious weeds, non-native invasive species, and incompatible vegetation on National Forest System lands. The Forest Service completed a programmatic EA in 2003 to allow for the use of herbicides within Arizona Department of Transportation (ADOT)/Federal Highway Administration (FHWA) ROWs crossing National Forest System lands (Forest Service 2003a). In addition, APS has been using herbicides as part of their vegetation management programs on non-Federal lands since the mid-1990s in an effort to eliminate regrowth of incompatible vegetation. This EA is a project-specific analysis of the potential impacts of the Proposed Action to use Forest Service-approved herbicides within the existing ROW on National Forest System lands in Arizona. The project area and analysis area for this EA is defined as the APS ROW and the terms are used synonymously throughout the EA. The analysis area includes the permitted APS ROW as specified in the special use permits where vehicles may drive off-road within the ROW and where vegetation may be removed or pruned to maintain safe clearance distance from the lines and the airspace over National Forest System lands. The Arizona Public Service Company also completes work outside of the APS ROW where hazard trees may be removed and along all access routes on National Forest System lands that vehicles use to gain access to the power lines ROWs. The Arizona Public Service Company maintenance and other activities that occur outside of the existing ROW, on private land, or other non- National Forest System lands are not part of the Proposed Action and are not included within the analysis area of this EA. The Arizona Public Service Company does not currently use herbicides to maintain vegetation in their ROWs on National Forest System lands in Arizona. Instead APS uses a combination of mechanical and manual methods, such as masticators (mowers, chippers, or brushcutters) and chainsaws, to remove incompatible vegetation. The Arizona Public Service Company conducts regularly scheduled inspections of the electrical distribution and transmission systems to monitor any ROW encroachments from incompatible vegetation. Depending on vegetation growth rates, each ROW is mechanically or manually treated approximately every three to six years on National Forest System lands.

1.3 Need for the Proposal The proposed project need is to encourage early successional communities, convert vegetation in the ROW to compatible low-growing plant species, and reduce hazardous fuels using more effective methods through the use of selected Forest Service-approved herbicides as part of vegetation management within the ROWs in order to ensure the delivery of safe and reliable electricity to the public. The Proposed Action is to add Forest Service-approved herbicides to the existing APS vegetation management tools for controlling incompatible vegetation in the ROW. The Forest Service’s responsibility under Section 501(a)(4) of the Federal Land Policy and Management Act of 1976 (FLPMA) and Title 36 Code of Federal Regulations (CFR) Part 251.50 is to respond to the APS application to use selected and Forest Service-approved herbicides within ROWs on National Forest System lands in Arizona.

1.4 Public Involvement and Issues 1.4.1. Public Scoping Public scoping was held from January 6 to February 9, 2015. The Forest Service posted a scoping letter and related information on its website and also mailed over 1,700 scoping letters and postcards to individuals, public organizations, and agencies. Native American Tribes were also contacted by the Forest Service and letters were sent with information pertaining to the project. A total of 60 comment letters, emails, or telephone calls were received during the public scoping period. During the scoping period, comments were received regarding the Proposed Action and the use of herbicides on National Forest System lands. Comment disposition varied from supportive to opposing, and comments were organized and coded based on subject matter. Public comments pertained largely to

9 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests health and safety, impacts on the environment and wildlife, and aspects of the EA document. Federal and State agency comments pertained largely to coordination, monitoring, impacts, invasive species, mitigation, and buffers. While many issues were presented during the scoping process, not all identified issues warrant analysis in the EA. If an issue was determined to be non-substantive, then it was not carried forward in the National Environmental Policy Act (NEPA) analysis. Non-substantive comments were eliminated because they were out of the scope of analysis, did not state a cause-and-effect relationship with the Proposed Action or alternatives, or stated personal opinions. 1.4.2. Tribal Consultation The Forest Service in Arizona routinely consults with Native American Indian tribes that historically used, and may continue to use, National Forest System lands for traditional cultural purposes and that attach cultural and religious significance to locations on these lands. As the lead forest for Cultural Resources and Tribal Consultation, the Tonto National Forest has been engaged in consultation and communication with the tribes for the past several years regarding this project. As mentioned above, scoping began in 2015 and included 15 tribes and 7 Chapters of the Western Navajo Agency. Two additional tribes and one additional Chapter of the Western Navajo Agency were consulted in 2018. A full list tribes contacted and responses received is included in Section 3.16 Cultural Resources. 1.4.3. Key Issues from Public Scoping The following issues were identified as a result of the analysis of comments received during the scoping period: . Herbicide treatment could negatively affect vegetation and animals, including aquatic species. . Herbicide treatment could negatively affect water resources, as well as damaging surface water, such as springs and seeps. . Herbicide treatment could negatively affect human health. Details of the public scoping comment analysis are documented in the project record. The analyses of these issues and project objectives provide the basis of formulating alternatives that meet the purpose and need for the Proposed Action and for making a decision on the project (Forest Service Handbook [FSH] 1909.15, Chapter 10 – Environmental Analysis, Section 12.32–12.33).

1.5 Decision Framework The Forest Supervisors of the five forests have granted to the Tonto National Forest Deputy Forest Supervisor the authority to act as the sole Responsible Official for this EA and the subsequent decision document(s). The Deputy Forest Supervisor of the Tonto National Forest is the Responsible Official for deciding: . If significant environmental effects would result from implementing the proposed selected use of herbicides, which would require preparation of an Environmental Impact Statement (EIS); . What design criteria and monitoring requirements will be applied to the project; and . Whether the project requires a forest plan amendment for any of the impacted forests.

1.6 Relationships to Statutes, Regulations, and Other Plans 1.6.1. Forest Plan Direction Each forest manages public land through land and resource management plans, as required by the FLPMA. These plans outline management direction, including desired future conditions, suitable uses, monitoring requirements, goals and objectives, and standards and guidelines. The Proposed Action is in

10 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona conformance with the management decisions in the following land use plans and additional discussion is in Appendix A. . Land Management Plan for the Apache-Sitgreaves National Forests (August 2015a) . Coconino National Forest Plan (August 1987); a revised Forest Plan is anticipated for release in May 2018 . Land and Resource Management Plan for the Kaibab National Forest (February 2014) . Land and Resource Management Plan for the Prescott National Forest (June 2015) . Tonto National Forest Plan (October 1985) 1.6.2. Relation to Other Documents Regulations implementing NEPA provide for the reduction of bulk and redundancy (40 CFR 1502.21) through incorporation by reference and tiering when the effect will be to reduce the size of documents without impeding agency and public review of the action. While the Council on Environmental Quality (CEQ) regulations discuss tiering to programmatic EISs, CEQ also acknowledges that preparing a programmatic EA is appropriate to determine whether a broad proposed action requires an EIS. In such a case, subsequent EAs may tier to the broader, programmatic EA. This EA may be tiered to EISs or EAs of broader scope to eliminate repetitive discussions (FSH 1909.15, Chapter 10 – Environmental Analysis Section 11.41 - Tiering). Refer to Appendix B for a list of documents that are either incorporated by reference or used to tier from and form the basis for the conclusions related to human health and effects to non-target species. 1.6.3. Other Applicable Federal Laws, Regulations, and Policies Title V of FLPMA and its implementing regulations found at 36 CFR 251.51 Subpart B provide the legal framework within which the Forest Service manages public lands and assesses the effects of its management actions. Review and authorization of the use of herbicides is also subject to requirements for consistency and conformance with a number of other applicable Federal laws, regulations, and policies. A list of other Federal laws, regulations, and policies relevant to the Proposed Action have been included in Appendix C.

11 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

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12 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

CHAPTER 2. Alternatives

This chapter describes and compares the No Action Alternative and the Proposed Action as part of vegetation management within the permitted APS ROW crossing the five forests in Arizona (refer to Figure 1-2 through Figure 1-6).

2.1 Alternative A - No Action Alternative Alternative A - No Action Alternative (Alternative A) is APS’s current management for its IVM program. This program is a system of managing plant communities by identifying compatible and incompatible vegetation and evaluating, selecting, and implementing the most appropriate control methods to ensure the safe, reliable delivery of electricity to customers, meeting APS’s established objectives. The Arizona Public Service Company’s IVM approach/methodology is consistent with Part 7 of the American National Standards Institute (ANSI) A300 standards and includes: Set Objectives – such as promoting safety, preventing sustained outages caused by vegetation growing into electric facilities, maintaining regulatory compliance, protecting structures and security; Evaluate the Site – inspection of ROWs before, during and after vegetation management work to identify target incompatible vegetation that poses a risk or identify a situation that would not be consistent with the APS set objectives; Define Action Thresholds – level at which the method of control would be initiated; Evaluate and Select Control Methods – selecting the most appropriate vegetation control methods including manual and mechanical techniques; Implement IVM – removing and pruning incompatible vegetation under and around utility lines and infrastructure through careful and targeted manual and mechanical treatments; and Monitor Treatment and Quality Assurance – post-work monitoring of treatment effectiveness and quality. On National Forest System lands, the ROWs would continue to be inspected annually in order to plan, prioritize, and conduct utility vegetation management work, in compliance with NERC reliability standard (FAC-003-4). Alternative A would not include the full range of vegetation management tools typically associated with IVM but APS would implement the most appropriate control methods from the available tools. A description of Alternative A is provided below. 2.1.1. Inspections All ROWs would continue to be routinely inspected by APS, typically on an annual basis, to check the condition of the ROWs and status of vegetation. These inspections would be performed in two ways: 1) aerial inspection and 2) ground inspection. Aerial inspections completed by APS would include the use of helicopters to perform annual aerial inspections on most overhead transmission lines. ROWs inspected by air include those with known problem areas, lines that are remote and difficult to access, and distribution lines adjacent to a transmission line would typically be included in the annual aerial inspections. Aerial inspections would include flying over the ROWs, checking and recording vegetation conditions and regrowth, looking for potential problem areas, and assessing the effectiveness and quality of previous vegetation management projects. During inspection flights, the helicopter crew may hover or circle over areas to get a closer look at the vegetation, and although rare, may even occasionally land to allow personnel to ground inspect a specific location or concern.

13 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

In addition to the routine inspection flights, APS conducts flights for gathering aerial photography and Light Detection and Ranging (LiDAR) data along the transmission power lines. LiDAR collects valuable information regarding the vegetation along and adjacent to the power line ROWs. It provides precise data on power line structures and locations, models topography using elevation contours, and identifies vegetation encroachment. The data is evaluated and used for planning, identifying, and prioritizing vegetation and line maintenance work. The Arizona Public Service Company’s LiDAR flights occur as needed on the transmission system. Flights could occur during any time of year, but ideally are scheduled in the late spring or early fall timeframe when there are leaves on the trees and no snow on the ground. Prior to a LiDAR flight, a crew may place ground control Global Positioning System (GPS) devices and weather stations in the ROW in three locations for a line or close group of lines. The stations are portable and about 5 to 6 feet tall. They sit temporarily on the ground while the flight is conducted for that line, then taken off site once the flight is complete. The stations are placed along or adjacent to the side of established roads within the ROW. Ground inspections would typically be conducted during the scheduled maintenance cycle prior to any vegetation work to plan for the upcoming vegetation maintenance projects. Additional ground inspections may occur outside of this cycle where and when aerial patrols are not conducted, to check known problem areas, follow up with conditions identified during aerial inspection, or inspect areas of concern identified by the public or APS personnel. During ground inspections, one to three inspectors would access the area driving a four-wheel drive pickup truck or sport utility vehicle, all-terrain vehicles (ATVs; e.g., quad or six-wheeler), snow cat, or by walking. These vehicles would be used by APS staff where roads or trails are established. Many of the ROWs have existing roads and trails that meander in and out of the ROW. These roads and trails are often used to inspect the power line. Where no roads are present and where the terrain allows, vehicles may travel off-road within the ROW. Where access by pickup truck or sport utility vehicle is not feasible, ATVs would be used to access portions of the ROWs or areas where no established roads/trails are present, unless otherwise restricted by ROW permits or corridor management plans. When a power line is scheduled for maintenance, the ROW would be inspected to identify areas where work is needed for manual and/or mechanical treatments. Generally, inspections encompass the entire length of the power line and in some circumstances, it may be determined that no treatment is needed. Ground inspections would also occur during and following cyclical vegetation management work to refine and audit the work. These inspections would generally involve a portion or multiple portions of the power line but may not include the entire line. During inspections, conditions of vegetation would be recorded and when work is required, the pertinent information would be provided to the Forest Service in the form of a corridor management plan/work proposal. 2.1.2. Vegetation Types The type of vegetation removed during routine vegetation maintenance varies depending on multiple factors including, but not limited to: terrain, accessibility, density of vegetation, vegetation composition, rate of vegetation regrowth, and power line voltage. It is not possible to list all the numerous combinations of factors that go into the management of vegetation across the five forests. However, APS designs prescriptions for vegetation management collaboratively with each Forest to determine the best approach for each vegetation condition and location. Appendix D includes a list of dominant and predominant vegetation species within the biotic communities in Arizona identified as either compatible or incompatible with APS objectives for vegetation management. However, any cacti, yucca, and agave listed as incompatible would not be treated using herbicide application.

14 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

2.1.3. Incompatible Vegetation Management The Arizona Public Service Company classifies manual and mechanical incompatible vegetation management into three general categories: 1) routine vegetation maintenance, 2) defensible space around poles (DSAP), and 3) hazard vegetation maintenance. The majority of incompatible vegetation maintenance work on National Forest System lands falls under the routine vegetation maintenance category. Routine vegetation maintenance is the process of identifying and removing or pruning vegetation within a ROW that has undergone previous vegetation treatments. Typically this would involve employing manual and mechanical treatment methods (refer to Sections 2.1.4 Manual Vegetation Treatment Method and 2.1.5 Mechanical Vegetation Treatment Method below) on a set maintenance schedule, targeting new and/or regrowth since the last treatment. During routine vegetation maintenance, all woody vegetation (shrubs and trees) within a 10-foot radius around poles and 40-foot radius around transmission towers would also be trimmed to the ground level. The removal, or selective spacing, of all woody vegetation would reduce fuels and would provide easier access to the poles or towers. The treatment schedule, ranging from every three to six years, would depend on the maintenance needs for each ROW based on the routine inspections. Since 2008, APS has actively managed power line ROWs to low growing conditions using the tools that were available at the time (i.e., manual and mechanical methods as described in Section 2.1.4 Manual Vegetation Treatment Method and Section 2.1.5 Mechanical Vegetation Treatment Method below). Consistent, routine vegetation maintenance over the years has reduced the bulk of incompatible vegetation within the power line ROWs. As a result, future routine vegetation maintenance primarily addresses regrowth of vegetation that has already been cut and new growth of incompatible vegetation. DSAP maintenance is a part of the current vegetation management program to comply with the International Fire Code (International Code Council 2011, Section A102.3.1). The objective is to remove vegetation from around the poles to reduce the risk of fire ignition from spark-emitting electrical equipment and to reduce fuel loads and create a fire break around these poles to help protect them in the event of a wildland fire. The Arizona Public Service Company has an estimated total of 13,863 poles on National Forest System lands, of which approximately 1,418 poles include electrical equipment that could spark1, e.g., transformers, capacitor banks, and switches. These poles are generally located in the wildland-urban interface areas near residential development. Only about 10 percent of the poles on the APS system on National Forest System lands have equipment where this type of treatment is required2. The total treatment area within the DSAP maintenance program would be approximately 10.2 acres, equivalent to 0.08 percent of the APS ROWs on National Forest System lands. The treatment of the vegetation within the DSAP would consist of manually removing all vegetation using chainsaws, handsaws, and string trimmers within a 10-foot radius (20 feet in diameter) from the base of the pole extending the entire height of the pole. During routine vegetation maintenance, all woody vegetation (shrubs and trees) within a 10-foot radius around poles. All combustible debris would be manually removed to bare ground within the 10-foot radius cylinder using rakes or other hand held tools (refer to Photographs 2-1 and 2-2). All treatments would remain within the ROW. Treatments would typically occur every three years with a minimum of two individuals per crew conducting the maintenance activities at a pole location. Up to three 2-man crews would be deployed at a time.

1 Numbers of poles with equipment that can spark are estimated. Geographic Information System (GIS) analysis was used to obtain these numbers using a dataset with known distribution equipment. This data was then analyzed to identify the total number of poles that contain equipment that can spark. The numbers provided are estimated because the location of each pole in GIS is not always accurate. Some poles that appear to be on National Forest System land in GIS are actually on private land. The estimated number of poles that may receive DSAP treatment is 1,418, though this represents an overestimate of the actual number of poles on National Forest System land. 2 The percentage of poles that require vegetation removal to protect from the danger of fire ignition due to spark-emitting electrical equipment and to reduce fuels/provide a fuel break has been extrapolated from data about APS distribution poles.

15 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

(Source: Wade Ward, APS Fire Mitigation Specialist) Photograph 2-1. Defensible Space around a Wooden Utility Pole

(Source: Pacific Gas & Electric Company) Photograph 2-2. Defensible Space around a Wooden Utility Pole, Christopher Creek, AZ Hazard vegetation maintenance is the treatment of vegetation that could come into close proximity or contact with electrical lines, structures, or equipment and may cause an electrical fault. Vegetation can be considered hazardous if it exhibits characteristics3 that could increase the chances of it contacting utility infrastructure by falling on or growing into the power lines. Healthy vegetation may be considered a hazard if it has encroached close enough to an electric power line that it could result in electrical fault (ANSI 2011). Dead, dying, and diseased vegetation may also be a hazard if it has the potential to fail and fall on the power line or structures. Hazard vegetation has the potential for public safety or reliability risk. This category of incompatible vegetation can be identified in several ways, including scheduled aerial and ground inspections, during regular line or facility maintenance, or through customer call-in. Hazard vegetation can also be categorized as an Imminent Hazard or Off-Cycle Hazard. Imminent Hazards would need to be resolved immediately with treatment occurring shortly after the hazard is identified. An Off- Cycle Hazard is vegetation conditions that have the potential to become a public safety or reliability risk prior to the next cycle of routine maintenance. Off-Cycle Hazard vegetation treatments have some flexibility regarding the timing of the treatment to accommodate the breeding season of protected species if the hazard is deemed sound enough to hold for a period of time. Hazard vegetation may be removed at any time of year, typically by manual treatment techniques.

3 A feature, condition, or deformity of vegetation or vegetation parts that indicates a weak structure and contributes to the likelihood of failure (ANSI 2011).

16 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

The Arizona Public Service Company maintains records of the hazard vegetation treated each year. Data collected includes the number of trees removed along each power line, the species of tree, location (including, whether the tree was in or out of the ROW), size class, and if the tree was alive or dead. Since 2008, the ROWs have been maintained to current standards and treated on average 222 hazard trees per year between 2008 and 2017 (74 percent of the hazard vegetation treated was outside of the permitted ROW). 2.1.4. Manual Vegetation Treatment Method Manual vegetation treatment is the most common method of treatment performed on National Forest System lands and generally consists of hand tools, such as chain, pole, and hand saws; climbing harnesses; and ropes. Manual work crews most often consist of two to five individuals per crew, though more may be deployed on the larger work areas and wider ROWs. These crews are trained in vegetation line clearance, arboriculture techniques, and safety procedures and perform work in accordance with ANSI A300 Standards and best management practices (BMPs) using hand-held tools (refer to Photographs 2-3 and 2-4). Tall trees and other vegetation (such as pinyon pines) and smaller vegetation (such as shrubs and young trees) are cut from the ground by manual work crews. Tall trees at the edge of but outside the ROW may also be pruned when branches of the tree extend into the ROW. Crews may use a vehicle with an associated basket (bucket truck) and chippers to treat tall vegetation where access or vegetation maintenance agreements allow their use. Crews can also climb trees using standard safety equipment to prune or remove trees. Complex rigging arboriculture techniques may be used when tree felling could result in the vegetation striking the power line or infrastructure (e.g., wall, fence, power pole). Manual work crews operate during daylight hours at any time of year. Crews would not access the ROW during adverse weather conditions to avoid damage and rutting of roads and trails or where environmental restrictions apply, except during emergency situations. All vegetation cut would be left onsite in the ROW unless otherwise dictated under special circumstances (refer to Section 2.1.6 Vegetation Disposal Methods below for more detail).

(Source: Rich Fertilizer 2016) Photograph 2-3. Example of Manual Treatment by Polesaw

17 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

(Source: Arb Access LTD 2015) Photograph 2-4. Example of Manual Treatment by Handsaw 2.1.5. Mechanical Vegetation Treatment Method Mechanical vegetation treatment method is used less than five percent of the time on National Forest System lands and generally would consist of rotary- and drum-style cutting devices (mowers and brushcutters) mounted on a vehicle such as a tractor, skid steer, or excavator with rubber tires or tracks (refer to Photographs 2-5 and 2-6). A mechanical work crew would minimally consist of an equipment operator and a grounds person to direct the driver. Other work crew members may follow the mechanical equipment to clean up, scatter debris, and prune or remove trees that the mechanical equipment could not access. All vegetation is cut into large mulch-like pieces and would be left onsite in the ROW. Mechanical vegetation treatment methods may be used at any time of year except during environmental restrictions or inclement weather conditions. Mechanical methods may not be feasible in specific areas based on terrain, presence of environmentally sensitive sites, or access; vegetation treatments would then be conducted using manual clearance methods as discussed in Section 2.1.4 Manual Vegetation Treatment Method above.

(Source: courtesy of Salt River Project) Photograph 2-5. Example of Mechanical Treatment by Slashbuster

18 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

(Source: Mike Wasgatt, Phillips and Jordan) Photograph 2-6. Example of Mechanical Treatment by John Deere 200LC with Shinn Cutter Head 2.1.6. Vegetation Disposal Methods Once vegetation is cut by either manual or mechanical means, various disposal methods could be employed. The overall objective of vegetation disposal is to distribute the cut/chipped material in a cost- effective and environmentally sensitive manner. The disposal would minimize potential impacts to sensitive environmental resources while mitigating fire risk within ROWs. The method of disposal would be determined through coordination between the Forest Service and APS prior to the commencement of vegetation maintenance work, as described in the corridor management plan in accordance with the Utility Vegetation Management Guidelines (Forest Service 2013a). During manual treatments, vegetation disposal would generally be by lop and scatter4 or chipping5, though other methods may be employed following coordination with the Forest Service. These types of vegetation disposal would generally be used in most areas within the national forests, especially in remote areas away from busy roads and campgrounds. Logs would generally not be hauled off site by APS. The Forest Service has occasionally asked APS to cut logs into firewood lengths and pile for public use when work would occur near campgrounds or busy roads. In addition, the Forest Service has occasionally asked APS to pile slash off of the ROW to be burned at a future date by the Forest Service. 2.1.7. Corridor Management Plan Vegetation maintenance standards for a particular line are established through an agreement between the Forest Service and APS in the corridor management plan for a particular line. The processes by which these maintenance standards are set are described in the Utility Vegetation Management Guidelines that was signed by APS (Forest Service 2006; Forest Service 2013a). Under this process, the Forest Service reviews the ROW permit, industry standards for minimum clearance, species considerations, and other Forest Service resource considerations (implementation of appropriate conservation and avoidance measures). Factors affecting vegetation maintenance standards vary among power line segments depending on power line configurations and voltages. Therefore, a corridor management plan is developed, incorporating the appropriate conservation measures for the particular line segment or ROW.

4 Limbs and logs of less than 9 inches in diameter would be lopped and scattered throughout the immediate area in a manner such that limbs and logs would be left no taller than 18 to 24 inches above the ground. Logs over 9 inches diameter would remain where felled and would be cut in sections to lay flush with the ground. 5 Limbs and logs less than 9 inches in diameter would be chipped and broadcast on site with chips placed no deeper than 4 inches.

19 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Prior to the completion of routine vegetation maintenance work on a ROW, APS would prepare a corridor management plan to the forest that outlines the general description of work to be completed, operational procedures, training and communication and includes any necessary specialist reports. The operational procedures includes the vegetation clearing prescription, treatment methods, disposal methods, access routes, fire prevention, and hazard vegetation description. Routine vegetation maintenance is constrained by the terms and conditions of the ROW permit, which is granted to APS by the Forest Service. At times, the maintenance requirements for a line may be wider than the permitted ROW. If necessary, permits could be expanded to allow for proper clearance widths. Most vegetation maintenance occurring within the permitted ROW consists of minor trimming, pruning, and removal of vegetation and is authorized under the terms of the ROW permit. Upon reviewing the corridor management plan and finding no environmental issues of concern, the Forest Service then proceeds to acknowledge that there is no additional environmental analysis required and concurs with the proposal as submitted. If in the alternative there are issues that must be addressed, the Forest Service would request revisions prior to the Forest Supervisor approval. In the case of certain hazardous conditions, APS first contacts the Forest Service by phone or email if possible. Details of the hazard vegetation, along with a map, are provided and include the following: 1) power line number on which the hazard was found; 2) GPS location of the hazard; 3) plant species; 4) size of vegetation (diameter at breast height for trees or linear height for saguaros); 5) and condition of vegetation (e.g., dead, diseased, heavily leaning). Once details of the hazard are received, Forest Service determines if onsite monitoring is needed. The work is then completed with follow-up correspondence documenting the situation. 2.1.8. Alternative A Design Features Besides the general procedures and methods described above and project specific requirements as outlined in the corridor management plans, APS implements the following design features when performing vegetation management activities: . Within the ROW, ATVs and vehicles may drive off-road if necessary with the implementation of relevant design features below. o ATVs and vehicles would be used only during dry conditions to avoid rutting, except under hazard vegetation maintenance situations. o ATVs and vehicles would avoid driving through rivers, standing water, and other water sources where water levels are above gear boxes except on established roads. o ATVs and vehicles would be driven at low speeds (less than 10 miles per hour) when traveling off-road within the ROW. o ATVs and vehicles would only be operated during daylight hours, except under hazard vegetation maintenance situations. o ATVs and vehicles would avoid driving directly up slopes and other areas that may contain highly erodible soils. o ATVs and vehicles would not drive on slopes greater than 20 percent when traveling off established roads. . Stumps from tree removal would be cut within 6 inches of the ground or if possible stumps would be cut flush with the ground. . During manual vegetation treatment, and as determined in the Corridor Management Plan (CMP), the following methods of disposal would be used: o Lop and scatter inside the ROW: Limbs and logs of less than 9 inches in diameter would be lopped and scattered throughout the immediate area in a manner such that limbs and logs would be left no taller than 18-24 inches above the ground. Logs over 9 inches diameter

20 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

would remain where felled and would be cut in sections to lay flush with the ground with the exception of access roads. These logs would be left at full lengths as much as possible while lying as flat to the ground as possible. Logs would not be dropped and laid across each other (i.e. jack-strawed). o Lop and scatter outside of ROW: This method would be used in areas of resource concerns on the National Forest System lands in a designated area. Limbs and logs of less than 9 inches diameter are lopped and scattered immediately outside of the ROW in a manner such that limbs and logs are cut down in pieces no taller than 18-24 inches from the ground. Logs over 9 inches in diameter would be cut and disposed of as described above for logs inside the ROW. o Chipping: Slash would be chipped and broadcast where resource concerns and conditions require it and if road access would allow for a chipper. Limbs and logs less than 9 inches in diameter would be chipped. Small chips produced during vegetation treatments would be broadcast across the ROW at a thickness no greater than 4 inches. o Lop limbs and leave trunk whole: This method would be used where timber may have a merchantable value or where leaving the trunk whole may provide erosion stabilization or species habitat. Limbs are lopped off of the trunk and disposed of according to the design features noted above. The felled tree trunk would be left whole on site, but not dropped and laid across other logs (i.e., jack-strawed). . Consider site characteristics, environmental conditions, and equipment in order to minimize damage to non-target vegetation. . All areas with the potential for flowing water (e.g., culverts, ditches, and washes) would be kept free of slash, logs, and debris from vegetation removal operations. . Do not operate a mechanical mower within riparian vegetation. Riparian vegetation shall be removed or pruned using manual methods. . Prior to mechanical vegetation treatment, sites will be identified that are eligible or unevaluated for the National Register of Historic Places (National Register). Salient features would be avoided by heavy equipment with a 50-foot buffer. Historic linear sites such as roads, trails, and railroads would not require avoidance. Vegetation maintenance within avoidance areas would be performed by hand-crews with chainsaws. . When working in riparian areas, wetlands, and near other aquatic habitats, access work site only on existing roads, and limit all travel on roads when damage to the road surface would result or is occurring. . Equipment staging areas and refueling areas should be located a minimum of 100 feet away from riparian areas and wetlands, where feasible and within areas of low gradients (less than 15 percent). . A qualified biologist or resource specialist, as determined by the Forest Service, would provide maintenance crew members with training on migratory bird nest reporting and nest avoidance: crews are to report active nests that occur on vegetation or on the ground internally per each Utilities’ avian reporting procedures. Do not conduct routine vegetation maintenance and DSAP treatments on the vegetation containing the nest and vegetation adjacent to ground nesting birds until after nesting is complete. . Do not cut Ertter’s rose, a sensitive plant occurring on the Coconino National Forest, during vegetation maintenance on the SE 14 power line in the vicinity of the West Fork Oak Creek confluence with Oak Creek in Oak Creek Canyon.

21 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

. To protect sensitive plants as much as possible, APS will coordinate with Forest biologists and/or botanists in identifying known populations of sensitive plants prior to manual and mechanical treatment. This may be done by providing work crews generalized or specific location information of the plant and photos and identification information of the plant for avoidance. . Arizona Public Service Company shall coordinate with Arizona Game and Fish Department (AGFD) annually to obtain updated bald and golden eagle nest locations. As part of this annual coordination, seek guidance from Arizona Game and Fish to determine any specific breeding areas that are likely to be active before or after the breading seasons for bald and golden eagles. . Do not conduct manual and mechanical vegetation treatments within 1 mile of the line of site of an active golden eagle nest during the golden eagle breeding season from February 1 to July 15. . Do not conduct manual and mechanical vegetation treatments within ¼ mile of an active bald eagle nest during the bald eagle breeding season from December 1 to June 30. . Within northern goshawk PFAs, drive ATVs only on existing publically accessible roads during the breeding season from March 1 to September 30. . Do not conduct manual and mechanical vegetation treatments within a northern goshawk PFA from March 1 to September 30 except under hazard and emergency conditions. If occupancy is unknown, assume the nest is active. If it is confirmed that there is no nesting, work may proceed. . Do not conduct manual and mechanical vegetation treatments within ¼ mile of an active peregrine falcon breeding area from March 15 to August 15 except under hazard and emergency conditions. If occupancy is unknown, assume the nest is active. If it is confirmed that there is no nesting, work may proceed. . When working in suitable habitat for Sonoran desert tortoise, train crews to look for tortoise around the vehicles and work site. If Sonoran desert tortoise are found, either delay work activities until the tortoise has moved away from the work area, or if work cannot be delayed follow the Arizona Game and Fish Handling Guidelines. . Arizona Public Service Company will coordinate with the Apache-Sitgreaves and Coconino National Forests so that the Forests can review the proposed work and determine if there are any Bebb’s willow that could be impacted by vegetation management work on lines within habitat for this species. APS may prune or remove Bebb’s willow using chainsaw and hand tools if necessary for safe operation of the power lines after coordinating the need for this work with the Forest. . Arizona Public Service Company will work cooperatively with the Forest Service during the CMP review to address preventing the spread of existing invasive and noxious plant species within the ROWs. Refer to Conservation Measures found in Appendix E for additional measures to minimize spread of noxious and invasive plant species. . Refer to complete list of Biological Resources Conservation Measures in Appendix E.

2.2 Alternative B - Proposed Action Alternative B - Proposed Action (Alternative B) consists of using selected, Forest Service-approved herbicides on incompatible vegetation within ROWs on National Forest System lands as part of the APS IVM program. The Arizona Public Service Company would continue using manual and mechanical methods as described in Alternative A, such as mowing or hand cutting, in combination with herbicide treatments. Control of incompatible vegetation through the judicious use of herbicides following manual and mechanical vegetation treatment would assist in the establishment of low-growing, compatible vegetation within the ROW.

22 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

These herbicides are not currently approved on all national forests included in this project area as some herbicides are only approved on a specific forest(s). However, all herbicides in Table 2.2-1 are proposed for use on all national forests in the APS ROW as part of Alternative B. This EA includes analysis for these herbicides to obtain authorization on Forests where not previous authorized. Several manufacturers offer multiple products under various trade names that include the same active ingredients listed in Table 2.2-1. Table 2.2-2 identifies the active ingredient, trade name, typical application technique, and a brief description. The risk assessments developed by the Forest Service apply to these active ingredients. Herbicide treatments would follow the Forest Service Manual (FSM) 2100 - Environmental Management; FSH 2109.14 - Pesticide Use Management and Coordination Handbook; and FSH 2509.22 Chapter 20, Section 21 - Pesticide Use Management and Coordination. Herbicides would be applied according to product label directions, which are reviewed and approved by the Forest Service. Generic herbicides with the same chemical properties under a different name could be used; therefore, the products or trade names listed in Table 2.2-1 are examples. Herbicides are categorized as selective or non-selective6 where selective herbicides kill only a specific type of plant and non-selective herbicides kill all types of plants. The selectivity category of the herbicides in Alternative B is provided in the use descriptions in Table 2.2-2.

Table 2.2-1. Forest Service-Approved Herbicides List Proposed for Use

Trade Name Active Ingredient (i.e., Example Commercial Formulations) Aminocyclopyrachlor Method Aminopyralid Milestone Chlorsulfuron Telar Clopyralid Transline and Reclaim 2,4-D 2,4-D Dicamba Vanquish Fluroxypyr Vista Glyphosate Roundup, Rodeo, Accord Imazapic Plateau Imazapyr Arsenal and Habitat Isoxaben Gallery Metsulfuron methyl Escort Picloram Tordon Sulfometuron methyl Oust Tebuthiuron Spike Triclopyr Garlon and Pathfinder With the current manual/mechanical treatment techniques, the root systems of some individual plants are relatively unaffected after the removal of the aboveground portion of the stem. The plant’s natural survival response is to resprout stems to reestablish enough leaves to support the root system. The rapid resprouting and increase in stem count ultimately allows the plant to support a larger root mass. Root- suckering species, such as Mexican black locust (Robinia neomexicana); African sumac (Rhus lancea);

6 For example, a selective herbicide for broadleaved plants can be used to manage such species while also maintaining compatible grass species in rangeland communities. Herbicides can be used selectively to control specific types of vegetation (e.g., killing invasive weeds), or non-selectively to clear all vegetation on a particular area. Some herbicides are post-emergent, which means they can be used to kill existing vegetation; others are pre-emergent, which stops vegetation before it grows (e.g., prohibiting seeds from germinating).

23 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

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24 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Table 2.2-2. Forest Service-Approved Herbicides List with Vegetation Treatment Application and Use Descriptions Herbicide Active Anticipated Foliar Cut Stump Basal DSAP Ingredient/ Trade Use Herbicide Use Description b application application application application Name Frequency a Selective herbicide used for control of broadleaf Aminocyclopyrachlor/ ● ● ● ● rare weeds, woody species, vines, and grasses; pre- Method and post-emergent control. Selective herbicide used for control of broadleaf Aminopyralid/ Milestone ● ● ● ● frequent weeds. Selective herbicide that controls select broadleaf Chlorsulfuron/ Telar ● ● rare weeds and incompatible grasses; pre- and post- emergent noxious and nuisance weed control. Clopyralid/ Transline and Selective herbicide used for control of broadleaf ● ● ● rare Reclaim weeds, thistles, and clovers. Selective herbicide that controls woody brush and 2,4-D ● ● ● ● rare broadleaf weeds. Selective herbicide that controls select broadleaf Dicamba/ Vanquish ● ● ● ● rare weeds. Selective herbicide that controls broadleaf weeds Fluroxypyr/ Vista ● ● rare and woody brush. Glyphosate/ Roundup, Broad spectrum (non-selective) control and has an ● ● ● ● frequent Rodeo aquatic label. Selective herbicide for both the pre and post- Imazapic/ Plateau ● ● rare emergent control of some annual and perennial grasses and some broadleaf weeds. Broad spectrum (non-selective) herbicide for control of a range of weeds including annual and Imazapyr/ Arsenal and ● ● ● ● moderate perennial grasses, broad-leaved, woody species, Habitat and riparian and emergent aquatic species. Often used for control of invasive species. Broad spectrum (non-selective) control of Isoxaben/ Gallery ● rare broadleaf weeds; pre-emergence and soil-acting herbicide.

25 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Herbicide Active Anticipated Foliar Cut Stump Basal DSAP Ingredient/ Trade Use Herbicide Use Description b application application application application Name Frequency a Selective herbicide used to control noxious weeds, Metsulfuron methyl/ ● ● frequent brush and problem broadleaves with excellent Escort grass tolerance. Selective herbicide used for general woody plant control; it also controls a wide range of broad- Picloram/ Tordon ● ● rare leaved and invasive weeds; most grasses are resistant. Non-selective herbicide used to control a wide Sulfometuron methyl/ ● ● rare range of annual and perennial grasses as well as Oust broad-leafed weeds. Non-selective herbicide used for control of broadleaf and woody weeds, grasses and brush; Tebuthiuron/ Spike ● rare requires rainfall for incorporation into the soil for root uptake. Triclopyr/ Garlon and Selective herbicide used to control broadleaf ● ● ● ● frequent Pathfinder weeds and woody vegetation. a Anticipated use frequency is based on current use and knowledge of herbicide products by APS. b Herbicide Use Description was populated from the herbicide product label and use and knowledge of herbicide products by APS.

26 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Russian olive (Elaeagnus angustifolia); and saltcedar (Tamarix ramosissima), respond to cutting by producing “suckers” (vertical shoots) from both the stump and the extensive root system of the established plant. The density of incompatible vegetation can increase by up to 35 percent when manual and mechanical treatment methods are employed without a follow-up herbicide treatment (Carroll Electric Cooperative 2010). A continuous cutting regimen stimulates growth that requires more cutting, which, in turn, increases vegetation treatment costs over time (Johnstone 2008). As described in Alternative A, the majority of APS vegetation maintenance efforts are attributed to the continual resprouting of incompatible vegetation following routine manual and mechanical treatments. To prevent plant species from resprouting, either the root crown or the entire root system must be removed. Herbicides control plants by interfering with specific botanical biochemical pathways. Herbicides are chemicals that are derived from plants or manufactured synthetically and used to damage or kill plants. Herbicides are categorized by their mode of action, i.e., the sequence of events from absorption into the plant to plant death (Penn State College of Agricultural Sciences 2017). Herbicides may affect plants in multiple ways. Mode-of-action categories include growth regulators and root and shoot inhibitors, in addition to other mechanisms that interfere with plant metabolism (Bussan and Dyer 1999). Herbicides must be applied by someone with the appropriate license identified in State laws. The Forest Service-approved herbicides that would be used in Alternative B would be applied according to the current label directions. Accessibility to the treatment site would be in accordance with the product label. The Arizona Public Service Company would comply with changes in label directions that may occur in the future and would comply with State registration requirements. Similar to Alternative A, in Alternative B the APS IVM program would include the following approach/methodology: 1) Set Objectives; 2) Evaluate the Site; 3) Define Action Thresholds; 4) Evaluate and Select Control Methods—selecting the appropriate vegetation control methods including manual, mechanical, herbicide, and/or a combination of these application techniques; 5) Implement IVM— removing and pruning incompatible vegetation under and around utility lines and infrastructure through careful and targeted manual, mechanical, herbicide, and/or a combination of these application techniques; and 6) Monitor Treatment and Quality Assurance—post-work monitoring of treatment effectiveness and quality. A description of Alternative B is provided in Sections 2.2.1 through 2.2.11 below. Where Alternative B is different than Alternative A, the difference is identified in the applicable section below. 2.2.1. Inspections The inspection methodology in Alternative B would be the same as described in Alternative A (refer to Section 2.1.1 Inspections above), and would be conducted by air or on the ground prior to, during, and after vegetation management work. The objectives of the inspections would be as follows and include consideration for herbicide treatments: . Identify hazard vegetation. . Identify and plan upcoming manual, mechanical, and herbicide maintenance work. . Audit work during and after manual, mechanical, and herbicide treatments. . Assess effectiveness and quality of vegetation management practices. . Identify areas for vegetation management for future cycles of work.

2.2.2. Vegetation Types The type of vegetation targeted for herbicide treatment with Alternative B would be the same as Alternative A outlined in Section 2.1.2 and listed in Appendix D. As discussed in Section 2.1.7, APS would work collaboratively with each Forest to determine the best approach for each vegetation condition and location.

27 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

2.2.3. Incompatible Vegetation Management In Alternative B, APS would continue to manage vegetation similar to Alternative A. Vegetation management is still considered in three general categories: 1) routine vegetation maintenance; 2) DSAP; and 3) hazard vegetation maintenance. Under Alternative B, all three would include the use of herbicide treatments in conjunction with manual and mechanical treatment methods. Routine vegetation maintenance using manual and mechanical methods would continue under Alternative B, similar to Alternative A, every three to six years. The addition of herbicides under Alternative B is anticipated to reduce the amount of vegetation requiring treatment during future routine vegetation maintenance cycles7. Since the vegetation types and treatments vary across the five forests and APS corridors, the amount of herbicides used would vary from year to year but would be identified in the specific Pesticide Use Proposal (PUP) prepared prior to yearly treatments for each forest. Over a period of six years all of the APS corridors would be evaluated for treatment needs including herbicide use. Alternative B would include evaluating and potentially treating approximately 13,500 acres over the six-year routine vegetation maintenance period. Photographs 2-7, 2-8, and 2-9 show examples of the incompatible vegetation that APS would target and treat with herbicide during the routine vegetation maintenance cycle. Select vegetation would be spot-treated using low volume handheld spray nozzles (refer to Section 2.2.6), no broadcast or aerial spraying would occur. These photographs demonstrate that the spot application of herbicide would only occur within a portion of the ROW. DSAP maintenance cycles in Alternative B would remain the same as the current activities and also include the use of herbicides for pre-emergent and cut-stump treatments to keep vegetation from growing inside the prescribed combustible-free area. Hazard vegetation within the ROWs would be continually maintained as part of the APS IVM program goals in Alternative B as it would be in Alternative A. 2.2.4. Manual Vegetation Treatment Method The manual vegetation treatment methods in Alternative B would be the same as described in Alternative A (refer to Section 2.1.4 Manual Vegetation Treatment Method). Under Alternative B, the frequency and intensity of these treatment methods would be reduced as described above in Section 2.2.3 Incompatible Vegetation Management. 2.2.5. Mechanical Vegetation Treatment Method The mechanical vegetation treatment methods in Alternative B would be the same as described in Alternative A (refer to Section 2.1.5 Mechanical Vegetation Treatment Method). Under Alternative B, the frequency and intensity of these treatment methods would be reduced as described in Section 2.2.3 Incompatible Vegetation Management.

7 Manual, mechanical, and herbicide routine vegetation maintenance under Alternative B would occur over three growing seasons. For example, a power line with a five-year vegetation maintenance cycle would be treated over three years. During year one, the power line would be evaluated and incompatible vegetation would be removed using manual and mechanical methods. Approximately 20 percent of this vegetation would also be treated with herbicides using cut-stump or basal methods during year one to reduce resprouting. In year two, incompatible seedling and resprouted vegetation that has grown since year one would be foliar treated with herbicides. The amount of vegetation to be treated in year two is anticipated to be approximately 80 percent of the incompatible vegetation treated in year one depending on the vegetation type. Year three would include a follow-up spot herbicide treatment of approximately 20 percent of the vegetation treated year two, if necessary. This cycle would repeat starting in year six with targeted manual/mechanical and herbicide treatments. Treatments starting in year six are anticipated to be approximately 10 percent of the amount of vegetation treated in year one.

28 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

(Source: Tracy Moore, APS) Photograph 2-7. Example of Incompatible Brush to Target for Herbicide Treatment

(Source: Christina Cloer, APS) Photograph 2-8. Example of Incompatible Pine Seedling to Target for Herbicide Treatment

29 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

(Source: Christina Cloer, APS) Photograph 2-9. Example of Incompatible Gambel Oak to Target for Herbicide Treatment 2.2.6. Herbicide Vegetation Treatment Methods With the implementation of Alternative B, the incompatible vegetation would typically first be removed by manual and/or mechanical treatments, as outlined in Alternative A. Herbicides would be used in conjunction with manual and mechanical treatments during the routine vegetation maintenance cycle and/or in subsequent years to treat regrowth and seedlings. Herbicide treatments, in some situations, would be used on vegetation that may not have had, or required, manual or mechanical treatments previously. Herbicides would be applied in selected locations using handheld sprayers from backpacks or spray units mounted on ATVs (refer to Photograph 2-10 and Photograph 2-11) for accurate spot treatment. The Arizona Public Service Company would apply the selected herbicide ingredients listed in Table 2.2-2. The adjuvant8 Thinvert®, which is a paraffinic (waxy) oil carrier, would be used with the majority of herbicide treatments on National Forest System lands, although an oil-based carrier may also be used in place of Thinvert. Applications using Thinvert are considered low-volume applications (Waldrum Specialties 2002). Applications using Thinvert are considered low-volume applications (Waldrum Specialties 2002). The application is made using a special nozzle that produces small uniform droplets coated with a thin film of oil which does not evaporate while falling through the air to the spray target. The thin invert emulsion reduces the number of small droplets formed and droplets do not readily break up into finer droplets as water droplets do, thereby minimizing drift and drip (Waldrum Specialties 2002).

8 An adjuvant is any substance in an herbicide formulation or added to the spray tank to improve herbicidal activity or application characteristics.

30 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

(Source: APS 2016) Photograph 2-10. ATV with Mounted Tanks and Low-Volume Hand Wand

(Source: Ron Romero, Southwest Ground Control) Photograph 2-11. Low-Volume Backpack Sprayer Due to the proprietary nature of herbicide formulations, the understanding of risk from inerts and adjuvants is limited and manufacturers are not required to disclose the identity of compounds in which the U.S. Environmental Protection Agency (EPA) has not classified as hazardous (Forest Service 2005a). Thinvert is included on the List of Approved Herbicide Formulations and Adjuvants for Forest Service. Because Thinvert and other oil-based carriers are not regulated or regarded in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), this EA will focus on the active ingredients and not the adjuvants, therefore no detailed analysis has been included. Additional information regarding adjuvants and Thinvert can be found in Appendix F.

31 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

The ratio of Thinvert (carrier) to herbicide would vary, as determined by APS and by the species of vegetation to be controlled, and would follow label requirements. Herbicide application would be targeted and overspray or drip would be limited by the addition of Thinvert as a carrier. Depending on the herbicides included in the custom blend, the ratio would be 90 to 94 percent Thinvert to 6 to 10 percent herbicide per gallon (refer to Table 2.2-2); this is equivalent to between 115 and 120 ounces of Thinvert and between 8 to 13 ounces of herbicide per gallon. A rate of 3 to 5 gallons of total mix per acre would result in approximately 24 to 39 ounces of herbicide being applied to one acre of vegetation. An acre of spot herbicide treatments could span several miles of a ROW, depending on ROW width and vegetation density. No aerial or broadcast application of herbicides would occur under Alternative B. After completion of the manual and mechanical vegetation removal, APS could employ four different herbicide application methods: foliar, cut stump, basal, and pre-emergence. The first three techniques are spot treatments that target specific vegetation, rather than broadcast treatments applied throughout the entire ROW. The last, pre-emergence, is where herbicide is applied directly to the soil to prevent germination and is limited to being used only where the DSAP exists. As previously noted, no broadcast or aerial spraying would occur as part of Alternative B. Below is a description of the application methods. Foliar application method would direct the herbicide mixture onto the leaves of the target vegetation, which would be most effective on smaller vegetation, between 1 and 5 feet tall and would be used on vegetation up to 10 feet tall (depicted in Photograph 2-12). The frequency of foliar treatments would depend on the amount and size of incompatible vegetation and regrowth. An initial treatment would typically occur one to two growing seasons after manual/mechanical treatments, and a second treatment would occur one to two growing seasons after the initial herbicide application. Routine herbicide treatments are anticipated to occur cyclically every three to six years, as identified through ROW inspections. In Alternative B, foliar application would be the preferred technique when treating most ROW vegetation and is anticipated to constitute 75 to 80 percent of all herbicide applications on National Forest System lands.

(Source: Ron Romero, Southwest Ground Control) Photograph 2-12. Foliar Application of Herbicides Using a Low-Volume Backpack Sprayer

32 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Cut-stump application treatment would be used on the stumps of woody species that normally resprout after being cut. This application would be conducted in conjunction with manual and mechanical vegetation removal. Because of the way it works on the tree’s metabolism, cut-stump treatment is most successful when applied immediately after the trunk is cut (typically within 15 minutes to an hour). Herbicides would be applied on the exposed cambium (living inner bark) of the stump and on exposed roots (depicted in Photograph 2-13). This treatment relies on translocation (movement of the herbicide within the plant) to the root system through the inner bark. Outer bark and heartwood would not be treated because these are not living tissue.

(Source: John Gauthier, APS, Phoenix, AZ) Photograph 2-13. Cut-Stump Technique Cut-stump treatments would also occur in conjunction with hazard tree removal. For species that resprout, this application technique would be made concurrent with any manual/mechanical vegetation treatment. The frequency of this application technique would be consistent with manual/mechanical treatments (refer to routine vegetation maintenance described in Section 2.2.3 Incompatible Vegetation Management). This application method is anticipated to constitute 15 to 20 percent of all ROW herbicide application in Alternative B. Basal application method would be applied directly to the lower 12 to 18 inches of the bark of the trunk (along all sides) of a standing tree, encircling stems, and root collars (depicted in Photograph 2-14). This application would be most effective on trees less than 6 inches in diameter with smooth bark (U.S. Department of Agriculture University of Florida 2015). The oil carrier penetrates the bark, carrying the herbicide into the plant. Basal applications can be made any time of the year but would be most effective during the growing season when plants are actively transporting nutrients into the roots. This method may be used where vegetation is too tall to effectively use foliar application methods or when an incompatible plant is adjacent to, or surrounded by, compatible vegetation.

33 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

(Source: BASF Corporation) Photograph 2-14. Basal Application The basal application method would rarely be used as part of routine vegetation management and is anticipated to constitute less than five percent of all ROW herbicide applications in Alternative B. Pre-emergence application method would be used only within the prescribed DSAP. About 10 percent of the DSAP would use a soil or pre-emergent9 herbicide to keep vegetation from growing around poles housing electrical equipment. Within the 10-foot radius of these poles, applicators would apply herbicide directly to the soil using a hand held sprayer. Herbicides specifically labeled for soil applications would be used to prevent the germination of seeds, extending the length of vegetation control achieved through manual clearing methods. Pre-emergent herbicides are generally applied when there is predictable rainfall within 30 to 60 days of application, in order to minimize the potential for photodegradation of the herbicide before it has had a chance of moving into the germination zone of the soil. The frequency of pre-emergence application treatments would depend on the DSAP maintenance cycle, soil type, time of the year, and amount and type of incompatible vegetation. The current DSAP program is on a three year cycle, and pre-emergent herbicides would improve vegetation control during a portion of the first year after treatment10. 2.2.7. Vegetation Disposal Methods The vegetation disposal methods in Alternative B would be the same as described in Alternative A (refer to Section 2.1.6 Vegetation Disposal Methods). Under Alternative B, less vegetation would require disposal. 2.2.8. Corridor Management Plan The corridor management plan in Alternative B would be the same as described in Alternative A (refer to Section 2.1.6) with the addition of a PUP for herbicide treatments as described in Section 2.2.9 Pesticide Use Proposal.

9 Pre-emergent refers to an application of herbicide applied to the soil before vegetation begins to sprout or before seeds begin to germinate. The herbicide is formulated to eliminate the vegetation in the germination process. 10 The total treatment area within the DSAP maintenance program would be approximately 10.2 acres, equivalent to 0.08 percent of the APS ROWs on National Forest System lands.

34 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

2.2.9. Pesticide Use Proposal As part of Alternative B, when APS plans to use herbicide treatments within the ROW, they would submit a PUP (FS 2100-2 form) to the Forest Supervisor of the National forest where the treatment is to take place. The Forest’s Invasive Species program lead would also receive the submitted PUP. The PUP would detail the location and herbicides proposed for use in the annual treatment plans and maintenance projects submitted to the Forest Service. Each PUP would include information on project specifications; herbicides proposed for use and the rate of application; surfactants; approximate dates of application; incompatible species targeted; key personnel responsibilities; appropriate resource site-specific buffers (e.g., as provided in biological conservation measures or herbicide manufacturers’ labels); and procedures for communication, safety, spill response, and emergencies. The analysis included in this EA would provide support for future PUPs and site-specific applications. The Forest Service Invasive and Noxious Weeds Program Lead is responsible for reviewing the PUP and the Forest Service Supervisor or the line officer is responsible for its approval. The Forest Service would approve a PUP once it has been determined to be adequate; after which APS could then begin herbicide treatments within the specified ROW. 2.2.10. Adaptive Management Adaptive management and managerial flexibility are tools that allow decision-makers to take advantage of new information that becomes available after a decision has been made. An adaptive management strategy is the process of evaluating and making adjustments if the prescribed management fails to result in desired outcome or as new circumstances arise. It is possible that new or improved herbicide products could become available during implementation of Alternative B. If new or improved products are made available, the new herbicide product could be considered for use without further NEPA analysis. This would be the case only if the new or improved product/technique fits within the same effects-analysis disclosure in this EA. An analysis would be done to determine the similarities of effects and whether the decision would be adapted to include that herbicide product. Other herbicide active ingredients may be used in the future, after they are evaluated and approved by Forest Service. According to the FSH 1909.15 - NEPA Handbook, Section 18, “If new information or changed circumstances relating to the environmental impacts of a proposed action come to the attention of the Responsible Official after a decision has been made and prior to completion of the approved program or project, the responsible official should review the information carefully to determine its importance. Consideration should be given to whether or not the new information or changed circumstances are within the scope and range of effects considered in the original analysis.” To accomplish this, the review consists of two parts: 1. Identification of new information or changed circumstances that are relevant to the decision. 2. If new information exists, a determination of whether the effects fall within the range and scope of effects disclosed in the previous environmental analysis for the proposed area or forest. For the purpose of adding an herbicide under the adaptive management strategy “new herbicides may become available that are better suited to an application than those approved in the decision.” (FSH 1909.15 Chapter 10, Section 18) (Forest Service 2005a). If prescribed management fails to result in desired outcome, alternative strategies will be developed, and management will be adapted until the desired conditions are achieved. New alternative strategies will be reviewed on a site-specific and case- by-case basis. If it is demonstrated through analysis that the environmental impacts of a new approach falls outside the impacts as disclosed in this document, then additional environmental analysis will be undertaken under NEPA.

35 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

2.2.11. Alternative B Design Features In addition to the design features listed below, Alternative B would include the design features listed for Alternative A (refer to Section 2.1.8 Alternative A Design Features). Conservation measures identified in the Vegetation Management and Line Maintenance in APS Power Line Rights-of-Way on Arizona Forests, Working Draft Biological Assessment for Threatened and Endangered Species (2018 BA: Forest Service 2018a) and Herbicide Use within APS Authorized Power Line Rights-of-Way on National forest System Lands in Arizona: Biological Evaluation and Specialist Report (2018 BE: Forest Service 2018b) also apply and have been included as an appendix to this document (refer to Appendix E). In addition to the design features listed below, APS would employ a closed chain-of-custody method consistent with the Utility Arborist Association’s BMPs (Goodfellow and Holt 2011) for shipping, distribution, storage, and mixing of the Forest Service-approved herbicide. All mixing of the herbicide ingredients would occur at an off-site blending facility and would use returnable/reusable product- dedicated storage containers. The herbicide mix would consist of a premixed “ready to use” formulation stored in a sealed container. This closed delivery system would help to protect the licensed applicator and the environment by reducing the potential for leaks and spills during handling, transferring, and loading, as well as any potential leaks due to container damage. The closed delivery system would also ensure the correct concentration of spray mixture, including active ingredients, diluting agents, and adjuvants, and would reduce the potential for omissions and unauthorized change in the amounts or products. There would also be a reduction in the risk of regulatory noncompliance, such as application of off-label rates or improper disposal of ingredients or empty containers. A licensed applicator would supervise the transfer and application process to ensure that proper techniques, cleanup, personal protective equipment, and safety procedures are followed. Support vehicles such as 4x4 trucks or ATVs would be located at intervals in the ROW where they would be accessible to transfer the herbicide mix from the pre-mixed herbicide storage containers to application containers (backpacks and tanks mounted to ATVs). In situations where a “closed connection”11 is not available and the applicator must fill a container (typically a backpack) at the job site, the applicator would comply with the operational and spill contingency plan prepared during the PUP process. This would only occur in rare circumstances, as containers are typically filled prior to leaving for the site and would often last for the entire day of treatment. A closed connection is a leak-proof connection or valve used to transfer the pre- mixed herbicide from the storage container to the backpacks or ATV-mounted tanks. As previously mentioned, herbicides would be applied in select locations using backpacks or containers mounted on ATVs equipped with handheld spray wands for accurate spot treatment. The herbicide-mix storage containers would be removed from the ROW every day following the application process, and storage containers would be returned to the supplier when empty. The closed containers are product-dedicated and can be refilled only with the same custom-blended herbicide formulations that they originally contained. Each sealed container is labeled with an EPA product registration number and the concentration of ingredients, including active ingredients, diluting agents, and adjuvants. The movement of the herbicides and containers through the chain of custody would be tracked by their unique identification numbers in the containers’ bar codes. The auditable recordkeeping documentation would tie the supply container and its contents to the location where it was delivered for a minimum of three years. The third-party vendor who blends the herbicides would keep a sample of the herbicide mix for three years, in case any issues arise with effectiveness or off-ROW damage claims are made.

11 Closed connection refers to a positive interlock valve or fitting between the pre-mixed herbicide storage container and the applicators container (Goodfellow 2011).

36 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

General: . Forest Service would survey the Sycamore Canyon Wilderness Area boundaries where the APS 230-2 authorized ROW is located within the wilderness area and provide GIS data to APS for use with planning vegetation treatments. . Herbicide use will comply with the direction in FSM 2100, Chapter 2150 – Pesticide-Use Management (Region 3 Supplement), including the requirement that a Pesticide (Herbicide) Use Proposal (form FS-2100-2) be completed for all proposed herbicide uses on national forest system lands. . Ensure that all herbicide applications follow Forest Service direction (e.g., FSM 2100, Chapter 2150 - Pesticide-Use Management and Coordination; FSH 2109.14 - Pesticide-Use Management and Coordination Handbook Chapters 30 - Project Type and Personnel, 40 - Storage, Transportation, and Disposal, and 60 - Spills, Incidents, and Accidents). . Apply the least amount of herbicide needed to achieve the desired results. . Herbicides may only be applied by a licensed applicator or a trained applicator under supervision of a licensed applicator. . Ensure that licensed applicators carry and have readily available product labels and relevant safety data sheets. . Use personal protective equipment as directed by the herbicide product label. . Follow the closed chain-of-custody method for herbicide shipping, distribution, storage, and mixing. . Loading of herbicides will occur minimally 100 feet from live water. . Use only Forest Service-approved herbicides and follow product label directions and advisory statements. . Notify the public of herbicide treatment as established in the PUP review process. . Keep records of each application, including the active ingredient, formulation, application rate, date, time, and location. . Use drift control agents, as appropriate, to reduce the potential for drift to non-target species, food, and water sources. . Consider climate, weather, soil type, slope, and vegetation type when developing herbicide treatment programs. . If there is a high probability of local rain of at least 0.25 inch or more within 24 hours, then applications should only occur when it is anticipated that there shall be sufficient time (at least four hours) for the application to dry before rainfall occurs. . Refer to complete list of Biological Resources Conservation Measures in Appendix E.

Soil: . Minimize treatments in areas where herbicide runoff is likely, such as steep slopes when heavy rainfall is expected. . Granular herbicides would not be used on slopes of more than 15 percent where there is the possibility of runoff carrying the granules into non-target areas. . Do not apply pre-emergent herbicides to sandy soils.

37 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Water Resources: . Within riparian areas, wetlands, and aquatic habitats, conduct herbicide treatments only with herbicides that are approved for use in those areas per product label and conservation measures. Implement buffers for herbicide not approved for use in riparian areas, wetlands, and aquatic habitats according to the product label, risk assessment guidance, and conservation measures with minimum buffer widths of 10 feet for hand spray applications. . Refer to complete list of Biological Resources Conservation Measures in Appendix E.

Wetlands and Riparian Areas: . Within riparian areas, wetlands, and aquatic habitats, conduct herbicide treatments only with herbicides that are approved for use in those areas per product label and conservation measures. Implement buffers for herbicide not approved for use in riparian areas, wetlands, and aquatic habitats according to the product label, risk assessment guidance, and conservation measures with minimum buffer widths of 10 feet for hand spray applications. . Do not apply pre-emergent herbicides in riparian areas or areas where the water table is high. . If there is a high probability of local rain of at least 0.25 inch or more within 24 hours, then applications should only occur when it is anticipated that there shall be sufficient time (at least four hours) for the application to dry before rainfall occurs. . Refer to complete list of Biological Resources Conservation Measures in Appendix E.

General Vegetation: . Removal of saguaros will be in accordance to the current saguaro protocol as agreed upon between APS and the Forest Service. . Refer to complete list of Biological Resources Conservation Measures in Appendix E.

Fish and Other Aquatic Organisms: . Within riparian areas, wetlands, and aquatic habitats, conduct herbicide treatments only with herbicides that are approved for use in those areas per product label and conservation measures. Implement buffers for herbicide not approved for use in riparian areas, wetlands, and aquatic habitats according to the product label, risk assessment guidance, and conservation measures with minimum buffer widths of 10 feet for hand spray applications. . Use drift control agents, as appropriate, to reduce the potential for drift to non-target species, food, and water sources. . Use herbicides of low toxicity to wildlife, where feasible. . Herbicide treatments would be minimized in areas where herbicide runoff is likely, such as steep slopes when heavy rainfall is expected. . Granular herbicides would not be used on slopes of more than 15 percent where there is the possibility of runoff carrying the granules into non-target areas. . Within riparian areas, wetlands, and aquatic habitats, conduct herbicide treatments only with herbicides that are approved for use in those areas, per product label and conservation measures. . Refer to complete list of Biological Resources Conservation Measures in Appendix E.

38 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Wildlife: . Use herbicides of low toxicity to wildlife, where feasible. . A qualified biologist or resource specialist, as determined by the Forest Service, would provide maintenance crew members with training on migratory bird nest reporting and nest avoidance: crews are to report active nests that occur on vegetation or on the ground internally per APS avian reporting procedures. Do not conduct herbicide treatments on the vegetation containing the nest and vegetation adjacent to ground nesting birds until after nesting is complete. . Refer to complete list of Biological Resources Conservation Measures in Appendix E.

Threatened, Endangered, and Sensitive Species: . Where two or more species’ similar habitats occur, ensure that the more restrictive measures take priority. However, conservation measures for Threatened and Endangered species shall take precedence over sensitive species. . Refer to complete list of Biological Resources Conservation Measures in Appendix E for specific measures to threatened, endangered, and sensitive species.

Recreation: . Limit treatments in developed recreation sites to time periods when facilities are closed or during periods of low human use, as identified in the PUP review process.

Human Health and Safety: . In areas of human habitation or high use such as a recreation site, administrative site, or area where people often collect plants, the treatment method must be documented to be low risk in areas of human occupation and use. Examples include non-herbicide methods or herbicides rated as having a very low risk of harmful effects to humans. . Notify the public of herbicide treatment as established in the PUP review process. . Prepare an operational and spill plan in advance of treatment as part of the PUP and have an emergency cleanup kit onsite during treatments.

Permits and Authorizations: . File a Notice of Intent, in compliance with the Arizona Pollutant Discharge Elimination System Pesticide General Permit program, with the Arizona Department of Environmental Quality (ADEQ) before commencing activities, if appropriate.

2.3 Alternatives Considered but Eliminated from Further Analysis 2.3.1. Aerial Spraying Aerial spraying does not meet the purpose and need of Alternative B because aerial spraying is a broadcast treatment that does not limit its effects to only incompatible vegetation within the APS ROWs. 2.3.2. Burning to Control Incompatible Vegetation The use of fire can be a viable option for control of undesirable vegetation; however, even a controlled burn near a power line can be a severe safety hazard and would require de-energizing the line, as well as other precautionary measures. Additionally, some species can be difficult to control using fire and are capable of resprouting after burning. This solution is not practical or economical for vegetative management within power line corridors.

39 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

2.3.3. Livestock Grazing to Control Vegetation Using livestock, such as or , can control some species of incompatible vegetation, especially when used with other vegetation treatment methods. However, the effectiveness of this type of treatment would vary throughout the season, depending on what stage of plant growth is the livestock’s preferred food. It would not be practical to keep livestock within the APS ROW because of the time that would be needed to achieve any substantial level of vegetation control through grazing. Livestock could also consume compatible plant communities and therefore would need to be moved to prevent overgrazing of desired vegetation. Fencing would also have to be added to keep livestock within the ROW, and predators would have to be managed to prevent loss of livestock. This alternative has been eliminated from further analysis since it is ineffective and it would not address the purpose and need. 2.3.4. Saltwater Using water with dissolved salt can be effective in treating incompatible vegetation when sprayed directly onto the plant. Upon an initial saltwater treatment, some of the saltwater would be absorbed into the plant tissues inhibiting the production of chlorophyll and photosynthetic processes. Once inside the plant, saltwater interferes with the chemical processes and begins to starve the plant of nutrients and water. The remaining saltwater not evaporated or absorbed by the leaves would fall onto the ground where it would be absorbed into the soil. Over time, the plant would continue to absorb the salts through the soil further inhibiting osmosis and drawing water out of the plant leading to dehydration, eventually killing the plant. Water temperature is a factor that impacts the effectiveness of this treatment method and using heated water with dissolved salt tends to be more effective than cold or warm water. However, using heated water would be difficult given the large magnitude of the project area and the remote treatment locations. Many of the vegetation treatments would be done on-foot or using ATVs making transporting heated water extremely difficult. Furthermore, regularly handling heated water would pose a hazard to workers. Unlike some herbicides, saltwater is not systemic and doesn’t travel through the plant. Therefore, the entire plant must be sprayed for this treatment method to be effective. Using saltwater to treat vegetation in areas that receive frequent rainfall may prove less effective since the salt would become diluted after application. Additionally, treating riparian or salt-tolerant species would reduce the effectiveness of the treatment. Depending on a variety of factors including rainfall, soil types, etc., salts would leach deeper into soils over time, spreading to other areas and impacting other non-targeted vegetation. Prolonged use of saltwater may result in soil contamination killing beneficial bacteria, fungi, and organisms eventually leading to a complete loss in all vegetation. Salt that reaches the water table may result in additional negative impacts to the environment. Unlike synthetic or organic pesticides that break down over time, sodium ions do not break down and can’t be neutralized quickly. Regular use of saltwater to treat incompatible vegetation may result in a complete absence of vegetation within the area until water leeches out the excess sodium. This alternative was eliminated from further analysis since it would not address the purpose and need.

40 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

CHAPTER 3. Affected Environment and Environmental Consequences

3.1 Introduction This chapter summarizes the physical, social, and economic environments of the analysis area and the effects of implementing each alternative on the environment. It also provides the basis for comparison of alternatives presented in Chapter 2. Details of the analyses in this section are in the specialist’s reports and on file in the project record. The following information describes the affected (existing) environment in the ROW, and presents the potential effects of Alternative A and Alternative B. Measures to avoid or minimize impacts have also been identified and are listed at the end of each resource discussion. Direct and indirect impacts are described in this chapter and cumulative impacts addressed in Chapter 4. Potential impacts are described in terms of duration, intensity, type, and context. Definitions of impact terms are provided below. In this document, the terms “effect” and “impact” are used synonymously. Effects fall into two categories, and can be either direct or indirect. For the purposes of this analysis, duration of the impact is defined as either short-term or long-term and the intensity or severity of the impact is defined as either negligible, minor, moderate, or major. The type of impact is either defined by adverse or beneficial, along with the context of either local or regional. For any given resource, the definition of the magnitude of effect may be more specific to the resource and is noted in the appropriate section of the chapter. Descriptions of potential impacts are provided in each resource by alternative. For any given resource, the definition of the magnitude of effect may be more specific to the resource and is noted in the appropriate section of the chapter. Descriptions of potential impacts are provided in each resource by alternative.

3.2 Resources Considered for Analysis The Forest Service is required to address specific elements of the environment that are subject to requirements in statute or regulation or by executive order (Forest Service 2010a). A table of resources has been included in Appendix H, which includes resources considered for analysis. The table lists the resources that must be addressed in all environmental analyses and indicates whether the resource is located within the proposed project area, if the resource would be potentially impacted, and if Alternative A or Alternative B would impact those elements to a degree necessary to warrant full evaluation in this EA. Resources evaluated in this chapter are considered the resources that warrant additional evaluation.

3.3 Soils 3.3.1. Introduction In this EA, the discussion of soil resources includes soils and biological soil crusts. Soil refers to the layer of rocks, minerals, organic materials, air, and water that is found on the surface of the land. Proper soil condition is a fundamental aspect to high functioning ecosystems and supports important physical and biological processes. As several resources and uses such as livestock grazing, recreational uses, and wildlife habitat, depend upon suitable soils, their attributes, conditions, and management should be considered during management decisions.

41 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Biological soil crusts refer to the community of multiple, unrelated organisms that occur together on the soil surface in arid and semi-arid landscapes. Structurally, the appearance of biological crusts can vary from a smooth to a rough, uneven carpet or skin of low stature (between 0.08 to 0.79 inches in thickness). They function as living mulch by retaining soil moisture, reducing wind and soil erosion, discouraging annual weed growth, and contributing to soil organic matter (Warren 2014). 3.3.2. Affected Environment A wide variety of soils occur on the five forests. Soils on the Colorado Plateau are generally moderately deep to deep, fine textured, strongly developed, and display a wide range of both internal and surface rock fragments. Similar to those on the Colorado Plateau, soils in the ponderosa pine and mixed conifer vegetation types in the Mogollon Rim area and below are moderately deep to deep over bedrock and have higher amounts of clay and silt. Soils within the Mogollon Rim area and below indicate younger soils and are typically moderately deep to shallow, coarse textured. In this area, the soils also contain a high amount of rock in the soil profile and on the surface (Forest Service Coconino National Forest 1992, Forest Service Kaibab National Forest 1991, and Forest Service Prescott National Forest 2000). There are areas containing shallow soils, many of which are poorly developed (Forest Service 2005a). In the semi-arid to arid environment across the ROW, the differences in topography, elevation, vegetation, and water sources are reflected in the diversity and productivity of soil types found within the State (Forest Service 2012a). Similar types of soils are grouped together into soil orders based on their characteristics, such as organic matter, clay content, and pH that give soil their unique properties (Jenny 1980). Soils in the ROWs are classified into the following six soil orders by the U.S. Department of Agriculture Natural Resources Conservation Service (NRCS): Alfisols, Aridisols, Entisols, Inceptisols, Mollisols, and Vertisols. These soil orders group the soils at the broadest level of classification and are briefly described below. Alfisols are moderately leached soils and commonly have a mixed vegetative cover that is productive for most crops, including commercial timber. These soils have formed primarily under forest and are characterized by subsurface clay accumulations and nutrient-enriched subsoil. Aridisols are calcium carbonate-containing soils that are characterized by an extreme water deficiency and having limited leaching. They are light colored soils, low in organic matter, and contain subsurface horizons in which clays, calcium carbonate, silica, salts, and/or gypsum have accumulated. Vegetation on these soils includes scattered desert shrubs and short bunchgrasses. Surface mineral deposits often form physical crusts that impede water infiltration. Entisols developed in unconsolidated parent material and are found in steep, rocky settings. They support desert shrub and sagebrush communities and may support trees in areas of higher precipitation. Entisols can include recent alluvium, sands, soils on steep slopes, and shallow soils. Soil productivity is often limited by shallow soil depth, low water holding capacity, or inadequate available moisture. Inceptisols are soils that are often found on fairly steep slopes, young geomorphic surfaces, and resistant parent materials. They often support coniferous and deciduous forests as well as rangeland vegetation. Inceptisols may form in resistant rock or thin volcanic ash on steep mountain slopes or depressions, on top of mountain peaks, or next to rivers. Productivity is varied and may be high where moisture is adequate. Mollisols are the soils of grassland ecosystems and are characterized by a thick, dark surface horizon. This fertile surface horizon results from the long-term addition of organic materials derived from plant roots. They are one of the most productive soils and support a variety of plant communities, including , chaparral-mountain shrub, and forests. Vertisols are clay-rich soils that have high shrinking and swelling characteristics. During dry periods, the soil volume shrinks and deep wide cracks form. The soil volume then expands as it absorbs water. This

42 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona shrink/swell action generally prevents formation of distinct, well-developed horizons in these soils (BLM 2017). Table 3.3-1 lists the estimated acres and percent of soil orders found in the ROW by National Forest.

Table 3.3-1. Acres of Soil Orders within APS ROW

Apache- Coconino Kaibab Prescott Tonto Sitgreaves Total National National National National Percent of Soil Order National ROW Forest Forest Forest Forest Total ROW Forest (acres) (acres) (acres) (acres) (acres) (acres) Alfisols 1,242.14 1,075.12 1,672.39 545.52 1,322.77 5,857.94 43.51 Aridisols 55.50 385.06 471.89 1,341.35 656.04 2,909.84 21.61 Entisols 26.65 125.74 31.83 108.63 919.45 1,212.30 9.00 Inceptisols 269.27 275.32 3.44 746.14 1,469.93 2,764.10 20.53 Mollisols 221.01 163.12 120.84 14.96 143.04 662.96 4.92 Vertisols 0 0 0 56.16 0.00 56.16 0.42 Source: NRCS National Geospatial Center of Excellence, Digital General Soil Map of United States.

Management activities can result in changes to soil quality and to certain properties such as organic matter and susceptibility to erosion. Soil quality refers to a soil’s capacity to function and sustain productivity and the ability of the soils to sustain its filtration and permeability capabilities (Forest Service 1999a). Table 3.3-2 provides information on some of the soil properties and characteristics that contribute to soil quality within the ROW. More detailed information on the soils within the ROW can be obtained through review of soil surveys conducted by the NRCS (NRCS 2017). Other related factors that contribute to the condition of the soil resource include biological soil crusts, micro- and macro-organisms, soil compaction, and soil disturbance. Biological soil crusts provide important functions, such as improving soil stability and reducing erosion, contributing nutrients to plants, and assisting with plant growth. Micro and macroorganisms help to break down and convert organic remains into forms that can be used by plants and build soil structure. Soil compaction changes soil structure, reduces the size and continuity of pores, and increases soil density. In any soil, the amount of organic matter is important in maintaining soil structure and function, allowing water and air to infiltrate to low depths, and providing a source of energy to microbial communities. Since many herbicides readily bind to organic matter, soils with less than 1 percent of organic matter would most likely not constrain the movement of herbicides in the soil, which would make the herbicide available to be taken up by the vegetation. Approximately 79 percent of the soils within the ROW, fall into this category of low organic matter with less than 2 percent of organic matter present within the top 6 inches of soil. Only approximately 2,764 acres (or 21 percent) of the ROW are currently mapped by the NRCS as having organic matter levels greater than 2.5 percent. These types of soils (Inceptisols) are generally found on steep slopes. Clayey soils have more surface area per volume and provide greater binding sites for herbicides and water, supporting herbicide breakdown by microorganisms. However, as the percentage of clay in a given soil increases, the potential for compaction and runoff also increases. If the soil is nearly all clay, seasonal drying and wetting can produce wide, deep cracks in the soil. Herbicides may end up deeper into the soil. Of the currently mapped NRCS acres, there is approximately five percent of ROW where the clay content is higher than 25 percent (refer to Table 3.3-2).

43 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Table 3.3-2. Soil Orders Properties within ROW

Average Average Wind Average Water Average Average Percent Percent Erosion Group Erosion Risk Average pH Soil Order Percent T of Total Organic Rating c Rating K Value e Clay a Factor b ROW Matter Factor d Alfisols 1.72 22.65 2.21 3.55 (M) 0.20(L) 7.44 (SA) 43.51 Aridisols 1.02 24.19 3.80 5.28 (L) 0.16 (L) 7.37 (N) 21.61 Entisols 1.04 16.90 2.57 4.32 (L) 0.19 (L) 7.43(SA) 9.00 Inceptisols 8.33 14.02 1.87 4.71 (M) 0.01 (VL) 6.92 (N) 20.53 Mollisols 1.93 27.36 3.05 5.74 (L) 0.22 (M) 7.28 (N) 4.92 Vertisols 1.35 50.00 2.16 4.96 (M) 0.10 (L) 7.77 (SA) 0.42 Source: NRCS 2017 a Average organic material and clay contents derived from the top six inches for all soils within the order, not the entire profile. In some cases, this includes an organic horizon, which increases the average organic material content and lowers clay contents. b T Factor: Refers to the maximum amount of soil loss (tons per acre per year) at which the quality of the soil can be maintained for plant growth/productivity. The factor of 1 ton per acre per year is for shallow soils and 5 tons per acre per year is for deep soils that are the least subject to damage by erosion. c Wind Erosion Groups rate the tons per acre soil loss potential for wind erosion on 70 percent‐plus unvegetated soil. Wind erosion ratings between 3 and 4 are considered moderately susceptible to wind erosion and those with ratings between 4 and 8 are considered to have a low susceptibility to wind erosion. Ratings are 1 = 160‐310 tons/acre/year; 2 = 134 tons; 3 and 4 = 86 tons; 5 = 56 tons, 6 = 48 tons; 7 = 38 tons; and, 8 = 0 tons (Forest Service 1999). d K Factor Erosion Risk Rating: Low 0.05 to 0.20, Medium 0.21 to 0.40, High 0.41+. Erosion factor K appears in the Universal Soil Loss Equation (Wischmeier and Smith 1978) as a relative index of susceptibility of bare cultivated soil to sheet and rill erosion by rainfall (data derived from Forest Service 2009). Soils high in clay and coarse texture soils have low K values because they resist detachment. Medium textured soils such as fine sandy loams have moderate K values because they are moderately susceptible to detachment and runoff. e Soils with a high pH are alkaline and soils with a low pH are considered acidic. The pH scale ranges from 0 to 14, with 7 is considered neutral (neither acidic nor alkaline). Soils with a pH between 6.6 and 7.3 are considered neutral (N); pH between 7.4 and 7.8 considered slightly alkaline (SA); and those with a pH between 7.9 and 8.8 considered moderately to strongly alkaline.

Erosion is the process where soil and rock material is removed from the land surface due to water, wind and other factors. Finer particles and organic material are more prone to erosion and are removed more easily, which results in soil with reduced nutrients. Vegetation is a major factor in controlling erosion because it reduces the ground-disturbing effects of precipitation, restricts surface flow, and improves infiltration. Soils are rated by NRCS to assess the amount of erosion that can be lost before productivity is reduced. Soils within the ROW can lose approximately 1.87 and 3.8 tons of soil per acre per year before their long-term productivity would be reduced (refer to T-Factor, Table 3.3-2). These soils also have a relatively moderate to low average wind erosion group rating (3.55 to 5.74) if 70 percent or more of their surface becomes exposed. Ninety-five percent of the ROW soils have a very low to low water erosion risk factor (refer to K-Factor, Table 3.3-2). In addition, the erosion hazard rates (potential soil loss) for 63.76 percent of the soils within the ROW range from slight to slight and moderate and only 6.78 percent have an erosion hazard rate of severe. Adsorption12 increases as the pH decreases (becomes acidic) and with increasing clay and organic matter content (Tu et al. 2001). At a soil pH above 7 the herbicide is less tightly adsorbed and more available to plants. According to NRCS, the average pH of the soil orders in the ROW are all neutral to alkaline, with an average range of pH between 6.92 to 7.77 (refer to Table 3.3-2). Approximately 55 percent of the soils

12 Soil adsorption is measured by the sorption coefficient (Koc), which describes the tendency of an herbicide to bind to soil particles. The higher the Koc the greater the sorption potential, which limits the movement of the herbicide and increases it’s persistence in the soil. The herbicides with a Koc value greater than 1,000 milliliter per gram indicates strong adsorption to soil whereas low Koc values (less than 500) tend to allow movement with water more so than movement absorbed to soil (BLM 2011).

44 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona are slightly alkaline. Soils considered neutral amount to 46 percent of those currently mapped. There are no soils considered to be acidic or moderately to strongly alkaline within the ROW at the soil order level. 3.3.3. Design Features Design features applicable to soils are stated in Chapter 2. For design features related to manual and mechanical treatment methods, refer to Section 2.1.8; for design features related to herbicide treatment methods, refer to Sections 2.1.8 and 2.2.11. 3.3.4. Environmental Consequences Direct and Indirect Effects of Alternative A Vegetation management activities under the Alternative A would include hazard vegetation removal, routine vegetation, and DSAP maintenance. Vegetation removal and disposal activities would include the use of tracked or wheeled vehicles, field crews, and hand and machine equipment such as chainsaws and large mowers in some circumstances. This assessment of impacts assumes that the design features for manual and mechanical treatment methods designed to reduce potential unintended impacts to soil would be followed for all vegetation management activities in Alternative A. Treatment methods in Alternative A may cause compaction, displacement of upper surface layers of soil, and increase the risk of erosion. Bare or compacted soils can be more susceptible to erosion and colonization by invasive plants more readily than native plants, as invasive plants tend to be better adapted to establishing on such altered sites. Compaction decreases soil pore space and increases soil density, which in turn can decrease productivity and reduce the ability of water to infiltrate through the soil. Decreased soil infiltration can lead to more water moving across the surface during storm events, thereby increasing erosion. Plant roots in Alternative A would remain in place, which would help reduce the potential for soil erosion before grasses and forbs become established. Vegetative ground cover and low bare soil stabilizes soils. Manual and mechanical treatments as well as DSAP maintenance treatments would reduce fuel loads within the ROW, create fire breaks, and decrease the risk of high intensity wildland fires. These efforts to help minimize the excessive loss of vegetation would have an indirect effect on soil resources by avoiding soil disturbance and erosion from catastrophic wildfires. Manual methods would be the most common method used to treat incompatible vegetation within the ROW and would involve cutting vegetation with non-motorized hand equipment or hand held power equipment such as chainsaws. Ground disturbance would be due primarily to off-road use of vehicles including 4x4 trucks and ATVs used to transport equipment and workers, and to a lesser extent, foot traffic. ATVs and other vehicles would be used off-road only during dry conditions to avoid rutting. Driving directly up slopes or on highly erodible soils would be avoided in order to limit compaction and soil surface disturbance. In addition, the vehicles would be driven at low speeds at all times. Some contamination of the soil from petroleum products used in vehicles and hand-held power equipment could occur, but these effects would be localized. Manual treatments would affect soils by removing vegetative cover, which could reduce the soil moisture and nutrient recycling and increase the risk of erosion. As the vegetation regrows, these impacts to soils would be substantially reduced. Leaving vegetation debris (wood chips and slash through lop and scatter) on the soil surface, or mulching and spreading them after a manual treatment, would help protect the soil surface by reducing the risk of erosion, retaining moisture, and supplying nutrients. Since grasses, forbs, and many shrubs would remain untreated (except for DSAP as described below), this would provide soil with some vegetative cover. Mechanical methods in Alternative A would be used less than five percent of the time within the ROW. These methods would generally consist of rotary and drum style cutting devices mounted on a vehicle with rubber tires or tracks. Similar to manual treatments, ground disturbance and soil compaction would occur from foot traffic and the vehicles used to transport equipment and workers; mechanical methods

45 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests would also cause ground disturbance and soil compaction from the use of heavy equipment. The actual shredding, cutting, and chopping of vegetation would not directly disturb the soil. However, mechanical treatments, like manual treatments, would affect soils by removing vegetative cover. Manual methods would have less direct impacts on soil resources within the ROW than mechanical methods. The type and weight of equipment used in mechanical vegetation treatment would have a greater potential to shear and rut soils as compared to the vehicles and equipment used in the manual treatment method. Although, similar to mechanical treatments, ATVs and vehicles would be used only during dry conditions to avoid rutting, except under hazard vegetation maintenance situations. Using tracked or rubber tires that would distribute vehicle weight over a larger area would help reduce the pressure on soil as compared to conventional tires. Compaction and erosion susceptibility can also be reduced by covering the treatment area with the mulched vegetation debris that could serve to protect the soil surface. The mulching of the woody vegetation would occur in front of the cutting equipment, leaving a cushion of mulch for the equipment to travel over, thereby reducing surface disturbance, risk of erosion, and the amount of compaction. The mulch would also help protect the biological soil crusts from the vehicles driven on the surface of the soil crust by creating a layer of cushion. As vegetation becomes reestablished and extend out their root masses, the erosion from exposed soils would decrease. Similar to manual methods, there may also be the potential for some contamination of the soil resources from petroleum products used by the equipment, but these effects would be extremely localized. DSAP maintenance activities associated with the Alternative A would consist of manually removing all combustible vegetation within the 10-foot radius of poles with equipment that can spark. Clearing the DSAP totally of vegetation would directly disturb the soil and any micro- and macro-organisms in addition to the removal of the root system of any vegetation within the 10-foot radius as well. The disturbed soil would be vulnerable to increased erosion, soil productivity and soil quality would be reduced, and cleared area would be susceptible to invasive species establishment. The total treatment area within the DSAP maintenance program would impact approximately 10.02 acres of the 13,463.30-acre ROW. Alternative A is anticipated to result in localized disturbance to soil resources from manual and mechanical treatments and DSAP maintenance activities since the ROW corridors have been continually maintained and only incompatible vegetation treated. Over the long-term, the routine vegetation maintenance requirements in terms of the number of acres to be treated, the density of vegetation to be removed, and the number of work crew members, equipment, and vehicles required are anticipated to be relatively the same for each work cycle. The regrowth of vegetation within the ROW would occur between work cycles and any detrimental effects to soil quality and erosion susceptibility from treatment activities would be reduced. Therefore, Alternative A would have short-term, direct and indirect, minor adverse impacts on soil resources because the intensity and duration of treatments and regrowth of vegetation would be localized and slightly alter soil resources. Over the long-term, Alternative A would have direct, negligible adverse impacts to soil resources. Additionally, this alternative would have long- term, indirect, minor beneficial impacts on soil resources by decreasing the risk of high intensity wildland fires in the ROW. Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with Alternative A described above, Alternative B would also result in impacts on soil and soil organisms from the use of herbicides as part of the management of incompatible vegetation within the ROW. Herbicide treatments may be completed at the same time as manual and mechanical methods such as for DSAP maintenance, hazardous vegetation removal, cut stump, and basal application methods. Minor increased soil disturbance and compaction may occur during these combined treatments if additional work crews and vehicles are needed in order to apply herbicide spot treatment immediately following the manual and/or mechanical treatments.

46 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Potential indirect impacts to soils associated with transporting herbicides to unintentional areas would be negligible because only targeted herbicide applications would be used within the ROWs. The foliar application of herbicides using the adjuvant Thinvert as the carrier would result in the herbicide adhering to the targeted plants and would minimize spray drift. The herbicide would also be more likely to remain on the plant reducing effects on soil resources. In addition, approximately 64 percent of the soils within the ROW have slight to slight to moderate erosion hazard rates. As a result, herbicides would tend to remain where applied with limited unintended transport by soil particles from erosion. Herbicides must be relatively persistent to have the potential to leach or runoff. Those herbicides that adsorb strongly to soil particles (because of herbicide and/or soil properties) tend to run off with soil movement. Soils that are high in organic content or clay tend to be the most adsorptive. Sandy soils are typically low in organic content and are generally the least adsorptive. Herbicides with low solubility in water may be more likely to run off and those with low soil adsorption tend to leach down through the soil (BLM 2016). Persistence of herbicides in soil varies widely and is dependent of soil conditions. The rate of decomposition of herbicides in the soil is related to soil properties such as moisture, pH, temperature, aerobic conditions, organic matter, and soil texture. Decomposition is also dependent on the herbicide’s chemical structure, solubility, dosage, and adsorption to soil characteristics as well as the soil’s microbial composition and population. The application of herbicide treatments would not affect soil chemistry such as pH or amount of organic matter. Sterile soils may could typically have slower herbicide transformation because of the limited biotic components. Herbicides would affect few soil organisms directly (Forest Service 2004a). However, research on the toxicity of herbicides to soil organisms is limited. Chlorsulfuron, picloram, and metsulfuron methyl are known to have some adverse effect on soil organisms; generally reducing but not eliminating local soil organism populations for a limited period. Other herbicides, including 2,4‐D, clopyralid, dicamba, glyphosate, sulfometuron methyl, and triclopyr, are reported to have no or negligible adverse effect on soil organisms, with some organisms showing increases in populations after herbicide treatments. Of the limited studies found to have been conducted on soil organisms for the remaining products, effects have been demonstrated, but at application rates many times higher than the typical rates proposed for use in Alternative B, or the decrease in soil organisms is temporary. These studies also show populations of soil organisms have increased in some situations. The Forest Service approved herbicides that would be used have not been shown to substantially decrease soil microbial activity. Natural decomposition of the herbicide would occur over time, further reducing any long-term impacts. Herbicides can be broken down under both anaerobic and aerobic conditions, e.g., glyphosate and isoxaben are degraded primarily anaerobically and picloram and 2,4-D more readily aerobically (Weed Science Society of America 2014). Of the herbicides approved by the Forest Service for use, aminocyclopyrachlor, aminopyralid, imazapic, imazapyr, isoxaben, and tebuthiuron have a half-life13 in soils greater than 90 days, while dicamba, sulfometuron methyl, metsulfourn methyl, picloram, and 2,4-D are relatively non-persistent in soil, having a half-life in soils of an average of 30 days or less (refer to Table 3.3-3). Approximately 79 percent of soils in the ROW have low organic matter accumulation. This could limit the ability of soils in the ROW to filter, store, and process herbicides. In addition, most of the herbicides identified under Alternative B have a low adsorption potential and conversely high movement rating. Of the Forest Service-approved herbicides selected for use in Alternative B, only glyphosate has a strong adsorption to soil. Except in the treatment of DSAP areas, the net effect of these factors would be that in the event that herbicides come in contact with soils, their effects on soils would be minimal.

13 The measure of persistence of a product in soil is calculated as the soil half-life. A half-life is the average time it takes for a certain amount of an herbicide to be reduced by half as it dissipates or breaks down in the environment. A half-life can be categories as non-persistent (less than 30 days), moderately persistent (30 to 90 days), and persistent (greater than 90 days) (BLM 2011).

47 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Herbicides may also indirectly affect soil through plant removal resulting in changes in physical and biological soil parameters. As vegetation is removed, there would less plant material to intercept rainfall and less to contribute organic material to the soil. Loss of plant material and soil organic matter can increase the risk of soil susceptibility to wind and water erosion. Alternative B would be limited to spot treatment of incompatible vegetation and no broadcast application would occur. Since the ROW corridors have been continually maintained and only incompatible vegetation would be treated, this would be a small change. The risk for increased erosion would be minor and temporary, lasting only until vegetation was reestablished. When herbicide treatments lead to natural establishment of native plants, soil stability would be improved relative to sites dominated by invasive plants. The increase in herbaceous cover may be more effective for soil stabilization in arid/semi-arid areas.

Table 3.3-3. Herbicide Characteristics in Water and Soil

Water Solubility Potential for Half Life in Soil a,b,c Potential for Active Ingredient (milligrams/ Surface Leaching e,f,g,h (aerobic conditions) liter) b,c,d Runoff e,f,g,h

Aminocyclopyrachlor 315 days 4,200 Low High Aminopyralid* 343 days 205,000 High High Chlorsulfuron 37 to 168 days 27,900 High Low Clopyralid 14 to 29 days 1,000 Moderate Low 2,4-D 6.2 days 569 Moderate Low Dicamba 31 days 6,500 Low to Moderate Low Fluroxypyr 7 to 23 days 7,950 Low Low Glyphosate 5.4 days 12,000 Low Low Imazapic 113 days 36,000 Low Low 2,150 days 11,100 Low Low Imazapyr (313 to 2,972 days) Isoxaben 21 to 318 days 1 Low Low Metsulfuron methyl 120 days 2,790 Moderate at pH 7 Low Picloram 90 days (18 to 513 days) 200,000 High Low Sulfometuron methyl 10 to 100 days 300 Moderate at pH 7 Low Tebuthiuron 1,062 days 2,500 High Low Triclopyr 0.2 to 69 days 7.4 to 440 Moderate High a Soil halftimes are based on neutral soil (pH.7) at an ambient temperature of about 77°F (20°C). Much shorter halftimes reported in acidic soils (pH 6) as well as soils at a higher temperatures. Degradation in soil is highly dependent on microbial activity (Priester 1991a) and may vary substantially within a given type of soil. b Source for Aminocyclopyrachlor, Aminopyralid, Chlorsulfuron, Clopyralid, 2,4-D, Dicamba, Fluroxypyr, Glyphosate, Imazapic, Imazapy, Isoxaben, Metsulfuron methyl, Picloram, Sulfometuron methyl, Tebuthiuron, and Triclopyr: Forest Service 2018c c Source: Shaner 2014 d Water Solubility = tendency of a chemical to dissolve in water e Source for all herbicides except aminocyclopyrachlor, aminopyralid, and picloram: Vincill 2002 f Source for aminocyclopyrachlor: Syracuse Environmental Research Associates, Inc. (SERA) 2012 g Source for aminopyralid: BLM 2016, Table 4-5, pp. 4-17 h Source for picloram: BLM 2007, Table 4-9, pp. 4-28

48 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Thinvert or an oil-based carrier may be used to increase the efficiency of herbicides. It is unknown whether adjuvants added to herbicides would cause additional impacts on soil quality beyond those already discussed above for herbicides. The adjuvant would be incorporated to reduce drip and drift of the herbicides being used, which would reduce the unintended direct contact of herbicide to soil. The use of IVM techniques under Alternative B would reduce the intensity and frequency of future mechanical and manual treatments, subsequently reducing potential impacts to soils. The impact reduction is based on successful use of herbicides that would prevent a species from returning for approximately eight years; generally disturbing less soil for most areas. Long-term, indirect impacts would be based on the successful use of herbicide and establishment of low-growing vegetation as a result of the reduction of vegetation requiring treatments. The composition of flammable vegetation within the ROWs would be altered resulting in reduced fuel loads and subsequently reduce fire intensity within the ROW. In comparison to Alternative B, the manual and mechanical treatment methods associated with Alternative A would result in a greater amount of area requiring treatment over the long-term, which would mean an increase in the number of ground vehicles and equipment within the ROW and a greater risk of erosion and compaction. Alternative A routine vegetation maintenance requirements in terms of the number of acres to be treated, the density of vegetation to be removed, and the number of work crew members, equipment, and vehicles required are anticipated to be the same for each work cycle. Conversely, with Alternative B, the routine vegetation maintenance requirements would substantially decrease over time within the ROW with the removal of incompatible vegetation and establishment of low-growing compatible species. Therefore, Alternative B would have short–term, direct and indirect, minor adverse impacts on soil resources. Additionally, Alternative B would have long-term, direct and indirect, moderate beneficial impacts on soil resources by the reduced frequency and intensity of vegetation management treatments as compared to Alternative A by allowing low-growing native compatible vegetation, and decreasing the risk of high intensity wildland fires within the ROW.

3.4 Water Resources and Quality (Drinking/Surface/Groundwater) 3.4.1. Introduction Water resources refer to surface water such as rivers, reservoirs, and ponds; and groundwater. Water resources are important for fish and wildlife habitat as well as a variety of human needs, including domestic consumption, crop irrigation, and recreation. Water quality is defined in relation to its specified and/or beneficial uses, such as human consumption and fisheries and is measured by its chemical, physical, biological, and radiological characteristics. The Clean Water Act (CWA), as amended in 1972, is the framework that regulates water quality standards and pollutant discharges into waters of the United States. The water resources analysis area consists of the surface and groundwater resources that are located within the ROW and were identified through various geographic information system (GIS)-based data sets. 3.4.2. Affected Environment Water Resources Water resources include perennial streams and rivers (continually flowing), intermittent streams (groundwater component with augmentation by seasonal precipitation), ephemeral streams (flowing in response to precipitation events), and groundwater within watersheds. Watersheds provide important ecosystem functions including recharge of streams and aquifers, maintain riparian communities, and provide habitat that supports adaptive animal and plant communities. Watersheds have enough effective vegetative groundcover, such that they are resilient, recover rapidly from natural and human disturbances, and maintain long term soil productivity (Forest Service 2013b).

49 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

The ROW is located within the Lower Colorado River hydrologic region. Surface water flow is ephemeral to non-existent most of the year and only major rivers such as the Gila and Verde Rivers have perennial flow. Groundwater can have variable flow rates and can recharge from streams and upland areas. Aquifers (underground water-bearing rock) are generally located in the northeastern and middle to southern portions of the State with smaller areas of shallow aquifers found in the mountainous alluvial stream valleys (Robson and Banta 1995). Surface Water. The National Hydrography Dataset (NHD), a GIS dataset that represents the surface water drainage network of named streams, rivers, canals, lakes, and reservoirs in the United States (U.S. Geological Survey [USGS] 2011) was used to analyze eight-digit Hydrologic Unit Code (HUC 8) watersheds where APS propose herbicide treatments within authorized ROW. Table 3.4-1 identifies the 18 HUC 8 sub-basin watersheds and associated acres of which the ROW crosses. Major river systems, including the Agua Fria River, Gila River, Hassayampa River, Little Colorado River, Salt River, and the Big Sandy River are located within the ROW. Additionally, a total of 121 named waterbodies are located within the ROW. Table 3.4-2 through Table 3.4-6 provide the named waterbody within the ROW and the miles of the surface water within the ROW for each of the five forests. Table 3.4-1. HUC 8 Subbasin Watersheds within ROW HUC 8 Apache- Coconino Kaibab Prescott Tonto Grand Subbasin Subbasin Sitgreaves National National National National Total Watershed Name Watershed National Forest Forest Forest Forest (acres) Number Forests (acres) (acres) (acres) (acres) (acres) Havasu Canyon 15010004 806.78 806.78 Silver 15020005 150.84 150.84 Middle Little 290.92 95.10 386.02 Colorado 15020008 Chevelon Canyon 15020010 1,263.90 1,263.90 Canyon Diablo 15020015 809.50 809.50 Lower Little 84.35 231.26 315.61 Colorado 15020016 Big Sandy 15030201 2.96 2.96 Santa Maria 15030203 257.44 257.44 San Carlos 15040007 8.01 8.01 Middle Gila 15050100 221.54 221.54 Upper Salt 15060103 90.54 1,335.37 1,425.91 Tonto 15060105 18.37 1,785.68 1,804.05 Lower Salt 15060106 0.08 0.08 Big Chino- Williamson 523.30 32.56 555.86 Valley 15060201 Upper Verde 15060202 953.05 739.05 1611.75 3,303.85 Lower Verde 15060203 82.36 105.73 1,088.99 1,277.08 Aqua Fria 15070102 769.59 71.58 841.17 Hassayampa 15070103 32.72 32.72 Total 1,814.57 2,024.36 2,300.39 2,812.75 4,511.24 13,463.32 Source: U.S. Department of Agriculture Watershed Boundary Dataset HUC 8 2017

50 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Table 3.4-2. Surface Water within ROW within Apache-Sitgreaves National Forests

Surface Waters Miles of Surface Waters within ROW Alder Creek 0.21 Chevelon Creek 0.06 Cottonwood Wash 0.01 Day Wash 0.09 Dodson Wash 0.01 Show Low Creek 0.03 West Chevelon Creek 0.14 Willow Creek 0.07 Total 0.62 Source: USGS NHD Flowlines 2016; USGS NHD Waterbody 2016

Table 3.4-3. Surface Water within ROW within Coconino National Forest

Surface Waters Miles of Surface Waters within ROW

Ashurst Run 0.02 Ball Court Wash 0.01 Coffee Creek 0.02 Deadman Wash 0.01 Dry Creek 0.05 East Clear Creek 0.01 0.03 Hulls Wash 0.01 Oak Creek 0.17 Rio de Flag 0.02 Sally May Wash 0.01 San Francisco Wash 0.26 Sinclair Wash 0.04 Soldier Wash 0.01 Spring Creek 0.02 Sycamore Creek 0.01 Towel Creek 0.01 0.09 Volunteer Wash 0.18 Walnut Creek 0.09 West Fork Oak Creek 0.03

51 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Surface Waters Miles of Surface Waters within ROW

Wet Beaver Creek 0.01 Wickiup Creek 0.01 Total 1.12 Source: USGS NHD Flowlines 2016; USGS NHD Waterbody 2016

Table 3.4-4. Surface Water within ROW within Kaibab National Forest

Surface Waters Miles of Surface Waters within ROW

Cataract Creek 0.01 Dogtown Wash 0.04 Grindstone Wash 0.05 Johnson Creek 0.13 Little Red Horse Wash 0.01 Meath Wash 0.30 Miller Wash 0.07 Partridge Creek 0.01 Russell Wash 0.06 Spring Valley Wash 0.09 West Cataract Creek 0.01 Total 0.78 Source: USGS NHD Flowlines 2016; USGS NHD Waterbody 2016

Table 3.4-5 Surface Water within ROW within Prescott National Forest

Surface Waters Miles of Surface Waters within ROW

Ash Creek 0.01 Aspen Creek 0.02 Banning Creek 0.07 Big Bug Creek 0.08 Chasm Creek 0.01 Cherry Creek 0.03 Crazy Basin Creek 0.02 Dry Creek 0.01 Gaddis Wash 0.01 Grief Hill Wash 0.01 Groom Creek 0.04 Hackberry Creek 0.03 Hassayampa River 0.03 Horsethief Creek 0.03

52 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Surface Waters Miles of Surface Waters within ROW

Indian Creek 0.02 Iron Springs Wash 0.02 Little Sycamore Creek 0.03 Lynx Creek 0.05 Page Wash 0.02 Poland Creek 0.01 Rattlesnake Wash 0.19 Skull Valley Wash 0.06 Spence Creek 0.03 Strickland Wash 0.02 Sycamore Creek 0.03 Tank Creek 0.02 Tonto Wash 0.03 Turkey Creek 0.02 Verde River 0.08 Wagon Tire Wash 0.09 Wolf Creek 0.01 Woods Ditch 0.01 Woolsey Wash 0.06 Yarber Wash 0.35 Yellow Jacket Creek 0.01 Total 1.56 Source: USGS NHD Flowlines 2016; USGS NHD Waterbody 2016

Table 3.4-6. Surface Water within ROW within Tonto National Forest

Surface Waters Miles of Surface Waters within ROW

Alder Creek 0.29 Ash Creek 0.01 Ashurst Creek 0.03 Banning Wash 0.06 Bishop Creek 0.01 Black Mountain Wash 0.12 Blue Wash 0.01 Braddock Creek 0.04 Brody Creek 0.01 Buena Vista Creek 0.02 Camp Creek 0.09 Campbell Creek 0.05

53 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Surface Waters Miles of Surface Waters within ROW

Canyon Creek 0.03 Chalk Creek 0.07 Cherry Creek 0.17 Coon Creek 0.04 Copper Creek 0.01 Corral Creek 0.11 DeVore Wash 0.03 Dry Creek 0.03 Eads Wash 0.04 East Verde River 0.07 Ellison Creek 0.05 Fossil Creek 0.04 Fuller Creek 0.01 Gentry Creek 0.07 Gibson Creek 0.21 Gold Creek 0.09 Green Valley Creek 0.42 Hardscrabble Creek 0.01 Hardt Creek 0.07 Haufer Wash 0.04 Horse Camp Creek 0.06 Houston Creek 0.08 H-Z Wash 0.04 Lambing Creek 0.01 Log Corral Wash 0.06 Maverick Mountain Wash 0.06 North Fork Cooper Forks 0.03 Pine Creek 0.02 Pinto Creek 0.10 Poison Springs Wash 0.03 Pringle Wash 0.03 Rock Creek 0.04 Rock House Creek 0.03 Rye Creek 0.10 Salt River 0.05 Sand Wash 0.07 Sheep Wash 0.03 Silver Creek 0.01

54 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Surface Waters Miles of Surface Waters within ROW

Slate Creek 0.08 Sloan Creek 0.05 Stewart Creek 0.01 Sycamore Creek 0.07 Tank Creek 0.01 Tonto Creek 0.10 Verde River 0.08 Webber Creek 0.02 Wrest Fork Oak Creek 0.06 Total 2.84 Source: USGS NHD Flowlines 2016; USGS NHD Waterbody 2016

Groundwater. Within the Lower Colorado hydrologic region, groundwater is found in the alluvium of the shallow basins and in the bedrock of the mountainous areas (i.e., deep reservoirs to depths of many thousands of feet). Groundwater occurs within an aquifer, or layers of permeable rocks that are recharged by precipitation in the mountains and infiltration of stream flow that percolates through the unsaturated zone to the water table. Within Arizona, average annual precipitation varies greatly depending on location. Within lower elevations, precipitation ranges between three and 11 inches, while higher elevations may experience 29 to 45 inches (ASU 2016). Aquifers vary in size and yield based on location and rates of infiltration and discharge. The Groundwater Atlas of the United States identifies Arizona as occurring within the Colorado Plateaus aquifers and the Basin and Range aquifers; however, much of Arizona does not have a principal aquifer (USGS 1995). The Colorado Plateau aquifers are located in the northeastern portion of the State and consist of the Dakota-Glen Canyon, the Coconino-De Chelly, and the Mesaverde aquifers. The ROW is located within the boundaries of the Dakota-Glen Canyon and Coconino-De Celly aquifers but not within the boundary of Mesaverde aquifer. The depth to the top of the Dakota-Glen Canyon aquifer is less than 2,000 feet for portions that occur within Arizona, but exceeds 12,000 feet in substantial parts throughout the system (USGS 1995). With the Coconino-De Chelly aquifer, fractures in sandstone formations in the vicinity of the act as conduits that allow groundwater to drain and emerge from underlying rocks at springs in the Grand Canyon and tributaries of the Colorado River (USGS 1995). Basin and Range aquifers account for a large portion of the middle to southern portion of Arizona. These aquifers are considered surficial aquifers due to their shallow depth to groundwater; however, they are considered part of a deeper and more extensive aquifer system that runs throughout the southwest. Basin fill deposits dominate the surface of these aquifers. Basin fill is considered highly permeable and primarily consists of unconsolidated to moderately consolidated, well to poorly sorted beds of gravel, sand, silt, and clay deposited on alluvial fans, pediments, flood plains, and playas (USGS 1995). Groundwater is obtained primarily from wells that tap into aquifers. The largest quantities of useable freshwater occur as groundwater, which provides drinking water for more than 97 percent of the rural population. It also provides between 30 and 40 percent of the water used for agriculture (Alley et al. 1999). As a result of extensive planning by the Arizona Department of Water Resources (ADWR), under the ADEQ, Arizona is divided into seven individual planning areas. These planning areas are composed of 51 individual groundwater basins to support water planning and development efforts by providing water- related information on a local, regional, and statewide level (ADWR 2010). Established under an ADWR

55 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests work plan and developed by the Environmental Working Group of the Water Resources Development Commission (WRDC), the final report “Arizona’s Inventory of Water-Dependent Natural Resources” evaluates the relationship between Arizona’s waters and the environmental resources those waters support (WRDC 2011). The final report documented groundwater level change from the late 1980s/mid 1990s to the mid/late 2000s by measuring depth to water in groundwater wells located in each groundwater basin to assist in making qualitative assessments of each groundwater basin’s current overdraft status. As a result of this review, a mean depth to water below land surface for each ADWR groundwater basin and respective subbasin was estimated. Table 3.4-7 provides the acres of ROW within each of the 21 groundwater subbasins for each of the five forests and the mean depth to water of the subbasin.

Table 3.4-7. Groundwater Subbasins within ROW

Apache- Mean Depth to Groundwater Sitgreaves Coconino Kaibab Prescott Tonto Water National National National National National Subbasin Forests Forest Forest Forest Forest (feet below (acres) (acres) (acres) (acres) (acres) land surface) Agua Fria 421.81 62.17 55 Fort Rock 2.96 214 Santa Maria 104.69 55 Skull Valley 154.23 150 Coconino Plateau 29.85 1,047.09 185 Donnelly Wash 12.51 No Data Little Colorado River Plateau 1,706.77 957.66 230 Mammoth 135.41 94 Carefree 9.39 94 East Salt River Valley 73.48 217 Fountain Hills 322.62 194 Little Chino 227.78 214 Upper Agua Fria 344.69 245 San Carlos Valley 8.21 722 Salt River Canyon 90.87 785.46 20 Salt River Lakes 552.35 68 Tonto Creek 16.92 1,781.52 38 Upper Hassayampa 32.93 356 Big Chino 521.55 48.55 132 Verde Canyon 71.98 17.15 768.12 183 Verde Valley 964.86 731.74 1,457.97 173 Source: WRDC 2011; ADWR 2011 Table Note: No Data = No depth to water data available from the WRDC Final Report.

Established under Section 1424(e) of the U.S. Safe Drinking Water Act, the U.S. EPA’s Sole Source Aquifer Program allows for EPA environmental review of any action that is financially assisted by Federal grants or Federal loan guarantees. Actions are evaluated to determine whether they have the

56 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona potential to contaminate a sole source aquifer. There are no sole source aquifers within the APS ROW on National Forest System lands within Arizona.

Water Quality The CWA is the primary law governing water quality. It establishes the basic structure for regulating discharges of pollutants into the waters of the United States and regulating quality standards for surface waters. Section 402 of the CWA created the National Pollutant Discharge Elimination System permit program, which is administered by most individual states and includes stormwater permits and requirements for construction areas. With oversight of the EPA, ADEQ administers Section 402 of the CWA on Forest Service-managed lands in Arizona through the Arizona Pollution Discharge Elimination System (AZPDES) General Permit. Additionally, on October 31, 2011, the AZPDES Pesticide General Permit (AZPGP2011-001) was issued for the application of pesticides to, including over and near, waters of the United States in Arizona, except for Indian country. The AZPDES Pesticide General Permit authorizes chemical and biological pesticide discharges to, over, and in the vicinity of waters of the United States for various activities including for weed, algae, and vegetation control. The Forest Service is committed to the protection of water quality consistent with the CWA and Safe Drinking Water Act and to restore and maintain the chemical, physical, and biological integrity of the water resources within or near the national forests (Forest Service 2012c). Regulatory programs for water quality standards include default narrative standards, non-degradation provisions, a total maximum daily load regulatory process for impaired waters, and associated minimum water quality requirements for the designated uses of listed surface waterbodies within the State. The ADEQ implements the standards set by the EPA and regulates the discharge of pollutants into surface and ground water and enforces the Primary Drinking Water Regulations. 3.4.3. Design Features Design features applicable to water resources are stated in Chapter 2. For design features related to manual and mechanical treatment methods, refer to Section 2.1.8; for design features related to herbicide treatment methods, refer to Sections 2.1.8 and 2.2.11. 3.4.4. Environmental Consequences Direct and Indirect Effects of Alternative A Under Alternative A, vegetation removal and disposal activities would include the use of tracked or wheeled vehicles, field crews, and hand and machine equipment such as chainsaws and in some circumstances large mowers. This assessment of impacts assumes that the design features for manual and mechanical treatment methods designed to reduce potential unintended impacts to water resources and water quality would be followed for all vegetation management activities in Alternative A. Vegetation treatments in Alternative A could affect both surface water and groundwater quality and quantity. Removal of incompatible vegetation could cause short-term effects on surface water by increasing surface runoff, promoting erosion and sedimentation, reducing shading and increasing water temperature, and limiting the amount of organic debris entering water bodies (Forest Service 2012a). Sediment, which has been described as the greatest non-point source of pollution, increases turbidity and contributes to reduction in dissolved oxygen. Vegetation treatments could also affect water quality by reducing nutrient uptake by plants, resulting in a pulse of nutrients to nearby water bodies. Soluble nutrients, such as nitrogen, would likely enter streams or other water bodies via groundwater, while nutrients adsorbed to soil particles (e.g., phosphorous) could be carried to surface water in runoff (BLM 2017). The direct and indirect impacts to surface water quality would be localized with the potential to affect a total of 7.74 miles of surface waters that are present within the ROW.

57 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

In locations near surface waters, water quality degradation could result from the reduction in shade and potentially increase water temperatures within the ROWs. As the vegetation regrows, the risk of erosion and runoff would be reduced. Additionally, not all of the vegetation within the ROW would be treated, compatible vegetation would be left untreated, reducing the potential for erosion and runoff. The loss of vegetation cover could slightly improve groundwater recharge over the short term by reducing the amount of water lost from evapotranspiration by plants (BLM 2017). However, the average depth to groundwater within the ROW is 181.95 feet and ranges from 20 to 722 feet and any changes would most likely not be detectable. The reduction of hazardous fuels from public lands would result in a long-term positive effect to surface water quality by helping reduce the risk of a future high-severity wildfire within the ROW. Wildfires and wildfire suppressions can increase surface soil erosion, resulting in short-term increases in stream flows. Manual methods would be used the majority of the time to treat incompatible vegetation within the ROW. Ground disturbance created by manual methods would be attributed primarily to vehicles used to transport equipment and workers and to a lesser extent, foot traffic. ATVs and other vehicles would be used off-road only during dry conditions to avoid rutting and driving directly up slopes or on highly erodible soils would be avoided. The vehicles would be driven at low speeds at all times thereby reducing ground disturbance and the risk of erosion and runoff. Precautions would be taken to minimize risks to surface and groundwater quality associated from fuel spills from the use of chainsaws or other power tools (refer to Section 2.1.8 Alternative A Design Features). Leaving vegetation debris on the soil surface, or mulching and spreading them after a manual treatment, would help protect the soil surface by reducing the risk of erosion and increased sedimentation to surface waters (BLM 2017). Mechanical method effects on water quality would result from the compaction of soil by heavy equipment, which would increase the likelihood of surface runoff by reducing the soil’s infiltration capacity. However, leaving debris in place would limit any detrimental effects on infiltration rates and sedimentation into streams. Furthermore, the mechanical method is only used approximately five percent of the time during vegetation treatment cycles. There could be risks to water quality from fuel leaks and spills associated with the use of heavy machinery or mechanized equipment. Releases of fuel would be more likely to affect surface water than groundwater, and would have the greatest effects to water quality if fuel was released directly into the water (BLM 2017). DSAP maintenance activities associated with Alternative A would remove all combustible vegetation within the 10-foot radius of poles with equipment that can spark. The disturbed soil would be vulnerable to increased erosion and runoff, which in turn could increase sedimentation to surface waters. The total treatment area within the DSAP maintenance program would impact approximately 10.2 acres of the 13,463.30 acres of the total ROW on National Forest System lands. The effects to water resources and quality from DSAP maintenance activities would not be detectable. With the implementation of the design features, Alternative A would result in short-term, localized effects on water resources from the soil disturbance and associated potential for runoff from manual, mechanical, and DSAP maintenance activities. Over the long-term, the routine vegetation maintenance requirements are anticipated to be relatively the same for each work cycle. The regrowth of vegetation within the ROW would occur between work cycles and any detrimental effects to surface and groundwater quality from treatment activities would be further reduced. Therefore, Alternative A would have localized, short-term, direct, minor adverse impacts and localized, long-term, direct, negligible adverse impacts on water resources. The reduction of hazardous fuels would result in a short- and long-term, indirect, negligible beneficial impact to surface water quality by helping reduce the risk of a future high-severity wildfire within the ROW.

58 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Direct and Indirect Effects of Alternative B In addition to the short-term, direct and indirect adverse effects associated with Alternative A described above, Alternative B would also result in impacts on water resources from the use of herbicides as part of the management of incompatible vegetation within the ROW. Prior Forest Service environmental documentation on the use of herbicides provided analysis of potential water resources impacts associated with the application of herbicides (Forest Service 2005a, pp. 122-123; Forest Service 2008a, pp. 70-71; and Forest Service 2012a, pp. 80-82). The detailed discussion of the analyses is not repeated in this EA and is instead incorporated by reference and summarized in this document. Alternative B would not include the application of herbicides directly to surface waters, and therefore, no direct impacts to surface quality are anticipated. In areas of the ROW near surface waters, herbicides registered for aquatic use would be used according to product label. Buffer zones would be established between treatment areas and water bodies to minimize impacts; the width of the buffer zones would be developed based on herbicide- and site-specific criteria and would include species-specific buffers identified in the biological assessment and evaluation documents (refer to Appendix E). The use of herbicides to control incompatible vegetation could have short-term, indirect impact on water quality. Similar to Alternative A, herbicide applications could reduce plant cover, leading to a potential increase in erosion, sedimentation, nutrient loading, and increase in water temperature due to the removal of shade trees. However, when compared to Alternative A, the rate of vegetation regrowth in areas treated with herbicide would be reduced which may contribute to minor increases in water temperature but because the ROW corridors having been continually maintained and only incompatible vegetation treated, this increase would be minor. Surface water quality could be indirectly affected by runoff, leaching, and drift of herbicides. The application of herbicides must be relatively persistent in order to have the potential for surface water runoff. Aminocyclopyrachlor, aminopyralid, chlorsulfuron, clopyralid, dicamba, glyphosate, imazapic, imazapyr, metsulfuron methyl, picloram, and sulfometuron methyl are anticipated to have low to moderate surface water runoff potential (Forest Service 2012a and Forest Service 2012b). According to the risk assessment isoxaben and 2,4-D, have no to very little runoff potential. Additionally, the risk assessments for fluroxypyr, tebuthiuron, and triclopyr indicate that the runoff potential is based on rainfall and soil type. Each identifying low potential for runoff and much less runoff expected from loam soils, and virtually no runoff is expected from predominantly sand soils. The use of the adjuvant Thinvert and the implementation of design features would reduce the potential impacts to surface waters. Similar to Alternative A, localized increase in runoff and sediment yield into waterbodies may be expected due to surface disturbance and decreased canopy. Adherence to product labels, the use of buffers, and proper application techniques would reduce the potential for herbicides to impact water quality. Additionally, application of herbicides by APS would be completed by or under the direction of a licensed applicator, and the closed chain-of-custody method would substantially reduce the potential for spills to occur. Any unintended releases would be cleaned up immediately and reported to the Forest Service per the PUP, applicator licensing, and ROW agreements. During application, drift of herbicides has the potential to degrade surface water quality when airborne as a result of application techniques, weather conditions, or applicator error. Spot, low-volume, use of Thinvert, and localized application techniques associated with Alternative B are less likely to result in drift because applications are targeted to specific plants. Additionally, the use of an adjuvant, such as Thinvert or an oil-based carrier, minimizes drift and drip. Application of herbicides applied directly to source plant material also has limited potential to be absorbed by the soil and migrate to surface waters or into groundwater aquifers. Even if an herbicide has a runoff or leaching potential, the likelihood of the herbicide reaching surface waters or groundwater aquifers would depend on site characteristics. Herbicides that are highly water soluble, relatively persistent, and not readily adsorbed by soil particles, such as clopyralid, dicamba, and picloram, have the greatest potential for movement into the groundwater. Sandy soils low in organic

59 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests content are the most susceptible to groundwater contamination (Forest Service 2005a). Implementation of design features related to not applying herbicides with high soil mobility in areas where soils could increase the potential for mobility would minimize potential impacts to groundwater. Alternative B would have no direct impact on groundwater quantity; no groundwater would be used in the application of herbicides. Potential indirect adverse impacts to groundwater quality from use of selected herbicides would not be detectable. Approximately 22 percent of the soils within the ROW are within the soil order Aridosols. These soils are prone to developing hardpans that limit depth of water, and consequently, the ability of herbicides reaching groundwater. Of the herbicides proposed for use in Alternative B, aminocyclopyrachlor, aminopyralid, imazapic, imazapyr, isoxaben, and tebuthiuron have an average half-life in soils greater than 90 days (Weed Science Society of America 2014). All of the other selected herbicides would decompose in a shorter time period. In addition, the foliar application of herbicides using the adjuvant Thinvert as the carrier would result in the herbicide adhering to the targeted plants and would minimize spray drift. The herbicide would also be more likely to remain on the plant reducing effects the potential to reach groundwater levels. It is unlikely that herbicides would reach aquifers, and no indirect impact to groundwater is anticipated. The use of IVM techniques under Alternative B would reduce the intensity and frequency of future mechanical and manual treatments, subsequently reducing potential impacts to water resources and water quality. With Alternative B, the routine vegetation maintenance requirement would decrease over time resulting in less area needing treatment and a reduction in the number of equipment, vehicles, and field crews within the ROW. Therefore, with the implementation of the proposed design features, Alternative B would have localized, short-term, direct, minor adverse impacts on water resources and water quality and localized, short-term, indirect, negligible beneficial impacts. Additionally, Alternative B would have localized, long-term, direct and indirect, moderate beneficial impacts on water resources by the decreasing the risk of future high-severity wildfire within the ROW and the reduced frequency and intensity of vegetation management treatments over time as compared to Alternative A.

3.5 Wetlands and Riparian Areas 3.5.1. Introduction Wetlands are generally defined as areas inundated by water at a frequency and duration sufficient to support vegetation that is typically adapted for propagation and growth in saturated soil. Executive Order 11990, Protection of Wetlands (3 CFR 1977) requires Federal actions to conduct an evaluation of effects to wetlands and to minimize impacts to wetlands. Riparian areas are water‐dependent ecosystems bordering streams, springs, and lakes. They form ecological links between the terrestrial and aquatic components of the landscape. Wetlands and riparian areas provide important ecological functions, including flood water attenuation, wildlife habitat, sediment trapping, and nutrient retention (BLM 2007). 3.5.2. Affected Environment Wetlands and riparian areas, including the perennial or ephemeral surface waters which support them, are scarce in Arizona with an estimated 0.5 percent of wetlands and riparian areas occupying the State’s total land area (Arizona Riparian Council 2004). The National Wetlands Inventory Program (NWI) produced by the U.S. Fish and Wildlife Service (USFWS) is a nationwide inventory of wetlands across the United States, which provides biologists and others with information on the distribution and types of wetlands to aid in conservation efforts. The NWI wetland data is derived from aerial photography that varies greatly in scale, resolution, and time of acquisition. Wetland mapping may differ in size and composition from actual ground conditions. According to the NWI, there are approximately 178.75 acres of wetlands within the ROW (refer to Table 3.5-1). Wetland types mapped throughout the ROW include freshwater forested/shrub wetlands, freshwater ponds, lakes, and riverine. The freshwater forested/shrub wetlands consist of both broad leaved and

60 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona needle leaved deciduous forested wetlands that are seasonally and temporarily flooded, as well as intermittently and seasonally flooded wetlands dominated by persistent woody shrub vegetation. Riverine wetlands are defined by wetland communities associated with riverine floodplains that are seasonally and temporarily flooded. These wetlands may also be found as littoral vegetated communities along streambeds and streambanks. The wetlands designated as ponds are all associated with impounded waterbodies, both natural and man-made. The wetland communities may be seasonally, intermittently, or permanently flooded. They are all considered palustrine wetlands that are characterized by persistent emergent forested, shrub, or marsh vegetation. Table 3.5-1 identifies the acreage of wetlands within the ROW by wetland type.

Table 3.5-1. NWI Wetland Type Acres within APS ROW Apache- Sitgreaves Coconino Kaibab Prescott Tonto Total Wetland Type National National National National National ROW Forests Forest Forest Forest Forest (acres) (acres) (acres) (acres) (acres) (acres) Freshwater Emergent 1.22 1.73 0.74 0.01 0.00 3.69 Wetland Freshwater Forested/ 0.07 0.41 0.01 0.73 15.19 16.41 Shrub Wetland Freshwater Pond 0.71 0.67 0.92 0.50 1.31 4.11 Lake 0.06 0.87 0.06 14.99 15.98 Riverine 13.84 19.25 14.38 29.95 61.12 138.55 178.75/ ROW Total/ Percenta 15.90/ 0.05 22.93/ 0.08 16.05/ 0.11 31.26/ 0.19 92.61/ 0.13 0.11 Source: USFWS 2016 a Percent represents the total of wetland acres in ROW by overall wetland acres in the respective national forest.

Riparian vegetation communities are influenced by landform, water availability, soil, elevation, and climate, as well as disturbance factors. These communities may consist of herbaceous or woody vegetation, or a combination of these two vegetation types. Presence and dominance are associated with vegetation species’ obligation or sensitivity to saturation, as well as the circumstances and conditions during which opportunities for establishment occur. Progression of a riparian community following changes in the physical characteristics of the site (particularly large changes in soil or water status) may result in a different potential natural community, that is, the vegetation that would be expected given environmental constraints (climate, geomorphology, geology) without human intervention or a hazard event (BLM 1992). Twelve riparian vegetation community types occur within the ROW for a total of 256.06 acres. Of these twelve riparian communities, Freemont Cottonwood/Shrub (54.61 acres), Sycamore - Fremont Cottonwood (49.87 acres), Fremont Cottonwood - Conifer (47.88 acres), and Desert Willow (38.38 acres) vegetation are the most prevalent totaling 190.74 acres (approximately 75 percent) within the ROW. Each of the vegetation communities is characterized by dense tree canopies and may have shrub understories composed of species such as arrowweed and desertbroom. Typical vegetation includes Gooding’s willow, velvet ash, box elder, and desert willow, Arizona walnut, willow species, juniper, hackberry, and velvet mesquite. Eight vegetation communities make up the remaining 25 percent of the project area (refer to Table 3.5-2).

61 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Table 3.5-2. Riparian Vegetation Community Types within APS ROW Apache- Sitgreaves Coconino Kaibab Prescott Tonto Riparian Vegetation Total National National National National National Community Type ROW Acres Forests Forest Forest Forest Forest (acres) (acres) (acres) (acres) (acres) Arizona Alder - Willow 0.00 0.08 0.00 3.09 0.00 3.17 Arizona Walnut 0.56 3.41 0.00 1.11 0.00 5.08 Desert Willow 0.00 0.10 0.00 32.74 5.53 38.38 Fremont Cottonwood/Shrub 2.98 4.42 0.01 8.44 38.76 54.61 Fremont Cottonwood - Conifer 0.00 0.00 0.00 0.00 47.88 47.88 Herbaceous Riparian 17.00 1.43 0.40 0.00 0.05 18.87 Historic Riparian - Agriculture 0.00 0.10 0.00 0.62 0.00 0.72 Historic Riparian - 0.00 0.04 0.00 0.00 0.00 0.04 Residential/Urban Narrowleaf Cottonwood/Shrub 16.30 2.11 0.00 0.00 2.54 20.96 Ponderosa Pine/Willow 0.00 0.00 0.48 0.41 14.48 15.37 Sycamore - Fremont 0.00 10.29 0.00 10.53 29.05 49.87 Cottonwood Willow - Thinleaf Alder 1.11 0.00 0.00 0.00 0.00 1.11 37.95/ 21.99/ 0.89/ 56.95/ 138.29/ 256.06/ ROW Total/Percenta 0.06 0.08 0.02 0.22 0.17 0.13 Source: Forest Service Southwestern Region Ecological Response Unit and Subclass (ERU) 2016a. a Percent represents the total of riparian acres in ROW by overall riparian acres in the respective national forest.

3.5.3. Design Features Design features applicable to wetlands, riparian areas, and floodplains are stated in Chapter 2. For design features related to manual and mechanical treatment methods, refer to Section 2.1.8; for design features related to herbicide treatment methods, refer to Sections 2.1.8 and 2.2.11. 3.5.4. Environmental Consequences Direct and Indirect Effects of Alternative A Vegetation removal and disposal activities in Alternative A would include only manual methods using tracked or wheeled vehicles, field crews, and hand equipment in wetland and riparian areas as identified in the design features. There are no poles with equipment that can spark within wetland or riparian areas, therefore no DSAP maintenance treatments would occur. This assessment of impacts assumes that the design features for manual treatment methods designed to reduce potential unintended impacts to wetlands and riparian areas would be followed for all vegetation management activities in Alternative A. Manual treatments would only occur at the margin of an emergent wetland, not within inundated or flooded wetlands. Riparian vegetation communities mapped within the ROW primarily consist of broad leaved and deciduous forested communities. These areas within the ROWs have been continually maintained as a result of ongoing manual vegetation treatment and are more open and less dense than adjacent riparian vegetation. Riparian and forested wetland vegetation within the ROW would continue to be maintained at a low height with targeted manual treatment of trees, tall shrubs, and other woody vegetation. Routine vegetation maintenance in riparian and forested wetland portions of the ROW would

62 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona tend to be more frequent than in upland areas because the vegetation tends to be relatively fast growing and in the case of tamarisks, capable of resprouting easily from cut stumps. In most cases, incompatible vegetation near a wetland or riparian area could be removed without disturbing non-targeted species. Typically, plant debris would be mulched. If adequate access is available for a chipper, or lopped and scattered and left on site. There would be no overland travel or use of ATVs within wetlands in the ROW. Vehicles would remain on existing roads and crews would walk to remove incompatible vegetation. Foot traffic within wetlands may trample some vegetation and result in some soil compaction; however these impacts would be short-term and negligible. Standing on and traversing streambanks and dry wash banks has the potential to destabilize soil and create the potential for localized erosion. Fuel and lubricant spills that could result from using chainsaws would be contained or cleaned up before contamination spread to surrounding sensitive areas. Alternative A is anticipated to have negligible effects on wetlands and riparian areas from manual treatment activities because ground disturbance would be limited and non-targeted vegetation would not be impacted. Furthermore, the vegetation within the ROWs in these areas has been continually maintained. Over the long-term, the routine vegetation maintenance would help control the spread of tamarisks and reduce the risk of wildland fire that could destroy compatible riparian and forested wetland vegetation. Therefore, Alternative A would have localized short-term, direct and indirect, negligible adverse impacts on wetlands and riparian areas because the use of only manual vegetation treatments and the implementation of the design features would limit any measureable effects to the resources. This would result in a long-term, direct, minor beneficial impacts to wetland and riparian areas by the overall routine control of tamarisk and long-term, indirect, minor, beneficial impacts by the reduction of hazardous fuels, reducing the risk of a future high-severity wildfire within the ROW. Direct and Indirect Effects of Alternative B In addition to the short-term, direct and indirect effects associated with Alternative A described above, Alternative B would also result in impacts on wetland and riparian areas from the use of herbicides as part of the management of incompatible vegetation within the ROW. In Alternative B, only Forest Service-approved herbicides would be used. Conservation measures and design features would be implemented for any herbicide application near bodies of water and within riparian, wetland, and aquatic habitat (refer to Section 2.1.8, Section 2.2.11, and Appendix E). In addition, the list of herbicides that would be used in riparian areas, wetlands, and near aquatic habitat has been narrowed down and provided in Table 3.5-3 below. This list does not include herbicides that can act as pre-emergent, herbicides that are soil active, herbicides that target grasses and forbs, and herbicides that target weed species that do not generally occur in riparian habitat. Any herbicides not on this list would only be applied outside of riparian, wetland, and aquatic habitat according to buffers listed in the conservation measures. Table 3.5-3. List of Herbicides Proposed for Use within Riparian and Wetland Vegetation and Adjacent to Aquatic Habitat

Anticipated Use Buffer Distance from Waterbody or Herbicide Active Ingredient Frequency* Wetland Aminocyclophrachlor Rare None Aminopyralid Frequent None Glyphosate (aquatic formulation) Frequent None Imazapyr Moderate None Fluroxypyr (acid formulation) Rare 30 feet Glyphosate (non-aquatic formulation) Frequent 30 feet Metsulfuron methyl Frequent 30 feet Triclopyr (amine salt formulation) Frequent 30 feet * Anticipated Use Frequency is based on current use and knowledge of herbicide products by APS.

63 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

The potential adverse effects to wetlands and riparian areas from the use of herbicides would be related to the amount, selectivity, and persistence of the herbicide used, application methods, and the specific plant species present. Spray drift can also degrade water quality in wetlands and riparian areas and could damage non-target vegetation. Application of herbicide within emergent wetlands would occur as a spot treatment of specific species where incompatible vegetation may occur. However these spot treatments would only occur at the margin of an emergent wetland, not within inundated or flooded wetlands. There are no pole locations within wetlands that would require DSAP treatment; therefore no herbicide applications would be necessary for complete vegetation removal at distribution line poles. Herbicides selected in Alternative B would use a low volume application method, and no broadcast or aerial application would be used. As with Alternative A, there would be no overland travel or use of ATVs within wetlands in the ROW. Vehicles would remain on existing roads and crews would walk to remove incompatible vegetation. Herbicide application in wetlands and riparian areas would be completed using backpacks with hand held sprayers using herbicides selected and labeled for aquatic use. Pre-emergent herbicides would not be used in riparian areas and wetlands based on design features. Within riparian areas, wetlands, and aquatic habitats, only herbicides that are approved for use in those areas would be applied (refer to Table 3.6-16). Most aquatic herbicides are non-selective and could cause adverse impacts to non-target wetland and riparian species. To minimize potential impacts to non-targeted species, herbicide application would be limited to backpack sprayers, as previously noted, and the adjuvant Thinvert would be used as the carrier. Thinvert, which is a paraffinic (waxy) oil carrier, would result in the herbicide adhering to the targeted plants and minimize spray drift. It acts as a drift control agent, each droplet spreading across the leaf surface to provide better contact and adsorption so that less product is needed to be effective. Because the herbicide would be more likely to remain on the plant and the potential for drift is minimized, the potential adverse effects on non-targeted species and soil resources would be reduced. Potential impacts to non-targeted species would also be minimized by the implementation of buffers for herbicide not approved for use in riparian areas, wetlands, and aquatic habitats according to the product label, risk assessment guidance, and conservation measures with minimum buffer widths of 10 feet for hand spray applications. Similar to Alternative A, herbicide applications could reduce plant cover, leading to a potential increase in erosion, sedimentation, nutrient loading, and water temperature. However, when compared to Alternative A, the rate of vegetation regrowth in areas treated with herbicide would be reduced which may contribute to minor increases in water temperature from the long-term conversion of areas to compatible, low-growing vegetation. Both Alternative A and B would remove forest cover in riparian areas potentially exposing more water surface to solar radiation in riparian areas. Alternative A would continue vegetation treatments to cut and remove incompatible vegetation on a routine maintenance cycle while Alternative B would use herbicides to reduce the potential for incompatible vegetation to regrow and instead establish low-growing subshrub or herbaceous cover. Risks to wetlands and riparian areas from surface runoff would be influenced by precipitation rates, soil types, and proximity to the application area. Since the ROW corridors have been continually maintained and only incompatible vegetation would be treated, short-term impacts from surface runoff would be similar to Alternative A. Some herbicides (e.g., sulfometuron methyl) that adsorb into soil particles could be carried off-site. These potential impacts would be localized and considered minor, short-term, adverse effects. Successful control of incompatible vegetation in wetlands and riparian areas would lead to improved conditions in these habitats over the long-term. The eventual transition to compatible vegetation in treated areas within the ROW would buffer the input of sediment and herbicides from runoff, and promote bank stability in riparian areas. Forested wetlands within the ROW may be treated with herbicides using targeted applications to recently cut tree stumps (cut-stump application) or new tree growth or resprouting one to two years following manual treatment of the vegetation (foliar application). The forested wetland type may include wetlands that are dominated by tamarisk. Tamarisk is extremely difficult to control through manual treatment

64 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona methods alone and is capable of resprouting easily from cut stumps. Targeted herbicide application within tamarisk stands would allow for more effective treatment and removal of the species from forested wetlands in the ROW. Tamarisk stands and other forested wetland types provide habitat for a variety of wildlife species. However, tamarisk would be maintained at a frequency in Alternative A that would not allow canopy development and would not be considered high value wildlife habitat. Refer to Sections 3.7 Federally Listed Species and 3.8 Forest Service Sensitive Species for detailed analysis of federally listed threatened and endangered species and sensitive riparian species. Alternative B would allow less frequent manual maintenance and would more effectively control the growth and recruitment of tamarisk and other incompatible riparian vegetation in the ROW. The eventual transition of forested wetlands to shrublands types would provide valuable wildlife habitat. Alternative B would have a long-term, beneficial impact resulting from the control of tamarisk stands and incompatible vegetation resulting in a reduction in frequency and intensity of manual treatments. Unintentional applications and spills could have detrimental effects for wetlands and riparian systems. In particular, accidental spills near wetland and riparian areas could be particularly damaging to wetland and riparian vegetation. A licensed applicator would supervise the application process to ensure that proper techniques, cleanup, personal protective equipment, and safety procedures are followed. The licensed applicator would comply with the operational and spill contingency plan prepared during the pesticide-use proposals process. Additionally, design features including the closed chain-of-custody would reduce the potential for spills (refer to Section 2.2.11 Alternative B Design Features). In Alternative B, the frequency and intensity of the routine vegetation maintenance in wetland and riparian areas would decrease over time resulting in less area needing treatment and a reduction in the equipment, vehicles, and field crews within the ROW. The eventual growth of compatible vegetation in treated areas would buffer the input of sediment and herbicides from runoff, and promote bank stability in riparian areas. Therefore, with the implementation of the design features, Alternative B would have localized, short-term, direct, minor, adverse impacts on wetlands and riparian areas and short-term, indirect negligible adverse impacts. Additionally, Alternative B would have long-term, moderate, direct and indirect, beneficial impacts on wetlands and riparian areas by more effectively controlling tamarisks, reducing the risk of a future high-severity wildfire, reducing the frequency and intensity of vegetation management treatments as compared to Alternative A, and by allowing low-growing native compatible vegetation within the ROW which would improve wetland and riparian habitat values.

3.6 General Vegetation 3.6.1. Introduction This section describes the general vegetation within the ROW and assesses the potential impacts to vegetation from the alternatives. The term “general vegetation” refers to all shrubs, grasses, trees, and cacti species (refer to Appendix D for Compatible and Incompatible Plant Species). Specific species of vegetation protected under State or Federal laws or regulations are assessed in more detail in Section 3.7 Federally Listed Species and Section 3.8 Forest Service Sensitive Species. The 2018 BA and 2018 BE (Forest Service 2018a; Forest Service 2018b) provides detailed vegetation information related to the power lines associated with specific species. Additionally, noxious and invasive weeds are discussed in Table H-1, Appendix H. Data presented in this section were compiled from a literature review and specific knowledge of the ROW. The Forest Service manages vegetation using FSMs for guidance, including FSM 2000, Chapter 2020 - Ecological Restoration and Resilience. The Forest Service has developed a guidebook for vegetation management with the central purpose of vegetation management to help ensure that public energy needs are reliably served without interruption from vegetation interference, while also ensuring people, wildlife, property, and lands are not harmed or threatened by wildfire caused by trees on power lines and other power-line related fires.

65 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

The Forest Service has developed the Forest Service National Desk Guide to Preparing Vegetation Management Procedures for Power Line Authorizations (Forest Service 2013a). The desk guide provides guidance and does not impose requirements for maintaining vegetation within the APS ROW. The applicability of this guidance may vary according to site-specific circumstances. It is impossible to create one set of vegetation management procedures for all landscapes. However, having agreed-upon guidance for managing vegetation within transmission and distribution ROWs across National Forest System lands helps provide a degree of consistency to Forest Service and APS staff in planning and conducting vegetation management. This consistency supports the delivery of safe, reliable electricity to the public while protecting National Forest System lands and other important natural resources. Successful vegetation management ensures that our national forests are conserved, restored, and made more resilient to climate change while enhancing our water resources. Integrated Vegetation Management is a component of the forest management program that is used to oversee reforestation and restoration of our national forests. Cacti and agaves are managed using the relevant protocol for the particular species. Columnar cacti (mostly saguaros) are slow growing but still have the potential to become a threat to the power lines as these cacti are full of water and conductive to electricity. Some agave species, although typically low- growing, may have stalks that grow up to 30 feet tall which can be a threat to power lines when growing under the right conditions. If the same agave species are growing in a location where the stalk would not pose a threat, the agave is left untreated. In other instances, only the removal of the agave stalk is necessary and the agave plant remains. 3.6.2. Affected Environment Arizona’s natural environment, including the areas within the ROWs, is characterized by a diversity of climate, soils, vegetation, and wildlife. The northern half of the State is composed of a series of plateaus and the southern half consists of deserts broken by numerous isolated mountain ranges. Like most arid and semiarid regions, Arizona is a land of great climatic contrasts. In the Sonoran Desert, freezing temperatures seldom, if ever, last longer than 24 hours, and summer temperatures are typically among the highest in the United States with daily highs often exceeding 100⁰F. Precipitation averages between two and 12 inches annually in the desert areas, depending on elevation, with well-defined winter and summer rainy seasons. Temperatures are much lower at higher elevations in the northern part of the State, and heavy snow events and below zero temperatures are common in winter. Annual precipitation can approach 60 inches at the higher elevations. Vegetation community types within Arizona are extremely varied as would be expected from the great diversity of topography, elevation, soils, and climate. There is a great diversity in plant life ranging from tall ponderosa pines and Douglas-fir trees of the high mountains to xerophytic low shrubs and grasses in the desert areas. In the Southwest the Forest Service uses a system of ecosystem types referred to as Ecological Response Units (ERUs), to facilitate landscape analysis and strategic planning. The Ecological Response Unit framework represents all major ecosystem types within the region and a coarse stratification of biophysical themes. Ecological Response Units are map unit constructs, technical groupings of finer vegetation classes of the National Vegetation Classification with similar site potential (Daubenmire 1968) and disturbance history. The suite of vegetation classes that make up any given ERU share similar disturbance dynamics, plant species dominants, and theoretical succession sequence (potential vegetation). The Ecological Response Unit system (formerly the potential natural vegetation types [PNVTs]) is a stratification of units with similar plant indicator species, succession patterns, and disturbance regimes that, in concept and resolution, are most useful to management. The Ecological Response Unit framework includes 31 terrestrial units, and eight associated subclasses (12 additional provisional subclasses are proposed), along with 21 riparian units (Wahlberg 2013).

66 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

The Arizona Public Service Company ROWs cross eight different vegetation system types and 34 different ERUs. Table 3.6-1 through Table 3.6-8 identify the ERUs present in each forest. Generally, the most prevalent vegetation system type within the ROW are woodland communities (43.58 percent) and forest (23.97 percent). Approximately 87 percent of the ROW falls within eight of the 34 ERUs, including Ponderosa Pine Forest, Colorado Plateau/Great Basin Grassland, Semi-Desert Grasslands, Interior Chaparral, Mojave-Sonoran Desert Scrub, Juniper Grass, Pinyon Juniper Evergreen Shrub, and Pinyon Juniper Woodland. The acreages within the remaining ERUs range between 0 and 3.39 percent and when combined make up approximately 13 percent of the ROW. Descriptions of the eight most prevalent vegetation system types have been included. Riparian vegetation communities consist of herbaceous or woody vegetation, or a combination of these two vegetation types. Twelve riparian ERUs occur within the ROW for a total of 256.06 acres. Because of their rarity and importance for wildlife, water, and the human environment, wetlands and riparian vegetation is a carefully managed resource and discussed further in Section 3.5 Wetlands and Riparian Areas.

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68 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Table 3.6-1. Forest Vegetation System ERUs Apache- Coconino Kaibab Prescott Tonto National Percent Sitgreaves Total National Forest National Forest National Forest Forest (of ROW National Forests (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ Acres/ of (ROW Acres/ Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) ERU Forest Acres) Mixed Conifer- 116.58/ 24.44/ 1.50/ 6.77/ 117.94/ 267.23/ 1.98/ Frequent Fire 116,507.48 46,998.71 127,760.32 6,544.55 51,656.79 349,467.85 0.08 Mixed Conifer with 136.00/ 7.04/ 0.00/ 0.05/ 0.00/ 143.09/ 1.06/ Aspen 155,905.36 79,711.89 9.22 28.54 6,773.65 242,428.66 0.06 Ponderosa Pine- 0.00/ 22.69/ 0.00/ 86.99/ 347.00/ 456.68/ 3.39/ Evergreen Oak 53,968.92 30,974.79 0.00 74,877.55 203,606.09 363,427.35 0.13 899.48/ 754.16/ 493.02/ 29.30/ 182.56/ 2358.52/ 17.52/ Ponderosa Pine Forest 640,128.55 734,106.98 552,381.29 29,814.27 37,371.01 1,993,802.10 0.12 0.00/ 1.92/ 0.00/ 0.00/ 0.00/ 1.92/ 0.01/ Spruce-Fir Forest 71,096.95 12,620.56 29,154.52 0.00 0.00 112,872.03 0.00 1152.06/ 810.25/ 494.52/ 123.11/ 647.50/ 3227.44/ 23.97/ Total Within ROW 1,037,607.26 904,412.93 709,305.35 111,264.91 299,407.54 3,061,997.99 0.11 Source: Forest Service 2016a

Table 3.6-2. Grassland Vegetation System ERUs Apache- Coconino Kaibab Prescott Tonto National Percent Sitgreaves Total National Forest National Forest National Forest Forest (of ROW National Forests (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ Acres/ of (ROW Acres/ Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) ERU Forest Acres) Colorado Plateau/ 305.22/ 42.55/ 400.90/ 1.14/ 0.00/ 749.81/ 5.57/ Great Basin Grassland 213,814.39 47,623.67 90,256.67 15,815.67 0.00 367,510.21 0.20 Montane/ Subalpine 0.00/ 79.22/ 87.86/ 0.00/ 0.00/ 167.08/ 1.24/ Grassland 63,925.05 53,031.28 40,668.92 0.00 0.00 157,625.25 0.11 0.00/ 308.47/ 0.00/ 618.38/ 541.39/ 1,468.24/ 10.91/ Semi-Desert Grassland 106,973.51 134,506.13 0.34 148,087.65 341,015.57 730,583.20 0.20 305.22/ 430.24/ 488.76/ 619.52/ 541.39/ 2385.13/ 17.72/ Total Within ROW 384,712.95 235,161.08 130,925.93 163,903.13 341,015.57 1,255,718.66 0.19 Source: Forest Service 2016a

69 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Table 3.6-3. Riparian Vegetation System ERUs Apache- Coconino Kaibab Prescott Tonto National Percent Sitgreaves National National National Total Forest (of ROW National Forests Forest Forest Forest (ROW Acres/ (ROW Acres/ Acres/ of (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ Forest Acres) Forest Acres) Forest Acres) ERU Forest Acres) Forest Acres) Forest Acres) Forest Acres) Arizona Alder- 0.00/ 0.08/ 0.00/ 3.09/ 0.00/ 3.17/ 0.02/ Willow 251.00 68.00 150.00 1,412.00 222.00 2,102.00 0.15 0.56/ 3.41/ 0.00/ 1.11/ 0.00/ 5.08/ 0.04/ Arizona Walnut 290.00 543.00 17.00 6,000.00 11.00 6,861.00 0.07 0.00/ 0.10/ 0.00/ 32.74/ 5.53/ 38.38 0.29/ Desert Willow 0.00 172.00 0.00 4,310.00 8,937.00 13,419.00 0.29 Fremont Cottonwood- 0.00/ 0.00/ 0.00/ 0.00/ 47.88/ 47.88/ 0.36/ Conifer 75 182 0.00 24.00 12,699.00 12,980.00 0.37 Fremont 2.98/ 4.42/ 0.01/ 8.44/ 38.76/ 54.61/ 0.41/ Cottonwood/Shrub 1,163.00 2,672.00 1,381.00 5,920.00 28,949.00 40,084.00 0.14 17.00/ 1.43/ 0.40/ 0.00/ 0.05/ 18.87/ 0.14/ Herbaceous Riparian 26,426.00 11,132.00 3,123.00 45.00 310.00 41,035.00 0.05 Historic Riparian- 0.00/ 0.10/ 0.00/ 0.62/ 0.00/ 0.72/ 0.01/ Agriculture 0.00 1,338.00 0.00 903.00 6.00 2,247.00 0.03 Historic Riparian- 0.00/ 0.04/ 0.00/ 0.00/ 0.00/ 0.04/ 0.00/ Residential/Urban 351.00 416.00 0.00 9.00 6,560.00 7,336.00 0.00 Narrowleaf 16.30/ 2.11/ 0.00/ 0.00/ 2.54/ 20.95/ 0.16/ Cottonwood/Shrub 18,558.00 2,257.00 0.00 0.00 1,823.00 22,638.00 0.09 Ponderosa 0.00/ 0.00/ 0.48/ 0.41/ 14.48/ 15.37/ 0.11/ Pine/Willow 175.00 4.00 86.00 661.00 6,022.00 6,947.00 0.22 Sycamore-Fremont 0.00/ 10.29/ 0.00/ 10.53/ 29.05/ 49.87/ 0.37/ Cottonwood 9,158.00 8,059.00 77.00 6,871.00 15,711.00 39,877.00 0.13 Willow-Thinleaf 1.11/ 0.00/ 0.00/ 0.00/ 0.00/ 1.11/ 0.01/ Alder 2,595.00 1,498.00 0.00 0.00 0.00 4,093.00 0.03 37.95/ 21.99/ 0.89/ 56.95/ 138.29/ 256.06/ 1.90/ Total Within ROW 59,936.00 28,387.00 4,859.00 26,156.00 81,773.00 201,110.00 0.13 Source: Forest Service 2016a

70 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Table 3.6-4. Riparian/Wetland Vegetation System ERUs Apache- Coconino Kaibab Prescott Tonto National Percent Sitgreaves Total National Forest National Forest National Forest Forest (of ROW National Forests (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ Acres/ of (ROW Acres/ Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) ERU Forest Acres) Freemont 0.00/ 0.30/ 0.00/ 0.53/ 3.96/ 4.79/ 0.04/ Cottonwood/Shrub 1,148.38 683.40 1,350.13 3,699.23 33,198.41 40,079.55 0.01 0.00/ 0.30/ 0.00/ 0.53/ 3.96/ 4.79/ 0.04/ Total Within ROW 1,148.38 683.40 1,350.13 3,699.23 33,198.41 40,079.55 0.01 Source: Forest Service 2016a

Table 3.6-5. Shrubland Vegetation System ERUs Apache- Coconino Kaibab Prescott Tonto National Percent Sitgreaves Total National Forest National Forest National Forest Forest (of ROW National Forests (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ Acres/ of (ROW Acres/ Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) ERU Forest Acres) Gambel Oak 0.00/ 0.00/ 2.12/ 0.02/ 0.00/ 2.14/ 0.02/ Shrubland 1,560.51 0.00 5,386.92 6.20 0.00 6,953.63 0.03 0.00/ 41.50/ 0.00/ 411.80/ 347.89/ 801.19/ 5.95/ Interior Chaparral 54,415.81 50,464.54 21.98 318,909.71 290,646.78 714,458.82 0.11 Mojave-Sonoran 0.00/ 6.47/ 0.00/ 9.00/ 851.62/ 867.09/ 6.44/ Desert Scrub 0.00 4,702.81 5.54 5,924.75 768,962.98 779,596.08 0.11 Mountain Mahogany 0.00/ 0.00/ 0.00/ 0.13/ 0.00/ 0.13/ 0.00/ Mixed Shrubland 16.82 2.60 1.02 15.11 0.00 35.55 0.37 0.00/ 0.00/ 25.31/ 0.00/ 0.00/ 25.31/ 0.19/ Sagebrush Shrubland 33.84 0.00 80,151.55 0.00 0.00 80,185.39 0.03 Sonora-Mojave 0.00/ 0.00/ 0.00/ 0.00/ 10.79/ 10.79/ 0.08/ Mixed Salt Desert 0.00 0.00 0.00 0.00 21,101.71 21,101.71 0.05 Scrub 0.00/ 47.97/ 27.43/ 420.95/ 1,210.30/ 1,706.65/ 12.68/ Total Within ROW 56,026.98 55,169.95 85,567.01 324,855.77 1,080,711.47 1,602,331.18 0.11 Source: Forest Service 2016a

71 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Table 3.6-6. Wetland Vegetation System ERUs Apache- Coconino Kaibab Prescott Tonto National Percent Sitgreaves Total National Forest National Forest National Forest Forest (of ROW National Forests (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ Acres/ of (ROW Acres/ Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) ERU Forest Acres) 17.00/ 1.43/ 0.40/ 0.00/ 0.05/ 18.88/ 0.14/ Herbaceous 21,945.62 9,776.23 1,709.23 24.28 302.91 33,758.72 0.06 17.00/ 1.43/ 0.40/ 0.00/ 0.05/ 18.88/ 0.14/ Total Within ROW 21,945.62 9,776.23 1,709.23 24.28 302.91 33,758.72 0.06 Source: Forest Service 2016a

Table 3.6-7. Woodland Vegetation System ERUs Apache- Coconino Kaibab Prescott Tonto National Percent Sitgreaves Total National Forest National Forest National Forest Forest (of ROW National Forests (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ Acres/ of (ROW Acres/ Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) ERU Forest Acres) 0.00/ 48.50/ 0.51/ 688.71/ 803.28/ 1,541.00/ 11.45/ Juniper Grass 96.71 28,542.86 41.48 97,483.29 414,112.66 540,277.00 0.29 Madrean Encinal 0.00/ 0.00/ 0.00/ 3.34/ 168.95/ 172.29/ 1.28/ Woodland 0.67 0.00 0.00 949.95 93,019.91 93,970.53 0.18 Pinyon-Juniper 0.00/ 211.31/ 0.00/ 737.78/ 755.93/ 1,705.02/ 12.66/ Evergreen Shrub 0.04 299,022.01 20.23 439,694.91 398,111.08 1,136,848.36 0.15 0.00/ 0.00/ 0.28/ 9.07/ 144.31/ 153.66/ 1.14/ Pinyon-Juniper Grass 44.73 17.40 47.97 21,664.30 74,238.38 96,012.78 0.16 Pinyon-Juniper 0.00/ 448.26/ 1,287.76/ 153.24/ 76.74/ 2,295.22/ 17.05/ Woodland 141,883.51 301,274.66 608,607.43 69,313.90 54,349.52 1,175,428.84 0.20 329.22/ 708.07/ 1,288.55/ 1,592.14/ 1,949.21/ 5,867.19/ 43.58/ Total Within ROW 142,025.66 628,856.66 608,717.20 629,106.44 1,033,831.55 3,042,537.51 0.19 Source: Forest Service 2016a

72 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Table 3.6-8. Human/Other Vegetation System ERUs Apache- Total Coconino Kaibab Prescott Tonto National Percent Sitgreaves (ROW National Forest National Forest National Forest Forest (of ROW National Forests Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ (ROW Acres/ Acres/ of (ROW Acres/ Forest Forest Acres) Forest Acres) Forest Acres) Forest Acres) Forest Acres) ERU Forest Acres) Acres) 0.00/ 0.00/ 0.00/ 0.00/ 8.22/ 8.22/ 0.06/ Sparsely Vegetated 1.92 8.51 10.03 0.01 1,263.02 1,283.49 0.64 0.11/ 1.68/ 0.24/ 0.99/ 12.78/ 12.78/ 0.12/ Water 2,093.25 3,047.68 276.99 176.26 22,288.05 27,882.23 0.06 0.11/ 1.68/ 0.24/ 0.99/ 21.00/ 24.02/ 0.18/ Total Within ROW 2,095.17 3,056.19 287.02 176.27 23,551.07 29,165.72 0.08 Source: Forest Service 2016a

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74 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

(Source: EdgeOfReason) Photograph 3-1. Ponderosa Pine Forest ERU - Coconino National Forest in Northern Arizona, near Flagstaff Ponderosa Pine Forest ERU makes up approximately 17.52 percent (2,358.52 acres) of the ROW and is widespread in the Southwest occurring at elevations ranging from 6,000 feet to 7,500 feet on soils from igneous, metamorphic, and sedimentary parent materials with good aeration and drainage, and across elevational and moisture gradients. As currently described, this ERU is comprised of both the “Ponderosa Pine Bunchgrass” and “Ponderosa Pine/Gambel oak” subclass concepts. The dominant species in this system is Ponderosa pine (Pinus ponderosa var. scopulorum). Other trees, such as Gambel oak (Quercus gambelii), pinyon pine (Pinus edulis), and juniper spp. (Juniperus spp.) may be present. There is typically a shrubby understory mixed with grasses and forbs, although this type sometimes occurs with extensive grasslands interspersed between widely spaced clumps or individual trees. This system is adapted to drought during the growing season, and has evolved several mechanisms to tolerate frequent, low intensity surface fires. The ROW crosses the Ponderosa Pine Forest in the each of the five forests.

75 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

(Source: Brennan 2008) Photograph 3-2. Characteristic Photo of the Colorado Plateau / Great Basin Grassland ERU Colorado Plateau/Great Basin Grassland ERU makes up approximately 5.57 percent (749.81 acres) of the ROW and is typically found along elevational and temperature gradients above Semi-Desert Grasslands and below Montane-Subalpine Grasslands. It occupies cooler and wetter sites than Semi- Desert Grasslands and is common above the Mogollon Rim. This ERU is typically associated with Pinyon-Juniper Grass along the grassland-woodland ecotone in cool climates. Vegetation coverage consists of mostly grasses and interspersed shrubs. Grass species may include but are not limited to: Indian ricegrass (Achnatherum hymenoides), threeawn spp. (Aristida spp.), blue grama (Bouteloua gracilis), fescue spp. (Festuca spp.), needle and thread grass (Hesperostipa comata), spike fescue (Leucopoa kingii), Muhlenbergia spp., James’ galleta (Pleuraphis jamesii), and Sandberg bluegrass (Poa secunda). Shrub species may include but are not limited to: sagebrush (Artemesia tridentate), saltbush (Atriplex spp.), Ephedra, snakeweed ( spp.), winterfat ( lanata), one-seeded juniper (Juniperus monosperma), Utah juniper (Juniperus osteosperma) and wax currant (Ribes cereum). As described, this ERU may have had over 10 percent shrub cover historically, but had less than 10 percent tree cover. The Arizona Public Service Company ROW crosses Colorado Plateau/Great Basin Grassland ERU in the Apache-Sitgreaves, Coconino, Kaibab, and Prescott national forests.

76 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

(Source: The Nature Conservancy) Photograph 3-3. Characteristic Photo of the Semi-Desert Grassland ERU Semi-Desert Grassland ERU makes up approximately 10.91 percent (1,468.24 acres) of the ROW and occurs throughout southeastern Arizona and southern New at elevations ranging from 3,000 to 4,500 feet. These grasslands are bounded by Sonoran or Chihuahuan desert at the lowest elevations and woodlands or chaparral at the higher elevations. Species composition and dominance varies across the broad range of soils and topography that occur within the two States. Dominant grassland associations/types are black grama (Bouteloua eriopoda) grassland, blue grama (Bouteloua gracilis) grassland, curly mesquite (Hilaria belangeri) grassland, tobosa (Pleuraphis mutica) grassland, giant sacaton (Sporobolus wrightii) grassland, mixed native perennial grassland, and non-native perennial grassland. Shrubs also occupy these grasslands and their abundance and species composition also varies. As described, this ERU may have had over 10 percent shrub cover historically, but had less than 10 percent tree cover. Semi-Desert Grasslands tend to occur adjacent to and above desert communities, and below Interior Chaparral and woodlands. The boundary between Semi-Desert Grasslands and desert communities is sometimes hard to distinguish as desert shrub species can be common in this ERU. The Arizona Public Service Company ROW crosses Semi-Desert Grassland ERU in the Coconino, Kaibab, and Tonto national forests.

77 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

(Source: Wahlberg 2013) Photograph 3-4. Characteristic Photo of the Interior Chaparral ERU Interior Chaparral ERU makes up approximately 5.95 percent (801.19 acres) of the ROW and is typically found on mountain foothills and lower slopes where low-elevation desert landscapes transition into wooded evergreens. Interior chaparral consists of mixed shrub associations including but not limited to the following species: Manzanita spp. (Arctostaphylos spp.), crucifixion thorn (Canotia holacantha), desert ceanothus (Ceanothus greggii), mountain mahogany (Cercocarpus montanus), little-leaved mountain mahogany (Cercocarpus intricatus), Antelope bushes (Purshia spp.), silktassles (Garrya spp.), Stansbury cliffrose (Purshia stansburiana), shrub live oak (Quercus turbinella), and sumacs (Rhus spp.). Historically this ERU had less than 10 percent tree canopy cover, maintained by relatively frequent, stand replacing fire events. As such, some sites that type as pinyon, juniper, or ponderosa pine associations that historically had sparse tree cover are grouped with the Interior Chaparral ERU. The Arizona Public Service Company ROW crosses Interior Chaparral ERU in the Coconino, Prescott, and Tonto national forests.

78 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

(Source: Wahlberg 2013) Photograph 3-5. Characteristic Photo of the Mojave-Sonoran Desert Scrub ERU Mojave-Sonoran Desert Scrub ERU makes up approximately 6.44 percent (867.09 acres) of the ROW and is found below 4,000 feet primarily on the Tonto National Forest though areas of this ERU are also found on the Prescott and Coconino national forests. Some areas within this ERU may be barren, with less than one percent cover, but most lands support succulents, desert grasses, desert scrub, and some herbaceous cover. Valley vegetation is typically dominated by a two to 25 percent cover of creosote bush (Larrea tridentata), with smaller associates that include bursage (Ambrosia deltoidea, Ambrosia dumosa). Alluvial fans in Sonoran regions with mild winters can be characterized by a diagnostic sparse, emergent tree layer of 15- to 30-foot-tall saguaro cactus (Carnegia gigantea) and 10- to 15-foot-tall palo verde (Parkinsonia microphylla) and ironwood (Olneya tesota), with creosote and bursage. Similar alluvial fans in the colder lose the frost sensitive saguaro but gain either Mohave Yucca (Yucca schidigera) or the larger (15- to 30-foot-tall) Joshua Tree (Yucca brevifolia), usually in the company of shrubs such as creosote, cheesebush (Hymenoclea salsola), blackbrush (Coleogyne ramosissima) and buckwheat (Eriogonum fasciculatum). Ephemeral watercourses can hold dense vegetation in both the Sonoran and Mojave deserts, especially catclaw (Acacia greggii) and wolfberry (Lycium spp). Most of this ERU is on steeper mountain slopes and associated colluvium. The ERU is characterized in the Sonoran desert by saguaro and palo verde, but with creosote replaced by up to 50 percent cover of small shrubs and trees such as brittlebush (Encelia farinosa), fairyduster (Calliandra eriophylla), and jojoba (Simmondsia chinensis). Desert mountains in the Mojave Desert lack the tall saguaros and palo verdes, but hold succulents such as the silver cholla (Cylindropuntia echinocarpa) and beavertail prickly pear (Opuntia basilaris), along with bursage (Ambrosia dumosa) and creosote. Invasive species are a special concern for this ERU. In southern Arizona, invasive species such as Sahara mustard (Brassica tournefortii) poses a danger to valley communities, especially those with sandy soils and buffelgrass (Cenchrus ciliarus) threatens the saguaro/paloverde communities. Further north, another invasive species, red brome (Bromus madritensis var. rubens), has introduced uncharacteristic fire into the Sonoran and Mohave deserts. The Arizona Public Service Company ROW crosses Mojave-Sonoran Desert Scrub ERU in the Coconino, Prescott, and Tonto national forests.

79 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

(Source: Wahlberg 2013) Photograph 3-6. Characteristic Photo of the Juniper Grass ERU Juniper Grass ERU makes up approximately 11.45 percent (1,541.00 acres) of the ROW and is typically found on warmer and drier settings beyond the environmental limits pinyon, and just below and often intergrading with the pinyon-juniper zone. The Juniper Grass ecosystem is generally uneven aged and very open in appearance, primarily on Mollisol soils. Trees occur as individuals or in smaller groups and range from young to old. A dense herbaceous matrix of native grasses and forbs characterize this type. Typical disturbances (fire, insects, and disease) are low severity and high frequency. These disturbance patterns create and maintain the uneven-aged, open-canopy nature of this type. The tree and grass species composition varies throughout the Region, consisting of a mix of one or more juniper species. Typically, native understory grasses are perennial species, while forbs consist of both annuals and perennials. Shrubs are characteristically absent or scattered. This type is typically found on sites with well-developed, loamy soil characteristics, generally at the drier edge of the woodland climatic zone. Overall these sites are less productive for tree growth than the Pinyon-Juniper Woodland Type. The Arizona Public Service Company ROW crosses Juniper Grass ERU in the Coconino, Kaibab, Prescott, and Tonto national forests.

80 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

(Source: FireScape) Photograph 3-7. Characteristic Photo of the Pinyon Juniper Evergreen Shrub ERU Pinyon Juniper Evergreen Shrub ERU makes up approximately 12.66 percent (1,705.02 acres) of the ROW and is typically found on lower slopes in transition zones, often between Interior Chaparral and montane forests, and is most extensive in geographic areas dominated by mild climate gradients and bi- modal precipitation regimes. The Pinyon-Juniper Evergreen Shrub ERU is a broad grouping of different plant associations for descriptive purposes, with tree and shrub species composition varying throughout the region. Historically, this ERU had greater than 10 percent tree canopy cover in later successional stages, expressed by twoneedle pinyon (Pinus edulis), single leaf pinyon (Pinus monophylla var. fallax), Utah juniper (Juniperus osteosperma), oneseed juniper (J. monosperma), or alligator juniper (J. deppeana). Pinyon is occasionally absent, but one or more juniper species are always present. Oak trees (i.e., Arizona white oak, gray oak, and Emory oak) are subordinate, but have high constancy in mild climate zones between central Arizona and southwestern New Mexico. Trees occur as individuals or in smaller groups and range from young to old, but typically small stands or clumps are even-aged in structure as a consequence of mixed severity fire (at least historically). The understory is dominated by low to moderate density shrubs, with herbaceous plants in the interspaces. Shrub species include Manzanita spp. (Arctostaphylos spp.), mountain mahogany (Cercocarpus montanus), Antelope bushes (Purshia spp.), silktassles (Garrya spp.), Stansbury cliffrose (Purshia stansburiana), turbinella oak (Quercus turbinella), and sumacs (Rhus spp.). The Arizona Public Service Company ROW crosses Pinyon Juniper Evergreen Shrub ERU in the Coconino, Prescott, and Tonto national forests.

81 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

(Source: Wahlberg 2013) Photograph 3-8. Characteristic Photo of the Pinyon-Juniper Woodland ERU Pinyon Juniper Woodland ERU makes up approximately 17.05 percent (2,295.22 acres) of the ROW and serves as a broad grouping of different plant associations for descriptive purposes. Trees may occur as individuals or in smaller groups and range from young to old, but more typically as large even-aged structured patches. The site is characteristically dominated by moderate to high density tree canopy, and understory herbaceous plants/shrubs are limited or scarce. Typical disturbances (fire, insects, disease, etc.) occur infrequently. These disturbance patterns create and maintain the even-aged nature of this type. Woodland development occurs in distinctive phases; ranging from open grass-forbs, to mid-aged open canopy to mature closed canopy forest. Tree and shrub species composition varies throughout the Region and common trees include twoneedle pinyon (Pinus edulis), single leaf pinyon (Pinus monophylla var. fallax), Utah juniper (Juniperus osteosperma), oneseed juniper (J. monosperma), and alligator juniper (J. deppeana). Typically, sparse native understory grasses are perennial species, while forbs consist of both annuals and perennials. Shrubs are characteristically sparsely- to moderately-distributed. This type is typically found on sites with rocky soil characteristics. The Arizona Public Service Company ROW crosses Pinyon Juniper Woodland ERU in all five forests.

82 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Vegetation and Soils There is a close relationship between soil type and vegetation. Vegetation plays an important part in the formation of soils from solid rock, and is particularly important in supplying the soil with organic matter. Different types of vegetation create different forms of organic matter in soils. Soil and vegetation exhibit an integral relationship in that soil gives support (moisture, nutrient, and anchorage) to vegetation to grow, and in return, vegetation provides protective cover for soil, reduces soil erosion, and helps to maintain soil nutrients through litter accumulation and subsequent decay (nutrient cycling). Vegetation strongly affects soil characteristics, including soil volume, chemistry, and texture, which in turn may affect vegetation characteristics, including productivity, structure, and composition.

Vegetation Management The ROWs were initially cleared during construction and are continually maintained to remove incompatible vegetation. As previously noted, incompatible vegetation includes plants under, above, and near power lines that could disrupt the safe, reliable, and continuous delivery of electricity to the APS customers. Power line ROWs have a lower density of tall growing vegetation than surrounding areas due to ongoing vegetation management. Only a portion of the acreage within the ROWs require treatment within a given maintenance cycle. In various regions of the ROW, the vegetation structure is not tall enough to pose a threat to the power line and would not need to be treated. For example, grasslands or shrub-lands within the ROW typically would not be a potential concern since these vegetation types do not grow tall enough to make contact or interfere with the utility infrastructure. However, some areas with very dense or taller shrubs (e.g., dense interior chaparral or pinyon juniper) may need to be cleared or thinned to reduce fuel loads (i.e., threat of fire). In some case, vegetation that may not necessarily grow tall enough to be a potential risk from contact may still be a concern and pose a fire threat. Interior chaparral vegetation, manzanita, tar bush, and juniper may pose a potential risk of wildfire because the vegetation burns at a higher temperature and the smoke produced holds a high carbon content. Build-up of carbon on the utility conductors would cause additional potential hazards for APS.

3.6.3. Design Features Design features applicable to vegetation are stated in Chapter 2. For design features related to manual and mechanical treatment methods, refer to Section 2.1.8; for design features related to herbicide treatment methods, refer to Sections 2.1.8 and 2.2.11.

3.6.4. Environmental Consequences Direct and Indirect Impacts of Alternative A Under Alternative A, vegetation would be removed manually and/or mechanically on routine vegetation maintenance cycles as described in Section 2.1.2. Manual and mechanical vegetation management would require over land travel by tracked or wheeled vehicles (e.g., ATVs or 4x4 trucks) to gain access to the treatment areas approximately every three to six years. Additionally, equipment such as chain, pole, and hand saws (manual devices) and/or masticators, chippers, and brushcutters (mechanical devices) would be used to conduct removal. Routine vegetation maintenance would be completed to maintain a reduced vegetation height, manage regrowth, and reduce fire potential. This assessment of impacts assumes that the design features for manual and mechanical treatment methods designed to reduce potential unintended impacts to vegetation would be followed for all vegetation management activities in Alternative A. This assessment also takes into consideration that the ROW corridors have been continually maintained and only incompatible vegetation would be treated.

83 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Manual methods make up the majority of APS’s routine vegetation maintenance activities. Manual treatments involving hand operated equipment would be selective and focused on target plants. With the current cutting techniques, the root system of individual plants would be left in place and relatively unaffected after the removal of the aboveground portion of the stem/tree trunk. In some cases this may perpetuate the growth of incompatible vegetation because of the biological response to rapidly resprout stems and reestablish enough leaves to support the root system. When a stem is cut, multiple sprouts can grow from the severed stump or the root system (also known as root-suckering). These sprouts are fast-growing because they are fed from a root system which is already well established. A repetitive cycle of cutting and sprouting can result in an increasing density of tall growing species (PG&E 2000). The rapid resprouting and increase in stem count would ultimately create a larger root mass. Manual treatments could benefit native communities by controlling woody shrub species, which have invaded desert grasslands and now occur in much greater densities than they have historically. These treatments, when timed correctly, can effectively control desert shrub species, such as creosote bush (Wood, et. al. 1991). Manual treatments would have a short-term benefit to native plant communities by removing encroaching woody species, and by stimulating the growth of understory forbs and grasses. Since the manual treatments only remove the aboveground portion of the plant, leaving the root system intact, there would be few lasting effects on non-target species that resprout because they would typically be able to recover quickly. Damage may occur to non‐target plants by trampling, breakage, and occasional mortality to individuals while workers are completing specific treatments. Indirect impacts may also occur from soil disturbance that could increase the germination of any seeds present, particularly since repeated treatments are often required to prevent the reestablishment of aggressive vegetation. Removal of vegetation as part of vegetation management treatments would create areas vulnerable to erosion and stormwater runoff, which could impact soils and vegetation, and increase sedimentation to surface waters (refer to Section 3.3.4.1 Soils and 3.4.4.1 Water Resources). The use of vehicles such as ATVs or 4x4 vehicles transporting crews to, or working within, the ROW could adversely affect native plant communities by bringing seeds of non-native species into treatment sites, creating opportunities for incompatible vegetation establishment. Additionally, ATVs and other vehicles which are spreading cut vegetation within the ROW would impact vegetation by compacting soils (refer to Section 3.3 Soils). Since manual treatments would occur on a routine basis (every three to six years), the repeated trips and activities within the ROW and/or treatments that remove larger areas of vegetation, could adversely affect native communities by altering the structure and diversity or species composition. Fuels and other chemicals used in association with manual treatments (e.g., from vehicles and/or hand-held equipment, such as chainsaw oils and gasolines) could also be released to the environment, potentially harming or killing vegetation. Manual vegetation treatments would also have indirect effects from the removal of hazardous fuels from the ROW. This would generally benefit the health of plant communities in which natural fire cycles have been altered. Continued historical wildfire management practices results in the buildup of dead plant materials (e.g., litter and dead woody materials), and often increases the density of flammable living fuels on a site (e.g., dead branches on living shrubs or live plants, especially during dry periods). The resultant fires burn hotter, spread more quickly, and consumes more plant materials than the historical fires that occurred under conditions of lower fuel loading. Treatments that restore and maintain fire-adapted ecosystems, through the appropriate use of routine thinning and other vegetation treatment methods, would decrease the effects from wildfire to communities and improve ecosystem resilience and sustainability. Vegetation treatments within the ROW would also reduce the incidence and severity of adjacent wildfires by creating a gap in vegetation or other combustible material, acting as a barrier to slow or stop the progress of a bushfire or wildfire. Mechanical methods would have the same effects that manual treatments would have relating to work crew site access. Mechanical treatments would also be selective and focused on target incompatible

84 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona vegetation but could impact non-target vegetation as a result of ground disturbance within the ROW. Mechanical methods may create greater ground disturbance and potentially expose barren soils, providing a greater opportunity for the introduction of non-native and invasive species to the landscape. Although mechanical treatment has the potential to result in greater disturbance, this treatment method is only used approximately five percent of the time. Mechanical equipment has larger cutting devices than chainsaws which makes it more difficult to only treat target vegetation. Mechanical treatments generally have the greatest effect on woody plant, and herbaceous plants would typically be more resilient to top-removal treatment methods, as many of these species die back annually (BLM 2007). Growth of herbaceous plants often increases after mechanical treatments as a result of reduced competition with woody species for light, nutrients, and water (Cox et al. 1982). Treatments occurring during the growing period and prior to seed maturation and dispersal would have the greatest potential effects on herbaceous species. Mechanical methods would be effective in removing thick stands of vegetation, although this method would require routine treatments to maintain. Potential additional or compounded effects to vegetation from mechanical treatments would include damage from the use of heavy vehicles, such as an increased soil compaction (which can lead to the puddling of water), scarification, and mixing of soil layers (Spencer et al. 1996). Reducing the potential for water infiltration due to the compaction of soils can hinder the re-establishment of seedlings or the growth of established vegetation. Mixing of mineral and organic layers influences the revegetation process as well (Beschta et al. 1995). The disturbance from heavy equipment and maintenance crews may result in the compaction and degradation of soils, thereby impacting the soil structure and reduce its ability to provide functions necessary for vegetation to thrive. Similar to manual treatments, repeated mechanical treatments could adversely affect compatible vegetation by altering species composition. Current ROW conditions have already been altered from the initial construction and routine vegetation maintenance resulting in altering species composition when compared to adjacent vegetation. Ongoing vegetation management is intended to maintain this existing condition. Successful mechanical treatments of pinyon-juniper would benefit native plant communities by reducing the occurrence of pinyon and juniper species, however with only a partial removal of trees mechanical treatments would only have a short-term benefit. Areas of pinyon-juniper would have to be retreated frequently because small trees and seedlings often survive these treatments and may rapidly regrow once free from competition (BLM 2007). DSAP maintenance activities would be completed around poles with electrical equipment that have a potential to spark as discussed in Section 2.1.2. Maintenance activities are consistent with the manual and mechanical treatments previously discussed, but would also use string trimmers to cut vegetation and hand rakes to remove all vegetation debris within the 10-foot radius (i.e., 20-foot diameter) around the base of the poles and up to a height of 10 feet. The total treatment area for this maintenance program would be approximately 10.20 acres of ROW on National Forest System lands across 1,418 pole locations. Because vegetation and debris would be completely removed to expose soil, it is assumed that soil compaction would occur within the entire 10-foot radius. Therefore, Alternative A would have short-term, moderate, direct and indirect, adverse effects to vegetation based on the ground disturbance from manual and mechanical equipment, ATVs, vegetation removal/disposal, and 4x4 vehicle uses in the ROWs. Over the long-term, the routine vegetation maintenance requirements in terms of the number of acres to be treated, the density of vegetation to be removed, and the number of work crew members, equipment, and vehicles required are anticipated to be relatively the same for each work cycle. Alternative A would have a long-term moderate direct and indirect adverse effect because the continued frequent disturbances and routine vegetation maintenance cycles would increase the effects of previous disturbance by disrupting the reestablishing vegetation and posing a continued risk for the introduction of noxious or invasive weeds.

85 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with Alternative A described above, Alternative B would employ the use of herbicides to augment current manual and mechanical methods of vegetation maintenance within the APS ROW. To prevent some incompatible plant species from resprouting, the entire root system must be removed. Herbicides interfere with specific botanical biochemical pathways of plants thereby assisting with the control of individual plants prone to resprout after the removal of the above ground portion of the plant. When trees that resprout or sucker are removed without herbicide treatment, dense thickets develop which could impede access, increase workloads and vegetation treatment costs, and potentially result in hazardous fuel loads. Herbicide application in conjunction with manual and mechanical treatments is a more effective treatment for incompatible vegetation. All herbicides would be used in conjunction with manual and mechanical treatments during the routine vegetation maintenance cycle and/or in subsequent years to treat regrowth and seedlings, as outlined in Section 2.2.6 Herbicide Vegetation Treatment Methods. Only Forest Service-approved herbicides would be used, which would also include the application of herbicides approved for pre-emergent use by the Forest Service for DSAP treatments. Selective herbicides would only affect certain plant species, whereas non-selective herbicides would affect all or most plant species. The non-selective herbicides include glyphosate, imazapyr, isoxaben, sulfometuron methyl, and tebuthiuron. The other herbicides (2,4-D, aminocyclopyrachlor, aminopyralid, chlorsulfuron, clopyralid, dicamba, fluroxypr, imazapic, metsulfuron methyl, picloram, and triclopyr) exhibit some selective qualities (refer to Table 2.2-2). Impacts to non- target vegetation are minimized by the design features, such as the application method, use of drift control agents, weather restrictions, and herbicide selectivity. Foliar application would be applied to the vegetation regrowth and young new growth vegetation, which is likely to be one to two growing seasons after manual or mechanical treatments (refer to Section 2.2.6 Herbicide Vegetation Treatment Methods). The following year after the initial herbicide treatment a second follow-up treatment would be completed to retreat localized vegetation that may have been missed or that may be in need of a second treatment at that time. This would require additional trips to the ROW in subsequent years after the initial manual or mechanical treatments. Herbicide treatment in the ROW would reduce the intensity of vegetation management efforts (manual, mechanical, and herbicide) over time through the establishment of a low growing compatible vegetation community as part of an IVM approach to vegetation management. With use of herbicides, and by encouraging the establishment of low-growing native communities in the ROW, the amount of vegetation treated during subsequent maintenance cycles would be reduced or potentially eliminated depending on the ROW conditions. This would result in less overland travel through vegetation communities which would in turn reduce disturbance and damage to vegetation by mechanical equipment (mowers), trucks, and ATVs. Since Alternative B would result in a reduction in the size of treatment areas, equipment, vehicles, and field crews within the ROW would also be reduced. Herbicide treatments completed at the same time as manual and mechanical methods include treatments for DSAP maintenance, hazardous vegetation removal, and cut-stump and basal application. Increased vegetation disturbance is anticipated during the vegetation cycle when these specific treatment methods are included. Because these treatments occur at the same time and in the same location as the manual and mechanical treatments, additional vehicles and field crew members typically would not be necessary. Additional foot traffic is anticipated from the use backpack sprayers, while additional overland travel may be required from the use of ATV-mounted sprayers. The combined treatments and additional work crew members and vehicles necessary would have a localized effect to vegetation from the slight increase in site activity. The Arizona Public Service Company would only use pre-emergent herbicide application in association with DSAP treatments, where vegetation would be completely removed from the 10-foot radius around poles housing equipment that could spark. This activity is proposed to occur within 10.20 acres of ROW

86 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona across 1,418 locations. Other treatment methods, such as manual methods are often not as effective at eliminating vegetation as the use of herbicides. Control of broadleaf plants by selective herbicides usually increases grass production. Herbicides such as glyphosate, metsulfuron methyl, picloram, tebuthiuron, and triclopyr are used to control woody species such as mesquite, creosote bush, and snakeweed. These herbicides usually decrease woody plant growth and increase growth of grasses, although it may take several years before grass and forb production increases in response to reduced competition from shrubs. Refer to Table 2.2-3 for more information regarding the herbicide, application method, and the use description. A detailed description and analysis of impacts to vegetation by the specific active ingredients are presented in the 2007 Herbicide PEIS and 2016 Herbicide PEIS, including a detailed description of effects to target and non-target vegetation by exposure scenario (direct spray, accidental spill to a pond, off-site drift, surface runoff, and wind erosion). The BLM analysis identified risk to non-target terrestrial and special status terrestrial plants associated from off-site drift would be low for aminopyralid, clopyralid, fluroxypyr, imazapyr, metsulfuron methyl, and triclopyr. Moderate risk is associated with chlorsulfuron, dicamba, and picloram. No risk was identified with imazapic, sulfometuron methyl, tebuthiuron, or glyphosate (BLM 2007 and BLM 2017). The herbicide, 2,4-D, was not evaluated for risk to non-target vegetation from off-site drift. The herbicide application rate is a major factor in determining risk, the higher the application rates the more likely to pose a risk to non-target vegetation. The Arizona Public Service Company would use a low volume spot application method to selectively apply the herbicide ingredients to target incompatible vegetation. Whether the herbicide comes in contact with non- targeted vegetation can also depend on the application technique. Because APS proposes to use low- volume spot herbicide applications to treat individual plants using handheld spray nozzles and drift control agents, there is little-to-no potential for the herbicide to contact non-targeted vegetation. Additionally, applicators must consider climate, weather (including wind), soil type, slope, and vegetation type when developing herbicide treatment programs. No aerial or broadcast application of herbicides would occur under the Alternative B, further reducing the potential to risk and impact to non-target vegetation. Herbicides have the potential to be carried to non-target plant by runoff, which is common when rainfall occurs shortly after the herbicide application. Prior to the application of herbicides the applicator would consider site characteristics, environmental conditions, and application equipment in order to minimize damage to non-target vegetation. Additionally, if there is a high probability of rain anticipated for the treatment areas, then applications would only occur when it is anticipated that there would be sufficient time (at least four hours) for the application to dry before rainfall occurs (refer to Section 2.2.11 Alternative B Design Features). Of the 16 proposed herbicides, 14 had no impact to vegetation (terrestrial and special status terrestrial plants) from surface runoff, one had a moderate risk (triclopyr), and one was not evaluated (2,4-D) (BLM 2007 and BLM 2017). The foliar application of herbicides using the adjuvant Thinvert as the carrier would result in the herbicide adhering to the targeted plants and would reduce spray drift and minimize drip off the plant onto vegetation and/or soil below. The use of Thinvert, which is a paraffinic (waxy) oil, would allow for ultra-low volume application, minimizing the volume of liquid applied and active ingredient used. Thinvert application minimizes drift and runoff when compared to water based-operations because the small droplets of active ingredients are captured within the waxy oil. The Thinvert mix is applied to the plant by making one slow, controlled pass of the hand wand across the targeted portion of the plant. The application is made using a special nozzle that produces small, uniform droplets that do not readily break up into finer droplets as water droplets do, thereby minimizing drift and drip (Waldrum Specialties 2002). Herbicide use with an oil-based carrier is typical with cut-stump treatment where the herbicide is applied with a hand wand targeting the stump of a recently cut tree. Cut- stump treatment method can be used selectively with no damage to surrounding vegetation. Additionally, since approximately 95 percent of the soils within the ROW has low to very low erosion susceptibility

87 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests rates and where the proposed herbicides have a low absorption rate, herbicides would tend to remain where applied with limited unintended transport from runoff (refer to Section 3.3 Soils). Herbicide treatment would require herbicide to be within the ROW in backpack sprayers or tank-mounted ATVs. A spill or leak of herbicides from storage tanks or malfunctioning equipment would result in potential overland flow of herbicides across a localized area of the landscape causing mortality to vegetation located within the spill area. Spills or leaks from small storage containers such as barrels or backpack sprayers would result in up to several gallons of herbicide in contact with vegetation in a localized area with minimal overland flow. Unintentional applications and spills could have adverse effects to vegetation. Chlorsulfuron, dicamba, aminopyralid, and fluroxypyr would have higher potential risk while picloram and tebuthiuron would have a moderate risk and aminocyclopyrachlor, imazapic, and isoxaben would have a low risk to non-target terrestrial and special status terrestrial plants as a result of an accidental spill. The herbicide, 2,4-D, was not evaluated and the remaining herbicide risks would vary depending on if the vegetation was terrestrial or special status terrestrial plants14 (BLM 2017). Design features were included as part of Alternative B to not only minimize the risk of spills through the use of closed chain-of-custody methods, but also to require the development of a spill contingency plan that outlines how spills would be contained and managed. ATVs would be driven at slow speeds and under certain conditions to reduce the risk of accidents, mixing of materials would occur off-site, and a closed chain of custody process reduces risk from open containers and potential for spills or leaks on-site (refer to Section 2.2.11 Alternative B Design Features). With these design features in place, the risk of spill would be limited to potential unforeseen equipment malfunction from ATV-mounted tanks and backpack sprayers. The highest risk to non-target vegetation from herbicide application generally would occur from accidental spill (BLM 2017). Due to the implementation of the closed chain-of-custody and operational and spill plan the chance of spills would be minimized. None of the herbicides were identified to pose risk under wind erosion scenarios. Effects to non-target plants would be minimal since Alternative B accounts for the implementation of the design features and would apply herbicides by spot treatment targeting only incompatible vegetation. Additionally, while columnar cacti and agave are sometimes treated using manual methods, Alternative B does not target agave or columnar cacti with herbicide. Indirect spray through drift could impact these plants; however, the use of Thinvert as a drift and drip control agent minimizes herbicide drift onto non- target plants and drip onto soil and underlying plants. It also would allow for ultra-low volume application, minimizing the volume of liquid applied and active ingredient used. Herbicides offer an effective and often resource efficient means of treating and managing unwanted vegetation. Mechanical and manual treatments are often more time and labor intensive than herbicide applications, and they would cause soil disturbance, which can provide the appropriate conditions for invasive weeds to resprout from roots or grow from dormant seeds. The use of Forest Service-approved herbicides would have beneficial effects to compatible plant communities by decreasing the growth, seed production, and competitiveness of target plants, which would relieve competitive pressures (e.g., water, nutrient, and space availability) to low-growing compatible vegetation. Additionally, plant communities adjacent to the ROWs would be benefitted by a reduction in wildfire risk. Conversely, Alternative B would result in the direct impact to some incompatible, native vegetation. The success of treatments would depend on numerous factors, and could require the use of a combination of methods to combat incompatible vegetation.

14 Sulfometuron methyl (no risk for terrestrial plants/high risk for special status terrestrial plants); clopyralid (high risk for terrestrial plants/no risk for special status terrestrial plants); glyphosate (moderate risk for terrestrial plants/low risk for special status terrestrial plants); imazapyr (high risk for terrestrial plants/moderate risk for special status terrestrial plants); metsulfuron methyl (high risk for terrestrial plants/low risk for special status terrestrial plants); and triclopyr (high risk for terrestrial plants/not evaluated for special status terrestrial plants).

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Therefore, Alternative B would have short-term moderate direct and indirect adverse effects to vegetation from the ground disturbance associated with the manual and mechanical treatments, vegetation disposal, herbicide use, and additional ATV and 4x4 vehicle uses in the ROWs. Alternative B would have long- term, direct and indirect, moderate beneficial impacts from the changes in the structure and composition of the vegetation in the ROW, a reduction in frequency and intensity of vegetation management treatments as compared to Alternative A, establishment of low-growing vegetation communities, and a reduction in the risk of future high-severity wildfire.

3.7 Federally Listed Species 3.7.1. Introduction The Endangered Species Act (ESA) was passed by Congress in 1973 (16 U.S.C. 1536) for the conservation of imperiled species and the ecosystems on which they depend. Under the ESA, species are listed or proposed for listing as “Endangered,” which is a species that is in danger of extinction, or “Threatened,” which is a species that is likely to become endangered within the foreseeable future. The Endangered Species Act protects listed species and their habitat by prohibiting “take” and the interstate or international trade of these species without a permit. Administration of the ESA is carried out by the USFWS for terrestrial and freshwater organisms (USFWS and National Marine Fisheries Service 1998). Section 7 of the ESA (1973, as amended) requires Federal agencies to ‘ensure’ that actions authorized, funded, or carried out by them are not likely to jeopardize the continued existence of threatened or endangered species, or result in the destruction or adverse modification of their critical habitats. The Endangered Species Act and 50 CFR 402 (Wildlife and Fisheries) direct each Federal agency to confer or consult with the USFWS on any action that is likely to jeopardize or affect the continued existence of a species or its habitat. Sections 7(b)(4) and 7(o)(2) of the ESA do not apply to the incidental take of listed plant species. However, protection of listed plants is provided to the extent that the ESA requires a Federal permit for removal or reduction to possession of threatened or endangered plants from areas under Federal jurisdiction, or for any act that will remove, cut, dig up, or damage or destroy endangered plants on any other area in knowing violation of any regulation of any State or in the course of any violation of a State criminal trespass law. 3.7.2. Affected Environment All federally listed and proposed species and designated and proposed critical habitats that are located within the five forests were considered in the 2018 BA (Forest Service 2018a). To determine which species to analyze, a species list was extracted on February 13, 2018 from the USFWS Information for Planning and Conservation (IPaC) tool by drawing a boundary around all of the five Forests included in the 2018 BA. The tool generated a list of the species including all threatened, endangered, and proposed species and their designated and proposed critical habitats occurring within the boundary. From this list, it was determined that these species do not occur within APS ROW and are not analyzed in the 2018 BA: black-footed ferret, California least tern, Yuma clapper rail, acuna cactus, Fickeisen plains cactus, San Francisco Peaks ragwort, and sentry milk-vetch. All species found in Table 3.7-1 through Table 3.7-6 may occur within the APS ROW and are analyzed in detail in the 2018 BA. Of the 21 species considered to be present or which have suitable habitat within APS ROW, six threatened species, 12 endangered species, and three experimental nonessential species were determined to be potentially present in the APS ROW (refer to Table 3.7-1 through Table 3.7-6). These include one amphibian, four birds, nine fish, three mammals, two plants, and two reptiles. In addition, nine species have designated critical habitat and three species have proposed critical habitat in the APS ROW. The amphibian, bird, mammal, and reptile species potentially present could occur in the APS ROW on an incidental basis while moving or foraging, whereas the plant species may occupy or be located directly

89 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests adjacent to the APS ROW. The fish species may be present within the APS ROW via waterways that bisect the APS ROW, or may occur in suitable habitat that is within proximity or downstream of the APS ROW. Although some individual federally listed species may occur within the APS ROW, no listed species are known to occupy the APS ROW exclusively. A brief description of each of the 21 federally listed threatened, endangered, and experimental, nonessential population species is provided below. A more detailed description of each species and associated habitat is provided in the 2018 BA (Forest Service 2018a). Table 3.7-1. Federally Listed Threatened, Endangered, and Experimental, Nonessential Population Species within APS ROW - Amphibians Common Name, Critical Habitat in National Forest Occurrence Statusa Scientific Name APS ROWb Chiricahua leopard frog, Apache-Sitgreaves, Coconino, Tonto T D Lithobates chiricahuensis a Status Definitions: T = Threatened, E = Endangered, XN = Experimental, Nonessential Population b Critical Habitat Definitions: D = Designated critical habitat, P = Proposed critical habitat, No = No critical habitat designated or proposed.

Table 3.7-2. Federally Listed Threatened, Endangered, and Experimental, Nonessential Population Species within APS ROW - Birds Common Name, Critical Habitat in National Forest Occurrence Statusa Scientific Name APS ROWb California condor, Coconino, Kaibab E, XN No (CA only) Gymnogyps californianus Mexican spotted owl, Apache-Sitgreaves, Coconino, T D Strix occidentalis lucida Kaibab, Prescott, Tonto Southwestern willow flycatcher, Apache-Sitgreaves, Coconino, E D Empidonax traillii extimus Kaibab, Prescott, Tonto Yellow-billed cuckoo, Apache-Sitgreaves, Coconino, T P Coccyzus americanus Prescott, Tonto a Status Definitions: T = Threatened, E = Endangered, XN = Experimental, Nonessential Population b Critical Habitat Definitions: D = Designated critical habitat, P = Proposed critical habitat, No = No critical habitat designated or proposed.

Table 3.7-3. Federally Listed Threatened, Endangered, and Experimental, Nonessential Population Species within APS ROW - Fish Common Name, Critical Habitat in National Forest Occurrence Statusa Scientific Name APS ROWb Colorado pikeminnow, No (CO, UT, and Coconino, Prescott, Tonto, E, XN Ptychocheilus lucius NM only) Desert Pupfish, No (None on AZ Tonto E Cyprinodon macularius Forests) Gila chub, Apache-Sitgreaves, Coconino, E D Gila intermedia Prescott, Tonto Gila topminnow, Tonto E No Poeciliopsis occidentalis occidentalis

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Common Name, Critical Habitat in National Forest Occurrence Statusa Scientific Name APS ROWb Gila trout, Tonto E No Oncorhynchus gilae Little Colorado spinedace, Apache-Sitgreaves, Coconino, T D Lepidomeda vittata Loach minnow, Apache-Sitgreaves, Coconino, E D Tiaroga cobitis Prescott, Tonto Razorback sucker, Apache-Sitgreaves, Coconino, E D Xyrauchen texanus Prescott, Tonto Spikedace, Apache-Sitgreaves, Coconino, E D Meda fulgida Prescott, Tonto a Status Definitions: T = Threatened, E = Endangered, XN = Experimental, Nonessential Population b Critical Habitat Definitions: D = Designated critical habitat, P = Proposed critical habitat, No = No critical habitat designated or proposed. Table 3.7-4. Federally Listed Threatened, Endangered, and Experimental, Nonessential Population Species within APS ROW - Mammals Common Name, National Forest Critical Habitat in Statusa Scientific Name Occurrence APS ROWb Mexican gray wolf, Apache-Sitgreaves XN No Canis lupus baileyi Ocelot, Tonto E No Leopardus pardalis a Status Definitions: T = Threatened, E = Endangered, XN = Experimental, Nonessential Population b Critical Habitat Definitions: D = Designated critical habitat, P = Proposed critical habitat, No = No critical habitat designated or proposed.

Table 3.7-5. Federally Listed Threatened, Endangered, and Experimental, Nonessential Population within APS ROW - Plants

Common Name, National Forest Critical Habitat in Statusa Scientific Name Occurrence APS ROWb Arizona cliffrose, Coconino, Tonto E No Purshia subintegra Arizona hedgehog cactus, Tonto E No Echinocereus triglochidiatus var. arizonicus a Status Definitions: T = Threatened, E = Endangered, XN = Experimental, Nonessential Population b Critical Habitat Definitions: D = Designated critical habitat, P = Proposed critical habitat, No = No critical habitat designated or proposed.

Table 3.7-6. Federally Listed Threatened, Endangered, and Experimental, Nonessential Population Species within APS ROW - Reptiles Common Name, Critical Habitat in National Forest Occurrence Statusa Scientific Name APS ROWb Narrow-headed gartersnake, Apache-Sitgreaves, Coconino, T P Thamnophis rufipunctatus Prescott, Tonto

91 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Common Name, Critical Habitat in National Forest Occurrence Statusa Scientific Name APS ROWb Northern Mexican gartersnake. Coconino, Tonto, Prescott T P Thamnophis eques megalops a Status Definitions: T = Threatened, E = Endangered, XN = Experimental, Nonessential Population b Critical Habitat Definitions: D = Designated critical habitat, P = Proposed critical habitat, No = No critical habitat designated or proposed.

Federally Listed Species within APS ROW – Amphibians

Chiricahua Leopard Frog (Lithobates chiricahuensis) The Chiricahua leopard frog was listed as threatened under the ESA in 2002 and critical habitat was designated in 2012. A recovery plan was prepared for the species in 2007. Since listing, evidence indicates that the overall population of Chiricahua leopard frogs in the United States is either static or, more likely, improving. There are 28.93 miles of designated critical habitat for the frog in the five forests (8.26 miles in Apache-Sitgreaves National Forests, 6.82 miles in Coconino National Forest, and 13.84 miles in Tonto National Forest). One APS ROW corridor occurs within Chiricahua leopard frog critical habitat; the ROW includes 0.05 mile of designated critical habitat where it crosses over Cherry Creek within the Tonto National Forest. There are no poles requiring DSAP treatment within or near Chiricahua leopard frog habitat (Forest Service 2018a). Chiricahua leopard frog populations in Arizona are divided into two areas: 1) the northern population (Mogollon Rim population), which extends from montane areas in central Arizona, east and south along the Mogollon Rim to montane parts of west-southwestern New Mexico; and 2) the southern population, which is located in the mountains and valleys south of the Gila River in southeastern Arizona and southwestern New Mexico, extending into Mexico. These federally listed amphibians are known to occur on the Payson Ranger District, Tonto National Forest and on the Red Rock Ranger District, Coconino National Forest. Since 1998, Chiricahua leopard frogs have been detected in and released at over 30 sites in creeks, springs, and stock tanks in the Gentry Creek and Upper East Verde Management Areas (MAs). Since the 1990’s, surveys for Chiricahua leopard frogs have been conducted by the AGFD and Tonto National Forest in both of these MAs. In 2014, 41 surveys were conducted at 23 sites in the Gentry Creek MA and 26 surveys were conducted at 15 sites in the Upper East Verde MA. Chiricahua leopard frogs were detected at 17 sites with breeding confirmed at 12 of these. Recent Chiricahua leopard frog survey data from 2013 to 2014 identified suitable, occupied habitat at multiple locations near five APS power lines, ranging from 0.3 mile to almost two mile from the APS ROWs (Forest Service 2018a).

Federally Listed Species within APS ROW – Birds

California Condor (Gymnogyps californianus) The California condor was listed as endangered under the ESA in 1967 and critical habitat was designated only in California in 1976. A recovery plan was prepared for the species in 1996. In Arizona, condors have been reintroduced and are part of an “experimental, nonessential population,” as characterized under Section 10(j) of the ESA (USFWS 1996). Roost sites include cliffs and tall trees, including dead trees (snags). Condors in Arizona spend the majority of their perching, roosting, and foraging time in locations such as the South Rim of Grand Canyon National Park and Vermillion Cliffs National Monument (Forest Service 2018a). There are multiple transmission and distribution power lines that occur within the California condor 10(j) experimental nonessential population area on Kaibab and Coconino national forests. The California condor 10(j) habitat covers 1,691,967.92 acres on National Forest System lands, including

92 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

396,418.18 acres on the Coconino National Forest and 1,295,549.74 acres on the Kaibab National Forest. The 10(j) area is located north of Interstate 40 (I-40) and bound to the east by U.S. Highway 191 (U.S. 191) and to the west by U.S. 93. The Arizona Public Service Company ROWs account for 2,097.10 acres of 10(j) area on National Forest System lands (524.28 acres on Coconino National Forest and 1,572.82 acres on Kaibab National Forest). California condors may fly as far south as Prescott National Forest, which is outside of the 10(j) area, so the total acres of suitable habitat within the ROW could be greater than the areas of ROW within the 10(j) area. There are a total of 285 poles that would receive DSAP treatment within the California condor 10(j) experimental nonessential population area, 159 of which occur on the Coconino National Forest and 126 occur on the Kaibab National Forest (Forest Service 2018a).

Mexican spotted owl (Strix occidentalis lucida) The Mexican spotted owl (MSO) was listed as endangered under the ESA in 1995 and critical habitat was designated in 2013. A recovery plan was prepared for the species in the 2012 Mexican Spotted Owl Final Recovery Plan (USFWS 2012c). Designated critical habitat for the MSO was published in 2004. In total, 421,423 acres is designated as critical habitat in the various river basins and areas throughout New Mexico and Arizona. Characteristics of suitable habitat include high canopy closure, high basal area, and the presence of dead trees (snags) and downed logs. Mexican spotted owls have also been found in relatively open shrub and woodland vegetation communities in arid canyonland habitat (Forest Service 2018a). Range-wide, this species is found in forested mountains and canyonlands from southern Utah, Colorado, Arizona, New Mexico, and western Texas south into several States in Mexico. Species distribution is not uniform throughout this range, but rather MSOs are found in isolated mountain ranges and canyon systems including the APS ROW on the five forests. Mexican spotted owl Protected Activity Centers (PACs), critical habitat, and recovery habitat also occur on these five forests. A Protected Activity Center is defined as “an area established around an owl nest (or sometimes roost) site, for the purpose of protecting that area”, and recovery habitat is defined as “areas outside of PACs managed as nest/roost, foraging dispersal, and wintering habitat [and includes] pine-oak, mixed-conifer, and riparian forests as well as rocky canyons.” The Arizona Public Service Company ROW transects recovery habitat, critical habitat, MSO PACs, and within one quarter mile of PAC boundaries on National Forest System lands15 (refer to Table 3.7-7). The analysis included this one-quarter mile buffer because some of the conservation measures would be applied to this buffered area outside the PACs. The Arizona Public Service Company ROW intersects with 39 MSO PACs and is within one-quarter mile of 22 additional PACs for a total of 61 PACs. A total of 15 poles that would receive DSAP treatment occur within MSO PACs, 828 poles that would receive DSAP treatment within MSO recovery habitat, and 261 poles that would receive DSAP treatment within MSO critical habitat. Table 3.7-7. Acres of APS ROW within MSO Critical Habitat, PACs, and Recovery Habitat by National Forest Total Designated MSO APS ROW Recovery Total Designated Critical Total PAC in within Habitat National Recovery Critical Habitat in MSO PAC APS 0.25 mile in APS Forest Habitat Habitat APS ROW (acres) ROW of PAC ROW (acres) (acres) (acres) (acres) (acres) (acres) Apache- 989,036.20 707.78 111,441.79 16.21 301.43 1,910,573.16 1,507.02 Sitgreaves Coconino 551,018.40 307.77 123,889.04 30.00 271.28 707,470.44 629.74

15 For PACs that are intersected by power lines, the portions of the power lines outside of the PAC but within one-quarter mile of the PAC are included in the calculations for project area within one-quarter mile of a PAC.

93 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Total Designated MSO APS ROW Recovery Total Designated Critical Total PAC in within Habitat National Recovery Critical Habitat in MSO PAC APS 0.25 mile in APS Forest Habitat Habitat APS ROW (acres) ROW of PAC ROW (acres) (acres) (acres) (acres) (acres) (acres) Kaibab 386,423.50 141.71 5,725.59 0 0.72 711,185.93 472.19 Prescott 82,451.69 75.94 9,986.65 16.01 49.34 212,543.09 201.39 Tonto 444,534.91 565.45 45,011.19 13.49 65.59 663,887.63 1,483.23 Total 2,453,464.69 1,798.66 296,054.27 75.71 688.36 4,205,660.26 4,293.57 Source: Forest Service 2018a.

Southwestern Willow Flycatcher (Empidonax traillii extimus) The southwestern willow flycatcher was listed as endangered under the ESA in 1995, and its critical habitat was designated in 2013. A recovery plan was prepared for the species in 2002, and a total of 1,227 stream miles are designated as critical habitat. Critical habitat is designated in 13 counties in Arizona, as well as counties in Utah, Nevada, Colorado, California, and New Mexico. The southwestern willow flycatcher is found in cottonwood/willow and tamarisk vegetation communities along rivers and streams at elevations below 8,500 feet. Nesting southwestern willow flycatchers prefer dense riparian thickets in areas where perennial flow, surface water, or saturated soil is present from April through September. The southwestern willow flycatcher can be found in Arizona during the nesting season from late April through August (Forest Service 2018a). Within the five forests, there are 13,541.85 acres of designated critical habitat for the federally listed flycatcher including 1,708.37 acres on Apache-Sitgreaves National Forests, 468.42 aces on Coconino National Forest, 501.26 acres on Prescott National Forest, and 10,863.80 on the Tonto National Forest. The Arizona Public Service Company ROW within designated critical habitat cover an area of 10.75 acres within APS ROWs (1.36 acres on Coconino National Forest, 2.55 acres on Prescott National Forest, and 6.84 acres on Tonto National Forest). A total of six poles that may receive DSAP treatment, with 0.04 acre, occur within critical habitat for the southwestern willow flycatcher. All six poles are located in upland habitat with no poles to be maintained within riparian habitat for southwestern willow flycatcher. For each of the locations where power line cross designated critical habitat for this species, APS presently maintains vegetation to conditions, which minimize the potential for interference with power lines. A review was conducted to determine if suitable habitat for southwestern willow flycatcher occurs within ROW outside of designated critical habitat. The review included evaluating ROW crossing riparian vegetation and assessment of vegetation community type structure, density, and extent. From this review, it was determined that there are no locations outside of designated critical habitat occurring within APS ROW. Thus, the areas of suitable habitat are the same as acres of designated critical habitat. The existing conditions within power line ROWs are currently not suitable breeding habitat for southwestern willow flycatchers and the habitat would never attain characteristics of breeding habitat while vegetation is managed to minimize interference with power lines. No nests would be expected to be present within the low-growing, open canopy vegetation maintained within the APS ROWs. There is the potential for southwestern willow flycatchers to be nesting in the adjacent riparian woodland vegetation yet it is unlikely that flycatchers would nest in trees along the edge of the ROW immediately adjacent to the open space created by the ROW. APS ROWs within and adjacent to stream channels would be suitable as foraging or migrating habitat.

94 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Yellow-billed cuckoo (Coccyzus americanus occidentalis) The western distinct population segment of the yellow-billed cuckoo was listed as threatened under the ESA in 2014, and its critical habitat was proposed in 2014. A recovery plan has not been prepared for the species. In total, 546,335 acres is proposed as critical habitat in Arizona, California, Colorado, Idaho, Nevada, New Mexico, Texas, Utah, and Wyoming. Proposed critical habitat within Arizona includes areas along the Colorado River, Gila River, Mule Creek, Bill Williams River, and Agua Fria River. In Arizona, yellow-billed cuckoos breed in large blocks of riparian habitat below 6,500 feet, particularly in cottonwood-willow, mesquite, ash, sycamore, and tamarisk forests with dense understory foliage (Forest Service 2018a). Within the five forests, there is 14,007.39 acres of proposed critical habitat on the Apache-Sitgreaves National Forests (2,219.44 acres), Coconino National Forest (2,092.84 acres), Prescott National Forest (2,259.19 acres), and Tonto National Forest (7,435.92 acres). The Arizona Public Service Company ROW intersects with approximately 6.72 acres of proposed critical habitat for the yellow-billed cuckoo on the Coconino National Forest (5.67 acres), Prescott National Forest (8.65 acres), and Tonto National Forest (24.64 acres). At each of the locations where the ROW crosses proposed critical habitat for this species, the ROW is currently maintained to favor low-growing grasses, forbs and shrubs and the vegetation is unsuitable for nesting western yellow-billed cuckoos. In addition, the project area was reviewed to determine if any ROW occurs within yellow-billed cuckoo suitable habitat outside of proposed critical habitat. From this review, it was determined that there are 6.59 acres of suitable habitat within the ROW outside of proposed critical habitat. A total of 10 poles that may receive DSAP treatments, comprising 0.07 acre, occur within proposed critical habitat for yellow-billed cuckoo and no poles that may receive DSAP treatment occur within suitable habitat outside of the proposed critical habitat (Forest Service 2018a).

Federally Listed Species within APS ROW – Fish

Colorado Pikeminnow (Ptychocheilus lucius) The Colorado pikeminnow was listed as endangered under the ESA in 1973, and critical habitat was designated in 1994. A recovery plan was prepared for the Colorado pikeminnow in 2002. This federally listed fish is endemic to the Colorado River Basin, where it was once widespread and abundant in warm water rivers and tributaries within the lower basin in California and Arizona. Now, wild populations of Colorado pikeminnow are found only in the upper basin, and the species currently occupies only about 25 percent of its historic range basin-wide. APS ROWs intersect the Salt River in one location and the Verde River in 11 locations. Colorado pikeminnow have been reintroduced into the Salt and Verde River systems as experimental nonessential populations. Of these, work in riparian vegetation is proposed in four locations. There are no poles that would receive DSAP treatment within the Colorado pikeminnow 10(j) experimental nonessential population area.

Desert Pupfish (Cyprinodon macularius) The desert pupfish was listed as endangered under the ESA in 1986, and critical habitat was also designated in 1986. A draft recovery plan was prepared for the species in 1993. Critical habitat for the desert pupfish was designated in 1986 at Quitobaquito Spring, Organ Pipe Cactus National Monument, Pima County, Arizona, and along portions of San Felipe Creek, Carrizo Wash, and Fish Creek Wash, Imperial County, California. The ROW does not cross any designated critical habitat for the desert pupfish (Forest Service 2018a). The desert pupfish was extirpated from Arizona, however, successful reintroductions at 16 locations have occurred throughout southern Arizona in a variety of small aquatic habitats. There are also 27 captive populations of desert pupfish in Arizona. Desert pupfish have been reintroduced into Walnut Spring and

95 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Mud Spring on the Tonto National Forest in 2007 and 2008. Mud Spring is the only population considered viable. There are other areas adjacent to National Forest System lands that have recently been stocked (Redfeild Canyon, Larry Canyon, Lousy Creek). Walnut Spring feeds into Alder Creek when runoff occurs. There is one APS ROW approximately 0.4 mile downslope of Walnut Spring where it crosses Alder Creek. At this location, the power line is high above Alder Creek with all proposed work occurring at and around the power line structures 0.4 mile from Walnut Spring and 220 feet upslope from Alder Creek. There are no APS power lines near Mud Spring. Arizona Game and Fish Department has long term plans to introduce Desert pupfish to Fossil Creek. There are two APS power lines that cross Fossil Creek at four locations (Forest Service 2018a).

Gila Chub (Gila intermedia) The Gila chub was listed as endangered under the ESA in 2005, and critical habitat was also designated in 2005. A draft recovery plan was prepared for the species in 2015. Gila chub commonly inhabit pools in smaller streams, springs, and cienegas and can survive in small artificial impoundments. They are highly secretive, preferring quiet, deeper waters and ponds or remaining under the cover of logs, boulders, and overhanging bank vegetation (Forest Service 2018a). Currently, all populations of the Gila chub occur in rivers, streams, and spring-fed tributaries of the Gila River Basin, central and southeastern Arizona, and possibly the northeastern tip of Sonora, Mexico. All Gila chub populations on the Apache-Sitgreaves National Forests are outside of the ROW. Within the five forests, there is 4,409.91 acres of designated critical habitat on the Apache-Sitgreaves National Forests (2,306.53 acres), Coconino National Forest (733.20 acres), Prescott National Forest (1,024.04 acres), and Tonto National Forest (346.13 acres). The Arizona Public Service Company ROW intersects with approximately 7.98 acres of critical habitat for the Gila chub on the Coconino National Forest (0.47 acre), Prescott National Forest (6.90 acres), and Tonto National Forest (0.62 acre). Four APS ROWs, intersect Gila chub critical habitat at seven locations including Spring, Indian, Silver, Sycamore, and Little Sycamore creeks. At Spring and Indian creeks, the ROWs do not cross over the creeks but are within the critical habitat near these creeks. There are no poles within Gila chub habitat that meet the conditions for treatment under the DSAP program. Work within riparian vegetation is only proposed at two locations where APS ROWs cross Silver and Sycamore creeks (Forest Service 2018a).

Gila Topminnow (Poeceliopsis occidentalis occidentalis) The Gila topminnow was listed as endangered under the ESA in 1967; critical habitat has not been designated for this species. A recovery plan was prepared for the Gila topminnow in 1984. Habitat requirements of the Gila topminnow are broad; they prefer shallow, warm, fairly quiet waters in ponds, cienegas, tanks, pools, springs, small streams, and the margins of larger streams. Dense mats of algae and debris along the margins of the habitats are an important component for cover and foraging. This species also occurred historically in the backwaters of large rivers, but it is currently isolated to small streams and springs (Forest Service 2018a). Range-wide, the Gila topminnow has been reduced from one of the most common fish of the Gila River Basin to one that exists in no more than 32 known locations—14 natural and 18 stocked—with an additional 20 captive populations in existence. Within Tonto National Forest, there are populations of Gila Topminnow in Bylas Spring, Cienega Creek, Coal Mine Spring, Cottonwood Spring, Fresno Canyon, Middle Spring, Monkey Spring, Salt Creek, Santa Cruz River San Rafael Tumacacori, and Sonoita Creek. During the next few years AGFD is proposing to stock Gila Topminnow into at least six new sites: Indian Creek, Sycamore Creek, and Little Sycamore Creek in Prescott National Forest; Walker Creek in Coconino National Forest; Hidden Water Spring and possibly Cottonwood Creek on Tonto National Forest. Eleven APS ROWs intersect Gila topminnow habitat at 12 locations (Tortilla Creek,

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Walnut Spring Cross F Allotment, and Sycamore Creek), and there are no poles requiring DSAP treatment near the threatened fish’s habitat (Forest Service 2018a).

Gila Trout (Oncorhynchus gilae) The Gila trout was listed as threatened under the ESA in 2006 and critical habitat has not been designated. A recovery plan was prepared for the Gila topminnow in 1979.The Gila trout prefers faster-moving water with cobble, sand, and gravel substrates with stable vegetated stream banks. They primarily feed on aquatic insects and terrestrial insect larvae and have been known to feed on small fish. They require clean substrates with low siltation for reproduction and spawning (Forest Service 2018a). Gila trout was stocked into Grapevine Creek on the Prescott National Forest in 2009 and Dude Creek on the Tonto National Forest in 2016 as recovery populations. It is too early to determine establishment for both of these populations. Additionally, Gila Trout were stocked into West Fork Oak Creek for recreational purposes in the fall of 2015. Gila Trout will also be stocked in Chase Creek on Tonto National Forest in spring of 2018 and in Ellison Creek in the future (Bush, Anthony and Jill Holderman Tonto National Forest Wildlife Biologist. 2018, personal communication). Additional supplemental stockings by USFWS and AGFD are likely to occur in the future (Forest Service 2018a). The 2003 Gila Trout Recovery Plan identifies Christopher Creek and East Verde River in Tonto National Forest and Oak Creek in the Coconino National Forest as potential restoration streams and treated as occupied habitat. Eight APS ROWs intersect Gila trout habitat at 30 locations; 17 of these crossings are associated with Oak Creek in the Coconino National Forest. There are 12 poles requiring DSAP treatment near the threatened fish’s habitat.

Little Colorado Spinedace (Lepidomeda vittata) The Little Colorado spinedace was listed as threatened under the ESA in 1987 and critical habitat was designated in 1987. A recovery plan was prepared for the Little Colorado spinedace in 1998. This species is typically found in shallow, slow-to-moderate-moving waters over fine sand/gravel bottoms. It may occur within open pools that have undercut banks, logs, or boulders for cover. The Little Colorado spinedace spawns in slow current over cobbles in the late spring into summer, and occasionally into the fall (Forest Service 2018a). Existing populations on the Apache-Sitgreaves National Forests are within Nutrioso Creek and one of its tributaries, Rudd Creek. In 2007, 95 fish were introduced into West Chevelon Creek. Potential recovery streams on the Apache-Sitgreaves National Forests also include Chevelon Creek and Willow Creek (and its tributaries). Leonard Canyon is the boundary between the Apache-Sitgreaves and Coconino national forests, and it is currently occupied by spinedace. On the Coconino National Forest, spinedace were found in Bear Canyon during the summer of 2009, but the only location known to maintain a population of Little Colorado spinedace is Leonard Canyon. There are several other locations in the East Clear Creek watershed that may be potential supplemental stocking sites if habitat conditions improve (Forest Service 1999). An aquatic organism passage project was completed on the forest in 2015 in Houston Draw to potentially open up that tributary for spinedace but the habitat has not been perennial during recent drought conditions (Forest Service 2018a). Within the five forests, there is 144.21 acres of designated critical habitat; however there are no APS ROWs that are within Little Colorado spinedace critical habitat. One APS power line ROW intersects spinedace suitable habitat at four locations across four creeks (Beaver Canyon, Chevelon Creek, West Chevelon Creek, and Willow Creek) on Apache-Sitgreaves National Forests, and there are no poles requiring DSAP treatment near the threatened fish’s habitat.

97 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Loach Minnow (Tiaroga cobitis) The loach minnow was listed as threatened in 1986 and uplisted to endangered under the ESA in 2012 and critical habitat was also designated in 2012. A recovery plan was prepared for the loach minnow in 1991. Loach minnow is found in small to large perennial streams below 8,000 feet with swift, shallow water over cobble and gravel, and they are sometimes associated with dense, filamentous green algae. This species prefers shallow riffles in moderate to large rivers with sand, gravel, and rubble substrate (Forest Service 2018a). Revised critical habitat for the loach minnow was finalized with the change in status from threatened to endangered. In total, approximately 179.51 miles are designated as critical habitat in the Gila River Basin within NSF lands (108.26 miles on Apache-Sitgreaves National Forests; 31.62 miles on Coconino National Forest; 34.39 miles on Prescott National Forest, and 5.24 miles on the Tonto National Forest). There are no APS ROWs encompassing critical habitat within this portion of the Apache-Sitgreaves National Forests; there is ROW within 0.11 mile on the Coconino National Forest, 0.11 mile on the Prescott National Forest, and 0.13 mile on the Tonto National Forest for a total of 0.35 mile of critical habitat. Loach minnows have not been recently collected in any streams within the APS ROWs except for Fossil Creek, which is co-managed by the Tonto and Coconino national forests. There are 12 power lines which intersect with loach minnow critical habitat at 19 locations of these rivers and creeks: Verde River and Beaver, Fossil, Oak, and Wet Beaver Creeks in the Coconino, Tonto, and Prescott national forests. There are three poles that may receive DSAP treatment along Oak and Wet Beaver Creeks in the Coconino National Forest and the Verde River in the Prescott National Forest.

Razorback Sucker (Xyrauchen texanus) The razorback sucker was listed as endangered under the ESA in 1991 and critical habitat was designated in 1994. A recovery plan was prepared for the razorback sucker in 1998. The razorback sucker is a medium-sized fish (up to 40 inches in length) that is oliveaceous to brownish black, with brownish or pinkish to reddish stripes on the sides and a lighter belly. Razorback suckers can be found in both rivers and lakes, occupying different habitats seasonally. Spawning usually occurs during spring, depending on temperatures, and evidence suggests that these fish may migrate to smaller tributaries to spawn (Forest Service 2018a) The razorback sucker was historically found throughout medium-sized to large rivers of the Colorado River Basin, but it has suffered substantial reductions in range and overall population size in the past 50 years. Razorback suckers have been stocked in the Salt and Verde Rivers and have been captured in Fossil Creek on National Forest System lands. There is approximately 179.4 miles of designated critical habitat on Forest Service land along the Colorado, Gila, Salt, and Verde rivers in Arizona. The five forests manage 3,261.10 miles of critical habitat including 11.07 miles on the Coconino National Forest, 198.31 miles on the Prescott National Forest, and 2,947.73 miles on the Tonto National Forest. The power line ROWs cross over 0.34 mile of critical habitat on the Coconino National Forest, 0.25 mile on the Prescott National Forest, and 1.45 miles on the Tonto National Forest for a total of 2.04 miles. APS ROWs intersect with razorback sucker critical habitat in 19 locations crossing Cherry and Fossil Creeks and the Salt and Verde Rivers and five along Oak Creek in suitable habitat. There is one pole that may receive DSAP treatment near Verde River in the Prescott National Forest (Forest Service 2018a).

Spikedace (Meda fulgida) The spikedace was listed as threatened in 1986 and uplisted to endangered under the ESA in 1991 and critical habitat was designated in 2012. A recovery plan was prepared for the spikedace in 1991. Spikedace habitat consists of moderate- to large-sized, shallow, perennial, moderately grade streams associated with riparian vegetation below 6,000 feet with sand, gravel, and/or cobble substrates. This

98 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona carnivorous fish generally feeds on insects and larvae of insects or fish. Spawning takes place in riffles or runs between April and June (Forest Service 2018a). There are two recently introduced populations on the Coconino National Forest in Spring Creek and Fossil Creek. The viability of these populations has not yet been confirmed though reproduction has been noted in Fossil Creek. Fossil Creek and Spring Creek are assumed to be occupied. Within the five forests, there are 240.81 miles of critical habitat: 88.39 miles on the Apache-Sitgreaves National Forests, 43.68 miles on the Coconino National Forest, 43.29 miles on the Prescott National Forest, and 65.44 miles on the Tonto National Forest. The Arizona Public Service Company ROW intersects with approximately 0.44 mile of critical habitat for the spikedace on the Coconino National Forest (0.15 mile), Prescott National Forest (0.12 mile), and Tonto National Forest (0.17 mile). APS ROWs intersect with spikedace habitat at the Verde River and Beaver, Oak, West Clear, Wet Beaver, Rye, Spring, Tonto, and Fossil Creeks with a total of 30 river or creek crossings (two of the crossings include more than one ROW at the Verde River and Oak Creek). There are four poles (two in the Coconino National Forest and one each in the Tonto and Prescott national forests) that may receive DSAP treatment (Forest Service 2018a).

Federally Listed Species within APS ROW – Mammals

Mexican Gray Wolf (Canis lupus baileyi) The Mexican gray wolf was listed as Endangered under the ESA in 1976 and critical habitat has not been designated. A recovery plan was prepared for the Mexican gray wolf in 1982. The Mexican gray wolf is the rarest, smallest, southernmost, and most genetically distinct of the five subspecies of gray wolves that once inhabited most of . Suitable habitat has minimal roads and minimal human development, as human access to areas inhabited by wolves can result in wolf mortality (Forest Service 2018a). Under the reintroduction program, captive-bred Mexican gray wolves have been released into the Blue Range Wolf Recovery Area within the Mexican Wolf Experimental Population Area (MWEPA). The Blue Range Wolf Recovery Area consists of the entire Apache and Gila national forests in east-central Arizona and west-central New Mexico, respectively; an area 6,845 square miles in size. The MWEPA is a larger area surrounding the Blue Range Wolf Recovery Area that extends from I-10 to I-40 across Arizona and New Mexico and a small portion of Texas (USFWS 2015a).The total acreage of the MWEPA on the five forests is 7,855,139.06 acres. Of this, 11,365.10 acres occur within APS ROW. Not all of the area within the MWEPA is suitable habitat for Mexican gray wolves. Mexican gray wolves are associated with montane woodlands characterized by sparsely to densely forested mountainous terrain consisting of evergreen oaks and juniper to higher elevation pine, mixed conifer forests, and adjacent grasslands at elevations of 4,000 to 5,000 feet where prey are abundant. A GIS analysis was conducted using this information to model suitable habitat for Mexican gray wolf and identified 1,431,062.01 acres of suitable habitat in higher elevations within National Forest System lands. From this model, 2,586.45 acres of ROW (244.24 acres on Coconino National Forest, 1,413.76 acres on Prescott National Forest, and 928.44 acres on Tonto National Forest) occur in vegetation types that have the potential to be suitable for Mexican gray wolf habitat (Forest Service 2018a). Total Mexican wolf occupied range on Apache-Sitgreaves and Tonto national forests is 1,649,615 acres. There are seven APS ROWs that occur within the occupied range for Mexican gray wolf, with a total of 1,594.66 acres (1,253.84 acres on the Apache-Sitgreaves National Forests and 340.81 acres on the Tonto National Forest). To date, no wolf locations have been recorded near the APS ROWS; the nearest power line ROW occurs approximately 35 miles from Mexican gray wolf locations as identified under the Mexican Wolf Recovery Program. However, Apache-Sitgreaves National Forests indicates that collared wolves have been moving across the Lakeside and Black Mesa Ranger Districts along the Mogollon Rim so some of these travel paths may have intersected APS ROWs on the Forest (DeRosier, Suzanne. 2018.

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Personal communication). There are 46 poles with equipment that could spark that would require DSAP treatment in the species occupied range (Forest Service 2018a)

Ocelot (Leopardus pardalis) The ocelot was listed as endangered under the ESA in 1982; critical habitat has not been designated for this species. A draft recovery plan was prepared for the species in 2010. The ocelot is listed as endangered throughout its range in the western hemisphere. Ocelots are secretive, nocturnal carnivores that inhabit dense vegetative cover (more than 75 percent canopy covering the northern part of its range). Habitats used by the ocelot throughout its range vary from tropical rainforest to pine forest to savanna, shrublands, and marshlands. Contiguous areas of vegetation are necessary for ocelot dispersal. Its prey consists primarily of rabbits, rodents, birds, and lizards (Forest Service 2018a). In April of 2010 an ocelot was found dead on the road along U.S. 60 between Superior and Miami, within the Globe Ranger District, Tonto National Forest. The dead ocelot was determined to be a wild cat and not an exotic pet. Since then, no other ocelot sightings have occurred in central Arizona. There is some suitable habitat for the species in the area on Globe Ranger District on the Tonto National Forest. Potential habitat for ocelot is defined as interior chaparral, Madrean encinal woodlands, and semi-desert grasslands. The Tonto National Forest estimates that there is approximately 226,242 acres of potential habitat for ocelot. A GIS analysis was performed on the APS ROWs to determine which ROW corridors occur on Tonto National Forest in suitable habitat. A total of 378.27 acres of ROW occur within suitable habitat on the Globe Ranger District. There are 16 poles covering 0.11 acre with equipment that could spark that would require DSAP treatment in the species habitat (Forest Service 2018a).

Federally Listed Species within APS ROW – Plants

Arizona Cliffrose (Purshia subintegra) The Arizona cliffrose was listed as endangered under the ESA in 1984 and critical habitat has not been designated. A recovery plan was prepared for the Arizona cliffrose in 1995. The Arizona cliffrose is generally found on rolling, rocky limestone hills and slopes within Sonoran desertscrub. Four widely separated populations of Arizona cliffrose occur in Arizona, including: Burro Creek Population, Cottonwood Population, Horseshoe Lake Population, and Bylas Population. APS ROWs on National Forest System lands fall within the Cottonwood Population, which is located east of Cottonwood, AZ. The Coconino National Forest has conducted surveys of this population and identified occupied habitat. Results of survey efforts suggest that Arizona cliffrose may be in decline in the Cottonwood population. An APS ROW occurs within the Cottonwood population with 0.46 acre of ROW that intersect with the 175 acres of occupied habitat identified by Coconino National Forest. Approximately 1.2 acres of ROW occur within or adjacent to the occupied habitat identified by Coconino National Forest. This 1.2 acres is considered as potentially suitable habitat, though not all of this area is likely to be suitable where soil type, slope, and aspect are not suitable for Arizona cliffrose. There are no poles that would require DSAP treatment within occupied habitat on National Forest System lands (Forest Service 2018a). The Coconino Forest Plan designated a 1,140-acre Verde Valley Botanical Area for the protection of a unique plant community, which includes Arizona cliffrose. This area is located north of State Route 89A (SR 89A), east of the Verde River, and west of Forest Road 761. Portions of APS ROW occur within the Verde Valley Botanical Area with a total of 4.97 acres of power line ROW with the designated botanical area (Forest Service 2018a).

Arizona Hedgehog Cactus (Echinocereus triglochidiatus var. arizonicus) The Arizona hedgehog cactus was listed as endangered under the ESA in 1979, and critical habitat has not been designated for this species. A recovery plan has not been prepared for the Arizona hedgehog cactus.

100 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

The Arizona hedgehog cactus is found at elevations ranging from 3,300 to 5,700 feet within the ecotone between the Madrean Evergreen Woodland and Interior Chaparral biotic communities. Preferred habitat for Arizona hedgehog cactus is exposed, stable bedrock and boulders exhibiting sufficient fracturing or rock interstices for establishment. The majority of Arizona hedgehog cacti are found scattered on open, rocky slopes of 20 to 90 degrees and on steep, fissured cliffs (Forest Service 2018a). The Arizona hedgehog cactus occupies a narrow geographic range between Superior and Globe in Pinal and Gila counties in central Arizona. A total of approximately 6,679 plants have been located; this number represents the best available scientific data on abundance counts. Of the 6,679 plants, 5,484 occur on Tonto National Forest. On the Tonto National Forest, there is 29,835 acres of potential habitat and 2,930 acres of occupied habitat. The ROW crosses 180.08 acres of potentially suitable Arizona hedgehog cactus habitat and 69.41 acres of ROW across occupied habitat. Survey for Arizona hedgehog cactus within one of the two ROWs in occupied habitat occurred in 2017. The survey occurred in 68.49 acres of occupied habitat and the survey found 420 individual Arizona hedgehog cacti within and adjacent to the power line ROW. There are three combustible-free space poles totaling 0.02 acre in potentially suitable Arizona hedgehog cactus habitat that may receive DSAP treatment and no poles within occupied habitat (Forest Service 2018a).

Federally Listed Species within APS ROW – Reptiles

Narrow-headed Gartersnake (Thamnophis rufipunctatus) The narrow-headed gartersnake was listed as threatened under the ESA in 2014 and critical habitat was proposed in 2013. The narrow-headed gartersnake is highly aquatic and preys on native fish and soft-rayed nonnative fish by foraging underwater. The narrow-headed gartersnake is strongly associated with clear, rocky streams; it predominantly uses pool-and-riffle habitat that includes cobbles and boulders. Shoreline habitat with shrubs and saplings is important for thermoregulation (e.g., basking) near the water’s edge (Forest Service 2018a). In order to determine where narrow-headed gartersnake suitable habitat occurs within APS ROW on national forest lands, areas where the ROWs intersect with perennial streams and rivers were identified. There were no areas identified outside of proposed critical habitat that are occupied by narrow-headed gartersnake where APS ROWs occur. There could be areas within proposed critical habitat that are not suitable for narrow-headed gartersnake however, all proposed critical habitat is assumed to be potentially occupied and/or contain suitable habitat for this federally listed gartersnake except where specifically noted in the BA. A total of 61,364 acres of proposed critical habitat occurs on National Forest System lands in Arizona, which includes 18,879.23 acres on the Apache-Sitgreaves National Forests; 8,199.23 acres on the Coconino National Forest; 6,280.17 acres on the Prescott National Forest and 28,005.61 acres on the Tonto National Forest. A total of 141.72 acres of APS ROW occur within proposed critical habitat for narrow-headed gartersnake including 1.09 acres in Apache-Sitgreaves National Forests, 55.51 acres in Coconino National Forest, 19.30 acres in Prescott National Forest, and 65.83 acres in Tonto National Forest. There are 56 poles with equipment that could spark that would require DSAP treatment in the species habitat (Forest Service 2018a).

Northern Mexican Gartersnake (Thamnophis eques megalops) The northern Mexican gartersnake was listed as threatened under the ESA in 2014, and critical habitat was proposed in 2013. A recovery plan has not been prepared for the species. Proposed critical habitat for the northern Mexican gartersnake was published in 2013. The northern Mexican gartersnake is generally found in riparian areas when not engaged in dispersal, gestation, or hibernation behaviors. It is also often found in streams, stock tanks, ephemeral pools, and spring sources within large-river riparian woodlands, forests, streamside gallery forests, and grasslands (Forest Service 2018a).

101 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

There were no areas identified outside of proposed critical habitat that are occupied by northern Mexican gartersnake where APS ROWs occur. There could be areas within proposed critical habitat that are not suitable for northern Mexican gartersnake. However, all proposed critical habitat is assumed to be potentially occupied and/or contain suitable habitat for this federally listed gartersnake except where specifically noted in the BA. A total of 29,608.78 acres of critical habitat occurs on National Forest System lands in Arizona, which includes 2,660.40 acres on the Apache-Sitgreaves National Forests; 7,141.79 acres on the Coconino National Forest; 6,876.14 acres on the Prescott National Forest and 12,930.45 acres on the Tonto National Forest. A total of 89.00 acres of power line ROW occur within proposed critical habitat for northern Mexican gartersnake including 34.47 acres on Coconino National Forest, 25.84 acres on Prescott National Forest, and 28.68 acres on Tonto National Forest. There are 16 poles with equipment that could spark that would require DSAP treatment in the species habitat (Forest Service 2018a).

Design features applicable to federally listed species are stated in Chapter 2. For design features related to manual and mechanical treatment methods, refer to Section 2.1.8; for design features related to herbicide treatment methods, refer to Sections 2.1.8 and 2.2.11. Additionally, biological resources conservation measures from the 2018 BA and 2018 BE have been included in Appendix E. 3.7.4. Environmental Consequences The 2018 BA prepared for this project analyzed effects to threatened, endangered, and experimental, nonessential population species due to the proposed herbicide application methods identified in this EA (Forest Service 2018a). A description of the direct and indirect effects on these species and their habitat from vegetation management activities associated with Alternatives A and B are presented in detail in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses on the potential effects from these management actions is not repeated here but is instead incorporated by reference and summarized below. In addition, toxicity class assessments16 for various categories of wildlife and fish are provided in Appendix H and conservation measures developed as part of the 2018 BA are found in Appendix E.

Federally Listed Species within APS ROW – Amphibians

Chiricahua Leopard Frog (Lithobates chiricahuensis) Direct and Indirect Effects of Alternative A Under Alternative A, routine aerial and ground inspections would be conducted and only manual methods would be used to maintain vegetation within the ROW. A description of the direct and indirect effects on the Chiricahua leopard frog and its habitat from inspections and manual maintenance treatments are presented in detail in the 2018 BA (Forest Service 2018a). There would be no mechanical or DSAP maintenance treatment within suitable habitat. The detailed discussion of the analyses on the potential effects from inspections and manual treatment provided in the 2018 BA (Forest Service 2018a) is not repeated here but is instead incorporated by reference and summarized below. The frequency of disturbance would create more opportunity for Chiricahua leopard frogs to be impacted; however, the implementation of conservation measures would minimize any potential impacts to the frog.

16 The toxicity classes refer to USFWS’s recommended protection measures based on a screening-level hazard assessment for chemical ingredients used as pesticides and herbicides. The chemicals are rated by a classification system that categorizes the level or type of protection to be given for a particular chemical with respect to toxicity for various groups of animal species such as warm water fish. Class 0 herbicides are practically nontoxic to a specific group of animal species that have similar toxicological responses. Class 1 herbicides are slightly to moderately toxic to a specific group of animal species that have similar toxicological responses. Class 2 herbicides are highly toxic to a specific group of animal species that have similar toxicological responses. Class 3 herbicides are very highly toxic to a specific group of animal species that have similar toxicological responses (refer to Appendix G).

102 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

The presence of humans associated with ground inspections and manual treatment of vegetation may temporarily displace Chiricahua leopard frogs in the ROW. Adult frogs typically avoid terrestrial predators or unknown threats by jumping into water to avoid confrontation. The ROW contains 0.17 percent of the total Chiricahua leopard frog designated critical habitat on National Forest System lands. Direct effects to Chiricahua leopard frogs from helicopter surveys would not occur because flights occur at heights above the ground such that a flight response from frogs would be unlikely. Trampling individual frogs while traveling to and from ROWs during ground surveys would be unlikely because travel generally occurs on existing open roads and access routes already traveled on a regular basis by APS and the public. Travel within riparian areas and wetlands only occurs on existing roads as identified in the species conservation measures, but travel may occasionally occur off-road outside or riparian areas and wetlands. However, the chance that this travel would occur at the same location as a Chiricahua leopard frog that is dispersing overland is so unlikely and remote as to be discountable. Hazard vegetation may be removed by bucket truck and ground based activities. The truck would remain on existing roads and, it would be unlikely that the bucket truck would tread on frogs. It is also unlikely that human foot traffic would result in trampling. The mechanical equipment would not operate within any washes, cienegas, springs, pools, tanks, lakes, reservoirs, streams, and rivers occupied by frogs. Disposal of vegetation would not be likely to occur directly within occupied habitat, but may be disposed of within suitable habitat. It is unlikely that the disposal of vegetation would cause direct effects to Chiricahua leopard frog (Forest Service 2018a). Indirect effects to habitat from the spread and introduction of disease organisms would be negligible because of the conservation measures that would be implemented when completing activities in occupied sites including the required washing of equipment and shoes between occupied sites (refer to Biological Resources Conservation Measures in Appendix E). Removal of hazard vegetation could alter habitat by slightly increasing sediments to occupied and suitable habitat or by removing vegetation that contributes to habitat characteristics. The occupied Chiricahua leopard frog sites that occur within the ROWs are at multiple locations near fivepowerline ROWs. No incompatible vegetation is expected to occur at one of the ROWs and the other ROW has a stock tank. For the stock tank, hazards would be felled away from the power lines and structures. There would be no increase to sedimentation in the stock tank. The potential of sedimentation from incompatible vegetation is unlikely in suitable habitat as well because vegetation management activities would occur relatively infrequently. Sedimentation could result in effects to prey and eggs, however, because sedimentation in suitable and occupied habitat is unlikely, effects to Chiricahua leopard frog would be negligible. It is expected that the organic debris and downed logs deposited on the forest floor from routine vegetation maintenance would benefit upland frogs by providing structure for cover and potential foraging. Indirect effects to Chiricahua leopard frogs would not be detectable because treatments would be limited to manually cutting of regrowth vegetation and pruning mature trees at the edge of the ROW. The lower growing shrubs, grasses, and forbs would remain untreated. Removal of vegetation within APS ROW would not cause any detectable negative effects to Chiricahua leopard frog habitat (Forest Service 2018a). Therefore, Alternative A would result in short- and long-term, direct and indirect, negligible adverse impacts to the Chiricahua leopard frog because the potential for direct contact with the species would be unlikely and their aquatic habitat would not be measurably disturbed. In addition, the 2018 BA has made the determination that the Alternative A “may affect, but is not likely to adversely affect” 17 the Chiricahua leopard frog or its habitat.

17 In order to meet the ESA Section 7 regulatory requirements for an action that is being propose to implement, fund or authorize, the Forest Service must make one of the following preliminary determinations with respect to threatened or endangered species or designated critical habitat: 1.) No effect; 2.) May affect, but is not likely to adversely affect; or 3.). May affect, and is likely to adversely affect. These effects determinations must be based on all direct and indirect effects of the actions under consideration. The 2018 BA has made an effects determination for all vegetation management activities within APS ROWS, which includes the application of Forest Service-approved herbicides in addition to manual and mechanical treatment as part of APS’s integrated vegetation management program. Consequently, the ESA Section 7 determination of effects will be the same for both alternatives analyzed in this EA.

103 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with the Alternative A described above, Alternative B would also result in impacts on the Chiricahua leopard frog from the use of herbicides as part of the management of incompatible vegetation within the ROW. A description of the direct and indirect effects of herbicide treatments on the Chiricahua leopard frog and its habitat are presented in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses is not repeated here but is instead incorporated by reference and summarized in this section of the EA. There would be no mechanical or DSAP maintenance treatment within suitable Chiricahua leopard frog habitat. Chiricahua leopard frogs could be unintentionally sprayed by herbicides during application. However, herbicides would not be directly applied to the water, and frogs are most likely to retreat to aquatic environments because of human presence during treatment. If in the unlikely event that direct contact of herbicides with Chiricahua leopard frogs would occur, only herbicides would be used within the areas of suitable habitat that have a toxicity rating of practically non-toxic to avoid any potential individual frog mortality or negative health effects. Herbicide treatments would be limited to spot applications to individual plants within the ROW, which would minimize overspray and avoid direct impacts to frogs. The quantity of vegetation treated over the ROW area is low with grasses, forbs, and lower growing shrubs remaining untreated. Changes in vegetation composition affecting Chiricahua leopard frog habitat due to herbicide application would be minimal and insignificant. The application of Forest Service-approved herbicides over time would reduce the frequency of the vegetation treatment, which would result in a reduction in humans and vehicles associated with vegetation management within the APS ROW (Forest Service 2018a). Indirect effects to Chiricahua leopard frogs would be limited to manually cutting of regrowth vegetation, pruning mature trees at the edge of the ROW, and spot applications of herbicide to individual plants within the ROW. Thinvert, a drift and drip reduction agent would be used to minimize surface runoff and any drift of herbicide onto non-target plants (Forest Service 2018a). With the implementation of the species-specific conservation measures listed in Appendix E, only herbicides with low toxicity to Chiricahua leopard frogs would be used within suitable habitat, buffers would be designated to exclude the use of higher toxicity herbicides near suitable habitat, and the timing of application would be limited to times when the possibility of precipitation is low. Therefore, Alternative B would result in direct and indirect, short-term, negligible adverse impacts to the Chiricahua leopard frog because the potential for direct contact with the species would be unlikely and their designated critical and suitable habitat within the ROW would not be measurably disturbed. There would also be long-term, direct and indirect, negligible beneficial impacts to the Chiricahua leopard frog because the frequency of routine vegetation maintenance would decrease, which would reduce the presence of workers and noise from handheld equipment within suitable habitat. In addition, the 2018 BA has made the determination that the Alternative B “may affect, but is not likely to adversely affect”18 the Chiricahua leopard frog or its habitat.

18 In order to meet the ESA Section 7 regulatory requirements for an action that is being propose to implement, fund or authorize, the Forest Service must make one of the following preliminary determinations with respect to threatened or endangered species or designated critical habitat: 1.) No effect; 2.) May affect, but is not likely to adversely affect; or 3.). May affect, and is likely to adversely affect. These effects determinations must be based on all direct and indirect effects of the actions under consideration. The 2018 BA has made an effects determination for all vegetation management activities within APS ROWS, which includes the application of Forest Service-approved herbicides in addition to manual and mechanical treatment as part of APS’s integrated vegetation management program. Consequently, the ESA Section 7 determination of effects will be the same for both alternatives analyzed in this EA.

104 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Federally Listed Species within APS ROW – Birds

California Condor (Gymnogyps californianus) Direct and Indirect Effects of Alternative A Under Alternative A, routine aerial and ground inspections would be conducted along with manual and mechanical vegetation treatment methods within the ROW. A description of the direct and indirect effects on the California condor and its suitable habitat from inspections and routine vegetation maintenance treatments are presented in detail in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses on the potential effects from the Alternative A is not repeated here but is instead incorporated by reference and summarized below. It is highly unlikely that California condor nest sites occur within or near the ROW since condors generally roost on cliffs and tall conifers, including dead snags, none of which occur within the ROW. Any interaction with condors during vegetation treatment would likely be with transient condors. California condors are naturally curious birds and may be attracted to vegetation treatment activities along the ROWs, which could result in unintended human/condor interaction. Displacement of individual condors from foraging may occur due to disturbance associated with vehicles including ATVs, chainsaw use, and aerial inspections. Condors within and outside of the 10(j) experimental nonessential population area may be affected as a result of potential condor/helicopter collisions. However, the likelihood of these effects would be discountable because of the low density of ROWs in the Grand Canyon Ecoregion/Colorado River corridor, where condor activity is concentrated (Forest Service 2018a). Therefore, Alternative A would result in short- and long-term, direct and indirect, negligible adverse impacts to the California condor and its habitat. With regards to the ESA, the 2018 BA has made the determination that Alternative A “may affect, but is not likely to adversely affect” the endangered California condor or its habitat and is not likely to jeopardize the experimental nonessential population of the California condor. Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with Alternative A described above, Alternative B would result in impacts on the California condor experimental, non-essential population and its suitable habitat from the use of herbicides as part of the management of incompatible vegetation within the ROW. A description of the direct and indirect effects of herbicide treatments on the California condor and its experimental, non-essential population area are also presented in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses is not repeated here but is instead incorporated by reference and summarized in this section of the EA. Vegetation is sparse in all areas within the California condor experimental population area. Herbicide application activities would be short in duration on a given ROW and targeted to individual plants. Thinvert would be used to minimize drift onto non-target plants. Any potential human/condor interactions would be localized as well as brief and unlikely to result in displacement of individual birds. Implementation of conservation measures by identifying known nests, roosts, and release sites and applying a 0.25 mile buffer would further reduce the likelihood of any human interaction with California condor. During low volume foliar application of herbicides within the ROWs, it is unlikely that condors would be exposed to direct spray due to their ability of flight (Forest Service 2018a). Indirect effects could occur if California condor fed on carrion within APS ROW that came in contact with or ingested vegetation that has been sprayed with an herbicide. However, the chance of an animal coming into contact with sprayed vegetation within the narrow ROW corridors, then dying and being ingested by California condor prior to the herbicide become inert would be so remote as to be

105 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests discountable. In addition, the only proposed herbicide that would be highly toxic to condors is dicamba which would rarely be used by APS (Forest Service 2018a). Therefore, similar to Alternative A, there would be short-term, direct and indirect, negligible adverse impacts because direct contact with condors would be unlikely due to their ability of flight and the ROW lacks suitable nesting or foraging habitat. Direct and indirect, long-term, negligible beneficial impacts to the California condor are anticipated because the frequency of routine vegetation maintenance would decrease, which would reduce the presence of workers and noise from equipment within suitable habitat. With regards to the ESA, the 2018 BA has made the determination that Alternative B “may affect, but is not likely to adversely affect” the endangered California condor or its habitat and is not likely to jeopardize the experimental nonessential population of the California condor.

Mexican spotted owl (Strix occidentalis lucida) Direct and Indirect Effects of Alternative A Under Alternative A, routine aerial and ground inspections would be conducted along with manual and mechanical vegetation treatment methods within the ROW. A description of the direct and indirect effects on the MSO and its designated critical habitat from inspections and routine vegetation maintenance treatments are presented in detail in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses on the potential effects from the Alternative A is not repeated here but is instead incorporated by reference and summarized below. Vegetation removal could occur within 75.71 acres of 39 PACs, within 4,293.57 acres of recovery habitat, and within 1,798.66 acres of designated critical habitat (0.04 percent of total MSO critical habitat on the five Forests). The Arizona Public Service Company’s aerial inspections may occur during the breeding season and could cause temporary disturbance to owls that may result in flush responses or decreased prey delivery. However, flights would occur during the day, are separated by greater than seven days, and would generally occur with a single pass, with brief circling and hovering occurring occasionally. Disturbances would be brief in duration and low in frequency and would not be expected to substantially disrupt normal feeding, breeding, and sheltering behavior. Because flights would be brief in duration and low in frequency they would not be expected to substantially disrupt normal feeding, breeding, or sheltering behavior. Ground patrols could temporarily startle or even cause MSO to flush from the nest, but it is not expected that the owls would have a reduced ability to provide for their young or decreased prey delivery because of the short duration, low frequency, and the low levels of noise from ground inspections (Forest Service 2018a). Routine vegetation maintenance using manual and mechanical methods and associated disposal activities would occur outside the breeding season (March 1 to August 31) within 0.25 mile of a PAC (refer to Biological Resources Conservation Measures in Appendix E) and thus direct effects to breeding are not expected from routine vegetation maintenance. Hazard vegetation treatment may occur during the breeding season to address imminent hazards. Noise disturbance from mechanized equipment (chainsaws) and human presence from hazard treatments could result in changed behavior, flushing from a nest, and reduced prey delivery rates. Noise disturbance would most likely occur at the level of an individual owl or PAC (Forest Service 2018a). Trees within MSO PACs that contribute to PAC habitat have already been removed through previous vegetation maintenance efforts. Future maintenance would primarily involve the removal of new growth and regeneration in the ROW. Removal of vegetation at the edge of or outside of the ROW could reduce canopy cover, alter canopy structure, reduce and remove snags, and create openings. These habitat alterations involve a small portion of the surrounding habitat and are concentrated within a previously disturbed power line ROW that differs from the surrounding habitat (i.e., power line ROWs have been continually maintained). Additionally, no extensive clearing of the power line ROWs would be needed.

106 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

While vegetation treatments could slightly alter habitat vegetation within MSO PACs, the change in habitat would be local, small in scale, and unlikely to result in adverse effects to MSO for most of the PACs in APS ROW. Vegetation treatments in the 39 PACs with power lines that transect through the PAC and not at the edge of the PAC could result in adverse effects to owl habitat in these PACs. While vegetation removal could decrease the overhead canopy by removing tall growing species, the under-story cover and residual plant cover would not directly be altered by vegetation removal and herbaceous understory may increase, which would benefit prey species for the owl (Forest Service 2018a). Vegetation removal would also occur within 4,293.57 acres of recovery habitat, and within 1,798.66 acres of designated critical habitat. This vegetation removal would occur within previously disturbed power line ROWs that have been continually maintained and differ from surrounding habitat. While vegetation treatments could slightly alter habitat vegetation within Mexican recovery habitat and critical habitat, the change in habitat would be local and small in scale. Vegetation treatments would preclude the development of suitable habitat in recovery habitat, and critical habitat resulting in adverse effects to these habitat types. For critical habitat, vegetation management activities would result in low levels of adverse effects to critical habitat PCEs related to the range of tree species, shade canopy, and clumps of trees, while Alternative B may result in minor beneficial effects of providing woody debris for prey species. Therefore, the Alternative A would result in short- and long-term, direct, negligible, adverse impacts as well as short- and long-term indirect, minor adverse impacts to the MSO and its designated critical habitat because vegetation would continue to be cut and would not be allowed to reach maturity. In addition, the 2018 BA has made the determination that Alternative A “may affect, and is likely to adversely affect” the MSO and its designated critical habitat. Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with Alternative A described above, Alternative B would also result in impacts on the MSO and its designated critical habitat from the use of herbicides as part of the management of incompatible vegetation within the ROW. A description of the direct and indirect effects of herbicide treatments on the MSO and its designated critical habitat are also presented in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses is not repeated here but is instead incorporated by reference and summarized in this section of the EA. It is unlikely that MSO or its prey would come into direct contact with herbicides because of the nocturnal nature of the owl. In the event that contact is made, the low toxicity of the herbicide being used would result in no effect or a minimal, insignificant effect. Effects associated with human presence are also unlikely because applications would avoid areas closest to MSO breeding during the breeding season, duration of work is short, and work is conducted using hand held equipment with low noise levels. Herbicide treatments would be restricted to only occurring outside of PACs during the breeding season where the overhead power lines transect the PAC rather than occurring at the edge of the PAC. This timing restriction further reduces the potential for any MSO to come into contact with freshly sprayed herbicides (refer to Biological Resources Conservation Measures in Appendix E). The use of herbicides may provide a beneficial effect to MSO by reducing the frequency of manual and mechanical treatment of vegetation. There an estimated 15 poles that may receive DSAP treatment within MSO PACs for 0.1 acres, an estimated 828 poles19 for 5.52 acres within MSO recovery habitat, and

19 Numbers of DSAP poles with equipment that can spark are estimated. GIS analysis was used to obtain these numbers using a dataset with known distribution equipment. The location of the equipment in GIS is not always accurate and some poles with equipment are likely on private land or other land owners. 828 poles represents an over-estimate of the actual number of poles that house equipment that could spark on National Forest System land.

107 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

261 poles for 1.74 acres within designated critical that may receive DSAP treatment (Forest Service 2018a). Prey of owls (mostly rodents) tends to also be nocturnal and shelter in burrows and at the base of shrubs and trees during the day. For prey species that seek shelter under target vegetation, the species may flee the area during work operations, temporarily displacing the species, though there is a chance that prey species would be exposed to herbicides. However, only herbicides of low toxicity to owl under the predatory avian category would be used within MSO PAC and recovery habitat as required by conservation measures. These same herbicides are also low toxicity to small mammals, and even if prey species are exposed to herbicide, they are not likely to be affected by the herbicide (Forest Service 2018a). The main habitat effect associated with herbicide application in PAC and recovery habitat is the preclusion of habitat developing within the ROW into suitable nest and roost habitat. This effect involves 75.71 total acres of PAC habitat, 4,293.57 acres of recovery habitat, and 1,798.66 acres of critical habitat within power line ROWs, though the effect is minimal in comparison to Forest-wide habitat (0.03 percent of total PAC habitat, 0.10 percent of total recovery habitat, and 0.07 percent of total critical habitat across the five Forests). Herbicide application as part of an integrated vegetation management program may also provide a beneficial effect as early successional plant communities develop in the ROW creating cover for prey species and providing plant diversity. Long-term indirect effects would occur because the ROW would not be allowed to develop into suitable habitat for owls (Forest Service 2018a). Therefore, the Alternative B would result in short- and long-term, direct, negligible, adverse impacts as well as short- and long-term indirect, minor adverse impacts to the MSO and its designated critical habitat because vegetation would continue to be cut and would be continually maintained limiting suitable nesting, roosting, or foraging habitats to establish. In addition, the 2018 BA has made the determination that Alternative B “may affect, and is likely to adversely affect” the MSO and its designated critical habitat.

Southwestern Willow Flycatcher (Empidonax traillii extimus) Direct and Indirect Effects of Alternative A A description of the direct and indirect effects on southwestern willow flycatcher and its designated critical habitat from Alternative A are presented in detail in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses on the potential effects from Alternative A is not repeated here but is instead incorporated by reference and summarized in this section. Critical habitat for the southwestern willow flycatcher totals 209,562 acres of which 13,541.85 acres are managed by the Forest Service. A total of 10.75 acres (0.08% of total on National Forest System lands) of critical habitat have the potential to be affected by Alternative A (Forest Service 2018a). Suitable habitat outside of designated critical habitat was also considered and it was determined that no suitable habitat occurred outside designated critical habitat within the ROWs. Thus, there is also a total of 10.75 acres of suitable habitat that have the potential to be affected by Alternative A. Noise from low-flying aircraft during aerial inspections may cause brief disturbance that may disrupt normal foraging or nesting activity. Because of the short duration and limited area, effects due to aerial inspections on breeding activity or on foraging flycatchers and their ability to provide for their young would be insignificant. Ground inspections would occur along all power lines at various times throughout the year and could occur during the flycatcher breeding season. If flycatchers are nesting or foraging near the area of ground inspection, it is unlikely that the ground inspections would result in anything greater than a short term startle response. Mechanical treatment methods would not occur within the floodplain of any stream or river system, including those with suitable habitat for flycatchers. Only manual treatments would be permitted in riparian areas, which would limit potential displacement of individual flycatchers

108 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona during treatment activities. Between maintenance cycles, small sapling vegetation would develop, but this vegetation would continue to be cut and would not be allowed to reach maturity in the 10.75 acres within the ROW containing designated critical habitat and suitable habitat for flycatcher. Routine vegetation maintenance treatments would not alter the availability of insect prey populations. Direct contact with flycatchers would be unlikely due to their ability of flight and the ROW’s limited suitable nesting or foraging habitat (Forest Service 2018a). Routine vegetation maintenance activities could indirectly affect southwestern willow flycatchers through modification of riparian vegetation that could potentially develop into future flycatcher breeding and foraging habitat. Current vegetation conditions within ROWs do not provide the density or structure necessary to support breeding flycatchers. Riparian development would remain, and the suppression of habitat would adversely affect 10.75 acres of riparian habitat. Routine vegetation maintenance may affect foraging habitat, but this impact is considered insignificant because of the small area affected and is not expected to reduce the abundance of flycatcher foraging habitat (Forest Service 2018a). Therefore, Alternative A would result in short- and long-term, direct, negligible, adverse impacts as well as short- and long-term indirect, minor adverse impacts to the southwestern willow flycatcher and its designated critical habitat because vegetation would continue to be cut and would not be allowed to reach maturity. In addition, the 2018 BA has made the determination that Alternative A “may affect, and is likely to adversely affect” southwestern willow flycatcher and its designated critical habitat. Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with Alternative A described above, Alternative B would also result in impacts on the southwestern willow flycatcher and its designated critical habitat from the use of herbicides as part of the management of incompatible vegetation within the ROW. A description of the direct and indirect effects of herbicide treatments on the southwestern willow flycatcher and its designated critical habitat are also presented in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses is not repeated here but is instead incorporated by reference and summarized in this section of the EA. Conservation measures would be implemented to minimize effects associated with human presence during herbicide application, including: 1) ATV use within the ROW would not occur during the breeding season; and 2) herbicide application would be avoided during the breeding season if possible, and if this work needs to be conducted during the breeding season, measures would be taken to minimize trips in and out and avoid walking directly through suitable habitat (refer to Biological Resources Conservation Measures in Appendix E). The noise level of herbicide application is very low, and the applicators do not walk through dense patches of vegetation where suitable breeding habitat may occur. The likelihood of a nesting flycatcher being present in the adjacent ROW when herbicide application would occur is discountable, the short duration and low noise levels of work ensure effects would be insignificant, and implementation of conservation measures that minimize work during the breeding season would result in impacts that would be discountable (Forest Service 2018a). Any migratory or foraging birds in the ROW would more than likely fly away before an applicator could get close enough to spray it. Herbicides could be sprayed on insects that are, in turn, ingested by flycatchers (refer to Biological Resources Conservation Measures in Appendix E). Application of conservation measures includes the use of low toxicity herbicides. Only a small portion of southwestern willow flycatcher suitable breeding, migration, and foraging habitat occur within the ROW ensure that these potential effects would be so remote. Given the limited potential for interaction with nesting, foraging, or migrating southwestern willow flycatchers during application of targeted herbicide applications, and the implementation of conservation measures listed above, the possibility of direct effects due to herbicide application are unmeasurable (Forest Service 2018a).

109 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

A total of six poles encompassing 0.04 acres that may receive DSAP treatment occur within critical habitat for the southwestern willow flycatcher. All six poles are located in upland habitat with no poles to be maintained within riparian habitat for southwestern willow flycatcher. Vegetation around equipment poles would be cleared using manual methods. The DSAP treatments would occur outside the breeding season for the flycatcher and vegetation around these poles has already been cleared using manual methods. The proposed herbicide treatments would reduce the frequency of disturbance by field crews (Forest Service 2018a). Therefore, there would be short- and long-term, direct, negligible, adverse impacts because the southwestern willow flycatcher would likely fly away before crew workers could get close enough to inadvertently spray them with herbicide. Additionally, treatments would either occur outside the breeding season or minimize effects if occurring during the breeding season (refer to Biological Conservation Measures in Appendix E). Short- and long-term, indirect, minor adverse impacts are anticipated because the vegetation within areas of critical or suitable habitat would be continually maintained limiting suitable nesting, roosting, or foraging habitats to establish. In addition, the 2018 BA has made the determination that Alternative B “may affect, and is likely to adversely affect” southwestern willow flycatcher and its designated critical habitat.

Yellow-billed cuckoo (Coccyzus americanus occidentalis) Direct and Indirect Effects of Alternative A Under the Alternative A, routine aerial and ground inspections would be conducted along with manual and mechanical vegetation treatment methods within the ROW. A description of the direct and indirect effects on the cuckoo and its proposed critical habitat from Alternative A are presented in detail in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses on the potential effects from Alternative A is not repeated here but is instead incorporated by reference and summarized in this section. Aerial and ground inspections would not likely affect yellow-billed cuckoos because of the short duration of these activities. Routine vegetation maintenance would be conducted outside the nesting season and would have no direct effect on breeding yellow-billed cuckoos, if present near the ROW. Hazard vegetation treatments may occur during the nesting season to treat imminent hazards, though this treatment is uncommon. A buffer would be established around the riparian vegetation within the ROW and ATVs would not be driven within the riparian area during the nesting season for hazard vegetation treatments and inspections, except on existing roads that are open to the public. Only manual treatments would be permitted in riparian areas, which would limit potential displacement of individual cuckoos during treatment activities. The crew workers may temporarily displace yellow-billed cuckoos present in the ROW. Disturbance to yellow-billed cuckoos from manual treatment of vegetation would not likely have any measurable consequences to individual cuckoos or the population as a whole on National Forest System lands because of the relatively limited area of the ROW that would need treatment and implementation of conservation measures that limit activities within breeding habitat to only imminent hazard situations. In Alternative A, incompatible vegetation would continue to be cut and would not be allowed to reach maturity in the 6.72 acres of riparian vegetation within the ROW containing suitable cuckoo habitat20. Direct contact with cuckoos would be unlikely due to their ability of flight and the ROW’s limited suitable breeding, migration, and foraging habitats and implementation of timing restriction conservation measures. Routine vegetation maintenance treatments would not alter the availability of insect prey populations (Forest Service 2018a).

20 Analysis in the BA looked at each ROW in suitable habitat and identified which ROWs would receive herbicide application. Of the 45.54 acres of yellow-billed cuckoo habitat, only 6.72 acres of suitable riparian habitat are proposed for vegetation management work. This calculation is based on removing areas where power lines are so high above the vegetation below that vegetation management activities are not necessary.

110 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Therefore, Alternative A would result in short- and long-term, direct, negligible, adverse impacts and short- and long-term indirect, minor adverse impacts to the yellow-billed cuckoo and its proposed critical habitat because incompatible vegetation would continue to be cut and would not be allowed to reach maturity. In addition, the 2018 BA has made the determination that the Alternative A “may affect, and is likely to adversely affect” yellow-billed cuckoo and its proposed critical habitat. Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with Alternative A described above, Alternative B would also result in impacts on the yellow-billed cuckoo and its proposed critical habitat and suitable habitat from the use of herbicides as part of the management of incompatible vegetation within the ROW. A description of the direct and indirect effects of herbicide treatments on the cuckoo and its proposed critical habitat are also presented in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses is not repeated here but is instead incorporated by reference and summarized in this section of the EA. The use of low toxicity herbicides, establishment of buffers within or near suitable habitat, the application of targeted, short duration herbicide treatments, and the use of the drift and drip reduction agent, Thinvert, would reduce any potential direct effects to yellow-billed cuckoos by Alternative B. Potential impacts to breeding yellow-billed cuckoos may occur from presence of crew workers during application of targeted herbicides from backpack sprayers within the ROW. Direct effects to yellow-billed cuckoo’s nesting activities would be unlikely and discountable because: the ROW does not contain suitable nesting habitat for cuckoo’s; it is highly unlikely that breeding cuckoos would occur immediately adjacent to the ROW with only a small portion of the action area occurring adjacent to suitable breeding habitat; herbicide applications are short in duration lasting approximately one hour per mile of power line; species-specific conservation measures would ensure ATVs are not used within suitable habitat during the breeding season except on existing roads open to the public; and any herbicide application during the breeding season would include measures to avoid walking through suitable habitat and minimize trips in and out of the area. The potential for yellow-billed cuckoo to be directly sprayed or come into contact with herbicide would also be unlikely because migratory birds in the ROW would more than likely fly away before an applicator could get close enough to spray it. In addition, the ROWs do not contain suitable nesting habitat and thus nesting cuckoos would not be directly sprayed. Aerial and ground inspections are not likely to affect yellow-billed cuckoos due to the short duration of these activities (Forest Service 2018a). Herbicides could be sprayed on insects that are, in turn, ingested by cuckoos. Targeted application of herbicides to only specific incompatible plants or re-sprouts limits the opportunity for insect prey species to be exposed. The use of low toxicity herbicides would minimize potential direct effects on prey species due to toxicity. Given the limited potential for disturbance to nesting, roosting, or migrating cuckoos during application of targeted herbicide applications, any direct effects due to herbicide application would not likely have any measurable consequences to individual cuckoos or the population of yellow-billed cuckoos (Forest Service 2018a). As noted in the Alternative A, vegetation maintenance is proposed on 6.72 acres of ROW that occurs within suitable habitat for yellow-billed cuckoo21. In Alternative B, routine vegetation maintenance would be carried out within this ROW to manage for low growing plant communities by targeted herbicide applications to individual plants. Long-term indirect effects to the riparian vegetation component of critical habitat within the ROW would occur because the 6.72 acres of riparian vegetation would not be

21 Analysis in the BA looked at each ROW in suitable habitat and identified which ROWs would receive herbicide application. Of the 45.54 acres of yellow-billed cuckoo habitat, only 6.72 acres of suitable riparian habitat are proposed for vegetation management work. This calculation is based on removing areas where power lines are so high above the vegetation below that vegetation management activities are not necessary.

111 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests allowed to develop into suitable breeding habitat for cuckoos22. Potential impacts to proposed critical habitat through effects to riparian woodlands and dynamic riverine processes would be relatively small in scale (Forest Service 2018a). The effect of DSAP treatment is expected to be discountable because vegetation around these 10 poles has already been cleared, no poles are proposed to be treated within riparian habitat, and proposed herbicide treatments would reduce the frequency of disturbance by field crews. DSAP treatment would have a minor effect to cuckoo habitat by reducing potential foraging vegetation by 0.07 acres in upland habitat. The treatment of poles to minimize potential of sparking, resulting in wildlife may result in beneficial effects of reducing fire risk to cuckoo habitat (Forest Service 2018a). Therefore with Alternative B, there would be short- and long-term, direct, negligible, adverse impacts because of the potential for disturbance to nesting, roosting, and migrating cuckoos is minimized by conservation measures and use of low toxicity herbicides in the species habitat, lack of suitable nesting habitat in the ROW, and the ability of migrating and foraging cuckoos to fly away during herbicide application and vegetation management activities. Short- and long-term, indirect, minor adverse impacts are anticipated to the yellow-billed cuckoo because the riparian vegetation would be continually treated there would be no potential for ROW to become suitable habitat over time. In addition, the 2018 BA has made the determination that the Alternative B “may affect, and is likely to adversely affect” yellow-billed cuckoo and its proposed critical habitat.

Federally Listed Species within APS ROW – Fish There are nine fish species and/or critical habitats that occur within APS ROW: Colorado pikeminnow (Ptychocheilus lucius), desert pupfish (Cyprinodon macularius), Gila chub (Gilla intermedia), Gila topminnow (Poeceliopsis occidentalis occidentalis), Gila trout (Oncorhynchus gilage), Little Colorado spindace (Lepidomeda vittata), loach minnow (Tiaroga cobitis), razorback sucker (Xyrauchen texanus), and spikedace (Meda fulgida). There are 25 creeks with federally listed fish occupied habitat and/or proposed or designated critical habitat within APS ROW and a total of 75 crossings (refer to Table 3.7-8).

Table 3.7-8. Summary of Stream or River, and Number of Crossings over Federally Listed Fish Species within APS ROW Number of APS Stream or River Federally Listed Fish Species ROW Crossings Beaver Canyon Little Colorado Spinedace 1

Beaver Creek Loachminnow and Spikedace 1

Cherry Creek Razorback sucker 1 Chevelon Creek Little Colorado Spinedace 1 Christopher Creek Gila Trout 1 East Verde River Gila Trout 6 Desert pupfish, Gila topminnow, Fossil Creek Loachminnow, Razorback sucker, and 4 Spikedace

22 Analysis in the BA looked at each ROW in suitable habitat and identified which ROWs would receive herbicide application. Of the 45.54 acres of yellow-billed cuckoo habitat, only 6.72 acres of suitable riparian habitat are proposed for vegetation management work. This calculation is based on removing areas where power lines are so high above the vegetation below that vegetation management activities are not necessary.

112 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Number of APS Stream or River Federally Listed Fish Species ROW Crossings

Indian Creek Gila chub and Gila topminnow 1

Little Sycamore Creek Gila chub and Gila topminnow 1

Gila Trout, Loachminnow, Razorback Oak Creek 17 sucker, and Spikedace Rye Creek Spikedace 2 Colorado Pikeminnow and Razorback Salt River 1 sucker Silver Creek Gila chub 2 Spring Creek Gila chub and Gila topminnow 1 Sycamore Creek (Prescott National Gila chub and Gila topminnow 2 Forest) Sycamore Creek (Tonto National Gila topminnow 1 Forest) Tonto Creek Spikedace 4 Colorado Pikeminnow, Loachminnow, Verde River 14 Razorback sucker, and Spikedace Walker Creek Gila topminnow and Gila chub 1 Walnut Spring Desert pupfish 1 West Chevelon Creek Little Colorado Spinedace 1 West Clear Creek Spikedace 2 West Fork Oak Creek Gila Trout 1 Gila chub, Loachminnow, and Wet Beaver Creek 2 Spikedace Willow Creek Little Colorado Spinedace 1 Total Number of Crossings in Project - 75 Area

Direct and Indirect Effects of Alternative A A description of the direct and indirect effects on these nine federally listed fish species and their designated critical or suitable habitat from Alternative A are presented in detail in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses on the potential effects from Alternative A is not repeated here but is instead incorporated by reference and summarized in this section. During routine vegetation maintenance riparian vegetation would not be treated along Walnut Spring, Indian Creek, Chevelon Creek, Greenback Creek, Rye Creek, Spring Creek, Little Sycamore Creek, and West Fork Oak Creek. Only upland vegetation would be treated under routine vegetation maintenance either because the power line does not cross over riparian vegetation or the riparian vegetation is far enough below the power line wires that treatment of this vegetation is not necessary. Routine vegetation maintenance of riparian and upland vegetation would have no direct effect on federally listed fish species because these activities would occur outside of aquatic environments. No direct effects to federally listed fish species due to aerial inspections would occur because these types of inspections occur high above the ground and fish aquatic habitats.

113 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Routine vegetation maintenance would involve the removal of vegetation within riparian and upland habitats. The ROWs where the power lines cross over the creek or river have been continually maintained and the composition of tall vegetation is currently sparse in comparison to adjacent riparian vegetation outside the ROWs. Any change in vegetation may reduce shade, cover, and potentially affect bank stability but these changes would be localized to small areas and would not have measurable effects to fish species habitat. Vegetation management may reduce forage and cover for terrestrial invertebrates but these effects would be negligible and localized. The pruning and removal of riparian vegetation adjacent to fish habitat would not result in noticeable effects on the federally listed fish habitats. Manual and mechanical treatment of vegetation in the upland habitat and manual treatment of vegetation in riparian habitat would be unlikely to cause soil disturbance that could runoff into aquatic environments. The routine vegetation maintenance treatment only includes removal of incompatible vegetation while soil stabilizing vegetation such as grasses, forbs, and some shrubs would remain untreated. Alternative A would result in an increase in downed logs and debris adjacent to the stream or river, which could move into the aquatic habitat, providing a beneficial effect of cover for these fish species. The removal of vegetation would not likely result in adverse effects to bank stability because some vegetation, including grasses, forbs, and shrub would remain untreated (Forest Service 2018a). Therefore, there would be no direct impacts and there would be short- and long-term indirect, negligible adverse impacts on the Colorado pikeminnow, desert pupfish, Gila chub, Gila topminnow, Gila trout, Little Colorado spindace, loach minnow, razorback sucker, or spikedace or its designated critical or suitable habitat from the Alternative A. The 2018 BA has made the determination that the Alternative A “may affect, but is not likely to adversely affect” the desert pupfish, Gila chub, Gila topminnow, Gila trout, Little Colorado loach minor, razorback sucker or spikedace or their designated critical or suitable habitat. In addition, Alternative A is not likely to jeopardize the 10j population of Colorado pikeminnow within the Verde River.

Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with Alternative A described above, Alternative B would also result in impacts on the nine federally listed fish species and each of their respective designated critical or suitable habitat from the use of herbicides as part of the management of incompatible vegetation within the ROW. A description of the direct and indirect effects of herbicide treatments on the listed fish species and their habitat are also presented in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses is not repeated here but is instead incorporated by reference and summarized in this section of the EA. The nine federally listed fish species could be exposed to herbicides that enter aquatic habitats through off-site drift or surface runoff. Because herbicide treatment would only involve spot application, drift potential would be reduced. Additionally, Thinvert would be used as a carrier in the herbicide mix, which minimizes drift and runoff. Implementation of species-specific conservation measures would stipulate that low toxicity herbicides would be used to further reduce any potential effect to the nine fish species and the associated aquatic habitat (refer to Biological Resources Conservation Measures in Appendix E). Herbicide treatments could also reduce the number of invertebrates, reducing food availability. However, herbicide treatment would be small in scale and there would be limited quantities of vegetation treated. If impacted, only small numbers of invertebrates would be affected and any potential effect to fish food availability would be localized (Forest Service 2018a). There are 16 poles that may require DSAP treatment within 300 feet of the high water mark of federally listed fish aquatic habitat. The majority of these (11 poles) are located in Oak Creek Canyon; the nearest pole to the creek bank is 90 feet away. Herbicides may be applied directly to the ground using a pre- emergent herbicide within the 10-foot radius treatment area. Most commonly, however, the herbicide treatment associated with DSAP is conducted through cut-stump treatment. Pre-emergent herbicides would not be applied in riparian areas, in sandy soils, areas where ground water level is high, or on steep

114 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona slopes where there is a chance that soil and herbicide could erode downhill (Forest Service 2018a) (refer to Section 2.2.11 Alternative B Design Features). Therefore, there would be short- and long-term direct, negligible adverse impactsand there would be short- and long-term indirect, negligible adverse impacts on the Colorado pikeminnow, desert pupfish, Gila chub, Gila topminnow, Gila trout, Little Colorado loach minor, razorback sucker or spikedace or its designated critical or suitable habitat from the Alternative B. In addition, Alternative B is not likely to jeopardize the 10j population of Colorado pikeminnow within the Verde River. The 2018 BA has made the determination that the Alternative B will have “no effect” on the Colorado pikeminnow or its designated critical or suitable habitat. A determination of “may affect, but not likely to adversely affect” was made for the desert pupfish, Gila topminnow, Gila chub, Little Colorado spinedace, loach minnow, razorback sucker, spikedace, Gila trout or their designated critical or suitable habitat.

Federally Listed Species – Mammals

Mexican Gray Wolf (Canis lupus baileyi) Direct and Indirect Effects of Alternative A Under Alternative A, routine aerial and ground inspections would be conducted along with manual and mechanical vegetation treatment methods within the ROW. A description of the direct and indirect effects on the Mexican gray wolf and its foraging habitat from Alternative A are presented in detail in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses on the potential effects from Alternative A is not repeated here but is instead incorporated by reference and summarized in this section. A total of 1,594.66 acres (0.10 percent of total Mexican wolf occupied range on Apache-Sitgreaves and Tonto national forests) of ROW occurs in this species’ occupied range. Additionally, a total of 1,464 miles of power line and 14,566 acres of ROW occur within the MWEPA (2018 BA) (Forest Service 2018a). Routine vegetation maintenance, vegetation disposal, aerial and ground inspections, and vehicle travel would not effect to the experimental nonessential population of Mexican gray wolf because these activities were and are active and ongoing and consistent and excluded from analysis based on the 10(j) rule for Mexican gray wolf. Alternative A would result in an insignificant change to Mexican gray wolf suitable habitat. The power line ROWs have been continually maintained and herbicide application would target vegetation already maintained through current vegetation management practices (Forest Service 2018a). Therefore, Alternative A would result in short- and long-term, direct and indirect, negligible adverse impacts to the Mexican gray wolf and its habitat. With regards to the ESA, the 2018 BA has made the determination that Alternative A “may affect, but is not likely to adversely affect” the Mexican gray wolf nonessential population or its habitat. Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with Alternative A described above, Alternative B would also result in impacts on the Mexican gray wolf and its habitat from the use of herbicides as part of the management of incompatible vegetation within the ROW. A description of the direct and indirect effects of herbicide treatments on the Mexican gray wolf and its habitat are also presented in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses is not repeated here but is instead incorporated by reference and summarized in this section of the EA. If present during herbicide application, it is unlikely that Mexican gray wolves would be directly exposed to herbicides during work activities since they would avoid treatment sites and are large enough that herbicide applicators would be able to see them. Seven power lines ROW occur in the occupied range of Mexican gray wolf, but the nearest wolf detection is approximately 35 miles or greater from these ROWs.

115 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

However, Apache-Sitgreaves National Forests indicates that collared wolves have been moving across the Lakeside and Black Mesa Ranger Districts along the Mogollon Rim so some of these travel paths may have intersected APS ROWs on the Forest (DeRosier, Suzanne. 2018. Personal communication). Wolves prefer to hunt in open areas and power line ROWs may provide enhanced prey opportunities, resulting in a slight beneficial effect. At the same time, this would also make wolves more vulnerable to poaching in areas accessible to human hunters. This affect would be insignificant, however, because the proposed use of herbicides would only slightly change the existing conditions of the ROW, which are already more open than surrounding habitat (Forest Service 2018a). Indirect effects to Mexican gray wolf could be exposed to herbicide by contact with foliage sprayed by herbicide or ingestion of prey items contaminated by herbicide. However, no predator or rodent pesticide control agents would be used as part of Alternative B. All herbicides proposed for use are low in toxicity to predatory mammals and any potential effect associated with ingestion of prey or from treated plants would be minimal and insignificant (Forest Service 2018a). Therefore, Alternative B would result in short- and long-term, direct and indirect, negligible adverse impacts to the Mexican gray wolf and its habitat. With regards to the ESA, the 2018 BA has made the determination that Alternative B “may affect, but is not likely to adversely affect” the Mexican gray wolf nonessential population or its habitat.

Ocelot (Leopardus pardalis) Direct and Indirect Effects of Alternative A Under the Alternative A, routine aerial and ground inspections would be conducted along with manual, mechanical, and DSAP vegetation treatment methods within the ROW. A description of the direct and indirect effects on the ocelot and its suitable habitat from Alternative A are presented in detail in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses on the potential effects from Alternative A is not repeated here but is instead incorporated by reference and summarized in this section. There is no designated or proposed critical habitat for the ocelot within the ROWs; the only potentially suitable habitat is within the Globe Ranger District of the Tonto National Forest. There are 378.27 acres of ROW within potentially suitable habitat (or 0.2 percent of the total estimated suitable habitat within the Tonto National Forest) and approximately 16 poles (0.11 acres) that may require DSAP treatment in ocelot potentially suitable habitat within the Tonto National Forest. Vegetation along the ROW within potential suitable ocelot habitat is sparse and would require minimal manual and mechanical vegetation treatment. Ocelots are nocturnal carnivores that inhabit dense vegetative cover. It would be unlikely that Alternative A would have direct impacts to ocelots since vegetation inspection and maintenance activities would occur during day time hours. Ocelots’ prey consists primarily of rabbits, rodents, birds, and lizards. There would be no direct or indirect impacts to prey species since the ROW has been continuously maintained and habitat values for these prey species would not change with Alternative A over existing conditions (Forest Service 2018a). Therefore, Alternative A would result in short- and long-term, direct and indirect, negligible adverse impacts to the ocelot and its habitat. With regards to the ESA, the 2018 BA has made the determination that Alternative A “may affect, but is not likely to adversely affect” the ocelot nonessential population or its habitat. Direct and Indirect Effects of Alternative B In addition to the effects associated with the Alternative A described above, Alternative B would also result in impacts on the ocelot and its habitat from the use of herbicides as part of the management of incompatible vegetation within the ROW. A description of the direct and indirect effects of herbicide treatments on the ocelot and its habitat are also presented in the 2018 BA (Forest Service 2018a). The

116 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona detailed discussion of the analyses is not repeated here but is instead incorporated by reference and summarized in this section of the EA. An ocelot coming into direct contact with vehicles, crew workers, or equipment associated with herbicide application or in contact with the herbicide itself would be unlikely. Herbicide treatments would occur during the daytime with minimal quantities of herbicide applied to the ROW’s sparse vegetation and ocelots are nocturnal. Ocelots could ingest prey that has come into contact with herbicide. No predator or rodent pesticide control agents would be used as part of Alternative B. All herbicides selected would be low in toxicity to predatory mammals. It would be unlikely for prey to consume herbicides and then be ingested soon thereafter by an ocelot. The frequency of the vegetation management treatment in Alternative B would become less often than Alternative A. DSAP treatment may result in minimal effects to ocelot habitat by the removal of vegetation around poles. However, these effects would be localized and limited to only 0.11 acres of ocelot habitat on Tonto National Forest (Forest Service 2018a). Therefore, Alternative B would result in short- and long-term, direct and indirect, negligible adverse impacts to the ocelot and its habitat. With regards to the ESA, the 2018 Forest Service BA has made the determination that Alternative B “may affect, but is not likely to adversely affect” the ocelot nonessential population or its habitat.

Federally Listed Species – Plants

Arizona Cliffrose (Purshia subintegra) Direct and Indirect Effects of Alternative A A description of the direct and indirect effects on the Arizona cliffrose and its habitat from Alternative A are presented in detail in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses on the potential effects from Alternative A is not repeated here but is instead incorporated by reference and summarized in this section. Occupied Arizona cliffrose habitat occurs on 0.46 acre of ROW within the Coconino National Forest. Vegetation within Arizona cliffrose habitat consists of desert shrubs and juniper that do not have the potential to grow tall enough to be an imminent hazard to the power line, though some shrubs and juniper are a fuel concern and require treatment under vegetation maintenance. There are no poles within APS ROWs with Arizona cliffrose suitable habitat that contain equipment that could spark (Forest Service 2018a). Because ground inspections would be conducted on foot and not from a vehicle, it is highly unlikely that Arizona cliffrose would be affected directly by ground inspections. Conservation measures would be implemented that would include training to avoid the cliffrose and ground inspections would be infrequent because of the low growing and sparse vegetation associated with cliffrose habitat. Effects to Arizona cliffrose seedlings would be minimized by implementation of conservation measures that would require training of crews to avoid trampling of or disposing of vegetation on seedling woody vegetation, regardless of species, and checking under treatment plants for Arizona cliffrose before cutting. Because direct effects would be minimized to the greatest extent possible through implementation of conservation measures, routine vegetation maintenance is highly unlikely to result in effects to Arizona cliffrose mature and seedlings plants (Forest Service 2018a). Human traffic may imperceptibly displace soil and marginally affect soil biota that Arizona cliffrose is dependent on. The soil composition in Arizona cliffrose habitat tends to be unstable and could erode rapidly. Foot traffic during ground inspections could result in some localized disturbance to soil and soil biota, though this disturbance would be so small in scale that it would not likely result in measureable effects. The ROW has been continually maintained and future routine vegetation maintenance work would involve cutting regrowth and new growth of juniper and crucifixion thorn. Lower shrubs would remain in the ROW, providing cover for seedling establishment (Forest Service 2018a).

117 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Therefore, Alternative A would result in direct and indirect, short- and long-term negligible, adverse impacts to Arizona cliffrose and its habitat (refer to Biological Resources Conservation Measures in Appendix E). In addition, the 2018 BA has made the determination that Alternative A “may affect, but is not likely to adversely affect” the Arizona cliffrose or its habitat. Direct and Indirect Effects of Alternative B Herbicide application is not proposed within suitable Arizona cliffrose habitat as described under the conservation measures and thus is not analyzed here. There are no poles within Arizona cliffrose suitable habitat that contain equipment that could spark and DSAP treatment with herbicides would not occur in Arizona cliffrose suitable habitat. Therefore, Alternative B would have the same results as Alternative A—direct and indirect, short- and long-term negligible, adverse impacts to Arizona cliffrose and its habitat. In addition, the 2018 BA has made the determination that Alternative B “may affect, but is not likely to adversely affect” the Arizona cliffrose or its habitat.

Arizona Hedgehog Cactus (Echinocereus triglochidiatus var. arizonicus) Direct and Indirect Effects of Alternative A Under Alternative A, routine aerial and ground inspections would be conducted along with manual vegetation treatment methods within the ROW. A description of the direct and indirect effects on the Arizona hedgehog cactus and its potential and occupied habitat from Alternative A are presented in detail in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses on the potential effects from Alternative A is not repeated here but is instead incorporated by reference and summarized in this section. Potential Arizona hedgehog cactus habitat occurs on 180.08 acres of ROW and occupied habitat occurs on 69.41 acres of ROW within the Tonto National Forest. This represents 0.60 percent of the identified potential habitat and 2.369 percent of known occupied habitat. There are no poles that may receive DSAP that are occupied with Arizona hedgehog cacti and three poles (0.02 acres) within potential habitat on Tonto National Forest. Conducting pretreatment cactus surveys, flagging Arizona hedgehog cacti and nurse plants, if present, using manual methods for incompatible vegetation management, and limiting vehicle and ATV use to established roads in occupied habitat would minimize direct impacts to Arizona hedgehog cacti. Mechanical vegetation treatments would not be used in the ROW containing occupied habitat. Implementing these and other species-specific design features would minimize any potential to affect habitat loss or degradation due to manual treatments. Manual treatments would have the potential to modify the local plant community within the ROW, however, treatments would be localized and affect only a small number of plants at any given treatment site with only 69.41 acres of ROW (0.36 percent of estimated potential suitable habitat) within occupied habitat for Arizona hedgehog cactus on national forest lands. In Alternative A, the nurse plants associated with Arizona hedgehog cacti would be left untreated or in some circumstances, limited pruning may be needed. Any cactus found within the non- combustible area associated with the 0.02 acres around DSAP treatment areas would remain and not be removed (Forest Service 2018a). However, the three DSAP locations in potential habitat have been surveyed and no Arizona hedgehog cacti were found. Therefore, Alternative A would result in direct and indirect, short- and long-term negligible, adverse impacts to Arizona hedgehog cactus and its habitat. In addition, the 2018 BA has made the determination that Alternative A “may affect, but is not likely to adversely affect” the Arizona hedgehog cactus or its habitat. Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with Alternative A described above, Alternative B would also result in impacts on the Arizona hedgehog cactus and its potential and occupied habitat from the use

118 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona of herbicides as part of the management of incompatible vegetation within the ROW. A description of the direct and indirect effects of herbicide treatments on the cacti and its potential and occupied habitat are also presented in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses is not repeated here but is instead incorporated by reference and summarized in this section of the EA. With the establishment of buffers around flagged cactus or clumps of cacti, and the use of spot treatment techniques, this would reduce any potential direct effects to Arizona hedgehog cacti by Alternative B. Additional species-specific conservation measures would restrict vehicles and ATVs to existing roads and prohibit ATVs from driving off-road within the ROW where there is occupied habitat would also minimize direct impacts to cacti. Herbicide treatments conducted within Arizona hedgehog cactus habitat would have the potential to modify the local plant community within the ROW. However, treatments would be localized and affect only a small number of plants at any given treatment site. For herbicide application, the use of Thinvert would minimize any drifting of herbicide onto non-target plants and drip to the soil and underlying plants (Forest Service 2018a). As previously noted, there are currently three poles with 0.02 acres in Arizona hedgehog cactus potential habitat within the ROW that meet the DSAP treatment criteria. However, if, during pretreatment survey, Arizona hedgehog cacti are found, the cactus would be left on site and no herbicide would be applied for the treatment of the DSAP area. Additionally, the three poles were surveyed in 2017 and no Arizona hedgehog cacti were found. The potential direct effects are expected to be localized and not measurable because only 0.02 acres occur within potential habitat for the Arizona hedgehog cacti (Forest Service 2018a). Therefore, Alternative B would result in direct and indirect, short- and long-term negligible, adverse impacts to the Arizona hedgehog cactus. In addition, the 2018 BA has made the determination that Alternative B “may affect, but is not likely to adversely affect” the Arizona hedgehog cactus or its habitat.

Federally Listed Species within APS ROW – Reptiles There are two reptile species and proposed critical habitats that occur within APS ROW: Narrow-headed Gartersnake (Thamnophis rufipunctatus) and Northern Mexican Gartersnake (Thamnophis eques megalops).

Direct and Indirect Effects of Alternative A Under Alternative A, routine aerial and ground inspections would be conducted and manual methods would be used to maintain vegetation within suitable habitat for gartersnakes; the species-specific conservation measures preclude the use of mechanical methods in gartersnake habitat (refer to Biological Resources Conservation Measures in Appendix E). A description of the direct and indirect effects on the narrow-headed gartersnake and the northern Mexican gartersnake and their proposed critical habitat from inspections and vegetation maintenance treatments are presented in detail in the 2018 BA (Forest Service 2018a). A total of 141.72 acres of APS ROW occur within proposed critical habitat for narrow-headed gartersnake on the Apache-Sitgreaves, Coconino, Prescott, and Tonto national forests. A total of 89.00 acres of APS ROW occur within proposed critical habitat for northern Mexican gartersnake on the Coconino, Prescott, and Tonto national forests. A total of 51 poles with 0.37 acres may receive DSAP treatment within proposed critical habitat for narrow-headed gartersnake. For the northern Mexican gartersnake, 11 poles with 0.08 acres may receive DSAP treatment within proposed critical habitat. All DSAP poles occur outside of riparian habitat, but occur in upland suitable gartersnake habitat. The detailed discussion of the analyses on the potential effects from inspections and vegetation maintenance treatment is not repeated here but is instead incorporated by reference and summarized below (Forest Service 2018a).

119 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Aerial inspections would occur annually for portions of the ROW, and potential direct effects to the two federally listed gartersnakes from helicopter inspections would be unlikely because the flights are at a high enough distance off the ground that a flight response from gartersnakes would not be measurable. Direct effects from trampling associated with vehicle travel to, from, and within ROWs during ground inspections would be highly unlikely and discountable because vehicle travel conservation measures and design features would minimize effects to narrow-headed gartersnake. In Alternative A, routine vegetation maintenance in narrow-headed and northern Mexican gartersnakes suitable habitat would only be performed by hand crews as identified in the conservation measures for these species (refer to Biological Resources Conservation Measures in Appendix E). In suitable upland habitat, narrow-headed and northern Mexican gartersnakes could occur during gestation, brumation23, or during migration. If the two federally listed gartersnakes are present in upland habitat during brumation, then the snakes are likely to be located in hollows created by rocks or downed debris and not in the vegetation being cut. Because the work would be conducted on foot with no large machinery, any potential effects to the gartersnakes due to routine vegetation maintenance work in upland habitat would be minimal (Forest Service 2018a). In suitable riparian habitat, narrow-headed and northern Mexican gartersnakes could potentially be found basking on shrubs or on saplings to be cut, though this may be unlikely in such a small portion of riparian suitable habitat in the ROW. For all maintenance activities that will occur within gartersnake habitat, crews would be provided with training material on identifying the gartersnake, what to do if a gartersnake is observed in the project area, and on the conservation measures in order to reduce impacts to individuals and habitat (refer to Biological Resources Conservation Measures in Appendix E). The movement or temporary displacement of gartersnakes due to routine vegetation maintenance, however, would be unlikely because of the small portion of riparian suitable habitat in the ROW. Human presence and use of chainsaws could temporarily displace gartersnakes near the work area, though this effect would be short in duration, generally only lasting a day or less where work occurs locally (Forest Service 2018a). Upland and riparian vegetation has been continually maintained within the ROW and in Alternative A, no wide-scale removal of vegetation is proposed. The removal and treatment of vegetation may result in minor local changes to narrow-headed and northern Mexican gartersnakes riparian and upland habitats. Important components for cover, such as woody debris would be maintained. The composition of canopy structure may be less important to the two federally listed gartersnakes than ground cover. The downed material resulting from vegetation removal may create local areas of woody material for the gartersnakes cover (Forest Service 2018a). Vegetation treatment projects have been routinely carried out within the ROWs to manage for low growing plant communities. In Alternative A, vegetation maintenance would be limited to targeted manual treatment of individual plants. Effects to the organic structural complexity of streamside habitat may be expected, though impacting a relatively small amount of riparian vegetation components of the proposed critical habitat (Forest Service 2018a). Therefore, Alternative A would result in short- and long-term, direct, negligible, adverse impacts to the narrow-headed gartersnake and northern Mexican gartersnake and their habitats because of the temporary displacement of the snakes during vegetation maintenance activities. Short- and long-term, indirect, minor adverse impacts to the gartersnakes and their habitats are anticipated as a result of Alternative A. The 2018 BA has made the determination that Alternative A “may affect, and is likely to adversely affect” the narrow-headed gartersnake and northern Mexican gartersnake and their proposed critical habitats.

23 Brumation is a term used for the hibernation-like state that cold-blooded animals like snakes utilize during cold weather. Brumation occurs generally from November to February, though there may be active periods during this time when winter temperatures are higher.

120 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Direct and Indirect Effects of Alternative B In addition to the effects associated with Alternative A described above, Alternative B would also result in impacts on the narrow-headed and northern Mexican gartersnakes and their proposed critical habitats from the use of herbicides as part of the management of incompatible vegetation within the ROW. A description of the direct and indirect effects of herbicide treatments on the narrow-headed and northern Mexican gartersnakes and their proposed critical habitats are presented in the 2018 BA (Forest Service 2018a). The detailed discussion of the analyses is not repeated here but is instead incorporated by reference and summarized in this section of the EA. Direct effects to narrow-headed and northern Mexican gartersnakes from contact with herbicides would be minimized by using approved low-toxicity herbicides within and near suitable habitats. Alternative B may introduce very minimal quantities of herbicide into the aquatic habitat through runoff or drift. Herbicide treatments would be limited to spot applications to individual plants within the ROW. The applications would be made when the chance of precipitation is low, and Thinvert would be used to limit runoff and off-site drift of herbicides. The use of herbicides would not result in any change to river flow or flooding regime. The quantity of vegetation treated over the ROW area is low with grasses, forbs, and lower growing shrubs remaining untreated. Changes in vegetation composition affecting the two federally listed gartersnakes’ suitable and proposed critical habitats due to herbicide application that could be expected through this effect is limited to narrow ROWs containing 141.72 acres for narrow-headed gartersnake and 89.00 acres for northern Mexican gartersnake riparian and upland suitable and proposed critical habitat. Prey species could come into contact with herbicide. However, conservation measures that limit which herbicides can be used in narrow-headed and northern Mexican gartersnakes’ habitats would also ensure that herbicides have low toxicity to prey species (Forest Service 2018a). Therefore, Alternative B would result in short- and long-term direct negligible, adverse impacts as well as short- and long-term, indirect, minor, adverse impacts to the narrow-headed gartersnake and northern Mexican gartersnake and their proposed critical habitats. The 2018 BA has made the determination that Alternative B “may affect, and is likely to adversely affect” the narrow-headed gartersnake and northern Mexican gartersnake and its proposed critical habitats.

3.8 Forest Service Sensitive Species 3.8.1. Introduction This section considers each of the Forest Service Sensitive wildlife and plant species that are known to occur or have potential to occur in the APS ROW, excluding those for which the ROW is outside of the species’ range. Whenever possible, species-specific habitat and locality data were used for analysis. Species occurrence data was obtained from various sources including written publications and GIS datasets from the AGFD Heritage Data Management System (AGFD 2016c), and survey data and incidental observations as represented in the Forest GIS databases, published literature on species, and personal communications with Forest Service biologists. Species that do not occur in Arizona or have ranges only located outside of the APS ROW were not considered for further analysis because the alternatives would have no impacts on those species or their respective habitats. 3.8.2. Affected Environment The Forest Service Sensitive Species Lists of wildlife and plants contains 71 species with habitat present in the ROW, including two amphibians, eight birds, five fish, seven invertebrates, five mammals, two reptiles, and 41 plants (refer to Table 3.8-1 through Table 3-43). A description of the 71 species is provided in Forest Service 2018 Draft Herbicide Use within APS Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona (Forest Service 2018b). The amphibian, bird, mammal, and reptile species potentially present could occur in the APS ROW on an incidental basis while moving or foraging, whereas the plant species may occupy or be located directly

121 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests adjacent to the APS ROW. The fish species may be present within the APS ROW via waterways that bisect the APS ROW, or may occur in suitable habitat that is within proximity or downstream of the APS ROW. Although some individual species may occur within the APS ROW, no Forest Service sensitive species are known to occupy the APS ROW exclusively. The sensitive species lists provided below (refer to Table 3.8-1 through Table 3-43) are presented by category and identify the species name, forests for which the species is listed as sensitive, and general habitat association.

Table 3.8-1. Forest Service Sensitive Species – Amphibians Apache- Sitgreaves Coconino Kaibab Prescott Tonto Common Name National National National National National Scientific Name Forests Forest Forest Forest Forest Habitat Association Lowland leopard frog Lithobates ● ● ● ● Aquatic and wetlands yavapaiensis Northern leopard frog Aquatic and wetlands Lithobates pipiens ● ● ● Source: Forest Service Region 3 2016

Table 3.8-2. Forest Service Sensitive Species – Birds

Apache- Sitgreaves Coconino Kaibab Prescott Tonto Common Name National National National National National Scientific Name Forests Forest Forest Forest Forest Habitat Association American peregrine Forested habitats near sheer falcon cliffs, particularly next to Falco peregrinus ● ● ● ● ● riparian forests anatum Dense, tall stands of grass, Baird’s sparrow usually in extensive expanses Ammodramus bairdii ● of grasslands with few mesquite bushes. Riparian forest with mature Bald eagle cottonwoods, occasionally Haliaeetus ● ● ● ● ● coniferous forest. Areas with leucocephalus high water-to-land edge, rock ledges, cliffs, large trees. Burrowing owl (western) Grasslands, desert scrub in Athene cunicularia ● ● ● undeveloped valley bottoms hypugaea Gray catbird Forests and forest edges with Dumetella ● dense vegetation carolinensis Northern goshawk Healthy conifer forest Accipiter gentilis ● ● ● ● ● Sulphur-bellied flycatcher Wooded canyons; prefers Myiodynastes ● sycamores luteiventris

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Apache- Sitgreaves Coconino Kaibab Prescott Tonto Common Name National National National National National Scientific Name Forests Forest Forest Forest Forest Habitat Association Yellow-eyed junco Coniferous forests and pine- Junco phaeonotus ● oak woods Source: Forest Service Region 3 2016

Table 3.8-3. Forest Service Sensitive Species – Invertebrates

Apache- Sitgreaves Coconino Kaibab Prescott Tonto Common Name National National National National National Scientific Name Forests Forest Forest Forest Forest Habitat Association A caddisfly Stream habitats in Oak Creek Lepidostoma knulli ● ● Canyon A caddisfly Stream habitats Wormaldia planae ● ● ● A mayfly Stream habitats, Salt River Fallceon eatoni ● Canyon in Gila County A mayfly Stream habitats in Oak Creek Moribaetis ● Canyon mimbresaurus Balmorhea saddle- Lotic environments in the case caddisfly ● Page/Bubbling/Lolomai Protoptila balmorhea Springs/Oak Creek Complex California floater Shallow freshwater in lakes, Anodonta ● ● reservoirs, streams with californiensis stable low velocities Rocks, vegetation, floating algal mats and submerged Page springsnail woody debris associated with Pyrgulopsis ● slow to moderate flows of morrisoni head springs, seeps, and lateral spring runs. Source: Forest Service Region 3 2016

Table 3.8-4. Forest Service Sensitive Species – Fish Apache- Coconino Kaibab Prescott Tonto Common Name Sitgreaves National National National National Habitat Association National Scientific Name Forest Forest Forest Forest Forests Desert sucker Aquatic Catostomus clarkii ● ● ● ● Headwater chub Aquatic Gila nigra ● ● ● Little Colorado sucker Catostomus sp.3 Aquatic (Candidate Conservation ● ● Agreement)

123 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Apache- Coconino Kaibab Prescott Tonto Common Name Sitgreaves National National National National Habitat Association National Scientific Name Forest Forest Forest Forest Forests Roundtail chub Aquatic Gila robusta ● ● ● ● Sonora sucker Aquatic Catostomus insignis ● ● ● ● Source: Forest Service Region 3 2016

Table 3.8-5. Forest Service Sensitive Species – Mammals Apache- Coconino Kaibab Prescott Tonto Common Name Sitgreaves National National National National Habitat Association National Scientific Name Forest Forest Forest Forest Forests Allen’s lappet-browed Desert scrub through to bat ● ● ● ● ponderosa forest zone with Idionycteris phyllotis mountains and cliffs Navajo Mogollon vole Meadows and Montane Microtus mogollonensis ● ● ● habitats near Mogollon Rim navaho Pale Townsend’s big- eared bat Desert scrub through to the Corynorhinus townsendii ● ● ● ● ● ponderosa/mixed conifer zone. pallescens Desert scrub through to Spotted bat ponderosa forest zone with Euderma maculatum ● ● ● ● mountains and cliffs Western red bat Riparian forests Lasiurus blossevillii ● ● ● ● ● Source: Forest Service Region 3 2016

Table 3.8-6. Forest Service Sensitive Species – Reptiles Apache- Coconino Kaibab Prescott Tonto Common Name Sitgreaves National National National National Habitat Association National Scientific Name Forest Forest Forest Forest Forests Rugged, rocky slopes and boulder fields within the Bezy’s night lizard upland Sonoran desertscrub Xantusia bezyi ● and interior chaparral communities. Desertscrub habitats, Sonoran desert tortoise particularly in foothills and Gopherus morafkai ● ● rocky substrates above low desert valleys Source: Forest Service Region 3 2016

124 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Table 3.8-7. Forest Service Sensitive Species – Plants Apache- Coconino Kaibab Prescott Tonto Common Name Sitgreaves National National National National Habitat Association National Scientific Name Forest Forest Forest Forest Forests Moist stream banks, seeps, Alcove bog orchid and hanging gardens; require Platanthera zothecina ● constant moisture. Moist soil in the shade of Aravaipa woodfern boulders in mesic canyons. Thelypteris puberula ● On riverbanks, seepage areas, var. sonorensis and meadow habitats. Shaded rocky slopes, in Arizona alum root humus soil, near seeps, Heuchera glomerulata ● ● streams and riparian areas. Located along moist, shady canyon bottoms and lower Arizona bugbane canyon slopes. Grows in Cimicifuga arizonica ● ● ● moist, loamy soil of ecotone between coniferous forest and riparian habitat. Moist mountain meadows, Arizona leatherflower, prairies, and open woods and clustered leatherflower thickets usually in limestone Clematis hirsutissima ● ● soils of ponderosa pine and var. hirsutissima mixed conifer. Open exposed limestone- rocky slopes within pinyon- Arizona phlox juniper woodlands and Phlox amabilis ● ● ● ● ● ponderosa pine-Gambel oak communities. Found in regions of ponderosa pine forests, Arizona sneezeweed especially around wet places Helenium arizonicum ● ● (bogs, ponds, lakes, roadside ditches). Arizona sunflower Open pine and/or juniper Helianthus arizonensis ● ● woodlands. Found along riverbanks, Bebb’s willow stream banks, overflow Salix bebbiana ● ● channels, and seeps. Mid to high-elevation wetlands with moist, organic Blumer’s dock soil adjacent to perennial Rumex orthoneurus ● ● ● springs or streams in canyons or meadows. Streams and moist soil of dry Broadleaf lupine stream beds, in oak- Lupinus latifolius ssp. ● ● cottonwood mixed shrub, and leucanthus ponderosa pine forest communities.

125 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Apache- Coconino Kaibab Prescott Tonto Common Name Sitgreaves National National National National Habitat Association National Scientific Name Forest Forest Forest Forest Forests Wet soils in streambeds, shallower draws in pine-oak Chihuahuan sedge forest and riparian woodland; Carex chihuahuensis ● ● wet meadows, cienegas, marshy areas, canyon bottoms. Moist soil near permanently Cochise sedge wet springs and streams; Carex ultra (=c. spissa ● ● ● undulating rocky-gravelly var. Ultra) terrain. Moist shaded slopes in Eastwood alum root ponderosa pine forests and Heuchera eastwoodiae ● ● ● ● canyons. Ertter’s rose Oak Creek canyon in Rosa woodsii var. ● Coconino National Forest. ertterae Very xeric habitat on very steep slopes, from cracks and Fish Creek rockdaisy crevices on cliff faces, large Perityle saxicola ● boulders and rocky outcrops in canyons and on buttes. Dry ponderosa pine forests in Flagstaff beardtongue mountainous regions south of Penstemon nudiflorus ● ● ● ● the Grand Canyon. Rock pavement, cliff, limestone and sandstone Flagstaff pennyroyal break habitats in the Hedeoma diffusum ● ● ● ● ponderosa pine vegetation type. Upper floodplains terraces in Galiuro sage shady canyon bottoms near Salvia amissa ● streams in understory of mature trees. Open grassland areas with Greene milkweed Madrean evergreen woodland Asclepias uncialis var. ● ● communities in Coconino, uncialis Pima, and Santa Cruz counties. Heathleaf wild Dry, gravelly to rocky slopes buckwheat of lacustrine, in mixed Eriogonum ericifolium ● ● ● grasslands, chaparral and var. ericifolium oak-woodlands.

126 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Apache- Coconino Kaibab Prescott Tonto Common Name Sitgreaves National National National National Habitat Association National Scientific Name Forest Forest Forest Forest Forests Found on benches or alluvial terraces on gentle bajada slopes above major drainages in desert scrub, with pre- Hohokam agave Columbian agricultural and Agave murpheyi ● settlement features, having been cultivated by the Hohokam. Also found near rock piles. Hualapai milkwort Desert grassland and juniper Polygala rusbyi ● ● ● woodland. Rocky, talus slopes and ledges, usually on sandstone, in pockets of soil between rocks, in evergreen woodland Lyngholm’s brakefern or chaparral plant Pellaea lyngholmii ● communities; occurs ONLY in NE corner of Yavapai County, approx. 20 miles SW of Flagstaff. Mapleleaf false snapdragon Rock overhands, on shaded Mabrya acerifolia ● cliffs and rock ledges. (=Maurandya acerifolia) Mearns sage Open creosotebush-shrub Salvia dorrii ssp. ● ● community in gypseous mearnsii limestone. Rocky slopes and canyons in Metcalfe’s tick-trefoil grasslands, oak/pinyon Desmodium metcalfei ● ● ● juniper woodlands and riparian forests. Granite cliff faces, chaparral through pine forests. Rock Mogollon fleabane crevices or ledges on Erigeron anchana ● boulders and vertical rock faces, usually in canyons. Oak and pine forests. Also Mt. Dellenbaugh found in open pine and pine- sandwort ● ● ● ● pinyon woodlands, and Arenaria aberrans among junipers. Rocky hillsides, grassland, Page springs agave woodland. Found near pre- Agave yavapaiensis ● Columbian agricultural and settlement features.

127 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Apache- Coconino Kaibab Prescott Tonto Common Name Sitgreaves National National National National Habitat Association National Scientific Name Forest Forest Forest Forest Forests Was only known to be found in Grand Canyon National Park, found on terraces next to rivers; however it was recently discovered in the Middle Verde Valley near Phillips’ agave Tuzigoot, Page Springs, Agave phillipsiana ● ● ● Sedona, and along the Hassayampa River south of Prescott. All findings are near archaeological features including habitation sites and agave processing tools. In tertiary lakebeds on well- drained powdery soils Ripley wild buckwheat derived from limestone, Eriogonum ripleyi ● ● ● sandstone, or volcanic tuffs and ashes. Sheer canyon walls, moist Rock fleabane north-facing slopes, steep Erigeron saxatilis ● ● ● solid rock and bedrock outcrops. Openings or meadows in ponderosa pine forests or at Rusby’s milkvetch the edges of thickets and Astragalus rusbyi ● ● aspen groves. From San Francisco Peaks to Oak Creek Canyon Rocky hillsides, grassland, Sacred mountain woodland. Found near pre- agave ● Columbian agricultural and Agave verdensis settlement features. Salt River rockdaisy Perityle gilensis var. ● Found along the Salt River salensis Cinder fields that are devoid of soil covering where other beardtongue ● herbaceous vegetation is Penstemon clutei sparse. Atop benches, at edges of slopes, and open hilly slopes Tonto Basin agave in desert scrub, overlooking Agave delamateri ● ● ● major drainages and perennial streams. Toumey groundsel Oak chaparral, and Packera neomexicana sometimes in pine forest, in var. toumeyi ● ● Cochise and Gila counties. (=Senecio n. var. t.)

128 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Apache- Coconino Kaibab Prescott Tonto Common Name Sitgreaves National National National National Habitat Association National Scientific Name Forest Forest Forest Forest Forests Open pinyon-juniper Tusayan rabbitbrush, grasslands on slopes and disturbed rabbitbrush flats, where periodic fires Chrysothamnus ● ● naturally occur at an interval molestus of every 15-30 years. Seldom found on steep hillsides. Sonoran desert scrub or Verde breadroot scattered juniper Pediomelum ● ● ● communities on limestone or verdiensis compacted roadsides. Source: Forest Service Region 3 2016

To evaluate potential impacts of the alternatives on habitat for sensitive wildlife, candidate wildlife, and wildlife with conservation agreements, an analysis was performed by identifying relevant ERUs for each species. A summary of this analysis is provided below in Section 3.8.4 Environmental Consequences. A more detailed description of habitat for each species is provided in the BE (Forest Service 2018b) 3.8.3. Design Features Design features applicable to forest sensitive species are stated in Chapter 2. For design features related to manual and mechanical treatment methods, refer to Section 2.1.8; for design features related to herbicide treatment methods, refer to Sections 2.1.8 and 2.2.11. Additionally, biological resources conservation measures from the 2018 BA and 2018 BE have been included in Appendix E. 3.8.4. Environmental Consequences

Amphibians There are two aquatic amphibians that are known to or could occur in APS ROW on National Forest System lands: the lowland leopard frog and northern leopard frog. There are no sensitive terrestrial amphibians present in the ROW.

Direct and Indirect Effects of Alternative A Under Alternative A, routine vegetation maintenance using mechanical vegetation removal is not proposed to occur within riparian areas and wetlands or within the adjacent riparian habitats (refer to design features in Section 2.1.8 Alternative A Design Features). All vehicles within riparian areas and wetlands would remain on existing roads, minimizing individual and habitat impacts. Human presence may temporarily displace Forest Service sensitive amphibians during manual treatments in the ROW from manual treatments. However, because adult frogs tend to avoid terrestrial predators and other perceived threats by jumping into water or retreating into burrows, work crews may cause frogs or toads to retreat, which would reduce the likelihood of direct contact with work crews and equipment. Some impacts associated with temporary changes in behavior are expected during work activities though these impacts are short in duration and not likely to result in adverse impacts to sensitive amphibians. The ongoing vegetation management work is not expected to contribute to viability declines on the Forest for these amphibians. In the long-term, the frequency of routine vegetation maintenance disturbance in Alternative A as compared to Alternative B would create more opportunity for the two Forest Service sensitive amphibians to be impacted. However, design features would minimize any potential impacts to amphibians. Lower growing shrubs, grasses, and forbs providing cover would remain untreated.

129 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Therefore, Alternative A would result in direct and indirect, short- and long-term negligible, adverse impacts to Forest Service sensitive amphibians because the potential for direct contact with the species would be unlikely and changes in their habitat would not adversely affect the survivability of amphibians. In addition, the 2018 BE has made the determination that the Alternative A “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the lowland leopard frog and northern leopard frog.

Direct and Indirect Effects of Alternative B In addition to the effects associated with Alternative A described above, Alternative B would also result in impacts on the two Forest Service sensitive amphibian species. It is highly unlikely that the Forest Service sensitive amphibians would be directly sprayed with herbicide. Aquatic amphibians are most active and tend to travel between aquatic sites during summer monsoon storms (ADOT 2014). It is not a best practice to apply herbicides when it is raining or a storm event is likely within a few hours after application. Human presence may temporarily displace Forest Service sensitive amphibians during herbicide treatments in the project area. However, because adult frogs and toads tend to avoid terrestrial predators and other perceived threats by jumping into water or retreating into burrows, work crews may cause frogs or toads to retreat and seek shelter. Sensitive amphibians could contact treated vegetation when traveling in terrestrial habitat. Terrestrial amphibians may be more prone to coming into contact with treated vegetation. Two herbicides, dicamba and triclopyr (ester formulation) are of higher toxicity to terrestrial and aquatic amphibians. Dicamba would rarely be used by APS and only after review of special circumstances during the PUP process (refer to Section 2.2.9 Pesticide Use Proposal). The amine formulation of triclopyr would be a commonly used herbicide during project implementation. This herbicide is labeled for aquatic use with low toxicity to amphibians. The ester formulation of triclopyr is high in toxicity to amphibians but is unlikely to be used; it is not labeled for aquatic use and it tends to volatilize at temperatures above 85 degrees. Conservation measures specify that a 50 foot buffer from any waterbody or wetland would be required for any applications involving the ester formulation of triclopyr or dicamba, so is unlikely that amphibians would come into contact with these higher toxicity herbicides (refer to Biological Resources Conservation Measures in Appendix E). Even if aquatic or terrestrial amphibians come into contact with treated vegetation, it is unlikely the herbicide would have any effect on these sensitive species. Herbicide treatments, including those near water sources, would be achieved by spot application to single plants or plant clusters using hand-operated backpack sprayers. Alternative B would not include the application of herbicides directly to standing water but only to the target terrestrial plants. Impacts from drift or runoff would be minimized by implementing design features. The design features include proper application methods and drift reduction agents to ensure that only target vegetation is treated and off target exposure to herbicide is minimized. In addition, Thinvert would be used as a carrier and would provide a measure of “rainfastness”, by adhering to the target plant or plant cluster. The chance that herbicides would leach or runoff into the environment is very low. Herbicides are only applied on vegetation previously cut or new growth vegetation. Grasses, forbs, and many smaller shrubs would remain untreated for the majority of the ROW with the exception of DSAP treatment areas. The implementation of design features would substantially reduce potential impacts to Forest Service sensitive amphibian species. Herbicide toxicity is low (with the exception of dicamba and ester formulation of triclopyr which would only be used in pre-approved locations), and any reduction in plant cover would be small and localized. Therefore, the Alternative B would result in direct and indirect, short-term, negligible, adverse impacts to the two Forest Service sensitive amphibian species because the potential for direct contact with the species would be unlikely and due to the effectiveness of design features when implemented. There would also be direct and indirect, long-term, negligible, beneficial impacts to these species because the frequency of routine vegetation maintenance would decrease, which would reduce the presence of workers and noise within suitable habitats. In addition, the 2018 BE has

130 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona made the determination that the Alternative B “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the lowland leopard frog and northern leopard frog.

There are six Forest Service sensitive bird species that are primarily terrestrial that are known to or could occur in APS ROW on National Forest System lands: American peregrine falcon, Baird’s sparrow, bald eagle, western burrowing owl, northern goshawk, and yellow-eyed junco. The remaining two sensitive species, gray catbird and sulphur-bellied flycatcher, are associated with riparian habitats.

Direct and Indirect Effects of Alternative A Under Alternative A, manual and mechanical control methods would continue to be used to maintain vegetation within the ROW. Mechanical treatments would not occur within riparian areas as identified in project design features. There are nine Forest Service sensitive bird species with suitable habitat within the ROW. The ROW has been regularly maintained in the past. APS maintenance crews who complete vegetation treatments in the ROWs are provided with training on appropriate nest avoidance measures and reporting requirements. The maintenance crews would internally report active nests that occur on vegetation or on the ground per APS’s avian reporting procedures and restrict treatments on the vegetation containing the nest until after nesting is complete. Maintenance crews do not conduct routine vegetation maintenance and DSAP treatments on the vegetation containing the nest and vegetation adjacent to ground nesting birds until after nesting is complete. The power line ROWs are currently being maintained free of incompatible vegetation and Alternative A would continue in maintaining these conditions such that Alternative A would not contribute to an overall decline of suitable habitat for Forest Service sensitive bird species. The American peregrine falcon, bald eagle, and northern goshawk prefer nesting and perching habitat that consists of cliffs, ledges, or mature vegetation; they may, however, forage in the ROW. Baird’s sparrow only breeds in the northern United States and Canada, not in Arizona. Burrowing owl, Baird’s sparrow, and yellow-eyed junco prefer shrubs, grasslands, or the ground as suitable habitat. This type of habitat generally does not require vegetation management actions, or if management action is needed, it would only target scattered trees or shrubs within the grassland habitat. Vegetation removal in riparian habitat would involve removal within the ROW only, and not along an entire reach of stream or river. Human presence and noise from chainsaw and other equipment may temporarily disturb gray catbird and sulphur-bellied flycatcher while foraging or migrating near or within the project area. However, these birds would simply retreat to adjacent habitat and impacts during foraging and migrating would be minimal. Changes in vegetation composition affecting suitable habitat for Forest Service sensitive bird species are anticipated to be localized and these habitats would be slightly altered in the short-term. Direct contact with Forest Service sensitive bird species would be unlikely due to their ability of flight. In comparison, direct impacts to terrestrial birds are expected to be relatively greater under Alternative A than Alternative B. Under Alternative A, vegetation management would continue to be conducted using manual and mechanical methods alone. These actions would be conducted more frequently, longer in duration, require more people, and have greater sound levels than herbicide application. These impacts could disturb terrestrial birds during nesting, foraging, and migration. Therefore, Alternative A would result in direct and indirect, short- and long-term, negligible, adverse impacts to Forest Service sensitive bird species. In addition, the 2018 BE has made the determination that the Alternative A “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the American peregrine falcon, baird’s sparrow, bald eagle, western burrowing owl, gray catbird, northern goshawk, sulphur-bellied flycatcher and yellow-eyed junco.

131 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Direct and Indirect Effects of Alternative B In addition to the effects associated with Alternative A described above, Alternative B would also result in impacts on Forest Service sensitive bird species. APS personnel and contractors who apply herbicide in the ROWs are provided with training on appropriate nest avoidance measures and reporting requirements. When applying herbicide on National Forest System lands crews would undergo the same training as discussed in Alternative A and report active nests on vegetation or on the ground. All treatments on the vegetation containing the nest and vegetation adjacent to ground nesting birds would be delayed until after nesting is complete. Herbicide application would result in minimal impacts to Forest Service sensitive predatory bird species; though they have been documented nesting in the vicinity of ROWs, peregrine falcons and bald eagles are not likely to nest within the ROWs. Conservation measures would be implemented to minimize impacts to peregrine falcons, bald eagles, and northern goshawks during their breeding seasons (refer to Biological Resources Conservation Measures in Appendix E). Smaller birds have the potential to come into contact with vegetation treated with herbicide, though there is a low potential for exposure because the ROWs are currently maintained free of mature vegetation and only seedling and resprouted vegetation would be treated under Alternative B. The only herbicide that is highly toxic to birds that is proposed is dicamba. This herbicide would be rarely used by APS, would only be used following review of the treatment locations during the PUP process, and would only be used outside of the buffers provided in the conservation measures for migratory birds (refer to Biological Resources Conservation Measures in Appendix E). A qualified biologist or resource specialist would provide the maintenance crew members with training on migratory bird nest reporting and nest avoidance. Similar to Alternative A, herbicide treatments could result in temporary noise and visual disturbances, but only while workers are present at a given location; the use of herbicide as a tool for managing vegetation would reduce the frequency and intensity of ongoing vegetation management. Therefore, Alternative B would result in direct and indirect, short-term, negligible, adverse impacts to Forest Service sensitive bird species because the potential for direct contact with the species would be unlikely due to the implementation of design features and conservation measures. There would also be direct and indirect, long-term, negligible, beneficial impacts to these species in Alternative B because the frequency and intensity of routine vegetation maintenance would decrease, which would reduce the presence of workers and noise within suitable habitat. In addition, the 2018 BE has made the determination that the Alternative B “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the American peregrine falcon, Baird’s sparrow, bald eagle, western burrowing owl, gray catbird, northern goshawk, sulphur-bellied flycatcher and yellow-eyed junco.

Invertebrates There are seven Forest Service sensitive invertebrate species that could have suitable habitat in the ROW: several caddisflies and mayflies (Lepidostoma knulli, Fallceon eatoni, Morbaetis mimbresaurus, Protoptila balmorhea, and Wormaldia planae), a springsnail (Pyrgulopsis morrisoni), and a mussel (California floater). These invertebrates may occur within ROWs in streams and other aquatic habitats.

Direct and Indirect Effects of Alternative A Under Alternative A, manual and mechanical control methods would continue to be used to maintain vegetation within the ROW, though mechanical treatment would not occur within riparian areas and wetlands. There are no poles with equipment that can spark within wetland or riparian areas, therefore no DSAP maintenance treatments would occur in these areas. Vegetation management actions in riparian areas adjacent to aquatic habitats could reduce vegetation cover locally. The ROWs that cross over creeks or rivers have been continually maintained through manual methods and the composition of tall vegetation is already sparse in comparison to riparian vegetation adjacent to the ROWs. Vegetation management actions would target vegetation previously maintained that has resprouted or young, new

132 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona growth vegetation not previous cut. Any change in shade structure would be localized and unlikely to result in any change in water temperature. Individual invertebrates may be impacted by a temporary increase in predation due to reductions in vegetative cover. Reductions in vegetative cover near aquatic sites may cause sensitive invertebrates to use habitat adjacent to the project area where conditions would not change. The continued manual treatment of vegetation would not notably alter existing conditions in the powerline ROW. Because vehicles (generally trucks, ATVs, and lift trucks) remain on existing roads open to the public in and near aquatic areas, crushing invertebrate larvae, adults, and eggs during ongoing maintenance activities would be unlikely. Alternative A would result in direct and indirect, short- and long-term negligible, adverse impacts to Forest Service sensitive invertebrate species. In addition, the 2018 BE has made the determination that the Alternative A “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the aforementioned Forest service sensitive invertebrates.

Direct and Indirect Effects of Alternative B In addition to the effects associated with Alternative A described above, Alternative B would also result in impacts on the seven Forest Service sensitive invertebrate species. Conservation measures would be implemented for any herbicide application near aquatic habitats in order to minimize impacts to Forest Service sensitive species. Potential impacts to invertebrates from Alternative B would be through exposure to herbicide that has drifted into the water or from herbicide runoff into the water. However, the implementation of design features would minimize the chance of herbicides reaching these aquatic habitats. If herbicides would reach aquatic habitats, the toxicity and the amount of herbicide used would be so small as to be unmeasurable in the water. Herbicides would be applied in a targeted manner (spot application) to individual plants or the target area for DSAP and would not be applied with broadcast or aerial applications. Thinvert would help adhere the herbicide to the plant surface. Each spray droplet would be coated with a thin film of oil which would not evaporate while falling, reducing susceptibility to off-target movement (Waldrum Specialties 2002). In addition, herbicide applications would be limited only to times when probability of rain is low, further reducing the chance of runoff. Due to the ongoing vegetation treatment within the ROWs, it is not anticipated that the addition of herbicide treatments would significantly alter existing conditions within the project area. Invertebrates have the potential to come into contact with vegetation treated with herbicide. The proposed herbicides are generally low in toxicity to invertebrates, with the exception of 2,4-D, for which the toxicity level is unknown and needs additional research. However, this herbicide would rarely be used and is subject to review and approval for use during the PUP process. Runoff of herbicides (including 2,4-D) into the aquatic environment is unlikely and minimized by conservation measures and design features including the use of Thinvert for most herbicide applications as described above. The herbicides that would be used near aquatic areas would be restricted to those that are low in toxicity to aquatic and riparian species. In the unlikely event herbicides reach aquatic habitat, the likelihood of any effects to invertebrates would be low and not measurable. Vehicles (trucks and ATVs/UTVs) would not be used within riparian areas, wetlands, and aquatic habitat except on existing roads open to the public, thus the potential to impact invertebrates through crushing larvae, eggs, and adults is highly unlikely. Workers on foot with backpack sprayers are not likely to trample eggs and larvae during treatment because these invertebrate lay their eggs in water where herbicide application activities are not proposed. Therefore, Alternative B would result in direct and indirect, short-term, negligible, adverse impacts to Forest Service sensitive invertebrate species because the potential for direct contact with these species would be unlikely due to the effectiveness of design

133 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests features and conservation measures. There would also be direct and indirect, long-term, negligible, beneficial impacts to these species because the frequency of routine vegetation maintenance would decrease, which would reduce disturbance within and adjacent to aquatic habitats. In addition, the 2018 BE has made the determination that the Alternative B “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the aforementioned Forest service sensitive invertebrates.

Fish There are five Forest Service sensitive fish species that could have suitable habitat in the ROW: the desert sucker, Little Colorado sucker, Sonora sucker, headwater chub, and roundtail chub.

Direct and Indirect Effects of Alternative A Under Alternative A, manual cutting of vegetation adjacent to aquatic environments (e.g., riparian vegetation), and manual and mechanical cutting of vegetation in upland areas would continue; these treatments would have no direct impact on fish because these activities would occur outside of aquatic habitats. Vegetation management actions in riparian areas could reduce shade and cover for aquatic habitats, and potentially affect bank stability, but these changes would be localized to small areas and would not have significant impacts to fish habitat. The ROWs that cross over creeks or rivers have been continually maintained through manual methods and the composition of tall vegetation is already sparse in comparison to riparian vegetation adjacent to the ROWs. Vegetation management actions would target vegetation previously maintained that has resprouted or young, new growth vegetation not previously cut. Any change in shade structure would be localized and unlikely to result in any change in water temperature. Use of a mechanical mower is not proposed to occur within riparian habitats, minimizing the potential for surface disturbance and runoff into aquatic environments. Manual and mechanical treatment of vegetation in the upland habitat and manual treatment of vegetation in riparian habitat are highly unlikely to cause soil disturbance that could run off into aquatic environments because these treatments only include removal of tall growing vegetation and incompatible dense shrubs while soil-stabilizing vegetation such as grasses, forbs, and some shrubs would remain untreated. With the implementation of design features and conservation measures, the amount of sedimentation that may occur is expected to be minimal and unlikely to result in any detectable changes to rivers or streams adjacent to or crossed by ROWs. Therefore, Alternative A would result in direct and indirect, short- and long-term negligible, adverse impacts to Forest Service sensitive fish species. In addition, the 2018 BE has made the determination that the Alternative A “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the desert sucker, Little Colorado sucker, Sonora sucker, headwater chub, and roundtail chub.

Direct and Indirect Effects of Alternative B In addition to the effects associated with Alternative A described above, Alternative B would also result in impacts on the five Forest Service sensitive fish species as a result of herbicide application within APS ROWs. Herbicides would be applied in a targeted manner (spot application) to individual plants or the target area for DSAP and would not be applied with broadcast or aerial applications. Thinvert would help adhere the herbicide to the plant surface. Each spray droplet would be coated with a thin film of oil which would not evaporate while falling, reducing susceptibility to off-target movement (Waldrum Specialties 2002). In addition, herbicide applications would be limited only to times when probability of rain is low, further reducing the chance of runoff. Under Alternative B, the most probable modes of exposure of sensitive fish to herbicides would be through drift or runoff of herbicide into the water. There is a small chance that some terrestrial invertebrates may be exposed to herbicides and consumed by fish, though this is not likely to be a significant route for herbicide exposure for fish. Fish exposed to herbicide may experience various types

134 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona of lethal and sub-lethal adverse effects depending on the toxicity and concentration of the herbicide that comes in contact with the fish. The implementation of design features and conservation measures for any herbicide application near bodies of water would ensure that only low toxicity herbicides are applied adjacent to aquatic habitats and would minimize the chance of herbicides reaching these aquatic habitats. Vegetation management activities may result in minor changes to vegetation composition, but would not impact the physical composition and structure of streams, springs, and rivers. The ROWs have been continually maintained and already provide less cover and shade than is present in adjacent areas. Therefore, Alternative B would result in direct and indirect, short-term, negligible, adverse impacts to Forest Service sensitive fish species because the potential for direct contact with these species would be unlikely with the implementation of design features and conservation measures. There would also be direct and indirect, long-term, negligible, beneficial impacts to these species because the frequency of routine vegetation maintenance would decrease, which would reduce disturbance within and adjacent to aquatic habitats. In addition, the 2018 BE has made the determination that the Alternative B “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the desert sucker, Little Colorado sucker, Sonora sucker, headwater chub, and roundtail chub.

Mammals There are three primarily terrestrial bat species that are known to or could occur in APS ROW: Allen’s lappet-browed bat, pale Townsend’s big-eared bat, and spotted bat. The remaining two Forest Service sensitive mammal species are the western red bat and the Navajo Mogollon vole, which favor riparian forests and meadows, respectively.

Direct and Indirect Effects of Alternative A Under the Alternative A, routine aerial and ground inspections would be conducted along with manual and mechanical vegetation treatment methods within the ROW. All three of the terrestrial bats roost in one or more of the following: caves, mines, manmade structures, rock shelters, tunnels, under bridges, and cliff cracks and crevices. None of these roost types are present within the power line ROWs. Western red bats roost during the day in the foliage of riparian trees, such as cottonwood, willow, and oak trees. Allen’s lappet-browed bat may also roost on tree snags and under the loose bark of trees. While suitable roost trees may occur adjacent to APS ROW, the ROWs have been continually maintained free of snags and mature trees, so these types of roost trees do not occur within the ROW. Manual and mechanical control methods would be used in Alternative A to maintain vegetation within the ROW. Because bats roost during the day, and these roosts could occur adjacent to the ROWs, human activity and noise from chainsaws and mowers could disturb bats at their day roosts. This impact would be short in duration over a single day or few days of work. Because vegetation has been continually maintained within the ROW in suitable habitats for Allen’s lappet-browed bat and western red bat, Alternative A would result in no change to availability of suitable habitat for these species. Navajo Mogollon vole is nocturnal and occupies burrows in grassland habitat, which do not generally require vegetation management activities. However, some tree species occur scattered within grassland habitats that require maintenance. Shrubs in sparse grassland vegetation are not generally targeted for removal unless they occur within the area around distribution line poles that may receive DSAP treatment. Vehicles (generally trucks, ATVs, and mechanical mowers) could drive over burrows within the power line ROWs requiring the burrow be rebuilt. This could result in impacts to individuals and localized populations but not to the extent of impacting survivability of any colony of voles. Therefore, Alternative A would result in direct and indirect, short- and long-term, negligible, adverse impacts to Forest Service sensitive mammals because the implementation of design features would be unlikely to result in measurable impacts to the species or their habitat. In addition, the 2018 BE has made

135 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests the determination that the Alternative A “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the Allen’s lappet-browed bat, pale Townsend’s big-eared bat, spotted bat, western red bat, and Navajo Mogollon vole.

Direct and Indirect Effects of Alternative B In addition to the effects associated with Alternative A described above, Alternative B would also result in impacts to Forest Service sensitive mammal species. None of the roost types for the four sensitive bat species would be targeted directly by herbicide. Because bats roost at night, and would not be out during the day during herbicide application, the bats would not be directly sprayed by herbicide. Disturbance to bats from aerial and ground-based inspection and vegetation treatment activities would be unlikely because these bats actively forage in the evenings and at night, while the aerial and ground-based activities occur during the day. Bats could come into contact with vegetation that has been sprayed with herbicide. However, by the time bats are out at night foraging, the vegetation would be dry and thus, dermal contact is not likely. All four of the Forest Service sensitive bats feed exclusively on insects, catching their prey in air, from the ground, and/or from vegetation. It is unlikely that bats would ingest prey that has been sprayed with herbicide because of the limited and targeted nature of the herbicide applications. If this event were to occur, the only herbicide proposed for use that is highly toxic to bats is dicamba; this herbicide is rarely used and would only be used following review of treatment locations during the PUP process. Navajo Mogollon voles are not likely to be directly sprayed with herbicide because they are nocturnal and not likely to be above-ground during herbicide applications. Because herbicide application is targeted to specific plants and includes measures to minimize drift, drip onto the ground, and runoff, it is unlikely that the voles would be directly exposed to herbicide in the area around burrow entrances or come into contact with treated vegetation. The only herbicide proposed for use that is highly toxic to voles is dicamba; this herbicide is rarely used and would only be used following review of treatment locations during the PUP process. The use of herbicides under Alternative B would reduce the frequency of vegetation cutting using manual and mechanical methods and would result in a slight reduction in impacts associated with driving over burrows. Alternative B would result in direct and indirect, short-term, negligible, adverse impacts to Forest Service sensitive mammal species because the potential for direct contact would be unlikely due to the implementation of design features and conservation measures. There would also be direct and indirect, long-term, negligible, beneficial impacts to these species because the frequency of routine vegetation maintenance would decrease, which would reduce the presence of workers and noise within suitable habitat. In addition, the 2018 BE has made the determination that the Alternative B “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the Allen’s lappet-browed bat, pale Townsend’s big-eared bat, spotted bat, western red bat, and Navajo Mogollon vole.

Reptiles There are two Forest Service sensitive reptile species that are known to or could occur in APS ROW on National Forest System lands: the Bezy’s night lizard and Sonoran desert tortoise.

Direct and Indirect Effects of Alternative A Under Alternative A, manual treatments, including DSAP maintenance, would be unlikely to affect most Forest Service sensitive reptile species. Maintenance using mechanical vegetation removal could result in disturbance to reptiles including those seeking cover in shallow burrows and/or to terrestrial habitat by the use of heavy equipment and larger vehicles. For Sonoran desert tortoise, crews are trained to look for tortoise when working in suitable habitat and to follow the AGFD handling protocol. Habitat for Bezy’s night lizard involves availability of cover sites in plant debris, rocks, and crevices. Under Alternative A,

136 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona the existing conditions for cover sites would not change as these actions would not impact cover. Similarly, the Sonoran desert tortoise requires shelter/cover sites which would also not be impacted under Alternative A. In the long-term, the frequency of routine vegetation maintenance disturbance in Alternative A as compared to Alternative B would create more opportunity for Forest Service sensitive reptiles to be impacted. However, design features would minimize any potential impacts to reptiles. Lower growing shrubs, grasses, and forbs providing cover would remain untreated. Therefore, Alternative A would result in direct and indirect, short- and long-term negligible, adverse impacts to Forest Service sensitive amphibians and reptiles because the potential for direct contact with the species would be unlikely and their habitat would not be measurably disturbed. In addition, the 2018 BE has made the determination that the Alternative A “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the Bezy’s night lizard and Sonoran desert tortoise.

Direct and Indirect Effects of Alternative B In addition to the effects associated with the Alternative A described above, Alternative B would also result in impacts on the two Forest Service sensitive reptile species. Direct impacts from herbicide application to reptiles would also be unlikely. All species would generally retreat from the work environment during application and would not be directly sprayed. An additional check for tortoise around vegetation to be treated would be conducted to look for tortoise resting under vegetation prior to herbicide application. Forest Service sensitive reptiles may be impacted through contact with vegetation that has been sprayed. The design features include proper application methods and drift reduction agents to ensure that only target vegetation is treated and off target exposure to herbicide is minimized. In addition, Thinvert would be used as a carrier and would provide a measure of “rainfastness”, by adhering to the target plant or plant cluster. The chance that herbicides would leach or runoff into the environment is very low. Herbicides are only applied on vegetation previously cut or new growth vegetation. Grasses, forbs, and many smaller shrubs would remain untreated for the majority of the ROW with the exception of DSAP treatment areas, which occur at a small number of isolated poles. Even if reptiles come into contact with treated vegetation, it is unlikely the herbicide would have any effect on these sensitive species. The implementation of design features would substantially reduce potential impacts to Forest Service sensitive reptile species. Herbicide toxicity is low (with the exception of dicamba which would only be used in pre-approved locations and would not be used in Sonoran desert tortoise habitat per the species-specific conservation measures), and any reduction in plant cover would be small and localized. Therefore, Alternative B would result in direct and indirect, short-term, negligible, adverse impacts to Forest Service sensitive reptile species because the potential for direct contact with the species would be unlikely and due to the effectiveness of design features when implemented. There would also be direct and indirect, long-term, negligible, beneficial impacts to these species because the frequency of routine vegetation maintenance would decrease, which would reduce the presence of workers and noise within suitable habitats. In addition, the 2018 BE has made the determination that the Alternative B “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the Bezy’s night lizard and Sonoran desert tortoise.

Plants There are 41 Forest Service sensitive plants that may occur in APS ROW on National Forest System lands. Of the 41 plants that may occur in the ROW, there are seven plants that can grow tall enough to be a threat to the power lines. This includes: Bebb’s willow, which grows up to 25 feet tall; Ertter’s rose, which grows up to 10 feet tall; and five agave species for which the stalks may grow between 13 and 20 feet tall. There are six plants that may occur in the project area that only occur on very steep slopes,

137 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests cracks and crevices on cliff faces, rock ledges, and/or at the base of cliffs and steep canyon walls, including: eastwood alumroot, Fish Creek rockdaisy, mapleleaf false snapdragon, Mogollon fleabane, rock fleabane, and Salt River rockdaisy. There are seven plants that prefer open habitat types and include: Arizona phlox, Arizona sneezeweed, Arizona sunflower, Flagstaff pennyroyal, Greene milkweed, Mt. Dellenbaugh sandwort, and Tusayan rabbitbrush. There are eight plants that inhabit predominantly riparian and wetland areas; these are Alcove bog orchid, Aravaipa woodfern, Arizona bugbane, Blumer’s dock, broadleaf lupine, Chihuanhuan sedge, Cochise sedge, and Galiuro sage. There are six plants that are restricted to calcareous or gypseous limestone soils or that only occur in the Verde Valley, including heathleaf wild buckwheat, Hualapai milkwort, Mearns sage, Ripley wild buckwheat, Verde beardroot, and Lyngholm’s brakefern. Four Forest Service sensitive plants occur in ponderosa or ponderosa pine/mixed conifer vegetation types in the ROW. These include Arizona leatherflower, Flagstaff beardtongue, Rusby’s milkvetch, and Sunset Crater beardtongue. Arizona alum root occurs on shaded slopes in woodland and forest habitats; Metcalfe’s tick-trefoil occurs on rocky slopes and canyons in grasslands, oak/piñon-juniper woodlands, and riparian forests; and Toumey groundsel is most commonly found in oak chaparral and occasionally found in pine forests.

Direct and Indirect Effects of Alternative A Under Alternative A, routine inspection and manual, mechanical, and DSAP vegetation treatment methods would occur within the ROW. Vegetation treatments would temporarily reduce vegetation cover and competition for resources in the immediate vicinity of treatment areas. Some sensitive plants located within the ROWs may benefit from reduced competition for space, light, water, and soil nutrient resources. For other plants that occur on steep slopes or shaded areas under rocks and in cracks such as the Mogollon fleabane and Salt River rockdaisy, the vegetation management activities would not result in any change in habitat. Forest Service would notify APS of known populations of sensitive plants when reviewing manual and mechanical treatment work proposals and crews would be provided identification cards to avoid these plants. These types of design features would minimize potential impacts to sensitive plants; however, there may be populations of sensitive plants that are unknown to Forest Service that would go undetected. The treatment of poles under the DSAP program could result in loss of individuals. Conservation measures would be implemented to minimize this by coordinating with Forest Service biologists to identify known locations of the sensitive plants. Potential direct effects include mortality of individuals, reduced vigor from trampling, and reduced seed production; however, Alternative A represents no change in impacts from existing conditions as treatments are currently occurring to manage vegetation within ROWs. ATV use and human traffic in the ROWs could result in crushing and trampling of individual plants, though this action would be infrequent and impact small numbers of plants. The effects from manual and mechanical control would be minimal; however, mowing would have a greater effect to Forest Service sensitive plants due to a reduced ability to target specific plants requiring removal. Mowing is not normally used as a treatment method near known Forest Service sensitive plant populations. Given the height of Bebb’s willow and the five agave species at maturity, these species would be target species under Alternative A and may be pruned or removed using manual methods. APS would coordinate with Forest Service biologists prior to conducting treatments in areas where Bebb’s willow may be present to determine the appropriate treatment (i.e., pruning or removal) (refer to Biological Resources Conservation Measures in Appendix E). Ertter’s rose has a very limited distribution and conservation measures are already implemented under Alternative A to avoid treatment of this sensitive plant. Agave stalks would be removed and placed outside of the ROWs so that the seed source remains in the area. For the vegetation removal under DSAP, sensitive agaves would be left untreated if present around the defensible pole. APS makes every effort to minimize direct treatment of sensitive agave plants during manual and mechanical treatment of vegetation. There is a chance that the mechanical mower could drive over and crush sensitive agave under Alternative A; affecting individual agave plants though

138 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona this impact is not expected to trend agave towards Federal listing or impacts species viability. In addition, Alternative A represents no change in impacts from existing conditions as these actions are currently occurring to manage vegetation within ROWs. For the riparian and wetland plants, vehicles would not be used within these plants’ habitat except on existing roads as identified in the project design features. Poles requiring DSAP treatment would also not occur within these species’ habitats because this type of pole and equipment does not generally occur within riparian areas and adjacent to or within streams, springs, wetlands, and rivers. All manual vegetation treatments in these habitats would be conducted by walking in. None of these sensitive plants are target plants under Alternative A and impacts to these plants are unlikely. There is a possibility these sensitive plants could be trampled during foot traffic. Therefore, Alternative A would result in direct and indirect, short- and long-term, negligible, adverse effects to Forest Service sensitive plants because the implementation of design features and conservation measures would be unlikely to result in measurable impacts to the species or their habitat. In addition, the 2018 BE has made the determination that the Alternative A “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the 41 Forest Service sensitive species.

Direct and Indirect Effects of Alternative B In addition to the effects associated with Alternative A described above, Alternative B would also result in potential impacts to Forest Service sensitive plant species. During all treatment besides DSAP, the application of herbicides consists of spot treatment of individual plants. These target plants have been maintained in the past during manual and mechanical treatments, except in the case of new growth target plants. The potential for drift or drip from the target plant to a non-target sensitive plant would be reduced by the use of low volume Thinvert application of the herbicide, and the resulting high degree of control and minimized off-target drift and runoff. This application method would virtually eliminate spray evaporation because each spray droplet is coated with a thin film of oil that would not evaporate, reducing susceptibility to off-target movement. DSAP treatment could result in removal of any of the sensitive plants in the ROW. Because DSAP treatment would be isolated to a small area within wildland urban interfaces around communities, and the vegetation around these treatment poles has been maintained in the past and is disturbed, the chance that sensitive plants occur around poles where DSAP treatment may occur would be low. Individual plants could be impacted but in such a small, isolated areas that it would not be expected to impact species viability on any of the forests. Conservation measures would be implemented where possible to avoid direct treatment of sensitive plants around DSAP poles (refer to Biological Resource Conservation Measures in Appendix E). However, it may not always be possible to identify sensitive plants for avoidance and there is a chance that Alternative B could result in mortality to some sensitive plants. None of the Forest Service sensitive plants would be directly targeted with herbicide; however, plants could be indirectly exposed to herbicide through drift or runoff. The potential of this is minimized by species-specific conservation measures for Bebb’s willow and Ertter’s rose (refer to Biological Resources Conservation Measures in Appendix E), and by the design of Alternative B, which includes targeted spot application of herbicide using Thinvert or other oil-based carrier, which minimizes off-target movement of the herbicide. In addition, agave plants, regardless of whether they are sensitive species, are not target plants for herbicide application. While individual plants could be exposed to herbicide, herbicide exposure would be infrequent and impact a relatively small number of plants. However, the design of Alternative B and conservation measures limits the potential for this as much as possible. Alternative B would reduce the frequency of mechanical and manual treatment of vegetation, reducing impacts associated with the potential crushing undetected sensitive plants from these treatments over the long term.

139 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Therefore, Alternative B is expected to result in localized, short-term, direct and indirect, minor, adverse impacts. By controlling or eliminating incompatible vegetation, over time native habitat for some plants would be enhanced, thereby increasing the availability of suitable habitat for some sensitive plants. Alternative B would therefore also result in localized, long-term, direct and indirect, negligible, beneficial impacts. In addition, the 2018 BE has made the determination that the Alternative B “may impact, not likely to result in a trend toward Federal listing or loss of viability” for the 41 Forest Service sensitive species.

3.9 Bald and Golden Eagle Protection Act 3.9.1. Introduction The Bald and Golden Eagle Protection Act (16 U.S.C. 668-668c), hereafter referred to as the Eagle Act, was enacted in 1940 and has been amended several times since then. The Eagle Act protects eagles from actions and management that would substantially interfere with breeding, feeding, or sheltering behavior. It prohibits anyone, without a permit issued by the Secretary of the Interior, from "taking" eagles, including their parts, nests or eggs, and provides criminal penalties for violation. The Eagle Act defines "take" as pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest, or disturb. "Disturb" means: “to agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause, based on the best scientific information available, 1) injury to an eagle, 2) a decrease in its productivity, by substantially interfering with normal breeding, feeding, or sheltering behavior, or 3) nest abandonment, by substantially interfering with normal breeding, feeding, or sheltering behavior." The Forest Service and APS along with AGFD and multiple land management agencies are signatories to a Memorandum of Understanding (MOU) for the conservation of the bald eagle in Arizona. The Memorandum of Understanding includes a commitment to implementing the Conservation Assessment and Strategy for the Bald Eagle in Arizona (AGFD 2006c) as a means to ensure the bald eagle remains delisted in Arizona. It describes the ongoing threats to eagles in the State and identifies management necessary to maintain their distribution and abundance post-ESA listing. As part of this MOU, the Forest Service and APS continues participation in the: 1) Southwestern Bald Eagle Management Committee; 2) bald eagle winter counts; 3) State eagle nestwatch program; 4) public education; and 5) other ongoing conservation activities and monitoring. 3.9.2. Affected Environment Bald eagles occur as year-round residents along Arizona’s rivers and lakes; their nests are typically placed on the tallest trees or cliffs in their breeding area. Mature trees that are suitable for bald eagle nesting, roosting, and perching do not occur within APS power line ROWs, as the ROWs have been maintained free of this type of vegetation; however, suitable nest trees (or cliffs) may occur in proximity to the ROWs. There are 16 known bald eagle breeding areas within one-quarter mile of APS power line ROWs on the Apache-Sitgreaves, Coconino, Prescott, and Tonto National Forests. There are no breeding areas within one-quarter mile of APS ROW on Kaibab National Forest. Bald eagles also occur as seasonal migrants from out of State during the winter months; these winter visitors occupy a variety of habitats but are most commonly found at the lakes and rivers along the Mogollon Rim and White Mountains. In Arizona, golden eagles are resident in their breeding areas during the spring and summer, and generally remain within or near their home range throughout the rest of the year. Cliff ledges are most often used for nesting, though tall trees and transmission towers may also be used, and there are always large open areas that provide suitable foraging habitat located nearby. There are 17 known golden eagle breeding areas documented near the project area (i.e., within 1 mile of ROWs) on the Coconino, Kaibab, Prescott and Tonto National Forests. There are no breeding areas within one mile of APS ROW on Apache- Sitgreaves National Forests.

140 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

3.9.3. Design Features Design features applicable to bald and golden eagles are stated in Chapter 2. For design features related to manual and mechanical treatment methods, refer to Section 2.1.8; for design features related to herbicide treatment methods, refer to Sections 2.1.8 and 2.2.11. Additionally, biological resources conservation measures from the 2018 BA and 2018 BE have been included in Appendix E. 3.9.4. Environmental Consequences Direct and Indirect Effects of Alternative A Under Alternative A, routine aerial and ground inspections would be conducted, and manual and mechanical control methods would be used to maintain vegetation within ROWs. These activities are temporary and short in duration, typically not lasting more than a few days at any location; however, they could result in disturbance to eagles, particularly during the breeding season when the birds are sensitive to visual and noise disturbance in proximity to their nests. APS coordinates with the AGFD each year to obtain updated information on bald and golden eagle breeding areas, and implements eagle-specific conservation measures that minimize the potential for disturbance of eagles during the bald and golden eagle breeding seasons. These include seasonal restrictions on conducting work within one-quarter mile of an active bald eagle nest and within one mile of the line of sight of an active golden eagle nest; no work is allowed within these protective buffer areas during the respective bald and golden eagle breeding seasons. Vegetation management within ROWs would not result in the direct loss of suitable nesting or foraging habitats for bald or golden eagles, and is not expected to directly or indirectly impact eagle breeding activities because vegetation removal in proximity to breeding areas (i.e., within the protective buffer areas) would be completed outside of the breeding season. In addition, ongoing vegetation management within ROWs would not substantially alter existing habitat conditions for bald or golden eagles, though it may prevent the growth of large trees that could be used for perching or roosting. Alternative A would result in direct and indirect, short-term and long-term, negligible, adverse impacts to bald and golden eagles as a consequence of maintaining the ROWs in proximity to eagle use areas such as breeding areas and foraging areas. With the implementation of eagle-specific conservation measures, Alternative A would not result in injury or “disturbance” to bald or golden eagles, and would therefore not require a permit for “take” under the Eagle Act. Direct and Indirect Effects of Alternative B Alternative B would include the use of herbicides in addition to the manual and mechanical control methods proposed under Alternative A. The majority of the herbicides that are proposed for use have a low toxicity to predatory birds; the exception is dicamba, which would rarely be used and would not be applied within one-quarter mile of a bald or golden eagle breeding area. Herbicide applications would only be conducted outside of protective buffer areas during the breeding seasons for bald and golden eagles, which would minimize the potential for direct impacts associated with vegetation removal activities or exposure to herbicides. The use of herbicides would reduce the frequency of manual and mechanical control methods within ROWs and would therefore reduce the potential for direct impacts to eagles compared to Alternative A. Alternative B would result in direct and indirect, short-term and long-term, negligible, adverse impacts to bald and golden eagles as a consequence of maintaining the ROWs and altering natural habitats in proximity to eagle use areas such as breeding areas and foraging areas. With implementation of eagle- specific conservation measures, Alternative B would not result in injury or “disturbance” to bald or golden eagles, and would therefore not require a permit for “take” under the Eagle Act.

141 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

3.10 Migratory Birds and Important Bird Areas 3.10.1. Introduction The majority of bird species in Arizona are protected by the Migratory Bird Treaty Act of 1918 (MBTA). The Bald and Golden Eagle Protection Act of 1940 (16 U.S.C. 668-668d) and the ESA offer additional protection to certain migratory bird species. Executive Order 13186 (Responsibilities of Federal Agencies to Protect Migratory Birds) issued on January 17, 2001, directed agencies to take certain actions to further implement migratory bird conventions (MBTA, Bald and Golden Eagle Protection Act, ESA, and other related statutes). Pursuant to Executive Order 13186, the Forest Service and USFWS entered into a Memorandum of Understanding to promote the conservation of migratory birds through enhanced collaboration between the two agencies (Forest Service 2008). 3.10.2. Affected Environment

Migratory Birds The list of migratory birds included in this analysis is provided in Table 3.10-1 below. This list was derived from migratory bird lists from each of the five forests. The Tonto National Forest list was derived from two sources, including the USFWS Birds of Conservation Concern (USFWS 2002a) and Arizona Partners in Flight (Latta et al. 1999). The Coconino National Forest list was created in August 2018 and was derived from Arizona Partners in Flight (Rosenberg et al. 2016) and USFWS Birds of Conservation Concern (USFWS 2008). The Kaibab National Forest list was derived from the 2016 Partners in Flight Land Bird Conservation Plan as species of continental importance (Rosenberg et al. 2016). The Prescott National Forest list came from the 2011 Prescott National Forest Draft Migratory Bird Report (Forest Service 2011a). The Apache-Sitgreaves National Forests list was derived from the USFWS Birds of Conservation Concern (USFWS 2008) and Arizona Partners in Flight Bird Conservation Plan (Latta et al. 1999). In Table 3.10-1, the column titled “Forest of Priority Migratory Bird” indicates which Forest the migratory bird is included on that Forests’ priority list. However, some of the birds included in Table 3.10-1 also occur on other Forests not listed in the “Forest of Priority Migratory Bird” column. Migratory birds that were previously analyzed in the 2018 BA and Section 3.7 Federally Listed Species above as a threatened, endangered, or proposed species, and in the 2018 BE and Section 3.8 Forest Service Sensitive Species above as a sensitive species or species protected under the Bald and Golden Eagle Protection Act were excluded from the analysis in this section because the previous analyses already covers impacts to these species. These birds include: California condor (Kaibab National Forest); yellow-billed cuckoo (Coconino, Prescott, and Tonto national forests); bald eagle (Coconino, Kaibab, and Prescott national forests); golden eagle (Coconino and Kaibab national forests); southwestern willow flycatcher (Coconino and Prescott national forests); burrowing owl (Coconino, Kaibab, and Prescott national forests); MSO (Coconino National Forest); Yuma clapper rail (Coconino National Forest); and Baird’s sparrow (Tonto National Forest).

Important Bird Areas Important Bird Areas (IBAs) are sites that provide essential habitat for one or more species of bird and include sites for breeding, wintering, and/or migrating birds on private lands, public lands, or both. Important Bird Areas may be a few acres or thousands of acres, but usually they are discreet sites that stand out from the surrounding landscape. The purpose of the IBA Program is to identify sites that maintain the long-term viability of wild bird populations and to conserve those areas of critical habitat. The Arizona IBA Program was established in 2001 and is co-administered by Audubon Arizona (a statewide chapter of the National Audubon Society) and the Tucson Audubon Society. Important Bird Area designation indicates a specific area’s importance for birds, but does not confer any legal protections (AGFD 2013a). Audubon Arizona identified 45 IBAs

142 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona in Arizona over a 10-year period (NAS 2018), six of which occur within the project area (refer to Table 3.10-2) in Bird Conservation Regions 16 - Southern Rockies Colorado Plateau, 33 - Sonoran and Mojave Deserts, and 34 - Sierra Madre Occidental. For the long-term conservation and management of the IBAs, the birds, habitats, threats, and other site characteristics need to be periodically evaluated (Supplee et al. 2012).

Table 3.10-1. Migratory Bird Species that may be Present in the Project Area Forest of Priority Species ᵃ/ Scientific name Habitat Association Nest Substrate b Migratory Bird c Beardless-tyrannulet, Northern Riparian deciduous tree Tonto Campostoma imberbe Bittern, least Marsh, wetland bulrush, cattail Prescott Ixobrychus exilis Grasslands, marshes, meadows, Blackbird, Brewer’s woodland, coastal scrub, chaparral, tall grass, shrubs Coconino, Prescott Euphagus cyanocephalus and sagebrush Bunting, lark Sonoran desertscrub, semi-desert Coconino, Prescott, ground, grass Calamospiza melanocorys grassland Tonto Chat, yellow-breasted Mixed broadleaf deciduous Apache-Sitgreaves, shrub Icteria virens riparian forest Prescott Duck, wood Cottonwood willow riparian forest tree Coconino Aix sponsa Falcon, peregrine Cliffs, piñon /juniper, chaparral, cliff, tree Prescott Falco peregrinus desert communities Falcon, prairie Grasslands, shrub-steppe, deserts cliff Prescott Falco mexicanus Finch, Cassin’s Evergreen forests, ponderosa pine conifer Coconino, Kaibab Haemorhous cassinii Flicker, gilded Sonoran desertscrub, riparian snag Prescott, Tonto Colaptes chrysoides Flycatcher, buff-breasted branch, deciduous Riparian Tonto Empidonax fulvifrons tree Flycatcher, Cordilleran deciduous tree, Pine and mixed conifer Prescott Empidonax occidentalis cliff, ground Flycatcher, gray Great Basin and semi-desert Apache-Sitgreaves, shrub Empidonax wrightii grasslands Prescott Apache-Sitgreaves, Flycatcher, olive-sided Mixed conifer (dry and wet) conifer Coconino, Kaibab, Contopus cooperi Prescott Godwit, marbled Sonoran and Mojave deserts ground Prescott Limosa fedoa Goldfinch, Lawrence’s conifer, deciduous Riparian, piñon /juniper Prescott, Tonto Spinus lawrencei tree, shrub Grosbeak, evening Mixed conifer, ponderosa pine tree Coconino, Kaibab Coccothraustes vespertinus Grosbeak, pine Spruce-fir deciduous shrub Prescott inicola enucleator Hawk, common black Coconino, Prescott, Low and high elevation riparian deciduous tree Buteogallus anthracinus Tonto

143 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Forest of Priority Species ᵃ/ Scientific name Habitat Association Nest Substrate b Migratory Bird c Hawk, ferruginous Riparian, Sonoran desertscrub, Coconino, Prescott, trees Buteo regalis semi-desert grassland Tonto Hawk, gray Riparian deciduous tree Tonto Buteo plagiatus Hawk, Swainson’s High elevation grassland cliff, tree Prescott Buteo swainsoni Hummingbird, broad-billed deciduous tree or Riparian, piñon /juniper Tonto Cynanthus latirostris shrub Hummingbird, Costa’s Sonoran desertscrub shrub Prescott, Tonto Calypte costae Jay, pinyon Apache-Sitgreaves, Piñon/juniper woodland conifer Gymnorhinus cyanocephalus Kaibab, Prescott Kinglet, golden-crowned Spruce-fir conifer Apache-Sitgreaves Regulus strapa Lark, horned Prairies, deserts, tundra, dunes, ground Kaibab Eremophila alpestris pastures, beaches Longspur, chestnut-collared Short-grass plains and prairies, ground, grass Coconino, Prescott Calcarius ornatus semi-desert grassland Martin, purple Apache-Sitgreaves, Sonoran desertscrub snag Progne subis Prescott, Tonto Nighthawk, common Forests, woodlands, prairies, ground Coconino, Kaibab Chordeiles minor plains, sagebrush grasslands Nighthawk, lesser Desertscrub ground Kaibab Chordeiles acutipennis Osprey Shorelines, waterways tree, tall structure Kaibab Pandion haliaetus Owl, elf Sonoran desertscrub, riparian, Coconino, Prescott, cactus Micrathene whitneyi Pinyon/juniper Tonto Apache-Sitgreaves, Owl, flammulated Ponderosa pine with Gambel oak snag Coconino, Kaibab, Psiloscops flammeolus Prescott Owl, northern pygmy Deciduous riparian forests, mixed deciduous and Kaibab Glaucidium gnoma conifer, spruce fir forests coniferous trees Owl, northern saw-whet Mixed conifer, ponderosa pine, deciduous and Kaibab Aegolius acadicus deciduous riparian forests coniferous trees Pewee, greater Montane pine forests with oak conifer, deciduous Prescott Contopus pertinax understory tree Phainopepla deciduous tree, Riparian, desert, and woodlands Coconino, Prescott nitens shrub Pigeon, band-taileda conifer, deciduous Madrean pine/oak Coconino, Prescott Paragioenas fasciata tree Poorwill, common Open grass or shrubby areas ground Kaibab Phalaenoptilus nuttallii Sapsucker, red-naped Aspen and mixed conifer deciduous tree Prescott Sphyrapicus nuchalis Shrike, loggerhead Sonoran desertscrub, semi-desert deciduous tree, Coconino, Kaibab, Lanius ludovicianus grassland shrub Tonto

144 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Forest of Priority Species ᵃ/ Scientific name Habitat Association Nest Substrate b Migratory Bird c Siskin, pine Coniferous or mixed conifer conifer Kaibab Spinus pinus forests Skimmer, black Sandy beaches, gravel or shell ground Prescott Rynchops niger bars, saltmarshes, lakes Sparrow, black-chinned Sonoran and Mojave deserts, Coconino, Kaibab, shrub Spizella atrogularis piñon/juniper -turbinella oak Prescott, Tonto Sparrow, Botteri’ Semi-desert grassland ground, grass Tonto Pseucaea botterii Sparrow, Brewer’s Sagebrush shrublands, desertscrub shrub Prescott Spizella breweri Sparrow, Cassin’s Semi-desert grassland grasses, shrub Prescott, Tonto Peucaea cassinii Sparrow, grasshopper Coconino, Prescott, Semi-desert grassland ground, grass Ammodramus savannarum Tonto Sparrow, Lincoln’s Ponderosa pine ground Coconino Melospiza lincolnii Sparrow, rufous-winged Semi-desert grassland cacti, mesquite Tonto Peucaea carpalis Sparrow, sage Shrubsteppe, sagebrush shrubs Prescott Artemisiospiza nevadensis shrublands, juniper/sagebrush Sparrow, savannah Apache-Sitgreaves, Montane/subalpine grasslands ground Passerculus sandwichensis Coconino Thrasher, Bendire's Sonoran desertscrub, semi-desert Coconino, Kaibab, shrub Toxostoma bendirei grassland Prescott, Tonto Thrasher, crissal Riparian, Sonoran desertscrub shrub Tonto Toxostoma crissale Thrasher, LeConte’s Sonoran desertscrub cacti, shrub Prescott, Tonto Toxostoma lecontei Sagebrush, arid and semi-arid Thrasher, sage grasslands and shrublands, ground, shrub Prescott Oreoscoptes montanus piñon/juniper woodlands Titmouse, juniper Piñon/juniper and riparian habitat deciduous tree, Tonto Baeolophus ridgwayi if adjacent to piñon/juniper habitat snag Towhee, canyon Chaparral, piñon/juniper, bush, tree Prescott Melozone fusca Evergreen Oak Vireo, Bell's Coconino, Prescott, Madrean pine/oak, riparian shrub Vireo bellii Tonto Vireo, gray Piñon/juniper with broad-leafed Coconino, Kaibab, shrub Vireo vicinior shrubs Prescott, Tonto Vulture, turkey snags, cliffs, Suburbs, farm fields, countryside Kaibab Cathartes aura caves Warbler, black-throated gray conifer, deciduous Apache-Sitgreaves, Piñon/juniper woodland Setophaga nigrescens tree Coconino, Prescott Apache-Sitgreaves, Warbler, Grace's Ponderosa pine conifer Coconino, Kaibab, Setophaga graciae Prescott Warbler, Lucy’s Low elevation riparian snag Coconino, Tonto Oreothlypis luciae

145 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Forest of Priority Species ᵃ/ Scientific name Habitat Association Nest Substrate b Migratory Bird c Warbler, MacGillivray’s Apache-Sitgreaves, Montane willow riparian forest shrub, ground Geothlypis tolmiei Coconino, Prescott Warbler, olive Pine and mixed conifer conifer Coconino, Prescott Peucedramus taeniatus Warbler, red-faceda Mixed conifer and riparian forest ground Coconino, Prescott Cardellina rubifrons Apache-Sitgreaves, Warbler, Virginia’s Chaparral ground Coconino, Kaibab, Leiothlypis virginiae Prescott Warbler, yellow Coconino, Prescott, Riparian shrub, tree Setophaga petechia Tonto Whip-poor-will, Mexican Pine-oak woodlands ground Coconino, Kaibab Antrostomus arizonae Woodpecker, American three-toed Spruce-fir conifer Apache-Sitgreaves Picoides dorsalis Woodpecker, Gila cactus, deciduous Riparian, Sonoran desertscrub Prescott, Tonto Melanerpes uropygialis tree Woodpecker, Lewis's Ponderosa pine forests, riparian pine, cottonwood, Coconino, Kaibab Melanerpes lewis woodlands snag a Species may occur in other habitat categories also b Source: Ehrlich et al. 1988 c This column indicates which Forests have the migratory bird included on their migratory bird priority species list. However, some migratory birds may also occur on Forests not listed in Forest of Priority Migratory Bird. This column does not indicate potential occurrence on the Forests, only which birds are on each Forests’ priority migratory bird list.

Table 3.10-2. Important Bird Areas within the ROW Total Acres of National Acres of IBA Percent of IBA Name IBA in National Forest within APS ROW Total IBA Forest Apache- Mogollon Rim Snowmelt Draws 29,423.66 219.22 0.75 Sitgreaves Coconino Anderson Mesa 163,775.37 106.05 0.06 Coconino Lower Oak Creek 2,836.34 9.53 0.34 Kaibab Grand Canyon National Park 790.06 5.02 0.64 and Tonto 2,575.99 0.30 0.01 Arnett-Queen Creeks Tonto Salt and Verde Riparian Ecosystem 15,284.98 42.17 0.28 Totals - 214,686.40 382.29 0.18 Source: List officially accepted by the Arizona IBA Science Committee review as “Identified” Arizona IBAs (Last review 06/24/2008). Additional information derived from National Audubon Society 2018. IBA = Important Bird Area; ROW = right-of-way Table Note: There are no IBAs within APS ROWs in the Prescott National Forest

146 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

3.10.3. Design Features Design features applicable to migratory birds and important bird areas are stated in Chapter 2. For design features related to manual and mechanical treatment methods, refer to Section 2.1.8; for design features related to herbicide treatment methods, refer to Sections 2.1.8 and 2.2.11. Additionally, biological resources conservation measures from the 2018 BA and 2018 BE have been included in Appendix E. 3.10.4. Environmental Consequences Direct and Indirect Effects of Alternative A Under Alternative A, routine aerial and ground inspections would be conducted along with manual, mechanical, and DSAP vegetation maintenance treatment methods within the ROW. Aerial inspections would not likely affect migratory birds. The crew workers associated with ground inspections and manual and mechanical treatment of vegetation may temporarily displace birds present in the ROW. If birds are active in the ROWs during vegetation management activities, workers and their vehicles and/or equipment would create noise and visual disturbances that may cause birds to flush and leave the immediate area. Only manual treatments would be permitted in riparian areas, which would limit potential displacement of individual birds during treatment activities. Since the ROWs have been managed consistently for many years, there are no suitable tall trees or tree cavities within the power line ROWs. Migratory birds that nest in trees and cavities adjacent to the ROW may experience localized and temporary disturbance due to human, vehicle, and equipment operations during implementation of Alternative A. These impacts may impact individual birds and would be minor because the work is short in duration and not likely to result in any longer-term impacts on these breeding birds. Ground nests and nests in and on cacti, sapling trees, and bushes may occur in ROWs in any given year. Some nests are hard to detect particularly during mechanical treatments. Alternative A could destroy vegetation containing nests or crush ground nests or nests in small shrubs resulting in the loss of adults, eggs or chicks. The likelihood that a nest would be present in the ROWs where vegetation management activities would take place would be low because only smaller, resprouting trees and shrubs, and seedlings would be removed. Smaller resprouting plants are rarely used for nesting sites but may be used during foraging, migration or as cover for ground dwelling birds. Mechanical mowers are less commonly used than manual treatments (mowers are used for less than five percent of treatments) so while mechanical treatment is considered more destructive to migratory birds, the use of mowers in uncommon. Additionally, the APS’s Avian Protection Program direct crews to avoid treating vegetation during the nesting season if a nest is found in target vegetation, thereby minimizing potential impacts. A qualified biologist or resource specialist would provide the maintenance crew members with training on migratory bird nest reporting and nest avoidance. The maintenance crews would internally report active nests that occur on vegetation or on the ground per APS’s avian reporting procedures and restrict treatments on the vegetation containing the nest until after nesting is complete (this design feature applies to all migratory birds in Arizona, not just those migratory birds included for analysis and listed in Table 3.10-1). Maintenance crews would not conduct routine vegetation maintenance and DSAP treatments on the vegetation containing the nest and vegetation adjacent to ground nesting birds until after nesting is complete. Between vegetation maintenance cycles, small sapling vegetation would develop, but this vegetation would continue to be cut and would not be allowed to reach maturity within the ROW. Routine vegetation maintenance treatments would not alter the availability of prey populations. Prey species such as small mammals may be affected by disturbance if their range is restricted to certain microhabitats. However, many small mammals live in burrows where they can retreat during disturbance by vehicles, equipment noise, and crew workers. Direct contact with migratory birds would be unlikely due to their ability of flight. Current and future APS vegetation management activities would adhere to the APS’s Avian Protection Program to mitigate potential impacts to migratory birds.

147 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Disturbance would be more frequent and longer in duration under Alternative A compared to Alternative B. Areas adjacent to the ROWs generally contain more vegetation than the ROWs, so a temporary flushing of birds from cover sites or food sources is not anticipated to impact migratory birds to any measurable degree. Additionally, vegetation management activities would benefit avian habitats within the ROW and in adjacent areas by replacing ladder fuels with low-growing, compatible vegetation. The ROW would act as a fire break and change the dynamics of wildland fire, thereby helping to reduce the potential for indirect impacts on avian habitat from catastrophic wildfire. Six IBAs are present on four national forests within in the ROW; however, very little of each IBA is located within the ROW. All have less than one percent of the IBA on National Forest System lands present within the ROW. Overall, 0.18 percent of the portion of the IBAs present on National Forest System land is present within the ROW. A very small portion of these six IBAs could be impacted under Alternative A and the frequency and duration of the impact would be relatively greater under Alternative A compared to the Alternative B. Therefore, Alternative A would result in short- and long-term, direct and indirect, negligible, adverse impacts to migratory birds. In addition, the 2018 BE determined that Alternative A may impact individual ground nesting and shrub nesting migratory birds but these effects are not likely to result in reductions in migratory bird populations for a given species due to implementation of design features and conservation measures that reduce impacts to nests. Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with Alternative A described above, Alternative B would also result in impacts on migratory birds from the use of herbicides as part of the management of incompatible vegetation within the ROW. Herbicide use within the ROW would be limited to spot applications for the control of incompatible vegetation within the ROWs. Similar to manual and mechanical methods, the herbicide application process involves people, vehicles, and equipment, which would result in localized, short-term noise and visual disturbances to migratory bird species in and adjacent to the ROWs. However unlikely a chance that a bird nest occurs within the ROW, the design features described above requires that applicators be trained on identifying and avoiding nests during migratory bird nesting season. This measure would ensure that nests and the vegetation the nest is on would not be targeted with herbicide until after the birds have fledged. Any birds in the ROW would more than likely fly away before crew workers could get close enough to inadvertently spray them with herbicide. Direct spray of eggs and chicks in ground and shrub nests would be unlikely due to implementation of the design feature that would require that crews are trained to look for and avoid nests and if a nest is found, herbicide treatment would not target the vegetation holding the nest or treatment would be delayed until the nest is not occupied. Migratory birds could come into contact with vegetation that has been sprayed by herbicides. Even if birds were to come into contact with herbicides, only herbicides of low toxicity to birds would be used. The only herbicide that is highly toxic to migratory birds that is proposed is dicamba, and use of this herbicide is limited to areas outside of buffers noted in the conservation measures for migratory birds. The potential for herbicide exposure resulting in detrimental impacts to migratory birds is unlikely. Migratory birds may winter within APS ROW. Wintering areas are critical foraging and hunting grounds for migratory birds that are not year-round residents of the area. Winter forage is essential to birds that must maintain body mass for migration to spring and summer breeding grounds. Herbicide application does not generally occur in the winter as herbicides are more affective when plants are actively growing. There would be a chance that herbicide application could occur during the winter particularly during the beginning and end days of the winter season. Noise disturbance due to herbicide application in overwintering areas may cause birds to briefly leave the work area and move to an adjacent area during

148 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona the period of disturbance. Birds may be temporarily displaced but would not likely to be forced to leave this important wintering habitat because herbicide application is short in duration, low in noise level, localized to a small area, and an infrequent action. Birds in important wintering grounds may be temporarily disturbed but this disruption would likely be brief and have a minimal impact, both short and long term, on birds’ ability to feed or roost. Activities associated with Alternative B could impact overwintering migratory birds within the IBAs. However, the period of disturbance would be very short in any given area, and impacts to overwintering birds are not expected. Alternative B may result in some changes to habitat components for migratory birds, particularly in reduction of shrubs and ground cover. These changes in habitat would be small as the ROWs have been continually maintained and ROWs are narrow and are only a small portion of surrounding habitats. While some impacts to habitat for migratory birds are expected the impacts would be relatively small in scale that habitat impacts are not likely to result in adverse impacts to migratory birds. Herbicides could be sprayed on insects or plant-based food (e.g., berries) that are, in turn, ingested by migratory birds. Targeted application of herbicides to only specific incompatible plants or re-sprouts limits the opportunity for insect prey species to be exposed, though plant-based food may be exposed to herbicide. The use of low toxicity herbicides, establishment of buffers within or near migratory birds, the application of targeted, short duration herbicide treatments, and the use of the drift and drip reduction agent, Thinvert, would reduce any potential direct effects to migratory birds by Alternative B. Therefore, Alternative B would result in direct and indirect, short-term, negligible, adverse impacts to migratory birds because the potential for direct contact with the species would be unlikely, the maintenance crew training, and due to the effectiveness of design features and conservation measures. There would also be direct and indirect, long-term, negligible, beneficial impacts to these species because the frequency of routine vegetation maintenance would decrease, which would reduce the presence of workers and noise within suitable habitat. In addition, the 2018 BE determined that Alternative B may impact individual ground nesting and shrub nesting migratory birds but these effects are not likely to result in reductions in migratory bird populations for a given species.

3.11 Forest Service Management Indicator Species 3.11.1. Introduction The National Forest Management Act directs the Forest Service to select and track species that are of special interest or indicative of management trends. These species are called management indicator species (MIS). These MIS are monitored during forest plan implementation to assess the effects of management activities on their populations and the populations of other species with similar habitat needs that they may represent (FSM 2670.5). This MIS analysis includes only national forests that have not recently updated Land Management Plans. Of the five forests, only Coconino and Tonto national forests require analysis for MIS. Forest-wide assessments summarize current knowledge of population and habitat trends for MIS. For Coconino National Forest, this assessment is titled Management Indicator Species Status Report for the Coconino National Forest, Version 2 (Forest Service 2013c). For the Tonto National Forest, the MIS status report (Draft Management Indicator Species Status Report for Tonto National Forest; Forest Service 2016b) is currently in draft form but was used as reference for this MIS analysis because it contains more current information than the previous version. 3.11.2. Affected Environment A list of MIS and indicator habitats for the Coconino and Tonto national forests are provided below in Table 3.11-1 and Table 3.11-2, respectively. To evaluate potential impacts of the alternatives on MIS, an analysis was performed by identifying relevant ERUs for each MIS, calculating total forest acres of each ERU, calculating total acres of ROW in the ERU, and comparing ROW acres to total forest acres (refer to Table 3.6-1 through Table 3.6-8).

149 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Table 3.11-1. MIS and Habitat, Forest-Wide and APS ROW Acres for Coconino National Forest Total Forest APS ROW Percent of Species Indicator Habitat (acres) a (acres) Forest Acres Abert’s squirrel Early seral b ponderosa pine 407,790.74 543.89 0.13 Cinnamon teal Wetlands/aquatic 9,755.69 0.30 0.00 Early seral pinyon-juniper, Elk ponderosa pine, mixed conifer, 1,520,651.62 1,516.39 0.10 and spruce-fir Snag component of ponderosa Hairy woodpecker pine, mixed conifer, and spruce- 915,916.56 832.58 0.09 fir Juniper (Plain) Late seral and snag component 631,271.18 682.25 0.11 titmouse of pinyon-juniper Late seral, high elevation Lincoln’s sparrow 1,029.20 0.00 0.00 riparian (>7000’) Late seral, low elevation riparian Lucy’s warbler 1,029.20 0.00 0.00 (<7000’) Late seral, high and low Macroinvertebrates 9,755.69 0.30 0.00 elevation riparian Late seral mixed conifer and Mexican spotted owl 904,412.93 810.25 0.09 spruce-fir Early seral aspen and pinyon- Mule deer 680,025.69 666.60 0.10 juniper Northern goshawk Late seral ponderosa pine 891,792.37 808.33 0.09 antelope Early and late seral grasslands 235,161.08 430.25 0.18 Pygmy nuthatch Late seral ponderosa pine 904,412.93 810.25 0.09 Late seral mixed conifer and Red squirrel 904,412.93 810.25 0.09 spruce-fir Red-naped (Yellow- Late seral and snag component 79,711.89 7.04 0.01 bellied) sapsucker of aspen Turkey Late seral ponderosa pine 1,520,651.62 1,516.39 0.10 Late seral, low elevation riparian Yellow-breasted chat 11,252.35 0.00 0.22 (<7000) Source: Forest Service 2016 a The acres are based on the Forest Service Southwestern Region ERU and Subclass 2016. b Seral stage (status): a stage of secondary successional development (secondary succession refers to an ecological process of progressive changes in a plant community after stand-initiating disturbance) (Forest Service 1996).

Table 3.11-2. MIS and Habitat, Forest-Wide and APS ROW Acres for Tonto National Forest Total Forest APS ROW Percent of Species Indicator Habitat (acres) a (acres) Forest Acres Successional stages of Abert’s squirrel 723,725.06 1,576.13 0.22 ponderosa pine Arizona gray squirrel General riparian 341,015.57 923.95 0.27 Ash-throated Ground cover 1,281,827.22 3,198.12 0.25 flycatcher Bald eagle General riparian 79,153 141.79 0.18

150 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Total Forest APS ROW Percent of Species Indicator Habitat (acres) a (acres) Forest Acres Bell's vireo Well-developed understory 48,848.66 161.48 0.33 Black throated sparrow Shrub diversity 1,309,108.65 3,644.33 0.28 Black-chinned sparrow Shrub diversity 688,757.86 1,809.46 0.26 Canyon towhee Ground cover 1,964,427.61 5,560.42 0.28 Common blackhawk Riparian streamside 30,304.76 95.83 0.32 Elk General forest conditions 1,333,239.09 3,365.04 0.25 Gray vireo Tree density 836,127.29 2,080.20 0.25 Hairy woodpecker Snags, cavities 329,712.29 1,007.94 0.31 Homed lark Vegetative aspect 829,366.62 2,094.12 0.25 Hooded oriole Medium sized trees 48,848.66 161.48 0.33 Juniper (Plain) General woodland conditions 749,086.60 1,703.53 0.23 titmouse Macroinvertebrates Water quality/fisheries 187.37 8.98 4.79 Northern flicker Snags 749,086.60 1,703.53 0.23 Northern goshawk Vertical diversity 299,407 647.50 0.22 Pygmy nuthatch Old growth ponderosa pine 299,407.54 912.11 0.30 Savannah sparrow Grass species diversity 1,153,239.32 2,874.35 0.25 Successional stages of pinyon- Spotted towhee juniper, Shrub density in 949,684.37 2,360.36 0.25 chaparral Summer tanager Tall, mature trees 48,848.66 161.48 0.33 Townsends solitaire Juniper berry production 452,460.60 1,104.00 0.24 Turkey Vertical diversity – forest mix 1,333,239.09 3,365.04 0.25 Violet-green swallow Cavity nesting habitat 89,027.80 491.34 0.55 Western wood pewee Medium overstory 30,304.76 95.83 0.32 Warbling vireo Tall overstory 30,304.76 95.83 0.32 Western bluebird Forest openings 89,027.80 491.34 0.55 Source: Forest Service 2016

3.11.3. Design Features Design features applicable to Forest Service management indicator species are stated in Chapter 2. For design features related to manual and mechanical treatment methods, refer to Section 2.1.8; for design features related to herbicide treatment methods, refer to Sections 2.1.8 and 2.2.11. Additionally, biological resources conservation measures from the 2018 BA and 2018 BE have been included in Appendix E. 3.11.4. Environmental Consequences Direct and Indirect Effects of Alternative A Under Alternative A, routine aerial and ground inspections would be conducted along with manual, mechanical, and DSAP vegetation maintenance treatment methods within the ROW. Alternative A primarily targets young regrowth and new growth vegetation and some shrubs. Small numbers of mature

151 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests trees at the edge of the ROWs may also be targeted. The section below includes an analysis of impacts by indicator habitat as described in Table 3.11-1 and Table 3.11-2. Early seral ponderosa pine, pinyon-juniper, mixed conifer, aspen, and/or spruce-fir (Abert’s squirrel, elk, and mule deer). Use of manual and mechanical vegetation treatment methods may result in noise disturbance and even failed reproduction efforts for some species like Abert's squirrel if present adjacent to the ROW. This impact is localized and may impact individuals but not populations. Manual and mechanical treatment would not likely impact elk and mule deer as these large mammals would avoid human activity. Alternative A would not result in change in population trends of these species. There would be some change in habitat trend locally within the ROWs between maintenance cycles. APS ROWs would continue to provide travel and foraging corridors for elk and deer. Snag components of ponderosa pine, mixed conifer, aspen, and/or spruce-fir (Hairy woodpecker, juniper titmouse, red-naped sapsucker, northern flicker, and western bluebird). Nesting and other activities in mature trees, cavities, and snags would not occur within the ROWs since the ROWs have been maintained free of suitable vegetation. Use of manual and mechanical vegetation treatment methods may result in noise disturbance and failed reproduction efforts on a localized scale for nesting adjacent to the ROWs but this impact would be localized and would not likely impact population trends. The ROWs would continue to be maintained free of these vegetation types. Hazard trees or dead and decaying trees that typically threaten the power lines from outside of the ROWs would continue to be removed, resulting in small reductions in habitat trends for snags and mature trees for species that nest primarily in snag cavities. Late seral ponderosa pine, mixed conifer, aspen, pinyon/juniper, and/or spruce-fir species (Juniper titmouse, pygmy nuthatch, red squirrel, red-naped sapsucker, turkey, Townsend’s solitaire, violet-green swallow, and western bluebird). Use of manual and mechanical vegetation treatment methods may result in noise disturbance and failed reproduction efforts on a localized scale for species that primarily nest, roost, and perch adjacent to the ROWs. Alternative A would not likely impact population trends for these species. Mature tree species are not present within the power line ROWs since these trees have been previously cleared within the power line ROW. The ROWs would continue to be maintained free of these vegetation types resulting in a permanent habitat conversion of ROW vegetation, though this is localized to the ROWs and not likely to result in significant reduction in habitat trends for MIS such as pygmy nuthatch, red squirrel, and violet-green solitaire who nest in tree cavities. Late seral ponderosa pine, mixed conifer, and spruce-fir species (MSO and northern goshawk). Nesting would not occur within the ROWs but may occur adjacent to ROWs. Implementing breeding season timing restrictions for federally listed species and Forest Service sensitive species such as the MSO and northern goshawk would minimize disturbance to these species. Ongoing manual and mechanical cutting of pine, mixed conifer, and spruce-fir trees would continue as these tree species are incompatible with the ROWs. The ROWs would be managed free of mature tree species, reducing the quantity of this habitat type locally within the ROWs consistent with existing baseline conditions. Wetlands/aquatic (Cinnamon teal and macroinvertebrates). Mechanical cutting of vegetation activities do not occur within aquatic and wetland habitat. In Alternative A, use of manual vegetation treatment methods would not impact macroinvertebrates directly, though sedimentation into habitat may impact these species indirectly. Noise disturbance may cause adverse impacts to cinnamon teal reproduction efforts if nesting near work activities. These impacts are localized and not likely to result in population level impacts. Late seral riparian (Common blackhawk, summer tanager, western wood pewee, and warbling vireo). Mature riparian trees suitable for nesting, roosting, and perching do not occur within the ROWs as ROWs have been maintained free of this type of vegetation. The use of manual vegetation treatment methods may result in noise disturbance and failed reproduction efforts on a localized scale for nesting, roosting, and perching adjacent to the ROWs but would not likely impact population trends. Bird species such as

152 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona the common blackhawk, western wood pewee, and warbling vireo require mature riparian trees for breeding. The power line ROWs do not contain suitable habitat for these late seral riparian birds. The ongoing removal of vegetation would continue to maintain the ROW free of late seral riparian vegetation resulting in no change in habitat trends for these birds. General riparian (Arizona gray squirrel, bald eagle, Bell’s vireo, hooded oriole, and yellow-breasted chat). Manual vegetation treatment methods may result in noise disturbance and even failed reproduction efforts for bird MIS, such as the yellow-breasted chat and Bell’s vireo if present adjacent to ROW. These potential impacts would be localized and may impact individuals but not populations. The ROWs would be maintained such that suitable shrub and grass habitat would be enhanced, providing a slight beneficial impact to habitat trends for MIS. Mechanical mowers would not be used within riparian areas. There would be a chance that undetected individuals may be impacted by hand vegetation removal despite standard practices to look for and avoid nesting birds. Individual birds could be impacted though this would not likely result in population level impacts. Arizona gray squirrel and hooded oriole nest and inhabit medium to mature sized trees. The power line ROWs do not contain suitable habitat for these two MIS and would continue to be maintained free of this vegetation with no change in habitat trends. Grasslands (Horned lark, pronghorn antelope, and savannah sparrow). Treatments involving ATV and vehicle use within the ROWs could result in negative impacts to the ground nesting bird, horned lark. Human presence and noise disturbance from chainsaw and mechanical mower may temporarily disturb lark, antelope, and sparrow. Impacts are localized and may impact individuals but not populations. Manual and mechanical treatment of vegetation is typically not conducted within grassland habitat except where wide apart trees are present. The management of ROWs likely provide habitat for grassland species and continued removal of vegetation would result in no change in habitat trends for these MIS. Ground cover (Ash-throated flycatcher and canyon towhee). Treatments involving ATV and vehicle use within the ROWs could result in adverse impacts to the shrub nesting bird, canyon towhee. Human presence and noise disturbance from chainsaw and mechanical mower may temporarily disturb ash- throated flycatcher and canyon towhee. These impacts would be localized and may impact individuals but not populations. The ROWs would continue to be maintained free of trees suitable for cavity nesting species such as ash throated flycatcher. Canyon towhee inhabits and nests in shrubs which do occur within the ROWs and would continue to remain in the ROWs. Suitable foraging habitat would be enhanced by continued maintenance of vegetation within the ROWs. Under Alternative A, very little change in habitat trend would be anticipated. Shrub diversity and/or density (Black-throated sparrow, black-chinned sparrow, and spotted towhee). Human presence and noise disturbance from chainsaw and mechanical mower may temporarily disturb birds. There is a chance that undetected individuals may be impacted by vegetation removal despite standard practices to look for and avoid nesting birds. These impacts would be localized and may impact individuals but not populations. Treatment of vegetation would result in some reduction in shrubs particularly where shrubs are dense. While this vegetation may have already been removed in the past, it regrows and would continue to be cut. Alternative A would result in some reduction in habitat for the black-throated sparrow Black-chinned sparrow and spotted towhee. Tree density (Gray vireo). Treatments involving ATV and vehicle use within the ROWs could result in negative impacts to undetected shrub nesting bird like the gray vireo though this is minimized by standard practices to look for and avoid nesting birds. Human presence and noise disturbance from chainsaw and mechanical mower may temporarily disturb these species. Potential impacts from Alternative A would be localized and may impact individuals but not populations. Manual and mechanical treatment of vegetation would target larger juniper trees, where present (though not many are present in ROWs due to continued maintenance) and chaparral vegetation. Alternative A primarily targets young regrowth, new growth vegetation, and some shrubs and may also target small numbers of mature trees at the edge of the ROWs. For these MIS, the main habitat

153 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests components for the species would not likely be targeted by Alternative A and impacts to population and habitat trends would be unlikely (Forest Service 2018a). Therefore, Alternative A would result in direct and indirect, short- and long-term, negligible, adverse impacts to MIS. Direct and Indirect Effects of Alternative B In addition to the effects associated with Alternative A described above, Alternative B would also result in impacts on MIS. APS personnel and contractors who apply herbicide in the ROWs would undergo the same training as in Alternative A. The analysis below includes an analysis of impacts by indicator habitat as described in Table 3.11-1 and Table 3.11-2. Early seral ponderosa pine, pinyon-juniper, mixed conifer, aspen, and/or spruce-fir (Abert’s squirrel, elk, and mule deer). MIS associated with this habitat may be exposed to herbicides if ingesting or coming into contact with herbicides on treated vegetation. The majority of proposed Forest Service-approved herbicides are low in toxicity to mammals. Dicamba is highly toxic to mammals but would be rarely used and only after review during the PUP process. Impacts would involve so small an area as to not measurably impact early successional MIS population trends on Coconino and Tonto national forests. Addition of herbicide as a tool would reduce frequency of manual and mechanical treatment, and would reduce ongoing impacts from vegetation management to MIS. Power line ROWs provide travel and foraging corridors for elk and mule deer. The addition of herbicides would maintain the ROWs to early- seral stage grasses, forbs, and shrubs, providing a beneficial impact to habitat trends for early successional species. Alternative B only targets young regrowth and new growth and would not impact forest structure or cone production for species like Abert's squirrel. Snag components of ponderosa pine, mixed conifer, aspen, and/or spruce-fir (Hairy woodpecker, juniper titmouse, red-naped sapsucker, northern flicker, and western bluebird). Because activities are short in duration and noise levels are low during herbicide treatments, disturbance to nesting MIS are unlikely. Birds could be exposed to herbicide through contact with vegetation treated, but the majority of proposed herbicides are low in toxicity to birds. Dicamba is highly toxic to birds but would be rarely used and only after review during the PUP process. Impacts would involve so small an area as to not measurably impact these MIS population trends. Addition of herbicide as a tool would reduce frequency and intensity of manual and mechanical treatment, and would reduce ongoing impacts from vegetation management to MIS. Similar to Alternative A, snags and mature trees are not present within the ROWs. The application of Forest Service-approved herbicides would simply provide another tool in maintaining this condition resulting in no change to habitat trends in comparison Alternative A. Late seral ponderosa pine, mixed conifer, aspen, pinyon/juniper, and/or spruce-fir species (Juniper titmouse, pygmy nuthatch, red squirrel, red-naped sapsucker, turkey, Townsend’s solitaire, violet-green swallow, and western bluebird). MIS could be exposed to herbicide through contact with vegetation treated in the ROW. The majority of proposed herbicides are low in toxicity to birds and mammals. Dicamba is highly toxic to mammals and birds but would be rarely used and only after review during the PUP process. Impacts would involve so small an area as to not measurably impact these MIS population trends. Addition of Forest Service-approved herbicides as a tool would reduce frequency and intensity of manual and mechanical treatment, thus reducing ongoing impacts from vegetation management to MIS. Late seral ponderosa pine, mixed conifer, and spruce-fir species (MSO and northern goshawk). With Alternative B, design features that include breeding season timing restrictions, nest buffers, and restrictions on which herbicides can be used would minimize potential impacts to MIS. Conservation measures for federally listed species and Forest Service sensitive species would reduce disturbance or toxicity impacts to MSO and northern goshawks. The use of Forest Service-approved herbicide application would only target young regrowth and new growth and would not include the treatment of mature late seral ponderosa pine, mixed conifer and spruce-fir tree species which have already been removed from the ROW.

154 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Wetlands/aquatic (Cinnamon teal and macroinvertebrates). Herbicide treatments may occur within and adjacent to the wetlands/aquatic habitats. Direct impacts due to noise/disturbance from work activities would be unlikely as work is short in duration and low in noise level. For invertebrates potentially exposed during herbicide application, only 2,4-D may cause negative effects. Dicamba is highly toxic to birds. Both these herbicides would be rarely used and would not be used within and adjacent to wetland and aquatic habitats. Measurable adverse impacts are not likely from herbicide exposure. Alternative B would not likely impact population trends for these MIS. In Alternative B, Forest Service-approved herbicides would not be applied directly into aquatic habitat (i.e., water application) and the chance of runoff and drift of herbicides is minimized due to design features, conservation measures, and use of the adjuvant, Thinvert, such that impacts to aquatic habitat for MIS are unlikely. Late seral riparian (Common blackhawk, summer tanager, western wood pewee, and warbling vireo). In Alternative B, MIS may be exposed to herbicide through contact with vegetation treated. The majority of proposed herbicides are low in toxicity to birds except for dicamba which is highly toxic to birds but would be rarely used and only after review during the PUP process. Dicamba would not be used in and near riparian areas. Potential impacts would involve so small an area as to not measurably impact these MIS population trends. General riparian (Arizona gray squirrel, bald eagle, Bell’s vireo, hooded oriole, and yellow-breasted chat). Arizona gray squirrel and hooded oriole would not be directly sprayed with herbicide but yellow- breasted chat and Bell's vireo could be sprayed during nesting if nesting in targeted shrubs is undetected. Design features to look for and avoid treating nests minimizes this potential impact. These MIS could come into contact with Forest Service-approved herbicides on treated vegetation. The majority of proposed herbicides are low in toxicity to birds. Dicamba, as previously noted is highly toxic to birds but would be rarely used and only after review during the PUP process; it would not be used in or near riparian areas. Herbicide treatment would continue to slightly enhance availability of early successional vegetation within the ROWs resulting in a beneficial impact in habitat trends for Bell's vireo and yellow- breasted chat. Grasslands (Horned lark, pronghorn antelope, and savannah sparrow). Treatments involving ATV and vehicle use within the ROWs could result in adverse impacts to the ground nesting bird, horned lark. Human presence during work activities would not likely disturb lark, antelope, and sparrow, because work would be short in duration with low noise levels. These MIS could come into contact with herbicide on vegetation, though all but dicamba is low in toxicity to birds and antelope and dicamba would be rarely used and only following review during the PUP process with the implementation of conservation measures. Because impacts would be isolated to small areas and impacts to habitat are not anticipated, it is not likely that Alternative B would impact population trends for these MIS. Herbicide treatment of vegetation in grassland habitat would generally not be needed except to target the occasional tree species. Ground cover (Ash-throated flycatcher and canyon towhee). Similar to grasslands habitat, treatments involving ATV and vehicle use within the ROWs could result in adverse impacts to the shrub nesting bird, canyon towhee. Human presence during work activities would not likely disturb these MIS because work is short in duration with low noise levels. These MIS could come into contact with herbicide on vegetation, though all but dicamba is low in toxicity to birds and it would be rarely used. Because impacts to vegetation would be isolated to small areas and impacts to MIS habitat would be unlikely, it is not anticipated that Alternative B would impact population trends for these MIS. Herbicide treatment would continue to maintain ground cover for foraging and nesting, resulting in no change in habitat trends. Shrub diversity and/or density (Black-throated sparrow, black-chinned sparrow, and spotted towhee). These MIS could nest in shrub vegetation of the ROWs. Conservation measures would be implemented to ensure vegetation with nests would not be treated with herbicides and work is deferred until outside the nesting season. Human and ATV presence during work activities would not likely disturb these MIS because work would be short in duration and low in noise level. MIS could come into contact with

155 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests herbicide on vegetation, though all but dicamba is low in toxicity to birds and dicamba would be rarely used. Because potential impacts would be isolated to small areas of habitat and impacts to birds are minimized by conservation measures, Alternative B would not likely impact population trends for these MIS. Herbicide treatment would continue to maintain shrub vegetation previously treated by manual and mechanical methods, though, with herbicide, the ROW would be converted long term to early seral stage vegetation with some shrubs remaining but areas of dense shrubs (such as chaparral) would be thinned. Tree density (Gray vireo). Gray vireo could nest in shrub vegetation of the ROWs and conservation measures would be implemented to ensure vegetation with nests is not treated with herbicide and work is deferred until outside the nesting season. Human and ATV presence during work activities may temporarily disturb vireo, though this would be short in duration. Vireo could come into contact with herbicide on vegetation, though all but dicamba is low in toxicity to birds and dicamba would be rarely used. Because potential impacts would be isolated to small areas of habitat and impacts to birds are minimized by conservation measures, Alternative B would not likely impact population trends for gray vireo. Large juniper would not be targeted by herbicide application, but chaparral vegetation would be. Alternative B would maintain what was removed previously by manual and mechanical methods, and would ensure that not as much chaparral vegetation re-grows between maintenance cycles. Alternative B would likely result in beneficial impact to habitat trends because of the increase in early successional and native plant communities in the ROWs and it would provide open habitat and travel and/or foraging corridors. Alternative B would reduce some impacts associated with Alternative A because the cutting of vegetation would occur less frequently and would include a smaller amount of vegetation when combined with use of herbicides. Overall, it was determined that potential impacts to indicator habitat in ROWs would likely be small in scale and not likely to impact population trend of these MIS. Therefore, Alternative B would result in direct and indirect, short-term, negligible, adverse impacts to MIS because the potential for direct contact with the species would be unlikely and due to the effectiveness of design features when implemented. There would also be direct and indirect, long-term, negligible, beneficial impacts to MIS in Alternative B because the frequency of routine vegetation maintenance would decrease, which would reduce the presence of workers and noise within suitable habitat.

3.12 Rangeland Health 3.12.1. Introduction In 1897, Congress authorized the Forest Service to regulate grazing in order to prevent damage to forest growth. The Public Improvement Act of 1978 established a national policy and commitment to manage, maintain, and improve the condition of public rangelands. According to the Forest Service, permitted grazing is the use of rangeland resources by livestock (Forest Service 2017a). The Forest Service controls the associated permits, herd size, allotments, and season of use in order to protect the rangelands (Rowley 1985). Public lands serve to provide an important source of forage for ranches and help to support the agricultural component of many communities scattered throughout the West. 3.12.2. Affected Environment Livestock grazing management activities occur on National Forest System lands and are established through active grazing allotments and permitted by the issuance and administration of grazing permits for a 10-year period. Rangeland and livestock grazing may be present within the APS ROW. Table 3.12-1 identifies the total acreage of grazing allotment within the ROW and the percent the acreage represents of the total ROW acreage for APS.

156 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Typical livestock grazing management activities that occur on rangelands include the following (Forest Service 2012a): . Movement of ranch horses and livestock from one pasture to another. . The use of vehicles and livestock trailers to transport livestock, feed, and water to working corrals on allotments. . Maintenance improvements including fence installation and repair. . Livestock processing such as feeding, sorting, branding, dehorning and other practices.

Table 3.12-1. Grazing Allotment Acreage Total Grazing National Forest Allotment Acreage Percent of ROW within ROW Apache-Sitgreaves 1,813.52 99.94 Coconino 1,667.67 82.38 Kaibab 2,300.39 100.00 Prescott 2,782.91 98.94 Tonto 4,478.71 99.28 Total 13,043.20 96.88

Approximately 97 percent of the APS ROW may be within grazing allotments. These rangelands throughout Arizona are diverse and vary based on a variety of factors including soils, climate, topography, disturbances, and vegetation communities and these factors help determine the potential to produce vegetation (NRCS 2005). Ecological processes attributed to rangeland health include the water cycle, energy flow, and nutrient cycle (NRCS 2005). Generally, stable soil surface are those with established native vegetation and are most resistant to erosion. Healthy plant communities generally support healthier rangelands and higher levels of livestock grazing than degraded plant communities. The presence of invasive plants contributes to a degradation of overall community health resulting in reduced capacity for grazing. On rangelands, livestock consume annual and perennial native and some introduced grass species, and seasonally use forbs and some shrubs (BLM 2015a). 3.12.3. Design Features Design features applicable to rangeland health are stated in Chapter 2. For design features related to manual and mechanical treatment methods, refer to Section 2.1.8; for design features related to herbicide treatment methods, refer to Sections 2.1.8 and 2.2.11. 3.12.4. Environmental Consequences Direct and Indirect Effects of Alternative A Under Alternative A, ongoing manual and mechanical vegetation maintenance would continue with the use of trucks, large mowers, and hand tools including chainsaws. Livestock could benefit from a reduction in woody species and other undesirable vegetation that serve as forage. The duration of these benefits would depend on the plant’s ability to re-sprout. Where woody species do re-sprout quickly, their palatability to livestock could be improved in the form of new growth. Any vegetation management methods in Alternative A that would successfully reduce the cover of noxious weeds on rangelands would benefit livestock by increasing the number of acres suitable for grazing and the quality of forage. Many noxious and invasive weed species are avoided by many large herbivores that prefer grazing on native

157 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests species (Sheley and Petroff 1999). Livestock may be temporarily displaced during manual and mechanical treatment by the presence of work crews, vehicles, and greater noise levels from the use of heavy equipment and power tools such as chainsaws. Manual Treatments could remove undesirable foraging species, but would not affect desirable species. This type of vegetation treatment would have minimal effects on livestock and their forage. Manual methods that remove competition and overstory vegetation would be expected to enhance grass production if grasses are present on the site. Mechanical Treatments could temporarily reduce the amount of livestock forage within the APS ROW. Treatments that rip up plants would be more likely to reduce forage than treatments that cut plants off at the base. These effects would be short-term in nature, as forage species would regrow following treatments. Since the ROW corridors have been continually maintained and only incompatible vegetation would be treated, this would be a small change. Similar to manual treatment methods, mechanical methods that remove competition and overstory vegetation would be expected to enhance grass production if grasses are present on the site. Mechanical removal could adversely affect foraging plants by compacting soils, creating bare ground, and uprooting desirable species. Ground disturbance could provide increased opportunities for weeds after treatment (BLM 2017). Rangeland areas with the greatest potential from ground disturbance would be those requiring the use of heavy mechanical equipment. Adverse impacts to rangelands could result from invasive plant species continuing to expand on National Forest System lands and into adjacent lands, resulting in the loss of forage material from out-competing native species and an increase in the abundance of unpalatable or toxic plants. Therefore, Alternative A would result in direct, short-term, negligible adverse impacts on rangeland health and grazing from the presence of work crews, heavy equipment movement throughout the corridor, and removing desirable foraging species. Alternative A would also result in indirect, short-term, negligible beneficial impacts from the removal of woody species and other undesirable vegetation that serve as forage and the potential to enhance grass production. Direct and indirect, long-term, negligible adverse impacts to rangelands from Alternative A could result from the continued intensity of manual and mechanical treatments, providing increased opportunities for invasive plant species to spread. Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with the Alternative A described above, Alternative B would also result in impacts on the rangeland health and grazing from the use of herbicides as part of the management of incompatible vegetation within the ROW. Alternative B would require less vegetation treatments over the long-term during routine vegetation management than that of Alternative A, which would reduce impacts to rangelands and disturbances to livestock from the presence of crew workers and noise levels from heavy equipment. Herbicide use poses a potential risk of direct impacts to livestock though toxic exposure; however, this risk would be minimized by following certain design features, following the herbicide labels, and adhering to any additional localized conditions in APS ROW identified during the PUP process. Livestock may experience adverse health effects if large amounts of vegetation contaminated from the spraying of herbicides are consumed. With targeted spot treatment, the levels to which the livestock would be exposed would be hundreds to thousands of times lower than the levels that would cause toxic effects (NRCS 2005). Livestock would also have a greater chance of being affected by herbicide use if their range extent was completely treated or areas grazed by the livestock were treated frequently. In Alternative B, it would be unlikely that APS would treat an entire ROW with herbicides, and the vegetation management treatments of the ROW would be reduced as compared to Alternative A. Impacts to rangelands and allotments could occur in the event of herbicide drift or runoff from treated areas, which could result in a loss of vegetation. The low-volume spot treatment and the use of the adjuvant Thinvert would minimize

158 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona herbicide drift or runoff and hence impacts to livestock and rangeland health. No permanent access limitations or impacts to grazing rotations are anticipated with Alternative B. Alternative B would not target grasses and plants commonly associated with grazing; herbicide treatments would target shrubs and sprouting trees. Using herbicides of low toxicity to livestock would further reduce these risks. One of the goal of the project is to maintain ROWs that contain native, low-growing compatible vegetation. Consequently, the amount of herbicides sprayed on grasses and forbs is anticipated to be minor and in insignificant amounts. As a result, herbicide concentrations are unlikely to be at levels that would reduce rangeland productivity or health. Indirect effects include the degree to which a species or individual is positively or negatively affected by changes in rangeland conditions. Herbicide treatments that successfully reduce the cover of noxious weeds on rangelands would benefit livestock by increasing the number of acres suitable for grazing and the quality of forage. Noxious weeds would only be treated if they are incompatible with the power lines or if specifically requested by the Forest Service. Noxious weed infestations can greatly reduce the land’s carrying capacity for domestic livestock, which tend to avoid most weeds. Livestock tend to select native or introduced forage species over weeds (BLM 2007). Alternative B would also reduce the risk of future catastrophic wildfire through fuels reduction which would benefit livestock. Uncontrolled, high intensity wildfires can damage large tracts of rangeland, reducing its suitability for livestock grazing. Alternative B would restore and maintain fire-adapted ecosystems that would decrease the effects from wildfire to rangeland plant communities and improve ecosystem resilience and sustainability. Treatments that control populations of non-native species on National Forest System lands would be expected to benefit native plant communities by aiding in the reestablishment of native species. Therefore, Alternative B would result in direct, short-term, negligible adverse impacts on rangeland health from the presence of work crews, heavy equipment movement throughout the corridor, and uprooting desirable foraging species. Alternative B would also result in indirect, short-term, negligible beneficial impacts on rangeland health and grazing from the removal of woody species and other undesirable vegetation that serve as forage and the potential to enhance grass production. Direct and indirect, long-term, minor beneficial impacts to rangeland health and grazing from Alternative B would result from reducing the amount of vegetation requiring treatment, establishment of low-growing compatible vegetation, reduction in potential catastrophic wildfire through fuels reduction, and reestablishment of native species.

3.13 Fire and Fuel Management 3.13.1. Introduction The Forest Service is responsible for fire management on public lands managed by the agency across Arizona. Their responsibilities include managing wildland fire to protect human life, welfare, and property. The Forest Service also manages wildland fire to restore and maintain healthy ecosystems. The primary directive of the fire program is to provide for public and firefighter safety. The Forest Service has identified uncharacteristic fire and the buildup of fuels as a threat to the health and sustainability of the national forests (Forest Service 2015b). Fire plays a critical role in shaping vegetative characteristics. Fire suppression practices of the 20th century have pushed some vegetative communities outside of their historic range of variability due to increased fuel accumulations, higher densities of trees and shrubs, and increased ladder fuels. As a result, these areas are prone to higher-intensity wildfires than historically experienced. Fuels are considered any type of combustible material or vegetation that is susceptible to sustaining fire. The purpose of hazardous fuels management through mechanical and chemical management techniques is to reduce the extent, intensity and severity of wildfire if and when it encounters a treatment area during

159 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests the lifespan of the treatments reducing the risk to communities, infrastructure, and natural resources. Strategically placed fuel treatments can have broader landscape effects that extend beyond the perimeter of the area physically treated, either through affecting fire behavior directly or by facilitating ecologically sensitive containment strategies (Wildland Fire Leadership Council [WFLC] 2014). Wildland fires are categorized in two types: 1) unplanned ignitions and 2) planned ignitions that are considered prescribed fires. Unplanned ignitions are associated with lightning strikes or unwanted and unplanned ignitions caused by human activity; lightning strikes may be managed as a prescribed fire for resource benefit based on fire management objectives in the area as well as environmental factors associated with weather, topography, and fuel loads (Western Area Power Administration [WAPA] 2012). The primary intent of APS’s vegetation management program is to prevent ignition starts under the electrical transmission lines and reduce surface, ladder, and canopy fuels through thinning and removal of vegetation. 3.13.2. Affected Environment The affected environment associated with wildfire and associated fuels is characterized and defined by the ROWs within each of the five forests. Table 2.2-1 in Chapter 2 identifies vegetation that is typically treated as part of the alternatives and also represents fuels that occur within and adjacent to the ROW. The composition and distribution of vegetation targeted for treatment can vary within each ROW and within each forest based on growth rate and environmental conditions which can affect fuel loads and fire behavior. Predicting the potential behavior and effects of wildland fire is an essential task in fire management (Scott and Burgan 2005). Twenty-one fuel models associated with Standard Fire Behavior Fuel Models: A Comprehensive Set for use with Rothermel’s Surface Fire Spread Model, known as Scott and Burgan Fire Behavior Fuel Models have been identified within the ROWs that occur on National Forest System lands. Table 3.13-1 provides descriptions for each of the main fire-carrying fuel types and Table 3.13-2 identifies the more specific fuel models, provides a brief description of their characteristic fire behavior, and indicates the amount of each within each of the five forests.

Table 3.13-1. Scott and Burgan Fuel Types

Fire-Carrying Fuel Description Fuel Model Type Code Grass Nearly pure grass and/or forb type GR Grass Shrub Mixture of grass and shrub, up to about 50 percent shrub GS coverage Non-Burnable Insufficient wildland fuel to carry wildland fire under any NB condition Shrub Shrubs cover at least 50 percent of the site; grass sparse to SH nonexistent Timber Litter Dead and down woody fuel (litter) beneath a forest canopy TL Timber-Understory Grass or shrubs mixed with litter from forest canopy TU

160 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Table 3.13-2. Scott and Burgan Fuel Models within APS ROWs Fuel Fire- Apache- Coconino Kaibab Prescott Tonto Model Carrying Sitgreaves Total National National National National Code Fuel Type Description National ROW Forest Forest Forest Forest Forest (acres) (acres) (acres) (acres) (acres) (acres) Grass is short, patchy, and possibly heavily grazed. GR1 Grass 677.85 247.70 603.87 255.60 335.84 2,120.86 Spread rate moderate; flame length low. Moderately coarse continuous grass, average depth GR2 Grass about 1 foot. 235.73 697.51 499.88 941.94 545.05 2,920.10 Spread rate high; flame length moderate. Moderately coarse continuous grass, average depth GR4 Grass about 2 feet. N/A 0.05 N/A N/A N/A 0.05 Spread rate very high; flame length high. Grass Shrubs are about 1 foot high, low grass load. GS1 390.27 209.59 570.18 170.82 229.13 1,569.98 Shrub Spread rate moderate; flame length low. Grass Shrubs are 1 to 3 feet high, moderate grass load. GS2 139.93 330.24 231.20 1,128.43 2,540.77 4,370.57 Shrub Spread rate high; flame length moderate. Non- Urban or suburban development; insufficient wildland NB1 31.34 45.23 24.61 11.26 64.28 176.73 Burnable fuel to carry wildland fire. Non- NB8 Open water 0.05 2.72 0.12 0.43 1.67 4.98 Burnable Non- NB9 Bare ground 5.39 28.05 18.35 51.05 36.21 139.05 Burnable Low shrub fuel load, fuelbed depth about 1 foot; some SH1 Shrub grass may be present. Spread rate very low; flame 73.04 32.57 3.52 1.14 1.41 111.68 length very low. Moderate fuel load (higher than SH1), depth about SH2 Shrub 1 foot, no grass fuel present. 13.06 10.40 N/A 5.02 17.94 46.43 Spread rate low; flame length low. Heavy shrub load, depth 4 to 6 feet. SH5 Shrub N/A 1.58 0.45 34.61 29.99 66.62 Spread rate very high; flame length very high Very heavy shrub load, depth 4 to 6 feet. Spread rate SH7 Shrub lower than SH5, but flame length similar. 14.57 18.24 13.91 123.57 442.53 612.82 Spread rate high; flame length very high

161 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Fuel Fire- Apache- Coconino Kaibab Prescott Tonto Model Carrying Sitgreaves Total National National National National Code Fuel Type Description National ROW Forest Forest Forest Forest Forest (acres) (acres) (acres) (acres) (acres) (acres) Timber Light to moderate load, fuels 1 to 2 inches deep. TL1 N/A 2.43 27.77 3.02 0.78 34.00 Litter Spread rate very low; flame length very low Fuelbed not recently burned Timber Fuelbed composed of broadleaf (hardwood) litter. Low TL2 5.00 2.26 0.35 N/A 1.73 9.34 Litter load, compact. Spread rate very low; flame length very low. Fuelbed not recently burned Timber Fuelbed does not include coarse fuels. Moderate load TL3 176.10 213.12 154.28 15.15 152.32 710.97 Litter conifer litter. Spread rate very low; flame length low. Fuelbed not recently burned Timber Fuelbed does not include coarse fuels. High load TL5 0.35 1.60 0.59 1.82 0.37 4.72 Litter conifer litter; light slash or mortality fuel. Spread rate low; flame length low. Fuelbed not recently burned Timber Fuelbed composed of broadleaf (hardwood) litter. TL6 N/A 0.49 1.19 0.70 1.26 3.64 Litter Moderate load, less compact. Spread rate moderate; flame length low. Fuelbed not recently burned Fuelbed composed of long-needle pine litter Timber TL8 Moderate load and compactness may include small 34.99 138.06 81.57 51.27 56.14 362.04 Litter amount of herbaceous load. Spread rate moderate; flame length low. Timber- Fuelbed is low load of grass and/or shrub with litter. TU1 12.73 40.93 67.31 15.31 52.79 189.08 Understory Spread rate low; flame length low. Timber- Fuelbed is moderate litter load with shrub component. TU2 N/A N/A N/A N/A 0.04 0.04 Understory Spread rate moderate; flame length low Fuelbed is high load conifer litter with shrub Timber- TU5 understory. 4.18 1.58 1.24 1.62 0.98 9.60 Understory Spread rate moderate; flame length moderate. Total 1,814.56 2,024.35 2,300.38 2,812.75 4,511.24 13,463.29 Source: Scott and Burgan 2005; Logan Simpson 2018 Table Note: N/A = not applicable

162 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

3.13.3. Design Features Design features applicable to fire and fuel management are stated in Chapter 2. For design features related to manual and mechanical treatment methods, refer to Section 2.1.8; for design features related to herbicide treatment methods, refer to Sections 2.1.8 and 2.2.11. 3.13.4. Environmental Consequences Direct and Indirect Effects of Alternative A All ROWs would continue to be routinely inspected by APS, typically on an annual basis, to check the condition of the ROWs and status of vegetation. The Arizona Public Service Company would conduct routine vegetation maintenance using manual and mechanical treatment methods (refer to Sections 2.1.4 through 2.1.8 above) on a set maintenance schedule/cycle that would trim or remove new growth and/or regrowth since the last treatment. During routine vegetation maintenance, all woody vegetation (shrubs and trees) within a 10-foot radius around poles and 40-foot radius around transmission towers would be removed. Fuels modifications associated with the removal, or selective spacing, of all woody vegetation would reduce fuel loading within the ROW. The treatment schedule, ranging from every three to six years, would depend on the maintenance needs for each ROW based on the APS routine inspections. On National Forest System lands, vegetation within the ROWs has been, and would be, continually maintained in coordination with Forest Service fire management staff within each district. In addition, DSAP maintenance would be part of Alternative A to comply with the International Fire Code (International Code Council 2011; Section A102.3.1). The objective is to remove vegetation from around the poles to reduce the risk of fire ignition from spark emitting electrical equipment and to reduce fuels/provide a fuel break around these poles to help protect them in the event of a wildland fire. These poles are generally located in the wildland-urban interface areas near residential development. Under Alternative A, fuel loads would constantly increase due to the regrowth and resprouting that is incompatible with the power line facilities. Surface24, ladder25, and canopy26 fuels would be modified over the short-term, but brush and shrubs would constantly resprout from the roots and would perpetually need to be addressed in the ROWs. Alternative A would modify the fuel characteristics27 but not lower the fuel loads in the ROWs because the existing vegetation treatment methods would lead to dense re-growth of vegetation and not the removal of fuel. In Alternative A, APS would be limited to using manual and mechanical control methods to maintain vegetation in the ROWs. Therefore, Alternative A would have short- and long-term, direct and indirect, negligible beneficial impacts on fuel management because the vegetation maintenance activities would alter the fire dynamics but the fuel loads would be maintained at current levels. Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with Alternative A described above, Alternative B would also have an effect on fire and fuel management on National Forest System lands. The use of Forest Service-approved herbicides would prevent fuel build-up that results from the rapid, dense regrowth and sprouting and then subsequent cut-back of undesired vegetation in the ROW. Over time, it is expected the

24 Surface fuels are fuels that are lying on or near the surface of the ground, consisting of leaf and needle litter, dead branch material, downed logs, bark, tree cones, and low stature living plants (https://www.nwcg.gov/glossary/a-z).

25 Ladder fuels are fuels which provide vertical continuity between strata, thereby allowing fire to carry from surface fuels into the crowns of trees or shrubs with relative ease. They help initiate and assure the continuation of crowning (https://www.nwcg.gov/glossary/a-z).

26 Canopy fuels are the stratum containing the crowns of the tallest vegetation present (living or dead), usually above 20 feet (https://www.nwcg.gov/glossary/a-z).

27 Fuel characteristics are factors that make up fuels such as compactness, loading, horizontal continuity, vertical arrangement, chemical content, size and shape, and moisture content (https://www.nwcg.gov/glossary/a-z).

163 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests post-treatment residue of vegetation debris would decline with the use of herbicides as compatible plant species become established in the ROW, and the use of herbicides would prevent resprouting and subsequent cutback. In Alternative B with the use of herbicides over time, the incompatible vegetation species would be removed and the compatible species would become more mature and established in the ROWs. This would reduce the need for constant fuels treatments and would substantially reduce residue build-up and fuel loads in the ROWs. The composition of flammable vegetation within the ROWs would be altered resulting in reduced fuel loads and subsequently reduce fire intensity within the ROW. The use of herbicides would make permanent the selective removal of plant species that are most prone to canopy fires and would reduce the surface, ladder, and canopy fuels in the area directly beneath the power lines. Alternative B would also facilitate and prolong the selective thinning of the surface, ladder and canopy fuels in the ROW. Fuel modifications associated with the use of herbicides within the existing ROWs could reduce the intensity of a flaming front28 of a crown fire as it enters the ROW by changing fire behavior characteristics associated with fuel breaks. The use of Forest Service-approved herbicides would more permanently establish the vegetation composition needed to create these conditions. Therefore, Alternative B would have short- and long-term, direct and indirect, moderate, beneficial impacts on fuel management because the use of herbicides would substantially reduce fuel loads and subsequently reduce fire intensity within the ROWs.

3.14 Human Health and Safety 3.14.1. Introduction This section examines the existing conditions and potential risks to human health and safety from physical and chemical hazards from vegetation management of transmission facilities. Transmission facilities provide electricity for heating, lighting and other services essential to the public. Managing vegetation around electric transmission facilities keeps the electricity from flashing to the ground or other objects which can result in power outages and even lead to fires that can cause loss of life or injuries. This same vegetation management can potentially harm people by the improper use of tools and machinery and exposure to chemicals and physical hazards. Risks to workers may differ from those facing the general public. People living in Arizona are exposed to a variety of risks common to the United States as a whole. There are risks to humans from diseases, natural disasters, contaminants in the air, water, soil, and food, and automobile collisions. Exposure to these risks are not addressed in this EA because they are not directly or indirectly connected to the potential environmental consequences of the alternatives. Human Health and Ecological Risk Assessments have been prepared by an independent company, SERA, for herbicides used by the Forest Service (Forest Service 2018c). Each risk assessment uses an extremely thorough literature review of environmental and human effects to create a model. In these documents, the process of risk analysis is used to quantitatively evaluate the probability that a given herbicide use might impose harm on humans or other species in the environment. Additionally, the Forest Service has supplemental documentation referred to as Human Health and Ecological Risk Assessments for herbicides commonly used by the Forest Service (Forest Service 2015c). These risk assessments consist of a review of available research and information to determine impacts to human health. Risk is defined as the likelihood that an effect (injury, disease, death, or environmental damage) may result from a specific set of circumstances (Forest Service 2015c). The Forest Service has analyzed the risks for all herbicides proposed for use in Alternative B and these risk assessments are available on the Forest Service’s Pesticide Management and Coordination website (Forest Service 2018). Additionally, EPA is

28 Flaming front is that zone of a moving fire where the combustion is primarily flaming. Behind this flaming zone combustion is primarily glowing or involves the burning out of larger fuels (greater than about three inches in diameter). Light fuels typically have a shallow flaming front, whereas heavy fuels have a deeper front (https://www.nwcg.gov/glossary/a-z).

164 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona the agency responsible for registering herbicides before their distribution or sale and conducts risk assessments to determine health and ecological impacts (EPA 2017). EPA lists recently reregistered herbicides in a Registration Eligibility Decision (RED), which can be viewed at EPA’s Reregistration and Other Review Programs Predating Pesticide Registration Review website (EPA 2017). 3.14.2. Affected Environment

Physical Hazards People living around the National Forests are exposed to a variety of common risk factors. Potential risks to human health and safety specifically within public land managed by the Forest Service include, but are not limited to, slips and falls, animal bites and stings, exposure to poisonous vegetation, and vehicle accidents; less frequent risks include wildland fires. Within the ROW, typical fire hazards include ignition of fuel sources (primarily vegetation) caused by sparks from routine maintenance vehicles, tools, or personnel. In addition, lack of adequate ROW maintenance and clearance (i.e., vegetation or trees too close to transmission lines) could lead to fires. Fires outside of the ROW could start for various reasons and later move into the ROW, endangering system operation.

Chemical Hazards People can have various responses to chemicals based on a variety of factors including sex, phase of life, and genetic predisposition to disease and organ system damage or impairment. Some vulnerabilities are temporary, others permanent. Toxic reactions result when chemical doses become high enough to interfere with the normal physiological functions of cells and tissues (Felsot 2001). Chemical sensitivity is defined as an adverse reaction to ambient doses of toxic chemicals, at levels that are generally accepted as subtoxic, in our air, food, and water (Rea 1994). All of the five forests have analyzed the risks to human health from using herbicides across the forest. Tonto and Prescott National Forests found a small percentage of the public may be hypersensitive or allergic to any one or more of the herbicides; a syndrome referred to as Multiple Chemical Sensitivity (MCS). An allergic reaction is the system overproducing antibodies to a specific foreign substance, which are often proteins. Some individual’s neurological or immune systems are especially susceptible (Munson 2004). Hypersensitive responses are unusual nontoxic overreactions likely associated with irritations to certain tissues in the nose or skin. Typical allergic or hypersensitive symptoms include runny nose, watery eyes, swelling and hives (Felsot 2001). However, the Arizona Technology Access Program (1996) noted 28 possible afflictions including asthma, chronic exhaustion, headaches, mental confusion, and seizures. About 16 percent of the population has multiple chemical sensitivities; four percent of these are more serious cases (Forest Service 2004a). Those with MCS may have adverse reactions to a variety of substances including cleaning supplies, paint, antibiotics as well as pesticides and herbicides. These individuals may take refuge in more remote areas such as National Forests due to the generally lower occurrences of chemicals and substances. Populations recognized as having particular susceptibility to herbicides include the following younger children, elderly people with respiratory or existing health issues, applicators, or persons on medication which may interact with herbicides (Munson 2004). 3.14.3. Design Features Design features applicable to human health and safety are stated in Chapter 2. For design features related to manual and mechanical treatment methods, refer to Section 2.1.8; for design features related to herbicide treatment methods, refer to Sections 2.1.8 and 2.2.11.

165 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

3.14.4. Environmental Consequences Direct and Indirect Effects of Alternative A Under Alternative A, human health and safety would not be subject to any potential impacts from the application of herbicides within APS ROW and the public, including those with MCS, would have no additional potential for herbicide exposure. The Arizona Public Service Company would continue to manage vegetation using manual and/or mechanical methods under their routine maintenance cycles as described in Section 2.2.3 Incompatible Vegetation Management. Incompatible vegetation would be treated in accordance to Forest Service policies and procedures for the purpose of safety and reliability of the electrical system. Manual methods involving hand operated equipment focused on target plants makes up the majority of the APS current routine vegetation maintenance activities. Adverse weather and rugged terrain commonly create harsh working conditions and increased potential hazards. Hazards associated with adverse weather conditions may include extreme temperatures. Other physical hazards would include risks from falling objects when cutting trees or limbs; tripping or slipping on hazards on the ground; protruding objects such as branches and twigs; poisonous plants and insects, and wildlife. Workers may be exposed to contact with irritant weeds, such as leafy spurge, which can cause blisters, dermatitis, and inflammation. Workers could also suffer allergic reactions to pollen from grasses and forbs. Some manual treatments would occur in remote areas where use of motorized equipment is difficult. The time required to obtain medical treatment in remote areas may complicate some injuries. Tools and equipment would present inherent risks such as sharp edges on the tools and the hazardous nature of fuels and lubricants used in mechanized equipment. The potential for hazard exposure (i.e., risk of injuries) would be exacerbated when workers are fatigued, poorly trained, or poorly supervised, and do not follow established safety practices. Appropriate training, together with monitoring and intervention to correct unsafe practices, would minimize risk of worker injury and illness. Compliance with Occupational Health and Safety Administration standards, along with agency, industry and manufacturers’ recommendations would reduce the potential exposure and risk of injury to workers. Maintaining equipment in optimal working condition and using automatic shut-off devices would help to reduce the likelihood of injury. It is unlikely that the public would be at risk from manual treatments. It is possible that flying debris could accidentally hit a person. People who may come near APS workers preforming manual vegetation treatments could be exposed to exhaust gases and fuel vapors, potential flying debris, and falling trees. Impacts on the public’s health and safety are unlikely because the remote locations of many of the APS facilities and manual clearing is closely supervised. Vehicles used to transport crew members and equipment to the treatment sites on access roads used by the public may present a risk in vehicle accidents. Mechanical methods would have similar potential risks to public health and safety as manual methods. Contact with cutting blades, mulchers, shredders, chainsaws, or similar equipment during maintenance activities could injure vegetation crew members. Equipment operators could be injured from improperly operating the equipment or losing control of equipment on steep or slippery terrain. Rocks and other flying debris kicked up by equipment could also strike and harm operators or other workers near the treatment site. High noise levels during equipment operations could cause operators to experience partial hearing impairment. Use of appropriate personal protection equipment (hearing protection devices) would help to reduce noise risks. Workers using machinery in power line ROWs would need to take extra precaution to avoid contact with the power line or with vegetation that may come in contact with the power line, to avoid electrocution. Injuries can vary from minor cuts, sprains, bruises, and abrasions to major arterial bleeding, compound bone fractures, serious brain concussions, and fatalities.

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The public would be at a slight risk for injury from flying debris. Risks to the public would be greatest for vegetation treatment activities near public facilities. Fuels and lubricants used in mechanical equipment could spill into a stream or other water body from an accident or leak, or during refueling. APS would refuel trucks, tractors, and other equipment away from water bodies, preferably at a designated fueling site, and would prepare a spill containment plan prior to beginning maintenance activities. Impacts on the general public’s health and safety is unlikely due to the limited access and remote locations of many APS facilities. The use of equipment on access roads used by the public presents an increased risk in vehicle accidents. DSAP maintenance activities, similar to both manual and mechanical vegetation management methods require the use of vehicles, use of hand and potentially power tools, field crew, and over land travel by tracked or wheeled vehicles (e.g., ATVs or 4x4 trucks) to gain access to the treatment areas approximately every three years. Again, similar to the potential risks associated with manual and mechanical methods, public that are near the ROW during clearing operations can be exposed to vehicle and equipment exhaust gases and fuel vapors, flying debris, and falling trees. Proper supervision would prevent exposure and reduce the risks to the public. Impacts on the general public’s health and safety would be minor because of limited access and remote locations of APS facilities. Vehicle and equipment on access roads used by the public may present a risk in vehicle accidents. Under Alternative A, ROWs would continue to be treated at the same frequency and intensity, subjecting workers to potential long-term increase for injuries as a result of continued work with heavy equipment, hand-held equipment, and ROW characteristics. Personal protection equipment including, but not limited to long sleeves, gloves, eye protection, and helmets would greatly reduce risk to workers but with the continued intensity of vegetation treatments additional opportunity for injury exists. With the continued use of heavy equipment for mechanical vegetation treatment, there is the increased potential for impacts as a result of hazardous spills such as petroleum products from the presence of heavy equipment. The likelihood of this is greater under Alternative A than Alternative B because of the more frequent presence of heavy equipment in the APS ROW. Design features and APS BMPs associated with both alternatives would assist in limiting potential hazards. Therefore, Alternative A would have short- and long-term, minor, direct and indirect, adverse effects to human health and safety because of the measurable risk to the workers and public associated with manual and mechanical vegetation treatment methods, vegetation disposal, and vehicle travel within the ROWs. Direct and Indirect Effects of Alternative B In addition to the short-term effects associated with Alternative A described above, Alternative B would also result in potential impacts on human health and safety from the use of herbicides as part of the management of incompatible vegetation within the ROW. This analysis of Alternative B assumes that herbicides would be applied according to product labels, which would help reduce potential risks to humans and the environment. Herbicide label information and requirements include: personal protective equipment; user safety; first aid; environmental hazards; directions for use; storage and disposal; general information; mixing and application methods; approved uses; weeds controlled; and application rates (Forest Service 2005a). The closed chain-of-custody method would establish a protocol for the herbicide shipping, distribution, storage, and mixing. Herbicides would be chosen to minimize risk to people. Each chemical has a label with specific requirements for handling and use of chemicals that must be followed for legal compliance and to ensure all safety procedures are adhered to. Most of the herbicides do not pose a risk to human receptors when applied at the typical application rate. Based on the Human Health and Ecological Risk Assessments, chlorsulfuron, clopyralid, glyphosate, picloram, and triclopyr would not pose a risk when applied at the typical rate, but would pose a risk under one or more exposure scenarios involving applications at the

167 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests maximum application rate (Forest Service 2018c). There would not be risks associated with scenarios involving applications of dicamba, imazapic, imazapyr, metsulfuron methyl, or sulfometuron methyl at the maximum, or typical, application rate. There would be risk to workers using 2,4-D or tebuthiuron at either the typical or the maximum application rate. In general, the public would be less at risk than the herbicide applicators and vegetation maintenance crew members. For most herbicides, risks to the public could be minimized or avoided by using the typical application rate and following the design feature that would greatly reduce the likelihood of accidents (BLM 2007). Crew members would include applicators, supervisors, and other personnel on-site or directly involved in the application of herbicides. Vegetation maintenance crew member would be more likely to be exposed to herbicides; the risk assessments consider the exposure rates likely for workers. The public includes non-project forestry workers, forest visitors or nearby residents who could be exposed through the drift of herbicide spray droplets, through contact with sprayed vegetation, or by eating, or placing in the mouth, contaminated food items or other plant materials, such as berries or shoots growing in the APS ROW. The probability of the publics’ chance of encountering an herbicide treated area is unlikely and the potential for exposure to an herbicide for the worker or general public would not exceed the daily exposure level determined to be safe by EPA. The amount of herbicide being applied is relatively small; depending on the herbicides included in the custom blend, the ratio would be 90 to 94 percent Thinvert or oil-based carrier to six to 10 percent herbicide, which is below the routine typical application rates. The adjuvant, ThinVert, would be used to minimize the overall amount of herbicide used as well as spray drift onto adjacent National Forest System lands. All herbicide application would be done at or below the routine typical application rates and these estimated rates assume a minimal exposure to workers and an even lower exposure of the general public. Any potential exposures by contact or drift would not exceed daily exposure levels determined to be safe by the EPA (Forest Service 2005a). The risk of public exposure to herbicides would be greatest with foliar application as opposed to basal, cut-stump, or pre-emergent treatments. Any potential exposure to the public would likely occur as a result from skin contact with sprayed vegetation and, to a lesser extent, from consumption of vegetation sprayed with herbicide. These risks would be highest within the first few minutes after treatment. The herbicides proposed for use do not require restricting access to the areas being treated. Individuals exposed to herbicides as a result of the accidentally ingestion of contaminated vegetation are at a much higher risk than those coming into contact with the herbicide via skin. The skin acts as a protective barrier and thus the lethal dose for oral intake is typically much less than the lethal dose for dermal contact (Hayes 1991). Illness as a result of herbicide inhalation can result in the most severe effects; however, inhalation is typically uncommon, even among herbicide applicators (Ross et al 2000). It is unlikely that the public would come into contact within the first few minutes after treatment or ingest contaminated vegetation. Therefore, Alternative B would have short- and long-term negligible direct and indirect adverse effects to human health and safety because of the inherent risk to the workers associated with manual and mechanical vegetation treatment methods, vegetation disposal, vehicle travel, and exposure to Forest Service-approved herbicides within the ROWs.

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CHAPTER 4. Cumulative Impacts

A cumulative effect is defined under NEPA as “the change in the environment which results from the incremental impact of the action, decision, or project when added to other past, present, and reasonably foreseeable future actions, regardless of what agency (Federal or non-Federal) or person undertakes such other action.” “Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time” (40 CFR Part 1508.7). Past, present, and reasonably foreseeable future actions that incrementally add to the potential adverse or beneficial cumulative impacts of Alternative A and Alternative B are considered in this EA.

4.1 Geographic and Temporal Scope of Analysis Geographic (spatial) and time (temporal) boundaries have been established for this cumulative effects analysis. Forest management, construction, and recreational activities can cause impacts similar to those of the alternatives in this EA. One cumulative effects study area (CESA) has been developed for both of the alternatives. Due to the linear nature of the power line ROWs and the diverse landscape that the power lines cross throughout Arizona, a vegetation management program would contribute relatively minor impacts when considered together with other actions in the region. Therefore, the alternatives’ “footprints,” or the CESA boundary for individual resources has been identified as the APS ROWs throughout the State of Arizona regardless of land jurisdictions. Although the ROW widths vary, 300 feet has been determined to be the appropriate corridor width (150 feet either side of the power line centerline) for the cumulative impact analysis. Table 4.1-1 provides the line miles and acres of the CESA by land jurisdiction or ownership.

Table 4.1-1. Cumulative Effects Study Area (CESA)a Total Miles of Power Percent of Total Land Jurisdiction/Ownership Acres of CESA Lines within CESA CESA Federal 2,741 99,673.72 16.38 Private 11,017 400,618.18 65.84 State 1,688 61,381.18 10.09 Tribal 1,285 46,727.27 7.68 Total 16,732 608,436.36 - Source: APS 2018 a The acres of APS ROW within private and State lands include urban areas and paved surfaces. Subsequently, the calculations for areas subject to vegetation management are overestimated in the table for the CESA.

169 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Figure 4-1. Power Lines in Arizona – Cumulative Effects Study Area

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4.2 Timeframe of Effects Short-term cumulative effects would occur during individual treatment implementation, which could occur systematically over multiple years. Treatments may occur over several weeks depending on the treatment size and complexity of terrain and access. Long-term cumulative effects would be expected to occur from ten years to up to two decades after implementation of treatments in specific locations as compatible vegetation becomes reestablished.

4.3 Past and Present Actions In order to understand the contribution of past actions to the cumulative effects of both alternatives, this analysis relies on current environmental conditions as a proxy for the impacts of past actions. Existing conditions reflect the aggregate impact of prior human actions and natural events that have affected the environment and could contribute to cumulative effects. The cumulative effects analysis does not attempt to quantify the effects of past human actions by adding up all prior actions on an action-by-action basis. By looking at current conditions, the residual effects of past human actions and natural events are captured, regardless of which particular action or event contributed those effects. The CEQ issued an interpretive memorandum on June 24, 2005 regarding analysis of past actions, which states, “agencies can conduct an adequate cumulative effects analysis by focusing on the current aggregate effects of past actions without delving into the historical details of individual past actions”.

4.4 Reasonably Foreseeable Future Actions Reasonably foreseeable future actions are actions that have existing decisions, funding, or formal proposals or that are highly probable. These actions are not connected to Alternative A or Alternative B. They are projections being made so that future effects, cumulative and otherwise, can be estimated, as required by NEPA. Anticipated future actions include the continuation of grazing activities, general use activities such as off-highway vehicle (OHV) use, recreation, construction projects, and the maintenance of existing facilities, and other on-going activities such as the Arizona Department of Transportation’s use of herbicides to control or eradiate invasive species and noxious weeds. Specific projects as part of the Forest Service Schedule of Proposed Actions (SOPAs) include landscape and forest restoration, fuel reduction, mining operation, and other vegetation management project projects. For this EA, 30 projects have been identified from the SOPA as of May 2018 and reviewed by each forest for resource impacts considered during this evaluation. Table 4-2 identifies the name and acreage of each project within the CESA (refer to Appendix I for a brief description of the projects).

4.5 Cumulative Impacts on Resources For this analysis, cumulative resource impacts for the CESA are the combined direct and indirect effects of the present and reasonably foreseeable future actions, plus the direct and indirect impacts of both alternatives. The levels of direct, indirect, and cumulative impacts are categorized as major, moderate, minor, or negligible based on the same thresholds for the environmental consequences. In addition, if the direct or indirect impacts were considered to be none or negligible as a result of Alternative A or Alternative B, there would be no contribution to the resources’ cumulative impacts and therefore no further discussion has been included in this section.

171 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Table 4.5-1. Reasonably Foreseeable Future Projects

Project Acres in CESA* Four Forest Restoration Initiative (4FRI) Rim County Project 3,776.47 Hassayampa Landscape Restoration Project 92.58 Chino Landscape Restoration Project 1,431.37 Turkey Butte/Barney Pasture Forest Health Restoration 105.3 Cragin Watershed Protection 30.36 Haigler Fuels Analysis 121.06 Jack Smith/Schultz Fuels Reduction and Forest Health Unknown Highway Tanks Tribal Forest Protection Act Project 0.05 Larson Forest Restoration Project 472.7/145.45 Spring Prescribed Fire 160.19 Western Area Power Administration Glen Canyon – Rogers 230/345kV Integrated Vegetation Management Program 0.31 Pinto Valley Mine Plan of Operations 32.75 Resolution Copper Project and Land Exchange Unknown Rim Lakes Forest Restoration 248.42 Travel Management Plan Implementation – Tonto 45.51 Travel Management Plan Implementation – Coconino 58.24 Travel Management Plan Implementation – Apache-Sitgreaves 36.09 Hicks-Pikes Peak Allotment Grazing Authorization 91.13 Fossil Creek WSR Interim Management 24.42 Kelly Motorized Trails 33.27 Rock Pit Development: Coconino and Kaibab National Forests 1.98 Rio de Flag - Flagstaff Urban Trail System (FUTS) Extension Project 24.65 Dry Lake II Solar Project – New road construction 41.15 Mountain View Estates Access Road (Project in Area 1) 2.33 Henness Road (Project in Area 3) 1.15 State Park Unknown SR 73 Frontage Road Unknown SR 85 - SR 303L Unknown SR 303L - SR 202L, South Mountain Unknown I-10 Maricopa, MP 54 - I-10 11.19 a Where acreage is stated as unknown, projects have been identified although no project scoping, environmental, or design document is available.

Alternative A and Alternative B would both result in short- and long-term, direct and indirect, adverse and beneficial impacts to resources within the ROW. Both the alternatives would employ design features to reduce adverse impacts to the extent possible. Adaptive practices would be employed to change and modify practices in annual plans and specific treatment plans if issues are identified. This would further help to minimize potential impacts or contributions to cumulative impacts.

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Based on the analysis of direct and indirect impacts, neither of the alternatives would have minor, moderate, or major adverse effects on cultural resources, migratory birds and IBAs, bald and golden eagles, and Forest Service MIS within the ROW. There would be no incremental contribution to the resources respective cumulative impacts; therefore, there is no cumulative effects analysis for these resources. The analysis of impacts from both alternatives is provided in Chapter 3; refer to the specific resource subsection for detailed information including tables providing specific data by national forest. At the end of each resource description of the cumulative impacts below, concluding statements of impacts are provided. The alternative's the magnitude, duration, and intensity direct and indirect impacts are restated, followed by a similar summary of cumulative impacts, which includes consideration of the direct and indirect alternative's effects. A statement on the contribution of the alternative's impacts to the cumulative impacts is made as well.

4.6 Soils 4.6.1. Reasonably Foreseeable Future Actions Cumulative Impacts Cumulative impacts on soils are a result of vegetative maintenance activities, including the use of herbicides, within ROW. Impacts are predominantly associated with landscape restoration activities, fuel reduction programs, road construction, OHV and other recreation use, wildland fire, grazing, and natural disturbances. APS can potentially incorporate herbicide treatments as part of their maintenance regime on over 16,000 miles of ROW on Federal, privately-owned land, State trust land, and tribal lands. Cumulative effects on soil quality would occur from the potential herbicide loading added from other public agencies and private landowners in the area. Cumulative effects may occur to soil organisms from herbicide applications; however, these adverse impacts are expected to be short-term and limited in extent to the treatment sites. Cumulatively, treatments would not affect soil organisms located away from treatments (on forest or off). Beneficial cumulative effects would occur for treatment areas where compatible vegetation communities increase and long-term soil qualities improve. Most of the ongoing and foreseeable future activities within the CESA have objectives aimed at enhancing and restoring ecosystem functionality and healthy water and soil conditions. Adverse cumulative effects to soil would be offset by forest restoration treatments designed and implemented by the Federal and State agencies with landholdings with the CESA. Federal, State, and local land management entities have proposed numerous policies, programs, and initiatives to restore soil productivity and improve the health of ecosystems. These would cumulatively combine with the long-term beneficial effects of the proposed treatments in reducing soil erosion and sediment sources. Project related efforts to reduce the spread of invasive vegetation and to reduce the risk of wildland fire such as the Four Forest Restoration Initiative Project and the Hassayampa and Chino Landscape Restoration projects are expected to help maintain soil productivity and function. Reasonably foreseeable future actions could cumulatively result in short-term, direct and indirect, minor adverse impacts to soil resources from increased soil disturbance, erosion, and reduced biological crust cover. Implementing design features and conservation measures would reduce the potential for cumulative adverse effects from reasonably foreseeable future actions. These short-term soil disturbances or impacts would not be considered detrimental when considered together with the long-term, direct and indirect, moderate beneficial cumulative impacts from the improvements in soil quality and productivity in areas where treatment occurs and compatible vegetative is re-established. 4.6.2. Alternative A Contribution to Cumulative Impacts Alternative A is anticipated to result in short-term, direct and indirect disturbance to soil resources from manual and mechanical treatments and DSAP maintenance activities. Over the long-term, the routine vegetation maintenance requirements in terms of the number of acres to be treated, the density of vegetation to be removed, and the number of work crew members, equipment, and vehicles required are anticipated to be relatively the same for each work cycle. The regrowth of vegetation within the ROW

173 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests would occur between work cycles and any detrimental effects to soil quality and erosion susceptibility from treatment activities would be reduced. Clearing the DSAP totally of vegetation would directly disturb the soil and any micro- and macro-organisms in addition to the removal of the root system of any vegetation within the 10-foot radius as well. The disturbed soil would be vulnerable to increased erosion, soil productivity and soil quality would be reduced, and cleared area would be susceptible to invasive species establishment. Based on the analysis of potential effects in this EA, Alternative A would have short-term, direct and indirect, minor adverse impacts and long-term direct, negligible, adverse impacts as well as long-term, indirect, minor beneficial impacts. Alternative A would require more intense and frequent maintenance than Alternative B resulting in the potential for more frequent ground disturbance. Cumulatively, effects of Alternative A, when combined with past, present, and reasonably foreseeable future actions, would result in short-term, direct and indirect, minor adverse cumulative impacts and long-term, direct and indirect, moderate beneficial cumulative impacts on the soil resources within the CESA. Alternative A would have a negligible contribution to the cumulative effects on soil resources because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA. 4.6.3. Alternative B Contribution to Cumulative Impacts In addition to the short-term effects associated with Alternative A described above, Alternative B would also result in impacts on soil and soil organisms from the use of herbicides as part of the management of incompatible vegetation within the ROW. Some amount of disturbance to soils and biological soil crusts would occur during the cycle of manual/mechanical and herbicide treatments with Alternative B. The amount of soil loss or erosion, or changes in soil characteristics would be minor and localized. Because the approved herbicides that would be used have not been shown to substantially decrease soil microbial activity, only short-term and localized minor adverse impacts would be expected on soil productivity until low-growing, early successional plant communities become prolific within the ROWs. Where used, herbicides have decreased the frequency or intensity of vegetative maintenance activities in most areas, resulting in decreased ground disturbance, which can adversely impact soils, damage biological soil crusts, and increase soil erosion potential. The use of IVM techniques under Alternative B would reduce the intensity of future mechanical and manual treatments, subsequently reducing potential impacts to soils. The impact reduction is based on successful use of herbicides that would prevent incompatible vegetation from returning for approximately eight years; generally disturbing less soil for most areas. Long-term, indirect impacts would be based on the successful use of herbicide and establishment of low- growing vegetation, which would result in the reduced frequency of vegetation management treatments. Based on the analysis of potential effects in this EA, Alternative B would have short-term, direct and indirect, minor adverse impacts to soil resources and long-term, direct and indirect, moderate beneficial impacts. Cumulatively, effects of Alternative B, when combined with past, present, and reasonably foreseeable future actions, would result in short-term, direct and indirect, minor, adverse cumulative impacts and long-term, direct and indirect, moderate beneficial cumulative impacts on the soil resources within the CESA. Alternative B would have a negligible contribution to the cumulative effects on soil resources because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA.

4.7 Water Resources and Quality (Drinking/Surface/Groundwater) 4.7.1. Reasonable Foreseeable Future Actions Cumulative Impacts Soil erosion, which can be caused by loss of vegetation in areas of sheet flow near water bodies, on banks and floodplains of perennial and intermittent stream beds, and in streams with increased stream flows, can impact surface waters. The Federal agencies within the CESA allow for the use of public lands for a variety of activities under their respective travel management plans, recreational permits, and mineral and

174 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona grazing leases. These federally permitted actions as well as, activities on private, State, and tribal lands related to motor vehicle use, mining, and cattle grazing are commonly associated with potential soil erosion and the deterioration of surface waters. These actions can also affect the amount of available groundwater due to pumping; however, maintenance and management goals of affected areas minimize potential cumulative impacts to water resources. Water quality monitoring is conducted by State and Federal agencies, local governments, tribes, and others, among which there is wide variance in the extent and types of monitoring. The use of herbicides for the reduction of vegetation is currently occurring on lands within the CESA. Additionally, permitted activities by Federal and State agencies include those related to transportation, recreation, mineral extraction, and grazing, are expected to continue. These activities are commonly associated with increased likelihood for turbidity as a result of erosion adjacent to and within surface waters. Short-term, adverse impacts created by the forest restoration efforts (Four Forest Restoration, Chino Landscape Restoration, High Tanks, and Turkey Butte), fuel reduction plans (Haigler, Jack Smith-Shultz, and Spring), and watershed projects such as the Cragin Watershed Protection Project over the long-term would result in beneficial impacts. Cumulatively, these activities would create a short-term, direct and indirect, minor adverse impacts on water resources and water quality and long- term, direct and indirect, minor beneficial impacts. 4.7.2. Alternative A Contribution to Cumulative Impacts Alternative A would result in short-term, localized effects on water resources from the soil disturbance and associated potential for runoff from manual, mechanical, and DSAP maintenance activities. Over the long-term, the routine vegetation maintenance requirements are anticipated to be relatively the same for each work cycle. The regrowth of vegetation within the ROW would occur between work cycles. Any detrimental effects to surface and groundwater quality from incompatible vegetation treatment activities would be reduced because of the decreased erosion potential with vegetation regrowth. Based on the analysis of potential effects in this EA, Alternative A would have short-term, direct, minor adverse impacts; short-term, indirect, negligible beneficial impacts; long-term, direct, negligible adverse impacts; and long-term, indirect, negligible beneficial impacts to water resources and water quality. Cumulatively, effects of Alternative A, when combined with past, present, and reasonably foreseeable future actions, would result in short-term, direct and indirect, minor adverse impacts and long-term, direct and indirect, minor beneficial impacts on the water resources and water quality within the CESA. Alternative A would have a negligible contribution to the cumulative effect on water resources and water quality because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA. 4.7.3. Alternative B Contribution to Cumulative Impacts The use of IVM techniques under Alternative B would reduce the frequency and intensity of future mechanical and manual treatments, subsequently reducing potential impacts to water resources and water quality. The routine vegetation maintenance requirement would decrease over time resulting in less area needing treatment and a reduction in the number of vehicles, field crews, and pieces of equipment within the ROW. Based on the analysis of potential effects in this EA, Alternative B would have short-term, direct, minor adverse impacts; short-term, indirect, negligible beneficial impacts; and long-term, direct and indirect, moderate beneficial impacts to water resources and water quality. Therefore, the incremental effect of Alternative B, when added to the past, present, and reasonably foreseeable future actions, would result in short-term, direct and indirect, minor adverse impacts and long-term, direct and indirect, minor beneficial cumulative impacts on the water resources and water quality within the CESA. Alternative B would have a negligible contribution to the cumulative effect on water resources and water quality because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA.

175 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

4.8 Wetlands and Riparian Areas 4.8.1. Reasonable Foreseeable Future Actions Cumulative Impacts The reasonably foreseeable future actions and present actions have objectives aimed at enhancing and restoring ecosystem functionality and healthy water conditions. Acreage of surface disturbance, number of stream crossings, and the proximity of disturbance to riparian areas of any reasonably foreseeable future actions are not known. Ongoing efforts to protect wetlands and riparian areas have reduced the level of impact of natural and human factors that degrade these habitats. Reasonably foreseeable future actions identified no, to negligible, impacts to wetlands and riparian areas. Additionally, vegetation treatment programs by the Federal and State agencies, along with restoration efforts by private landowners and tribes, continue to improve the condition of degraded wetland and riparian habitats. Efforts to improve water quality are ongoing, including goals by the FS which are evident through planned projects such as the Cragin Watershed Protection Project. The FS and other land management agencies also continue programs to restore degraded wetland/riparian areas, which includes vegetation treatment programs and forest restoration projects. Ongoing efforts by the FS such as watershed and forest restoration projects would enhance wetland and riparian vegetation helping to increase the acres of wetlands that are in proper functioning condition. Activities that would contribute to minor adverse cumulative impacts to wetlands and riparian areas in the CESA include recreation, agricultural land uses and runoff associated with agricultural practices, road projects, water diversions, stock tanks, wildlife catchments, dams, and livestock grazing. The collective direct effects of vegetation management on stream systems should be minor when design features are followed. Travel management plans such as the Tonto and Coconino National Forests’ Travel Management Plan Implementations have identified the reconstruction and stabilization of roads to reduce adverse effects to surface water quality. Initially, wetlands and riparian areas would experience short-term increases in sediment production and transport as a result of activities. As the landscape is stabilized, improved conditions for wetlands and riparian areas would be established. Cumulatively, the reasonably foreseeable future actions would create short-term, direct and indirect, moderate adverse impacts on wetlands and riparian areas and long-term, direct and indirect, minor beneficial impacts. 4.8.2. Alternative A Contribution to Cumulative Impacts Alternative A is anticipated to have undetectable effects on wetlands and riparian areas from manual treatment activities because ground disturbance would be limited and non-targeted vegetation would not be impacted. Over the long-term, the routine vegetation maintenance would help control the spread of tamarisks and reduce the risk of wildland fire that could destroy compatible riparian and forested wetland vegetation. Based on the analysis of potential effects in this EA, Alternative A would have short-term, direct and indirect, negligible adverse impacts and long-term, direct and indirect, minor beneficial impacts to wetlands and riparian areas. Cumulatively, effects of Alternative A, when combined with past, present, and reasonably foreseeable future actions, would result in short-term, direct and indirect, moderate adverse impacts and long-term, direct and indirect, minor beneficial impacts on wetlands and riparian areas within the CESA. Alternative A would have a negligible contribution to the cumulative effect on wetlands and riparian areas because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA. 4.8.3. Alternative B Contribution to Cumulative Impacts Herbicide applications could reduce plant cover, leading to a potential increase in erosion, sedimentation, nutrient loading, and water temperature. Risks to wetlands and riparian areas from surface runoff would be influenced by precipitation rates, soil types, and proximity to the application area. Some herbicides (e.g., sulfometuron methyl) that adsorb into soil particles could be carried off-site. These potential impacts would be localized and considered short-term effects. Thinvert would be used to minimize drift onto non-target plants and potential effects to riparian vegetation would be very small in scale. Successful

176 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona control of incompatible vegetation in wetlands and riparian areas would lead to improved conditions in these habitats over the long-term. The eventual growth of compatible vegetation in treated areas would buffer the input of sediment and herbicides from runoff and promote bank stability in riparian areas. Based on the analysis of potential effects in this EA, Alternative B would have short-term, direct, minor adverse impacts; short-term, indirect, negligible adverse impacts; and long-term, direct and indirect, moderate beneficial impacts to wetlands and riparian areas. Cumulatively, effects of Alternative B, when combined with past, present, and reasonably foreseeable future actions, would result in short-term, direct and indirect, moderate adverse impacts on wetlands and riparian areas and long-term, direct and indirect, minor beneficial impacts on the wetlands and riparian areas within the CESA. Alternative B would have a negligible contribution to the cumulative effect on wetlands and riparian areas because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA.

4.9 General Vegetation 4.9.1. Reasonable Foreseeable Future Actions Cumulative Impacts Treatments that remove hazardous fuels from public lands would be expected to benefit the health of plant communities in which natural fire cycles have been altered. Any treatments that restore and maintain fire-adapted ecosystems, through the appropriate use of mechanical thinning, fire, and other vegetation treatment methods, would decrease the effects of wildfire on plant communities and improve ecosystem resilience and sustainability. Cumulative impacts to vegetation would stem from forest management activities, public land uses, and activities on other public and private lands. There are and would be activities in the reasonably foreseeable future within the CESA that contribute to cumulative effects to vegetation including a variety of vegetation management practices such as landscape and forest health restoration, reforestation projects, watershed protection projects, and prescribed fires. Forest Service projects such as the Four Forest Restoration Initiative Rim Country, Highway Tanks Tribal Forest Protection, and Turkey Butte/Barney Pasture Forest Health Restoration would contribute for overall forest health on National Forest System lands within the CESA. Many of the same human activities that have altered native plant communities in the past would continue to do so in the future. Populations of invasive species and noxious weeds would continue to spread. Treatments by the Forest Service, BLM, and other entities to remove hazardous fuels and control invasive species and noxious weeds would help offset these adverse effects. Projects to be conducted over the next 10 years would primarily be aimed at restoring vegetation and ecosystem functionality, based on agency priorities and budgets. Overall, the most noticeable cumulative effect on vegetation would be beneficial, especially over the long term. Cumulatively, the reasonably foreseeable future actions would create short-term, direct and indirect, moderate adverse impacts and long-term, direct and indirect, moderate beneficial impacts on general vegetation. 4.9.2. Alternative A Contribution to Cumulative Impacts Herbaceous plants would typically be more resilient to top-removal treatment methods, as many of these species die back annually. Growth of herbaceous plants often increases after mechanical treatments as a result of reduced competition with woody species for light, nutrients, and water. Treatments occurring during the growing period and prior to seed maturation and dispersal would have the greatest potential effects on herbaceous species. Mechanical treatment methods are effective in removing thick stands of vegetation, although mechanical methods require more routine treatments to maintain. Continued frequent disturbances and routine vegetation maintenance cycles would increase the effects of previous disturbance by disrupting the reestablishing vegetation and pose a continued risk for the introduction of noxious or invasive weeds. Based on the analysis of potential effects in this EA, Alternative A would have short- and long-term, direct and indirect, moderate adverse impacts on general vegetation. Cumulatively, effects of Alternative A, when combined with past, present, and reasonably foreseeable future actions, would result

177 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests in short-term, direct and indirect, moderate adverse impacts and long-term, direct and indirect, moderate beneficial impacts on general vegetation within the CESA. Therefore, Alternative A would have a negligible contribution to the cumulative effect on general vegetation because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA. 4.9.3. Alternative B Contribution to Cumulative Impacts Effects to non-target plants would be minimal since Alternative B accounts for the implementation of the design features and would apply herbicides using an adjuvant and by spot treatment targeting only incompatible vegetation. The use of herbicides would benefit plant communities by decreasing the growth, seed production, and competitiveness of target plants, thereby relieving competitive pressures (e.g., water, nutrient, and space availability) to low-growing compatible vegetation. The success of treatments would depend on numerous factors, and could require the use of a combination of methods to combat incompatible vegetation. Alternative B would have localized impacts from the changes in the structure and composition of the vegetation in the ROW, a reduction in frequency and intensity of vegetation management treatments as compared to Alternative A, establishment of low-growing vegetation communities, and a reduction in the risk of future high-severity wildfire. Based on the analysis of potential effects in this EA, Alternative B would have short-term, direct and indirect, moderate adverse impacts and long-term, direct and indirect, moderate beneficial impacts to general vegetation. Cumulatively, effects of Alternative B, when combined with past, present, and reasonably foreseeable future actions, would result in short-term, direct and indirect, moderate adverse impacts and long-term, direct and indirect, moderate beneficial impacts on general vegetation within the CESA. Alternative B would have a negligible contribution to the cumulative effect on general vegetation because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA.

4.10 Federally Listed Species There would be no contribution to cumulative impacts on the Chiricahua leopard frog, California condor, Mexican gray wolf, ocelot, Arizona cliffrose, Arizona hedgehog cactus, Colorado pikeminnow, desert pupfish, Gila chub, Gila topminnow, Gila trout, Little Colorado spinedace, loach minnow, razorback sucker, and spikedace because Alternative A and Alternative B would have negligible adverse impacts. As a result, these species are not analyzed for cumulative impacts. In the below discussion, the following species were analyzed: MSO, southwestern willow flycatcher, yellow-billed cuckoo, narrow-headed gartersnake, and northern Mexican gartersnake. 4.10.1. Reasonable Foreseeable Future Actions Cumulative Impacts Reasonably foreseeable future actions identified may have effects to the MSO, southwestern willow flycatcher, yellow-billed cuckoo, narrow-headed gartersnake, and northern Mexican gartersnake which would include the loss, modification, and fragmentation of habitat, and would increase the likelihood of local extirpations of individuals. These federally listed species would have protection under the ESA on lands within the CESA to help reduce or minimize some of the adverse impacts to the species and their habitats. Habitat fragmentation on and off public lands would continue, increasing the likelihood of potential impacts to federally listed species. These risks are greatest on privately-owned lands, which comprise over 65 percent of the CESA. Non-Federal activities that could impact federally listed species within the CESA include: various forms of recreation; road or construction projects (Dry Lake Phase II, Kelly Trail, and Fossil Creek improvement); mining expansion (Pinto Valley and Resolution Copper); and, livestock grazing. Introduction of non-native species such as bullfrogs, crayfish, and spiny-rayed fish on public and non-public lands can negatively impact northern Mexican gartersnake and their prey base within the CESA. Degradation and dewatering of aquatic habitats, livestock operations, and OHV use on public and non-public lands could also adversely affect northern Mexican gartersnake habitat. Forest restoration, along with noxious and invasive weed treatments would have short term impacts, such as

178 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona potential erosion, sedimentation, or loss of canopy cover, and long-term would result in minor habitat improvements on federally-managed lands by reducing encroachment, promoting riparian woody species, and reducing risk of catastrophic fire. Herbicide applications is ongoing by the Forest Service as well as by others on public and private lands and may potentially have cumulative effects on resources. The potential cumulative effect would be minimized by proper application procedures, such as to apply herbicides when rain is unlikely and that herbicides are applied in accordance with label directions. Aside from the design features under the control of the Forest Service, information regarding the magnitude and extent of future herbicide application outside National Forest System lands is quite limited. Cumulatively, the reasonably foreseeable future actions would create short- and long-term, direct and indirect, moderate adverse impacts on Mexican spotted owl, southwestern willow flycatcher, yellow-billed cuckoo, narrow-headed gartersnake, and northern Mexican gartersnake. 4.10.2. Alternative A Contribution to Cumulative Impacts

or less where work occurs locally. Upland and riparian vegetation has been continually maintained within the ROW. The removal and treatment of vegetation may result in minor local changes to narrow-headed gartersnake and northern Mexican gartersnake riparian and upland habitat. Important components for cover, such as woody debris would be maintained. Based on the analysis of potential effects in this EA, Alternative A would have short- and long-term, indirect, minor adverse impacts and short- and long-term, direct, negligible adverse impacts on the Mexican spotted owl, southwestern willow flycatcher, yellow-billed cuckoo, narrow-headed gartersnake, and northern Mexican gartersnake and their respective habitats. Cumulatively, effects of Alternative A, when combined with past, present, and reasonably foreseeable future actions, would result in a short- and long-term, direct and indirect, moderate adverse impacts on these five federally listed species and their habitat within the CESA. Alternative A would have a minor contribution to the cumulative effect on these five species and their respective habitats because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA. 4.10.3. Alternative B Contribution to Cumulative Impacts Federally listed species would continue to be at risk for exposure to chemicals. Identifying and restricting use of active ingredients with the greatest toxicological risks to sensitive species in favor of active

179 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests ingredients with lower risks would help reduce cumulative effects associated with exposure to these chemicals. The application of Forest Service-approved herbicides over time would reduce the frequency of the vegetation treatment, which would result in a reduction in humans and vehicles associated with vegetation management within the APS ROW (Forest Service 2018a). Alternative B would also result in impacts on the MSO and its designated critical habitat from the use of herbicides as part of the management of incompatible vegetation within the ROW. In the event that contact is made with the MSO, low-toxicity herbicides would be used resulting in no effect or a minimal, insignificant effect. The use of herbicides may provide a beneficial effect to MSO by reducing the frequency of manual and mechanical treatment of vegetation. Motorized vehicles would not be used near suitable habitat during the nesting season for the southwestern willow flycatcher and yellow-billed cuckoo. Herbicide application would be limited during the nesting season within suitable habitat. During other times of the year, any adult birds in the ROW would more than likely fly away before crew workers could get close enough to inadvertently spray them with herbicide. Long-term indirect effects to the riparian vegetation within the ROW would occur because this portion of the ROW would not be allowed to develop into suitable breeding habitat for flycatchers. Direct effects to narrow-headed and northern Mexican gartersnakes from contact with herbicides would be minimized by using approved low-toxicity herbicides within and near gartersnake habitat. Herbicide treatments would be limited to spot applications to individual plants within the ROW. The quantity of vegetation treated over the ROW area is low with grasses, forbs, and lower growing shrubs remaining untreated. Changes in vegetation composition affecting the two federally listed gartersnakes’ suitable habitats due to herbicide application could be expected. Based on the analysis of potential effects in this EA, Alternative B would have short- and long-term, indirect, minor adverse impacts and short- and long-term, direct, negligible adverse impacts on the Mexican spotted owl, southwestern willow flycatcher, yellow-billed cuckoo, narrow-headed gartersnake, and northern Mexican gartersnake and their respective habitats. Cumulatively, effects of Alternative B, when combined with past, present, and reasonably foreseeable future actions, would result in a short- and long-term, direct and indirect, moderate adverse impacts on these five federally listed species and their habitat within the CESA. Alternative B would have a negligible contribution to the cumulative effect on these five species and their respective habitats because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA.

4.11 Forest Service Sensitive Species There would be no contribution to cumulative impacts on Forest Service sensitive amphibians, birds, invertebrates, fish, mammals, and reptiles because Alternative A and Alternative B would have negligible adverse impacts. As such, there would be no contribution towards loss of viability or trend toward Federal listing for these species. As a result, these species are not analyzed for cumulative impacts. However, Forest Service sensitive plant species were analyzed in the below discussion. 4.11.1. Reasonable Foreseeable Future Actions Cumulative Impacts Reasonably foreseeable future projects within the CESA that contribute to cumulative effects include the variety of vegetation management practices, landscape and forest health restoration, reforestation projects, watershed protection projects, and prescribed fires. Future effects to Forest Service sensitive plant species would include the loss, modification, and fragmentation of habitat, which would increase the likelihood of local extirpations of individuals. Habitat loss and fragmentation on and off public lands would continue, increasing the likelihood of potential impacts to Forest Service sensitive plants. These risks are greatest on privately-owned lands, which comprise over 65 percent of the CESA. Non-Federal activities that could impact sensitive species within the CESA include new construction projects, recreation activities such as OHV use, and grazing. Similarly, under the Travel Management Plans for the Tonto, Apache-Sitgreaves,

180 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona and Coconino national forests travel routes and recreation opportunities such as outlined in the plans may also contribute to the degradation of Forest Service sensitive plant species. The application of Forest Service-approved herbicides over time would reduce the frequency of the vegetation treatment cycles, which would result in a reduction in humans and vehicles associated with vegetation management within the APS ROW (Forest Service 2018a). Cumulatively, the reasonably foreseeable future actions would create short- and long-term, direct and indirect, moderate adverse impacts on the Forest Service sensitive plant species. 4.11.2. Alternative A Contribution to Cumulative Impacts There would be no contribution to cumulative impacts to Forest Service sensitive plant species because the direct and indirect effects for Alternative A would result in negligible impacts. As such, Alternative A would not result in a loss of viability or trend toward federal listing of Forest Service sensitive plants. Therefore, Alternative A does not analyze Forest Service sensitive plant species for cumulative impacts. 4.11.3. Alternative B Contribution to Cumulative Impacts Alternative B would result in potential adverse impacts to Forest Service sensitive plants. Target plants have been maintained in the past during manual and mechanical treatments with the exception of new growth target plants. Sensitive plant species could be targeted if they are not compatible with the power lines or may be inadvertently impacted. DSAP treatment may result in removal of sensitive plants in the ROW. Alternative B would reduce the frequency and intensity of mechanical and manual treatment of vegetation, reducing impacts to sensitive plant species. Based on the analysis of potential effects in this EA, Alternative B would have short- and long-term, indirect, minor, adverse impacts and short- and long-term, direct, negligible adverse impacts to Forest Service sensitive plant species. Cumulatively, effects of Alternative B, when combined with past, present, and reasonably foreseeable future actions, would result in short- and long-term, direct and indirect, moderate adverse impacts on sensitive plants within the CESA. Alternative B would have a negligible contribution to the cumulative effect on sensitive plants because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA.

4.12 Rangeland Health 4.12.1. Reasonable Foreseeable Future Actions Cumulative Impacts Rangeland health accounts for impacts to soil, vegetation, and water resources to assess site stability, productivity, nutrient cycling, and vegetation diversity. Treatments that remove hazardous fuels from public lands would be expected to benefit the health of plant communities in which natural fire cycles have been altered. Any treatments that restore and maintain fire-adapted ecosystems, through the appropriate use of mechanical thinning, fire, and other vegetation treatment methods, would decrease the effects of wildfire on plant communities and improve ecosystem resilience and sustainability. There are and would be activities in the reasonably foreseeable future within the CESA that contribute to cumulative effects to rangeland health including a variety of vegetation management practices such as fuel reduction plans, reforestation projects, and prescribed fires. Forest Service projects such as the Four Forest Restoration Initiative and Turkey Butte/Barney Pasture Forest Health Restoration would contribute to overall forest and rangeland health on National Forest System lands within the CESA. Many of the same human activities that have altered native plant communities in the past would continue to do so in the future. Treatments by the entities to control vegetation, remove hazardous fuels, and control invasive species and noxious weeds would also benefit rangeland health and help reduce these adverse effects. Cumulatively, reasonably foreseeable future actions would create short-term, direct and indirect, moderate adverse impacts and long-term, direct and indirect, minor beneficial impacts on rangeland health.

181 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

4.12.2. Alternative A Contribution to Cumulative Impacts There would be no contribution to cumulative impacts on rangeland health because Alternative A would have negligible impacts. As a result, rangeland health for Alternative A is not analyzed for cumulative impacts. 4.12.3. Alternative B Contribution to Cumulative Impacts The use of IVM techniques collective throughout the CESA would reduce the frequency and intensity of future vegetation treatments and impacts to soil and vegetation, subsequently reducing potential adverse cumulative impacts to rangeland health. Increases in human population and overuse of rangelands may result in degradation of this resource. Effects to non-target plants would be minimal since Alternative B accounts for the implementation of the design features and would apply herbicides by spot treatment targeting only incompatible vegetation. Indirect spray through drift could impact these plants, but Thinvert or an oil-based carrier would be used to minimize drift onto non-target plants and potential effects to vegetation would be very small in scale. Based on the analysis of potential effects in this EA, Alternative B would have short-term, negligible impacts and long-term, direct and indirect, minor beneficial impacts to rangeland health. Cumulatively, effects of Alternative B, when combined with past, present, and reasonably foreseeable future actions, would result in short-term, direct and indirect, moderate adverse impacts and long-term, direct and indirect, moderate beneficial impacts on rangeland health within the CESA. The restoration efforts and reduction in frequency and intensity of vegetation maintenance disturbances would off-set the effects of previous disturbance by limiting the disruption of reestablishing vegetation and promote site stability. Alternative B would have a negligible contribution to the cumulative effect on rangeland health because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA.

4.13 Fire and Fuel Management 4.13.1. Reasonable Foreseeable Future Actions Cumulative Impacts Treatments that remove hazardous fuels from public lands would be expected to benefit the health of the vegetation communities in which historic fire cycles have been altered. Any treatments that restore and maintain fire-adapted ecosystems, through the appropriate vegetation management treatments methods, would decrease the effects of wildfire and improve ecosystem resilience and sustainability. Multiple reasonably foreseeable future actions are focused on landscape restoration and fuel reduction such as the Haigler Fuel Reduction, Turkey Butte, Cragin Watershed Protection, Highway Tanks Tribal Forest Protection, Hassayampa Landscape Restoration, and Four Forest Restoration and would contribute to the overall forest health and fire hazard reduction on National Forest Systems lands within the CESA. By reducing fuel loads, wildland fire would likely be smaller in scale, natural fuel breaks would be enhanced, and native vegetative communities would be more resilient and capable of successful post-fire response as a result of reduced fire severity. Overall cumulative effects for fire management would be moderately beneficial. Large wildland fires provide the opportunity for the replacement of native species with non- natives or weeds, which is a long-term adverse cumulative effect. Many of the same human activities that have altered native plant communities in the past would continue to do so in the future. Treatments by the Forest Service, BLM, and other entities to remove hazardous fuels and control invasive species and noxious weeds would help offset these adverse effects. Cumulatively, reasonably foreseeable future actions would create short-term, direct and indirect, moderate adverse impacts and long-term, direct and indirect, moderate beneficial impacts on fire and fuel management.

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4.13.2. Alternative A Contribution to Cumulative Impacts There would be no contribution to cumulative impacts to fire and fuel management because Alternative A would have negligible impacts. As a result, fire and fuel management for Alternative A is not analyzed for cumulative impacts. 4.13.3. Alternative B Contribution to Cumulative Impacts The use of herbicides would prevent fuel build-up that results from the rapid, dense re-growth and sprouting and then subsequent cut-back of undesired vegetation in the ROW. Over time, it is expected the post-treatment vegetation debris would decline with the use of herbicides as compatible plant species become established in the ROW, and the use of herbicides would prevent re-sprouting and subsequent cut-back. In Alternative B with the use of herbicides over time, the incompatible vegetation species would be removed and the compatible species would become more mature and established in the ROWs. This would reduce the need for repeated fuels treatments and would substantially reduce cut vegetation build- up and fuel loads in the ROWs. The composition of vegetation within the ROWs would be altered resulting in reduced fuel loads and subsequently reduce fire intensity within the ROW. Fuel modifications associated with the use of herbicides within the existing ROWs could reduce the intensity of a flaming front of a crown fire as it enters the ROW by changing fire behavior characteristics associated with fuel breaks. The use of herbicides would more permanently establish the vegetation composition needed to create these conditions and reduce the risk of future high-severity wildfire. Based on the analysis of potential effects in this EA, Alternative B would have short-term, direct and indirect, minor adverse impacts and long-term, direct and indirect, moderate, beneficial impacts to fire and fuel management. Cumulatively, effects of Alternative B, when combined with past, present, and reasonably foreseeable future actions, would result in a short-term, direct and indirect, moderate adverse impacts and long-term, direct and indirect, moderate beneficial impacts on fire and fuel management within the CESA. Alternative B would have a negligible contribution to the cumulative effect on fire and fuel management because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA.

4.14 Human Health and Safety 4.14.1. Reasonable Foreseeable Future Actions Cumulative Impacts Potential risks to human health and safety within the CESA include, slips and falls, animal bites and stings, exposure to poisonous vegetation, and vehicle accidents; less frequent risks include wildland fires. There is a potential for worker injury while performing vegetation maintenance activities as a result of tools and equipment and exposure to vegetation, wildlife, and weather. Majority of the reasonably foreseeable future actions are focused on landscape restoration and fuel reduction such as the Haigler Fuel Reduction, Turkey Butte, Cragin Watershed Protection, Highway Tanks Tribal Forest Protection, Hassayampa Landscape Restoration, and Four Forest Restoration and would contribute to overall forest health within the CESA, which would reduce the potential for human health risks associated with fighting wildland fire and subsequent forest restoration efforts. Cumulative impacts would also include projects which involve the proposed use of herbicide within the CESA such as Western Area Power Administration Glen Canyon-Rogers 230/345kV Integrated Vegetation Management Program. Cumulatively, risks to human health from the additive effects of herbicide exposure would be low. The potential human contact with wet herbicides on plant or soil surfaces is unlikely since once the formulation is dry and/or absorbed into the plant, the risk is lower than that assumed in the exposure scenarios analyzed in the risk assessments. The herbicides proposed for use have no access restrictions or reentry times established. Application rates have been registered using a process to determine toxicity and exposure, with the use of the “reference dose” to account for cumulative exposure. These doses represent a very small amount that, when given over a lifetime (70 years), would

183 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests show no effect. Workers who apply the herbicide are at the greatest risk, but with use of protective clothing and equipment along with following label restrictions, they are not expected to exceed this dose. The risk to the general public is even lower, even when all the amounts are considered cumulatively. Initial activities within the CESA would create adverse impacts, but the overall vegetation management and landscape restoration would reduce the amount of future treatments required. Cumulatively, reasonably foreseeable future actions could cumulatively result in short-term, direct and indirect, negligible adverse impacts to human health and safety with the implementation on applicable design features and long-term, direct and indirect, minor beneficial impacts. 4.14.2. Alternative A Contribution to Cumulative Impacts Under Alternative A, ROWs would continue to be treated at the same frequency and intensity, subjecting workers to potential long-term increase with injuries as a result of continued work with heavy equipment and hand-held equipment. Alternative A may result in more intense maintenance than Alternative B resulting in a greater likelihood of hazardous spills such as petroleum products due to the presence of heavy equipment. Design features would minimize risks to workers and the public. Based on the analysis of potential effects in this EA, Alternative A would have short- and long-term, direct and indirect, minor adverse impacts on public health and safety. Cumulatively, effects of the Alternative A, when combined with past, present, and reasonably foreseeable future actions, would result in short-term, direct and indirect, negligible adverse impacts and long-term, direct and indirect, minor beneficial impacts on public health and safety within the CESA. Alternative A would have a negligible contribution to the cumulative effects on human health and safety because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA. 4.14.3. Alternative B Contribution to Cumulative Impacts Alternative B would result in potential impacts on human health and safety from the use of herbicides as part of the management of incompatible vegetation within the ROW. This analysis of Alternative B assumes that herbicides would be applied according to product labels, which would help reduce potential risks to humans and the environment. Herbicide label information and requirements include: personal protective equipment; user safety; first aid; environmental hazards; directions for use; storage and disposal; general information; mixing and application methods; approved uses; weeds controlled; and application rates. The closed chain-of-custody method would establish a protocol for the herbicide shipping, distribution, storage, and mixing. Risk assessments indicate that treatment under Alternative B and added to other herbicide treatments ongoing or foreseeable, the likelihood is extremely low that any individual would be exposed to an amount of herbicide that exceeds the reference dose. Alternative B is consistent with EPA, OSHA and Forest Service regulations regarding herbicide use. Alternatives A and B are consistent with OSHA guidelines for worker safety. Based on the analysis of potential effects in this EA, Alternative B would have short- and long-term, direct and indirect, negligible adverse impacts on public health and safety. Cumulatively, effects of Alternative B, when combined with past, present, and reasonably foreseeable future actions, would result in short-term, direct and indirect, negligible adverse impacts and long-term, direct and indirect, minor beneficial impacts on public health and safety within the CESA. Alternative B would have a negligible contribution to the cumulative effects on human health and safety because the ROW on National Forest System lands is a very small portion (2.21 percent) of the CESA.

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CHAPTER 5. Finding of No Significant Impact

The following is a summary of the project analysis to determine significance, as defined by the Council on Environmental Quality regulations (40 CFR 1508.27) and Forest Service Handbook 1909.15_05. The significance of environmental impacts must be considered in terms of context and intensity. The significance of an action must be analyzed in the context of effects occurring on a local, regional, or global scale and the affected interests. Intensity refers to the severity of degree of impact. Context For the Proposed Action and No Action alternatives, the context of the environmental effects is based on the environmental analysis in this EA. The setting of this project is localized with implications to the immediate treatment areas located within the ROWs throughout the state of Arizona. The people most affected by the treatments will be workers and local residents located near the project area. This action is consistent with forest management projects that have occurred for many years on the five of the six national forests in Arizona, including Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto national forests. Adverse effects would be mitigated through implementation of the Design Features (pages 20-22, Section 2.1.8 Alternative A Design Features; and pages 36-39, Section 2.2.11 Alternative B Design Features) and Biological Conservation Measures (Appendix E) developed for the project. Intensity 1. Impacts that may be both beneficial and adverse: A significant effect may exist even if the federal agency believes that on balance the effect will be beneficial. Both beneficial and adverse effects have been taken into consideration when making a determination of significance. While there will be beneficial effects, this action does not rely on those effects to balance adverse environmental effects. Both beneficial and adverse, direct and indirect effects may result from the implementation of the Proposed Action, as described in Chapter 3. Design features would help reduce or eliminate adverse impacts and promote beneficial impacts. None of the environmental effects presented in this EA are considered significant (pages 41-168, Chapter 3. Affected Environmental and Environmental Consequences). 2. The degree to which the proposed action affects public health or safety. The Proposed Action is designed to treat incompatible vegetation and promote the establishment of compatible vegetation within the APS ROWs to prevent vegetation from coming into contact with a power line causing blackouts and power outages or threaten public safety. In addition to vegetation interference, the vegetation treatments associated with the Proposed Action would reduce fuel build-up within the ROWs, reducing the risk of fires within the ROW and minimizing risks to people and property (pages 159-164, Section 3.13 Fire and Fuel Management). Individuals most likely to be affected by the Proposed Action are those with chemical sensitivities. Design features would be implemented to minimize impacts to human health and safety including, but not limited to, notifying the public of herbicide use as established in the PUP review process and preparing an operations and spill plan in advance of treatment. The application of herbicides would be conducted according to product labels which reduce potential risks to humans and the environment. The Proposed Action would have short- and long-term negligible direct and indirect adverse effects to human health and safety because of the risk to the workers associated with manual and mechanical vegetation treatment methods and exposure to Forest Service-approved herbicides within the ROWs (pages 164-168, Section 3.14 Human Health and Safety).

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3. Unique characteristics of the geographic area such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas. The use of herbicides is unlikely to adversely impact areas with unique characteristics such as historical or cultural resources (addressed specifically in item 8), park lands, prime farmlands, wetlands, designated or eligible wild and scenic rivers, or other ecologically critical areas (refer to Appendix H. Resources Considered for Analysis). The application of herbicides would not result in any modification of a floodplain that would impede or redirect flood flows that would result in property damage on- or off-site. The flood-carrying capacity of the floodplain, the pattern, or the magnitude of the flood flow would not be affected. No treatments of actively cultivated land would occur under Alternative B and only incompatible vegetation would be targeted for herbicide use. Vegetation growing in surface waters would not be treated in the segments of the Upper Verde Wild and Scenic River (Segments 3-scenic and 4-recreational) within the ROW. Vegetation adjacent to these segments of the Upper Verde River would be treated in some locations, outside of established buffers or according to design features. No impacts are anticipated as only incompatible vegetation within the vicinity of power lines that could disrupt the delivery of electricity would be spot treated with herbicides. Additionally, the Proposed Action does not propose to use herbicides within any designated wilderness boundaries. Treatment areas may contain some unique characteristics including wetlands and riparian areas, federally listed and Forest Service species and habitats, and migratory bird areas. However, with the implementation of Design Features and Biological Conservation Measures (Appendix E), no major adverse impacts would occur. Project activities would not significantly affect lands with unique characteristics. 4. The degree to which the effects on the quality of the human environment are likely to be highly controversial. A total of 60 comment letters, emails, or telephone calls were received during the public scoping period. The comments consisted of three main points outlined in Section 1.4 Public Involvement (pages 9-10). Opposing comments submitted by the public for the project related largely to concerns regarding human health and safety and impacts on the environmental and wildlife. Key issues as a result of public scoping were developed and analyzed within the EA document. Based on the limited context of the project, review of public comments, and the project’s analysis, there are no highly controversial effects to the human environment. There is no substantial scientific controversy related to the environmental effects of the Proposed Action. 5. The degree to which the possible effects on the human environment are highly uncertain or involves unique or unknown risks. Based on this project’s analysis, possible effects on the human environment that are uncertain or involve unique or unknown risks are minimal or non-existent. This project is similar to the various herbicide vegetation treatment projects conducted on National Forest System lands. Human Health and Ecological Risk Assessments have been prepared by the Forest Service which includes analysis of risks for all herbicides proposed for use as part of this project. The effects associated with the Proposed Action are recognized, familiar, and acceptable (pages 164-168, Section 3.14, Human Health and Safety). The analysis is based on our best use of available science and data on herbicides and our experience with various types of herbicide projects. 6. The degree to which the action may establish a precedent for future actions with significant effects or represents a decision in principle about a future consideration. This project represents a site-specific project that does not set precedence for future actions or present a decision in principle about future considerations. Any proposed future project will be evaluated on its own merits and effects. The activities are in accordance with the best available science we have to manage vegetation and reduce fuel loads to protect people and personal property.

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7. Whether the action is related to other actions with individually insignificant but cumulatively significant impacts. Significance exists if it is reasonable to anticipate a cumulatively significant impact on the environment. Significance cannot be avoided by terming an action temporary or by breaking it down into small component parts. These actions do not individually, nor with other activities taken cumulatively within the affected area, reach a level of significance (pages 169-184). The Proposed Action would only result in a negligible contribution to the cumulative effects on Soils (pages 173-174, Section 4.6); Water Resources and Quality (Drinking/Surface/Groundwater) (pages 174-175, Section 4.7); Wetlands and Riparian Areas (pages 176- 177, Section 4.8); General Vegetation (pages 177-178, Section 4.9); Federally Listed Species (pages 178- 180, Section 4.10); Forest Service Sensitive Species (pages 180-181, Section 4.11); Rangeland Health (pages 181-182, Section 4.12); and Fire and Fuel Management (pages 182-183, Section 4.13); Human Health and Safety (pages 183-184, Section 4.14). The Proposed Action would not result in any minor, moderate, or major contribution to cumulative impacts. Cumulative effects of the actions in the Proposed Action and other foreseeable actions have been evaluated throughout the EA. 8. The degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places (NRHP) or may cause loss or destruction of significant scientific, cultural, or historical resources. The project would comply with the Forest Service Region 3 Programmatic Agreement and would not have an adverse effect on cultural or historical resources. (Refer to page 309, Table H-1. Summary of Resources Considered for Analysis). 9. The degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973. The Proposed Action would result in minor adverse impacts to the MSO (pages 105-112, Section 3.7.4.2 Federally Listed Species within APS ROW-Birds); southwestern willow flycatcher (page 108-110, Section 3.7.4.2 Federally Listed Species within APS ROW-Birds); yellow-billed cuckoo (pages 110-112, Section 3.7.4.2 Federally Listed Species within APS ROW-Birds); narrow-headed gartersnake and northern Mexican gartersnake (pages 119-121, Section 3.7.4.6 Federally Listed Species within APS ROW-Reptiles). The Forest Service consulted with the U.S. Fish and Wildlife Service regarding the herbicide application and USFWS has provided a Draft Biological Opinion. Additional information on species impacts can be found in the 2018 BE, 2018 BA, and the conservation measures in Appendix E. 10. Whether the action threatens a violation of Federal, State, or local law or requirements imposed for the protection of the environment. Implementation of the Proposed Action does not violate any known federal, state, or local law or requirement imposed for the protection of the environment. This will be ensured by carrying out the selected actions in a way that is consistent with the standards and guidelines, management requirements, established design features, and biological conservation measures. The project meets the disclosure requirements of the National Environmental Policy Act. The application of herbicides would be conducted in accordance with the project labels, design features, and State requirements.

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Conclusion The environmental effects described in the EA and documentation included in the project record have been reviewed and considered. The responsible official (Thomas Torres, Tonto NF Deputy Forest Supervisor) has examined the context and intensity of impacts (40 CFR 1508.27) described above and determined that Alternative 2 (Proposed Action) will not have a significant effect on the quality of the human environment. As a result, no environmental impact statement will be prepared.

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CHAPTER 6. List of Preparers and Reviewers

6.1 List of Preparers and Reviewers The following individuals were involved in the preparation and/or review of this EA:

Name Role/Discipline Forest Service Regional Office Barrera, Bobbi Wildlife/Fish/Rare Plants Begay, Yolynda Tribal Relations Bogart, Candace GIS Fredrickson, Bjorn Wilderness Areas Jaramillo, Anna Watershed Kennedy, Kathryn Regional Botanist Paroz, Yvette Fisheries Program Manager Plunket, Steve Threatened and Endanger Species Upland Prewitt, Cheryl NEPA Reed, William Archaeology/Cultural and Heritage Resources Snow, Heather Special Uses Program Manager Taylor, Ernest Wildlife Wayne, Robbie Soils White, Allen Pesticides – Herbicides Ziehe, Gary Range Apache-Sitgreaves National Forests Chavez, Randall Herbicides/Visuals Coleman, Stephanie Aquatic Biologist DeRosier, Susanne Terrestrial Biologist Gilloon, Tim NEPA Hughes, Kendall Range Morgan, Esther Tribal Relations/Archaeology Richardson, Stephen GIS Rihs, Jon Watershed Roberts, Eric Soil Scientist Sorenson, Tina Realty Thatcher, Orry NEPA Coconino National Forest Adams, Judy Realty Camp, Julia Terrestrial Biologist Crisp, Deb Botanist Dechter, Mike NEPA Haines, Jeremy Archaeology Hase, Gary Range Johnson, Craig Tribal Relations MacDonald, Christopher (Kit) Soil Scientist MacDonald, Christopher (Kit) Herbicides

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Name Role/Discipline Runyon, Thomas Watershed Kaibab National Forest Christano, Mark GIS Farley, Sue NEPA/Visual Hangan, Margaret Archaeology Kiesow, Micah Soil Scientist Kline, Natasha Aquatic/Wildlife Biologist Lyndon, Mike Tribal Relations MacDonald, Christopher Watershed MacDonald, Christopher Herbicides Sevy, Leigh Botanist/Range Prescott National Forest Della Porta, Richard Realty Fletcher, Noel Wildlife Biologist Johnson, Susan West Zone Staff, Visual Kenton, Gabrielle NEPA McKie, James Archaeology/Tribal Relations Moore, David Soil Scientist Potter, Tom GIS Sillas, Albert Fisheries Biologist Yocum, Chad Hydrologist Tonto National Forest Bailey, David GIS Carrie Templin Public Affairs Enterprise Team Visual Hill, Kris Archaeology Holderman, Jill Wildlife Biologist Loomis, Grant Hydrologist/Soil Scientist McEntarffer, Mark Realty Mundy, Chandler Range Nez, Nanebah Tribal Relations Nicholas, Ryan Herbicides Thomas, Marianne NEPA Torres, Thomas Line Officer and Responsible Official APS Flynn, Conor Vegetation Management and Biology SME Moore, Tracy Herbicide and Vegetation SME Rable, Andrew APS Project Sponsor Watkins, Chris Cultural/Heritage/Tribal Relations Young, Lisa Biological Resources Project Manager Logan Simpson Baker, Roy GIS Bilthrop, David Casey Soil Scientist Bockey, Chris Visual/Fire and Fuel

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Name Role/Discipline Casteel, Victoria Water Resources/Technical Editor Hayes, Marshall NEPA/Project Administration Hedquist, Saul Tribal Relations Laurila, Erick Cultural/Heritage McCabe, Patricia NEPA Lead Simpson-Colebank, Diane NEPA Tackett, Ian Biological Resources - Wildlife/Vegetation/Noxious and Invasive Weeds/Threatened and Endanger Species Touchin, Jewel Tribal Relations

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192 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona CHAPTER 7. Glossary

Absorb(tion): The movement of a substance (e.g., a chemical) through a membrane into the body after exposure has occurred. Soil particles, dust, activated charcoal, or other substances often absorb chemicals. Active ingredient: The effective part of an herbicide/pesticide formulation that actually destroys the target vegetation or performs the desired functions, or the actual amount of a technical material present in the formulation. Adaptive management: A continuing process of action-based planning, monitoring, researching, evaluating, and adjusting with the objective of improving implementation and achieving the goals of the standards and guidelines (USDA, USDI 1994a). Additive effect: A situation in which the combined effects of exposure to two chemicals simultaneously is equal to the sum of the effect of exposure to each chemical given alone. The effect most commonly observed when an organism is exposed to two chemicals together is an additive effect. Adjuvant(s): A substance in an herbicide formulation, such as wetting agents, sticking agents, stabilizers, enhancers, or thickening agents, that are added to herbicide products or spray tank to enhance the herbicidal activity or application characteristics. Adsorption: The tendency of one chemical to adhere to another material such as soil. The assimilation of gas, vapor, or dissolved mater by the surface of a soil colloid or organic matter through an ionic bond. Adverse impact: Type of impact that would have a detrimental effect to a resource. Aerobic: Life or processes that require, or are not destroyed by, the presence of oxygen. Affected Environment: Existing biological, physical, social, and economic conditions of an area subject to change, both directly and indirectly, as the result of a proposed human action. Agent: Any substance, force, radiation, organism, or influence that affects the body. The effects may be beneficial or injurious. Alluvial: Relating to clay, silt, sand, gravel, or similar detrital material deposited by flowing water. Alluvial deposits may occur after a heavy rain storm. Annual: A plant which completes its entire life cycle from germinating seedling to seed production and death within a year. Aquifer: An underground geological formation or group of formations containing usable amounts of groundwater that can supply wells and springs. Area of Potential Effect: The geographic area or areas within which an undertaking may directly or indirectly cause changes in the character or use of historic properties, if any such properties exist. Arid: A terrestrial region lacking moisture, or a climate in which the rainfall is not sufficient to support the growth of most vegetation. Beneficial impact: Type of impact that would have a positive effect to a resource. Best management practices (BMP): A practice or combination of practices determined by a State or an agency to be the most effective and practical means (technological, economic, and institutional) of controlling point and non-point source pollutants at levels compatible with environmental quality. Biological Control: The use of nonnative agents including invertebrate parasites and predators (usually insects, mites, and nematodes), and plant pathogens to reduce populations of nonnative, invasive plants.

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Biologically sensitive: A term used to identify a group of individuals who, because of their developmental stage or some other biological condition, are more susceptible than the general population to a chemical or biological agent in the environment. Biota or Biome: All living organisms of a region or system. Broadcast application: In pesticides, to spread a chemical over a broad area. Candidate Species: Those plant and animal species that, in the opinion of the USFWS may qualify for listing as endangered or threatened. Carrier: a non-pesticidal substance added to a commercial pesticide formulation to make it easier to handle or apply. Chemical Control: The use of naturally derived or synthetic chemicals called herbicides to eliminate or control the growth of invasive plants. Chipping: Limbs and logs less than 9 inches in diameter would be chipped and broadcast on site with chips placed no deeper than 4 inches. Chronic exposure: Adverse effects occurring after exposure to a toxic agent for a long period (with animal testing, this is considered to be the majority of the animal’s life). These effects are considered to be permanent or irreversible. Chronic RfD: An estimate of a lifetime daily exposure level for the human population, including sensitive subpopulations, that is likely to be without an appreciable risk of deleterious effects. Chronic RfDs (reference doses) are specifically developed to be protective for long-term exposure to a compound (7 years to lifetime). Chronic toxicity: The ability of a substance or mixture of substances to cause harmful effects over an extended period, usually upon repeated or continuous exposure sometimes lasting for the entire life of the exposed organism. Code of Federal Regulations (CFR): Document that codifies all rules of the executive departments and agencies of the Federal government. It is divided into fifty volumes, known as titles. Title 40 of the CFR (referenced as 40 CFR) lists all environmental regulations, including regulations for EPA pesticide programs (40 CFR Parts 150-189). Colluvium: soil material or rock fragments moved downslope by gravitational forces. Compaction: the result of rolling, tamping, or use of heavy equipment on soil. Soils becomes hardened, difficult to cultivate, and impermeable to air and water. Contaminants: For chemicals, impurities present in a commercial grade chemical. For biological agents, other agents that may be present in a commercial product. Control: Means, as appropriate, eradicating, suppressing, reducing, or managing invasive species populations, preventing spread of invasive species from areas where they are present, and taking steps such as restoration of native species and habitats to reduce the effects of invasive species and to prevent further invasions (Executive Order 13112, 2/3/99). Corridor: a strip of land forming a passageway for transportation or utility facilities. Cultural Control: The establishment or maintenance of competitive vegetation, use of fertilizing, mulching, prescribed burning, or grazing animals to control or eliminate invasive plants. Cultural Resources: a general term frequently used to refer to a wide range of archeological sites, historic structures, museum objects, and traditional cultural places.

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Cumulative Effect: The impact on the environment that results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions—regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can result from individually minor, but collectively significant, actions taking place over a period of time (40 CFR 1508.7). Cumulative Exposures: Exposures resulting from one or more activities that are repeated over a period of time. Degradation: Physical or biological breakdown of a complex compound into simpler compounds. Diffusion: The movement of suspended or dissolved particles from a more concentrated to a less concentrated region as a result of the random movement of individual particles. The process tends to distribute the particles uniformly throughout the available volume. Direct impact: Impact that is caused by the action, same time and place. Distribution lines: Power lines that are lower in voltage and a generic term for a distribution voltage (2,400 volts to 35,000 volts) line that carries power from a substation to end users such as a residence or business. These lines may be overhead or underground and are part of a network that typically includes medium-voltage power lines, substations, pole-mounted transformers, low-voltage distribution wiring, and meters. Dose: The actual quantity of a chemical administered to an organism or to which it is exposed. Drift: That portion of a sprayed chemical that is moved by wind off a target site. Emergent: For purposes of this project, the term “emergent” is used to better describe ground conditions relative to where invasive plants are growing alongside a stream or other waterbody. Emergent vegetation is defined as plants that grow from below the water line to above the water line. Free floating vegetation is not considered emergent and will not be treated with herbicides under this project. Endangered Species: 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 USFWS or the NOAA Fisheries to be endangered or threatened with extinction in all or a significant portion of its range. Among other measures, ESA requires all Federal agencies to conserve these species and consult with the USFWS or NOAA Fisheries on Federal actions that may affect these species or their designated critical habitat. Endemic: “A species or other taxonomic group that is restricted to a particular geographic region due to factors such as isolation or response to soil or climatic conditions” (Allaby 1996). Compare to “Indigenous” and “Native”. Extirpate: To destroy completely; wipe out. Fauna: The wildlife or animals of a specified region or time. Federally Listed Species: Formally listed as a threatened or endangered species under the ESA. Designations are made by the USFWS or NMFS. FIFRA Pesticide Ingredient: An ingredient of a pesticide that must be registered with EPA under the Federal Insecticide, Fungicide, and Rodenticide Act. Products making pesticide claims must submit required information to EPA to register under FIFRA and may be subject to labeling and use requirements. Flora: Plant life, especially all the plants found in a particular country, region, or time regarded as a group. Also, a systematic set of descriptions of all the plants of a particular place or time.

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Floodplain: that portion of a river valley adjacent to the stream channel that is covered with water when the stream overflows its banks during flood stage. Food chain: a hierarchical sequence of organisms, each of which feeds on the next, lower member of the sequence. Forage: Food for animals. In this document, term applies to both availability of plant material for wildlife and domestic livestock. Forbs: A group of herbaceous (non-woody) plants, other than grasses, generally including wildflowers and many other plants, including those commonly referred to as weeds. Formulation: The form in which a pesticide is packaged or prepared for use. A chemical mixture that includes a certain percentage of active ingredient (technical chemical) with an inert carrier. Half-life or halftime: The length of time required for the mass, concentration, or activity of a chemical or physical agent to be reduced by one-half. For example if the half-life of a chemical is 10 days, half the product would be broken down 10 days after application; after 10 more days, half of that half of the product is broken down, etc. Hardpan: A hardened layer of soil occurring at or below the surface which impairs drainage and plant growth. Hazard analysis: Involves gathering and evaluating data on the types of injury or disease that may be produced by a substance and on the conditions of exposure under which injury or disease occurred. Hazard identification: The process of identifying the array of potential effects that an agent may induce in an exposed of humans or other organisms. Hazardous vegetation: A tree, vegetation, or portion of tree or vegetation (e.g. limb) that could come into contact with a power line, structure, or equipment and cause electrical fault. Vegetation can be considered hazardous if it exhibits a structural defect (see Structural Defect definition) that increases the chances of it failing and contacting electric utility infrastructure. Healthy vegetation may also be considered a hazard if it has encroached close enough to an electric power line that it could result in electrical fault (ANSI 2012). Hazard vegetation can be categorized as an Imminent Hazard or Off-Cycle Hazard (see Imminent Hazard and Off-Cycle Hazard definitions). Herbaceous: A plant that does not develop persistent woody tissue above the ground (annual, biennial, or perennial). Herbaceous vegetation includes grasses and grass-like vegetation, and broadleaved forbs. Herbicide: A chemical preparation designed to regulate the growth of or kills specific weeds or undesirable plants. Hypersensitivity: A state of extreme sensitivity to an action of a chemical; a state of altered reactivity in which the body reacts with an exaggerated immune response to a foreign substance. Impact Assessment: Impacts are defined by type, duration, intensity, Duration is considered either: . Direct: caused by the action, same time and place. . Indirect: caused by the action, but later in time or further in distance, but are still reasonably foreseeable. For the purposes of this analysis, duration of the impact is defined as follows: . Short-term: impacts that would be less than 10 years in duration. . Long-term: impacts that would be 10 years or greater in duration. For the purposes of this analysis, intensity or severity of the impact is defined as follows: . Negligible: changes would not be detectable and/or measureable. The resource would be essentially unchanged or unaltered.

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. Minor: changes would be detectable, localized, and/or measurable. The resource would be slightly changed or altered. . Moderate: changes would be clearly detectable, measurable, and/or have an appreciable effect on the resource. The resource would be notably changed or altered. . Major: changes would be readily detectable, and/or have a severe effect on the resource. The resource would be substantially changed or altered. For the purposes of the type of impact is defined as follows: . Adverse: impacts that would have a detrimental effect to a resource. . Beneficial: impacts that would have a positive effect to a resource. Context is the setting within which an impact is analyzed: . Local: within and immediately adjacent to the project area/ROW. . Regional: remaining area outside of the ROW but within the five forests. Incompatible vegetation: Defined in this EA as plants under, above, and near power lines that could disrupt the safe, reliable, and continuous delivery of electricity to APS’s customers. Indirect impact: Impact that is caused by the action, but later in time or further in distance, but is still reasonably foreseeable. Inert ingredients: All ingredients in a formulated pesticide product that are not classified as active ingredients. Infested Area: A contiguous area of land occupied by a single invasive plant species. An infested area of land is defined by drawing a line around the actual perimeter of the infestation as defined by the canopy cover of the plants, excluding areas not infested. Generally, the smallest area of infestation mapped will be 1/10th (0.10) of an acre or 0.04 hectares (Natural Resource Information System Standards). Inhalation: The movement of a chemical from the breathing zone, through lung tissues, and into the blood system. Intake: Amount of material inhaled, absorbed through the skin, or ingested during a specified period of time. Integrated Vegetation Management (IVM): a strategy to control unwanted vegetation by considering the use of all suitable control methods within the context of the whole environment (ecosystem). An array of control methods is used, and methods are chosen based on the vegetation needing control and the environmental conditions present. The goal is to have the most benign overall long-term effect on the ecosystem. Introduced Species: An alien or exotic species that has been intentionally or unintentionally 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 also “Noxious Weed” and “Exotic.” Introduction: “The intentional or unintentional escape, release, dissemination, or placement of a species into an ecosystem as a result of human activity” (Executive Order 13112, 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 13112, 2/3/99). Irreversible effect: Effect characterized by the inability of the body to partially or fully repair injury caused by a toxic agent.

197 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Irritant: Non-corrosive material that causes a reversible inflammatory effect on living tissue by chemical action at the site of contact as a function of concentration or duration of exposure. Label: All printed material attached to or part of the pesticide container. LC50 (Median Lethal Concentration or lethal concentration50): A calculated concentration of a chemical in air or water to which exposure for a specific length of time is expected to cause death in 50 percent of a defined experimental animal population. Used in aquatic toxicity and inhalation studies. LD50 (Median Lethal Dose or lethal dose50): The dose of a chemical calculated to cause death in 50 percent of a defined experimental animal population over a specified observation period. The observation period is typically 14 days. Leaching: the process by which chemicals on or in soil or other porous media are dissolved and carried away by water, or are moved into a lower layer of soil. Level of Concern (LOC): The concentration in media or some other estimate of exposure above which there may be effects. Local impact: Context of the impact is within and/or immediately adjacent to the project area/ROW. Long-term impact: Impact that would be 10 years or greater in duration. Lop and scatter: Limbs and logs of less than 9 inches in diameter would be lopped and scattered throughout the immediate area in a manner such that limbs and logs would be left no taller than 18 to 24 inches above the ground. Logs over 9 inches diameter would remain where felled and would be cut in sections to lay flush with the ground. Lowest-observed-adverse-effect level (LOAEL): The lowest dose of a chemical in a study, or group of studies, that produces statistically or biologically significant increases in frequency or severity of adverse effects between the exposed and control populations. Low-growing plant communities: a dense population of relatively short plants (e.g., grasses, shrubs, forbs, herbs) that can “outcompete” trees and tall-growing brush for sunlight and nutrients, thereby reducing the presence of trees. Low-growing plants shade the ground and absorb available moisture, making it harder for the trees to germinate underneath the shrubs or to grow up through the low-growing plant cover. This is essentially vegetation “self management.” Major impact: Intensity or severity of the changes caused by the impact would be readily detectable, and/or have a severe effect on the resource. The resource would be substantially changed or altered. Manage Known Sites: To maintain the habitat elements needed to provide for persistence of the Survey and Manage species at the site. ‘Manage’ may range from maintaining one or more habitat components such as down logs or canopy cover, up to complete exclusion from disturbance for many acres, and may permit loss of some individuals, area, or elements not affecting continued site occupancy. Manual Control: The use of any non-mechanized approach to control or eliminate invasive plants (i.e., hand-pulling). Margin of safety (MOS): A separation between the highest no-effect level of a chemical found by animal experimentation and the level of exposure estimated to be safe for humans. It is derived by reducing the NOEL by 100 times, which is considered to be a low risk. Mechanical Control: The use of any mechanized approach to control or eliminate incompatible vegetation (i.e., mowing, excavating, weed whacking, tractors). Metabolite: A compound formed as a result of the metabolism or biochemical change of another compound.

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Microorganisms: A generic term for all organisms consisting only of a single cell, such as bacteria, viruses, protozoans and some fungi. Minimal: very small in amount or degree. Also refers to definition of minimal risk level in the R6 2005 FEIS, which is defined as “an exposure level that is not likely to be associated with adverse effects in the general population, including sensitive subgroups.” Minor impact: Intensity or severity of the changes caused by the impact would be detectable, localized, and/or measurable. The resource would be slightly changed or altered. Mitigation: steps taken to lessen the effects predicted for each resource as potentially caused by a vegetation management program. They may include reducing the impact, avoiding it completely, or compensating for the impact. Moderate impact: Intensity or severity of the changes caused by the impact would be clearly detectable, measurable, and/or have an appreciable effect on the resource. The resource would be notably changed or altered. Mollusks: Invertebrate animals (such as slugs, snails, clams, or squids) that have a soft unsegmented body usually enclosed in a calcareous shell; representatives found on National Forest System land include snails, slugs, and clams. Morbidity: Rate of disease, injury or illness. National Environmental Policy Act (NEPA): An Act passed in 1969 to declare a National policy that encourages productive and enjoyable harmony between humankind and the environment, promotes efforts that prevent or eliminate damage to the environment and biosphere, stimulates the health and welfare of humanity, enriches the understanding of the ecological systems and natural resources important to the nation, and establishes a Council on Environmental Quality (USDA, USDI 1994a). National Forest Management Act (NFMA): A law passed in 1976 as an amendment to the Forest and Rangeland Renewable Resources Planning Act, requiring preparation of Forest Plans and the preparation of regulations to guide that development (USDA, USDI 1994a). National Marine Fisheries Service (NMFS): The Federal agency that is the listing authority for marine mammals and anadromous fish under the ESA. National Pollutant Discharge Elimination System (NPDES): As authorized by the Clean Water Act, the NPDES permit program controls water pollution by regulating point sources that discharge pollutants into waters of the United States. An NPDES permit is required for herbicide use into water or adjacent conveyances with a hydrologic surface connection to water at the time of application. Native plant/Native species: species of plants, animals, or birds that originated in a given ecological area. Native plants or species are often best adapted to a given area. Natural community: An assemblage of organisms indigenous to an area that is characterized by distinct combinations of species occupying common ecological zones and interacting with one another. Negligible impact: Intensity or severity of the changes caused by the impact would not be detectable and/or measureable. The resource would be essentially unchanged or unaltered. Nesting Cover: An assemblage of vegetation exhibiting a specific growth form to allow nesting activities associated with wildlife reproduction. Neurotoxicity: Exerting a destructive or poisonous effect on nerve tissue. Non-native Species: species that have migrated or been imported into an ecological area. Non-native plants or species may compete for space and nutrients with a (more desirable) native species.

199 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Non-target: Any plant or animal that is not the intended organism to be controlled by an herbicide/pesticide treatment. Noxious Weed: A noxious weed is a plant species listed in State laws or regulations or specifically listed by a Federal agency. Organic matter: Decomposed plant and animal material. On any soil, the amount of organic matter is critical to maintaining soil structure and function, allowing water and air to infiltrate to low depths, and providing a source of energy to microbial communities. It increases water capacity and nutrient supply, as well as provides positive benefits to soil structure and limits erosion by increasing water capacity. Pathogen: A living organism, typically a bacteria or virus that causes adverse effects in another organism. Perennial: A plant species having a life span of more than 2 years. Persistence: Refers to the length of time a compound, once introduced into the environment, stays there. Personal Protective Equipment (PPE): Clothing and equipment worn by pesticide mixers, loaders and applicators and re-entry workers, hazmat emergency responders, workers cleaning up Superfund sites, etc., which is worn to reduce their exposure to potentially hazardous chemicals and other pollutants. Pest: An insect, rodent, nematode, fungus, weed or other form of terrestrial or aquatic plant or animal life that is classified as undesirable because it is injurious to health or the environment. Pesticide: Any substance used for controlling, preventing, destroying, repelling, or mitigating any pest. Includes fungicides, herbicides, fumigants, insecticides, nematicides, rodenticides, desiccants, defoliants, plant growth regulators, and so forth. pH: The negative log of the hydrogen ion concentration. A high pH (>7) is alkaline or basic and a low pH (<7) is acidic. Plant community: An association of plants or various species found growing together in different areas with similar site characteristics. Population - “A group of individuals of the same species in an area” (Wilson and Hipkins, 1999). Proposed species: Any plant or animal species that is proposed by the USFWS or NOAA Fisheries in a Federal Register notice to be listed as threatened or endangered. Potential Vegetation Type (PVT): The term PVT is used to represent the combination of species that could occupy the site in the absence of disturbance. Pruning: the removal of selected branches from tree trunks, without felling the whole tree. Reference Dose (RfD): The term preferred by the EPA to express acceptable daily intake (ADI). The RfD is a numerical estimate of a daily exposure to the human population, including sensitive subgroups such as children, that is not likely to cause harmful effects during a lifetime. RfDs are generally used for health effects that are thought to have a threshold or minimum dose for producing effects. Regional impact: Context of the impact is in the remaining area outside of the ROW but within the five forests. Registered herbicide: All pesticides sold or distributed in the United States must be registered by the EPA, based on scientific studies, showing that they can be used without posing unreasonable risks to people or the environment. Registration: Formal licensing with EPA of a new pesticide before it can be sold or distributed. Under the Federal Insecticide, Fungicide, and Rodenticide Act, EPA is responsible for registration (pre-market

200 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona licensing) of pesticides on the basis of data demonstrating no unreasonable adverse effects on human health or the environment when applied according to approved label directions. Resprouting: the sending out of new, often multiple, branches from the cut surface of the stump of a tree or bush. Restoration: “[Ecological restoration] is the process of assisting the recovery and management of ecological integrity. Ecological integrity includes a critical range of variability in biodiversity, ecological processes and structures, regional and historical context, and sustainable cultural practices” (Society of Ecological Restoration, 2000). Revegetation: “The re-establishment of plants on a site (does not imply native or nonnative; does not imply that the site can ever support any other types of plants or species and is not at all concerned with how the site ‘functions’ as an ecosystem)” (Northern Region Native Plant Handbook, 1995). Right-of-way: The term ROW in this document refers to an area that is permitted to APS for the purpose of operating and maintaining electrical power line infrastructure through a Special Use Permit. Riparian: of, or pertaining to, the bank of a river, stream, lake, or other watercourses. Often applied to the characteristic water-loving vegetation of such an area. Risk: the chance of an adverse or undesirable effect. Route of exposure: An avenue by which a chemical comes in contact with an organism, including inhalation, ingestion, and dermal contact. Runoff: The movement of water across the soil surface until it reaches a defined natural stream channel. Safety: Practical certainty that a substance will not cause injury under carefully defined circumstances of use. Safety data sheet (SDS): A compilation of information required under the Occupational Health and Safety Administration Communication Standard on the identity of hazardous chemicals, health and physical hazards, exposure limits, and precautions. Saturated zone: a subsurface area in which all pores and cracks are filled with water under pressure equal to or greater than that of the atmosphere. Scoping: an early opportunity for the public to tell a Federal agency what issues they think are important and should be considered in the environmental analysis of a proposed Federal action. Sensitive species: Species identified by the Regional Forester for which population variability is a concern, as evidenced by significant current or predicted downward trend in population numbers or density; or significant current or predicted downward trends in habitat capability that would reduce a species existing distribution (FSM 2670). Short-term impact: Impact that would be less than 10 years in duration. Slash: The residue left on the ground after felling, includes unused logs, uprooted stumps and broken tops. Snag: A dead or dying tree that is still standing. Solvent: A liquid capable of dissolving another substance. Many solvents are organic, or carbon-based; many of these are volatile, flammable, and toxic. Examples of organic solvents include acetone, trichloroethylene (TCE), ethanol, isopropanol, and benzene. Water is a nonorganic solvent. Species: “A group of organisms all of which have a high degree of physical and genetic similarity, generally interbreed only among themselves, and show persistent differences from members of allied groups of organisms” (Executive Order 13112, 2/3/99).

201 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

Standards and guidelines: The rules and limits governing actions, as well as the principles specifying the environmental conditions or levels to be achieved and maintained (USDA, USDI 1994a). Substrate: With reference to enzymes, the chemical that the enzyme acts upon. Succession: The progressive development of trees or other plants towards their highest role in their ecology; their climax. An example would be the replacement of shrubs and grasses by a forest. Successional plant communities: Successional plant communities refers to vigorously growing grasses, forbs, shrubs, and trees. Examples of early successional habitats include weedy areas, grasslands, old fields or pastures, shrub thickets, and young forest. Successional advanced plant communities: Successional advanced plant communities refers to communities in which composition has changed over time resulting in established vegetation. Surface water: All water naturally open to the atmosphere (rivers, lakes, reservoirs, streams, impoundments, seas, estuaries, etc.) and all springs, wells, or other collectors which are directly influenced by surface water. Surfactants are commonly used in herbicide formulations to ensure even distribution and improve absorption or permeation of the herbicide into the plant. A surface active agent; usually an organic compound whose molecules contain a hydrophilic group at one end and a lipophilic group at the other. Promotes solubility of a chemical, or lathering, or reduces surface tension of a solution.Surfactants play a key role in the effectiveness of an herbicide formulation. There is limited information on the types of surfactants used and the toxicity of surfactants, especially since the industry considers these formulations to be proprietary information. Synthetic: Made by humans. Take: To kill or capture a species covered by the ESA. Threatened species: Plant or animal species likely to become endangered throughout all or a significant portion of its range within the foreseeable future. A plant or animal identified and defined in accordance with the 1973 Endangered Species Act and published in the Federal Register (USDA, USDI 1994a). Threshold Level: The maximum dose or concentration level of a chemical or biological agent that will not cause an effect in the organism. Tolerances: Permissible residue levels for pesticides in raw agricultural produce and processed foods. Whenever a pesticide is registered for use on a food or a feed crop, a tolerance (or exemption from the tolerance requirement) must be established. EPA establishes the tolerance levels, which are enforced by the Food and Drug Administration and the Department of Agriculture. Toxicity: The inherent ability of an agent to affect living organisms adversely. As defined by EPA, toxicity is “...the degree to which a substance or mixture of substances can harm humans or animals. Traditional use plants: native plants associated with traditional cultural practices including sustenance, ceremony, medicine, tools, garments, or other uses. Transmission lines: Power lines that are high-voltage lines that carry electricity over long distances, such as from a power plant to a city, or from a substation to a city. They are generally high voltage and are placed on physically tall structures. A transmission line is a bare uninsulated high-voltage (69,000 volts to 500,000 volts) overhead line, usually strung from steel towers or tall wood poles. The Arizona Public Service Company also uses steel mono poles along with steel lattice towers and wood poles.

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Treated area: An infested area where weeds have been treated or retreated by an acceptable method for the specific objective of controlling their spread or reducing their density (Natural Resource Information System Standards). Turbidity: The extent to which a body of water is muddy or cloudy with particles of sediment stirred up or suspended in it. U.S. Fish and Wildlife Service (USFWS): The Federal agency that is the listing authority for species other than marine mammals and anadromous fish under the ESA. Viability: Ability of a wildlife or plant population to maintain sufficient size to persist over time in spite of normal fluctuations in numbers, usually expressed as a probability of maintaining a specific population for a specified period (USDA, USDI 1994a). Volatilization: To evaporate or cause to evaporate. Waterbody: All perennial, intermittent and ephemeral streams, wetlands, and springs. Water-soluble: Dissolves in water. Weed: “A plant growing where man does not want it to grow” (Daubenmire 1978). Well distributed: Distribution sufficient to permit normal biological function and species interactions, considering life history characteristics of the species and the habitats for which it is specifically adapted. Wetlands: An area that is regularly saturated by surface or ground water and subsequently is characterized by a prevalence of vegetation that is adapted for life in saturated soil conditions. Wilderness: Areas designated by Congressional action under the 1964 Wilderness Act. Wilderness is defined as undeveloped Federal land retaining its primeval character and influence without permanent improvements or human habitation. Wilderness areas are protected and managed to preserve their natural conditions, which generally appear to have been affected primarily by the forces of nature with the imprint of human activity substantially unnoticeable; have outstanding opportunities for solitude or for a primitive and confined type of recreation; include at least 5,000 acres or are of sufficient size to make practical their preservation, enjoyment, and use in an unimpaired condition; and may contain features of scientific, educational, scenic, or historical value as well as ecological and geologic interest.

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204 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona CHAPTER 8. References

Agyagos, Janie. 2016. Wildlife Biologist, Red Rock Ranger District, Coconino National Forest. Personal Communication, December 6, 2016.

Alley et al. 1999. Alley, W.M., T.E. Reilly, and O.L. Franke. 1999. Sustainability of Ground-water Resources. U.S. Geological Survey Circular 1186. Available at http://water.usgs.gov/pubs/circ/circ1186/index.html

American National Standards Institute (ANSI). 2006. American National Standard for Tree Care Operations — Tree, Shrub, and Other Woody Plant Maintenance — Standard Practices (Integrated Vegetation Management a. Utility Rights-of-way). ANSI A300, Part 7. International Society of Arboriculture, Champagne, Illinois.

American National Standard Institute (ANSI). 2011. ANSI A300 for Tree Care Operations Part 9 – Tree, Shrub, and Other Woody Plant Management – Standard Practices (Tree Risk Assessment a. Tree Structure Assessment).

American Southwest with comments on conservation. Copeia, 2000(1), pp. 251-256.

Arb Access LTD. 2015. Tree Pruning. Available at http://www.arbaccess.co.uk/tree-pruning/. Accessed May 30, 2017.

Arizona Cooperative. 2017. Yavapai County Native & Naturalized Plants. Available at https://cals.arizona.edu/yavapaiplants/

Arizona Department of Agriculture. 2017. Noxious Weeds Regulated and Restricted Noxious Weeds (R3- 4-244). Web interface. Available at https://agriculture.az.gov/pests-pest-control/agriculture- pests/noxious-weeds. Accessed August 17, 2017.

Arizona Department of Environmental Quality (ADEQ). 2016. 2012/14 Status of Water Quality Arizona’s Integrated 305(b) Assessment and 303(d) Listing Report. Electronic document, Available at http://legacy.azdeq.gov/environ/water/assessment/download/appc.pdf. Accessed June 28, 2016.

Arizona Department of Transportation (ADOT). 2014. Biological Assessment of ADOT Herbicide Treatment Program on Bureau of Land Management Lands in Arizona. NEPA No. DOI-BLM-AZ- 0000-2013-0001-EA. Submittal 4. December 24.

____. 2018. Project Managers Report, Project Resource Offices - List of Projects. July 2018. https://apps.azdot.gov/pro/PMmain.asp.

Arizona Department of Water Resources (ADWR). 2010. Arizona Water Atlas, September 2010.

____. 2011. Water Resources Development Commission Environmental Working Group Arizona’s Inventory of Water-Dependent Natural Resources. Water Resources Development Commission Final Report: Volume II Committee Reports.

____. 2016. http://www.azwater.gov/azdwr/gis/. Groundwater Subbasins.

Arizona Game and Fish Department (AGFD). 1995. Meda fulgida. Unpublished abstract compiled and edited by the Heritage Data Management System, Arizona game and Fish Department, Phoenix, Arizona.

205 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

____. 1997. Ripley wild buckwheat (Eriogonum ripleyi). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 1999. Arizona Partners in Flight Bird Conservation Plan. Technical Report 142. June 1999, 342 pp., Arizona Game and Fish Department, Phoenix.

____. 2000a. Cochise sedge (Carex ultra). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2000b. Pima Indian mallow (Abutilon parishii). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2001a. Burrowing Owl (Athene cunicularia hypugaea). Unpublished abstract compiled and edited by the Heritage Data Management System, 7 pp., Arizona Game and Fish Department, Phoenix.

____. 2001b. Gray catbird (Dumetella carolinensis). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2001c. Little Colorado Sucker (Catostomus sp.3). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2001d. Allen’s lappet-browed bat (Idionycteris phyllotis). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2001e. Fish creek fleabane (Erigeron piscaticus). Unpublished abstract compiled and edited by the Heritage Data Management System, 5 pp., Arizona Game and Fish Department, Phoenix.

____. 2002a. Northern leopard frog (Lithobates pipiens). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2002b. American peregrine falcon (Falco peregrinus anatum). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2002c. Desert sucker (Catostomus clarkii). Unpublished abstract compiled and edited by the Heritage Data Management System, 5 pp., Arizona Game and Fish Department, Phoenix.

____. 2002d. Sonora sucker (Catostomus insignis). Unpublished abstract compiled and edited by the Heritage Data Management System, 5 pp., Arizona Game and Fish Department, Phoenix.

____. 2002e. Springerville silky pocket mouse (Perognathus flavus goodpasteri). Unpublished abstract compiled and edited by the Heritage Data Management System, 5 pp., Arizona Game and Fish Department, Phoenix.

____. 2002f. Blumer’s dock (Rumex orthoneurus). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2002g. Galiuro sage (Salvia amissa). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2002h. Mearns sage (Salvia dorrii ssp. mearnsii). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

206 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

____. 2002i. Arizona willow (Salix arizonica). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2003a. Balmorhea saddle-case caddisfly (Protoptila balmorhea). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2003b. Brown springsnail (Pyrgulopsis sola). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2003c. Fossil springsnail (Pyrgulopsis simplex). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2003d. Verde River springsnail (Pyrgulopsis glandulosa). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2003e. Pale Townsend’s big eared bat (Corynorhinus townsendii pallescens). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2003f. Spotted bat (Euderma maculatum). Unpublished abstract compiled and edited by the Heritage Data Management System, 9 pp., Arizona Game and Fish Department, Phoenix.

____. 2003g. Flagstaff beardtongue (Penstemon nudifloris). Unpublished abstract compiled and edited by the Heritage Data Management System, 3 pp., Arizona Game and Fish Department, Phoenix.

____. 2003h. Flagstaff pennyroyal (Hedeoma diffusa). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2003i. Hohokam agave (Agave murpheyi). Unpublished abstract compiled and edited by the Heritage Data Management System, 7 pp., Arizona Game and Fish Department, Phoenix.

____. 2003j. Hualapai milkwort (Polygala rusbyi). Unpublished abstract compiled and edited by the Heritage Data Management System, 3 pp., Arizona Game and Fish Department, Phoenix.

____. 2003k. Mogollon fleabane (Erigeron anchana). Unpublished abstract compiled and edited by the Heritage Data Management System, 5 pp., Arizona Game and Fish Department, Phoenix.

____. 2003l. Rock fleabane (Erigeron saxatilis). Unpublished abstract compiled and edited by the Heritage Data Management System, 5 pp., Arizona Game and Fish Department, Phoenix.

____. 2003m. Sunset crater beardtongue (Penstemon clutei). Unpublished abstract compiled and edited by the Heritage Data Management System, 5 pp., Arizona Game and Fish Department, Phoenix.

____. 2003n. Tonto basin agave (Agave delamateri). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2003o. Navajo Mogollon Vole (Microtus mogollonensis navaho). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2003p. Bezy’s night lizard (Xantusia bezyi). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

207 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

____. 2004a. Toumey groundsel (Senecio neomexicanus var. toumeyi). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2004b. Alcove bog orchid (Platanthera zothecina). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2004c. Aravaipa woodfern (Thelypteris puberula var. sonorensis). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2004d. Arizona alum root (Heuchera glomerulata). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2004e. Fish creek rockdaisy (Perityle saxicola). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2004f. Mt. Dellenbaugh sandwort (Arenaria aberrans). Unpublished abstract compiled and edited by the Heritage Data Management System, 3 pp., Arizona Game and Fish Department, Phoenix.

____. 2004g. Parish’s alkali grass (Puccinellia parishii). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2004h. Chihuahuan sedge (Carex chihuahuensis). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2005a. Arizona phlox (Phlox amabilis). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2005b. Arizona sneezeweed (Helenium arizonicum). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2005c. Broadleaf lupine (Lupinus latifolius spp. leucanthus). Unpublished abstract compiled and edited by the Heritage Data Management System, 5 pp., Arizona Game and Fish Department, Phoenix.

____. 2005d. Eastwood alum root (Heuchera eastwoodiae). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2005e. Grand Canyon rose (Rosa stellate spp. abyssa). Unpublished abstract compiled and edited by the Heritage Data Management System, 5 pp., Arizona Game and Fish Department, Phoenix.

____. 2005f. Heathleaf wild buckwheat (Eriogonum ericifolium var. ericifolium). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2005g. Mapleleaf false snapdragon (Mabrya acerifolia). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2005h. Mogollon thistle (Cirsium parryi ssp. mogollonicum). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

208 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

____. 2005i. Tusayan rabbitbrush (). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2005j. Common black hawk (Buteogallus anthracinus). Unpublished abstract compiled and edited by the Heritage Data Management System, 7 pp., Arizona Game and Fish Department, Phoenix.

____. 2006a. Lowland leopard frog (Lithobates yavapaiensis). Unpublished abstract compiled and edited by the Heritage Data Management System, 10 pp., Arizona Game and Fish Department, Phoenix.

____. 2006b. Greene milkweed (Asclepias uncialis greene). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2006c. Conservation assessment and strategy for the bald eagle in Arizona. Nongame and Endangered Wildlife Program Technical Report 173. Arizona Game and Fish Department, Phoenix.

____. 2011a. Bald eagle (Haliaeetus leucocephalus). Unpublished abstract compiled and edited by the Heritage Data Management System, 9 pp., Arizona Game and Fish Department, Phoenix.

____. 2011b. Western red bat (Lasiurus blossevillii). Unpublished abstract compiled and edited by the Heritage Data Management System, 7 pp., Arizona Game and Fish Department, Phoenix.

____. 2012a. Arizona bugbane (Cimicifuga arizonica). Unpublished abstract compiled and edited by the Heritage Data Management System, 5pp., Arizona Game and Fish Department, Phoenix.

____. 2012b. Desert Tortoise (Gopherus agassizii). Unpublished abstract compiled and edited by the Heritage Data Management System, 11 pp., Arizona Game and Fish Department, Phoenix.

____. 2013a. Arizona Bird Conservation Initiative: Important Bird Areas (IBAs). Available at azgfd.gov. Accessed November 16, 2016.

____. 2013b. Northern goshawk (Accipiter gentilis). Unpublished abstract compiled and edited by the Heritage Data Management System, 8 pp., Arizona Game and Fish Department, Phoenix.

____. 2013c. Arizona sunflower (Helianthus arizonensis). Unpublished abstract compiled and edited by the Heritage Data Management System, 3 pp., Arizona Game and Fish Department, Phoenix.

____. 2013d. Baird’s sparrow (Ammodramus bairdii). Unpublished abstract compiled and edited by the Heritage Data Management System, 6 pp., Arizona Game and Fish Department, Phoenix.

____. 2014a. Page Springs Agave (Agave yavapaiensis). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2014b. Sacred Mountain agave (Agave verdensis). Unpublished abstract compiled and edited by the Heritage Data Management System, 5 pp., Arizona Game and Fish Department, Phoenix.

____. 2015a. Page springsnail (Pyrgulopsis morrisoni). Unpublished abstract compiled and edited by the Heritage Data Management System, 7 pp., Arizona Game and Fish Department, Phoenix.

____. 2015b. Sonoran desert tortoise (Gopherus morafkai). Unpublished abstract compiled and edited by the Heritage Data Management System, 10 pp., Arizona Game and Fish Department, Phoenix.

____. 2015c. Ertter’s Rose (Rosa woodsia var. ertterae). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

209 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

____. 2015d. Lyngholm’s brakefern (Pellaea lyngholmii). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2015e. Verde breadroot (Pediomelum verdiensis). Unpublished abstract compiled and edited by the Heritage Data Management System, 4 pp., Arizona Game and Fish Department, Phoenix.

____. 2016a. Arizona Bat Information. Arizona Game and Fish Department. Available at http://www.azgfd.gov/w_c/bat_conserv_az_bats.shtml. Accessed October 20, 2016.

____. 2016b. Arizona Game and Fish Department. Arizona Bald Eagle Management Program. Available at https://www.azgfd.com/wildlife/speciesofgreatestconservneed/baldeagles/. Accessed November 1, 2016.

____. 2016c. Heritage Data Management System. Dataset provided January 20, 2016.

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____. 1985. Tonto National Forest Plan. U.S. Department of Agriculture Forest Service. Southwestern Region, Albuquerque, New Mexico. Available at http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3795286.pdf.

____. 1990. Policy of Noxious Weed Management. Departmental Regulation No. 9500-10. Available at https://www.fsa.usda.gov/Assets/USDA-FSA-Public/usdafiles/Environ-Cultural/dr9500-010.pdf. Accessed November 22, 2016.

____. 1994, Neotropical Migratory Bird Reference Book. USDA Forest Service, Pacific Southwest Region.

____. 1999a. Forest Service Handbook (FSH) 2509.18 – Soil Management Handbook. Region 3 Supplement No. 2509.18-99-1

____. 1999b. Little Colorado Spinedace

____. 2003a. Environmental Assessment for Management of Noxious Weeds and Hazardous Vegetation on Public Roads on National Forest System Lands in Arizona. Southwest Region. Albuquerque, New Mexico. Mexico. Available at http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/20 fsbdev3_020955.pdf. Accessed November 22, 2016.

____. 2003b. Decision memo for noxious weeds prescribed burn along Highway 188. Tonto Basin Ranger District, Tonto National Forest.

____. 2004a. Healthy Forests Restoration Act of 2003: Summary of Implementation Actions. Available at https://www.forestsandrangelands.gov/ resources/overview/hfra-implementation12-2004.shtml. Accessed November 7, 2016.

____. 2004b. Forest Service Manual 2100 – Environmental Management; Chapter 2150 – Pesticide-Use Management and Coordination. Supplement No.: 2100-2004-1. U.S. Department of Agriculture Forest Service Southwestern Region (Region 3), Albuquerque, New Mexico. Available at https://www.fs.fed.us/cgi-bin/Directives/get_dirs/fsm?2100.

____. 2004c. Biological Assessment and Evaluation for Environmental Assessment for Management of Noxious Weeds and Hazardous Vegetation on Public Roadways on National Forest Service System Lands in Arizona. U.S. Department of Agriculture Forest Service. https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_021389.pdf. Accessed November 7, 2016.

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____. 2005a. Final Environmental Impact Statement for Integrated Treatment of Noxious or Invasive Weeds: Coconino, Kaibab, and Prescott National Forests within Coconino, Gila, Mohave, and Yavapai counties, Arizona. Southwest Region. Albuquerque, New Mexico. Available at http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download. akamai.com/11558/www/nepa/30_FSPLT1_013753.pdf. Accessed November 22, 2016.

____. 2005b. FSM 2066 – Wildlife, Fish and Sensitive Plant Habitat Management. Chapter 2670 – Threatened, Endangered and Sensitive Plants and Animals. Available at http://bit.ly/2fwO0DQ. Accessed November 7, 2016.

____. 2005c. Forest Service Manual 2600 – Wildlife, Fish and Sensitive Plant Habitat Management. Chapter 2670 – Threatened, Endangered and Sensitive Plants and Animals. Amendment No. 2600- 2005-1. U.S. Department of Agriculture Forest Service National Headquarters, Washington, DC. Available at https://www.fs.fed.us/cgi-bin/Directives/get_dirs/fsm?2600. Accessed November 7, 2016.

____. 2006. Forest Service National Desk Guide to Preparing Vegetation Management Procedures for Power Line Authorizations. December 20, 2013. – page 12

____. 2007. Final Environmental Impact Statement for Integrated Treatment of Noxious or Invasive Weeds, Coconino, Kaibab, and Prescott National Forests within Coconino, Gila, Mojave, and Yavapai Counties, Arizona (USDA Forest Service SW Region 2005) Post-Decisional (Section18) Review. Review of Aminopyralid.

____. 2008a. Environmental Analysis for the Implementation of the Apache-Sitgreaves National Forests Integrated Forest-Wide Noxious or Invasive Weed Management Program. U.S. Department of Agriculture Forest Service Apache-Sitgreaves National Forests. Springerville, Arizona.

____. 2008b. Decision Notice and Finding of No Significant Impact: Environmental Assessment for the Apache-Sitgreaves National Forests Integrated Forest-Wide Noxious or Invasive Weed Management Program. 268 pp.

____. 2008c. Memorandum of Understanding between the U.S. Department of Agriculture Forest Service and the U.S. Fish and Wildlife Service to Promote the Conservation of Migratory Birds. Forest Service Agreement No. 08-MU-1113-2400-264.

____. 2008d. Decision Notice and Finding of No Significant Impact Jack Smith/Schultz Fuels Reduction and Forest Health Project. U.S. Department of Agriculture Forest Service, Peaks and Mormon Lake Ranger District, Coconino National Forest Coconino County, Arizona. August 2008.

____. 2009. Forest Service Manual 2080 – Noxious Weed Management. Supplement No.: 2000-2009-1. U.S. Department of Agriculture Forest Service Southwestern Region (Region 3), Albuquerque, New Mexico. Available at https://www.fs.fed.us/cgi-bin/Directives/get_dirs/fsm?2000.

____. 2010a. Southwestern Region Climate Change Trends and Forest Planning – A Guide for Addressing Climate Change in Forest Plan Revisions for Southwestern National Forests and National Grasslands.

____. 2010b. Forest Service Manual 2000 – National Forest Resource Management, Chapter 2020 – Ecological Restoration and Resilience. Interim Directive No.: 2020-2010-1. U.S. Department of Agriculture Forest Service National Headquarters, Washington, DC. Available at https://www.fs.fed.us/cgi-bin/Directives/get_dirs/fsm?2000.

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____. 2011a. National Forest Draft Migratory Bird Report. Prescott, AZ: Prescott National Forest.

____. 2011b. Forest Service Manual 2900 Invasive Species Management. Forest Service National Headquarters, Washington, DC.

____.2011c. Triclopyr Human Health and Ecological Risk Assessment final report. USDA Forest Service.

____. 2011d. Forest Service Manual 2900 Invasive Species Management. Amendment No.: 2900-2011-1. U.S. Department of Agriculture Forest Service National Headquarters, Washington, DC. Available at https://www.fs.fed.us/cgi-bin/Directives/get_dirs/fsm?2900.

____. 2011e. Haigler Fuels Analysis Project Scoping Letter. U.S. Department of Agriculture Forest Service, Tonto National Forest, Pleasant Valley Ranger District. March 2011. https://www.fs.usda.gov/project/?project=34507.

____. 2011f. Final Environmental Impact Statement Travel Management on the Coconino National Forest. U.S. Department of Agriculture Forest Service, Coconino National Forest. MB-R3-04-12. September 2011.

____. 2011g. Final Environmental Impact Statement Travel Management on the Coconino National Forest. U.S. Department of Agriculture Forest Service, Coconino National Forest. MB-R3-04-12. September 2011.

____. 2012a. Environmental Assessment for Integrated Treatment of Noxious or Invasive Plants, Tonto National Forest: Gila, Maricopa, Pinal, and Yavapai Counties, Arizona. U.S. Department of Agriculture. Southwestern Region, Albuquerque, New Mexico. Available at http://a123.g.akamai.net/ 7/123 /115 5 8 /abc123/forestservic.download.akamai.com/11558/www/nepa/4482_FSPLT2_284237.pdf. Accessed November 22, 2016.

____. 2012b. Forest Health Technology Enterprise Team. Aminocyclopyrachlor Human Health and Ecological Risk Assessment Final Report SERA TR-056-01-03a. September 27, 2012.

____. 2012c. National Best Management Practices for Water Quality Management on National Forest System Lands. Volume 1. National Core BMP Technical Guide. FS-990A. April 2012.

____. 2012d. Forest Service Handbook 1909.15 National Environmental Policy Act Handbook, Chapter 10 Environmental Analysis. Amendment No.: 1909.15-2012-3. U.S. Department of Agriculture Forest Service National Headquarters (WO), Washington, DC. Available at https://www.fs.fed.us/cgi-bin/Directives/get_dirs/fsh?1909.15.

____. 2012e. Turkey Butte - Barney Pasture Forest Health Restoration Project Proposed Action. U.S. Department of Agriculture Forest Service, Coconino National Forest, Flagstaff Ranger District. April 2012.

____. 2012f. Environmental Assessment for the Kelly Motorized Trail Project, Coconino National Forest. U.S. Department of Agriculture Forest Service, Southwestern Region. September 2012.

____. 2013a. Forest Service National Desk Guide to Preparing Vegetation Management Procedures for Power Line Authorizations. December 20, 2013.

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____. 2013b. Invasive Plants and Weeds of the National Forests and Grasslands in the Southwestern Region. Second Edition. Available at https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3802006.pdf

____. 2013c. Management Indicator Species Status Report for the Coconino National Forest. Version 2. Coconino National Forest, Flagstaff, AZ. January 28, 2013.

____. 2013d. Southwestern Region. Draft Land and Resource Management Plan for the Coconino National Forest. Coconino, Gila, and Yavapai Counties, Arizona. MB-R3-04-20. October 2013.

____. 2013e. Regional Forester’s Sensitive Species: Plants – 2013. U.S. Department of Agriculture Forest Service Southwestern Region. Available at http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_021246.pdf.

____. 2013f. Pesticide-Use Management and Coordination. Forest Service Manual 2150. National Headquarters, Washington, D.C.

____. 2013g. Forest Service Manual 2100 – Environmental Management; Chapter 2150 – Pesticide-Use Management and Coordination. Amendment No.: 2100-2013-1. U.S. Department of Agriculture Forest Service National Headquarters, Washington, D.C. Available at https://www.fs.fed.us/cgi- bin/Directives/get_dirs/fsm?2100.

____. 2014a. Guidance for Invasive Species Management in the Southwestern Region. Available at https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd488913.pdf

____. 2014b. Final Environmental Impact Statement for Integrated Treatment of Noxious or Invasive Weeds, Coconino, Kaibab, and Prescott National Forests within Coconino, Gila, Mojave, and Yavapai Counties, Arizona (USDA Forest Service SW Region 2005) Post-Decisional (Section18) Review. Review of Aminocyclopyrachlor.

____. 2014c. Land and Resource Management Plan for the Kaibab National Forest. Coconino, Yavapai, and Mojave Counties, Arizona.

____. 2014d. Final Biological Evaluation: Travel Management Plan for Tonto National Forest. 412 pp., Available at www.fs.fed.us/database/feis/plants. Accessed March 15, 2015.

____. 2015a. Land Management Plan for the Apache-Sitgreaves National Forests. Apache, Coconino, Greenlee, and Navajo Counties, Arizona. MB-R3-01-10. August 2015. Slightly revised October 2016.

____. 2015b. Land Management Plan for the Apache-Sitgreaves National Forests. Apache, Coconino, Greenlee, and Navajo Counties, Arizona. MB-R3-01-10. August 2015. Slightly revised October 2016.

____. 2015c. Pesticides. Available at https://www.fs.fed.us/research/invasive- species/control/pesticides.php

____. 2015d. Land and Resource Management Plan for the Prescott National Forest. Yavapai and Coconino Counties, Arizona.

____. 2015e. Bebb’s willow (Salix bebbiana) Unpublished species abstract. Available at www.fs.fed.us/database/feis/plants/tree. Accessed March 15, 2015.

____. 2015f. Final Environmental Impact Statement for the Four-Forest Restoration Initiative with Errata and Objection Resolution Modifications. U.S. Department of Agriculture Forest Service, Coconino and Kaibab National Forests, Coconino County, Arizona. April 2015.

216 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

____. 2016a. Ecological Response Unit and Subclass. Natural Resource Information System. GIS Data from U.S. Department of Agriculture Forest Service Southwestern Region

____. 2016b. Draft Management Indicator Species Status Report for Tonto National Forest.

____. 2016c. Northern goshawk (Accipiter gentilis) Unpublished species abstract. Available at http://www.fs.fed.us/database/feis/animals/bird/acge/all.html. Accessed October 28, 2016

____. 2016d. Southwestern Region Geodatabase Schema, S_USA.TESP_OccurrenceAll.

____. 2016e. Southwestern Region Geodatabase Schema, Potential habitat_EIS species.

____. 2016f. Travel Management on the Tonto National Forest. Final Environmental Impact Statement, Volume 1. June 2016. Available at http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/nepa/5 9232_FSPLT3_3086270.pdf

____. 2016g. Forest Service Handbook 2109.14 Pesticide-Use Management and Coordination Handbook, Chapter 10 Planning. Amendment No.: 2109.14-2016-3. U.S. Department of Agriculture Forest Service National Headquarters (WO), Washington, DC. Available at https://www.fs.fed.us/cgi- bin/Directives/get_dirs/fsh?2109.14.

____. 2016h. Forest Service Region 3 GIS. Data request from SRP to Forest Service Region 3 Information Received.

____. 2016i. Pinto Valley Mine Plan of Operations. U.S. Department of Agriculture Forest Service, Tonto National Forest, Globe Ranger District. May 2016. https://data.ecosystem- management.org/nepaweb/nepa_project_exp.php?project=33272.

____. 2016j. Travel Management on the Tonto National Forest Final Environmental Impact Statement. U.S. Department of Agriculture Forest Service, Tonto National Forest. June 2016.

____. 2016k. Tonto National Forest; Pinal County, AZ; Resolution Copper Project and Land Exchange Environmental Impact Statement. U.S. Department of Agriculture Forest Service, Tonto National Forest. Federal Register Vol. 81, No. 53/Friday, March 18, 2016. https://www.fs.usda.gov/project/?project=48956.

____. 2016l. Decision Memo Fossil Creek Interim Management. U.S. Department of Agriculture Forest Service Red Rock Ranger District, Coconino National Forest Payson Ranger District, Tonto National Forest Coconino and Gila County, Arizona. February 2016.

____. 2016m. Rock Pits Environmental Assessment. U.S. Department of Agriculture Forest Service, Coconino and Kaibab National Forests. June 2016.

____. 2017a. Rangeland Management Reports. Available at https://www.fs.fed.us/rangeland- management/reports/index.shtml

____. 2017b. APS Corridor Management Plan, Vegetation Management, SE-14 Distribution Line: Coconino National Forest, Red Rock Ranger District. Version 2 dated January 10, 2017.

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____. 2002b. Colorado pikeminnow (Ptychocheilus lucius) Recovery Goals: amendment and supplement to the Colorado Squawfish Recovery Plan. Denver, CO.

____. 2002c. Razorback sucker (Xyrauchen texanus) Recovery Goals: amendment and supplement to the Razorback Sucker Recovery Plan. Denver, CO.

____. 2004a. Migratory Bird Treaty Reform Act of 2004. Pub. L. No. 108-447, 118 Stat. 2809, 3071-72.

____. 2004b. Endangered and Threatened Wildlife and Plants: Final Designation of Critical Habitat for the Mexican Spotted Owl, Final Rule. Federal Register 69(168): 53182-53298.

____. 2005. Endangered and threatened wildlife and plants: Listing the Gila chub as endangered with critical habitat; Final Rule. Federal Register, 70(211), 66664-66721.

____. 2006. Endangered and Threatened Wildlife and Plants; 12-Month Finding on a Petitition to List a Distinct Population Segment of the Roundtail Chub in the Lower Colorado River Basin and To List the Headwater Chub as Endangered or Threatened with Critical Habitat. Federal Register 71(85): 26007-26017.

____. 2007a. National Bald Eagle Management Guidelines. 25 pp., U.S. Fish and Wildlife Service. Division of Migratory Bird Management.

——. 2008. Birds of Conservation Concern 2008. Division of Migratory Bird Management, Arlington, Virginia. 85 pp.

____. 2010a. Ocelot (Leopardus pardalis) Recovery Plan; Draft First Revision. Albuquerque, NM. 185 pp.

____. 2010b. U.S. Fish and Wildlife Service 5-Year Review of the Desert Pupfish (Cyprinodon macularius). Phoenix, AZ. 43 pp.

____. 2011. Chiricahua leopard frog (Lithobates chiricahuensis). 5-Year Review: Summary and Evaluation edited by the Arizona Ecological Services Field Office, 39 pp., U.S. Fish and Wildlife Service.

____. 2012a. Desert tortoise (Gopherus agassizii). Unpublished abstract compiled and edited by the Arizona Ecological Services Field Office, 1 pp., U.S. Fish and Wildlife Service.

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____. 2012b. Biological Assessment/Evaluation of the Integrated Treatment of Noxious or Invasive Plant Program for the Tonto National Forest. U.S. Forest Service Southwestern Region, Tonto National Forest, AZ. 94 pp.

____. 2012c. Final Recovery Plan for Mexican Spotted Owl (Strix ocidentalis lucida), First Revision. Albuquerque, New Mexico. 414 pp.

____. 2012d. Endangered and Threatened Wildlife and Plants; Endangered Status and Designations of Critical Habitat for Spikedace and Loach Minnow. Federal Register 77(36): 10810–10932. Available at http://www.fws.gov/southwest/es/arizona/Loach.htm

____. 2012e. Tonto National Forest Land and Resource Management Plan Biological/Conference Opinion. Consultation Number 2012-F-0011. April 30, 2012.

____. 2013a. Arizona Cliffrose (Purshia subintegra) 5-Year Review: Summary and Evaluation. Phoenix, AZ. 29 pp. Available at https://www.fws.gov/southwest/es/arizona/Documents/SpeciesDocs/AZ_Cliffrose/AzCliffrose_5- YrReview_Aug2013.pdf.

____. 2013b. Final Biological Opinion for the Phase II Maintenance Activities. Reference Number AESO/SE 22410-2006-F-0365-R1. June 11, 2013.

____. 2013c. Mexican Spotted Owl (Strix occidentalis lucida). 5-Year Review Short Form Summary. Available at https://www.fws.gov/southwest/es/arizona/Documents/SpeciesDocs/MSO/MexicanSpottedOwl_5- yrReview_Aug2013.pdf.

____. 2013d. Final Biological and Conference Opinion for the Rosemont Copper Mine, Pima County, Arizona. U.S. Fish and Wildlife Service, Phoenix, AZ. 506 pp.

____. 2014a. Chiricahua Leopard Frog – Recovery Program. Available at https://www.fws.gov/southwest/es/arizona/CLF_Recovery_Home.htm.

____. 2014b. Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for the Western Distinct Population Segment of the Yellow-Billed Cuckoo; Proposed Rule. Federal Register 79(158): 48548-48652.

____. 2014c. Endangered and Threatened Wildlife and Plants; Threatened Status for the Northern Mexican Gartersnake and Narrow-Headed Gartersnake: Final Rule. Federal Register 79(130): 38678- 38746.

____. 2014d. News Release: Once Thought Locally Extinct, Endangered Razorback Suckers Discovered Spawning in Grand Canyon National Park. Available at http://www.fws.gov/southwest/es/arizona/Razorback.htm

____. 2015a. Endangered and Threatened Wildlife and Plants; Endangered Status for the Mexican Wolf. Federal Register 80(11): 2488-2512.

____. 2015b. Candidate Notice of Review. 50 CFR Part 17. Federal Register Vol. 80, No. 247. 32 pp. Published December 24.

____. 2015c. Endangered and Threatened Wildlife and Plants; Threatened Species Status for the Headwater Chub and a Distinct Population Segment of the Roundtail Chub. Federal Register 80(194): 60754-60783.

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____. 2015d. Endangered and Threatened Wildlife and Plants; Revision to the Regulations for the Nonessential Experimental Population of the Mexican Wolf; Final Rule. Federal Register 80(11): 2512-2568.

____. 2016a. Environmental Conservation Online System (ECOS). Available at https://ecos.fws.gov/ecp0/reports/delisting-report. Accessed November 9, 2016.

____. 2016b. Biological Opinion for the Tonto National Forest Travel Management Rule. Reference number AESO/SE 02EAAZ00-2014-F-0463.March 1, 2016.

____. 2016c. Species account for Desert sucker (Catostomus clarkii). Available at https://www.fws.gov/endangered/what-we-do/cnor.html. Accessed October 20, 2016.

____. 2016d. Species account for Arizona bugbane (Cimicifuga arizonica). Available at https://www.fws.gov/southwest/es/arizona/Documents/Redbook/Arizona%20Bugbane%20RB.pdf. Accessed November 2, 2016.

____. 2016e. Candidate Conservation Agreements. Available at https://www.fws.gov/endangered/what- we-do/cca.html. Accessed November 9, 2016.

____. 2016f. Species account for Goodding’s onion (Allium gooddingii). Available at https://www.fws.gov/southwest/es/arizona/Documents/Redbook/Goodding%27s%20Onion%20RB.p df. Accessed November 9, 2016.

____. 2016g. Species account for Arizona willow (Salix arizonica). Available at https://www.fws.gov/southwest/es/Arizona/Documents/Redbook/Arizona%20Willow%20RB.pdf. Accessed November 9, 2016.

U.S. Geological Survey (USGS). 1995. Groundwater Atlas of the United States: Segment 2 Arizona, Colorado, New Mexico, Utah. Reston, Virginia 1995.

____. 2011. National Hydrography Dataset. Available at http://nhd.usgs.gov/.

____. 2016a. Standards for National Hydrography Dataset: Reston, Virginia, U.S. Geological Survey. Hydrologic Unit Code. Available at http://nhd.usgs.gov/. Accessed April 22, 2016.

____. 2016b. Standards for National Hydrography Dataset: Reston, Virginia, U.S. Geological Survey. NHDFlowline. Available at http://nhd.usgs.gov/. Accessed April 22, 2016.

____. 2016c. Standards for National Hydrography Dataset: Reston, Virginia, U.S. Geological Survey. NHDWaterbody. Available at http://nhd.usgs.gov/. Accessed April 22, 2016.

U.S. President. 2014. Memorandum. “Creating a Federal Strategy to Promote the Health of Honey Bees and Other pollinators” Federal Register Volume 79, Number 121 (June 20, 2014): 35903-35907. Creating a Federal Strategy to Promote the Health of Honey Bees and Other pollinators. Available at https://www.gpo.gov/fdsys/pkg/FR-2014-06-24/pdf/2014-14946.pdf.

Vahle, R. J. and D. R. Patton. 1983. Red squirrel cover requirements in Arizona mixed conifer forests. Journal of Forestry Vol. 81(1): 14-15, 22.

Vincill, W.K. 2002. Herbicide Handbook, Eight Edition. Weed Science Society of America, Lawrence, Kansas.

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Voeltz, J.B. 2002. Roundtail Chub (Gila robusta) status survey of the Lower Colorado River Basin. AGFD Nongame and Endangered Wildlife Program Technical Report #186, Arizona Game and Fish Department. Phoenix, AZ. pp. 221.

Voorhees, R, Deputy State Epidemiologist. 1999. Results of analyses of multiple chemical sensitivities questions, 1997 Behavioral Risk factor Surveillance System, New Mexico Department of Health, February 8.

Waldrum Specialties. 2002. Thinvert: General Information. Available at http://www.waldrumspecialties.com/thinvert/index.html. Waldrum Specialties, Inc. Published March 16, 2002.

____. 2002. Thinvert: Deposition Aid: ThinVert Concentrate. Available at http://www.waldrumspecialties.com/thinvert/DEP-conc.html.

____. 2002. Thinvert: Deposition Aid: ThinVert Ready to Use. Available at http://www.waldrumspecialties.com/thinvert/DEP-rtu.html.

Wahlberg, M.M., F.J. Triepke, W.A. Robbie, S.H. Strenger, D. Vandendriesche, E.H. Muldavin, and J.R Malusa. 2013. Ecological Response Units of the Southwestern United States. U.S. Department of Agriculture Forest Service Forestry Report FR-R3-XX-XX. Southwestern Region, Regional Office, Albuquerque, NM. 201 pp.

Warren, S.D. Role of Biological Soil Crusts In Desert Hydrology and Geomorphology: Implications for Military Training Operations. The Geological Society of America Reviews in Engineering Geology XXII. p. 177–186. U.S. Forest Service, Rocky Mountain Research Station, Shrub Sciences Laboratory, Provo, Utah 84606-1856. 2014.

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Wildland Fire Leadership Council (WFLC). 2014. The Final Phase in the Development of the National Cohesive Wildland Fire Management Strategy. Washington, DC.

Water Resources Development Commission. 2011. Final Report Volume II Committee Reports. October 1, 2011.

Wright, A.H. and A.A. Wright. 1949. Handbook of frogs and toads of the United States and Canada. Comstock Publishing Associates. Ithaca, New York. pp. 366-368.

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This document proposes the use of pesticides. Pesticides used improperly can be injurious to man, animals, and plants. Follow the directions and heed all precautions on the labels. Store pesticides in original containers under lock and key--out of the reach of children and animals--and away from food and feed. Apply pesticides so they do not endanger humans, livestock, crops, beneficial insects, fish, and wildlife. Do not apply pesticides when there is danger of drift, when honeybees or other pollinators are visiting plants, or in ways that may contaminate water or leave illegal residues. Avoid prolonged inhalation of pesticide sprays or dusts; wear protective clothing and equipment if specified on the label. If your hands become contaminated with a pesticide, do not eat or drink until you have washed. In case a pesticide is swallowed or gets in the eyes, follow the first aid treatment given on the label, and get prompt medical attention. If a pesticide is spilled on your skin or clothing, remove clothing immediately and wash skin thoroughly.

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Appendix A. Conformance with National Forest Land and Resource Management Plans

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Conformance with National Forest Land and Resource Management Plans Each national forest manages public land through land and resource management plans, as required by the Federal Land Policy and Management Act. These plans outline management direction, including desired future conditions, suitable uses, monitoring requirements, goals and objectives, and standards and guidelines. The proposed action is in conformance with the following land use plans:

Land Management Plan for the Apache-Sitgreaves National Forests (August 2015)  Guidelines for Soil (Page 21): “Projects with ground-disturbing activities should be designed to minimize long and short term impacts to soil resources. Where disturbance cannot be avoided, project specific soil and water conservation practices should be developed.”  Guidelines for Water Resources (Page 23): “Projects with ground-disturbing activities should be designed to minimize long and short term impacts to water resources. Where disturbance cannot be avoided, project specific soil and water conservation practices and best management practices (BMPs) should be developed.”  Desired Conditions for All PNVTs [Potential Natural Vegetation Types] (Page 28) Landscape Scale Desired Conditions (10,000 acres or greater): “Natural processes and human and natural disturbances (e.g., wildland fire, mechanical vegetation treatments) provide desired overall tree density, structure, species composition, coarse woody debris, and nutrient cycling. Natural fire regimes are restored. Uncharacteristic fire behavior is minimal or absent on the landscape.” “Native plant communities dominate the landscape.”  Standards for All PNVTs (Page 30): “Vegetation treatments shall include measures to reduce the potential for introduction of invasive plants and animals and damage from nonnative insects and diseases.”  Guidelines for All PNVTs (Page 30): “During project design and implementation, precautions should be taken to reduce the potential for damage to residual vegetation in order to prevent premature or excessive mortality.” “Insect and disease infected trees should be removed to prevent spread beyond endemic levels.”  Invasive Species (Page 65): “Management of invasive species is an increasing need across all PNVTs on the Apache- Sitgreaves NFs. There is an array of tools (chemical, biological, mechanical, and cultural) to help managers control or eradicate these species. To address terrestrial invasive plants, managers have implemented an integrated forestwide noxious or invasive weed management program. Even though complete eradication of invasive species is not always possible, aggressive treatment of existing populations, along with prevention of new infestations or populations, is important to protect native ecosystem diversity.”

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 Guidelines for Invasive Species (Page 66): “Treatment of invasive species should be designed to effectively control or eliminate them; multiple treatments may be needed.”  Desired Conditions for Wildland Fire Management (Page 107): “Human life, property, and natural and cultural resource are protected within and adjacent to NFS lands.”  Desired Conditions for Energy Corridor (Page 116): “Energy corridors serve a public benefit by providing for a reliable supply of energy essential to local, regional, and national economies.” “Vegetative conditions and land uses within the energy corridor facilitate the operation and maintenance of the associated facilities and infrastructure.” “Vegetation consists predominantly of grasses, forbs, shrubs, low-growing trees, and sapling- sized trees.”  Guidelines for Energy Corridor (Page 116): “Energy corridors should be managed as nonmotorized areas to avoid conflicts with corridor operations and maintenance needs, although operations and maintenance activities may use motorized equipment.”  Guidelines for Energy Corridor (Page 117): “Within and adjacent to energy corridors, vegetation should be managed similarly to the Community-Forest Intermix Management Area so that facilities stay operational and reduce the hazards of human-caused damage, damage from wildland fire, and falling trees.” “Clearing of vegetation along rights-of-way, facilities, and permitted sites should be limited to that which achieves desired conditions, abates an identified hazard to the facility, or for operational efficiency and weed control.” “Invasive plant species should be aggressively controlled within energy corridors to prevent or minimize spread.”  Management Approaches for Energy Corridor (Page 117): “Existing energy corridors are managed according to approved management plans. Energy utility companies also comply with maintenance standards enforced by the North American Electric Reliability Corporation. Energy corridors are generally not managed to provide recreation opportunities. They are managed for very low scenic integrity where vegetation and structural changes may attract attention and dominate the landscape when viewed from nearby.”  Management Approaches: Invasive Species (Page 293): “Use an array of tools (chemical, biological, mechanical, and cultural) to control or eradicate invasive species.”

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Coconino National Forest Plan (August 1987); a revised Forest Plan is anticipated to be released in 2018  Ground-Disturbing Activities (Page 51-2): “Any management activity planned near or within a known cave area is examined for its potential impacts to caves and karst features. This includes activities which might increase sedimentation, sterilize soil, change a cave's natural hydrology or water quality, add nutrients or other chemicals (including pesticides, herbicides and fertilizers), or modify the cave. Cave entrances and karst features are also not used as disposal sites for slash, waste rock or fill materials, and other refuse.”  Water Resource Inventory (Page 73): “Inspect areas proposed to be treated with chemical agents such as pesticides and herbicides to ensure that surface or ground water contamination does not occur.”  Special-Use Management (Page 177): “New special-uses are normally not allowed in riparian areas unless they benefit riparian management. Exceptions which cannot be avoided, such as utility lines or roads crossing stream courses, are designed to minimize the amount of riparian affected and the degree of effects.”

Land and Resource Management Plan for the Kaibab National Forest (February 2014)  Desired Conditions for Soils (Page 44): “Soils provide for diverse native plant species. Vegetative ground cover is well distributed across the soil surface to promote nutrient cycling and water infiltration.” “Soils are free from anthropogenic contaminants that could alter ecosystem integrity or affect public health.”  Desired Conditions for Watersheds (Page 44): “Vegetation conditions within watersheds contribute to downstream water quality and quantity. Surface runoff, sheet, rill, and gully erosion, and subsequent sedimentation into connecting waters downstream is minimal.” “Water quality meets or surpasses State of Arizona or Environmental Protection Agency water quality standards for designated uses. Water quality meets critical needs of aquatic species.”  Guidelines for Soils and Watershed Management (Page 44): “Projects should incorporate the national best management practices for water quality management and include design features to protect and improve watershed condition. “In disturbed areas, erosion control measures should be implemented to improve soil conditions.”  Management Approach for Soils and Watersheds (Page 45): “Watershed protection was one of the primary reasons for establishing the national forests. Forested lands absorb precipitation, refill regional underground aquifers, sustain watershed stability and resilience, and provide aquatic and wildlife habitat. On the Kaibab NF, the highest risk to watersheds is uncharacteristic wildfire. Projects that reduce this risk and

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restore the natural vegetative and fuels composition also restore watersheds. As a result, the Kaibab NF uses an integrated management approach to make progress toward the soil and watershed desired conditions. Objectives to address these needs are found in the “Major Vegetation Community Types,” “Nonnative Invasive Species,” and “Natural Waters” sections of this plan. With these and other activities, the Kaibab NF generally employs best management practices before, during, and after activities to reduce or eliminate adverse effects.”  Guidelines for Wildlife (Page 49): “Project activities and special uses should be designed and implemented to maintain refugia and critical life cycle needs of wildlife, particularly for raptors.”  Desired Conditions for Threatened, Endangered, and Sensitive Species (page 51): “Threatened, endangered, and sensitive species have quality habitat, stable or increasing populations, and are at low risk for extirpation.”  Guidelines for Threatened, Endangered, and Sensitive Species (Page 51): “Project activities and special uses occurring within federally listed species habitat should integrate habitat management objectives and species protection measures from approved recovery plans.” “Project activities and special uses should be designed and implemented to maintain refugia and critical life cycle needs of Forest Service Sensitive Species.”  Desired Conditions for Rare and Narrow Endemic Species (Page 52): “Habitat and refugia are present for narrow endemics or species with restricted distributions and/or declining populations.”  Guidelines for Rare and Narrow Endemic Species (Page 52): “Project design should incorporate measures to protect and provide for rare and narrow endemic species where they are likely to occur.”  Guidelines for Nonnative Invasive Species (Page 53): “All ground-disturbing projects should assess the risk of noxious weed invasion and incorporate measures to minimize the potential for the spread of noxious and invasive species. New populations should be detected early, monitored, and treated as soon as possible.” “Treatment approaches should use integrated pest management (IPM) practices to treat noxious and nonnative invasive species. IPM includes manual, biological, mechanical, and herbicide/pesticide treatments.” “Use of pesticides, herbicides, and biocontrol agents should minimize impacts on non-target flora and fauna.”  Desired Conditions for Recreations and Scenery (Page 63): “Recreation settings retain high to moderate scenic quality. Some human influenced elements in the background are present.”  Guidelines for Transportation (Page 77): “Motorized uses in semiprimitive nonmotorized areas should be restricted, except for necessary minimal administrative activities, permitted activities, and emergency access.

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 Desired Conditions for Energy Transmission and Development (Page 81): “Energy transmission and development on the Kaibab NF meets the legal mandates to facilitate the transmission and development of energy resources in a manner that minimizes adverse impacts and does not detract from meeting other desired conditions applicable to the area.” “Energy corridors provide a reliable supply of energy essential to meet local, regional, and national economic demands.” “Vegetative conditions and land uses within energy rights-of-way facilitate the operation and maintenance of the associated facilities and infrastructure. They may differ from the surrounding PNVT desired conditions in that they generally consist of low growing or non- woody vegetation.” “Wildland fires do not interrupt the delivery of energy resources within the rights-of-way.”  Appendix A. Proposed and Possible Actions; Wildlife and Plants (Page 168): “Treat weeds using an integrated pest management approach, which includes chemical, biological, and physical methods, on 2,000 to 3,000 acres annually.”

Land and Resource Management Plan for the Prescott National Forest (2015)  Lands and Special Uses: Guide-Lands-5 (Page 88): “Overhead utilities should have approved corridor management plans or operating plans in place prior to all vegetation treatments. Guide-Lands-4 (Page 87): “Vegetation clearing should be limited to defensible space within: (a) the communication sites; (b) fuel breaks around the perimeter of the sites; and (c) areas that pose a hazard to facilities and operational efficiency.” Guide-Lands-5 (Page 88): “Low growing plant communities that do not interfere with overhead lines, should be maintained within power line corridors.”  Desired Conditions for All Vegetation (Page 24): Fine Scale (less than 10 acres) “Locally endemic plant communities are intact and functioning. Unique plant community habitats (e.g., limestone cliffs, margins of seeps and springs, Verde Valley Formation, basalt-lava flows/cinders, calcareous soil/alkaline clay, canyons/cliffs and ledges, granitic soils/igneous rocks, sandstone rocks/soils and riparian forest) are present to maintain well distributed populations of associated native plant species. Native plants provide nectar, floral diversity, and pollen throughout the seasons that pollinator species are active. Desired habitat conditions promote pollinator success and survival. Species identified as culturally important are valued and, therefore, enhanced and protected.”

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 Vegetation (Page 74): Guide-Veg-2: “Applicable design features in appendix B—Design Features, Best Management Practices, Required Protection Measures and Mitigation Measures—from the “Final Environmental Impact Statement for Integrated Treatment of Noxious or Invasive Weeds” (Forest Service, 2005a) or more current direction—should be followed in treating nonnative invasive plant species and for managing site disturbing projects and maintenance.”  Lands and Species Uses (Page 87): “Vegetation clearing should be limited to defensible space within: (a) the communication sites; (b) fuel breaks around the perimeter of the sites; and (c) areas that pose a hazard to facilities and operational efficiency.” “Visual resource objectives should be maintained by using design standards that make towers unobtrusive and by using nonreflective surface materials and colors which blend in with the surroundings.” “Low growing plant communities that do not interfere with overhead lines, should be maintained within power line corridors.” “Overhead utilities should have approved corridor management plans or operating plans in place prior to all vegetation treatments.”

Tonto National Forest Plan (October 1985)  Introduction (Page 4): “Coordination with land and resource planning efforts of other Federal agencies, State, and local governments, Indian tribes, and adjacent private landowners.”  Wildlife Habitat (Page 11): “Wildlife habitat diversity will be increased through coordinated management activities and direct habitat improvement projects.”  Soil, Water and Air Quality (Page 19): “Meet minimum air and water quality standards, emphasize improvement of soil productivity, air & water quality, augment water supplies when compatible with other resources, and enhance riparian ecosystems.”  Amendment No. 25, 8/2006 Replacement; Wildland/Urban Interface (Page 20): “Wildland Fires in the Interface pose an immediate threat to life, property, and adjacent resources. Actively participate with all interested and potentially affected parties to develop strategic Interface management measures to reduce Wildland Fire threats to life, property and resources, address issues of Forest health, and provide for community partnerships including treatments of vegetation and fuels, and access needs. Wildland Fires threatening the Wildland/Urban Interface will have high suppression priority.”  Decision Unit – 34; Activities D03, E045, E05, P34, P35 (Page 43): “Pesticide proposals will be handled through additional environmental analysis and documentation to ensure project objectivity and public safety.”

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 Decision Unit – 34; Activities F01, Management Prescriptions (Page 44): “Minimize impacts on soil and water resources from all ground disturbing activities.”  Amendment No. 22, 6/5/1996; Decision Unit – 17, 18; Activities – D03; Applicable Analysis Area – 5300, 5301 (Replacement Page 69): “Use of approved herbicides on a selective basis where brush encroachment is clearly inhibiting forage production for wildlife and domestic livestock. Possible treatment areas will be identified in Allotment Management Plans and will involve areas of limited size and extent where other management practices (i.e. prescribed burning) cannot be effectively or economically utilized to achieve management objectives. Projects of this nature will be subject to environmental assessment and public involvement to insure project objectivity and public safety.”

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Appendix B. Documents Incorporated by Reference or Used for Tiering

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Relation to Other Documents Regulations implementing NEPA provide for the reduction of bulk and redundancy (40 CFR 1502.21) through incorporation by reference and tiering when the effect will be to reduce the size of documents without impeding agency and public review of the action. The following documents are either incorporated by reference or used to tier from and form the basis for the conclusions related to human health and effects to non-target species: . Biological Assessment and Evaluation for Environmental Assessment for Management of Noxious Weeds and Hazardous Vegetation on Public Roadways on National Forest Service System Lands in Arizona (McDonald 2004) . Environmental Analysis for the Implementation of the Apache-Sitgreaves National Forests Integrated Forest-wide Noxious or Invasive Weed Management Program (Forest Service 2008a) . Environmental Assessment for Integrated Treatment of Noxious or Invasive Plants, Tonto National Forest (Forest Service 2012a) . Final Programmatic Environmental Impact Statement for Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron on Bureau of Land Management Lands in 17 Western States (BLM 2016) . Recommended Protection Measures for Pesticide Applications in Region 2 of the U.S. Fish and Wildlife Service (White 2007) . Risk Assessments for 2,4-D, Aminocyclopyrachlor, Aminopyralid, Chlorsulfuron, Clopyralid, Dicamba, Fluroxypyr, Glyphosate, Imazapic, Imazapyr, Isoxaben, Metsulfuron methyl, Picloram, Sulfometuron methyl, Tebuthiuron, and Triclopyr (Forest Service 2018c) . Preparation of Environmental Documentation and Risk Assessments for the USDA/Forest Service (Durkin 2014) . Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western States Programmatic Environmental Impact Statement (BLM 2007) . Final Environmental Impact Statement for the Integrated Treatment of Noxious Invasive Weeds on the Coconino, Kaibab, and Prescott National Forests (Forest Service 2005a) . Record of Decision Final Environmental Impact Statement for Integrated Treatment of Noxious or Invasive Weeds (Coconino, Kaibab, and Prescott National Forests) (Forest Service 2005a) . Decision Notice and Finding of No Significant Impact Environment Assessment for Integrated Treatment of Noxious or Invasive Weeds, US Forest Service, Tonto National Forest (Forest Service 2012a) . Environmental Assessment for Management of Noxious Weeds and Hazardous Vegetation on Public Roads on National Forest System Lands in Arizona (Forest Service 2003a) . Maintenance in APS and SRP Power Line Rights-of-Way on Arizona Forests Working Draft Biological Assessment for Threatened and Endangered Species (Forest Service 2018a)

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Appendix C. Applicable Federal Laws, Regulations, and Policies

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Applicable Federal Laws, Regulations, and Policies Title V of The Federal Land Policy and Management Act and its implementing regulations found at 36 CFR 251.51 Subpart B provide the legal framework within which the Forest Service manages public lands and assesses the effects of its management actions. Review and authorization for the use of herbicides is also subject to requirements for consistency and conformance with a number of other applicable Federal laws, regulations, and policies. The following table summarizes most of the other Federal laws, regulations, and policies relevant to the proposed action.

Table C-1. Summary of Other Applicable Federal Laws, Regulations, and Policies

Relevant Authority Description American Indian Religious Freedom Act of This act protects and preserves the Native American 1978 (42 United States Code [USC] 1996) traditional religious rights, access to ethnic heritage sites, and the use of sacred objects. Antiquities Act of 1906 (16 USC 431–433) This act protects historic and prehistoric remains and sites of scientific value on Federal lands; establishes criminal sanctions for unauthorized destruction or removal of antiquities; authorizes the President to establish national monuments by proclamation; and authorizes scientific investigation of antiquities on Federal lands, subject to permit and regulations. Bald and Golden Eagle Protection Act This act prohibits anyone without a permit issued by the of 1940 Secretary of the Interior from “taking” bald or golden (16 USC 668–668d) eagles. “Taking” includes killing, molesting, or disturbing the birds, their nests, or their eggs. Clean Air Act This act regulates air emissions and pollutants from area, (42 USC 7401 et seq., as amended) stationary, and mobile sources to improve air quality. It authorizes the Environmental Protection Agency to establish National Ambient Air Quality Standards to protect public health and the environment. Clean Water Act This act establishes structure for regulating quality (33 USC 1251 et seq.) standards for surface waters and requires states to set standards to protect water quality, including regulation of stormwater and wastewater discharges during construction and operation of a facility. Endangered Species Act of 1973 This act Federally protects threatened and endangered (16 USC 1513 et seq.) plants, invertebrates, fish, and wildlife through listing; requires consultation with the U.S. Fish and Wildlife Service on Federal projects (known as Section 7 consultation); prohibits the “taking” of listed species; and provides for permits to allow the “incidental taking” of listed species. Energy Policy Act of 2005 This act establishes a comprehensive, long-range national (Public Law [PL] 109-58; 42 USC 13201 energy policy, including both traditional energy et seq.) production and newer energy technologies and conservation. Executive Order 13007, Indian Sacred Sites This order directs Federal land management agencies to (May 24, 1996) accommodate (as practicable) access to and ceremonial use of tribal sacred sites by Native American religious practitioners and to avoid adversely affecting the physical integrity of such sacred sites.

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Relevant Authority Description Executive Order 13112, Invasive Species This order requires Federal agencies to take actions to (February 3, 1999) prevent the introduction and spread of invasive species; to provide for invasive-species control; and to minimize the economic, ecological, and human health impacts of invasive species. Executive Order 13175, Consultation This order reiterates the requirement for regular and and Coordination with Indian Tribal meaningful government-to-government consultation Governments between the Federal government and tribal officials. (November 9, 2000) Executive Order 13186, Responsibilities of This order outlines a collaborative approach to promote Federal Agencies to Protect Migratory Birds the conservation of migratory bird populations and directs (January 10, 2001) agencies to take certain actions to further implement the migratory bird conventions, the Migratory Bird Treaty Act, the Bald and Golden Eagle Protection Act, and other pertinent statutes. Executive Order 13211, Actions This order directs Federal agencies to identify impacts that Concerning Regulations that Significantly their actions may have on the supply, distribution, or use Affect Energy Supply, Distribution, or Use of energy in the United States. (May 18, 2010) Executive Order 13212, Actions to Expedite This order directs Federal agencies to expedite their Energy-Related Projects reviews of permits or other actions for energy-related (May 18, 2010) projects, to accelerate the completion of those projects. Executive Order 13423, Strengthening This order instructs Federal agencies to conduct their Federal Environmental, Energy, and environmental, transportation, and energy-related activities Transportation Management in a manner that is environmentally, economically, and (January 24, 2007) fiscally sound; integrated; continuously improving; efficient; and sustainable. The order sets goals in the following areas: energy efficiency, acquisition, renewable energy, toxic chemical reduction, recycling, sustainable buildings, electronics stewardship, fleets, and water conservation. Hazardous Materials Transportation Guides This regulation governs the transportation of hazardous (43 CFR 171–177 and 350–399) materials and related guidelines. Migratory Bird Treaty Act of 1918 This act makes it unlawful to take or possess any (16 USC 703–711) migratory bird (or any part of such migratory bird, including active nests) as designated, unless permitted by regulation (example e.g., duck hunting). National Forest Management Act of 1976 This act is the primary Federal statute governing the (PL 94-588) administration of national forests and is an amendment to the Forest and Rangeland Renewable Resources Planning Act of 1974, which called for the management of renewable resources on national forest lands. National Historic Preservation Act of 1966 This act established the National Register of Historic (16 USC 470 et seq.) Places for listing historic properties that are significant in American history, architecture, archaeology, and culture. Section 106 requires Federal agencies to take into account the effect of a proposed undertaking on resources listed or eligible for listing on the National Register of Historic Places.

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Relevant Authority Description Native American Graves Protection This act establishes additional requirements for ownership and Repatriation Act of 1990 and control of Native American cultural items, human (25 USC 3001–3002) remains, and associated funerary objects. It also establishes requirements for the treatment of Native American human remains and cultural objects found on Federal land. This act further provides for the protection, inventory, and repatriation of Native American human remains, objects of cultural patrimony, sacred objects, unassociated funerary objects, and associated funerary objects. Safe Drinking Water Act Amendments This act and its amendments emphasize preventing of 1996 contamination through source-water protection and (42 USC 300f) enhanced water system management to better provide for the sustainable use of water by our nation’s public water systems. Plant Protection Act of 2000 This act establishes that the detection, control, eradication, (7 U.S.C. 7701 et seq.) suppression, prevention, or retardation of the spread of plant pests or noxious weeds is necessary for the protection of the agriculture, environment, and economy of the United States.

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Appendix D. List of Compatible or Incompatible Vegetation

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Compatible and Incompatible Vegetation The table below includes dominant and predominant vegetation species within biotic communities in Arizona identified as either compatible or incompatible with APS objectives for vegetation management. Note that vegetation management includes manual, mechanical, and herbicide treatment of vegetation. However, any cacti, yucca, and agave listed as incompatible would not be treated using herbicide application.

Table D-1. Summary of Species Compatability with APS Objectives

Biotic Compatible / Community Incompatible Common Name Scientific Name

Great Basin IC Juniper Juniperus sp. Conifer Woodland

IC Pinyon Pinus edulis

C Grama grass Bouteloua sp.

C Western Wheatgrass Pascopyrum smithii

C Indian Ricegrass Achnatherum hymenoides

C Galleta Grass Pleuraphis jamesii

C Snakeweed Gutierrezia sarothrae

C Groundsel Senecio sp. C other grass and forb spp.

Interior Chaparral IC Shrub Live Oak Quercus turbinella

IC/C Ceonothus Ceanothus sp.

IC Manzanita Arctostaphylos sp.

IC Sugar Sumac Rhus ovata

IC Skunkbush Sumac Rhus trilobata

IC Mountain Mahogany Cercocarpus montanus

IC Silk Tassel Garrya sp.

C Cliffrose Purshia mexicana

C Brickelbush Brickellia californica

C Yucca Yucca glauca

C Snakeweed Gutierrezia sarothrae

C Buckwheat Polygonum sp.

C Penstemon Penstemon sp. C other grass and forb spp. Madrean IC Emory Oak Quercus emoryi Evergreen IC Arizona White Oak Quercus arizonica Woodland IC Arizona cypress Cupressus arizonica IC Larchleaf goldenweed Ericameria laricifolia C Cane bluestem Bothriochloa barbinoides C Blue grama Bouteloua gracilis C Sideoats grama Bouteloua curtipendula

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Biotic Compatible / Community Incompatible Common Name Scientific Name Madrean C Little bluestem Schizachyrium scoparium Evergreen C Penstemons Penstemon sp. Woodland (continued) C Lupines Lupinus sp. C Bricklebush Brickellia sp. C Sage Salvia sp. C Rainbow cactus Echinocereus pectinatus C Barrel cactus Ferocactus wislizeni C Cane cholla Cylindropuntia spinosior C Engelmann prickly pear Opuntia phaecantha C Banana yucca Yucca baccata C Agave Agave sp. C Beargrass Nolina sp. C other grass and forb spp. Petrane Montane IC Ponderosa Pinus ponderosa Conifer Forest IC Douglas-fir Pseudotsuga menziesii IC White Fir Abies concolor IC Limber Pine Pinus flexilis IC Aspen Populus tremuloides IC Gambel oak Quercus gambelii IC NM Locust Robinia neomexicana C Buckbush Ceanothus sp. C Barberry Berberis sp. C Gooseberry Ribes sp. C Rose Rosa sp. C Elderberry Sambucus sp. C Snowberry Symphoricarpos sp. C other grass and forb spp. Plains & Great IC Four-wing saltbush Atriplex canescens Basin Grassland IC Rabbitbrush Ericameria nauseosa IC Juniper Juniperus sp. C Grama Grass Bouteloua sp. C Buffalo-grass, Bouteloua dactyloides C Indian Rice Grass Achnatherum hymenoides C Galleta Grass Pleuraphis jamesii C Lovegrass Eragrostis sp. C Vine Mesquite Grass Panicum obtusum C Winterfat Krascheninnikovia lanata C Cholla Opuntia sp.

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Biotic Compatible / Community Incompatible Common Name Scientific Name Plains & Great C Soapweed Yucca Yucca elata Basin Grassland C Snakeweed Gutierrezia sarothrae (continued) C Prickly Pear Opuntia engelmannii C other grass and forb spp. Riparian IC Tamarisk Tamarix sp. IC Mesquite Prosopis juliflora IC Cottonwood Populus fremontii IC Willow Salix sp. IC Arizona Ash Fraxinus velutina IC Sycamore Platanus wrightii IC Juniper Juniperus sp. IC Desert Willow Chilopsis linearis IC Box Elder Acer negundo IC Alder Alnus spp. IC Arizona Walnut Juglans major C Cattail Typha sp. C Arrowhead Sagittaria sp. C Spikerush Eleocharis sp. C Rush Juncus sp. C Sedge Carex sp. C Saltgrass Distichlis spicata C Phragmites Phragmites C other grass and forb spp. Semidesert IC Soaptree Yucca Yucca elata Grassland IC Mesquite Prosopis spp. IC/C Agave Agave sp. C Juniper Juniperus sp. C Three-awn Grass Aristida sp. C Grama Grass Bouteloua sp. C Curly Mesquite Grass Hilaria belangeri C Burroweed Ambrosia dumosa C Prickly Pear Opuntia sp. C other grass and forb spp. Sonoran IC Mesquite Prosopis spp. Desertscrub IC Ironwood Olneya tesota IC Palo Verde Parkinsonia spp. IC Smoketree Psorothamnus spinosus IC Desert Willow Chilopsis linearis

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Biotic Compatible / Community Incompatible Common Name Scientific Name Sonoran IC Acacia Acacia spp. Desertscrub IC Wolfberry Lycium spp. (continued) IC Desert Broom Baccharis sarothroides IC Creosotebush Larrea tridentata IC Ocotillo Fouquieria splendens IC Saguaro Carnegiea gigantea IC Hackberry Celtis reticulata IC Saltbush Atriplex spp. IC Crucifixion Thorn Canotia holacantha IC/C Cholla Opuntia spp. C Triangle leaf Bursage Ambrosia deltoidea C Chuparosa Justicia californica C Brittlebrush Encelia farinosa C Jatropha Jatropha spp. C Prickly-pear Opuntia spp. C Ragweed Ambrosia spp. C Burroweed Ambrosia dumosa C Ragweed Ambrosia spp. C other grass and forb spp.

Petrane Montane IC Ponderosa Pinus ponderosa Conifer Forest

IC Douglas-fir Pseudotsuga menziesii

IC White Fir Abies concolor

IC Limber Pine Pinus flexilis

IC Aspen Populus tremuloides

IC Gambel oak Quercus gambelii

IC NM Locust Robinia neomexicana

C Buckbush Ceanothus sp.

C Barberry Berberis sp.

C Gooseberry Ribes sp.

C Rose Rosa sp.

C Elderberry Sambucus sp.

C Snowberry Symphoricarpos sp. C other grass and forb spp.

Plains & Great IC Four-wing saltbush Atriplex canescens Basin Grassland

IC Rabbitbrush Ericameria nauseosa

IC Juniper Juniperus sp.

C Grama Grass Bouteloua sp.

C Buffalo-grass, Bouteloua dactyloides

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Biotic Compatible / Community Incompatible Common Name Scientific Name Plains & Great C Indian Rice Grass Achnatherum hymenoides Basin Grassland C (continued) Galleta Grass Pleuraphis jamesii C Lovegrass Eragrostis sp. C Vine Mesquite Grass Panicum obtusum C Winterfat Krascheninnikovia lanata C Cholla Opuntia sp. C Soapweed Yucca Yucca elata C Snakeweed Gutierrezia sarothrae C Prickly Pear Opuntia engelmannii C other grass and forb spp.

Riparian IC Tamarisk Tamarix sp.

IC Mesquite Prosopis juliflora

IC Cottonwood Populus fremontii

IC Willow Salix sp.

IC Arizona Ash Fraxinus velutina

IC Sycamore Platanus wrightii

IC Juniper Juniperus sp.

IC Desert Willow Chilopsis linearis

IC Box Elder Acer negundo

IC Alder Alnus spp.

IC Arizona Walnut Juglans major

C Cattail Typha sp.

C Arrowhead Sagittaria sp.

C Spikerush Eleocharis sp.

C Rush Juncus sp.

C Sedge Carex sp.

C Saltgrass Distichlis spicata

C Phragmites Phragmites C other grass and forb spp.

Semidesert IC Soaptree Yucca Yucca elata Grassland

IC Mesquite Prosopis spp.

IC/C Agave Agave sp.

C Juniper Juniperus sp.

C Three-awn Grass Aristida sp.

C Grama Grass Bouteloua sp.

C Curly Mesquite Grass Hilaria belangeri

C Burroweed Ambrosia dumosa

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Biotic Compatible / Community Incompatible Common Name Scientific Name Semidesert C Prickly Pear Opuntia sp. Grassland (continued) C other grass and forb spp.

Sonoran IC Mesquite Prosopis spp. Desertscrub

IC Ironwood Olneya tesota

IC Palo Verde Parkinsonia spp.

IC Smoketree Psorothamnus spinosus

IC Desert Willow Chilopsis linearis

IC Acacia Acacia spp.

IC Wolfberry Lycium spp.

IC Desert Broom Baccharis sarothroides

IC Creosotebush Larrea tridentata

IC Ocotillo Fouquieria splendens

IC Saguaro Carnegiea gigantea

IC Hackberry Celtis reticulata

IC Saltbush Atriplex spp.

IC Crucifixion Thorn Canotia holacantha

IC/C Cholla Opuntia spp.

C Triangle leaf Bursage Ambrosia deltoidea

C Chuparosa Justicia californica

C Brittlebrush Encelia farinosa

C Jatropha Jatropha spp.

C Prickly-pear Opuntia spp.

C Ragweed Ambrosia spp.

C Burroweed Ambrosia dumosa

C Ragweed Ambrosia spp. C other grass and forb spp. Source: Vegetation types in this table were derived from the Forest Service Southwestern Region Ecological Response Unit (ERU) and Subclass (Forest Service 2016a). IC= Incompatible vegetation: defined as plants under, above, and near power lines that could disrupt the safe, reliable, and continuous delivery of electricity to APS’s customers C= Compatible vegetation: defined as plants under, above, and near power lines that are not expected to disrupt safe, reliable, and continuous delivery of electricity to APS’s customers. Vegetation in this category are incompatible when occurring with the Defensible Space around Poles (DSAP) treatment area. IC/C= Incompatible/Compatible: Species with this designation under the this category can be classified compatible or incompatible based on density, terrain type and slope, blooming stalk, or plant height at time of inspection among other variables.

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Appendix E. Biological Conservation Measures

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Biological Assessment and Biological Evaluation Conservation Measures The following conservation measures were developed as a part of the Vegetation Management and Line Maintenance in APS Power Line Rights-of-Way on Arizona Forests, Working Draft Biological Assessment for Threatened and Endangered Species (Pending Forest Service BA 2018-in progress) and Herbicide Use within APS Authorized Power Line Rights-of-Way on National forest System Lands in Arizona: Working Draft Biological Evaluation and Specialist Report (Pending Forest Service BE 2018-in progress).

Riparian Area, Wetland, and other Aquatic Habitat Conservation Measures 1. Implement the following buffers for riparian, wetlands, and other aquatic habitats when applying herbicide29. a. Herbicides rated as class 0 requires no buffer. Herbicides that meet this criterion include: aminocyclopyrachlor, aminopyralid, glyphosate (aquatic formulation), imazapic, imazapyr (aquatic and nonaquatic formulations). b. Do not apply herbicides rated as class 1 within 30 feet of the waterbody or wetland to be protected. Herbicides that meet this criterion include: chlorsulfuron, clopyralid, fluroxypyr (acid formulation), glyphosate (non-aquatic formulation), isoxaben, metsulfuron methyl, picloram, sulfometuron methyl, tebuthiuron, and triclopyr (amine salt formulation). c. Do not apply herbicides rated as class 2 within 50 feet of the waterbody or wetland to be protected and within 10 feet of riparian vegetation, if present. Herbicides that meet this criterion include: 2,4-D (aquatic and non-aquatic amine salt formulations), dicamba, and triclopyr (ester formulation). d. Do not apply herbicides rated as class 3 within 100 feet of the edge of the waterbody or wetland to be protected and within 20 feet of riparian vegetation, if present. Herbicides that meet this criterion include: 2,4-D aquatic and non-aquatic ester formulations. e. For pool habitats, do not apply herbicides within 30 feet of pools when there is no surface flow of water in and out of pool.

Migratory Bird Conservation Measures 1. Do not apply 2,4-D and dicamba within ½ mile of burrowing owl nests until birds have left the area. These herbicides rate as Class 2 and Class 3 in the predatory avian, small mammal, or terrestrial arthropod toxicity group.

29 The list of herbicides provided under each toxicity level (Class 1, 2 or 3) was derived by listing out the toxicity for each proposed herbicide from the categories from Appendix G that are applicable to species that may occur in riparian area, wetlands, and other aquatic habitats. These categories included Small Avian, Reptile, Aquatic Amphibian, Terrestrial Amphibian, Cold Water Fish, Warm Water Fish, and Aquatic Arthropod. To determine the herbicide toxicity class of each herbicide, the highest toxicity number for all these categories was used. For example, triclopyr has a Class 0 or Class 1 herbicide toxicity in some categories but Class 2 in other categories, so this herbicide was included in the Class 2 buffer under conservation measure 6.c.

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2. To protect all other migratory birds, do not apply dicamba within the following buffers for each bird category*: Species Category Dicamba Buffer Buffer Type Falcons, kites, ospreys, owls, small 300 feet Occupied nests hawks Carrion eating birds (large hawks, 660 feet (1/8 Occupied nests caracaras, ravens, vultures, etc.) mile) Small avian seed and grit eating 30 feet Occupied habitat migratory birds (doves, finches, meadowlarks, sparrows, etc.) Geese 300 feet Occupied nests Waterfowl other than geese (ducks, 30 feet Occupied habitat grebes, loons, mergansers, etc.) *Insect eating small migratory birds such as flycatchers, swallows, warblers, woodpeckers, and wrens do not require buffers for spot application of solid and liquid formulations of herbicides.

Measure for All Species that Applies to All Activities 1. APS shall work with the Forest Service, AGFD, and FWS annually to update the species information for all those included in this consultation to ensure that new information is incorporated in an assessment for determining if any re-initiation triggers have been tripped. For example, a new population is found in an area where activities associated with the proposed action may affect this population.

General Noxious Weed Best Management Practices 1. Ensure that mower, track, or other off-road equipment, which has high potential to carry noxious weeds (not including service vehicles, pick-up trucks, or passenger cars) are free of soil, weeds, vegetative matter or other debris that could harbor seeds prior to entering National Forests. 2. APS shall contact the appropriate District to identify known or high probability noxious weed hotspots. In those areas, APS would ensure that mower, track, or other off-road equipment, which has high potential to carry noxious weeds (not including service vehicles, pick-up trucks, or passenger cars) are free of soil, weeds, vegetative matter or other debris that could harbor seeds prior to moving equipment between line segments.

Chiricahua Leopard Frog To protect the Chiricahua leopard frog, the following conservation measures are to be applied to suitable Chiricahua leopard frog habitat along the 500-3, PR 06, TT 14, 345-1, NE-01, and NE- 21 power lines and any other power lines in the future where suitable habitat has been identified.

Herbicide Conservation Measures 1. For herbicide application, implement Riparian Area, Wetland, and Other Aquatic Habitat Conservation Measures. Non-Herbicide Conservation Measures 1. When driving within Chiricahua leopard frog habitat, implement design features from Riparian Area, Wetland, and Other Aquatic Habitat Conservation Measures.

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a. When working in riparian areas, wetlands, and near other aquatic habitats, access work site only on existing roads, and limit all travel on roads when damage to the road surface would result or is occurring. b. To the degree possible, equipment staging areas and refueling areas should be located away from riparian areas and wetlands. Whenever possible, these activities should be located in previously disturbed areas. 2. Biologists or other environmental specialists from APS would contact appropriate biologists from FWS, AGFD, and Forest Service on an annual basis to ensure that all project planning and implementation activities account for possible newly discovered or reestablished Chiricahua leopard frog populations. 3. To the extent possible, locate ground disturbing activities outside of occupied Chiricahua leopard frog habitat, habitat restoration/creation sites, and the immediate watersheds of such habitats. 4. If avoidance is not possible, ground disturbing activities should be minimized in occupied Chiricahua leopard frog habitat, habitat restoration/creation sites, and the immediate watersheds of such habitats through the use of the least disturbing equipment (e.g., in sensitive riparian zones, use hand tools in place of motorized equipment). 5. Within occupied Chiricahua leopard frog habitats, the area of disturbance of vegetation, soils, and water should be the minimum required for the project activity. Project activities should be located out of wetted sites to the extent practicable. 6. If practicable, locate equipment staging areas away from occupied habitat and habitat restoration/creation sites. 7. If work activities includes walking through or running or driving equipment off-road through water of occupied or unoccupied Chiricahua leopard frog habitat, either delay work until the area is dry or disinfect according to the protocol outlined. a. Ensure shoes and equipment is clean, dry, and disinfected before moving to another suitable habitat location. b. Rinse equipment with tap or bottled water until all debris is removed. c. Scrub surfaces with one percent sodium hypochlorite (household bleach); d. Following disinfection, rise well with tap water e. Footwear must be completely cleaned with special attention paid to grips, cleats, and laces. f. All equipment shall be completely dried before re-use.

California Condor To protect the California condor, the following conservation measures are to be applied to APS power lines on Coconino and Kaibab National Forests that occur north of I-40 in California condor 10(j) habitat.

1. Contact FWS field office in Flagstaff, AZ at 928-226-0614 for information on the California condor before application of pesticide near release sites, nest sites, or known communal roost sites in species habitat of canyon lands and mountain ridges.

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2. Do not apply herbicides within 1/4 mile of currently occupied California condor nests, roosts, or release sites.

Mexican Spotted Owl Herbicide Conservation Measures To protect the Mexican spotted owl, the following conservation measures are to be applied to the APS power line ROWs within and near Mexican spotted owl PACs.

1. Use only Class 0 or Class 1 herbicides within the Predatory Avian toxicity group (see Appendix G: Ecotoxicity Ratings for Pesticide Active Ingredients and Various Formulations) within Mexican spotted owl PACs and recovery habitat. This includes all proposed herbicides with the exception of dicamba. 2. Do not apply herbicides rated as Class 2 or Class 3 within 300 feet of the outside perimeter of a PAC and/or within Mexican spotted owl recovery habitat. Dicamba is the only proposed herbicide that falls under this category. 3. When driving an ATV through a Mexican spotted owl PAC during the breeding season (March 1 to August 31), ATV must remain on existing roads that are open to the public. 4. Do not apply herbicides during the Mexican spotted owl breeding season from March 1 to August 31 in the 14 Mexican spotted owl PACs with overhead power lines, as identified in Table 23 of the BA. For the remaining PACs, herbicide of Class 0 or 1 within the Predatory Avian toxicity group may be applied within a Mexican spotted owl PAC during the breeding season (March 1 to August 31) using backpack sprayer or other hand-operated equipment only after review and approval by Forest Service and FWS. Only ROWs that occur at the edge of the PAC and do not intersect towards the center of the PAC would be considered for this treatment. Non-Herbicide Conservation Measures Routine vegetation maintenance and non-hazard line maintenance treatments: 1. Avoid ground work (use of equipment) within PACs between March 1 and August 31. 2. Avoid use of loud machinery within 0.25 mile of PACs between March 1 and August 31, with the goal of limiting noise levels at PAC boundary to less than 69 decibels. 3. When disposing of vegetation within a Mexican spotted owl PAC, coordinate disposal methods with the Forest District and, if appropriate/feasible, leave large logs (greater than 12 inches in diameter) whole rather than cutting into smaller sections.

Southwestern Willow Flycatcher To protect the southwestern willow flycatcher, the following conservation measures are to be applied to suitable southwestern willow flycatcher habitat on the: 500-3, CU 06, HD 02, MZT06, NW 02, and QS 02 power lines crossing the Salt and Verde Rivers and Tonto Creek and any other power lines in the future where suitable habitat has been identified.

Herbicide Conservation Measures 1. Implement Riparian Area, Wetland, and Other Aquatic Habitat Conservation Measures within suitable riparian habitat for southwestern willow flycatcher.

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2. Do not drive ATVs within 50 meters (164 feet) of southwestern willow flycatcher habitat (riparian vegetation) during the nesting season (May 1 to August 31) except on existing roads that are open to the public. 3. Avoid herbicide application during the nesting season from May 1 to August 31 whenever possible. If herbicide application is necessary during the nesting season, ensure work is conducted with the least number of trips in and out and workers walk only in the ROW and open areas and not in dense thickets of vegetation where suitable nesting habitat may occur. Non-herbicide Conservation Measures 1. Avoid non-hazardous ground work disturbance in the floodplain containing occupied breeding habitat or suitable breeding habitat if occupancy is unknown between May 1 and August 31. 2. For LiDAR flights do not land for refueling or stage the helicopter within 0.25 mile of southwestern willow flycatcher occupied habitat during the breeding season.

Yellow-Billed Cuckoo To protect the western yellow-billed cuckoo, the following conservation measures are to be applied to suitable western yellow-billed cuckoo habitat on power lines, as indicated in the 2018 BA, and any other power lines in the future where suitable habitat has been identified.

Herbicide Conservation Measures 1. Implement Riparian Area, Wetland, and Other Aquatic Habitat Conservation Measures within suitable riparian habitat for yellow-billed cuckoo. 2. Do not drive ATVs within 50 meters (164 feet) of yellow-billed cuckoo suitable breeding habitat during the breeding season from May 1 to September 30 except on existing roads that are open to the public. This measure applies to power lines that occur in suitable breeding habitat (500-3 at Cherry Creek, MZT06 at Rye Creek, QS 02 and QS 10 at Upper Verde River, CN 02, CP 02, and SE 06 at Oak Creek, CU 02 and MG 10 at Beaver Creek, CU 06 at Lower Verde River and West Clear Creek, MZT 06 at Tonto Creek, and HD 02, NW 02, and NW 04 at Verde River). 3. Avoid herbicide application during critical times of the nesting season from May 1 to September 30 whenever possible. If herbicide application is necessary during the nesting season, ensure work is conducted with the least number of trips in and out and workers walk only in the ROW and open areas and not in dense thickets of vegetation. This measure applies to power lines that occur in suitable breeding habitat (500-3 at Cherry Creek, MZT06 at Rye Creek, QS 02 and QS 10 at Upper Verde River, CN 02, CP 02, and SE 06 at Oak Creek, CU 02 and MG 10 at Beaver Creek, CU 06 at Lower Verde River and West Clear Creek, MZT 06 at Tonto Creek, and HD 02, NW 02, and NW 04 at Verde River). Non-herbicide Conservation Measures 1. For non-hazardous groundwork, avoid ground work disturbance in the floodplain containing occupied breeding habitat between May 1 and September 30.

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2. For LiDAR flights, APS would not land the helicopter for refueling within 0.25 mile of yellow-billed cuckoo occupied habitat during the breeding season.

Fish The conservation measure below shall be implemented for all creeks and rivers in the project area regardless of whether the location is occupied or not by proposed or federally listed fish. To protect fish, the following conservation measures are to be applied for work immediately adjacent to any river or creek within the project area. 1. Implement Riparian Area, Wetland, and Other Aquatic Habitat Conservation Measures.

Mexican Gray Wolf 1. Immediately report sightings of wolves occurring within or adjacent to ROWs to the USFWS and/or the National Forest where the sighting took place.

Ocelot 1. Immediately report sightings of ocelots occurring within or adjacent to ROWs to the USFWS and/or the National Forest where the sighting took place.

Arizona Cliffrose The conservation measures below are to be applied to the APS QS 10 distribution power line where it occurs within Arizona cliffrose suitable habitat on Coconino National Forest. 1. Do not use a mechanical mower for routine vegetation maintenance within Arizona cliffrose suitable habitat. 2. Do not apply herbicides within Arizona cliffrose suitable habitat. 3. Prior to routine vegetation maintenance work, a survey for Arizona cliffrose would be conducted by a biologist of other professional experienced in the identification of Arizona cliffrose. GPS coordinate of found plants will be recorded and reported to the Forest Service. 4. Prior to routine vegetation maintenance work and ground disturbing line maintenance activities, locate and flag all Arizona cliffrose within and immediately adjacent to the area for avoidance. 5. Avoid Arizona cliffrose during maintenance activities. Avoid cutting of, trampling of, and disposing of vegetation on Arizona cliffrose. Avoid ground disturbing work (such as pole replacement) where Arizona cliffrose is located. 6. Work crews are to be educated on the avoidance of Arizona cliffrose prior to scheduled work in suitable habitat. The training shall include: education on appearance of Arizona cliffrose; reference materials to assist in avoidance in the field; field visit, if needed, for refinement of search image; and procedures on avoiding Arizona cliffrose not found during inventory. This training may be a professionally developed written training that is reviewed prior to work. 7. Instruct routine vegetation maintenance crews to avoid trampling or disposing of vegetation on seedling woody plants in an effort to avoid Arizona cliffrose seedlings.

268 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

8. During routine vegetation maintenance, check under plants to be treated for seedling Arizona cliffrose prior to cutting the vegetation to identify any plants that may have been missed during inventory. If a plant is found that could be Arizona cliffrose, take measures to avoid affecting the plant. If the Arizona cliffrose is protected and shaded by the plant to be cut, either leave the target plant or selectively trim the plant so that Arizona cliffrose continues to be protected. 9. When accessing the power line ROW by vehicle from the Lime Kiln Trail and Bill Ensign Trail for line maintenance work, a trained biologist, botanist, or other professional experience in the identification of Arizona cliffrose is to inventory the off-road driving path prior to vehicular access and identify and flag any Arizona cliffrose plants for avoidance. 10. When driving vehicles off-road in the ROW in Arizona cliffrose habitat, do so during dry conditions to minimize soil disturbance.

Arizona Hedgehog Cactus To protect the Arizona hedgehog cactus, the following conservation measures will be applied to the PZ 01 and 500-3 power lines.

General Conservation Measures 1. Work crews are to be educated on the avoidance of Arizona hedgehog cactus prior to scheduled work in potential habitat. The training for work crews shall involve one or more work crew members, crew foreman, or utility employee overseeing work and include: education on appearance of Arizona hedgehog cactus; reference materials to assist in avoidance in the field; field visit, if needed, for refinement of search image; and procedures on identifying and avoiding any Arizona hedgehog or similar looking cacti not found during pre-work inventory.

Vegetation Management Conservation Measures 1. Do not use a mechanical mower for routine vegetation maintenance within Arizona hedgehog cactus occupied habitat. 2. Drive vehicles only on existing roads and utility access routes to access the ROW. Do not drive vehicles off-road within the ROW. 3. Prior to each vegetation management cycle, a survey for Arizona hedgehog cactus would be conducted by a qualified botanist or other professional experienced in the identification of this plant. GPS coordinates of found plants will be recorded and reported to the Forest Service. a. For manual cutting of vegetation, all Arizona hedgehog cacti within and immediately adjacent to the work area are to be flagged for avoidance. b. For herbicide application, a buffer of 20 feet will be established for avoidance. No herbicide treatments would occur within the 20 foot buffer. Any vegetation that needs treatment within the buffer zone will be selectively trimmed using manual methods only. c. In an effort to be conservative, all Arizona hedgehog cactus and those similar to it, may be included in the flagging for avoidance.

269 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

4. During vegetation management work (herbicide and manual cutting), crews will check for Arizona hedgehog cactus under target plants prior to treatment. If a cactus is found, appropriate conservation measures to avoid the cactus will be implemented. 5. During manual vegetation maintenance work, if an Arizona hedgehog cactus occurs underneath, and is shaded by a shrub to be cut, the target shrub will be left untreated. In very rare circumstances, the nurse plant may be selectively trimmed in a manner to maintain the same shading protection for the Arizona hedgehog cactus. No more than 30% of the nurse plant may be trimmed. 6. For herbicide application: a. Do not use the pre-emergent herbicides isoxaben in Arizona hedgehog cactus potential habitat. b. Do not use 2,4-D within 300 feet of occupied Arizona hedgehog cactus habitat to minimize effects to pollinators. These herbicides are rated as Class 2 or Class 3 in the pollinating toxicity group. c. Conduct post-herbicide application visual inspection between two weeks and eight weeks following application of herbicide in accordance to protocols identified in the 2018 BA, Appendix H: Arizona Hedgehog Cactus Herbicide Post-Application Visual Inspection Protocol. d. Any misapplications of herbicide that violates the above conservation measures or result in damage to Arizona hedgehog cactus would be immediately reported to the Forest Service and the local FWS office to discuss re-initiation of consultations and any additional actions that may be needed to further reduce impacts.

Narrow-Headed and Mexican Gartersnake To protect the narrow-headed gartersnake, the following conservation measures are to be applied to suitable narrow-headed gartersnake habitat within APS power line ROWs, as well as any other power lines in the future where suitable habitat has been identified. 1. For all maintenance activities that will occur within gartersnake habitat, provide crews with training material on identifying the gartersnake, what to do if a gartersnake is observed in the project area, and on the following conservation measures in order to reduce impacts to individuals and habitat. The USFWS will develop with the Utilities and USFS training materials, which could include field guide materials, natural history literature, photographs, maps, comparison to other common snakes, contact lists, and instructions for collecting photo-documentation. 2. For all maintenance activities within gartersnake habitat, only drive on designated open roads and do not drive over-land. Within upland gartersnake habitat, avoid driving over- land unless it is necessary for safe maintenance of utility infrastructure. When driving within gartersnake habitat, drive at a speed slow enough to allow a surface-active snake to be seen by the driver and avoided. 3. For all maintenance activities, crews will coordinate the timing of activities such that work is consolidated into the least number of days of work and least number of trips in and out of gartersnake habitat to minimize the duration and frequency of disturbance to the gartersnakes.

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4. For all maintenance activities, crews shall not touch or handle snakes of any species. 5. For routine vegetation maintenance work, do not use mechanical mower within gartersnake habitat. 6. For herbicide applications, implement the Riparian Area, Wetland, and Other Aquatic Habitat Conservation Measures found in Appendix F of the BA in all riparian areas, wetlands, and aquatic habitats within the action area of the project. In addition, implement the following buffers for gartersnake proposed critical habitat and other known occupied habitat not proposed or designated as critical habitat outside of riparian, wetland, and aquatic habitat buffers: a. Herbicides rated as class 0 in the reptile toxicity group require no buffer and may be applied within gartersnake proposed critical habitat and occupied habitat outside of the riparian, wetland, and aquatic habitat buffers. Herbicides that meet this criterion include: aminocyclopyrachlor, aminopyralid, 2, 4-D (aquatic and nonaquatic ester formulations), fluroxypyr, glyphosate (aquatic formulation), imazapic, imazapyr (aquatic and nonaquatic formulations), picloram, sulfometuron methyl, tebuthiuron, and triclopyr (ester formulation). b. Do not apply herbicides rated as class 1 in the reptile toxicity group within 30 feet of gartersnake proposed critical habitat and occupied habitat. Herbicides that meet this criterion include: chlorsulfuron, clopyralid, 2,4-D (aquatic and nonaquatic amine salt formulations, glyphosate (non-aquatic formulation), isoxaben, metsulfuron methyl, and triclopyr (amine salt formulation). c. Do not apply herbicides rated as class 2 in the reptile toxicity group within 50 feet of gartersnake proposed critical habitat and occupied habitat. Herbicides that meet this criterion include: dicamba. 7. Do not apply herbicides rated as class 3 in the reptile toxicity group within 100 feet of gartersnake proposed critical habitat and occupied habitat. There are currently no herbicides proposed that meet this criteria. For all maintenance activities when working within gartersnake habitat, avoid filling in or crushing burrows and crevices at the base of trees or between large rocks and boulders; and, avoid moving large rocks, boulders and logs unless necessary for safe maintenance of utility infrastructure. A biological monitor may be needed if work involves ground disturbance or movement of rocks and logs (see 8 below). 8. For significant ground disturbing work in gartersnake habitat, a biological monitor must be present during the ground disturbing activity to look for gartersnakes. The specific biological monitoring protocol will be developed by USFWS in coordination with Forest Service and APS. a. A biological monitor will be needed while digging or filling the trench or hole, as well as for regular inspections of any hole or trench in order to ensure entrapment of any gartersnakes does not occur and to avoid injuring a gartersnake during digging or burying a snake while back-filling. b. If there is uncertainty on whether a monitor would be needed, the Utilities will coordinate with USFWS and Forest Service to determine the need for a monitor. An uncertain circumstance may be if a pole needs to be replaced within proposed critical habitat and that pole is located where a cliff face separates the pole and

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creek, a gartersnake would not travel up the cliff face to where the pole is located so a monitor would not likely be needed. Forest Service and USFWS would be contacted to verify whether a monitor is not needed under this circumstance. c. If there is a gartersnake detection, the detection must be reported to USFWS within 72 hours. When a gartersnake is detected, work may continue with implementation of the conservation measures. 9. For work that does not require a biological monitor (see number 8), report any observations of narrow-headed gartersnake or northern Mexican gartersnakes on or near the worksite to the APS, USFWS, and Forest Service designated representatives within approximately one week of the observation. Reports must be accompanied by photographs whenever possible. Contacts will be defined in the crew training. The report should include at least the location (i.e. pole number or GPS coordinate), date, time, photo (if possible), and any observational information that may be useful. When a gartersnake is observed, work may continue with implementation of the conservation measures above. 10. After a gartersnake has been detected and reported in accordance with number 8 and 9 above, the USFWS, Forest Service, and APS will review all relevant information and evaluate whether further discussion and protective action is necessary to address gartersnake conservation.

Sensitive Plant Conservation Measures 1. To protect sensitive plants as much as possible, APS will coordinate with Forest biologists and/or botanists in identifying and avoiding known populations of sensitive plants prior to herbicide application. This may be done by providing work crews generalized or specific location information of the plant and photos and identification information of the plant for avoidance. APS will work with the Forest during the PUP review to determine if an herbicide-free buffer needs to be applied to sensitive plants. 2. If crews identify a previously undetected sensitive plant (or plant that appears to be one of the sensitive plants provided in the crew education material, see conservation measure number one), crews are to document the GPS coordinate and photo of the plant and APS shall provide this location and photo to the Forest for the purpose of updating occupancy data of that plant on the Forest. 3. APS will coordinate with the Apache-Sitgreaves and Coconino National Forests so that the Forests can review the proposed work and determine if there are any Bebb’s willow that could be impacted by vegetation management work on lines within habitat for this species. APS will not apply herbicide within 20 feet of Bebb’s willow. APS may prune or remove Bebb’s willow using chainsaw and hand tools if necessary for safe operation of the power lines after coordinating the need for this work with the Forest. 4. To protect agave species: a. Do not apply herbicide to agave plants, regardless of species b. During DSAP treatments, avoid treating any agave plant species that occur within the 10 foot radius of DSAP treatment poles. 5. To protect Tusayan rabbitbrush during DSAP treatment, coordinate with Kaibab NF biologist or botanist to determine if Tusayan rabbitbrush occurs in the treatment area at

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the DSAP pole located on Tusayan Field Office on the RD 01 power line near the junction of Highway 64 and NF road 305 (GPS coordinate: -112.130917 35.844980, in decimal degrees). 6. To protect Arizona bugbane during DSAP treatment, coordinate with Coconino NF biologist or botanist to determine if Arizona bugbane occurs in the treatment area at the DSAP pole located near Sterling Springs Fish Hatchery. If Arizona bugbane occurs in the treatment area, do no use herbicides for treatment around this pole. 7. To protect Ertter’s rose which is located near the SE 14 line at the confluence of West Fork Oak Creek with Oak Creek Canyon, implement the following conservation measures: a. Avoid DSAP treatment of Ertter’s rose if present within the treatment area. b. Do not apply herbicide to Ertter’s rose and within the vicinity of the area where Ertter’s rose occurs.

Eagle Conservation Measures 1. APS shall coordinate with Arizona Game and Fish Department annually to obtain updated bald and golden eagle nest locations. As part of this annual coordination, seek guidance from Arizona Game and Fish to determine any specific breeding areas that are likely to be active before or after the breading seasons provided below for bald and golden eagles. 2. Do not conduct work within 1 mile of the line of sight of an active golden eagle nest during the golden eagle breeding season from February 1 to July 15. 3. Do not apply dicamba within 1/4 mile of a golden or bald eagle nest. This herbicide is rated as class 2 in the predatory avian toxicity group. 4. Do not conduct work within ¼ mile of an active bald eagle nest during the bald eagle breeding season from December 1 to June 30.

Northern Goshawk Conservation Measures 1. Do not use dicamba within 300 feet of a northern goshawk post-fledging area. This herbicide is rated as Class 2 (highly toxic) in the Predatory Avian toxicity group. 2. Within northern goshawk PFAs, drive ATVs only on existing publically accessible roads during the breeding season (March 1 to September 30) and apply herbicide using backpack sprayers when vegetation is not accessible from the existing roads. 3. Do not conduct manual and mechanical vegetation treatments within a northern goshawk post-fledging area from March 1 to September 30 except under hazard and emergency conditions. If occupancy is unknown, assume the nest is active. If it is confirmed that there is no nesting, work may proceed.

Peregrine Falcon Conservation Measures 1. Do not use dicamba within 300 feet of a peregrine falcon post-fledging area. This herbicide is rated as Class 2 (highly toxic) in the Predatory Avian toxicity group. 2. When working within ¼ mile of peregrine falcon breeding area, drive ATVs only on existing publically accessible roads during the breeding season (March 15 to August 15)

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and apply herbicide using backpack sprayers when vegetation is not accessible from the existing roads. 3. Do not conduct manual and mechanical vegetation treatments within ¼ mile of an active peregrine falcon breeding area from March 15 to August 15 except under hazard and emergency conditions. If occupancy is unknown, assume the nest is active. If it is confirmed that there is no nesting, work may proceed.

Sonoran Desert Tortoise Conservation Measures To protect the Sonoran desert tortoise, the following conservation measures are to be applied on all APS power lines in Sonoran Desert Tortoise Habitat: 1. Designate a Field Representative to ensure compliance with the following conservation measures. 2. Develop a training program that trains the Field Representative in avoidance and proper tortoise handling, relocation, and reporting protocols. This Field Representative shall provide herbicide crews training on the tortoise protocols described below and shall be the contact for field crews if a tortoise is encountered during work operations. 3. Field crews shall attempt to avoid any tortoise found within the project area. If tortoise is found, attempt to delay operations until the tortoise has moved from the site and can be avoided. If the tortoise cannot be avoided, report the tortoise to the Field Representative and the Field Representative may remove the tortoise from the project site according to Arizona Game and Fish Department handling protocol. 4. Field crews shall conduct a search for tortoise under and around vehicles prior to moving vehicles. If a tortoise is found, follow conservation measure 3 above. 5. Field crews shall search under and around vegetation prior to spraying that vegetation for tortoise. If tortoise is found, follow conservation measure 3 above. 6. Do not apply dicamba within Sonoran desert tortoise habitat. Ensure that herbicide spray drift does not occur beyond the right-of-way by using herbicide sprays with coarse droplet sizes from a spray gun. 7. If a Sonoran desert tortoise is seen, note the date and location of the tortoise, and if possible, take a photo. If the tortoise is relocated, note the date, location found and where it was relocated to. 8. Field crews shall maintain clean project sites and remove all trash to avoid subsidizing Sonoran desert tortoise predator populations such as ravens which prey on young tortoise.

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Appendix F. Supplemental Information: Herbicides and Adjuvants (Including Thinvert)

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ThinVert and Other Adjuvants A key component of analysis in this EA has been the individual risk assessments developed by the Forest Service for each herbicide. Each risk assessment discusses the formulations analyzed for use in this project. These risk assessments were developed to document the process for determining the risk of using each herbicide generally, with worksheets provided to evaluate the risk at project level circumstances (such as application rate and application method). The risk assessments provide Forest Service officials with a summary of the most relevant information available to the use of herbicides. They are not comprehensive summaries of all the available information. This appendix incorporates by reference the 16 risk assessments available to date. Risk assessment can be accessed from the Forest Service wedsite at: https://www.fs.fed.us/foresthealth/protecting-forest/integrated-pest-management/pesticide- management/pesticide-risk-assessments.shtml.

As noted in Table F-1 below, the risk assessment preparation dates from 2000 through 2016. Regardless of the completion date, each risk assessment follows a set method for analyzing the information. The following process applies to the human risk assessment: . Describe use of the herbicide in Forest Service programs. This includes brand names of the registered herbicides, as well as the generally accepted application rates (assuming they are somewhat different from the permitted label rate but within those permitted under the label). . Describe the hazards as best presented in the literature available, including “open literature” cited by a number of commenters on the Invasive Plant DEIS (e.g., Journal of Pesticide Reform). . Describe potential exposure to workers, based on the proposed application methods, using two plausible exposure scenarios from normal application (from backpack spray, and from vehicle mounted boom spray), as well as a number of accidental exposure scenarios (wearing contaminated gloves, accidental spills on bare skin that includes hands, legs). Vehicle mounted boom spray is not proposed in this EA and therefore results from this evaluation would not be applicable. . Describe potential exposure to the general public, based on a number of possible scenarios, including direct accidental spray, walking through a sprayed area, eating contaminated vegetation, and drinking contaminated water. . Describe the Reference dose (RfD), which may have both an acute and a chronic measure. . Finally, a “hazard quotient” (HQ) is calculated by dividing the expected exposure by the RfD. A number less than one is considered below a level of concern. A number greater than one raises a concern, but may not pose a high risk if the length of the exposure is short term. An HQ greater than 10 raises a concern that would require further evaluation of the cause in order to avoid this scenario.

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Table F-1. Herbicide Risk Assessments Developed by the Forest Service

Active Ingredient Date Prepared Reference Pages Website Link

https://www.fs.fed.us/foresthealth Aminocyclopyrachlor September 27, 2012 SERA 2012 226 /pesticide/pdfs/Aminocyclopyrac hlor.pdf https://www.fs.fed.us/foresthealth Aminopyralid June 28, 2007 SERA 2007 231 /pesticide/pdfs/062807_Aminopy ralid.pdf https://www.fs.fed.us/foresthealth Chlorsulfuron November 21, 2004 SERA 2004a 180 /pesticide/pdfs/112104_chlorsulf. pdf https://www.fs.fed.us/foresthealth Clopyralid December 5, 2004 SERA 2004b 154 /pesticide/pdfs/120504_clopyralid .pdf Forest https://www.fs.fed.us/foresthealth 2,4-D September 30, 2006 245 Service 2006 /pesticide/pdfs/093006_24d.pdf https://www.fs.fed.us/foresthealth Dicamba November 24, 2004 SERA 2004c 179 /pesticide/pdfs/112404_dicamba. pdf https://www.fs.fed.us/foresthealth Fluroxypyr June 12, 2009 SERA 2009 218 /pesticide/pdfs/0521303a_fluroxy pyr.pdf https://www.fs.fed.us/foresthealth Glyphosate March 25, 2011 SERA 2011a 336 /pesticide/pdfs/Glyphosate_SER A_TR-052-22-03b.pdf https://www.fs.fed.us/foresthealth Imazapic December 23, 2004 SERA 2004d 110 /pesticide/pdfs/122304_Imazapic. pdf https://www.fs.fed.us/foresthealth Imazapyr December 16, 2011 SERA 2011b 213 /pesticide/pdfs/Imazapyr_TR- 052-29-03a.pdf https://www.fs.fed.us/foresthealth Isoxaben October 26, 2000 SERA 2000 141 /pesticide/pdfs/Isoxaben_RA.PDF https://www.fs.fed.us/foresthealth Metsulfuron methyl December 9, 2004 SERA 2004e 152 /pesticide/pdfs/120904_Metsulfur on.pdf https://www.fs.fed.us/foresthealth Picloram September 29, 2011 SERA 2011c 293 /pesticide/pdfs/Picloram_SERA_ TR-052-27-03a.pdf https://www.fs.fed.us/foresthealth Sulfometuron methyl December 14, 2004 SERA 2004f 163 /pesticide/pdfs/121404_Sulfomet uron.pdf https://www.fs.fed.us/foresthealth Tebuthiuron September 22, 2016 SERA 2016 206 /pesticide/pdfs/Tebuthiuron.pdf https://www.fs.fed.us/foresthealth Triclopyr May 24, 2011 SERA 2011d 267 /pesticide/pdfs/seratr01_43_08_0 4.pdf

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The outline for the ecological risk to animals is similar, except it includes specific information about the toxicity of each herbicide to various species of animals where information is available, as well as terrestrial and aquatic plants. The exposure is also evaluated based on a number of plausible scenarios, which include direct spray, the animal ingesting herbicide from vegetation or water. A hazard quotient is calculated by dividing the exposure by the reference dose (human risk assessment or other marker for animals [NOEL]). Plant risks are also evaluated, although herbicides are intended to kill plants. Exposure scenarios in the risk assessments include accidental direct spray, drift during application, runoff, wind movement of soil containing the herbicide, and irrigation water. Hazard quotients are developed using the Lowest Observable Effect Concentration (LOEC) provided by available data. Although not a comprehensive review of all study information about the respective herbicide, each assessment uses sources of information that are evaluated, along with any caveats that may apply to specific information/studies. In addition, the EPA includes peer reviewed studies when possible and continues to update the information as new data is shown to be relevant. When information is not available, the risk assessments state this and provide, if possible, inferences of risk from the available information.

Impurities, Adjuvant and Inert ingredients in Herbicide Formulations During commercial synthesis of some pesticides, byproducts can be produced and carryover into the product eventually formulated for sale. Occasionally byproducts or impurities are considered toxicologically hazardous, and their concentrations must be limited so that potential exposures do not exceed levels of concern (Felsot 2001).

The proprietary nature of herbicide formulations limits the understanding of the risks posed by inert ingredients and adjuvant in herbicide formulations. Unless the compound is classified as hazardous by the EPA, the manufacturer is not required to disclose its identity. It could be suggested that the inert ingredients in these herbicides are not toxic, or their toxicity would be reported to the EPA. EPA is increasing the testing requirements for inert ingredients, but in many cases, the inert ingredients currently in use have not been tested rigorously and their toxicity is not well characterized. Studies on the toxicity of technical grade formulations, which often contain the inert ingredients, account for the toxicity of the inert ingredients and these studies show that the use of herbicides by the Forests would not expose workers or the public to levels of concern.

Many herbicide formulations contain dyes. The use of dyes can be beneficial in that they can color vegetation, making it less likely for an individual to inadvertently or intentionally consume contaminated vegetation. The presence of a dye in herbicide formulations may also make it easier for workers to see when they have been contaminated and allow for prompt remedial action. Dyes may also pose risks to humans and wildlife. The most common dyes used with herbicides are Milori blue, Heliogen blue, Lithol rubine, and Sico fast orange. Little information is available on the toxicity of the majority of dyes used in the industry. There has been considerable concern over the carcinogenic potential of less used dyes Rhodamine B and Basic Violet 3. Rhodamine B is a colorant used in some commercial herbicide dyes. Basic Violet 3 is the colorant used in Colorfast Purple. Both have been used with glyphosate. The Forest Service completed a risk assessment of Rhodamine B and Basic Violet 3. Both evaluations suggest that use of these dyes does not pose an unacceptable health risk. Dyes that are part of the registered

279 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests formulations (e.g. in Arsenal and Roundup) have been evaluated with the product for risk. Other dyes may be added at the time of application to make the area of application more visible, without substantially changing the risk (in fact reducing the risk by making the place of application more visible).

Surfactants are also commonly used in herbicide formulations. Surfactants are added to herbicides to improve herbicide mixing and the absorption or permeation of the herbicide into the plant. Like dyes and other inert ingredients, there is often limited information on the types of surfactants used and the toxicity of surfactants, especially since the industry considers the surfactant to play a key role in the effectiveness of the herbicide formulations. Most knowledge of surfactants is kept as proprietary information and not disclosed. This is not always the case. A review that attempted to assess the effects of surfactant formulations on the toxicity of glyphosate (SERA 1997b) reported that the toxicity of glyphosate alone was about the same as the toxicity of the glyphosate and surfactant mixed, and greater than the toxicity of the surfactants alone. A more recent risk assessment (SERA 2003a) of glyphosate notes that the surfactant POEA has a pronounced effect on the acute lethal potency of glyphosate to aquatic systems. It is assumed that given the level of review of the risk assessments, the toxicological studies performed on herbicide formulations (which contain the inert ingredients and surfactants) portray the toxicity and risks posed by the surfactant to humans and other elements of the environment. The following lists identifies the herbicide proposed for use and the available information regarding adjuvants and other ingredients.

Under FIFRA, U.S. EPA is responsible for regulating both the active ingredients (a.i.) in pesticide formulations as well as any other chemicals that may be added to the formulation. As implemented, these regulations affect only pesticide labeling and testing requirements. The term inert was used to designate compounds that are not classified as active ingredient on the product label. While the term inert is codified in FIFRA, some inerts can be toxic, and the U.S. EPA now uses the term Other Ingredients rather than inerts (http://www.epa.gov/opprd001/inerts/). For brevity, the following discussion uses the term inert, recognizing that inerts may be biologically active and potentially hazardous components.

Thinvert (Waldrum Specialties, Inc. 2002 - http://www.waldrumspecialties.com/thinvert/)

The THINVERT Application System combines an innovative nozzle design and an effective spray fluid into a system which allows the effective application of herbicides, insecticides, fungicides, and plant growth regulators at low spray volumes. It maximizes spray effectiveness, while minimizing off-target movement by reducing spray drift and virtually eliminating spray evaporation.

Spray drift is reduced by the THINVERT nozzles which make small uniform droplets, and by the thin invert emulsion which reduces the number of small droplets formed. THINVERT forms a more stable droplet, which does not readily break up into finer droplets as water droplets do when released into the atmosphere. THINVERT carriers are usually only slightly more viscous than typical oil carriers.

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Spray evaporation is virtually eliminated, because each THINVERT spray droplet is coated with a thin film of oil which does not evaporate while falling through the air to the spray target. Water droplets of the size produced by the THINVERT nozzle will lose much of their diameter while falling from aerial application heights, making them more susceptible to off-target movement. This effect is magnified under low humidity conditions.

McWhorter's work at the USDA Applied Technology Research Unit at Stoneville, MS (see attachments) indicates that paraffinic oils are desirable carriers for many pesticide sprays. THINVERT technology utilizes the advantages of oil sprays, but uses water to fill the inside of the spray droplet, reducing the total amount of oil required but keeping the characteristics of an oil spray. Conventional emulsions have a continuous water phase on the outside of the droplet, which is subject to evaporation, while THINVERT sprays have a continuous oil phase on the outside of the spray droplet. In addition, water-miscible materials can be readily dispersed in the water phase of THINVERT, while oil-miscible products will remain in the THINVERT oil phase. Some compatibility problems of spray combinations may be reduced by using THINVERT technology.

THINVERT sprays are effective at low spray volumes because the droplets are small but uniform, and efficiently cover plant surfaces. Spray droplets from THINVERT aerial nozzles are in the size range of 300 to 500 micrometers, although larger or smaller droplets may be produced by altering the nozzle orifice size.

Current THINVERT commercial formulations use a non-phytotoxic paraffinic oil, which is colorless and odorless. However, vegetable oils, methylated vegetable oils, aliphatic oils, and other petroleum oils may be used.

The Proposed Action would involve the use of ThinVert and other adjuvants. ThinVert use would include two formulations: ThinVert Concentrate and Ready to Use (RTU). According to the Arborchem Products Co. SDS for ThinVert Concentrate and RTU, hazard identification includes eye, skin, inhalation, and ingestion hazards. Label requirements provided by Waldrum Specialties, Inc., for both are consistent with this and also identify these hazards and suggestive measures for avoidance.

Due to the proprietary nature of herbicide formulations, the understanding of risk from inerts and adjuvants is limited and manufacturers are not required to disclose the identity of compounds in which the EPA has not classified as hazardous (Forest Service 2005). Some toxicity studies completed for technical grade formulations which contain inerts, may account for the toxicity of the inerts. These studies do not report human health concerns at the levels of herbicide use proposed by the forests in this project (USDA 2005). However, often times the inerts have not been thoroughly tested and their toxicity is not well known. The EIS for Integrated Treatment of Noxious or Invasive Weeds on the Coconino, Kaibab, and Prescott national forests concludes that none of the impurities, surfactants, adjuvants, inert ingredients and dyes will have significant adverse effects on human health in the context in which they would be used on the National Forest System lands (Forest Service 2012). Additionally, the Environmental Analysis for the Implementation of the Apache-Sitgreaves National Forests Integrated Forest-Wide Noxious or Invasive Weed Management Program, lists several adjuvants to be used and protection measures for restrictions in riparian areas.

281 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

The Propose Action includes several measures that minimize the chance of drift or runoff of herbicides. Herbicides are only applied in a targeted manner to individual plants or the area for DSAP (spot application) and are not applied in a broadcast manner. Herbicides are not mixed on site virtually eliminating the chance of spill. APS proposes to use the carrier, Thinvert, as part of most herbicide blends which allows for ultra-low volume application of herbicides with herbicides well below the recommended concentration. Thinvert is a combination of paraffinic oil blended with an emulsifier, surfactant, and water to form a thin invert emulsion (fine droplets of water in an outer layer of oil) that is applied with specialized ultra-low volume nozzles (Lentz 2014). Spray evaporation and drift is minimized because each spray droplet is coated with a thin film of oil which does not evaporate while falling, reducing susceptibility to off-target movement (Waldrum Specialties 2016). Studies of this application method indicate that using this treatment approach allows for high percentage of control, minimal under story damage, and no off-target drift (Lentz 2008).

Aminocyclopyrachlor Adjuvants and Other Ingredients Other Ingredients (Inerts) As discussed in Section 2.2.2.130, the MSDS for DuPont™ Method® 50 SG and DuPont™ Method® 240SL do not identify inerts in the formulations, and hazardous inerts are not specified on the product labels. As discussed previously, essentially parallel toxicity studies are available for technical grade aminocyclopyrachlor, DuPont™ Method® 50 SG, and DuPont™ Method® 240SL for acute oral toxicity (Section 3.1.4), skin irritation (Section 3.1.11.1), skin sensitization (Section 3.1.11.2), eye irritation (Section 3.1.11.3), and dermal toxicity (Section 3.1.12). These studies do not indicate that the biological activity of the aminocyclopyrachlor formulations is substantially different from technical grade aminocyclopyrachlor. This lack of differences in biological activity suggests that the inerts in DuPont™ Method® 50 SG and DuPont™ Method® 240SL do not contribute substantially to the toxicity of the formulations. This comparison is limited in that the parallel studies cover only acute effects, which is common with most pesticides and their formulations.

Adjuvants Adjuvants, including nonionic surfactants, methylated seed oils, or vegetable oil concentrates are recommended for applications of aminocyclopyrachlor. These adjuvants are commonly used with herbicides.

Product labels recommend the use of nonionic surfactants at a concentration of 0.25% v/v or the use of methylated seed oil or vegetable oil at a concentration of 1% (v/v). Adjuvants enhance the efficacy of aminocyclopyrachlor by increasing its absorption in plants (Bukun et al. 2009; Bukun et al. 2010). There is no information regarding the impact of adjuvants in combination with aminocyclopyrachlor or aminocyclopyrachlor formulations on humans or other mammals.

Although methylated seed oils and vegetable oil concentrates are somewhat vague terms, there is no basis for asserting that these adjuvants are likely to enhance the toxicity of aminocyclopyrachlor to humans. Several seed and vegetable oils are approved food additives

30 Table and section references in Appendix F apply to the source document unless otherwise noted.

282 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

(Clydesdale 1997); moreover, many vegetable and fruit oils are classified as minimal risk inerts (U.S. EPA/OPPTS 2009). Nonionic surfactants comprise a large and complex group of materials (e.g., Kosswig 1994). In the absence of mammalian studies regarding the potential toxicity of aminocyclopyrachlor in combination with various nonionic surfactants, it is not possible to generalize about potential hazards to human health.

Aminopyralid Inerts and Adjuvants As noted in Section 2.2 of the risk assessment, the Milestone formulations covered in this risk assessment contain only the triisopropanolamine (TIPA) salt of aminopyralid and water. Inerts are classified by the U.S. EPA as inerts of toxicological concern (List 1), potentially toxic compounds (List 2), inerts of unknown toxicity (List III), inerts of minimal concern (List 4A), and other compounds that are not likely to be of concern based on use patterns (4B). A listing of all inerts is available at http://www.epa.gov/opprd001/inerts/lists.html. Triisopropanolamine (CAS No. 122-20-3) is classified by the U.S. EPA as a List 3 inert. In other words, the U.S. EPA judges that the available information on TIPA is not sufficient to determine whether or not the use of TIPA in pesticides poses a potential risk.

Consistent with the position taken by the U.S. EPA on the classification of TIPA as a List 3 inert, relatively little information is available on the toxicity of TIPA. Material Safety Data Sheets (MSDS) (e.g., ScienceLab 2005) are available and a very brief overview of the toxicity of TIPA is available from the World Health Organization (WHO 1997). The most detailed compilation on TIPA encountered in the literature is the summary in the Hazardous Substances Databank (HSDB 2003), a compendium of chemical information profiles maintained by the National Library of Medicine.

On the MSDS from ScienceLab (2005), the rat LD50 for TIPA is listed as 4730 mg/kg. Following the categorization system used by the U.S. EPA in human health risk assessments, TIPA would be classified marginally as Category III (Caution), which applies to compounds with oral LD50 values in the range of >500 to 5,000 mg/kg (SERA 2007A, Table 3-2). Following the classification system used by the U.S. EPA in ecological risk assessments, TIPA would be classified as Practically Nontoxic because the oral LD50 is >2000 mg/kg (see SERA 2007A, Table 4-1). The HSDB (2003) summary of TIPA indicates that this compound is approved as an indirect food additive for use only as a component of adhesives. TIPA, however, is not listed as an approved food additive in Clydesdale (1997).

The MSDS for TIPA also classifies TIPA as a moderate eye irritant that may cause corneal damage (ScienceLab 2005) and this classification is also given in the HSDB (2003) summary. The WHO (1997) summary on TIPA does not give a categorization for eye irritation but does indicate that TIPA can cause corrosive effects on the eyes including pain, redness, severe deep burns, loss of vision. The MSDS also indicates that TIPA is a moderate skin irritant.

Two subchronic studies on TIPA have been conducted: a 2-week drinking water toxicity study in rats (McCollister et al. 1981) and a 13-week dietary toxicity study in dogs (Mullin 1987). These studies have not been reviewed by the U.S. EPA in the human health risk assessment for the registration of aminopyralid (U.S. EPA/OPP-HED 2005). Summaries of these studies, however,

283 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests are contained in the 90-day subchronic study of the GF-871 formulation by Stebbins and Dryzga (2004).

In the subchronic drinking water study in rats by McCollister et al. (1981), the animals were dosed with 100, 300, 600, 1200 or 2000 milligrams TIPA/kg bw for 2 weeks. The only effect was increased kidney weight (but no organ pathology or changes in BUN values) at doses of 300 mg/kg bw and higher. In the 13-week dietary study by Mullin (1987), dogs were exposed to TIPA in the diet at doses equivalent to 0, 16.8, 71.2, and 272 mg TIPA/kg body weight/day for males and 0, 19.7, 78.3, and 288 mg/kg for females. The summary of this study by Stebbins and Dryzga (2004) indicates that: There were no effects that were considered compound related or biologically significant in any of the parameters measured (Stebbins and Dryzga 2004, p. 15).

It is not clear that TIPA plays a role in any of the toxicity studies conducted on the GF-871 formulation. As noted in Section 3.1.5.1, the 90-day toxicity study in rats by Stebbins and Dryzga (2004) is the only subchronic mammalian toxicity study that used the GF-871 formulation. Expressed as TIPA equivalents, the doses in this dietary study were 0, 92, 241, and 482 mg TIPA/kg bw/day. Based on the rat drinking water study by Mullin (1987) on TIPA, increased kidney weights in rats could have been expected in the Stebbins and Dryzga (2004) study. As noted in Appendix 3, however, increased kidney weights were noted only at the highest dose and the increases were slight – 2.4% in males and 3% in females – and were not statistically significant.

Several acute studies are available on the GF-871 formulation. As noted in Section 3.1.4, lacrimation and cloudy eyes have been noted in an acute oral limit test with the TIPA salt formulation of aminopyralid at a dose of 5000 mg formulation/kg bw (Wilson et al. 2003) and this effect was not noted in the acute oral limit test of technical grade aminopyralid at a dose of 5000 mg a.e./kg bw (Brooks 2001a). Conversely, technical grade aminopyralid powder caused severe and persistent eye damage in a standard eye irritation assay (Brooks 2001b) whereas the GF-871 formulation with TIPA caused only minimal eye irritation (Brooks and Radtke 2002a). Lastly, the skin irritation studies on both technical grade aminopyralid (Brooks 2001b) and the GF-871 formulation (Brooks and Radtke 2002b) noted little skin irritation. As discussed in Section 3.1.11.1, however, the formulation study did note slight erythema that was not seen in the study on technical grade aminopyralid.

Thus, it is not clear if any of these differences in the studies on technical grade aminopyralid and the GF-871 formulation can be associated with the presence of TIPA in the formulation. The ocular effects in the oral study of the formulation (Wilson et al. 2003) are unusual. Since the GF- 871 formulation consists of 41.9% aminopyralid TIPA, the 5000 mg formulation/kg bw corresponds to a dose of about 2095 mg aminopyralid TIPA/kg bw. Based on the molecular weights of aminopyralid TIPA (398.27 g/mole) and TIPA (191.27 g/mole) (Table 2), the formulation dose in the Wilson et al. (2003) study corresponds to a dose of about 1000 mg TIPA/kg bw. The available toxicity studies on TIPA, discussed above, are all substantially below this dose of 1000 mg TIPA/kg bw. It is unclear if the ocular effects observed in the study by Wilson et al. (2003) are attributable to TIPA or a simply an aberration. That the ocular effects are attributable to aminopyralid or TIPA is unclear. As detailed in Section 3.1.2.5, the study by Wilson et al. (2003) is the only oral study on aminopyralid in which ocular effects were noted

284 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona and several other comparable studies have been conducted in which these ocular effects were not noted.

Chlorsulfuron Inerts and Adjuvants The formulation of chlorsulfuron used by the Forest Service contains materials other than chlorsulfuron that are included as adjuvants to improve either efficacy or ease of handling and storage. The identity of these materials is confidential. The inerts were disclosed to the U.S. EPA (Armstrong 1988a; Brennan 1999a,b) and were reviewed in the preparation of this risk assessment. All that can be disclosed explicitly is that none of the additives are classified by the U.S. EPA as toxic. As noted in Section 2.2, the manufacturers recommend that chlorsulfuron formulations be mixed with a non-ionic surfactant. There is no published literature or information in the FIFRA files that would permit an assessment of toxicological effects of chlorsulfuron mixed with surfactant.

Clopyralid Inerts and Adjuvants As indicated in Section 2, the commercial formulation of clopyralid used by the Forest Service is Transline, which contains clopyralid as the monoethanolamine salt – i.e., monoethanolamine is considered part of the active ingredient. Transline also contains isopropyl alcohol and polyglycol as adjuvants.

Both monoethanolamine and isopropyl alcohol are approved food additives (Clydesdale 1997), and there is no evidence to assert that these compounds will materially impact the risks associated with the use of clopyralid.

The other inert in Transline is Polyglycol 26-2 (Section 2.2). This compound is classified by the U.S. EPA (2003) as a List 3 inert. In other words, there is insufficient information to categorize this compound as either hazardous (Lists 1 or 2) or non-toxic (List 4). Notwithstanding this classification, surfactants such as Polyglycol 26-2 are surface active agents that can disrupt cellular membranes and lead to a number of different adverse effects (e.g., Warisnoicharoen et al. 2003). In an in vitro study on oxidative phosphorylation in submitochondrial particles derived from a marine algae, Oakes and Pollak (1999) noted that Polyglycol 26-2 inhibited oxidative function in the submitochondrial preparations at a concentration of about 0.01%. While this study clearly indicates that Polyglycol 26-2 will impact mitochondrial function in vitro, the implications for potential effects in humans at plausible levels of exposure are not apparent.

As noted in Section 2.2, publically available information at the web site of the Northwest Coalition for Alternatives to Pesticides (http://www.pesticide.org/FOIA/clopyralid.html) indicates that the only other inerts in Transline is water. As noted above, the toxicity of a formulated product that is comparable to Transline appears to be comparable to that of technical grade clopyralid (Sections 3.1.4, 3.1.11, and 3.1.13).

285 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

2, 4, D Inerts and Adjuvants As summarized in Table 2-4, several inert ingredients are listed for certain formulations of 2,4-D acid, esters, and salts. The known toxicity information for these inerts, as well as U.S. EPA’s pesticide inert list classification are summarized in Table 3-4.

Table 3-4: Summary of select toxicity information for inert ingredients in 2,4-D formulations. Inert ingredient Toxicity Information Reference EPA Pesticide [CAS#] Inert List Classification1 Dimethylamine Rat oral LD50: 698 mg/kg; OSHA, 1996a 3 [000124-40-3] Mouse oral LD50: 316 mg/kg; Guinea Pig oral LD50: 240 mg/kg Rat 6 hr inhalation LC50: 4540 ppm Corrosive to eyes/skin/respiratory tract; Chronic exposure can lead to conjunctivitis, dermatitis and lung damage Ethylenediamine Mouse oral LD50: 240 mg/kg; Fisher Scientific, 4B tetraacetic acid Corrosive to eyes/skin/gastrointestinal tract; 2005 [60-00-4] respiratory tract irritant; Prolonged exposure may cause respiratory tract inflammation, kidney damage, muscle cramps, bone marrow depression and generalized allergic reaction. Ethylene Glycol Human Chronic Oral RfD: 2 mg/kg/day; U.S. EPA 1989b 3 [ 000107-21-1] basis is chronic oral rat NOEL: 200 mg/kg/day; LOAEL: 1000 mg/kg/day on basis of kidney damage; Teratogenic in mice; reproductive toxin in rats and mice at doses causing maternal toxicity; RfD is protective of these effects. Isopropanol Acute exposure, humans: eye and mucous OSHA 1996b 4B [00067-63-0] membrane irritation; may cause in- coordination and narcosis. Ingestion causes gastrointestinal pain, nausea, vomiting, and may cause coma and death. Chronic exposure causes sensitization and eczema in rare cases.

Rat oral LD50: 5,045 mg/kg Rabbit dermal LD50: 12,850 mg/kg Kerosene [8008- Harmful or fatal if swallowed. Harmful if JT Baker 2003 3 20-6] inhaled. Causes Irritation to skin, eyes and respiratory tract. Central nervous system depressant.

Rat oral LD50: >500 mg/kg; Guinea pig: Severe skin irritation in Draize test at 500 mg

286 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Inert ingredient Toxicity Information Reference EPA Pesticide [CAS#] Inert List Classification1 Petroleum 13-week rat gavage study LOAEL: 500 ExxonMobil 2 distillates mg/kg, associated with kidney damage in Chemical [64742-47-8] males and liver damage in males and Company 2001 females; also for males: significantly elevated platelet count, significantly decreased serum glucose. Polyglycol 26-3 NOTE: This listing, taken from the msds for Esteron®9 (Table 2-4), may be in error, as (ethylene oxide) the given CAS# and name do not appear on EPA’s list of pesticide inerts. [69020-39-6] Triisopropanolamine Mouse oral LD50: 2520 mg/kg ScienceLab.com 3 [000122- Moderate skin and eye irritant; 2005 20-3 1 The United States Environmental Protection Agency, Office of Pesticide Programs established a policy on inert ingredients in 1987: 52 FR 13305, Inert Ingredients in Pesticide Products Policy Statement (04/22/87)). This policy established four categories of toxicological concern for the inert ingredients in existence at that time. In 1989, List 4 "Inerts of Minimal Concern" was subdivided into List A and List 4B (see 54 FR 48314, Inert Ingredients in Pesticide Products; Policy Statement; Revision and Modification List (11/22/89)). List 1: inert ingredient are known to be toxic, and pesticides must include the label statement "This product contains the toxic inert ingredient (name of inert)."; List 2: Potentially Toxic Other Ingredients/High Priority for Testing inerts; List 3: inerts of “unknown toxicity” which have no basis for listing in the other categories; List 4A: Minimal risk inert ingredients; List 4B: EPA has sufficient information to reasonably conclude that the current use pattern in pesticide products will not adversely affect public health or the environment. This information is available on the internet at: http://www.epa.gov/opprd001/inerts/lists.html. The USEPA/OPP classifications given here are listed as being current as of August 2004.

Dicamba Inerts and Adjuvants As noted in Section 2.2, the identity of inerts in both Banvel and Vanquish has been disclosed to the U.S. EPA (Velsicol Chemical Corp 1961,1984; Bryant 1995a,b) and this information has been reviewed as part of this risk assessment. This information, however, is protected under FIFRA (Section 10). Other than to state that no apparently hazardous materials have been identified, which is consistent with the MSDS for both Banvel and Vanquish (C&P Press 2003), the information on the inerts in these formulations cannot be detailed.

Fluroxypyr Inerts and Adjuvants The identities of inerts in pesticide formulations are generally considered trade secrets and need not be disclosed to the general public. Nonetheless, all inert ingredients as well as the amounts of the inerts in the formulations are disclosed to and reviewed by the U.S. EPA as part of the registration process. Some inerts are considered potentially hazardous and are identified as such on various lists developed by the federal government and state governments. The identity of these inerts must be listed on the Material Safety Data Sheet for the formulation. As summarized in Table 1, the fluroxypyr formulations considered in this risk assessments contain two listed inerts: naphthalene and 1-methyl-2-pyrolidinone.

Naphthalene is both an inert in some formulations as well as active ingredient in other formulations. As detailed in U.S. EPA/OPP (2008b), naphthalene is registered as a pesticide used as an insecticide and insect repellant. For example, naphthalene is the active ingredient in mothballs.

287 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

1-Methyl-2-pyrolidinone is not a registered insecticide. It is a solvent used in pesticide formulations as well as in various chemical operations related to the production of petroleum and plastics (U.S. EPA/OPP 2006d). Both naphthalene and 1-methyl-2-pyrolidinone are approved for use in pesticide formulations in both food crop and nonfood crop products. In order for an inert to be used in pesticide formulations applied to food crops, pesticide tolerances must be established or a waiver for tolerances must be granted by the EPA. Because naphthalene is a registered pesticide, pesticide tolerances are established (U.S. EPA/OPP 2008b). The toxicology data on 1-methyl-2-pyrolidinone were reviewed by the EPA, and the requirement for pesticide tolerances was waived (U.S. EPA/OPP 2006d). In other words, the EPA determined that the use of 1-methyl-2-pyrolidinone in pesticide formulations applied to food crops or other vegetation does not constitute an unreasonable risk. Specifically, the EPA concludes:

The EPA assessments on naphthalene are extensively documented in the Reregistration Eligibility Decision (RED) for naphthalene (U.S. EPA/OPP 2008b) as well as related EPA assessments of naphthalene (U.S. EPA 1990, 1998). These assessments are consistent with the ATSDR review of naphthalene (ATSDR 2005). While the literature on 1-methyl-2-pyrolidinone is less extensive than that on naphthalene, the inert reassessment made by U.S. EPA/OPP (2006d) is well-documented with information from the open literature as well as studies submitted to the EPA by pesticide registrants.

Glyphosate Adjuvants and Other Ingredients General Considerations In most Forest Service pesticide risk assessments, the active ingredient is the agent of primary concern, and a discussion of other ingredients is limited to this subsection of the risk assessment.

The handling of other ingredients in the risk assessment of glyphosate, however, is much different. The surfactants used in many glyphosate formulations may be of equal or greater concern to the risk assessment than the toxicity of glyphosate itself. Consequently, as justified by the available data, most subsections of the current Forest Service risk assessment on glyphosate are subdivided into discussions of the toxicity of glyphosate, the toxicity of glyphosate formulations, and/or the toxicity of the surfactants.

While a number of surfactants may be used in conjunction with glyphosate, the most important class of surfactants is the POEA (polyoxyethyleneamine) group. A specific POEA surfactant, designated as MON 0818, was originally used with glyphosate in Roundup formulations at a concentration of 15% (Wan et al. 1989). The surfactant was a complex mixture consisting of a tallow amine surfactant at a concentration of 75% and other unidentified components. POEA is not proposed for use by APS and therefore assessment of POEA is not applicable.

Given the lack of specific information about the composition of the surfactants used by the various suppliers of glyphosate formulations as well as any differences in surfactants which might be used by a single supplier for different formulations, potential differences between surfactant-containing formulations of glyphosate limit the hazard identification for some toxic effects.

288 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

Imazapic Inerts and Adjuvants Plateau and Plateau DG, the commercial formulations of imazapic used by the Forest Service, contain materials other than imazapic that are included as adjuvants to improve either efficacy or ease of handling and storage. The identity of these materials is confidential. The additives were disclosed to the U.S. EPA (American Cyanamid Company 1998b,c) and were reviewed in the preparation of this risk assessment. All that can be disclosed explicitly is that none of the additives is classified by the U.S. EPA as toxic. This is consistent with the MSDS for Plateau (American Cyanamid Company 1997) that does not disclose the occurrence of toxic inerts in the formulation. Because none of the studies in experimental animals specifically tested Plateau or Plateau DG as the subject compound, a comparison of relative toxicity of technical imazapic and Plateau formulations cannot be used to assess the potential for inerts to affect the toxicity. Note that the identity of the inert ingredients in several herbicides has been obtained by the Northwest Coalition for Alternatives to Pesticides (NCAP) under the Freedom of Information Act and this information is publicly available at http://www.pesticide.org/FOIA/inertslinks.html. Imazapic, however, is not among the herbicides whose inert ingredients are listed by NCAP.

As reviewed by Levine (1996), testing requirements for pesticide inerts that have been used as additives or adjuvants for many years are minimal, and the scarcity of information on the toxicity of inert ingredients in pesticide formulations is a general problem in many pesticide risk assessments. For new inerts, the U.S. EPA does require more extensive testing (Levine 1996).

Imazapyr Adjuvants and other Ingredients Information provided by the U.S. EPA/OPP on all of the inerts used in imazapyr formulations was reviewed in the previous Forest Service risk assessment (SERA 2004a). Specific notes are included in Appendix 1 concerning those toxicity studies in which information on inerts is specified. This information, however, is considered proprietary under FIFRA. Other than to state that no apparently hazardous materials have been identified, this information cannot be disclosed in detail.

All of the technical formulations of imazapyr covered in this risk assessment involve the isopropylamine or isopropanolamine salts of imazapyr. Little toxicity data are available for these compounds. Isopropanolamine is classified in U.S. EPA (2007b) as a List 3 inert. These are compounds that the U.S. EPA cannot classify as hazardous or non-hazardous based on the available information. Isopropyl alcohol, isopropylamine, and numerous other derivatives of isopropanol are used as food additives and classified as GRAS (generally recognized as safe) compounds (Clydesdale 1997). Isopropyl alcohol is classified as a List 4B inert, and isopropanolamine as well as a number of related compounds are classified by U.S. EPA as List 3 inerts (U.S. EPA/OPP 2007).

The Northwest Coalition for Alternatives to Pesticides (NCAP) obtained information on the identity of the inerts in Arsenal AC from U.S. EPA, under the Freedom of Information Act. This listing is no longer posted on the NCAP web site; however, the information was reviewed in the SERA (2004a) risk assessment. The only inert other than water listed at NCAP site was glacial acetic acid (CAS No. 64-19-7). Dilute acetic acid is an approved food additive and is also

289 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests classified as a GRAS compound (Clydesdale 1997). Acetic acid is a major component of vinegar and is a List 4B inert (U.S. EPA/OPP 2003).

Adjuvants Adjuvants including nonionic surfactants, methylated seed oils, or vegetable oil concentrates are recommended in both terrestrial and aquatic applications of imazapyr. Most product labels recommend the use of a nonionic surfactant at a concentration of at least 0.25% v/v and some formulations recommend concentrations of up to 1% v/v. Although the use of adjuvants may enhance the efficacy of imazapyr, there is no information regarding the impact of adjuvants in combination with imazapyr or imazapyr formulations on humans or other mammals.

Methylated seed oils and vegetable oil concentrates are somewhat vague terms, but there is no basis for asserting that these adjuvants are likely to enhance the toxicity of imazapyr to humans. Several seed and vegetable oils are approved food additives (Clydesdale 1997); moreover, many vegetable and fruit oils are classified as minimal risk inerts (U.S. EPA/OPPTS 2009). Nonionic surfactants comprise a large and complex group of materials (e.g., Kosswig 1994). In the absence of mammalian studies regarding the potential toxicity of imazapyr in combination with various nonionic surfactants, it is not possible to generalize about potential hazards to human health. As discussed further in the ecological risk assessment, some nonionic surfactants are much more toxic than imazamox to aquatic species (Section 4.1.3.5).

Isoxaben Inerts Gallery 75, the commercial formulation of isoxaben used by the Forest Service, contains materials other than isoxaben. Two inerts are listed on the MSDS for Gallery 75 (C&P Press 1999b): kaolin and crystalline silica which is one of the components in kaolin. The U.S. EPA (1998) lists kaolin as a List 4A inert. List 4A inerts are those classified by the U.S. EPA as posing minimal risk (U.S. EPA 1995). Crystalline silica, when inhaled in the form of quartz or cristobalite, is classified by IARC as a human carcinogen (Farrar 2000). No discussion of the possible risks associated with exposure to crystalline silica as a component of kaolin has been encountered in the literature.

No inerts other than kaolin and crystalline silica are listed on the MSDS for Gallery 75 (C&P Press 1999b). This indicates that no other compounds that are classified as toxic under 29 CFR 1910.1200 are contained in this formulation.

Metsulfuron Methyl Inerts and Adjuvants Escort, the commercial formulation of metsulfuron methyl used by the Forest Service, contains materials other than metsulfuron methyl that are included as adjuvants to improve either efficacy or ease of handling and storage. The Northwest Coalition for Alternatives to Pesticides (NCAP) has obtained information on the identity of the inerts in Escort from U.S. EPA under the Freedom of Information Act and has listed this information on the NCAP web site (http://www.pesticide.org/FOIA/clopyralid.html). The inerts listed on this web site are sodium naphthalene sulfonate-formaldehyde condensate, mixture of a sulfate of alkyl carboxylate and sulfonated alkyl naphthalene (sodium salt), polyvinyl pyrrolidone, trisodium phosphate, and

290 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

sucrose. Both trisodium phosphate (CAS No. 7601-54-9) and sucrose (CAS No. 57-50-1) are classified by the U.S. EPA as List 4 inerts and therefore, are generally recognized as safe compounds and are approved as food additives (U.S. EPA 2003, Clydesdale 1997). There is no evidence to assert that these compounds will materially impact the risks associated with the use of metsulfuron methyl. Polyvinyl pyrrolidone (CAS No. 88-12-0) is classified as a List 3 inert (U.S. EPA 2003). In other words, there is insufficient information to categorize this compound as either hazardous (Lists 1 or 2) or non-toxic (List 4). Sodium naphthalene sulfonateformaldehyde condensate and the mixture of a sulfate of alkyl carboxylate and sulfonated alkyl naphthalene (sodium salt) were not identified in the EPA Inert List (U.S. EPA 2003). Other naphthalene derivatives identified on the EPA Inert List are classified as List 3 or List 4; no naphthalene derivatives are classified as List 1 or List 2 inerts (U.S. EPA 2003). Thus, there is insufficient information available to assess the impact of either polyvinyl pyrrolidone or the naphthalene derivatives on the risks associated with the use of metsulfuron methyl. However, as noted above, the toxicity of a formulated product that is comparable to Escort appears to be comparable to that of technical grade metsulfuron methyl (Sections 3.1.4, 3.1.11, and 3.1.13). Therefore, there is no plausible basis for asserting that these inerts are present in Escort in toxicological amounts. Although the identity of inerts has been disclosed, the quantity of the inert agents in Escort is confidential and cannot be disclosed. The amount of each inert agent in Escort was disclosed to the U.S. EPA (Du Pont 1985b,c) and reviewed in the preparation of this risk assessment.

As noted in Section 2.2, the manufacturer recommends that Escort be mixed with a surfactant for application. There is no published literature or information in the FIFRA files that would permit an assessment of toxicological effects of metsulfuron methyl mixed with surfactant.

Picloram Adjuvants and Other Ingredients As indicated in Section 2, the commercial formulation of picloram used by the Forest Service is in the form of the potassium salt of picloram. Both of the Tordon formulations also contain the surfactant, Polyglycol 26-2 (CAS No. 069029-39-6). Surfactants are surface active agents that can disrupt cellular membranes and lead to a number of adverse effects (e.g., Warisnoicharoen et al. 2003). In an in vitro study on oxidative phosphorylation in submitochondrial particles derived from a marine algae, Oakes and Pollak (1999) noted that a commercial preparation of 2,4-D and picloram that contained Polyglycol 26-2 as well as Polyglycol 26-2 both inhibited oxidative function in the submitochondrial preparations at a concentration of about 0.01%. While this study clearly indicates that Polyglycol 26-2 will impact mitochondrial function in vitro, the implications for potential effects in humans at plausible levels of exposure are not apparent.

Other inerts used in Tordon K and Tordon 22K have been publicly disclosed by Northwest Coalition for Alternatives to Pesticides. These include emulsified silicone oil (CAS No. 63148- 62-9), ethoxylated cetyl ether (CAS No. 9004-95-9), and potassium hydroxide (CAS No. 1310- 18 58-3). All of these compounds are classified in U.S. EPA (2004) as List 4B, inerts of minimal concern. Potassium hydroxide is a GRAS (generally recognized as safe) compound and is approved as an indirect food additive (Clydesdale 1997). Both formulations also contain water as an inert.

291 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

The limited toxicity data on picloram formulations do not suggest substantial differences between the toxicity of the formulations (when dose is expressed in units of acid equivalents) and the toxicity of picloram (when dose is expressed in units of acid equivalents). Dow Chemical Co. (1970) specifically compared the acute oral toxicity of picloram (98.5% a.e.) to a Tordon formulation (22% a.e.). The acute oral LD50 in rats for the formulation was 8.2 mg a.e./kg and the corresponding LD50 for the formulation is given as approximately 10 mg a.e./kg (Dow Chemical Co. 1970).

The only qualitative difference in the activity of picloram and formulations of picloram involves skin sensitization. As discussed in Section 3.1.11.2, Tordon 22K but not picloram is a skin sensitizer according to standard assays for skin sensitization in guinea pigs.

Sulfometuron Methyl Inerts and Adjuvants The formulations of sulfometuron methyl used by the Forest Service contains materials other than sulfometuron methyl that are included as adjuvants to improve either efficacy or ease of handling and storage. As discussed in Section 2.2, the identity of these inert materials in Oust XP is confidential. The inerts were disclosed to the U.S. EPA (DuPont Agricultural Products 1999) and were reviewed in the preparation of this risk assessment. All that can be disclosed explicitly is that none of the additives in Oust XP are classified by the U.S. EPA as toxic. As also discussed in Section 2.2, the identity of inert ingredients for the sulfometuron methyl formulation Oust have been disclosed. The Northwest Coalition for Alternatives to Pesticides (NCAP) has obtained information on the identity of the inerts in Escort from U.S. EPA under the Freedom of Information Act and has listed this information on the NCAP web site (http://www.pesticide.org/FOIA/clopyralid.html). The inerts listed in this web site are sucrose, sodium salt of naphthalene-sulfonic acid formaldehyde condensate, polyvinyl pyrrolidone, sodium salt of sulfated alkyl carboxylated and sulfated alkyl naphthalene, and hydroxypropyl methylcellulose. Sucrose (CAS No. 57-50-1) is classified by the U.S. EPA as a List 4 inert and therefore, is generally recognized as a safe compound and is approved as a food additive (U.S. EPA 2003). Hydroxypropyl methylcellulose (Cas No. 009004-65-3) is classified as a List 4a inert, which is generally recognized as safe (U.S. EPA 2003). There is no evidence to assert that either sucrose or hyrdoxypropyl methylcellulose will materially impact the risks associated with the use of sulfometuron methyl. Polyvinyl pyrrolidone (CAS No. 88-12-0) is classified as a List 3 inert (U.S. EPA 2003). In other words, there is insufficient information to categorize this compound as either hazardous (Lists 1 or 2) or non-toxic (List 4). Sodium naphthalene sulfonate- formaldehyde condensate and the mixture of a sulfate of alkyl carboxylate and sulfonated alkyl naphthalene (sodium salt) were not identified in the EPA Inert List (U.S. EPA 2003). Other naphthalene derivatives identified on the EPA Inert List are classified as List 3 or List 4; no naphthalene derivatives are classified as List 1 or List 2 inerts (U.S. EPA 2003). Thus, there is insufficient information available to assess the impact of either polyvinyl pyrrolidone or the naphthalene derivatives on the risks associated with the use of sulfometuron methyl.

However, as noted above, the toxicity of Oust and Oust XP appears to be comparable to that of technical grade sulfometuron methyl (Sections 3.1.4, 3.1.11, and 3.1.13). Therefore, there is no plausible basis for asserting that these inerts are present in Oust or Oust XP in toxicological amounts.

292 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona

As noted in section 2.2, the manufacturers recommend that sulfometuron methyl formulations be mixed with a non-ionic surfactant. There is no published literature or information in the FIFRA files that would permit an assessment of toxicological effects of sulfometuron methyl mixed with surfactant.

Tebuthiuron Adjuvants and Other Ingredients Other Ingredients The identities of inerts in pesticide formulations are generally considered trade secrets and need not be disclosed to the general public. Nonetheless, all inert ingredients as well as the amounts of the inerts in the formulations are disclosed to and reviewed by the U.S. EPA as part of the registration process. Some inerts are considered potentially hazardous and are identified as such on various lists developed by the federal government and state governments. Material Safety Data Sheets (MSDS) sometimes specify inerts used in pesticide formulations. U.S. EPA/OPP (2015b, p. 5-13) encourages but does not generally require expanded inert statements on product labels which specifically identify the inert ingredients in the product. One notable exception, however, involves petroleum distillates including xylene or xylene range solvents that are part of 34 the formulation and at a concentration of ≥10%. In this case, the product label must contain the following statement: Contains petroleum distillates, xylene or xylene range aromatic solvents (U.S. EPA/OPP 2010d, p. 5-11). None of the product labels for the representative formulations list in Table 2 indicate that these formulations contain petroleum distillates.

Table 3 summarizes the other ingredients/inerts disclosed for the formulations of tebuthiuron explicitly covered in the current risk assessment. There are no disclosed inerts for the Alligare formulations (i.e., Alligare Tebuthiuron 20 P and Alligare 80 WG). As summarized in Table 3, the Spike formulations of tebuthiuron—i.e., Spike 20P and Spike 80DF—both contain clay. Spike DF also contains titanium dioxide. When used as a pesticide inert, both clay and titanium dioxide are categorized as List 4B inerts. This list is described by EPA as follows: Other ingredients for which EPA has sufficient information to reasonably conclude that the current use pattern in pesticide products will not adversely affect public health or the environment (U.S. EPA/OPP 2004a, p. 1). Clay is also on the FDA list of compounds that are “Generally Recognized As Safe” (GRAS) (FDA 2015). Spike 80DF also contains Silica gel which is classified as a List 4A inert. List 4A inerts are classified by EPA as Minimal Risk Inert Ingredients (U.S. EPA/OPP 2004b, p. 1).

Adjuvants The product labels for Spike DF and Alligare Tebuthiuron 80 WG do not recommend the use of adjuvants. Similarly, the granular formulations of tebuthiuron—i.e., Spike 20P and Alligare Tebuthiuron 20 P—do not recommend the use of any adjuvants.

Triclopyr Adjuvants and Other Ingredients At least some formulations of triclopyr TEA contain the triethylamine salt of triclopyr as well as emulsifiers, surfactants, and ethanol (Table 4). Triclopyr BEE formulations contain the butoxyethyl ester (BEE) of triclopyr as well as inerts, including deodorized kerosene. As reviewed in U.S. EPA/OPP (1998a), triclopyr TEA dissociates extremely rapidly to triclopyr

293 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests acid and triethylamine, and triclopyr BEE hydrolyzes rapidly to triclopyr acid and 2- butoxyethanol. As noted in Section 2.2, formulations of Garlon manufactured after January 4 2011 will not use kerosene. Kerosene is considered in the following discussion because the currently available toxicity data on Garlon 4 does involve formulations that contained kerosene.

Relatively little information is available on the toxicity of triethylamine. There is an extensive database on the toxicity of 2- butoxyethanol, and much of the available information associated with potential human health effects is reviewed by ATSDR (1998). The acute oral MRL for 2- butoxyethanol is 0.4 mg/kg/day, and the intermediate MRL for 2-butoxyethanol is 0.07 mg/kg/day (ATSDR 2002). As detailed further in Section 3.3, the acute MRL for 2- butoxyethanol is on the same order as the acute RfD for triclopyr (1 mg/kg/day), and the intermediate MRL for 2-butoxyethanol is similar to the intermediate and chronic RfD for triclopyr (0.05 mg/kg/day).

The toxicity of ethanol, which is used in formulations such as Garlon 3A, is extremely well characterized in humans, and the hazards of exposure include intoxication from acute exposure as well as liver cirrhosis and fetal alcohol syndrome (WHO 1988). For chronic exposure, the alcohol contained in Garlon 3A will not be of toxicological significance because of the rapid breakdown of alcohol in the environment and the relatively high levels of alcohol associated with chronic alcohol poisoning. Similarly, alcohol is not likely to pose an acute toxic hazard. Approximately 15 mL of alcohol is contained in 1 oz of an alcoholic beverage containing 50% alcohol (100 proof) [0.5 ⋅ 1 oz ⋅ 29.6 mL/oz ≃ 14.8 mL]. This level may cause mild intoxication in sensitive individuals. Each mL of Garlon 3A contains 0.01 mL of ethanol. Therefore, 1480 mL, or approximately 1.5 L, of Garlon 3A must be consumed to equal the amount of alcohol contained in 1 oz of an alcoholic beverage. The same amount of Garlon 3A contains 540,000 mg a.e. of triclopyr [1.5 L ⋅ 360,000 mg a.e./L]. For a 70 kg man, this dose would equal approximately 770 mg a.e./kg, which is similar to the LD50 for rats. As discussed in the dose- response section (section 3.3), this estimate may be a reasonable approximation of a lethal dose for triclopyr in humans. Thus, compared with the active ingredient, which is triclopyr, the amount of ethanol in Garlon 3A does not appear to be toxicologically significant in terms of potential systemic toxicity. Nonetheless, ethanol is an effective solvent. As detailed in Section 3.1.11, some formulations of triclopyr TEA have been associated with severe eye irritation. While somewhat speculative, these irritant effects could be due, at least in part, to ethanol.

The importance of kerosene to the potential toxicity of Garlon 4 is more difficult to assess. Deodorized kerosene is classified by U.S. EPA as a List 3 Inert. This list contains pesticide inerts that the U.S. EPA considers lacking in toxicological data. The toxicity of kerosene is reviewed in ATSDR (1995). At sufficiently high doses, kerosene can cause many gastrointestinal, central nervous system (CNS), and renal effects. Although some of the effects observed are consistent with the effects observed in mammals given large oral doses of Garlon 4 (e.g., diarrhea, lethargy, tremors, etc.), the same effects are observed in animals given triclopyr alone or Garlon 3A.

The acute lethal dose of kerosene for humans ranges from approximately 2000 to 12,000 mg/kg; the acute oral LD50 values in experimental mammals range from approximately 16,000 to 23,000 mg/kg. As discussed in section 3.3, there is no information regarding the acute lethal potency of triclopyr to humans. In experimental mammals, acute oral LD50 values for triclopyr range from approximately 600 to 1000 mg/kg. Thus, the acute lethal potency of kerosene is

294 Environmental Assessment for Herbicide Use within Authorized Power Line Rights-of-Way on National Forest System Lands in Arizona approximately 16 times less than the acute lethal potency of triclopyr. Given the relative potency of kerosene, the acute effects associated with exposure to Garlon 4 are probably attributable to triclopyr and not to kerosene.

No monitoring data are available regarding kerosene levels during the application of Garlon 4. Middendorf et al. (1992) monitored triclopyr air levels ranging of approximately 5-15 μg/m3, based on the personal breathing zone air of workers involved in backpack sprays. If kerosene is present at a concentration of ≤20% in Garlon 4, the corresponding concentration of kerosene in the air would be approximately 1-3 μg/m3. The NOAEL for neurological effects in experimental mammals after exposure to kerosene, which ranged from 14 days to 1 year, is approximately 100 mg/m3; the NIOSH TLV for petroleum distillates is 350 mg/m3 (ATSDR 1995). Thus, plausible levels of exposure to kerosene during applications of Garlon 4 are approximately 30,000-100,000 below the NOEL for kerosene in experimental mammals and a factor of 120,000-350,000 below the TLV for petroleum distillates. Although some components of kerosene are known to be carcinogenic to humans (e.g., benzene), kerosene is not classified as a carcinogen, and quantitative risk assessments have not been conducted on kerosene (ATSDR 1995).

Inferences concerning the toxicological significance of TEA, BEE, as well as other adjuvants used in triclopyr formulations can also be made based on a comparison of the toxicities of triclopyr acid, triclopyr BEE, triclopyr TEA, and triclopyr formulations. As summarized in Appendix 2, the acute oral LD50 of triclopyr acid is 729 mg a.e./kg bw in male rats and 630 mg a.e./kg bw in female rats. These oral toxicity values are similar to the LD50 values of 828 mg a.e./kg in male rats and 594 mg a.e./kg for exposure to Garlon 3A. Similarly, the acute oral LD50 values for triclopyr acid are very close to the reported LD50 of 578 mg a.e./kg bw for exposure to triclopyr BEE. In other words, based on a comparison of the acute oral LD50 values, triclopyr acid rather than the TEA or BEE moieties appears to account for the toxicity of the two active ingredients.

Taking the oral 578 mg a.e./kg bw for triclopyr BEE, the expected LD50 of a 60.5% a.i. (44.3% a.e.) would be about 1300 mg formulation/kg bw [578 mg a.e./kg bw ÷ 0.443 a.e./formulation ≈ 1305 mg formulation/kg bw]. As discussed above and detailed in Appendix 1, the lower bound of the reported LD50 values for 60.5% a.i. formulations of triclopyr BEE is 1338 mg formulation/kg bw. In other words, the toxicity of these triclopyr formulations is consistent with the assumption that the agent of concern in the triclopyr BEE formulations is triclopyr rather than the BEE moiety or the other ingredients included in the triclopyr BEE formulations.

As summarized in Appendix 2, Table 1, the oral LD50 of triclopyr TEA (as Garlon 3A) is 828 mg a.e./kg bw in male rats and 594 mg a.e./kg bw in female rats (Mizell and Lomax 1988). These LD50 values are very similar to oral LD50 of triclopyr acid – i.e., 729 mg/kg in male rats and 630 mg/kg in female rats. Thus, as with triclopyr BEE (discussed above), the toxicity of this triclopyr formulation is consistent with the assumption that the agent of concern in the triclopyr 1 TEA formulation is triclopyr rather than the TEA moiety.

295 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

References - Aminocyclopyrachlor {Bukun et al. 2009} Bukun B; Nissen J; Lindenmayer B; Shaner D; Brunk G; Westra P. 2009. The influence of different surfactants on aminocyclopyrachlor (DPX-MAT-28) and aminocyclopyrachlor methyl ester (DPXKJM-44) absorption in Canada thistle (Cirsium arvense L.). WSSA Meeting Abstracts. 117. [Set00]

{Bukun et al. 2010} Bukun B: Lindenmayer RB; Nissen SJ; Westra P; Shaner DL; Brunk G; 2010. Absorption and Translocation of Aminocyclopyrachlor and Aminocyclopyrachlor-Methyl Ester in Canada Thistle (Cirsium arvense). Weed Science. 58(2): 96-102. [AGRICOLA]

{Clydesdale 1997} Clydesdale, FM. 1997. Food Additives: Toxicology, Regulation, and Properties. CRC Press, Boca Raton, Florida. CD-ROM Database.[Std]

{SERA 2011b} SERA (Syracuse Environmental Research Associates, Inc.). 2011b. WorksheetMaker Version 6.00, User Guide. SERA TR-052-20-01b. Document dated December 21, 2011. Syracuse Environmental Research Associates, Inc., Fayetteville, NY. Available at www.sera-inc.com. [Std]

{U.S. EPA/OPPTS 2009} U.S. EPA/OPPTS (U.S. Environmental Protection Agency/Office of Pollution Prevention and Toxic Substances). 2009. Inert Ingredients Eligible for FIFRA 25(b) Pesticide Products. Last Updated March 3, 2009. Available at: http://www.epa.gov/opprd001/inerts/section25b_inerts.pdf. [Std]

{Kosswig 1994} Kosswig K. 1994. Surfactants. In: Ullmann’s Encyclopedia of Industrial Chemistry. 5th Edition, Volume 25a. pp. 747-815. [Std]

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HSDB (Hazardous Substances Data Bank). 2003. Triisopropanolamine, Hazardous Substances Databank Number 5593. Available at: http://toxnet.nlm.nih.gov/cgi-bin/sis/search/f?./temp/~tBQaBi:1.

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Stebbins KE; Dryzga MD. 2004. GF-871: 90-Day dietary toxicity study in Fischer 344 rats. February 25, 2004. Toxicology and Environmental Research and Consulting, Midland, MI. Study ID 031140. Unpublished. [Did not appear in listing of studies from OPP. Have DER.] MRID No. 46235622.

Brooks KJ; Radtke BJ. 2002a. GF-871: Acute Eye Irritation Study In New Zealand White Rabbits. Toxicology & Environmental Research and Consulting, The Dow Chemical Company, Midland, Michigan. Laboratory Project Study ID 021098. (Not in EPA bibliography from FOIA.) MRID No. 46235610.

Brooks K. 2001b. DE-750: Acute Eye Irritation Study in New Zealand White Rabbits. Project Number: 011118.Unpublished study prepared by Dow Chemical Co. 17 p. MRID No. 46235609.

Wilson DM; Brooks KF; Radtke BJ. 2002. GF-871: Acute Dermal Toxicity Study in Fischer 344 Rats. Project Number: 021097. Unpublished study prepared by Dow Chemical Co. dated Dec. 2, 2002.

Clydesdale, FM. 1997. Food Additives: Toxicology, Regulation, and Properties. CRC Press, Boca Raton, Florida. CD-ROM Database.

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McCollister SB; Quast JF; Hermann EA; Pugh LA; Dittenber DA; Gorzinski SJ. 1981. Triisopropanolamine: Results of a Two-Week Toxicity Study in the Drinking Water of CDF Fischer 344 Rats. Report of Toxicology and Environmental Research and Consulting, The Dow Chemical Company, Midland, Michigan.

Mullin LS. 1987. Subchronic Oral Toxicity: 90-Day Study with TIPA Feeding Study in Dogs. Medical Research Project No. 8086-001. E. I. du Pont de Nemours and Company, Inc., Haskell Laboratory for Toxicology and Industrial Medicine, Newark, Delaware. As summarized in Stebbins and Dryzga 2004 MRID 46235622.

References – Chlorsulfuron Armstrong J. 1988a. Product Identity, Description of Formulation Process, Formation of Impurities, and Certification of Limits for: End use Product Du Pont Avatar Herbicide. Laboratory Pro ject ID: FPC-88-5-ID. Unpublished compilation prepared by E. I. du Pont de Nemours. MRID 40622706.

Brennan D. 1999a. Technical Grade Chlorsulfuron (DPX-W4189) Analysis and Certification of Product Ingredients. Lab Project Number: AMR 4727-97: S788.849: S7850.160.01.ES. Unpublished study prepared by E.I. du Pont de Nemours and Company. 150p. {OPPTS 830.1550, 830.1700, 830.1750, 830.1800} MRID 449640.

Brennan D. 1999b. Technical Grade Chlorsulfuron (DPX-W4189) Manufacturing Description and Formation of Impurities. Lab Project Number: AMR 4869-98. Unpublished study prepared by E.I. du Pont de Nemours and Company. 71 p. {OPPTS 830.1550, 830.1620, 830.1670} MRID 44964002.

References - Clopyralid Clydesdale FM. 1997. Food Additives: Toxicology, Regulation, and Properties. CRC Press, Boca Raton, Florida. CD-ROM Database.

U.S. EPA (U.S. Environmental Protection Agency). 2003. Draft Final Guidelines for Carcinogen Risk Assessment. EPA/630/P-03/001A. February 2003.

Warisnoicharoen W; Lansley AB; Lawrence MJ. 2003. Toxicological evaluation of mixtures of nonionic surfactants, alone and in combination with oil. J Pharm Sci. 92(4): 859-868.

Oakes DJ; Pollak JK. 1999. Effects of a herbicide formulation, Tordon 75D, and its individual components on the oxidative functions of mitochondria. Toxicology. 136 (1):41-52.

References – 2, 4, D OSHA (Occupational Safety and Health Administration) 1996a. Occupational Safety and Health Guideline for Dimethylamine. http://www.osha.gov/SLTC/healthguidelines/dimethylamine.

Fisher Scientific. 2005. Material Safety Data Sheet for Ammonia Buffer Solution. http://www.catalogue.fisher. co.uk/scripts/search.dll?ViewMSDS&SheetNumber=88979.

U.S. EPA (United States Environmental Protection Agency) 1989b. Integrated Risk Information System (IRIS), Ethylene Glycol (CASRN 107-21-1). http://www.epa.gov/iris/subst/0238.htm

OSHA (Occupational Safety and Health Administration) 1996b. Occupational Safety and Health Guideline for Isopropyl Alcohol. http://www.osha.gov/SLTC/healthguidelines/isopropylalcohol

JT Baker 2003. Material Safety Data Sheet for Kerosene (Low Odor). http://www.jtbaker.com/ msds/englishhtml/k2175.htm.

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References – Dicamba Velsicol Chemical Corporation. 1961. Velsicol Banvel D: 2-Methoxy- 3,6-dichlorobenzoic acid (Velsicol 58-CS-11, Compound B). Chicago, Ill.: VCC. Bulletin no. 521-2. MRID 00023088

Velsicol Chemical Corporation. 1984. Banvel Herbicide: Product Chemistry Data Submitted in Partial Fulfillment of Requirements for the Re-registration of Dicamba. Unpublished compilation. 15 p. MRID 00143504

Bryant J. 1995a. SAN821 H 480 SL 402 DP Product Identity and Composition: Amended: Lab Project Number: 083194-11. Unpublished study prepared by Sandoz Agro, Inc. 49 p. MRID 43643825

Bryant, J. (1995b) SAN 821 H 480 SL 402 DP Analysis and Certification of Product Ingredients: Amended: Lab Project Number: 083194-2. Unpublished study prepared by Sandoz Agro, Inc. 97 p. MRID 43643826

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Budai P; Varnagy LE; Somlyay IM; Varga T. 1997. Ocular irritation study of some pesticides in HET-CAM test. Mededelingen faculteit landbouwkundige en toegepaste biologische wetenschappen universiteit gent. 62 (2A):265- 268.

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Kuhn J. 1998a. Acute Dermal Toxicity Study in Rabbits: Dicamba Sodium Salt: Final Report: Lab Project Number: 3870-97. Unpublished study prepared by Stillmeadow, Inc. 12 p. MRID 44524404.

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Beavers J. 1986. (Dicamba) - 3 Lb./Gal. Isopropylamine Salt of Dicamba: An Acute Oral Toxicity Study with Bob White: Project No. 107-217. Unpublished study prepared by Wildlife International Ltd. 24 p. MRID 00164105.

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{Wan et al. 1989} Wan MT; Watts RG; Moul DJ. 1989. Effects of different dilution water types on the acute toxicity to juvenile pacific salmonids and rainbow trout of glyphosate and its formulated products. Bull. Environ. Contam. Toxicol. 43(3):378-385. [GlyArch1]

{Brausch and Smith 2007} Brausch JM; Smith PN. 2007. Toxicity of Three Polyethoxylated Tallowamine Surfactant Formulations to Laboratory and Field Collected Fairy Shrimp, Thamnocephalus platyurus. Archives of Environmental Contamination and Toxicology, 52(2), 217-221. [Set04]

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American Cyanamid Co. 1998bc. Submission of Product Chemistry Data in Support of the Registration of Plateau DG Herbicide. Transmittal of 1 Study. MRID No. 44697701.

American Cyanamid Co. 1997. Material Safety Data Sheet for Plateau Herbicide. C&P Press. Sheet No. AG09168- 4. Dated June 2, 1997.

Levine, TE. 1996. The regulation of inert ingredients in the United States. Chapter 1 in Pesticide Formulation and Adjuvant Technology. CL Foy and DW Pritchard (eds). CRC Press. Boca Raton, Florida. pp. 1-11.

References – Imazapyr {SERA 2004a} SERA (Syracuse Environmental Research Associates, Inc.). 2004a. Imazapyr - Human Health and Ecological Risk Assessment - Final Report, SERA TR 04-43-17-05b, Report dated December 18, 2004. Prepared under USDA Forest Service BPA: WO-01-3187-0150, Purchase Order No.: 43-1387-3-0716. Available at: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml. [Set00]

{U.S. EPA/OPP 2007b} U.S. EPA/OPP (U.S. Environmental Protection Agency/Office of Pesticide Programs). 2007b. Inert Ingredients Permitted in Pesticide Products. Updated December 21, 2007. Available at: http://www.epa.gov/opprd001/inerts/lists.html [Std]

{Clydesdale 1997} Clydesdale, FM. 1997. Food Additives: Toxicology, Regulation, and Properties. CRC Press, Boca Raton, Florida. CD-ROM Database.[Std]

{U.S. EPA/ORD 2007} U.S. EPA/ORD (U.S. Environmental Protection Agency/Office of Research and Development). 2000. Dermal Exposure Assessment: A Summary of EPA Approaches. EPA/600/R-07/040F. Report dated September 2007. Available at http://www.epa.gov/ncea/. [Std]

{U.S. EPA/OPP 2003} U.S. EPA/OPP (U.S. Environmental Protection Agency/Office of Pesticide Programs). 2003. User’s Manual for Swimmer Exposure Assessment Model (SWIMODEL) Version 3.0. U.S. EPA/OPP Antimicrobials Division. Available at: http://www.epa.gov/oppad001/swimodel.htm. [Std]

{SERA 2011b} SERA (Syracuse Environmental Research Associates, Inc.). 2011b. Glyphosate, Human Health and Ecological Risk Assessment, Final Report. SERA TR-052-22-03b. Report dated March 25, 2011. Available at: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml. [Std]

{U.S. EPA/OPP 2009} U.S. EPA/OPP (U.S. Environmental Protection Agency/Office of Pesticide Programs). 2009. Final List of Initial Pesticide Active Ingredients and Pesticide Inert Ingredients to be Screened Under the Federal Food, Drug, and Cosmetic Act. Fed Reg. 74(71): 17579-17585. [Set00]

{Kosswig 1994} Kosswig K. 1994. Surfactants. In: Ullmann’s Encyclopedia of Industrial Chemistry. 5th Edition, Volume 25a. pp. 747-815. [Set 00]

299 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

References – Isoxaben C&P Press (Chemical and Pharmaceutical Press). 1999b. Gallery 75 Dry Flowable Material Safety Data Sheet. Dow AgroSciences Reference: DR-0324-6740. Greenbook.net. http://www.greenbook.net.

EPA (U.S. Environmental Protection Agency). 1998. Lists of Inert Pesticide Ingredients. Http://www.epa.gov/opprd001/inerts/lists.html. Updated Augurs 7, 1998.

EPA (U.S. Environmental Protection Agency). 1995. Inert Ingredients in Pesticide Products. U.S. EPA, Washington, D.C. Federal Register. 60(130):35396-35399. From the Federal Register Online via GPO Access, wais.access.gpo.gov., http://www.epa.gov/docs/fedrgstr/EPA-PEST/1995/July/Day-07/pr-331.htm.

Farrar AC. 2000. IARC Reclassification of Crystalline Silica as Human Carcinogen Affects Product Labeling and MSDSs. Http://www.claytonenv.com/iarc_art.htm..

References – Fluroxypyr {U.S. EPA/OPP 2008b} U.S. EPA/OPP (U.S. Environmental Protection Agency/Office of Pesticide Programs). 2008b. Reregistration Eligibility Decision for Naphthalene. EPA 738-R-07-010. Report dated September 12, 2008. Available at: http://www.epa.gov/pesticides/reregistration/REDs/naphthalene-red.pdf. [Internet]

{U.S. EPA/OPP 2006d} U.S. EPA/OPP (U.S. Environmental Protection Agency/Office of Pesticide Programs). 2006d. Inert Reassessments: N-methylpyrrolidone (CAS Reg. No. 872-50-4). Available at: http://www.epa.gov/opprd001/inerts/methyl.pdf. [Internet]

{U.S. EPA 1990} U.S. EPA (U.S. Environmental Protection Agency). 1990. Integrated Risk Information System (IRIS) entry for naphthalene. Available at: http://www.epa.gov/iris/subst/0436.htm. [Internet]

{U.S. EPA 1998} U.S. EPA (U.S. Environmental Protection Agency). 1998. Toxicological Review of Naphthalene (CAS No. 91-20-3). In Support of Summary Information on the Integrated Risk Information System (IRIS). Report dated August 1998. Available at: http://www.epa.gov/iris/toxreviews/0436-tr.pdf. [Internet]

{ATSDR 2005} ATSDR (Agency for Toxic Substances and Disease Registry). 2005. ATSDR ToxProfiles for Naphthalene, 1-MethylNaphthalene, and 2-MethylNaphthale. Available from U.S. Department of Health and Human Services, Public Health Service, ATSDR, Division of Toxicology. Http://www.atsdr.cdc.gov/. [Std – Have]

References - Metsulfuron Methyl U.S. EPA/OPP (United States EPA/Office of Pesticide Programs. 2003. List of Inert Pesticide Ingredients. Updated August 14, 2003. Available at: http://ww.epa.opprd001/inerts/.

Clysdale, FM. 1997. Food Additives: Toxicology Regulation, and Properties. CRC Press, Boca Raton, Florida.

Du Pont(E I du Pont de Nemours & Co Inc). 1985b. Product Chemistry Data for DPX-R9674 Herbicide. Unpublished study. 24 p. MRID No. 00155976.

Du Pont(E I du Pont de Nemours & Co Inc). 1985c. Metsulfuron Methyl Product Chemistry Data. Unpublished study. 27 p. MRID No. 00151054.

References – Picloram {Warisnoicharoen et al. 2003} Warisnoicharoen W; Lansley AB; Lawrence MJ. 2003. Toxicological evaluation of mixtures of nonionic surfactants, alone and in combination with oil. J Pharm Sci. 92(4): 859-868. [RA2003r]

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{Oakes and Pollak 1999} Oakes DJ; Pollak JK. 1999. Effects of a herbicide formulation, Tordon 75D, and its individual components on the oxidative functions of mitochondria. Toxicology. 136 (1):41-52. [RA2003]

{Clydesdale 1997} Clydesdale, FM. 1997. Food Additives: Toxicology, Regulation, and Properties. CRC Press, Boca Raton, Florida. CD-ROM Database.[Std]

{U.S. EPA/OPP 2004} U.S. EPA/OPP (U.S. Environmental Protection Agency/Office of Pesticide Programs). 2003. Inert Ingredients Ordered by CAS Number – List 4B, Updated August 2004. Available at: http://www.epa.gov/opprd001/inerts/inerts_list4Bcas.pdf. [Std]

{Dow Chemical 1970} Dow Chemical Co. 1970. Comparison of Acute Oral Toxicities of Tordon Herbicide Formulations in Small Animals. (Unpublished study including letter dated Mar 3, 1970 from M.L. Leng to Harold G. Alford, received Mar 6, 1970 under 0F0863; CDL: 093160-B) MRID 00045404. [MRID03R]

References - Sulfometuron Methyl Dupont. 1999a. Product Label for Oust XP. Available at www.greenbook.net.

U.S. EPA/OPP (United States EPA/Office of Pesticide Programs. 2003. List of Inert Pesticide Ingredients. Updated August 14, 2003. Available at: http://ww.epa.opprd001/inerts/.

References – Tebuthiuron {U.S. EPA/OPP 2015b} U.S. EPA/OPP (U.S. Environmental Protection Agency/Office of Pesticide Programs). 2015b. Label Review Manual. Updated 2015. Available at: http://www2.epa.gov/sites/production/files/2015- 08/documents/lrm-chap1-18-aug-2015.pdf. [Std]

{U.S. EPA/OPP 2010a} U.S. EPA/OPP (U.S. Environmental Protection Agency/Office of Pesticide Programs). 2010a. Endocrine Disruptor Screening Program; Second List of Chemicals for Tier 1 Screening. Fed Reg. 75(221): 70248-70254. [Std]

{U.S. EPA/OPP 2004a} U.S. EPA/OPP (U.S. Environmental Protection Agency/Office of Pesticide Programs). 2004a. List 4B - Other ingredients for which EPA has sufficient information to reasonably conclude that the current use pattern in pesticide products will not adversely affect public health or the environment. - By Chemical Name. Updated August 2004. Available at: http://www.epa.gov/sites/production/files/2015- 10/documents/inerts_list4bcas_0.pdf. [Std]

{U.S. EPA/OPP 2004b} U.S. EPA/OPP (U.S. Environmental Protection Agency/Office of Pesticide Programs). 2004b. List 4A - Minimal Risk Inert Ingredients - By Chemical Name, Updated August 2004. Available at: http://www.epa.gov/sites/production/files/2015-10/documents/inerts_list4aname.pdf. [Std]

FDA 2015} FDA (Food and Drug Administration). 2015. GRAS Substances (SCOGS) Database. Available at: http://www.accessdata.fda.gov/scripts/fdcc/?set=SCOGS. [Std]

References – Triclopyr {U.S. EPA/OPP 1998a} U.S. EPA/OPP (U.S. Environmental Protection Agency/Office of Pesticide Programs). 1998a. Reregistration Eligibility Decision (RED): Triclopyr. Available at: http://www.epa.gov/pesticides/reregistration/status_page_t.htm. [SET00]

{ATSDR 1998} ATSDR (Agency for Toxic Substances and Disease Registry). 1998. Toxicological Profile for 2- Butoxyethanol and 2-Butoxyethanol Acetate. Available from U.S. Department of Health and Human Services, Public Health Service, ATSDR, Division of Toxicology. http://www.atsdr.cdc.gov/. [Tric03]

{ATSDR 2002} ATSDR (Agency for Toxic Substances and Disease Registry). 2002. Exposure Investigation Spring Valley Neighborhood. Available at: http://www.atsdr.cdc.gov/sites/springvalley/mar02ei.html. [Std]

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{ATSDR 1995} ATSDR (Agency for Toxic Substances and Disease Registry). 1995. Toxicological Profile for Fuel Oils. ATSDR ToxProfiles on CD-ROM. Available from U.S. Department of Health and Human Services, Public Health Service, ATSDR, Division of Toxicology. http://www.atsdr.cdc.gov/. [Tric03]

{WHO 1988} WHO (World Health Organization). 1988. IARC Monographs on the Evaluation of Carcinogenic Risk to Humans: Alcohol Drinking. IARC Working Group on the Evaluation of Carcinogenic Risks to Humans, Lyon, France. International Agency for Research on Cancer, World Health Organization, Geneva Switzerland. pp. 122-125. [Tric03]

ATSDR 1995} ATSDR (Agency for Toxic Substances and Disease Registry). 1995. Toxicological Profile for Fuel Oils. ATSDR ToxProfiles on CD-ROM. Available from U.S. Department of Health and Human Services, Public Health Service, ATSDR, Division of Toxicology. http://www.atsdr.cdc.gov/. [Tric03]

Middendorf et al. 1992} Middendorf P; Timchalk C; Kropscott B; Rick D. 1992. Forest worker exposures to triclopyr butoxyethyl ester during directed foliar applications of Garlon4. Proc South Weed Sci Soc. 45: 177-188. [SET01b]

{Mizell and Lomax 1988} Mizell M ; Lomax L. 1988. Garlon 3A (Triclopyr as Triethylamine Salt): Acute Oral Toxicity Study in Fischer 344 Rats: Lab Project Number: M-003724-009A. Unpublished study prepared by The Dow Chemical Co. 28 p. MRID 41443301. [MRID03]

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Appendix G. Ecotoxicity Ratings for Pesticide Active Ingredients and Various Formulations

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Table G-1. Ecotoxicity Ratings for Pesticide Active Ingredients and Various Formulations Herbicide Species Toxicity Groups a,b,c

Active Ingredient L-MA P-MA S-MA P-AV S-AV REP A-AM T-AM CW-F WW-F A-AR BEE T-AR FW-M Plant

Aminocyclopyrachlor 0e 0e 0e 0 0 0 0 0 0 0 0 0 0 0 NS Aminopyralid 0 0 0 0 0 0 0 0 0 0 0 0 0 0 D Chlorsulfuron 1e 1e 1e 1e 1e 1e 0 1e 0 0 0 0 0 0 NS Clopyralid 1e 1e 1e 1e 1e 1e 0 1e 0 0 0 0 0 0 D 2, 4-D (aquatic amine salt) 1e 1e 1e 1e 1e 1e 0 1e 0 0 2 2 2 Daq 2, 4-D (nonaquatic amine salt) 1e 1e 1e 1e 1e 1e 0 1e 0 0 2 2 2 D 2, 4-D (aquatic ester formulation) 1 1 1 0 0 0 1 1 2 2 3 3 3 Daq 2, 4-D (nonaquatic ester formulation) 1 1 1 0 0 0 1 1 2 2 3 3 3 D Dicamba 2e 2e 2e 2e 2e 2e 1 2e 1 1 1 0 1 1 D Fluroxypyr (acid formulation) 1 1 1 0 0 0 1 1 1 1 0 0 0 0 D Glyphosate (aquatic) 0 0 0 0 0 0 0 0 0 0 0 0 0 NSaq Glyphosate (nonaquatic) 1e 1e 1e 1e 1e 1e 1 1 1 1 1 0 1 1 NS Imazapic 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NS Imazapyr (aquatic) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NSaq Imazapyr (nonaquatic) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NS Isoxaben 1e 1e 1e 1e 1e 1e 1 1 1 1 1 0 1 1 D Metsulfuron methyl 1e 1e 1e 1e 1e 1e 1 1e 1 1 1 1 1 0 NS Picloram (see note below) 1 1 1 0 0 0 1 1 1 1 1 0 1 1 NS Sulfometuron methyl 0 0 0 0 0 0 1 1 1 1 1 0 1 1 NS Tebuthiuron 1 1 1 0 0 0 1 1 1 1 0 1 1 0 NSf Triclopyr (amine salt formulation) 1e 1e 1e 1e 1e 1e 0 1e 0 0 0 0 0 0 D Triclopyr (ester formulation) 1 1 1 0 0 0 2 2 2 2 1 0 1 1 D a L-MA= Large Mammal; P-MA= Predatory Mammal; S-MA= Small Mammal; P-AV= Predatory Avian; S-AV= Small Avian; REP= Reptile; A-AM= Aquatic Amphibian; T-AM= Terrestrial Amphibian; CW-F= Cold Water Fish; WW-F= Warm Water Fish; A-AR= Aquatic Arthropod; T-AR= Terrestrial Arthropod; FW-M= Freshwater Mollusk b 0 = practically non-toxic; 1 = slightly to moderately toxic; 2 = highly toxic; 3 = very highly toxic; D = Dicot-specific; M = monocot-specific; NS = non-specific C Subscripts: aq = aquatic formulation; e = eye irritation rating; f = formulation dependent Diuron = herbicide may be released as urine into waterbodies by that have grazed on field-applied Diuron Picloram = picloram is used mostly for broad-leaved plants but can harm some grasses and other monocots Source: White, 2007.

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Appendix H. Resources Considered for Analysis

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Resources Considered for Analysis The Forest Service is required to address specific elements of the environment that are subject to requirements in statute or regulation or by executive order (Forest Service 2010a). Table H-1 lists the elements that must be addressed in all environmental analyses and indicates whether Alternative A or Alternative B affects those elements.

Table H-1. Summary of Resources Considered for Analysis

May be May be Resource Or Issue Present Affected Rationale for Determination Yes/No Yes/No Air Quality Yes No No impacts are anticipated since there would be limited ground disturbance as a result of both alternatives. Neither of the alternatives would result in any overall net increase in vehicles within the project area that may impact air quality or contribute to reduced air quality. With the very low volume of herbicides proposed (amount/rate) and design features (e.g., use of an adjuvant, notification, closed-chain of custody), both drift and volitalized gases should provide adequate protection and neither alternative is expected to have measurable impacts to air quality. Bald and Golden Yes Yes Refer to discussion in Chapter 3 Affected Eagles Environment/Environmental Consequences (Section 3.9) Heritage Resources Yes No Approximately 87 percent of the APS ROW on National Forest System lands have been subject to previous pedestrian survey efforts, including 1,395.97 linear miles of the total 1,607.43 linear miles. A cultural resources summary report has been prepared and included in the project record. This analysis can be obtained by request to the Forest Service Region 3 Office. This report includes a summary of available information regarding the affected environment, area surveyed by each forest, known sites and site types, and site elegibility. The Proposed Action falls under the Forest Service Region 3 Programmatic Agreement First Amended Programmatic Agreement Regarding Historic Property Protection and Responsibilities among New Mexico Historic Preservation Officer, Arizona State Historic Preservation Officer, Texas State Historic Preservation Officer, Oklahoma State Historic Preservation Officer, the Advisory Council on Historic Preservation, and United States Department of Agriculture – Forest Service Region 3 (Forest Service Region 3 PA). Climate Change/ Yes No Neither alternative would encourage additional development in Greenhouse Gas the area which may lead to an increase in greenhouse gas Emissions emissions or climate change. Furthermore, neither of the alternatives would result in any overall net increase in vehicles within the project area that may contribute to an increase in greenhouse gas emissions. Therefore, neither alternative is expected to have measurable impacts to climate change or greenhouse gas emissions due to the limited frequency of treatments. Environmental Yes No Neither alternative would cause displacements of residents nor Justice disproportionately high or adverse health or environmental effects on low income or minority populations as described in Executive Order 12898.

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May be May be Resource Or Issue Present Affected Rationale for Determination Yes/No Yes/No Farmlands (Prime Yes No Under Alternative B, no impacts are anticipated as only or Unique) incompatible vegetation within the vicinity of power lines that could disrupt the delivery of electricity would be spot treated with herbicides. No treatments of actively cultivated land would occur under either of the alternatives. Federally Listed Yes Yes Refer to discussion in Chapter 3 Affected Species Environment/Environmental Consequences (Section 3.7). Fire and Fuels Yes Yes Refer to discussion in Chapter 3 Affected Management Environment/Environmental Consequences (Section 3.13). Floodplains Yes No Executive Order 11988, Floodplain Management, requires an evaluation of impacts to floodplains for all federal actions and directs federal entities to reduce impacts to floodplains and minimize flood risks to human safety. The application of herbicides within the ROW through National Forest System lands would not result in any modification of a floodplain that would impede or redirect flood flows that would result in property damage on- or off-site. The flood-carrying capacity of the floodplain, the pattern, or the magnitude of the flood flow would not be affected. Forest Service Yes Yes Refer to discussion in Chapter 3 Affected Sensitive Species Environment/Environmental Consequences (Section 3.8). Forest Service Yes Yes Refer to discussion in Chapter 3 Affected Management Environment/Environmental Consequences (Section 3.11). Indicator Species General Fish and Yes Yes The potential impacts to general fish and wildlife has been Wildlife completed although the Forest Service does not require this analysis to make an informed decision regarding the potential impacts of the Proposed Action. Therefore the full analysis has been placed in the project record. Impacts to general fish and wildlife will not be included or further analyzed in this EA. This analysis can be obtained by request to the Forest Service Region 3 Office. General Vegetation Yes Yes Refer to discussion in Chapter 3 Affected Environment/Environmental Consequences (Section 3.6). Geology, Mineral Yes No No impacts are anticipated since there would be limited ground Resources, and disturbance and no access restrictions following herbicide Energy Production application are required (refer to Section 2.2 Alternative B – Proposed Action). Neither of the alternatives would affect any ongoing exploration activities. Human Health and Yes Yes Refer to discussion in Chapter 3 Affected Safety Environment/Environmental Consequences (Section 3.14). Lands and Realty Yes No Although ROWs/leases may be present, both alternatives would have no effect to these authorizations and activities and no temporary or permanent access limitations are associated with either of the alternatives.

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May be May be Resource Or Issue Present Affected Rationale for Determination Yes/No Yes/No Livestock Grazing Yes No Only herbicides approved for use on National Forest System lands would be used. Livestock and grazing leases would not be specifically targeted for treatment (refer to Section 2.2 Alternative B – Proposed Action), although treatment may occur on grazing leases within the APS authorized ROW and where the two leases overlap. No restrictions associated with grazing are identified on labels of products proposed for use. The following design feature has been incorporated into the project: Notify the public of herbicide treatment as established in the PUP review process. Spot treatment and the use of the adjuvant would eliminate the need for any restricted or limited access associated with Alternative B. The potential to eliminate forage is not anticipated to be substantial enough to affect preference. Therefore, neither alternative is anticipated to impact livestock grazing. Migratory Birds and Yes Yes Refer to discussion in Chapter 3 Affected Important Bird Environment/Environmental Consequences (Section 3.10). Areas Native American Yes No Tribal Consultation was initiated with 15 tribes in 2015. Religious Concerns Additionally, seven Chapters of the Western Navajo Agency were notified of the proposed project. Six tribes responded to the consultation letters; none of which objected to Alternative B. No specific properties or sites having traditional cultural or religious significance were identified by tribes in the APS ROW. Two additional tribes and one Navajo Nation Chapter House was consulted as the request of the Apache-Sitgreaves National Forest in 2018. No additional comments or concerns were identified. Continued coordination with tribes would be completed as outlined in the Forest Service Region 3 PA). Noxious and Yes Yes Each of the five forests have evaluated and prepared a NEPA- Invasive Weeds compliant document for the use of herbicides on National Forest System lands for the treatment of noxious and invasive weeds (refer to Appendix B for a list of the forest documents that are either incorporated by reference or used to tier). The analysis completed by each forest and included in its respective NEPA documents Forest Service-approved herbicides proposed for use under Alternative B (refer to Table 2-12. Forest Service- Approved Herbicides List Proposed for Use). Alternatives A and B would have short-term, minor, direct, beneficial effects from the potential control of the spread of some noxious and invasive weeds within the ROW. Additionally, both alternatives would result in short-term indirect minor adverse impacts due to the spread of noxious and invasive vegetation associated with ground disturbance from travel within the ROW. However, Alternative A would have a long-term, minor, direct and indirect, adverse effects because the continued frequent disturbances and routine vegetation maintenance cycles would increase the effects of previous disturbance by disrupting the reestablishing vegetation and pose a continued risk for the introduction or allowing the continued spread of noxious or invasive weeds. Long-term direct and indirect minor beneficial

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May be May be Resource Or Issue Present Affected Rationale for Determination Yes/No Yes/No impacts are anticipated for Alternative B as herbicide treatments are more effective in controlling incompatible vegetation and treating noxious and invasive weeds, assisting with compatible vegetation community transition. Although Alternative B does not directly target noxious and invasive weeds, the less vegetation requiring treatment per maintenance cycles would mean less site disturbance and less likelihood of transporting noxious or invasive weed and the seed establishing and/or spreading. Therefore, noxious and invasive weeds will not be further analyzed in this EA. Paleontology Yes No The project area does not occur within or adjacent to any paleontological resources and both alternatives would involve minimal ground disturbance. Therefore, paleontological resources would not be impacted by Alternative A or Alternative B. Rangeland Health Yes Yes Refer to discussion in Chapter 3 Affected Environment/Environmental Consequences (Section 3.12). Recreation Yes No Although dispersed recreation and trails are present in the ROW, none of the alternatives would affect recreational activities. No access restrictions or limitations would be required (refer to Section 2.2 Alternative B – Proposed Action). Where appropriate, notification (as determined during the PUP process) would be required for the treated areas according to manufacturers’ guidelines and resources for additional information in accordance with Forest Service requirements and as listed on the herbicide product label. Additionally, in developed recreation sites, herbicide treatments would occur in time periods when facilities are closed or during periods of low human use, as designated in the PUP process. Socio-Economics No No No impacts are anticipated to local employment, businesses, or government revenue/expenditures, since no changes in property ownership, displacement, or limited access would occur as a result of the project. Soils Yes Yes Refer to discussion in Chapter 3 Affected Environment/Environmental Consequences (Section 3.3). Travel Management Yes No No impacts are anticipated since no temporary or permanent access limitations or road closures are associated with either of the alternatives. No new access or travel routes are proposed or evaluated in this EA. Furthermore, since neither of the alternatives would result in any overall net increase in vehicles, no impacts to existing roads are anticipated. Water Resources Yes Yes Refer to discussion in Chapter 3 Affected and Quality Environment/Environmental Consequences (Section 3.4). (Drinking/Surface/ Groundwater) Wetlands, Riparian Yes Yes Refer to discussion in Chapter 3 Affected Areas Environment/Environmental Consequences (Section 3.5).

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May be May be Resource Or Issue Present Affected Rationale for Determination Yes/No Yes/No Wild and Scenic Yes Yes Of the 0.25-mile wide corridor of the Fossil Creek Wild and Rivers Scenic River, the ROW currently encompasses 21.25 acres of the 2,915 acres within the Coconino and Tonto National Forests. This portion of Fossil Creek has “outstandingly remarkable” wild river values and flows through a series of canyons. From the creek, views of the ROW corridor would be from an inferior position (below the ROW), and the potential for the casual observer to see routine vegetation management activities from either alternatives would not be likely. The Upper Verde River contains segments that are determined Wild and Scenic for three classifications, 1) wild, 2) scenic, and 3) recreational. No impacts are anticipated within Upper Verde (wild) Wild and Scenic Rivers because there are no ROWs that cross or are within 0.25 mile of the portion of these rivers with “outstandingly remarkable” wild river values. Vegetation growing in surface waters would not be treated in the segments of the Upper Verde Wild and Scenic River (Segments 3-scenic and 4-recreational) within the ROW. Vegetation adjacent to these segments of the Upper Verde River would be treated in some locations, outside of established buffers or according to design features. Of the 0.25-mile wide corridor of Segment 3 of the Upper Verde River, the ROW currently encompasses 16.61 acres of the 5,684 acres within the Tonto, Prescott, and Coconino national forests. This portion of the Verde River flows within incised landforms where views are spatially enclosed. The vegetation is predominately pinyon-juniper scattered in random patterns on the sloping landforms. Deviation from the existing landscape character within the ROW would be at the same scale and repeat the form, line, and pattern of the existing and future conditions of the ROW. Potential short-term, negligible adverse impacts within the ROW would occur in Alternatives A and B where mechanical and manual treatments occur because of the low contrast in color and form that would occur with the cutting and disposal of vegetation during routine vegetation management activities. The long-term effects from the application of herbicides in Alternative B may be a subtle change in the texture and form as compared to Alternative A because over time the taller incompatible vegetation would be replaced with low- growing compatible vegetation. With the implementation of Alternative B, less frequent and intense manual and mechanical treatments would occur with the establishment of compatible vegetation. The design features and preparation the PUP prior to routine vegetation maintenance work considers issues related to scenery resources that the individual forest may have with the implementation of Alternative B. Therefore, scenery resources will not be further analyzed in this EA. Wilderness Areas Yes No No herbicide treatments are proposed within wilderness areas therefore wilderness resources will not be further analyzed in this EA. Scenery Resources Yes Yes The Forest Service manages scenery resources within National

313 Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests

May be May be Resource Or Issue Present Affected Rationale for Determination Yes/No Yes/No Forest System lands based on the agency’s Scenery Management System (USDA 1995). The ROW has been assigned Scenic Integrity Objectives (SIOs) that establish limits of acceptable alterations in the character of the landscape. Scenic integrity relates to the level of intactness of, or conversely the degree of deviation from, the existing or desired character of the landscape. The majority of APS ROWs (56.20 percent) is categorized as a Moderate SIO, which allows for changes in the landscape character to appear slightly altered and 23.42 percent of the ROW is identified as either Low or Very Low where deviations can dominate the landscape. The remainder of the ROW is identified as High (19.95 percent) and Very High (0.42%). and which by definition the landscape should appear with either minute if any deviation or where deviations are not evident. The landscape character within the authorized ROW designated as Very High/High SIOs has already been altered by the construction of the overhead power lines, structures and the routine vegetation management (mechanical, manual, and DSAP treatments) of the ROW. The deviation from the existing landscape character within the ROW would be at the same scale and repeat the form, line, and pattern of the existing and future conditions of the ROW. Design features would minimize potential affects to scenery resources associated with incompatible vegetation management. Potential short-term, negligible adverse impacts within the ROW would occur in Alternatives A and B where mechanical, manual, and DSAP treatments occur because of the contrast in color and form that would occur with the cutting and disposal of vegetation during routine vegetation management activities. The long-term effects from the application of herbicides in Alternative B would be a subtle change in the texture and form as compared to Alternative A because over time the taller incompatible vegetation would be replaced with low-growing compatible vegetation. With the implementation of the design features for both Alternatives A and B, the Moderate, Low, and Very Low SIOs would be met within the existing and future conditions of the authorized ROW. Conformance with Very High and High SIOs within the ROW under either alternative may not be met depending on the site specific conditions immediately after incompatible vegetation treatments, however these scenery objectives would be meet over the long-term between treatment cycles. The preparation the PUP prior to routine vegetation maintenance work being done would consider any issues related to scenery resources that the individual forest may have with the implementation of Alternative B. Therefore, scenery resources will not be further analyzed in this EA. Wild Horses and Yes No No temporary displacement would be required during active Burros treatments. Spot treatment and the use of the adjuvant would eliminate the need for any restricted or limited access. Therefore, no potential effect on herd or populations as a whole is anticipated as a result of either alternative.

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Appendix I. Projects Considered for Cumulative Effects Analysis

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U.S. Department of Agriculture Forest Service Projects

Four Forest Restoration Initiative (4FRI) Source: Final Environmental Impact Statement for the Four-Forest Restoration Initiative with Errata and Objection Resolution Modifications, U.S. Department of Agriculture Forest Service, Coconino and Kaibab National Forests, Coconino County, Arizona. April 2015. This is a landscape-scale restoration project located on the Coconino, Apache-Sitgreaves, and Tonto National Forests of ponderosa pine ecosystems, designed to maintain, improve, and restore ecosystem structure, pattern, function, and resiliency. This would involve proposed mechanical thinning, prescribed fire, and other restoration activities throughout the project area that would make the forest more resilient to natural disturbances such as fire, insect and disease, and climate change. The project is expected to move almost 600,000 acres toward comprehensive, landscape-scale restoration with benefits that include improved forest function and health, vegetation biodiversity, wildlife habitat, soil productivity, watershed function, and reduced risk of severe fire effects. These activities will be completed on National Forest System lands and involve vegetation that may fall within the Cumulative Effects Study Area (CESA) for this project. The Record of Decision (ROD) for the 4FRI was signed on April 17, 2015 and selected Alternative C. Approximately 13,463.29 acres of the 4FRI project area are located within the CESA. Currently, the Forest Service is planning an implementation project for 4FRI called 4FRI Rim Country project, where approximately 2,134.24 acres of the project area is located within the CESA.

Western Area Power Administration Glen Canyon - Rogers 230/345kV Integrated Vegetation Management Program Source: Recommendation for the Western Area Power Administration Loveland Area Projects and Colorado River Storage Project To Pursue Final Negotiations Regarding Membership in a Regional Transmission Organization Federal Register Notice, Western Area Power Administration. Federal Register Vol. 82, No. 196/Thursday, October 12, 2017. Western Area Power Administration (WAPA) is proposing to implement an operation and maintenance (O&M) and Integrated Vegetation Management (IVM) program on the Rogers- Glen Canyon section of the Colorado River Storage Project (CRSP) Transmission System. This program would include the use of herbicides. Operations and maintenance activities would consist of aerial and ground patrols, regular and preventive maintenance, inspections and repairs, and road repair. The IVM program would remove vegetation to protect facilities from fire, control the spread of noxious weeds to protect environmental quality, establish and maintain stable, low-growing plant communities in the right-of-way (ROW), and provide for public and worker safety around transmission lines and other facilities. This environmental assessment (EA) will include vegetation management for six substations, nine communication sites, and 262 miles of transmission lines. The substations and communication sites are primarily located in central and northeast Arizona. The transmission line runs from Mesa to Page, passing just east of Flagstaff. This project is in the early stages of document preparation, therefore very little information about specific actions or anticipated impacts is currently available. However, herbicides will be used as a form of vegetation management. Approximately 0.31 miles of this project area are located within the CESA.

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Turkey Butte/Barney Pasture Forest Health Restoration Source: Turkey Butte - Barney Pasture Forest Health Restoration Project Proposed Action, U.S. Department of Agriculture Forest Service, Coconino National Forest, Flagstaff Ranger District. April 2012. The Turkey Butte/Barney Pasture Forest Health Restoration EA project would involve tree thinning and prescribed burns to help improve forest and watershed health solely on Coconino National Forest lands. The primary purpose of the Turkey Butte-Barney Pasture Project is to improve and restore forest and ecosystem health, structure, functioning, and resilience within the 17,838 acre project area. Additionally, there is a need to reduce the current high fire hazard and restore the historic function of fire in southwestern ponderosa pine forests to the project area in order to achieve and maintain desired forest and ecosystem conditions. The project proposes to use mechanical and hand thinning, pile and prescribed burning, individual tree cutting by hand, and tornado salvage. Resource impacts have not been reviewed, however mitigation were present in the Proposed Action document. The project is ongoing and expected implementation is September 2020. Approximately 105.3 acres of this project area are located within the CESA.

Cragin Watershed Protection Project Source: Cragin Watershed Protection Project Preliminary Environmental Assessment, U.S. Department of Agriculture Forest Service, Coconino National Forest, Mogollon Rim Ranger District. June 2017. The Cragin Watershed Protection Project proposes fuel reduction on over 64,000 acres within and adjacent to the watersheds that drain into the C. C. Cragin (formerly known as Blue Ridge) Reservoir. The purpose of the Cragin Watershed Protection Project is to reduce the risk of uncharacteristic wildfire and subsequent flooding and sedimentation within and adjacent to the three sub-watersheds that drain to C.C. Cragin reservoir through a combination of mechanical thinning and prescribed fire. The Proposed Action consists of a variety of vegetation treatments, fuels reduction, and prescribed burning actions over the next 20 years. Mechanical and hand vegetation treatments are proposed over about 39,000 acres and prescribed burning actions are proposed over about 64,000 acres within the project area. Expected implementation for this project is July 2018. Approximately 30.36 acres of this project area are located within the CESA.

Pinto Valley Mine Plan of Operations Source: Pinto Valley Mine Plan of Operations, U.S. Department of Agriculture Forest Service, Tonto National Forest, Globe Ranger District. May 2016. The Pinto Valley Mine is an existing copper and molybdenum mine located approximately 8 miles west of Town of Miami, Arizona, on private and National Forest System lands in the Globe Ranger District, Tonto National Forest, in Gila County. The Pinto Valley Mine EIS proposes to expand the existing copper mine and operation facilities. The new disturbances proposed to take place on National Forest System lands includes the installation of temporary roads and installation of two water pipelines. Of the estimated 1,011 acres proposed to be affected only 245 acres is on National Forest System lands. Of that 245 acres, 0.92 acre is within the APS ROW. The approximate locations are as such: 0.62 miles of APS ROW falls within the "Approximate Boundary Unpatented Claims" on the NE side of the expansion, 0.14 miles on the W side of the expansion, and 0.16 miles on the SW side of the expansion. Implementation of this project would follow the anticipated final ROD in the third quarter of 2019. Approximately 32.75 acres of this project area are located within the CESA.

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Haigler Fuels Analysis Source: Haigler Fuels Analysis Project Scoping Letter, U.S. Department of Agriculture Forest Service, Tonto National Forest, Pleasant Valley Ranger District. March 2011. The Haigler Fuels Analysis project proposes to manage timber and woody vegetation to help maintain forest health, reduce forest fuels, and improve wildlife habitat and range conditions on approximately 43,435 acres of the Tonto National Forest near Young, AZ. The purpose of the project is to maintain the health of forest and woodland vegetation, reduce forest fuels and the potential for large stand-replacement wildfire, and improve wildlife habitat and range conditions on Forest Service land. A combination of varied burn intensities, shaded fuel breaks, and pile burning are anticipated to be used in order to achieve the project goals. This project is currently on hold, and as such an expected implementation date is unknown. Resource impacts have not been reviewed. Approximately 121.06 acres of this project area are located within the CESA.

Jack Smith-Shulz Fuels Reduction and Forest Health Project Source: Decision Notice and Finding of No Significant Impact Jack Smith/Schultz Fuels Reduction and Forest Health Project, U.S. Department of Agriculture Forest Service, Peaks and Mormon Lake Ranger District, Coconino National Forest, Coconino County, Arizona. August 2008. The Jack Smith-Shulz Fuel Reduction and Forest Health project addresses hazardous fuel reduction to reduce flame lengths, fuel loads, and crown fire potential, and allow low to moderate surface fires to take place. In addition, it would reduce canopy cover and stand densities while restoring a diverse, uneven-age forest structure that is essential for understory diversity and wildlife habitat. To accomplish these goals, approximately 9,660 acres will be thinned and/or prescribed burned. The project also includes fencing to protect aspen regeneration on 150 acres and obliteration of 38 miles of roads which are damaging natural resources. Implementation of the project began in spring, 2009 on approximately 1,500 acres. No EA is available on the FS website. The exact area of this APS ROW is unknown. However, the Decision Notice and Finding of No Significant Impact is available for this project. Alternative 2 was selected which involves thinning and/or prescribed burning on approximately 9,662 acres within the 11,827 acre Jack Smith/Schultz Project area as described in the Jack Smith/Schultz Fuels Reduction and Forest Health Project Environmental Assessment (EA).

Highway Tanks Tribal Forest Protection Act Project Source: Highway Tanks Tribal Forest Protection Act Project Scoping Letter, U.S. Department of Agriculture Forest Service, Tonto National Forest, Globe Ranger District. December 2017. This project would focus on restoration of fire adapted ecosystems, including mechanical thinning and prescribed burning to accomplish landscape restoration objectives as proposed by the Tribe that are on the Tonto National Forest and Tribal Land. The project area is approximately 250,000 acres encompassing part of the San Carlos Apache Indian Reservation to the east and part of the Tonto National Forest, Globe Ranger District, to the west. Although no prescribed fire would occur, mechanical thinning could occur within the ROWs. Approximately 0.05 acre of this project area is located within the CESA.

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Tonto National Forest Motorized Travel Management Source: Travel Management on the Tonto National Forest Final Environmental Impact Statement, U.S. Department of Agriculture Forest Service, Tonto National Forest. June 2016. The Tonto National Forest has released the draft ROD in compliance with the Final Travel Management Rule, which requires that all National Forest System lands designate roads, trails, and areas for motor vehicle travel. This EIS selected a modified version of alternative C which would involve road designation; some roads would involve decommissioning. Also, motor vehicle use would be allowed within one mile on both sides of designated roads and motorized trails, solely for hunting. Motor vehicle use would be allowed up to 100 feet on both sides of existing roads and motorized trails for camping. Fuelwood gathering would be limited to 300 feet of a designated road or motorized trail. Approximately 45.51 miles of roads for this project area are located within the CESA.

Spring Prescribed Fire Project Source: Spring Prescribed Fire Project CE, U.S. Department of Agriculture Forest Service, Tonto National Forest, Pleasant Valley Ranger District. April 2018. This project proposed prescribed burning on 211,218 acres within the Spring Fuel analysis area to improve timber stand conditions and wildlife habitat by reducing the fire hazard and natural fuel build-up. The project area is located South and West of Young, Arizona. The project area borders the Hellsgate Wilderness to the North and East of Pleasant Valley and the eastern boundary is the Fort Apache Reservation and Cherry Creek. The proposed action would help maintain the health of the forest and woodland vegetation. Approximately 160.19 acres of this project area are located within the CESA.

Resolution Copper Project and Land Exchange Source: Tonto National Forest; Pinal County, AZ; Resolution Copper Project and Land Exchange Environmental Impact Statement, U.S. Department of Agriculture Forest Service, Tonto National Forest. Federal Register Vol. 81, No. 53/Friday, March 18, 2016. The Tonto National Forest is preparing an environmental impact statement (EIS) to disclosure the environmental effects from: 1) a mining proposal submitted by Resolution Copper; 2) the exchange of land between Resolution Copper and United States. No project maps are currently available and the exact area of this APS ROW is unknown.

Rim Lakes Forest Restoration Project Source: Final Environmental Impact Statement for the Rim Lakes Forest Restoration Project, U.S. Department of Agriculture Forest Service, Apache-Sitgreaves National Forests, Black Mesa Ranger District. 2013. This project is located within the Black Mesa Ranger District of the Apache-Sitgreaves National Forests and proposed forest restoration treatments consists of broadcast burning of approximately 9,339 acres and thinning of approximately 23,615 acres. An Environmental Impact Statement was prepared and the Record of Decision was issued in July of 2013 which selected a modified version of Alternative B. Approximately 248.42 acres of this project area are located with the CESA.

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USDA Forest Service Designation of Section 368 Energy Corridors on National Forest System Land in 10 Western States Source: USDA Forest Service Designation of Section 368 Energy Corridors on National Forest System Land in 10 Western States, U.S. Department of Agriculture Forest Service, January 14, 2009. The Forest Service assisted as a cooperating agency in the preparation a Programmatic Environmental Impact Statement (PEIS) to amend Land Management Plans (LMPs) for the designation of section 368 energy corridors. The PEIS identified potential Section 368 energy corridors; evaluated effects resulting from their designation; identified mitigation measures of potential effects anticipated from future development; and included the Interagency Operating Procedures applicable to the planning, construction, operation, and decommissioning of future projects within the corridors. The corridors on NFS lands are located in 10 of the 11 contiguous western states and include Arizona, California, Colorado, Idaho, Montana, Nevada, Oregon, Utah, Washington, and Wyoming. A Record of Decision to amend LMPs was issued on January 14, 2009 and included designating corridors at the specified centerline, width and compatible uses.

Hicks-Pikes Peak Allotment Grazing Authorization Source: Hicks-Pikes Peak Allotment Grazing Authorization Preliminary Environmental Assessment, U.S. Department of Agriculture Forest Service, Tonto National Forest, Globe Ranger District, Coconino, Gila, and Yavapai Counties, Arizona. September 2017. This project is a new planning effort to authorize livestock grazing on the Hicks-Pikes Peak Allotment in a manner that is consistent with the goals, objectives, and standards and guidelines of the Tonto National Forest Plan. The Hicks-Pikes Peak Allotment is located eight miles north and northwest of Globe, Arizona in Gila County. It encompasses a total area of 66,838 acres spread over 18 pastures. This project proposes to continue to authorize livestock grazing on the Hicks-Pikes Peak allotment. Approximately 91.13 acres of this project area are located within the CESA.

Coconino National Forest - Travel Management EIS Implementation Source: Final Environmental Impact Statement Travel Management on the Coconino National Forest, U.S. Department of Agriculture Forest Service, Coconino National Forest. September 2011. This involves ongoing implementation of motor vehicle management on the Coconino National Forest. Implementation includes blocking and signing non-designated roads that result in user- conflict or where unauthorized motor vehicle use causes effects to forest resources. A Record of Decision was signed on September 28, 2011 and selected “Alternative 3, as Modified.” Approximately 58.24 miles of roads for this project area are located within the CESA.

Apache-Sitgreaves National Forests – Travel Management Source: Apache-Sitgreaves National Forests, Schedule of Proposed Actions, Apache-Sitgreaves National Forests Public Motorized Travel Management Plan EIS, U.S. Department of Agriculture Forest Service, Apache-Sitgreaves National Forests. This is a Forest Service proposal to designate motorized travel routes (roads and trails) in areas on federal lands administered by the Forest Service within the Apache-Sitgreaves National Forests. The purpose of this project is to comply with the Travel Management Rule by providing a system of roads, trails, and areas designated for motor vehicle use that reduces impacts to biological, physical, and cultural resources on the forests. The revised proposed action would designate a system of roads, trails, and areas for motorized use as well as motorized access for

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dispersed camping and motorized access for big game retrieval. The road system would have 15 percent fewer roads and 68 percent more motorized trails than the current system. That would result in 2,890 miles of NFS roads open to public motorized travel, including 2,143 miles of roads that are open to both highway legal and off-highway vehicles. Also, this would result in 270 miles of motorized trails across the Forests, with 20 miles open to all vehicles and 182 miles open to vehicles less than 50 inches wide. The proposed action would designate 300 feet from either side of around 35 percent of the designated open roads (1,027 miles) for the sole purpose of accessing dispersed camping locations with motor vehicles. Motorized big game retrieval would be allowed within a 1-mile distance off the designated road and motorized trail system (1.2 million acres) for elk. No other species would be retrieved using motor vehicles. There would be one motorized use area designated (17 acres). All other cross country travel would be prohibited (Federal Register, Vol. 82, No. 189). There are 36.09 miles of this project area located within the CESA.

Fossil Creek WSR Interim Management Source: Decision Memo Fossil Creek Interim Management, U.S. Department of Agriculture Forest Service Red Rock Ranger District, Coconino National Forest Payson Ranger District, Tonto National Forest Coconino and Gila County, Arizona. February 2016. This would implement additional interim management actions to protect Fossil Creek Wild and Scenic River (WSR) values and improve public safety. Short-term actions include using a reservation system and temporary entry booths to manage day use and camping. This is located along the designated Fossil Creek Wild and Scenic River and a 1/4 mile boundary on either side of the creek. In some instances there are management actions proposed beyond the WSR corridor as well. The Decision Memo Fossil Creek Interim Management was signed on February 23, 2016. As part of this decision, it was determined that entry stations and parking would be provided and a permit system implemented to restrict use. Approximately 24.42 acres of this project area are located within the CESA.

Kelly Motorized Trails Source: Environmental Assessment for the Kelly Motorized Trail Project, Coconino National Forest, U.S. Department of Agriculture Forest Service, Southwestern Region. September 2012. The Kelly Motorized Trails project is a Coconino National Forest project to create a sustainable motorized trail system for both single-track (motorcycles) and larger off-highway vehicles using a combination of existing non-system trails, roads, and new trail construction. The project area is generally bound on the north by the southern boundary of the Flagstaff Airport, Forest Road 240 on the south, and Interstate 17 on the west, and Forest Road 132 on the east, within the Flagstaff Ranger District. Alternative C was selected on December 10, 2012, which would designate a trail system that includes approximately 95 miles, of which 52 miles will be designed for motorcycles only, and 43 of which will be designed for use by OHVs 62 inches or less in width. Approximately 33.27 acres of this project area are located within the CESA.

Hassayampa Landscape Restoration Project Source: Hassayampa Landscape Restoration Environmental Assessment, U.S. Department of Agriculture Forest Service, Prescott National Forest, Bradshaw Ranger District. January 2018. The Bradshaw Ranger District, Prescott National Forest, is proposing to reduce hazardous and excess fuels and restore fire to its natural role on approximately 246,000 acres of National Forest System Lands. This project would include a combination of vegetation management treatments,

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including mechanized and non-mechanized fuels treatments, prescribed burning, and fuelbreak construction. The project area includes National Forest System lands south, southeast, and southwest of the city of Prescott, Arizona. Approximately 92.58 acres of this project area are located with the CESA.

Larson Forest Restoration Project Source: Larson Forest Restoration Project, U.S. Department of Agriculture Forest Service, Apache-Sitgreaves National Forests, Black Mesa Ranger District. August, 2015. The project included thinning trees, prescribed fire, and watershed, wildlife habitat, and transportation improvements on the Black Mesa Ranger District, adjacent to the Forest Lakes Estates community. The Decision Notice was issued in August of 2015 for this EA and selected a modified Alternative 2 with modification which included selectively cutting trees and broadcast burning after treatment on approximately 25,701 acres. Additionally, the project involves broadcast burning on approximately 4,906 acres, vegetation treatment within Mexican spotted owl protected activity centers, and mechanical treatment in up to 26,916 acres in Northern Goshawk areas. There are 13 miles of this project within the CESA. However, this project only proposes actions within 4 miles of the CESA. Therefore, approximately 145.45 acres of this project area are located within the CESA.

Rock Pit Development: Coconino and Kaibab National Forests Source: Rock Pits Environmental Assessment, U.S. Department of Agriculture Forest Service, Coconino and Kaibab National Forests. June 2016. This project consists of the approved development, operation, and in some cases expansion of 37 pits throughout the Coconino and Kaibab National Forests for aggregate material to use for road maintenance throughout the forests. Separate decisions were signed approving rock pit development and operation for a total of 35 rock pits across both forests, with additional reclamation of 3 existing pits. The Rock Pits Environmental Assessment analyzed impacts to resources as a result of the selected alternative: Alternative B – Proposed Action. Approximately 1.98 acres of this project area are located within the CESA.

Chino Landscape Restoration Source: Chino Landscape Restoration Draft Environmental Assessment, U.S. Department of Agriculture Forest Service, Chino Valley Ranger District, Prescott National Forest, Yavapai County, Arizona. January 2018. This project will encompass a series of actions targeting watershed function, wildlife habitat, vegetation conditions, and natural fire regime. The project area consists of 484,000 acres in the northern part of the Prescott National Forest and spans both sides of the Chino Valley Ranger District. Project activities will primarily consist of landscape scale treatment of vegetation with an emphasis on the improvement of wildlife habitat and watershed function. Approximately 1,431.37 acres of this project area are located within the CESA.

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County and State Projects

Rio de Flag FUTS Extension Project Source: Rio de Flag - FUTS Extension Project Overview, Coconino County, Arizona. May 2017. The goal of the Rio de Flag Flagstaff Urban Trail System (FUTS) Extension Project is to extend the Flagstaff Urban Trail system along the Rio de Flag and ultimately to Picture Canyon. The project involves construction of the trail, revegetation of the waterway, improvement of the yard's drainage, and relocation of the water standpipe that is located near the Sheep Hill Yard Access Road on the south side of the department's main office at 5600 E. Commerce Avenue. Another objective of this project is to restore the canyon slopes so that they emulate the natural surrounding landscape of this area, which is adjacent to a section of the . Approximately 24.65 acres of this project area are located within the CESA.

Dry Lake ll Solar Project Source: Dry Lake ll Photovoltaic Solar Power Generation Facility Special Use Permit Application, Navajo County Public Works Department, Navajo County, Arizona. May 2011. This is a special use permit to allow Aurora Solar to place a 399 acre solar generating station facility within a portion of the Dry Lake ll wind farm. The project area is located approximately 4 miles north of the Town of Snowflake. Approximately 41.15 acres of this project area are located within the CESA.

Mountain View Estates Access Road Source: Projects in Area 1, Current Projects, Pinal County Public Works Department. Pinal County, AZ. July 2018. This project involves construction of a new roadway from Sunland Gin Road to John Jacob Astor Avenue. Approximately 2.33 acres of the Mountain View Access project area are located within the CESA.

Henness Road Source: Projects in Area 3, Current Projects, Pinal County Public Works Department. Pinal County, AZ. July 2018. This project involves construction of a new roadway from Val Vista Road to Waverly Road. Approximately 1.15 acres of the Henness Road project area are located within the CESA.

Tonto Natural Bridge State Park Source: Project Managers Report, Project Resource Offices - List of Projects. Arizona Department of Transportation. July 2018. This project would involve the construction of a new roadway.

SR 73 Frontage Road Source: Project Managers Report, Project Resource Offices - List of Projects. Arizona Department of Transportation. July 2018. This project would involve the construction of a new roadway.

SR 85 – SR 303L Source: Project Managers Report, Project Resource Offices - List of Projects. Arizona Department of Transportation. July 2018. This project would involve the construction of a new roadway.

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SR 303L – SR 202L, South Mountain Source: Project Managers Report, Project Resource Offices - List of Projects. Arizona Department of Transportation. July 2018. This project would involve the construction of a new roadway.

I-10 Maricopa, MP 54 – I-10 Source: Project Managers Report, Project Resource Offices - List of Projects. Arizona Department of Transportation. July 2018. This project would design construct and maintain a new approximately 22-mile-long freeway. Approximately 11.19 acres of this project area are located within the CESA.

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