Environmental Assessment Non Native Invasive Management Chippewa NF

Environmental Assessment Non-Native Invasive Plant Management Chippewa National Forest

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Contents

Chapter 1: INTRODUCTION, PURPOSE AND NEED, PUBLIC INVOLVEMENT, AND ISSUES .. 7 1.1 Document structure ...... 7 1.2 Summary ...... 7 Table 1.2.1 Maximum herbicide treatment acres by species ...... 8 1.3 Purpose and need ...... 9 1.3.2 Introduction ...... 9 1.3.3 Laws, Regulations and Policies that direct us to manage invasive species ...... 9 1.3.4 Existing Condition ...... 10 1.3.5 Desired Condition ...... 11 1.3.6 How to meet Purpose and Need...... 12 1.3.7 Timing ...... 13 1.4 Project area ...... 13 1.5 Proposed Action (Original) ...... 13 1.6 Scoping and public Involvement ...... 14 1.7 - Issues ...... 15 1.7.1 Key Issues ...... 15 1.7.2 Non-Key Issues ...... 16 CHAPTER 2: ALTERNATIVES ...... 17 2.1 Development Of Alternatives ...... 17 2.2 Forest Plan Management Direction And Consistency ...... 17 2.3 Alternatives Analyzed In Detail ...... 17 2.3.1 Alternative A - No Action ...... 17 2.3.2 Alternative B – Programmatic Integrated Pest Management ...... 17 2.3.3 Alternative C - Programmatic Integrated Pest Management With Only Site Specific Use of Herbicides on Leech Lake Reservation ...... 18 2.3.3 Alternative D - No Use of Herbicides...... 18 2.4 Treatment Details ...... 18 2.4.1 Programmatic Treatment ...... 18 2.4.2 Treatment Methods ...... 18 Table 2.4.1 – Sequence and priority of treatments by species ...... 23 Table 2.4.2 Herbicide Treatment Summary ...... 28 Table 2.4.3 -- Proposed Herbicides ...... 31 2.4.3 Treatment Strategies ...... 32

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2.5 New Species ...... 32 2.6 Alternatives Considered But Eliminated From Detailed Study ...... 33 2.6.1 - The Original proposed action as Scoped ...... 33 2.6.2 - Close Selected Roads to Minimize NNIP Spread ...... 33 2.7 Project Design Features and MItigation Measures ...... 33 2.7.1 Tribal Consultation ...... 33 2.7.2 General ...... 34 2.7.3 Storage and Disposal ...... 34 2.7.4 Drift Avoidance ...... 34 2.7.5 Neighbors ...... 34 2.7.6 Soil and Vegetation ...... 35 2.7.7 Wildlife and Threatened, Endangered and Sensitive Species ...... 35 2.7.8 Water ...... 35 2.7.9 Herbicide Transportation and Handling Safety/Spill Prevention and Containment ...... 36 2.8 Comparison of alternatives ...... 37 Table 2.8.1 Comparison of Alternatives ...... 37 2.9 Monitoring ...... 39 CHAPTER 3: ENVIRONMENTAL CONSEQUENCES ...... 40 3.1 Introduction ...... 40 3.2 Human Health and Safety ...... 40 3.2.1 Issue ...... 40 3.2.2 Scope of the Analysis ...... 40 3.2.3 Regulation of Pesticides ...... 40 3.2.4 Extra Steps for Safety ...... 41 3.2.5 Analysis methods ...... 41 3.2.6 Direct and Indirect Effects ...... 42 Table 3.2.1 Scenarios exceeding human toxicity hazard quotients from herbicide applications. .. 44 3.2.7 Comparison of Alternatives ...... 45 3.2.8 Cumulative Effects ...... 45 3.3 Traditional Practices ...... 46 3.3.1 Issue ...... 46 3.3.2 Scope of the Analysis ...... 46 3.3.3. Management Direction and Forest Plan Consistency ...... 46 3.3.4 Existing Condition ...... 47

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3.3.5 Direct and Indirect Effects ...... 48 3.3.6 Cumulative Effects ...... 51 3.4 Wildlife ...... 53 3.4.1 Scope of the Analysis ...... 53 3.4.2 Management Direction and Forest Plan Consistency ...... 53 3.4.3 Existing Condition/Affected Environment ...... 53 3.4.4 Threatened and Endangered Species ...... 53 Table 3.4.1 -- Threatened and Endangered Species known or suspected to occur within the area of influence of the NNIPC project ...... 53 3.4.5 Regional Forester’s Sensitive Species (RFSS) ...... 55 Table 3.4.2 Summary of effects to RFSS from implementation of Alternatives A, B, or C ...... 56 3.4.6 Management Indicator Species (MIS) ...... 60 3.4.7 Management Indicator Habitats ...... 61 3.4.8 Neotropical Migratory Birds ...... 62 3.4.9 Selected Game Species ...... 62 3.5 Water Quality ...... 64 3.5.1 Issue ...... 64 3.5.2 Scope of the Analysis ...... 64 3.5.3 Direct and Indirect Effects ...... 64 Table 3.5.1 Indicators of risk to the aquatic environment associated with proposed herbicides ... 65 3.5.4 Cumulative Effects ...... 67 3.6 Historic Properties ...... 69 3.6.1 Issue ...... 69 3.6.2 Scope of the Analysis ...... 69 3.6.3 Management Direction and Forest Plan Consistency ...... 69 3.6.4 Existing Condition/Affected Environment ...... 70 3.6.5 Effects ...... 70 3.7 Vegetation ...... 72 3.7.1 Issue ...... 72 3.7.2 Scope of the Analysis-Direct, Indirect and Cumulative Effects ...... 72 3.7.3 Existing Condition/Affected Environment ...... 72 3.7.4 Direct and Indirect Effects ...... 73 Table 3.7.1 Summary of Direct and Indirect Effects to Vegetation ...... 78 3.7.5 Cumulative Effects ...... 78 3.8 Soils ...... 80

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3.8.1 Issues ...... 80 3.8.2 Scope of the Analysis ...... 80 Table 3.8.1 Area in acres of Clay, Sand, Loam, and Peat/Muck textured soil on Chippewa National Forest Lands ...... 81 3.8.3 Direct and Indirect Effects ...... 81 Table 3.8.2 Indicators of risk to the soil environment associated with proposed herbicides ...... 82 Table 3.8.3 Erosion Hazard Analysis for Soils on Chippewa National Forest Lands ...... 83 3.8.4 Cumulative Effects ...... 84 3.9.1 Issue: ...... 86 3.9.2 Scope of the Analysis ...... 86 3.9.3 Spatial and Temporal Framework ...... 86 3.9.4 Existing Condition/Affected Environment ...... 86 3.9.5 Effects ...... 86 3.10 Environmental Justice ...... 90 3.10.1 Introduction ...... 90 3.10.2 Issue ...... 90 3.10.3 Effects ...... 90 3.11 Economics ...... 92 3.11.1 Scope of the Analysis ...... 92 3.11.2 Issue ...... 92 3.11.3 Effects ...... 92 4. List of Preparers and Agencies Consulted ...... 94 4.1 Core Interdisciplinary Team ...... 94 4.2 Agencies Consulted ...... 94 4.3 Corporations Consulted ...... 94 4.4 Individuals Consulted ...... 94 APPENDIX A: Chippewa National Forest Invasive Plant Management Priority List ...... 96 APPENDIX B: Invasive Proposed for Treatment ...... 97 APPENDIX C: Literature Cited ...... 104 APPENDIX D: Maps ...... 111 Appendix E Summary of Past, Present and Future Invasive Plant Control Actions in the Vicinity of the Chippewa National Forest ...... 121 E.1 Manual Control ...... 121 E.2 Biological Control ...... 121 E.3 Chemical Contol ...... 122

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Chapter 1: INTRODUCTION, PURPOSE AND NEED, PUBLIC INVOLVEMENT, AND ISSUES

1.1 DOCUMENT STRUCTURE

The Forest Service has prepared this Environmental Assessment (EA) in compliance with the National Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. This EA discloses the direct, indirect, and cumulative environmental effects that would result from the alternatives. The document is organized into five parts:

Chapter 1: Introduction, Purpose and Need, Public Involvement, and Issues: This section includes information on the history of the project proposal, the purpose of and need for the project, and the agency’s proposal for achieving that purpose and need. This section also details how the Forest Service informed the public of the proposal and how the public responded. Chapter 2: Alternatives: This section provides a more detailed description of the agency’s proposed actions as well as alternative methods for achieving the stated purpose. These alternatives were developed based on key issues raised by the public and other scoping efforts including contacts with the Leech Lake Band of Ojibwe, and other government agencies. This section also includes discussion for possible mitigation measures. Finally, this section provides a summary table of the environmental consequences associated with each alternative. Chapter 3: Environmental Consequences: This section describes the environmental effects of implementing the alternatives. This analysis is organized by resource area and related key issues. Within each section, the affected environment is described first, followed by the effects of the No Action Alternative that provides a baseline for evaluation and comparison of the other alternatives that follow. Chapter 4: List of Preparers Agencies and Persons Consulted: This section provides a list of preparers and agencies consulted during the development of the environmental assessment. Appendices: The appendices provide more detailed information to support the analyses presented in the environmental assessment.

Additional documentation, including further detailed analyses of project-area resources, may be found in the project planning record located at the Supervisor’s Office in Cass Lake, Minnesota.

1.2 SUMMARY

In order to maintain and improve aquatic and terrestrial wildlife habitat and to maintain healthy, resilient native plant communities, the Chippewa National Forest (CPF) proposes to implement a Forest-wide non-native invasive plant (NNIP) management program, including hand pulling, mechanical and biocontrol treatments on a maximum of 1000 acres and herbicide treatments on up to 530 acres over the next 10 years. Under the proposed action, management would occur on National Forest System Lands and on adjacent federal, state, private or tribal lands under agreements with the land owner or manager per 1998 Wyden Amendment provisions.

This document outlines proposed actions to manage non-native invasive plants (NNIP) and analyzes the potential environmental effects of NNIP management on the Chippewa National Forest. Analysis will weigh the potential adverse effects of taking action versus the effects of taking no action.

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NNIP management will focus on eradicating high priority populations of invasive plants and preventing further spread of larger populations. An integrated approach would be taken to employ the state of the art methods integrating manual, mechanical, cultural, biological and chemical means and incorporating a strong program of ecosystem restoration. Chemical methods would not be used as a tool for large scale (greater than 100 acres) landscape-wide control programs.

Herbicide treatments would be targeted spot treatments using portable sprayers or direct wipe application. Acreage figures refer to overall treated areas; however the actual treatment would be much smaller. In most cases the actual area occupied by the invasive plant, and the area that would actually be exposed to herbicides would be 10 percent or less of the overall treated area. The point here is that treatments would be targeted, and limited. No widespread, landscape-wide, or aerial spraying is proposed.

The potential harmful effects of herbicide application have been thoroughly investigated. These scenarios include the potential for human exposure, the potential effects on native plants which are more susceptible to herbicides than humans or animals, and effects to wildlife, including game species, fish, and amphibians. We thoroughly investigated likely scenarios taking into account local soil, groundwater, and climate conditions in a number of typical sites in the CPF and identified potentially harmful uses of chemicals to be avoided.

Table 1.2.1 Maximum herbicide treatment acres by species More detail can be found in table 2.4.2

Permanent Admin Sites: Natural openings: Developed Gravel Areas: Roadsides, Recreation Total pits Forest, pipelines, power Sites, Wildlife Wetlands lines openings Garlic 30 0 20 50 100 mustard Buckthorn 100 0 10 100 210 Leafy spurge 10 100 5 2 17 Hawkweeds, Thistles, 5 100 5 2 12 Spotted knapweed purple 10 5 5 10 30 loosestrife common 20 100 10 10 40 parsnip Reed 5 100 5 2 12 canarygrass

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Common tansy, St. 5 100 105 102 112 Johnswort

1.3 PURPOSE AND NEED

1.3.2 Introduction Non–native invasive plants (NNIP) alter the type and abundance of organisms (structure), relative abundance of species (organization), and function of ecosystem processes, usually with undesirable outcomes (Olson 1999). NNIPs affect the structure and organization of ecosystems by altering the composition of plant communities, often by displacement of native plant species. By altering the structure of plant communities, NNIPs harm wildlife dependent on native plants for food, cover and shelter. NNIPs affect function of ecosystems by altering soil properties through increased erosion, changes in amount of organic matter and nutrients, and by adding chemical compounds that interfere with soil organisms.

NNIPs can adversely affect plants used by people for harvest of wild foods. They can adversely affect the economy through interference with regeneration of forests after harvest leading to loss of value from forest products, by loss of habitat for commercially valuable wildlife, and degradation of scenery important to tourism. Some NNIPs harm human health.

1.3.3 Laws, Regulations and Policies that direct us to manage invasive species The National Environmental Policy Act (42 U.S.C. 4321-4346) directs Federal agencies to analyze the effects of significant action on the human environment including proposed noxious weed control activities, such as ground-disturbing activities or herbicide application. Unless the action is categorically excluded from documentation, an environmental assessment (EA) is conducted in order to determine if the action requires an environmental impact statement (EIS) or alternatively, a finding of no significant impact (FONSI). This decision will be made by the CPF Forest Supervisor.

Several policy directives require the USDA Forest Service to manage invasive plants. Executive Order 13112 directs federal agencies to prevent introduction of invasive species, detect and respond rapidly to and control populations of invasive species in a cost-effective and environmentally sound manner, monitor invasive species populations accurately and reliably, and provide for restoration of native species and habitat conditions in ecosystems that have been invaded. "Invasive species" means an alien species whose introduction does or is likely to cause economic or environmental harm or harm to human health (EO 13112).

The Federal Plant Protection Act (7 U.S.C. 7701) requires cooperation with State, local, and other Federal agencies in the application and enforcement of all laws and regulations relating to management and control of noxious weeds, including control of undesirable plants which are noxious, harmful, injurious, poisonous, or toxic on federal lands under the agency's jurisdiction and establishment of integrated weed management to control or contain species identified and targeted under cooperative agreements and/or memorandums. Noxious weeds are plants specifically listed by state or federal law as harmful and are often, but not always non-native in origin.

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Forest Service regulations at 36 CFR 222.8 acknowledges the Agency's obligation to work cooperatively in identifying noxious weed problems and developing control programs in areas where National Forest System lands are located.

Departmental Regulation 9500-10 (DR 9500-10) sets forth Departmental policy for the management and coordination of noxious weed activities among agencies of the Department of Agriculture and other executive agencies, organizations, and individuals. DR 9500-10 specifically establishes Integrated Pest Management (IPM) as the preferred approach to noxious weed prevention, control, and eradication.

The Forest Service Manual (FSM2080.2) directs the Forest Service to use an integrated weed management approach to control and contain the spread of noxious weeds on National Forest System lands and from National Forest System lands to adjacent lands. Specific objectives for noxious weed management include prevention of the introduction and establishment of noxious weed infestations and containment and suppression of existing noxious weed infestations. Forest Supervisors are responsible for developing and implementing a noxious weed management program that is consistent with the goals and objectives identified in forest land and resource management plans and district rangers are responsible for preventing the introduction and establishment, as well as providing for the containment and suppression of noxious weeds.

The Wyden Amendment (Public Law 109-54, Section 434) authorizes the Forest Service to enter into cooperative agreements to benefit resources within watersheds on National Forest System lands. Agreements may be with willing Federal, Tribal, State, and local governments, private and nonprofit entities, and landowners to conduct activities on public or private lands for protection, restoration, and enhancement of fish and wildlife habitat and other resources.

The Forest Service Pesticide Use Handbook and Manual (FSH 2109.14 and FSM 2150) provide agency guidance on proper use of pesticides including: applicator certification and documenting pesticide approval, planning, implementation, and reporting of projects that include herbicides. Coordinated Position Statement, Lake States Forest Supervisors (CNNF, Chippewa, Superior, Ottawa, Hiawatha, and Huron-Manistee) regarding herbicide environmental impact statements was amended in 2003 to allow herbicide use to treat invasive plants.

The Minnesota Noxious Weed Law (PR#221) designates eleven native and non native weed species as Prohibited Noxious Weeds, two Restricted Noxious Weeds that cannot be sold or transported in the state and 52 Secondary Species that can be petitioned as a prohibited noxious weed on a county by county basis (PR #222).

1.3.4 Existing Condition The area now inside the CPF proclaimed boundary has experienced disturbance to native vegetation through a variety of means including logging, road construction, alteration of surface waters, farming, homes, towns and associated structures for over one hundred years. This disturbance combined with the influx of settlers of European heritage to the area led to the introduction of a number of non-native plant species. These plants had a broad range of effects on the environment. Some were benign while others caused serious harm to values such as habitat for wildlife, recreational opportunities and opportunities for gathering native plants. During the nineteenth and twentieth centuries new species

7/5/2011 10:55 AM Page - 10 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF continued to be introduced and this process continues with new non-native plant species being introduced in recent times. For instance, garlic mustard, a highly invasive plant species, was found in Cass County for the first time in 2002.

The CPF has developed a prioritized list of 27 non native invasive plant species occurring within or near the CPF proclaimed boundary. This list was developed through a process where the distribution and abundance, ecosystems at risk, and treatment options were evaluated. (CPF-LLBO NNIP Management Plan PR#229). Species considered came from preexisting lists (PR#230), State of Minnesota listed noxious weeds species and professional knowledge and opinion. The final list incorporated species known to disrupt ecosystem structure, organization or function; either on the CPF or elsewhere. Forest staff has recorded over 1300 instances of invasive plant species within the CPF boundary, ranging in size from one square yard to 130 acres, although this list is far from complete.

Most of these mapped infestations are on disturbed areas such as roadsides, gravel pits, and utility corridors, but several infestations are found in high-quality natural habitats with minimal disturbance. High quality natural habitats are locations with intact native plant communities where non-native plants contribute to less than 5% cover, and human-caused disturbance is minimal and rarely occurs. Examples include mature forests, marshes, fens, swamps, bogs and prairie remnants. Examples of lower quality habitats include mowed roadsides, dirt roads, trails, waste areas, utility rights-of-way, administrative sites, mowed lawns, developed campgrounds, picnic areas, parking areas, log landings, and pine plantations. While populations of NNIP on degraded low quality habitats do not immediately interfere with ecosystems, these populations threaten to move into higher value natural habitats.

This EA lists 27 invasive species of concern (Appendix A), and proposes treatment on 17 target species.

1.3.5 Desired Condition The Forest Plan for the Chippewa National Forest directs management in the form of goals, desired conditions, objectives, standards and guidelines.

Two Forest-Wide objectives and one guideline are set for Non-Native Invasive Species:

O-WL-38: Reduce the spread of terrestrial or aquatic non-native invasive species that pose a risk to native ecosystems.

O-WL-39: Use Integrated Pest Management to: Eradicate any populations of new invaders Contain or eradicate populations of recent invaders (i.e., non-native invasive species that have only recently become established but are not widespread in the planning area) Limit the spread of widespread, established invaders within the planning area

G-WL-25: During project implementation, reduce the spread of non-native invasive species. Sensitive plants could potentially be adversely affected by invasive plants. One objective for sensitive plants is relevant to invasive plant management.

Other relevant management direction from the Forest Plan includes:

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O-WL-31: Enhance or restore high-quality habitat on a minimum of 20 (average of 2 sites per year) known sites of sensitive plants. Priority for habitat improvement would generally be for those species and habitats for which: Proactive management (versus protection based on avoidance of any management activities) is needed to maintain species.

D-WL-1: Aquatic and terrestrial wildlife habitats are diverse, healthy, productive, and resilient.

D-WL-5: Roads and trails are managed to protect or maintain native plants and animals, protect water quality, and to manage for compatible human uses and types of access.

D-WL-9: Native plants and animals dominate all terrestrial and aquatic ecosystems, with non-native plants and animals forming, at most, a minor component.

In addition, the USDA Forest Service National Strategy for Invasive species management relies on four elements:

Prevention -- Prevention is the most effective method for managing NNIPs. Methods include limiting dispersal, containing neighboring infestations, minimizing soil disturbances, establishing competitive native plants, properly managing native plant communities (Sheley, et al 1999).

Early Detection and Rapid Response --By increasing resources to detect invasive species, managers may increase their chances of finding a species at a smaller population level, lessening the extent of damages and making subsequent control potentially less expensive and more effective (Mehta et al. 2007). Catching infestations early greatly increases the probability of success and lowers costs of control. (Rejmanek 2002).

Control and Containment -- Once populations have exceeded a threshold where eradication is an achievable goal, focus of management moves to decreasing the size of existing populations, prevention of increases in size, or prevention of establishment of new populations.

Rehabilitation and Restoration -- Removal of invasive plants often results in soil disturbance and a poorly developed native plant community. All invasive plant treatment plans must include a component of restoration. Restoration methods include planting forest trees or appropriate native grass forb mixes in non forested areas. Often, natural reseeding of an area can supplant or substitute for replanting or reseeding.

1.3.6 How to meet Purpose and Need In support of the Forest Plan desired conditions and the National Strategy the following is proposed: 1. Eradication of newly introduced invasive plants that are currently limited in abundance and susceptible to control methods at our disposal 2. Reductions in the distribution and abundance of invasive plants that can be controlled but cannot be eradicated 3. An end to the further spread of widespread and abundant invasive plant populations that are widespread and difficult to control. 4. Rehabilitation and restoration of native plant communities after invasive plant treatment.

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1.3.7 Timing Implementation would occur over a ten year period beginning the first spring (2011) after the Decision Notice and Finding of No Significant Impact (FONSI) is signed by the Forest Supervisor.

1.4 PROJECT AREA

The Chippewa National Forest (CPF) is located in north-central Minnesota, including portions of Beltrami, Cass, and Itasca Counties. The CPF proclamation boundary encompasses approximately 1.6 million acres and includes tracts of National Forest System land totaling approximately 660,000 acres (USDA 2004, p. 1-2). A diversity of vegetation types, soils, and landforms are found on the CPF. The uplands are forested by various stands of northern hardwoods, ash, oak, pine, aspen, spruce, and fir. There is an abundance of lowlands, both forested and shrub/marshy. Streams and lakes are common with about 736 lakes and ponds over 10 acres, about 925 miles of rivers, about 401,000 acres of wetlands and a total of 25 watersheds. The CPF is home to a variety of animals and plants, ranging from common to rare.

1.5 PROPOSED ACTION (ORIGINAL)

The original proposed action included in the scoping letter addressed known NNIP sites and anticipated future areas resulting from temporary roads, utility corridors, harvest activities, trails, etc. in need of treatments:

Approximately 515 infested acres currently known planned for treatment and up to an additional 515 additional acres may be treated as new infestations are found. These sites are most likely to occur in disturbed areas such as gravel pits, roadsides, trails, power lines and other utility corridors plus timber harvest areas and access roads.

Manual and mechanical methods consist of pulling, cutting, root stabbing, scorching, and mowing. These treatments would initially be preferred over chemical treatments for very small, isolated, infestations, or when in close proximity to a known rare plant site.

Herbicides proposed for use are Imazapic, Aminopyralid, Metsulfuron methyl, and Glyphosate. Except for Glyphosate, the application amounts are small.

Biocontrol species would be used for leafy spurge, spotted knapweed, and purple loosestrife. Seedhead fly (Urophora spp.) and a seedhead weevil (Larinus spp.) have been used in Minnesota for Spotted Knapweed and would be used on large infestations. Leafy Spurge Beetles (Apthonia spp.) are also commonly used as a biocontrol species in Minnesota on leafy spurge. Several insects are approved for purple loosestrife by the Minnesota Department of Agriculture and include beetles (Galerucella calmariensis), (Galerucella pusilla), and weevils (Hylobius transversovittatus).

By reducing the vigor of the invasive plant (through mowing at strategic times) and then planting competitive vegetation which provides additional root competition that slows NNIP establishment, invasive plant populations would be reduced.

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1.6 SCOPING AND PUBLIC INVOLVEMENT

On April 30, 2008 a letter and attachments (PR# 105, 105a, 105aa, 105e, 105f, 105g, 105h, and 105i) were sent to 187 individuals, groups, and agencies (PR# 105b, 105c, and 105d) soliciting comments on this proposed action. The scoping letter was also posted on the Chippewa NF website for an extended period of time. A news article about the up-coming project was placed in the DiBahJiMon in May of 2008 asking for comments on the project (PR# 106). The scoping legal notice for this action was published in the Bemidji Pioneer on May 12, 2008 (PR# 106b). The proposal was listed in the Forest's Schedule of Proposed Actions (NEPA Quarterly) on a quarterly basis from October 2007 to present (PR# 99b, 104aa, 104ab, 130, 137b, 138a, 142, and 166).

In response to the scoping letter, four comments were received. (PR# 110, 113, 116, and 128). In addition one comment was received prior to the scoping letter (PR# 104). These Comments generally were supportive of using herbicides. One recommended identifying the sequence of treatments where multiple treatment methods and timing are needed.

In December of 2009 in response to an advance copy of the draft EA released to the Leech Lake Band of Ojibwe (LLBO) the CFP received a letter from the LLBO stating that the Band could not support the document for a range of reasons. The letter suggested that the CPF and LLBO mutually develop an invasive species management plan addressing trust responsibility, impact of NNIP on cultural and traditional plant resources, management strategies, criteria for identifying when herbicide use is justifiable, impacts of management strategies to the environment, DRM permitting process and potential resource sharing.

In January 2010 the CPF and LLBO met to initiate an invasive plant management plan. This resulted in the development of the document Draft LLBO-CPF Invasive Plant Management Plan (PR#277). This document was developed to provide a “road map” for invasive plant management on the Chippewa National Forest. In developing this plan it became apparent that there was a need for National Forest staff to better integrate our program with the Leech Lake Band of Ojibwe. To that end, a species-by- species review was conducted by CPF and LLBO staff to develop priorities, strategies and recommendations for invasive plant management. While this document was never finalized by the LLBO it was used by the Chippewa National Forest to develop treatment priorities, methods and site specifications used in this document.

As of February 2011, contacts and/or discussion of this project has been made with the 13 local Indian Councils (LIC) (PR# 107, 122, 137, 140, 143, 146, 149, 205a, 206, 212, 231, 233, 234, 235, 236, 237, 237a, 238, 239, 240, 241, 242, 243, 245 and 273) and the Division of Resource Management (DRM) of the Leech Lake Band of Ojibwe (LLBO) (PR# 100, 101, 132, 138, 138aa, 139a, 141, 214, 216,218, 224, 225,). Comments covered a range from asking questions about the types of treatments, their costs and effectiveness, to support for the use of herbicides to concern regarding the health effects on people and animals.

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In April 2011 the CPF and LLBO DRM met to discuss a draft of the EA. DRM again stated that concerns on the part of the LLBO about the use of herbicides and the programmatic nature of the document.

In June 2011 CNF and DRM met in the field to discuss garlic mustard management. While a perfect agreement was not reached about herbicide treatment, progress was made in finding common ground as to appropriate situations for use of herbicide. This type of consultation is expected to be the model for future consulation between the LLBO and CNF on actions proposed in this document.

Using the comments from the public, other agencies, and internally; the interdisciplinary team developed the list of issues to address (Section 1.7 - ISSUES).

Since the scoping letter the original proposed action has been revised. The revised proposed action is described in Chapter 2. Issues and concerns identified are primarily tied to herbicide use and would apply to the revised proposed action.

1.7 - ISSUES

An issue is a point of discussion, dispute, or debate involving the proposed action described in terms of an effect on a physical, biological, social, or economic resource. Key issues are used to formulate alternatives for the proposal, prescribe mitigation procedures if necessary, and analyze possible environmental effects. Concerns brought forth by the public about the proposed action, which are not considered issues are discussed only briefly, as allowed by National Environmental Policy Act (NEPA) regulations [40 CFR 1500.4(c) and 40 CFR 1502.2(b)].

1.7.1 Key Issues These are the final Issue Statements for the NNIP EA. These are based on internal discussions and review of scoping comments by the ID Team. Key issues drove the development of alternative courses of action.

Issue 1: Herbicides can have negative effects on human health and safety. Indicator: Hazard quotients for human exposure.

Issue 2: Herbicides can have negative effects on Native American traditional practices: Indicators: Loss of traditionally gathered resources Contamination of spiritual sites

Issue 3: Herbicides can have negative effects on Wildlife Indicator: Potential effects on T&E and RFSS species Management indicator species, management indicator habitats, neotropical migratory birds, and selected game species.

Issue 4. Herbicides may have negative effects on water quality, aquatic organisms, and ground and surface water. Indicators: Water quality: Sedimentation, Maximum Contaminant Load (surface and ground water)

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Aquatic Organisms: Hazard Quotients (under modeled scenarios) Herbicide degradation as measured in half-life (halftime)

Issue 5. The public can not be propertly informed by a programmatic proposal for the use of herbicide. LLBO DRM objected to a programmatic approach to defining the proposed action, specifically for herbicide treatments. A programmatic approach is where the circumstances for a NNIP treatment are defined but not a specific site.

1.7.2 Non-Key Issues Non-key issues are issues that were not brought up as serious concerns but were analyzed to ensure that no significant effects of the proposed action would be overlooked.

Non-key issues addressed in this document: Potential adverse effects of NNIP management to: Historic properties (Section 3.6) Vegetation and native plant communities (3.7) Soils (3.8) Recreation and aesthetics (3.9) Environmental justice (3.10) Economics (3.11)

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CHAPTER 2: ALTERNATIVES

2.1 DEVELOPMENT OF ALTERNATIVES

This chapter describes and compares the alternatives considered for the Non-native Invasive Plants (NNIP) Management Project. It includes a description of each alternative considered in detail. This section also presents the alternatives in comparative form displaying the differences in addressing issues, the associated effects, and in meeting the purpose and need for the project. For each action alternative, mitigation measures, design features, as well as Forest Plan Standards and guidelines, and Voluntary Site-Level Forest Management Guidelines (MFRC (Gold Book) 2005) were identified (Section 2.7).

The interdisciplinary team developed alternatives to the proposed action based on public input and government-to-government consultation with the Leech Lake Band of Ojibwe regarding the effects of herbicides on human health and safety, traditional practices, water quality, and wildlife.

The forest supervisor will select one of the alternatives for implementation or select a modification of an alternative based on analysis of the potential environmental consequences and the effectiveness of meeting the purpose and need for the project and Forest Plan management direction related to this project.

2.2 FOREST PLAN MANAGEMENT DIRECTION AND CONSISTENCY

Alternatives were developed to meet the Forest Plan management directions – Standards and Guidelines for each of the resource areas as specified in the Chippewa National Forest Land and Resource Management Plan. Direction can be found on the following pages in the Forest Plan.

Watershed health, Riparian Areas, and Soil Resources…………..p 2-11 through 2-15 Vegetation………………………………………………………..p 2-21 through 2-24 Terrestrial & Aquatic Wildlife…………………………………...p 2-24 through 2-34 Social and Economic Stability…………………………………...p 2-35 Tribal Rights and Interests: Heritage…………………………….p 2-35 through 2-39 Recreation, Trails, and ORVs……………………………………p 2-39 through 2-43 Public Health and Hazardous Materials………………………….p 2-51 through 2-52

2.3 ALTERNATIVES ANALYZED IN DETAIL

2.3.1 Alternative A - No Action Alternative A proposes no treatments for non-native invasive plants. Since abandoning all efforts at controlling invasive plants would not comply with agency direction, this alternative is presented for comparison purposes only.

2.3.2 Alternative B – Programmatic Integrated Pest Management Treatments as discussed under the revised proposed section include mechanical, cultural, biocontrol and chemical methods. The treatment methods and priorities of methods to use for each species have been

7/5/2011 10:55 AM Page - 17 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF specified along with details on the herbicides proposed on different sites. The specific treatments are detailed in section 2.4.

The revised proposed action shifts emphasis from large scale treatment of invasive species on disturbed sites such as roadsides, trails, utility corridors and timber harvest areas to smaller scale treatments, gravel pits, and sites that pose a potential for invasion into undisturbed natural areas.

2.3.3 Alternative C - Programmatic Integrated Pest Management With Only Site Specific Use of Herbicides on Leech Lake Reservation

This alternative incorporates all the details of Alternative B (see Tables 2.1, 2.2, and 2.3) but restricts use of herbicides on the Leech Lake Reservation to Garlic Mustard on Stony Point/Onigum Area and Common Buckthorn in Stands 09030502047002 (Swede Hill) and 090305021090078 (Oak Point). (See Appendix D for maps.) Alternative C retains the programmatically proposed herbicide treatments on portions of the CPF not in the Leech Lake Reservation (LLR) and non-herbicide treatments including all mechanical, cultural and biocontrol treatments within the proclaimed boundary of the Chippewa National Forest but would restrict chemical methods to those outside the LLR boundary and those mentioned in the preceeding sentence.

2.3.3 Alternative D - No Use of Herbicides. This alternative incorporates all details of Alternative B (see Tables 2.1 and 2.2 but would not allow use of herbicides for any treatment. All other treatments, including manual, mechanical, cultural and Biocontrol methods would be done but no herbicide use would be permitted.

2.4 TREATMENT DETAILS

The CPF proposes to eradicate, control or contain known populations of non-native invasive plants in a series of management actions using an Integrated Pest Management-based approach and incorporating adaptive management principles.

2.4.1 Programmatic Treatment Similar to the process of fighting a wildfire, invasive plant treatment requires some measure of flexibility and rapid response time. Programmatic treatments, rather than specifying specific areas to be treated the document outline the kind of places to be treated and the methods to be used as well as limits to how many acres may be treated in specific land use types but do not specify the exact site to be treated. Site specific treatments are those meet a need known at this time and can be specifically proposed and planned.

2.4.2 Treatment Methods Treatments would be considered in order of preference:

1. Mechanical methods: hand pulling, hand tool digging, mowing, scorch. 2. Cultural methods: tillage, barriers, competitive seeding, controlled burning 3. Biocontrol: insect releases and grazing 4. Chemical methods: foliar wipe, foliar spray, stump, and frill herbicide application.

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In many cases a combination of the treatment methods listed above would be employed.

Hand pulling and hand tool digging are the most selective methods and are highly effective in some cases. NNIP species capable of regenerating from root fragments often do not respond well to this type of treatment. Hand pulling is the most expensive method per acre. Hand methods are most appropriate for small areas, satellite populations, and on fringes of infestations. Hand methods can be implemented with minimal preparation. Hand methods work well in early detection and rapid response operations where small infestations of NNIP species in the early stages of establishment can be found. Hand methods can increase erosion. Hand methods do not work well for species that have extensive underground biomass in the form of roots and rhizomes capable of resprouting.

Mowing rarely kills plants but can be useful to prevent seed production by certain species in easily accessible sites such as roadsides, utility corridors and trails. Timing is critical and in many cases mowed plants would produce new and be capable of setting seed, although often at reduced rates.

Scorch treatments employ use of a propane weed torch to scorch or wilt green . This is done early or late in the growing season when NNIP are green and native perennials are dormant. It does not start a ground fire. Scorch methods do not work well for perennial species that are capable of resprouting from underground roots or rhizomes and would not be used in the majority of cases.

Tillage turns over soil using agricultural equipment such as plows, disks or harrows. Tillage is useful for total restoration projects where the area is so badly degraded that the plant cover must be restarted from scratch. Like hand treatments it may be ineffective for species that regenerate from root fragments. Tillage may be used in combination with herbicide treatments to prepare a site for reseeding with native species. Tillage opens up seed banks and may need to be done repeatedly to remove weeds from the seed bank. Tillage must be carefully evaluated for erosion potential.

Barriers use materials placed on soil to smother infestations of NNIPs. Materials include black plastic, clear plastic, geotextile fabric, rock, soil, wood chips, or any other material capable of smothering plant growth. Loose materials such as rock, soil or wood chips must be thick enough that plants are unable to penetrate the barrier. Barriers are effective if left in place for a number of years. Plants often spread underground so barriers must be larger than the infested site. Barriers are less expensive than hand methods and are effective for small infestations. Materials must be durable enough to last several years and non biodegradable materials must be removed after treatment. Barriers are often ugly and can affect scenic values. Sites are devoid of vegetation after barriers are removed and usually must be reseeded.

Competitive seeding involves reseeding areas with plants that can outcompete NNIPs. This method requires careful selection of desirable species that are well suited to site soil, moisture, nutrient and light conditions to ensure the desired species can outcompete NNIPs. Competitive seeding should use a wide variety of species to create a more diverse and resilient plant community. However, the most aggressive NNIPs are capable of competing with native vegetation. Many NNIPs are not tolerant of shade and on many sites on the CPF vegetation can be expected to change to forested cover. Tree

7/5/2011 10:55 AM Page - 19 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF planting, tree seeding and allowing natural succession processes in this type of situation can be expected to convert the site to a more desirable state.

Controlled burning can be effective when timing and intensity of the fire favors desirable native vegetation over NNIPs. Some plant species are resistant to fire and some are very susceptible to fire. On sites where desirable fire resistant species are in place or can be seeded and NNIPs are fire intolerant, controlled burning can be effective. Controlled burns already being conducted to reduce wildfire risk, for silvicultural treatment, and wildlife habitat improvement could be designed with an eye on timing and intensity to reduce or eliminate NNIPs.

Biological controls involve organisms that feed on or parasitize the target pest. Usually this refers to insects that feed on NNIP but in some cases could refer to microorganisms or grazing animals. Biological control techniques take advantage of the fact that many non-native plants have arrived without being accompanied by their natural enemies.

The CPF proposes to release insects for control of purple loosestrife, spotted knapweed, and leafy spurge. Biological controls reduce numbers and vigor of NNIPs but do not lead to elimination of all individuals in a population. Biocontrol is best employed on large populations of NNIPs where other methods would be costly or ineffective. Biocontrols require a large enough population of target plants in order to complete their life cycle and to remain effective. Studies indicated a minimum of at least one acre of purple loosestrife (PR# 68b), ½ to two acres of leafy spurge with moderately dense patches (60-90 stems per square yard) (PR# 59, p. 5 and PR# 180, p. 2-3), and two acres of spotted knapweed (PR# 68c, p. 2) are required for a successful release. 50-100 insects per release are typical rates.

The U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) is responsible for controlling introductions of species brought into the United States for biological control of plants, in accordance with the requirements of several plant quarantine laws, the National Environmental Policy Act, and the Endangered Species Act. This process begins with surveys in the plant’s area of origin to discover candidate natural enemies, studies on their biology and host specificity and release and evaluation of their impacts on the target plant. Petitions for release of plant biological control agents are judged by a Technical Advisory Group (TAG), which represents the interests of a diverse set of federal and other agencies. Insects used as biological control agents are generally released as adults (not eggs or larvae) between June and August. They may be released by simply emptying a container of insects at an NNIP site, or by placing an insect-bearing plant at the site. If a release is successful, then the insects would continue to live and reproduce at the site as long as the host plant remains. If the host plant is eliminated, the insects would die out.

Biocontrol agents proposed: Black-margined loosestrife beetle (Galerucella calmariensis) for purple loosestrife; Golden loosestrife beetle (Galerucella pusilla) for purple loosestrife; Loosestrife root weevil (Hylobius transversovittatus) for purple loosestrife; Knapweed root weevil (Cyphocleonus achates) for spotted knapweed; Lesser knapweed weevil (Larinus minutus) for spotted knapweed Knapweed seedhead flies Urophara affininis and U. quadrifasiciata Blunt knapweed flower weevil (Larinus obtusus) for spotted knapweed

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Brown-legged leafy spurge flea beetle (Aphthona lacertosa) for leafy spurge; Black dot leafy spurge flea beetle (Aphthona nigriscutis) for leafy spurge; Copper flea beetle (Aphthona flava) for leafy spurge Red-headed leafy spurge stem borer (Oberea erythrocephala) for leafy spurge

All agents proposed are proven for effectiveness and have been used in many parts of the United States since at least the early 1990s without substantial non-target effects. (Weeden et al 2010, Weeden ea al. 2010a, Lang 2010, Lang 2010a, Lang 2010b, Hansen 2010, Hansen 2010a, Hansen 2010b, Hansen 2010c, Hansen 2010d)

Use of grazing animals may be employed by the CPF. This could include using small herds of goats to graze disturbed areas such as roadsides, utility rights-of-way, gravel pits, and landings.

Herbicides provide inexpensive and effective control of many species. Some herbicides have limited selectivity. Common objections to the use of herbicides include effects to humans, wildlife, domestic animals, fish, non-target plants, insects, soil organisms and many other living organisms which compose an important component of healthy ecosystems but are not immediately apparent to the casual observer.

Herbicides are regulated as a class of pesticides by the US Environmental Protection Agency and the Minnesota Department of Agriculture. The public has an interest in how pesticides are handled, used and applied for the protection of public health and security and the environment. Most herbicides and application equipment were developed for use in crop production, where weeds occur in close proximity to food crop plants. These crop plants are also sensitive to herbicide damage, so commonly used herbicide application methods are designed to minimize off-target effects. We can take advantage of these methods to minimize off target effects to wild foods and other resources. Foliar sprays are done at low pressures with large droplet sizes that are more of a sprinkle than a fine mist which eliminates most drift. Application is done during conditions of low wind speed. Dye is added to the chemical mix to enable the applicator to readily see where the chemical is being delivered and allow the public to see the treated area and plants.

Herbicide application methods proposed under Alternatives B and C include spot spray, wipe, basal bark, frill, and cut stump. Spot herbicide application would be done using handheld and backpack sprayers. In some cases sprayers using All Terrain Vehicle-mounted pumps with handheld wand applicators may be used. Wipe methods are those that involve directly sponging chemicals onto target foliage. Woody species can be treated using basal bark application where a stream of herbicide is directed at the bark of the tree or shrub, or by frill methods, sometimes called “hack and squirt” where tissue beneath the bark is exposed and treated with a direct wipe of the chemical. Woody species may also be cut and the exposed stump wiped with herbicide to prevent resprouting.

Broadcast application, where a vehicle mounted boom sprayer applies a selective herbicide to target and non target plants over a large area and spraying with aircraft is excluded from the proposed action.

The objective of herbicide use is to control NNIP infestations where manual or mechanical means are less effective, cost-prohibitive or result in excessive soil disturbance or other resource damage. Potential herbicides listed below were selected based on their effectiveness and low toxicity to non-

7/5/2011 10:55 AM Page - 21 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF target organisms. Generally, there would be one chemical application per site per year with follow-up monitoring and re-treatment in subsequent years. The timing of treatment would vary by NNIP species in order to avoid negative impacts on non-target species and to be most effective on the NNIP.

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Table 2.4.1 – Sequence and priority of treatments by species

Methods are listed in the order that we would consider using them for programmatic treatments. Treatments considered most effective appear first, chemical option listed last unless other methods are not effective.

Species Treatment Method Timing Comments Chemical Hand or backpack sprayer Mid-April to late May Spray in spring and fall and in the fall when other plants are not (rosettes) emergent. Use barriers to minimize off-target effects. Use on larger and denser populations. Manual Hand pull with hand tools April until seed set Use on smaller outlier populations in close proximity to natural vegetation. Hand pulling has the effect of churning soil, increasing garlic mustard seed germination and trampling competing natural vegetation. Garlic Mustard Cultural Tarps/solarization Multi-year Heavily infested areas of low scenery and biological value in sunny spots can be tarped in order to increase soil temperatures until seed is killed.

Cultural Conversion to lawn Multi-year Regular mowing of areas of low biological value can be performed several times per year to establish turf eliminating garlic mustard.

Biocontrol No agents available

Manual Use “weed wrench” Any time soil not frozen Chemical Hand spray basal bark treatment Early September to Basal bark treatment avoids late October. off-target effects and is less Common and labor intensive than cut Glossy stump treatment. Buckthorn, Bush Chemical Hand spray cut stumps Early September to Use cut stump treatment on Honeysuckles late October. stems >6” diameter

Biocontrol No agent available

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Table 2.4.1 (continued) -- Sequence and priority of treatments by species Species Treatment Method Timing Comments Biocontrol Release insects. Early July Use Apthonia Beetles and root weevils for extensive infestations. Cultural Plastic Tarps Multi-year Use tarps to increase soil temperatures and kill plants. This was used successfully in Itasca State Park Chemical Hand or backpack sprayer Late August to mid On small populations, Leafy Spurge October. chemical control is difficult. or Cypress Mid September is Remove flowering tops by Spurge best cutting/mowing before seed set then spray re-sprouts. Use on sites greater than 0.25 acres where tarping or biocontrol is impractical Competitive Light scarification and seed or As soon as possible planting or plant after treatment seeding depending on plant requirements. Mechanical Mow or cut second year plants. Needs periodic mowing at early bud state over several years to reduce seed source. Chemical Hand or backpack sprayer Late August to mid Remove flowering tops by October. cutting/mowing before seed Mid September is set then spray re-sprouts. best Competitive Light scarification and seed or As soon as possible

planting or plant. after treatment Plumeless seeding depending on plant Thistle requirements. Chemical Hand or backpack sprayer Treat in spring at rosette stage or cut in late summer to force plants back to rosette stage for fall treatment. Biocontrol No agents available Biocontrol Release insects. Late May to early June.

Manual Hand pull very small infestations Any time At minimum, remove seed Purple that threaten natural areas. heads to prevent Loosestrife reproduction.

Chemical Hand or backpack sprayer Late July to early Need to spray only 25% of August. the foliage. Cut stem spraying works on large plants.

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Table 2.4.1 (continued) -- Sequence and priority of treatments by species Species Treatment Method Timing Comments Mechanical Dig or pull. Any time. Possible scorch with torch to eliminate resprouting Chemical Basal bark, cut stumps or hand Early September to Siberian spray foliage Late October Peashrub Competitive Light scarification and seed or As soon as possible planting or plant after treatment seeding depending on plant requirements. Biocontrol No agents available Biocontrol Release insects Use Urophora or Larinus spp. on the larger populations. Manual Pull or root stab. July. Treat new populations to debilitate the plants. Treat

before seeds are formed.

Need to deplete seed bank

over time. Wear gloves.

Chemical Hand or backpack sprayer Mid June to July. Rosette to bolting stage. Spotted Really need to soak plants Knapweed with Glyphosate. Competitive Light scarification and seed or As soon as possible planting or plant after treatment seeding depending on plant requirements. Manual/ Mow, pull, or root stab. Late June to July. Root stab small populations. Mechanical Treat prior to seed formation. Wear gloves - blistering sap.

Chemical Hand spray. Late June to July.

Wild Parsnip Biocontrol No agents available

Cultural Tarping/Solarization with plastic Multi-year Could work in small areas. sheeting Chemical Hand or backpack sprayer Late spring, before Meadow flowering Hawkweed, Biocontrol No agents available Orange hawkweed

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Table 2.4.1 (continued) -- Sequence and priority of treatments by species Species Treatment Method Timing Comments Manual Pull Any time Because of extensive underground root systems, not likely to work except on the smallest populations, would require reseeding Cultural Competitive tree planting Reforest areas, such as impoundments being removed. May need to control reed canary grass

with herbicides 3-5 years to

allow trees to establish. Reed Chemical Hand or Backpack Sprayer Late summer canarygrass

Cultural Tarping/Solarization with plastic 1-3 consecutive years Could work in small areas. sheeting For small isolated clumps in areas where desirable natives are not mixed with reed canarygrass. Seeding with native species required as follow up. Biocontrol No agents available Chemical Hand or Backpack Sprayer Late rosette stage. Not a priority species at this time but may be treated in conjunction with other species. Manual Hand pull or dig with hand tools Limited effectiveness due to extensive underground root Perennial networks. Sowthistle

Biocontrol No agents available

Manual Hand pull or dig with hand tools Treatment for several years required to exhaust seed bank White and Chemical Hand or Backpack Sprayer Yellow Cultural Prescribed burning A hot early complete Sweetclover first year burn followed by a hot late spring burn, repeat after two years Biocontrol No agents available

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Table 2.4.1 (continued) -- Sequence and priority of treatments by species Species Treatment Method Timing Comments Chemical Hand or Backpack Sprayer Early rosette stage or Widespread on CPF. mow late summer to Chemical control would only force plants back into be used when it threatens to rosette stage and expand into high quality spray early fall to natural areas. maximize translocation of herbicide to roots. Manual Dig with hand tools Newly established plants may be successfully controlled by hand pulling. May require follow up treatment after 1 year. Extensive root networks in Canada Thistle established populations reduce likelihood of success to zero. Manual Dig with hand tools Before seed set, Remove entire root. dispose mature plants carefully because they can set seeds after being pulled Biocontrol No agents available

Manual Dig with hand tools Before seed set, Remove entire root. dispose mature plants carefully because they can set seeds after being pulled Bull Thistle Chemical Hand or backpack sprayer Fall treatment of A combination of pulling 2nd rosette stage just year plants before seed set before killing frost and spraying 1st year plants most effective. in fall might be successful. Biocontrol No agents available Manual Dig with hand tools Before seed set, Remove entire root. dispose mature plants carefully because they can set seeds after being pulled

Chemical Hand or backpack sprayer Fall treatment of A combination of pulling 2nd Common rosette stage just year plants before seed set Tansy before killing frost and spraying 1st year plants

most effective. in fall might be successful. Mechanical Mowing Repeated mowing would reduce seed production Biocontrol No agents available

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Table 2.4.2 Herbicide Treatment Summary This table shows what kind of treatments would be allowed in different types of sites. Treatment Sites Administrative Natural Areas –Sites with Species Sites, intact native plant communities Roadside, landings Gravel Pits Recreation sites, where non-native species make Wildlife Openings up less than 5% cover. Up to 100 total Up to 100 acres total in acres in Stony Up to 100 total acres in Stony Stony Point Area Treat after Point Area Point Area. Triclopyr amine Garlic mustard Glyphosate (3%) + consultation with Triclopyr amine (3%)+ Sulfometuron methyl (1 Sulfometuron methyl (1 resource specialists (3%) + oz/ac) oz/ac). Sulfometuron methyl (1 oz/ac). Glossy and common Treat up to 100 acres with Triclopyr ester 18% with oil) Basal bark treatment. Cut stump on trees buckthorn, exceeding 6" dbh, unlimited hand-tool pulling Siberian Peashrub Up to twenty treatments with, Up to twenty treatments Aminopyralid (0.5 with Aminopyralid (0.5 oz/gal) or Imazapic oz/gal) or Imazapic w/ Aminopyralid (0.5 Treat up to 20 undeveloped w/ Methylated Methylated Seed Oil (fall oz/gal) or Imazapic sites with, Aminopyralid. 0.5 Seed Oil (fall application only) (12 w/ Methylated Seed oz/gal or Imazapic w/ Leafy Spurge application only) oz/ac). Up to 0.25 acres Oil (fall application Methylated Seed Oil (fall (12 oz/ac) e. Up to per treatment on only) (12 oz/ac) up application only) (12 oz/ac) Up 0.25 acres per developed sites that to 100 acres to 0.10 acres per treatment. treatment on provide access to developed sites uninfested areas that provide access to uninfested areas Meadow Up to twenty Hawkweed treatments with Orange Up to twenty treatments Aminopyralid + hawkweed with Aminopyralid + Metsulfuron Aminopyralid + Treat up to 20 undeveloped Perennial Metsulfuron Methyl (e.g. Methyl (e.g. Metsulfuron Methyl sites with Aminopyralid + Sowthistle Opensight 3.3 oz/ac), or Opensight 3.3 (e.g. Opensight 3.3 Metsulfuron Methyl (e.g. Sweetclovers Milestone VM (7 oz/ac). oz/ac), or oz/ac), or Milestone Opensight 3.3 oz/ac), or Spotted Up to 0.25 acres per Milestone VM (7 VM (7 oz/ac) up to Aminopyralid (7 oz/ac). Up to Knapweed, treatment on developed oz/ac). Up to 0.25 100 acres 0.10 acres per treatment. Canada Thistle sites that provide access acres per treatment Bull Thistle to uninfested areas on developed sites Plumeless that provide access Thistle to uninfested areas

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Treat up to twenty Treat up to ten acres with Aquatic acres with Aquatic Treat up to ten acres with Treat up to ten acres with formulations of formulations of Aquatic formulations of Aquatic formulations of Glyphosate (3%) or Glyphosate or Glyphosate (3 oz./acre) or Glyphosate or Aquatic Purple Aquatic Aquatic Aquatic Formulations of Formulations of Triclopyr loosestrife Formulations of Formulations of Triclopyr (6 lb/acre) or aquatic 6 lb/acre or Imazapyr (1 Triclopyr 6 lb/acre Triclopyr 6 lb/acre formulations of Imazapyr (1 pt/Ac) . Up to 0.25 acre or Imazapyr) (1 or Imazapyr (1 pt/Ac). Up to 0.25 acre per per treatment. pt/Ac). Up to 0.25 pt/Ac). Up to 0.25 treatment. acre per treatment. acre per treatment. Herbicide spot treat up to twenty acres in areas Herbicide spot treat up to where human twenty acres in areas Aminopyralid + health is a concern where human health is a Metsulfuron Methyl using concern using (e.g. Opensight 3.3 Aminopyralid + Aminopyralid + Wild parsnip oz/ac) or Metsulfuron Metsulfuron Methyl (e.g. Metsulfuron methyl Methyl (e.g. Opensight 3.3 oz/ac) or (1 oz./Ac) up to 100 Opensight 3.3 Metsulfuron methyl (1 oz. acres oz/ac) or /Ac). Up to 1/2 acre per Metsulfuron treatment. methyl (1 oz. /Ac). Up to 1/2 acre per treatment. Up to twenty spot treatments, 0.25 Up to twenty spot acres max, with treatments, 0.25 acres Up to twenty spot treatments, Imazapic (12 oz/Ac) Imazapic (12 max, with Imazapic (12 0.10 acres max, with Imazapic Reed or Imazapyr (3-4 oz/Ac) or oz/Ac) or Imazapyr (3-4 (12 oz/Ac) or Imazapyr (3-4 canarygrass pt/Ac) up to 100 Imazapyr (3-4 pt/Ac) on developed sites pt/Ac) on undeveloped sites acres pt/Ac) on that provide access to (natural habitat). developed sites uninfested areas that provide access to uninfested areas

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Metsulfuron methyl (1 oz/ac), up to 20 spot treatments up to 0.25 acre per treatment on developed sites that provide access to uninfested areas.

Metsulfuron methyl (1 Metsulfuron oz/Ac) up to 20 spot methyl (1 oz/ac) Treat up to 100 Treat up to 20 undeveloped Common tansy treatments. Up to 0.25 on clearcuts and acres with sites (natural habitat) with and St. acre per treatment on wildlife openings Metsulfuron methyl Metsulfuron methyl (1 oz. /ac) Johnswort developed sites that infested with over (1 oz/Ac) Up to 0.10 acres per treatment. provide access to 50% cover of tansy uninfested areas where regeneration of forest trees is hampered. Maximum 100 acres treated by spraying 6 foot diameter circles to allow seedlings to overtop tansy, eventually shading it out.

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Table 2.4.3 -- Proposed Herbicides Herbicide - Examples* of Application Common/Scientific Description and Targeted Use Comments trade names Method Names Glyphosate A non-selective, broad spectrum, (N- systemic herbicide used to control Roundup Pro [phosphonomethyl] many grasses, forbs, vines, shrubs, Roundup Binds to soil, not soil Foliar spray glycine) and trees. Original active or wipe Pines show limited tolerance if Foresters application is after they form resting buds in late summer. Glyphosate Aquatic formulations (N- Binds to soil, not soil A non-selective, broad spectrum, [phosphonomethyl] Rodeo active. systemic herbicide that is used to Foliar spray glycine) Accord Practically non-toxic to control emergent plants and or wipe Aquamaster fish. shoreline vegetation

Triclopyr Amine Basal Bark Garlon3A Generally non-mobile in Selective; controls many woody and Foliar Spray Brush-B-Gone soil, not soil-active. broadleaf species. Grasses are or Wipe Vine-X tolerant. Ester formulations control Frill Tahoe 3a Practically non-toxic to pines as well as hardwoods. Cut stump Renovate fish.

Triclopyr ester Basal Bark Ester is highly toxic to fish Garlon 4 Frill Woody plants Cut stump

Imazapic Weakly absorbed by soil. Plateau Selective control of annual and Mobile in soil. Plateau Eco-Pak some perennial grasses, and many Foliar Practically non-toxic to Journey broadleaf weeds and vines. fish. Aminopyralid Milestone, Opensight (with Selective control of broadleaf weeds Immobile in soil. Foliar spray Metsulfuron in grasses. or wipe methyl) Metsulfuron methyl Escort Metsulfuron Somewhat selective affecting many Mobile in soil. Foliar spray methyl DF broadleaf weeds and many annual Soil active. or wipe Opensight (with grasses. Aminopyralid) Imazapyr Foliar spray Habitat Non selective for aquatic sites or wipe

Sulfometuron Non selective affecting many Mobile in water. Soil Foliar spray Oust Methyl broadleaf weeds and grasses. Active or wipe

*Herbicide trade names are used as examples only. Actual products used will conform to common names outlined in the table and proposed action.

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The actions and methods outlined in tables 2.4.1-2.4.3 outline our strategy and approach to building an integrated pest management based program that makes best use of all available tools to manage invasive plants. The program will only be successful if it incorporates lessons learned (adaptive management) and ensures that plant communities are successfully restored.

2.4.3 Treatment Strategies

Integrated pest management (IPM) The pervasiveness, complexity and cost of weed control necessitate using an integrated management approach. IPM integrates plant ecology and technology with preventive, cultural, biological, mechanical, and chemical methods to manage nonnative invasive plants in natural areas.

IPM is an effective and broad-based environmentally sensitive approach to pest management that relies on a combination of reliable, proven practices. IPM programs use current, comprehensive information on the life cycles of pests and their interaction with the environment. This information, in combination with available pest control methods, is used to manage pest damage by the most economical means, and with the least possible hazard to people, property, and the environment (EPA 2009).

Before taking any pest control action, IPM first sets an action threshold, a point at which pest populations or environmental conditions indicate that pest control action must be taken. However, not all organisms require control. IPM programs work to monitor for pests and identify them accurately, so that appropriate control decisions can be made in conjunction with action thresholds. As a first line of pest control, IPM programs work to manage the area to prevent pests from becoming a threat. Once pest control is required, IPM programs then evaluate the proper control method both for effectiveness and risk.

Simply put, IPM consists of using all the tools at ones disposal using the least harmful tools first and understanding the survival strategies of the plant to be controlled.

Adaptive Management Adaptive management is a structured, iterative process of optimal decision making in the face of uncertainty, which aims to reduce uncertainty over time via system monitoring. In this way, decision making simultaneously maximizes one or more resource objectives and, either passively or actively, accrues information needed to improve future management.

Revegetation (restoration) Restoration of sites after treatment is an essential component of any NNIP control action. If steps are not taken to ensure that a desirable mix of species colonizes the site afterward, the site is likely to be re-occupied by NNIPs. In some cases natural vegetation may be expected to reoccupy the site naturally. All NNIP control actions should include an evaluation of restoration options for the site.

2.5 NEW SPECIES

In some cases, populations of new species currently not known to exist on the CPF may require treatment. In such cases treatment would be accomplished using the same methods outlined in tables 2.4.1. Any herbicide treatment would be within the acreage bounds established in table 2.4.2 and herbicides would be restricted to those listed in table 2.4.3. A supplemental information review will

7/5/2011 10:55 AM Page - 32 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF include consultation with The Leech Lake Band of Ojibwe Division of Resource Management (DRM) and Tribal Historic Preservation Office (THPO). Line officer approval would be required to ensure that treatments conform to the scope of this environmental assessment

2.6 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED STUDY

2.6.1 - The Original proposed action as Scoped During the scoping process and in the ensuing year additional information surfaced that caused us to change the proposed action.

This alternative was dropped from detailed study because:

Experts said that mowing and cutting leafy spurge would actually encourage it rather than control it (PR# 139ad). Experts mentioned three additional insects that would be valuable for the biological control (PR# 139ad). Additional surveys resulted in more site specific locations of NNIP that need treatment. A review of the GIS data showed some errors in the initial tables and maps.

A listing of specific changes to the scoped proposed action is available in the project file.

2.6.2 - Close Selected Roads to Minimize NNIP Spread There was a short discussion about closing roads as a means to stop or minimize the spread of NNIP.

This alternative was dropped from detailed study because:

The infestations are located along all classes of roads, so closing only low quality roads would be of minimal effect. Existing infestations on roads that would be closed would still exist and spread outward naturally; although vehicles would not drive through them and spread the seeds farther and faster.

2.7 PROJECT DESIGN FEATURES AND MITIGATION MEASURES

Anything incorporated into the actual design of the treatment is not considered a mitigating measure. These items are part of the prescriptions and called "design features." They include guidance from the various management plans, ideas from the ID Team, and best management practices (BMPs), which are "normal" design factors that are known from past practices to reduce the negative impacts of a treatment on a particular resource. They are to be followed at all times during implementation of this project.

2.7.1 Tribal Consultation LLBO DRM and LICs will be notified at prior to scheduled application with a map of the site, chemical formulation to be applied, species to be treated and site soil and water characteristics. Consultation, including site visits prior to treatment will be done with Leech Lake Band of Ojibwe Division of Resource Management and the Local Indian Council(s) for the treated area as requested by LLBO.

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2.7.2 General a) All control treatments will be designed to be effective based on the species biology and life history, yet minimize impacts on human health, non-target plants, wildlife, water, recreation, and other resources. b) When herbicide treatment is indicated, spot treatments, such as a sponge, glove, or wick applicator, would be used whenever possible over broadcast spraying. c) All those working with herbicides must be certified and would review corresponding Material Safety Data Sheets. d) Appropriate protective gear would be worn by herbicide applicators per label direction. e) Herbicide label directions would be carefully followed. This could include temporary closure of treatment areas for public health and safety. f) Areas to receive ground disturbance would be preapproved by CPF archaeology staff to ensure protection of cultural resources. If any cultural resource sites are located, then appropriate protection measures would be implemented. g) Weed torches would only be used during times of low fire danger, on sites with low potential to carry a fire, with Forest wildland firefighters on site.

2.7.3 Storage and Disposal a) Herbicides would be labeled and stored appropriately in accordance with label specifications, state and federal laws, and Forest Service regulations b) Herbicides stored on-site would have Material Safety Data Sheets per Forest Service guidelines. c) Herbicide containers would be disposed of following label and State of Minnesota guidelines.

2.7.4 Drift Avoidance a) Weather forecasts would be obtained prior to herbicide treatment, and treatment activities would be halted, if needed, to prevent runoff during heavy rain events. b) Do not apply herbicide when temperatures exceed 85 degrees (F) (decreases volatilization). c) Herbicide application would only occur when wind speeds are less than 10 mph, (or less according to label direction), to minimize herbicide drift. d) Use a marker dye in the herbicide to mark the treated area.

2.7.5 Neighbors a) Work with owners and managers of neighboring lands to respond to invasive plants that straddle multiple ownerships. b) Adjacent landowners and residents (within 500 feet of treated sites) would be notified when herbicides would be used. c) Notices/signs would be posted near all areas that are to be treated with herbicides, during and for three weeks after treatment (or longer per labeling guidance). The signs would tell what herbicides were applied, when they were applied, and any warnings about use of affected plants that may be appropriate, e.g. if berry plants are in the area and have on them at the time. d) High use areas, including administrative sites, developed campgrounds, visitor centers, and trailheads would be posted in advance of herbicide application or closed. Areas of potential conflict would be prominently marked on the ground or otherwise posted. Postings would

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indicate the date of treatments, the herbicide used, and when the areas are expected to be clear of herbicide residue. The public would be notified about upcoming herbicide treatments via the local newspaper or individual notification, fliers, and/or posting signs. Forest Service and other websites may also be used for public notification.

2.7.6 Soil and Vegetation a) Equipment, boots, and clothing would be cleaned thoroughly before moving to another treatment site to ensure that NNIP seeds and parts capable of starting new plants are not spread. b) All treatments would be designed to minimize undesired impacts on native vegetation. Retain native vegetation and limit soil disturbance as much as possible. c) Vehicles (including all terrain vehicles) used to access or implement invasive plant projects would remain on roadways, trails, parking areas or other previously disturbed areas to prevent damage to riparian vegetation and soil, and potential degradation of water quality and aquatic habitat. d) Use only approved seed mixtures and weed free mulch. e) Following NNIP treatments, revegetate exposed soils promptly to avoid re-colonization by NNIP. For manual treatments that disturb the soil, tamp the soil down. Use only approved seed mixtures and weed seed-free mulch.

2.7.7 Wildlife and Threatened, Endangered and Sensitive Species a) All treatments would be designed to ensure that they do not negatively impact Threatened, Endangered, or Sensitive (TES) Species. b) Prior to treatment of any new infestations not known at the time of this EA, information about new infestations would be reviewed by appropriate resource specialists to determine whether surveys for sensitive species are needed. c) Areas to receive herbicide treatment would be evaluated to ensure protection of TES species. If any TES species are located, then appropriate protective measures would be implemented. d) If any TES species are observed during implementation of NNIP control activities, work would stop until the district wildlife biologist or forest botanist is consulted. Treatments would be revised as necessary to avoid impacts to TES species. e) Prior to treatment, botanical surveys would occur as necessary to identify Threatened, Endangered or Sensitive plants. This is only if unsurveyed suitable habitat is within 25 feet of planned treatments. f) When work is conducted in areas containing sensitive plants, those plants would be flagged or marked, and treatment would avoid them. In these areas, the least disruptive treatment method such as hand pulling or wick application of herbicide would be used to avoid impacts to RFSS plants. g) No mechanical treatments would be conducted within 660 feet of known occupied bald eagle nests from February 15 to September 30. h) No treatments would be conducted within 660 feet of active black tern or trumpeter swan nests during the breeding season (April 1 to August 1). i) No mechanical treatment would be conducted within 860 feet of known occupied northern goshawk or red-shouldered hawk nests from: March 1 to August 31 for northern goshawks and April 1 to August 31 for red-shouldered hawks.

2.7.8 Water

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a) Fueling of gas-powered equipment with gas tanks larger than 5 gallons would not occur within 150 feet of surface waters. Fueling of gas-powered equipment with gas tanks smaller than 5 gallons would not occur within 25 feet of any surface waters. b) Mixing and loading of herbicides would occur outside of wetlands, areas with poorly drained soil, filter strips, and riparian management zones. c) Herbicide use within 1000 feet of known water intakes would be coordinated with the water user or manager. d) All wells and springs used for domestic water supplies would be protected with a 100 foot buffer for wells and a 200 foot buffer for springs. Label guidance relative to water contamination would be followed. e) Rinse water for cleaning or rinsing actions in conjunction with herbicide treatment would be disposed of according to Environmental Protection Agency regulations. f) Only formulations registered for aquatic use would be used within 100 feet of perennial and wet intermittent streams, dry streams, vernal pools, lakes, and wetlands. g) Prior to herbicide treatment in gravel pits perform soil auger test at a central location to a minimum depth of 5 feet to ensure that shallow groundwater is not contaminated or use a formulation approved for use on aquatic habitats.

2.7.9 Herbicide Transportation and Handling Safety/Spill Prevention and Containment An Herbicide Transportation and Handling Safety/Spill Response Plan would be the responsibility of the herbicide applicator. At a minimum the plan would: a) Address spill prevention and containment. b) Estimate and limit the daily quantity of herbicides to be transported to treatment sites. c) Require that impervious material be placed beneath mixing areas in such a manner as to contain small spills associated with mixing/refilling. d) Require a spill cleanup kit be readily available for herbicide transportation, storage and application (minimum FOSS Spill Tote Universal or equivalent). e) Outline reporting procedures, including reporting spills to the appropriate regulatory agency. f) Ensure applicators are trained in safe handling and transportation procedures and spill cleanup. g) Require that equipment used in herbicide storage, transportation and handling are maintained in a leak proof condition. h) Address transportation routes so that traffic, domestic water sources, and blind curves are avoided to the extent possible. i) Specify conditions under which guide vehicles would be required. j) Specify mixing and loading locations away from water bodies so that accidental spills do not contaminate surface waters. k) Require that spray tanks be mixed or washed more than 150 feet from surface water. l) Ensure safe disposal of herbicide containers. m) Require chemicals being transported by boat to be packed in a floating waterproof overpack container.

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2.8 COMPARISON OF ALTERNATIVES

This section provides a summary of the effects of implementing each alternative. Information in the table is focused on activities and effects where different levels of effects or outputs can be distinguished quantitatively or qualitatively among alternatives. Table 2.8.1 Comparison of Alternatives Alternative C Site Specific Alternative B Use of Alternative A Programmatic Alternative C Resource Indicator Herbicides No-Action use of No herbicides on Leech Herbicides Lake reservation

Human Health Hazard quotients for No Effect No Effect No Effect No Effect and Safety human exposure. Loss of traditionally Traditional gathered resources No Effect No Effect No Effect No Effect Practices

Potential beneficial Potential effects from Potential harm to Possible Effects beneficial effects Potential Traditional control of spiritual sites from increased from control of beneficial Practices NNIP, NNIP NNIP, negative effects negative effects mitigated effects mitigated Sedimentation, May Adversely Water Quality Maximum No Effect No Effect No Effect Affect Contaminant Load Aquatic May Adversely Water Quality Organisms: Hazard No Effect No Effect No Effect Affect Quotients Herbicide degradation as Water Quality No Effect No Effect No Effect No Effect measured in half- life

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Alternative C Site Specific Alternative B Use of Alternative A Programmatic Alternative C Resource Indicator Herbicides No-Action use of No herbicides on Leech Herbicides Lake reservation

Potential effects on T&E and RFSS Very slight Very slight species, management Very slight potential for potential for indicator species, Potential potential for direct direct effects. management negative effects direct effects. effects. Wildlife Potential indicator habitats, due to spread of Potential Potential beneficial neotropical NNIP. beneficial effects beneficial effects to migratory birds, and to habitat. effects to habitat. selected game habitat. species.

Historic properties Historic damaged due to No Effect No Effect No Effect No Effect Properties treatment methods.

Trend of native plant communities to Beneficial May Adversely Beneficial Vegetation increase or decrease Beneficial Effect Effect less than Affect Effect in size and number. Alt B

Offsite movement through soil No Soils No Effect No Effect No Effect percolation Effect

Herbicide half life No Soils No Effect No Effect No Effect Effect

Infiltration to No Soils groundwater No Effect No Effect No Effect Effect

Failure to Potential shifts in Long term control NNIP Long term Long term recreation enhancement Recreation and could adversely enhancement of enhancement experiences or of Aesthetics affect recreational of recreational opportunities recreational recreational experience. experience experience. experience.

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Alternative C Site Specific Alternative B Use of Alternative A Programmatic Alternative C Resource Indicator Herbicides No-Action use of No herbicides on Leech Herbicides Lake reservation

Changes to scenic Failure to Short term qualities control NNIP Short term Short term Recreation and adverse could adversely adverse effects adverse effects Aesthetics effects on affect scenic on aesthetics on aesthetics. aesthetics qualities. Environmental Adverse Effects to No Effect No Effect No Effect No Effect Justice Low-Income Persons Qualitative change to Economics local social or No Effect No Effect No Effect No Effect economic conditions

2.9 MONITORING

25-50% of treatments would be monitored for effectiveness and safety for at least one year following treatment. Estimates of percent cover of treated invasive plant populations using quadrat counts or visual estimates of percent cover would be conducted as a measure of effectiveness. Herbicide drift to untreated plants should also be noted as a measure of off-target effects.

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CHAPTER 3: ENVIRONMENTAL CONSEQUENCES

3.1 INTRODUCTION

Chapter 3: Environmental Consequences contains assessments of the affected environment and analysis of the alternatives described in Chapter 2.

This chapter summarizes the appropriate/relevant health, physical, biological, and social environment effects on the affected project area and the potential changes to those environments due to implementation of the alternatives. It describes probable consequences and direct, indirect, and cumulative effects of each alternative on selected environmental resources. This chapter is organized by resource.

The Alternatives B, C and D are consistent with Forest Service policy, Forest Plan objectives, desired conditions, and management direction, as well as other Federal, State, and local laws and regulations.

The analysis in this chapter is on the revised proposed action, referred to as simply “the proposed action” for the remainder of this document.

3.2 HUMAN HEALTH AND SAFETY

3.2.1 Issue Herbicides can have negative effects on human health and safety. There is concern that herbicides cause adverse effects to human health through accidental exposure and consumption of contaminated food or water. No human health concerns were identified for other NNIP control methods including biocontrol, cultural, manual or mechanical treatments.

Indicator: Hazard quotients for human exposure.

3.2.2 Scope of the Analysis The boundaries used for the direct, indirect, and cumulative effects were the proclamation boundaries of the CPF, including National Forest System lands and lands in other ownerships, and the time it takes for the proposed chemicals to degrade (see section 3.5 for a discussion of chemical half-lives). This boundary has been used because of the minimal disturbance expected from manual/mechanical treatments, treatment protocol and design criteria which limit mobility of the herbicides proposed to be used, and the rapid decomposition of the herbicides

3.2.3 Regulation of Pesticides The US Environmental Protection Agency evaluates pesticides (including herbicides) to ensure they will not have unreasonable adverse effects on humans, the environment and non-target species. Pesticide registration is the process through which EPA examines the ingredients of a pesticide; the site or crop on which it is to be used; the amount, frequency, and timing of its use; and storage and disposal instructions. The EPA evaluates the pesticide to ensure that it will not have unreasonable adverse effects on humans, the environment, and nontarget species. A pesticide cannot be legally used if it has not been registered with EPA's Office of Pesticide Programs.

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The Minnesota Department of Agriculture regulates the use of pesticides. Comprehensive rules are in place to ensure that pesticides are stored, transported, applied and disposed of in a safe manner.

3.2.4 Extra Steps for Safety Simply using EPA registered materials and following state regulation should ensure the safety of the public and the environment. However, in order to address the concerns of the public to the furthest extent possible, several additional steps were taken in the preparation of our NNIP management plan.

First, large-scale broadcast application was eliminated from the NNIP plan. Second, we would only use non-restricted use herbicides. Restricted use herbicides are those that can only be applied under direct supervision of trained applicators because of some concern about product toxicity or misuse of the product. All applications of herbicide would be conducted by licensed applicators.

Third, we conducted an in-depth analysis of proposed herbicide use using materials provided through a USDA Forest Service contract with Syracuse Environmental Research Associates (SERA) to assess human health and ecological effects. These materials were prepared according to National Research Council recommendations. Results were presented in the form of risk assessment documents for each herbicide and program worksheets which allowed the calculations to be customized using our application parameters.

Finally, we developed a list of project design features or mitigations (Section 2.7) designed to minimize the risk of accidental exposures.

3.2.5 Analysis methods Both the human health and ecological risk assessments were prepared using data from experimental studies. Additional sources of information like epidemiology studies, case reports, and clinical investigations were used to prepare human health risk assessment. The hazard identification was based on a review of the toxicological and pharmacokinetics data.

A description of the risk assessment process can be found in the document Preparation of Environmental Documentation and Risk Assessments for the USDA/Forest Service (SERA 2007 PR# 279). Risk assessment documents and program worksheets can be found in the project record and CD which will be made available with the EA.

Chippewa National Forest staff conducted a thorough review of SERA/USFS risk assessments (SERA 1997, 2002, 2003, 2003a, 2004, 2004a, 2004b, 2004c, 2004d, 2007) and program worksheets (PR# 263, 264, 265, 266, 267, 268, 269, 270) for each chemical proposed for use in this EA. This review included adjusting program worksheets allowing the risk assessments to be customized to the proposed action by tailoring results to local soil, rainfall, temperature data as well as proposed application rate for each pesticide.

In some cases, a risk assessment may find no objective suggestion of an adverse effect based on the currently available data. Even in such cases, the risk characterization must clearly make the point that absolute safety cannot be proven and the absence of risk can never be demonstrated. No chemical is studied for all possible effects and the use of data from laboratory animals to estimate hazard or the

7/5/2011 10:55 AM Page - 41 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF lack of hazard to humans or other species is an uncertain process. Thus, prudence dictates that normal and reasonable care should be taken in handling any chemical.

Risk assessment models were developed by examining a number of chemical exposure scenarios for the general public based on experimental data. For each pesticide, at least three general exposure scenarios were considered, including walking through a contaminated area shortly after treatment, the consumption of water from a contaminated watershed, and the consumption of contaminated vegetation.

Exposure scenarios are extremely conservative. Estimates of longer-term consumption of contaminated water are based on estimated application rates (lbs a.i./acre) and monitoring studies that can be used to relate herbicide concentration in water to treatment rates in an entire watershed; however, in proposed action, substantial portions of a watershed would not be treated. Also, the exposure scenarios based on longer-term consumption of contaminated vegetation assume that an area of edible plants is inadvertently sprayed and that these plants are consumed by an individual over a 90-day period. While such inadvertent contamination might occur, it is extremely unlikely to happen as a result of directed applications (e.g., backpack applications). In addition, it is likely that the contaminated plants would show obvious signs of damage over a relatively short period of time and would therefore not be consumed. Nonetheless, these general exposure assessments are included because the risk assessment is intended to be extremely conservative with respect to potential effects on the general public, and to provide estimates regarding the likelihood and nature of effects after human exposure to pesticides.

The risk assessments depend on hazard quotient calculations generated by each scenario. A hazard quotient is the ratio of a projected level of exposure (Ei) divided by some index of an acceptable exposure or reference dose (RfD). The RfD, in turn, is an experimental no observed adverse effect level (i.e., NOEL or NOAEL) divided by an uncertainty factor (UF):

HQ = Ei / (NOAEL/UF) (Eq. 3-20)

The uncertainty factor is at least 10 when defining the hazard quotient from the no adverse effect level (NOAEL). This is a “margin of safety” that says we will only accept an exposure one tenth as much as what experimental evidence on laboratory animals implies is safe. In some cases, such as exposure of a child, the uncertainty factor is increased to at least100.

To sum up, an estimation of human exposure likely to follow herbicide application was compared to an acceptable level of exposure based on 1/10 to 1/100 of levels where adverse effects were observed in animal studies.

3.2.6 Direct and Indirect Effects Risk assessment model outputs (program spreadsheets) identified a few scenarios where hazard quotients exceeded acceptable levels. Most of these scenarios involved accidental exposures resulting from improper handling of chemicals. In the case of direct spray to the body, exposure exceeded acceptable hazard quotients for triclopyr and triclopyr amine but not for any other herbicides proposed for use. In the case of consumption of water from a pond exposed to an accidental spill, acceptable hazard quotients were exceeded for triclopyr, triclopyr amine, glyphosate and imazapic but not for metsulfuron methyl, sulfometuron methyl, or aminopyralid.

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In our modeling exercise, a couple of “non-accidental” exposure scenarios exceeded safe limits. Non accidental means exposures that could result from normal application of herbicides, even though these contacts would be unintentional and steps would be taken to prevent them from occurring. Contact with vegetation treated with triclopyr by an adult female exceeded safe limits. Consumption of fruit or vegetation treated with triclopyr, or glyphosate in some cases exceeded safe limits.

Safe limits were not exceeded for any other non-accidental exposure to herbicides proposed for use. These scenarios included fish consumption in treated areas, swimming in treated areas, or consumption of water in treated areas.

It bears noting that one of the most extreme scenarios, direct spray to the entire body of a child for one hour, did not result in exceeding the acceptable hazard quotient for most of the chemicals proposed for use. This is largely because herbicides act on biochemical processes unique to plants, so they are much more toxic to plants than to humans and other animals.

The Minnesota Department of Agriculture has developed best management practices to reduce water contamination from such activities as storing, transporting, mixing and loading of pesticides as well as managing drift, disposing of waste chemicals, and developing incident response plans. These are incorporated into project design features listed in Section 2.7 which are meant to reduce the risk of exposure to herbicides, and are expected to eliminate the possibility of inadvertent exposures listed in table 3.2.1

When taking into consideration the extremely conservative nature of the risk assessment models and exposure scenarios in addition to project design features and mitigation measures including signage of treated areas to prevent unintended human exposure to treated vegetation, no direct or indirect effects to human health are expected to occur.

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Table 3.2.1 Scenarios exceeding human toxicity hazard quotients from herbicide applications.

Herbicide exceeding acceptable Scenario Receptor hazard quotient

Accidental Acute Exposures

Direct Spray of Child, whole Child Triclopyr, Triclopyr amine, body

Direct Spray of Woman, feet Adult Female Triclopyr, Triclopyr amine, and lower legs

Triclopyr, Triclopyr amine, Water consumption (spill) Child Glyphosate, Imazapic

Fish consumption (spill) Adult Male None Subsistence Fish consumption (spill) None Populations Non-Accidental Acute Exposures Vegetation Contact, shorts Adult Female Triclopyr, Triclopyr amine and T-shirt

Contaminated Fruit Adult Female Triclopyr amine Triclopyr, Triclopyr amine, Contaminated Vegetation Adult Female Glyphosate Swimming, one hour Adult Female None

Water consumption Child None

Fish consumption Adult Male None Subsistence Fish consumption None Populations Chronic/Longer Term Exposures Contaminated Fruit Adult Female Triclopyr, Triclopyr amine,

Contaminated Vegetation Adult Female Triclopyr, Triclopyr amine,

Water consumption Adult Male None

Fish consumption Adult Male None Subsistence Fish consumption None Populations

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3.2.7 Comparison of Alternatives The discussion above only pertains to Alternative B and C. No adverse effects to human health are expected from the no-action alternative A no-herbicide alternative D.

3.2.8 Cumulative Effects Cumulative effects are those that result not from the effects of a particular action, but from the combination of multiple actions that overlap in location and duration of effects.

A summary of past present and future NNIP management can be found in Appendix E.

Past Effects The effects of past mechanical, manual, chemical, or biological methods of NNIP are no longer evident and so, there would be no additive effect with regards to the proposed action. Herbicide usage on CPF lands was eliminated long ago except for in campgrounds and administrative sites to control poison ivy. Even in those areas, treatment areas are small and not likely to overlap spatially with the proposed management activities.

Current Effects The area within the proclamation boundary of the Chippewa National Forest is a patchwork of federal, state, municipal, tribal and private ownerships. Land uses include small urbanized areas, farms, utility corridors such as power lines and pipelines, and homes. Private landowners are not restricted from using approved herbicides on their property. Crop production in Minnesota accounts for the majority of herbicide use in the state. The state, counties, and municipalities generally avoid herbicide use within the CPF proclaimed boundary, especially within the Leech Lake Reservation.

Future Effects Based on past actions, it is expected that other agencies and adjacent land owners would maintain the current level of treatments. Future plans by parties other than the Chippewa National Forest within the CPF proclaimed boundary for herbicide treatment of invasive plants are not known at this time.

Treatments in this EA will be implemented over the next ten years and are expected to require follow- up treatments. In all cases the expectation is that intensity and scope of follow-up treatment would decrease over time until the NNIP population was eliminated or contained.

Summary of Cumulative Effects When taking into consideration the extremely conservative nature of the risk assessment models and exposure scenarios in addition to project design features and mitigation measures including signage of treated areas to prevent unintended human exposure to treated vegetation, no direct or indirect effects to human health are expected to occur.

Because of the lack of reasonably foreseeable direct or indirect effects posed by the proposed action, cumulative effects on human health are not anticipated.

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3.3 TRADITIONAL PRACTICES

This section will address potential effects to traditional resource collection and traditional spiritual use of lands in the CPF. Traditional resources sites that may be subject to collection and use may or may not be tangible, have discrete boundaries, or have time depth greater than 50 years.

The principal consideration is the effects to traditionally collected resources themselves, human health and safety, and access and use of areas for wide range traditional purposes including hunting, gathering, and spiritual, sacred or ceremonial activities. Some of these activities may occur regularly in specific areas and could not only include resource collection, but many other activities such as vision quest or other spiritual practices. Other activities could occur on an irregular basis in a more dispersed fashion.

For the purposes of this analysis, traditionally gathered resources include any plant, fungus, animal, animal part, mineral, or other tangible component of the forest ecosystem that is collected for spiritual use, medicinal use, clothing, dyes, traditional crafts or food. This analysis is primarily concerned with effects to plants as other types of materials are not expected to be affected or are treated elsewhere in the document. The analysis does not include water (see Hydrology and Water Quality Section), game animals (See Wildlife Section), or commercial products for use outside the community such as balsam boughs for holiday decorations (See Vegetation Section).

3.3.1 Issue Herbicides can have negative effects on Native American traditional activities:

Indicators: Loss of traditionally gathered resources Potential harm to spiritual sites

3.3.2 Scope of the Analysis Spatial framework: Effects are discussed for areas that would be affected, either directly or indirectly by NNIP control activities or the failure to control NNIP. This area has been estimated as within 100 feet of gathering and traditional uses.

Timeframe: The last 13 years where we know of NNIP treatments and the next 10 years during which the treatments are planned.

3.3.3. Management Direction and Forest Plan Consistency The Forest Plan (PR# 72a) contains several items that deal with gathering and traditional uses. Following are excerpts from the Forest Plan and Forest Plan Environmental Impact Statement

Final Environmental Impact Statement for the Forest Plan Beginning in the mid-19th century, the government of the United States made treaties with the Ojibwe that created reservations and ceded areas of land in northern Minnesota to the federal government. The treaties also preserved the right of the Ojibwe bands to hunt, fish, and gather within the treaty area. This guarantee is important in the context of

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natural resource management. The Chippewa National Forest has a role in maintaining these rights because they are offices of the federal government responsible for natural resource management on lands subject to these treaties.

Band members in the treaty areas use and rely upon a wide array of plant and animal resources… There is widespread use of forest products tied to the gathering for personal, traditional and treaty purposes and includes fishing, hunting, trapping, harvesting wild rice, tree boughs, saps, roots, bark, berries, medicines, and firewood… The National Forest has a role in maintaining ecosystem health on lands under its jurisdiction so as to have the overall effect of allowing for continued resource use as reserved by treaty. (FEIS Excerpts pp. 3.1-12 to 3.1-14)

FEIS Record of Decision Tribal Interests and Treaty Rights The Leech Lake Band of Ojibwe Reservation Boundary almost entirely overlaps the boundary of the Chippewa National Forest. I’ve considered not only Treaty Rights and our Government-to-Government relationship, but comments of tribal members who use and enjoy the Forest. My decision supports Tribal Treaty Rights, and provides for other activities and uses deemed important by those tribal members using the forest for a wide variety of reasons. The plan would sustain those values held important by tribal members. (ROD Page 8) (and also ROD Pages 17, 19, 22, 33, and 34)

Forest Plan The Forest Plan (PR# 72) contains several items that deal indirectly or directly with gathering and traditional uses:

Tribal Rights and Interests (TR) (FP pp. 2-35, 2-36):

D-TR-1 Lands within the Forest serve to help sustain American Indians’ way of life, cultural integrity, social cohesion, and economic well-being.

S-TR-3 Forest management activities will be conducted in a manner to minimize impacts to the ability of Tribal members to hunt, fish, and gather plants and animals on Forest Service administered lands.

S-TR-5 Affected Tribes would be consulted regarding opportunities for restoration, enhancement, and maintenance of native plant communities and wildlife species, including threatened, endangered, sensitive, or rare species that are of interest to tribes. Where tribal interest is indicated, cooperative programs for restoration and/or maintenance of these communities/species would be established.

S-TR-6 Environmental documents disclose potential effects on cultural resources, traditional use areas and areas of special interest that include tribal cultural values, properties, and uses, and species of special concern.

G-TR-3 Plant and animal species of traditional use should be given consideration in any management project when desired and sought after by tribal members.

3.3.4 Existing Condition Members of the Leech Lake Band of Ojibwe and others attach great significance to the collection and use of traditional resources. The importance of this activity is documented by the practitioners themselves as well as in local studies of this aspect of Ojibwe culture (e.g. McAvoy and Shirilla 2003).

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3.3.4.1 - Spiritual Sites These areas are normally not known by the general public and not discussed openly. Spiritual sites may be present in more secluded areas or in obvious large openings.

Effects could include destruction or invasion of spiritually sensitive areas by NNIP or conversely; any adverse effects to spiritually sensitive areas caused by NNIP control activities.

3.3.4.2 Traditionally Gathered Resources The Chippewa National Forest and the Leech Lake Tribal Historic Preservation Office maintain a geographic database showing many areas where Band members collect traditional resources. It is based upon interviews with many individuals involved in this activity but is, by no means exhaustive. The existing database, however, does indicate very extensive collection of a wide range of traditional resources within much of the Forest. Records within this database are confidential and protected from release under FOIA by Section 8106 of the Farm Bill.

For purposes of this analysis, we will treat traditional gathering activities as ubiquitous across the forest because details of traditional gathering are confidential.

3.3.5 Direct and Indirect Effects Since most of the specific NNIP sites to be treated have not yet been defined, mitigation of adverse effects will have to be accomplished on a case-by-case basis through communication with the local community.

Because mitigation measures including coordinating with the public prior to treatment should lead to avoidance of negative impacts to spiritually sensitive sites, there are no direct or indirect effects to them.

3.3.4.2 - Traditionally Gathered Resources Alternative A No direct or indirect adverse effects on traditionally gathered resources would occur from Alternative A.

Alternatives B, C and D In the case of all control methods, controlling the NNIP would allow native plants, and possibly the traditionally gathered resources, to re-inhabit the sites that are covered with NNIP now. It would also prevent or minimize the spread of the NNIP into larger patches or new, nearby areas. Having fewer NNIP is a neutral or beneficial effect on the traditional resources. The methods of controlling the NNIP could result in negative effects but these effects are thought to be minor compared to the potential benefits from controlling NNIP that threaten traditionally gathered resources.

Manual treatments (e.g. pulling, hand cutting, root stabbing) are unlikely to kill or injure substantial numbers of traditionally gathered plants. These methods would not be used on many of the NNIP we are treating since they are effective on only a few species and only when patches are very small. Competitive seeding and planting following these treatments should fill in the disturbed spaces with native plants or a short-term cover crop that will affect traditional resources less than the NNIP and

7/5/2011 10:55 AM Page - 48 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF will be more likely to support traditionally gathered plants in the long run. This portion of Alternatives B and C will have little or no effect on the traditionally gathered resources.

Mechanical treatments (e.g. mowing, scorching) would likely kill or injure any traditionally gathered plants that are within the treated patch. The area treated and disturbed by such treatments would be a small percentage of such sites on the Forest as a whole. Most of the sites being proposed for such treatments are along roads or trails or in gravel pits, utility corridors, or wildlife openings that are commonly mowed or disturbed periodically so this is not a new or highly unusual occurrence. Competitive seeding and planting following these treatments should fill in the disturbed spaces with native plants or a short-term cover crop that will affect traditional resources less than the NNIP and will be more likely to support traditionally gathered plants in the long run. Therefore, this portion of Alternatives B and C will have little or no effect on the resource.

Herbicide treatments (e.g. cut stump, foliar spray) could possibly kill or injure traditional plants that are within inches of a treated NNIP in the treated patch, depending on the selectivity of the herbicide. The majority of traditionally gathered plants are broadleaved as are the majority of NNIP, so it is likely that the proposed herbicides would kill both of them if they are touched by the herbicide. The area treated and disturbed by such treatments would be a small percentage of a given site and an extremely small percentage of such sites on the Forest as a whole. Based on the analysis in the human health section, this is not likely to affect the safety of the plants or animals for human consumption, unless an animal or human was to eat large quantities of plants or animals directly from the treated patches.

With herbicides there is also the possibility of indirect effects from the drift of herbicides during foliar spraying and from volatilization of the chemicals in dry, hot conditions. This is a minor concern due to the design criteria of not spraying when the wind is over 10 miles per hour or the temperature over 85 degrees. Chemicals that spread indirectly would be deposited at low concentrations and not likely to have effects on traditional resources. Competitive seeding and planting following these treatments should fill in the disturbed spaces with native plants or a short-term cover crop that will affect traditional resources less than the NNIP and will be more likely to support traditionally gathered plants in the long run. This would affect resources directly in the treated patches, with a minor risk of indirect effects. This portion of Alternatives B and C would lead to little or no effect on the traditionally gathered resources.

Bio-control treatments are highly selective and kill or injure only the target plants. It is unlikely that any traditional resources (plant or animals) would be affected by the bio-control agents. Based on the characteristics of the bio-control agents, this would not affect the safety of the plants or animals for human consumption. Competitive seeding and planting following these treatments should fill in the disturbed spaces with native plants or a short-term cover crop that will affect traditional resources less than the NNIP and will be more likely to support traditionally gathered plants in the long run. This would affect resources directly in the treated patches, with a minor risk of indirect effects. This portion of Alternatives B and C would have little or no effect on the traditionally gathered resources.

Alternative D In the case of all control methods, controlling the NNIP would allow native plants, and possibly the traditionally gathered resources, to re-inhabit the sites that are covered with NNIP now. It would also prevent or minimize the spread of the NNIP into larger patches or new, nearby areas. Having fewer NNIP is a neutral or beneficial effect on the traditional resources. The methods of controlling the NNIP

7/5/2011 10:55 AM Page - 49 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF could result in negative effects but these effects are thought to be minor compared to the potential benefits from controlling NNIP that threaten traditionally gathered resources.

Manual treatments (e.g. pulling, hand cutting, root stabbing) are unlikely to kill or injure substantial numbers of traditionally gathered plants. These methods would not be used on many of the NNIP we are treating since they are effective on only a few species and only when patches are very small. Competitive seeding and planting following these treatments should fill in the disturbed spaces with native plants or a short-term cover crop that will affect traditional resources less than the NNIP and will be more likely to support traditionally gathered plants in the long run. This portion of Alternative D will have little or no effect on the traditionally gathered resources.

Mechanical treatments (e.g. mowing) would likely kill or injure any traditionally gathered plants that are within the treated patch. The area treated and disturbed by such treatments would be a small percentage of such sites on the Forest as a whole. Most of the sites being proposed for such treatments are along roads or trails or in gravel pits, utility corridors, or wildlife openings that are commonly mowed or disturbed periodically so this is not a new or highly unusual occurrence. Competitive seeding and planting following these treatments should fill in the disturbed spaces with native plants or a short-term cover crop that will affect traditional resources less than the NNIP and will be more likely to support traditionally gathered plants in the long run. Therefore, this portion of Alternative D will have little or no effect on the resource.

Bio-control treatments are highly selective and kill or injure only the target plants. It is unlikely that any traditional resources (plant or animals) would be affected by the bio-control agents. Based on the characteristics of the bio-control agents, this would not affect the safety of the plants or animals for human consumption. Competitive seeding and planting following these treatments should fill in the disturbed spaces with native plants or a short-term cover crop that will affect traditional resources less than the NNIP and will be more likely to support traditionally gathered plants in the long run. This would affect resources directly in the treated patches, with a minor risk of indirect effects. This portion of Alternative D would have little or no effect on the traditionally gathered resources.

3.3.4.3 Spiritual Sites Alternative A No direct or indirect adverse effects on traditionally gathered resources would occur from Alternative A.

Alternatives B and C Spiritual sites could be adversely affected by implementation of Alternatives B and C. Activities by non-practitioners of Native American traditional practices could inadvertently cause harm to spiritual sites due to lack of understanding of unique characteristics of the site leading to performing actions inconsistent with the value of the site. Since NNIP managers on the CPF are unlikely to have in-depth knowledge of the location, uses and defining characteristics of these sites, effects of treatment would be mitigated through case-by-case consultation with local elders mediated by Local Indian Community groups and the Leech Lake Tribal Historical Preservation Office. (See mitigation section 2.7.1) The first choice would be to develop a plan that uses input from local practitioners to avoid negative impacts from management action.

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Alternative D. Based on consultation with LLBO THPO no adverse effects to spiritual sites are expected from Alternative D.

3.3.6 Cumulative Effects A summary of past present and future NNIP management can be found in Appendix E.

Past and Current Effects The adverse effects of past and current mechanical, manual, chemical, or biological methods of NNIP are not evident. No concerns have been raised regarding current NNIP management activities or those occurring in the last thirteen years.

Future Effects Based on past actions, it is expected that other agencies and adjacent land owners would maintain the current level of treatments. Levels may increase but future plans for increased management by parties other than the Chippewa National Forest within the CPF proclaimed boundary for herbicide treatment of invasive plants are not known at this time.

Mitigation measure and project design features are expected to prevent any direct and indirect effects from Alternatives A, B, C or D.

Summary of Cumulative Effects Under Alternative A, NNIPs would be allowed to grow in the existing patches and expand from there. The increase in NNIP extent and density would likely crowd out or weaken most of the native plants that exist there now, including traditionally gathered plants. Therefore Alternative A would have some adverse effects on traditional practices

Because of the lack of direct or indirect effects posed by Alternatives B and C, cumulative effects on traditional practices are not anticipated.

Because of the lack of direct or indirect effects posed by Alternative D, cumulative effects on traditional practices are not anticipated.

7/5/2011 10:55 AM Page - 51 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF Table 3.3.1 -- Summary of Effects Related to Traditional Use Indicator Alternative A Alternative B Alternative C Alternative D

Native plants become more Native plants become more Native plants become more common in NNIP patches as common in NNIP patches as common in NNIP patches as control efforts eliminate control efforts eliminate NNIP. control efforts eliminate NNIP. Occasional mortality of NNIP. Occasional mortality of No effects unless desirable plants from manual, Occasional mortality of desirable plants from manual, NNIP adversely mechanical, or chemical desirable plants from manual mechanical, or chemical affect sites’ spiritual treatments in the treated or mechanical, treatments in Loss of traditionally treatments in the treated qualities. patches. the treated patches. gathered resources. patches.

No effects from No effects from bio-control. No effects from bio-control. No effects from bio-control. treatments.

Positive effects from Positive effects from Positive effects from revegetation if desirable plants revegetation if desirable revegetation if desirable plants are part of the seed mixture. plants are part of the seed are part of the seed mixture. mixture.

Possible negative effects due Possible negative effects due to Possible negative effects due No effects unless to herbicide use, soil herbicide use, soil disturbance to soil disturbance from NNIP adversely disturbance from manual from manual methods or manual methods or affect sites’ spiritual methods or unspecified effects unspecified effects on spiritual unspecified effects on Potential harm to qualities. on spiritual values of sites. values of sites. spiritual values of sites. spiritual sites

No effects from Mitigate through Mitigate through Mitigate through treatments. communication with the local communication with the local communication with the local community. community. community.

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3.4 WILDLIFE

3.4.1 Scope of the Analysis The scope or area and timeframe of the analysis vary according to the species being examined. Direct, indirect, and cumulative effects of the project alternatives on threatened, endangered, and sensitive species are analyzed at the local NNIP infestation level, and forest-wide (or project area), depending on the habitat needs and ranges of the individual species.

3.4.2 Management Direction and Forest Plan Consistency All action alternatives comply with the Forest Plan objectives, standards, and guidelines relative to threatened and endangered species, regional forester sensitive species, management indicator species (MIS), management indicator habitats (MIH), and other species of interest on National Forest land.

3.4.3 Existing Condition/Affected Environment There is one key issue based on public comments and internal discussion (See Section 1.7 for all issues) relating to threatened, endangered, or sensitive wildlife and plants (TES) and their habitat; or to other aspects of wildlife and its habitat.

Issue: Herbicides can have negative effects on Wildlife:

Indicator: Potential effects on T&E and RFSS species, management indicator species, management indicator habitats, neotropical migratory birds, and selected game species.

There are a total of 54 TES and MIS on the CPF. Data regarding known occurrences of these species were obtained from the CPF GIS file (USFS 2008) (PR# 253). Determinations of effects for each species are summarized in this EA. The direct and indirect effects of each project alternative on TES species are more fully described in the biological assessment (BA) and biological evaluation (BE), which can be found in the project record.

In addition, effects on management indicator species (MIS), management indicator habitats (MIH), neotropical migratory birds, and selected game species are disclosed.

3.4.4 Threatened and Endangered Species This section summarizes key findings and determinations from the BA (USFS 2011a) (PR#255).

3.4.4.1 EXISTING CONDITION/AFFECTED ENVIRONMENT (T&E) The gray wolf (Canis lupus) and Canada lynx (Lynx canadensis) are listed as threatened and endangered species. Table 3.4.1 lists the federal status and presence of these species in the Non Native Invasive Plant Management (NNIPM) project area. The BA tiers to the programmatic biological assessment for the revision of the Forest Plan (USFS, 2004c) (PR# 71h) and provides detailed information regarding site-specific effects of the NNIPM project on threatened and endangered species. Because the Forest Service determined that this project would have “no effect” for Canada lynx and gray wolf, concurrence from the US Fish and Wildlife Service (USFWS) was not required.

Table 3.4.1 -- Threatened and Endangered Species known or suspected to occur within the area of influence of the NNIPC project

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Species Federal Status Species Presence Canada lynx Threatened Unknown Gray wolf Threatened Known

3.4.4.1.1 Canada Lynx The historic range of Canada lynx extended from Alaska across much of Canada, with southern extensions into parts of the western United States, the Great Lakes states, and New England (Ruediger et al. 2000) (PR# 254). The FWS listed the Canada lynx in March 2000 as threatened in the contiguous United States (USFWS 2000) (PR# 255). The distribution of lynx is strongly associated with the boreal forest and stable populations of the snowshoe hare (Ruggiero et al. 1999) (PR# 256). There have been 4 verified lynx sightings on the CPF.

Threats to Canada lynx consist of habitat loss or modification, trapping, inadequate regulatory mechanisms to protect lynx and their habitat, and other factors such as increased human access into suitable habitat and human-induced changes in habitat allowing other species (bobcats and coyotes) to move into lynx habitat and compete with them. Snow conditions on the CPF do not commonly give lynx a competitive advantage during the winter when survival is most difficult. The CPF usually has about 12 inches of snow on the ground for 45 days/year. Snow that does fall on the CPF often sublimates and frosts over, forming a crust that can easily support small to medium-sized mammals.

3.4.4.1.2 Gray Wolf The gray wolf population in Minnesota far exceeds the population goal of 1,400 wolves in the state. The winter survey of 1997-1998 showed a 50% increase in the statewide population estimate compared to surveys conducted a decade ago, with about 2,450 wolves ranging over 33,970 square miles in the state. The 2007-2008 wolf survey results showed an estimated 2,921 wolves in the State, well above the population goal and the population in 1997-1998 (Erb, 2008) (PR#257). The white-tailed deer population is also at an all time high, due in part to aspen clearcutting that creates quality forage and mild winters in recent years resulting in low winter mortality. Although a severe winter would reduce the herd and reduce wolf numbers, the deer herd has quickly rebounded in the past. Wolves are known to occur throughout the CPF.

3.4.4.2 – EFFECTS (T&E) 3.4.4.2.1 – ALTERNATIVE A Alternative A would have no apparent direct, indirect, or cumulative effects to any threatened or endangered species. There would be no change in habitat for lynx, wolves, or their prey. Most NNIP occur in areas (roadsides, gravel pits, recreation areas) not typically utilized by these species. As a result, any effects would be negligible.

3.4.4.2.2 – ALTERNATIVES B and C and D The BA (USFS 2011a) (PR# 187) documents the potential effects on Threatened and Endangered species that result from implementation of Alternative B. There would be no change in habitat for lynx, wolves, or their prey. Most NNIP occur in areas (roadsides, gravel pits, recreation areas) not typically utilized by these species. As a result, any effects would be negligible.

Alternatives C and D would have the same effects as Alternative B. Any effects would be negligible.

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3.4.5 Regional Forester’s Sensitive Species (RFSS)

3.4.5.1 - EXISTING CONDITION/AFFECTED ENVIRONMENT (RFSS) The Forest Plan identifies sensitive species whose viability is of concern on the CPF due to their rarity, limited range, or susceptibility to management activities. Sensitive species are plant and animal species identified by a Regional Forester for which population viability is a concern as evidenced by (FSM 2670.5):

Significant current or predicted downward trends in population numbers or density. Significant current or predicted downward trends in habitat capability that reduce a species’ existing distribution.

The BE (USFS 20011b) (PR# 183) evaluates all proposed project alternatives for effects on Regional Forester’s Sensitive Species. Forest Service Manual (FSM 2672.42) objectives for completing a BE are to:

Ensure that Forest Service actions do not contribute to loss of viability of any native or desired non- native plant or animal species, Ensure that Forest Service activities do not cause any species to move toward federal listing, and Incorporate concerns for sensitive species throughout the planning process, reducing negative impacts to species and enhancing opportunities for mitigation.

There are 51 species listed as RFSS on the CPF. Based on species presence and potential for habitat to be impacted by NNIP, the list was reduced to 29 species that are evaluated in detail. A summary of the potential impacts to these selected sensitive species is found in Table 3.4.2 The remaining species that were not evaluated in detail received a finding of “no impact” from implementation of Alternatives A, B, C or D. These remaining RFSS species are not discussed in detail.

Most of the RFSS analyzed in detail share similar habitats on the CPF and are summarized below:

Forest Birds Wet Meadow/Marsh Birds Bay-breasted warbler LeConte’s sparrow Olive-sided flycatcher Nelson’s sharp-tailed sparrow Connecticut warbler Yellow rail Trumpeter swan Wilson’s phalarope

Mesic Northern Hardwoods Plant Guild Upland Disturbed Plant Guild Blunt-lobed grapefern Pale moonwort Goblin fern Ternate grapefern Lanceleaf grapefern One-flowered broomrape Goldie’s wood fern Squirrel Corn

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Riparian/Wetland Plant Guild Olivaceous spike-rush Northern bur-reed Few-flowered spike-rush Awlwort American shoreweed slender waternymph Southern waternymph Snail seed pondweed Sheathed pondweed Hidden-fruit bladderwort Cuckoo-flower

Canada yew can be found in a variety of habitats, but is typically associated with mature forests.

3.4.5.2 – EFFECTS (RFSS)

Table 3.4.2 Summary of effects to RFSS from implementation of Alternatives A, B, C or D Effects Determination* Common Name Summary of Effects Alt. A Alts. B and C LeConte’s Sparrow MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Ammodramus Alts B, C and D: Very slight potential for direct effects. Potential leconteii) beneficial effects to habitat. Nelson’s sharp-tailed MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. sparrow Alts B, C and D: Very slight potential for direct effects. Potential (Ammodramus beneficial effects to habitat. nelsoni) Olive-sided NI MIHN Alts B, C and D: Slight potential for direct effects. Potential flycatcher beneficial effects to habitat. (Contopus cooperi) Yellow rail MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Coturnicops Alts B, C and D: Very slight potential for direct effects. Potential noveboracensis) beneficial effects to habitat. Trumpeter swan MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Cygnus buccinators) Alts B, C and D: Very slight potential for direct effects. Potential beneficial effects to habitat. Bay-breasted warbler NI MIHN Alts B, C and D: Slight potential for direct effects. Potential (Dendroica castenea) beneficial effects to habitat. Connecticut warbler NI MIHN Alts B, C and D: Slight potential for direct effects. Potential (Oporornis agilis) beneficial effects to habitat. Wilson’s phalarope MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Phalaropus tricolor) Alts B, C and D: Very slight potential for direct effects. Potential beneficial effects to habitat. Lanceleaf grapefern MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Botrychium Alts B, C and D: Very slight potential for direct effects. Potential lanceolatum var. beneficial effects to habitat. angustisegmentum) Goblin fern MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Botrychium mormo) Alts B, C and D: Very slight potential for direct effects. Potential

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Effects Determination* Common Name Summary of Effects Alt. A Alts. B and C beneficial effects to habitat. Blunt-lobed MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. grapefern Alts B, C and D: Very slight potential for direct effects. Potential (Botrychium beneficial effects to habitat. oneidense) Pale moonwort MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Botrychium Alts B, C and D: Slight potential for direct effects. Potential pallidum) beneficial effects to habitat. Ternate grapefern MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Botrychium Alts B, C and D: Slight potential for direct effects. Potential rugulosum) beneficial effects to habitat. Goldie’s wood-fern MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Dryopteris goldiana) Alts B, C and D: Very slight potential for direct effects. Potential beneficial effects to habitat. Olivaceous spike- MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. rush Alts B, C and D: Very slight potential for direct effects. Potential (Eleocharis olivacea) beneficial effects to habitat. Few-flowered spike- MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. rush (Eleocharis Alts B, C and D: Very slight potential for direct effects. Potential quinqueflora) beneficial effects to habitat. One-flowered MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. broomrape Alts B, C and D: Very slight potential for direct effects. Potential (Orobanche uniflora) beneficial effects to habitat. Northern bur-reed MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Sparganium Alts B, C and D: Very slight potential for direct effects. Potential glomeratum) beneficial effects to habitat. Awlwort MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. () Alts B, C and D: Very slight potential for direct effects. Potential beneficial effects to habitat. Canada yew MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Taxus canadensis) Alts B, C and D: Very slight potential for direct effects. Potential beneficial effects to habitat. Squirrel corn (Dicentra MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. canadensis) Alts B, C and D: Very slight potential for direct effects. Potential beneficial effects to habitat. American shoreweed MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Littorella paludosa) Alts B, C and D: Very slight potential for direct effects. Potential beneficial effects to habitat. Slender waternymph MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Najas gracillima) Alts B, C and D: Very slight potential for direct effects. Potential beneficial effects to habitat. Southern waternymph MIHN MIHN Alt A: Potential negative effects due to spread of NNIP.

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Effects Determination* Common Name Summary of Effects Alt. A Alts. B and C (Najas guadalupensis Alts B, C and D: Very slight potential for direct effects. Potential spp. olivacea) beneficial effects to habitat. Snail seed pondweed MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Potamogeton Alts B, C and D: Very slight potential for direct effects. Potential bicupulatus) beneficial effects to habitat. Sheathed pondweed MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Potamogeton Alts B, C and D: Very slight potential for direct effects. Potential vaginatus) beneficial effects to habitat. Hidden-fruit MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. bladderwort Alts B, C and D: Very slight potential for direct effects. Potential (Utricularia beneficial effects to habitat. geminiscapa) Cuckoo-flower MIHN MIHN Alt A: Potential negative effects due to spread of NNIP. (Cardamine pratensis Alts B, C and D: Very slight potential for direct effects. Potential var. palustris) beneficial effects to habitat. * NI: No Impact MIHN: May impact individuals or habitat, but would not likely contribute to a trend toward federal listing or cause a loss of viability to the population or species.

3.4.5.2.1 ALTERNATIVE A Under this alternative, no NNIP treatments would take place. Therefore, there would be no direct impacts to RFSS from any treatment activities.

NNIP would continue to spread under Alternative A and impact native plant communities. For the wet meadow/marsh bird group and for all of the RFSS plants, continued NNIP spread would degrade suitable habitat thus causing some potential indirect negative impacts to these species. This is especially true for the one known Goldie’s wood fern location within 50 feet of a garlic mustard infestation and the three Canada yew locations within 50 feet of spotted knapweed infestations.

3.4.5.2.2 ALTERNATIVES B AND C For the majority of RFSS, Alternatives B and C would have no impacts. For other species (Table 3.4.2) there could be a mix of slight adverse effects and beneficial effects. For many species, the reason for no impact is simply that suitable habitat for the RFSS does not overlap with where the weed infestations are; most NNIP infestations are along roads, in gravel pits, at recreation sites, or other areas that are not suitable habitat. Design features also help to prevent impacts, for example by changing the timing of treatments for some species or by minimizing the risk that herbicides would move off-site and have non-target impacts, such as by using spot application of herbicides rather than broadcast application.

Five known RFSS plant (Goldie’s wood fern [1], Goblin fern [1], and Canada yew [3]) locations occur within 50 feet of known NNIP infestations. In these cases the treatment method with the least impact would be chosen, such as hand pulling or wick application of herbicide, to ensure no impacts to RFSS plants. Some short term impacts from trampling of suitable RFSS plant habitat is possible. However,

7/5/2011 10:55 AM Page - 58 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF over the long term Alternatives B and C would help improve or maintain suitable habitat for many of these species.

For RFSS plants, there is a chance that individuals could be missed during surveys and thus get directly sprayed by herbicide or could be impacted by mechanical/manual treatment. However, sufficient suitable habitat at any given site would remain untreated such that only individuals would probably get impacted, not entire populations.

For wetland RFSS plants, Alternatives B and C would have very slight potential for direct effects due to trampling of plants if they occur in NNIP areas and due to the use of aquatic approved herbicides on new purple loosestrife infestations. Treatment of purple loosestrife infestations would likely improve habitat for wetland/aquatic RFSS plants.

Some RFSS birds occupy habitats where NNIP are frequently found so there is a possibility that these species may accidentally be sprayed. The probability of this occurring is very low due to the high mobility of these species. LeConte’s sparrow, Nelson’s sharp-tailed sparrow, olive-sided fly catcher, yellow rail, black throated blue warbler, bay breasted warbler, Connecticut warbler, and Wilson’s phalarope all eat (at least for part of their diet) insects or berries/seeds and could thus potentially experience dietary exposure to herbicide, if they eat food that had been sprayed. The risk of negative effects is low because none of the proposed herbicides are highly toxic to birds (USFS 2009b). Ecological risk assessments conducted for the proposed herbicides suggest that use of these herbicides at rates commonly used by the Forest Service poses little or no risk to birds (USFS 2009b). However, the risk assessments for glyphosate and triclopyr conclude that small birds who consume insects from areas treated with the maximum application rate for an extended period of time could potentially experience adverse effects (USFS 2009b). Therefore, although negative effects are unlikely for these species due to the small areas treated, it is conservative to conclude that some individuals could be impacted.

There is a very slight chance that forest and wetland/marsh RFSS birds could be impacted by mechanical/manual treatments. Impacts could include short-term disturbance of individual birds or disturbance or damage to nests. The risk level for these effects is very low because most NNIP occur in areas that do not provide habitat for these species and individual treatment areas are very small. Treatments that occur in these RFSS bird habitats would be designed so that negative effects do not occur (See Mitigation Measures and design features, Chapter 4).

No impacts to RFSS are expected from release of biocontrol insects.

3.4.5.2.3 ALTERNATIVE D The effects disclosed for mechanical and biological control of NNIP under Alternative B and C would apply to Alternative D. There would be no herbicide use therefore no effects from herbicides on RFSS.

3.4.5.2.4 CUMULATIVE EFFECTS A summary of past present and future NNIP management can be found in Appendix E.

This cumulative effects analysis applies to the aforementioned species (Table 3.4.2). There would be no cumulative effects to all other sensitive species.

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Negative cumulative effects would continue under Alternative A and likely increase over time as NNIP spread. This continued spread could reduce the acres of suitable habitat for these species. NNIP prevention measures incorporated in recent and future vegetation and transportation management EAs and NNIP treatments occurring on state, county, and privates lands, which have primarily been the use of herbicides and bio-controls at a small scale would help to limit the negative cumulative effects of Alternative A, but there would still be a net increase in NNIP infestations on the CPF.

There may be a net beneficial effect of Alternatives B, C and D on RFSS. The design features would ensure that cumulative negative impacts to RFSS are minor. There would be beneficial effects to suitable habitat for these species under Alternatives B, C and D as NNIP are contained, controlled, or eradicated. Efforts to control NNIP on state, county, and private lands, which have primarily been the use of herbicides and bio-controls at a very small scale, would cumulatively add to these beneficial effects.

Alternatives B and C will have a slightly higher beneficial effect than Alternative D because using the full range of available control methods will have a greater effect in containing, controlling or eradicating NNIP. (See comparisons of effectiveness of different control strategies in Nuzzo 2000, Converse 2007, Wilson and Callahan 1999, MNDNR 2010, PE 2011, ALF 2011) Mechanical treatment, i.e. mowing, similar to what be proposed in Alternative D likely add a slightly negative cumulative effect as these types of treatments likely maintain NNIP on affected sites.

Overall, cumulative beneficial effects would probably slightly exceed the minor negative cumulative effects mentioned earlier. This would create a net beneficial cumulative effect for Alternatives B,C and D.

3.4.6 Management Indicator Species (MIS)

3.4.6.1 - EXISTING CONDITION/AFFECTED ENVIRONMENT (MIS) Management indicator species are those species that are monitored over time to assess the effects of management activities on their populations. MIS monitoring also indicates the effects on populations of other species with similar habitat needs, which represent major biological communities. National Forest Management Act regulations [CFR 36, part 219.19, paragraph a-6] state that “Population trends of management indicator species would be monitored and relationships to habitat changes determined.” This direction applies specifically to the forest planning process, but also has implications for project planning. There are four MIS on the CPF.

Gray Wolf Refer to the gray wolf section for project effects and population status on the CPF.

Bald Eagle Eagle numbers appear to have reached a leveling off point on the CPF. There is some evidence that in recent years, competition among breeding pairs due to high nesting densities has resulted in some declines in breeding success. It appears that the growth rate of eagles on the CPF is dropping, and the habitat in this region has reached its capacity (USFS 2004c) (PR# 312).

Activity and productivity flights were conducted for bald eagles in 2007. A total of 259 nests were surveyed. Of these, 113 nests were active with 55 of them fledging young. A total of 66 eagle chicks

7/5/2011 10:55 AM Page - 60 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF were observed during the productivity flights; 0.58 young fledged per active nest. This productivity is up slightly from 2005, the last year bald eagles were monitored on the CPF, when the average was 0.41 young fledged per active nest. For the period from 1987 thru 2004, CPF bald eagle monitoring shows an average of: 151 (range, 88-189) active breeding pairs; 96 successful breeding pairs (range, 66-108); and 1.02 young fledged per active nest (range, 0.76-1.39) (USFS 2008b) (PR# 258). Bald eagles nest throughout the CPF where suitable nesting habitat is present.

Northern Goshawk Over the past 10 years, the number of active goshawk territories known on the CPF has ranged from 7 to 16. Of the 14 active territories in 2009 on the CPF, 11 of the territories successfully fledged young. The great variability of young per active nest and signs of predation at failed nests indicates intense predation pressure. Predators such as red-tailed hawks, great horned owls, raccoons, and fisher are more abundant in open areas and edge habitat. Goshawks nest throughout the CPF where suitable nesting habitat is present.

White Pine No change in the acreage and distribution of white pine is expected on the CPF as a result of this project so further discussion of existing conditions is not warranted.

3.4.6.2 – Effects (MIS)

3.4.6.2.1 – ALTERNATIVE A Since there would be no change in habitat for MIS, effects resulting from increases in NNIP are negligible.

3.4.6.2.2 - ALTERNATIVES B, C and D Since there would be no change in habitat for MIS, effects are negligible.

Gray Wolf Refer to the gray wolf section for project effects and population effects on the CPF.

Bald Eagle The NNIPC project is anticipated to have “no impact” on bald eagles or their habitat. This is due to no potential for direct, indirect, or cumulative effects.

Northern Goshawk The NNIPC project is anticipated to have “no impact” on goshawks or their habitat. This is due to no potential for direct, indirect, or cumulative effects.

White Pine There would be no change in the acreage and distribution of white pine on the CPF as a result of this project.

3.4.7 Management Indicator Habitats

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Management indicator habitats (MIHs) are groupings of forest types. The 9 management indicator habitats include upland forest, upland deciduous, northern hardwoods, aspen-birch, upland conifer, upland spruce-fir, red and white pine, jack pine, and lowland black spruce-tamarack. MIHs are described in more detail in the Forest Plan (USFS 2004a, C-1, C-2) (PR# 72) and Objectives, Standards, and Guidelines relating to the MIHs are also described in the Forest Plan (USFS 2004a, 2- 32, 2-33) (PR# 72).

There will be no change in the amount, size, or distribution of MIHs on the CPF resulting from implementation of Alternatives A, B, C, or D.

3.4.8 Neotropical Migratory Birds

3.4.8.1 - EXISTING CONDITION/AFFECTED ENVIRONMENT (NTMB) Neotropical migratory birds breed in the U.S. and Canada, and winter in the Caribbean, Mexico, Central America, and South America. Many populations are in decline, due in part to conversion of grasslands and wetlands to agriculture, fragmentation of habitat, loss of wintering and migratory habitat, and brood parasitism.

Northern Minnesota and the CPF are located within the Boreal Hardwood Transition Zone that occurs between the mixed hardwood forest to the south and the boreal forests to the north. Twenty five neotropical migratory bird species on the Forest are associated with this zone. These species are associated with a variety of habitats on the CPF including mature forest, young forest, shrublands, marshes, and openings.

3.4.8.2 EFFECTS (NTMB) Potential impacts to several migratory birds and their habitats have already been discussed in the RFSS section. Impacts to other bird species would be very similar to those mentioned previously in this EA. Refer to the RFSS section of the EA and the BE (USFS 2011b) (PR# 183) for potential impacts to migratory birds and their habitats.

3.4.9 Selected Game Species

3.4.9.1 Existing Condition/Affected Environment (Game) Game species of interest in the project area include ruffed grouse (Bonasa umbellus), white-tailed deer (Odocoileus virginianus), and American woodcock (Scolopax minor).

Ruffed Grouse Ruffed grouse on the CPF appear to reflect similar trends to those across northern Minnesota, with a 10-year cycle being characteristic of their population dynamics.

White-tailed Deer White-tailed deer population levels are at historically high levels, supported by generally favorable combinations of foraging habitat (young aspen-birch forests) and winter thermal cover (dense conifers). Habitat is excellent with the abundant clearcutting that has been done over the last 3 decades, especially the recent aspen regeneration.

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American woodcock The statewide and national population trends have been declining, possible due to the succession of old farm fields to forest and less young forest near riparian areas. On the CPF, there is very little timber harvest within riparian management zones that creates young riparian forest habitat that woodcock prefer.

3.4.9.2 Effects (Game) Since most NNIP infestations do not occur in habitat for these species (i.e. roadsides, gravel pits, etc.) any impacts from implementation of Alternatives A, B, C or D would be negligible.

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3.5 WATER QUALITY

3.5.1 Issue Herbicides may have negative effects on water quality, aquatic organisms, and ground and surface water.

Indicators: Water quality: Sedimentation, Maximum Contaminant Load (surface and ground water) Aquatic Organisms: Hazard Quotients (under modeled scenarios) Herbicide degradation as measured in half-life (halftime)

3.5.2 Scope of the Analysis The boundaries used for the direct and indirect effects were the proclamation boundaries of the CPF, including National Forest System lands and lands in other ownerships, and the time it takes for the proposed chemicals to degrade. This boundary has been used because of the minimal disturbance expected from manual/mechanical treatments, design criteria to prevent chemicals from entering water systems, the limited mobility of the herbicides proposed to be used, and the rapid decomposition of the herbicides.

Effects of the proposed treatment methods range in duration from a few days for some of the herbicides up to one year for adequate site re-vegetation. Table 3.5.1 gives the half-life data for the proposed list of herbicides.

3.5.3 Direct and Indirect Effects

Alternative A No direct or indirect effects will occur from Alternative A.

Alternatives B, C and D Manual, mechanical, and bio-control methods would have minimal direct or indirect effects on water quality. Work performed in aquatic or wetland settings could temporarily suspend sediments in the water, but given the small size of the areas proposed for treatment and the required use of Best Management Practices (BMPs); effects, such as erosion and sedimentation, would be brief, localized and minimal in magnitude. Mowers and other vehicles would not be operated in wetlands while the ground surface is inundated or saturated or otherwise unable to support the equipment (dry or frozen only).

Directly adjacent to aquatic systems such as lakes, streams, and wetlands are transitional lands known as riparian areas. “They are the areas through which surface and subsurface hydrology connect water bodies with their adjacent uplands” (Committee on Riparian Zone Functioning and Strategies for Management, 2002). Any of the NNIP control methods mentioned above should have limited adverse effects within Riparian Management Zones (RMZs) as long as they conform to the Forest Plan desired conditions, objectives, and guidelines as outlined in the Forest Plan (USDA 2004, Chapter 2: D-WS-9, D-WS-11, D-WS-12, O-WS-2, O-WS-7, O-WS-10, G-WS-6, G-WS-7). Adhering to project design features should provide adequate protection for hydrology, water quality, and aquatic organisms when managing NNIP with manual or mechanical methods under Alternative B,C and D.

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Chemical control methods involving spraying herbicides could expose soils and surface water to herbicides, even when label directions are followed. Herbicides that fall on soil during spray operations can leach into groundwater or be transported via surface runoff that could result in unintended affects elsewhere. However, the small areas proposed for treatment each year under Alternative B and C would not allow for more than localized migration of small quantities of herbicides. Furthermore, modern herbicides are designed to rapidly break down into inactive products in soils and water (see herbicide half-life data in Table 3.5.1 and the soils discussion in Section 3.8).

To minimize any unintended impacts to water quality or aquatic organisms, project design features in Alternative B and C require buffers around wet areas and recommend only those herbicides with formulations approved in aquatic applications be used. According to the Natural Resources Conservation Service, to reduce sediment and sediment-adsorbed contaminants, filter strips (i.e. buffers) adjacent to aquatic habitats should have a width of at least 30 feet and have a minimum width of 50 feet to substantially reduce/intercept chemical pesticides.

The Forest Plan describes RMZs as having two zones, each being 100 feet wide. Herbicides used in the zone nearest the aquatic habitat, known as the “near-bank” zone, would be the aquatic formulations, thus greatly reducing the likelihood of unintended runoff impacts into aquatic environs. The outer zone, known as the “remainder” zone, could be treated similarly to other non-riparian areas in regards to herbicide usage since the distance from water would be at least 100 feet, thereby substantially reducing the likelihood of contaminants reaching surface water.

However, in the event herbicides do enter surface water, concentrations would quickly decline due to mixing (dilution), volatilization, and degradation by sunlight and microorganisms.

Table 3.5.1 Indicators of risk to the aquatic environment associated with proposed herbicides Herbicide Water Half- Solubility/Mobility Risk Characterization life for Terrestrial Plants from Runoff 1 Aminopyralid Photolysis: 0.6 Maximum depth of soil penetration with Exceeds hazard quotient days annual rain 20 – 25 inches: 60 inches (for levels for sensitive species clay, loam, or sand soils). 1.55 – 1.79 % on clay soils. of applied amount lost via runoff on predominantly clay soils (20 – 25 inches of precipitation). Virtually no runoff from sand or loam soils. Glyphosate (less A few days High water solubility (SERA 2003a) Does not exceed hazard toxic quotient levels formulations)2 Imazapic 30 days Higher application rates along with Does not exceed hazard increased precipitation increases risk of quotient levels runoff. Loss via wind erosion is also a possibility Imazapyr Photolysis: 2.5 “At annual rainfall rates of 10 *No model worksheets* – 5.3 days inches/year or more, imazapyr will be removed from the soil by runoff (clay) or percolation (sand)” (SERA 2004c). Metsulfuron- 30 day average Ground-water monitoring studies Exceeds hazard quotient

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Herbicide Water Half- Solubility/Mobility Risk Characterization life for Terrestrial Plants from Runoff 1 methyl detected no metsulfuron methyl in areas levels for sensitive species of its usage. on clay soils. Sulfometuron- 14 days (low Model suggests runoff risk exceeds Exceeds hazard quotient methyl pH) – 60 days toxicity levels apt to affect sensitive and levels for sensitive and (high pH) tolerant terrestrial plant species when tolerant species on clay soils. applied to clay soils. Triclopyr (ester 84 days in (pH Very little translocation or runoff. Lower Exceeds hazard quotient formulation: 5) solution, 7 water solubility and higher affinity for levels for sensitive and TBEE) hours under soils tolerant species on loam and basic (pH 9) sand soils. Approaches conditions hazard quotient levels on clay soils. Triclopyr Disappears in Little off-site movement. Does not exceed hazard amine(salt 4 to 8 days. quotient levels formulation: Garlon 3A, TEA) Notes: 1 Runoff is modeled for terrestrial plants only. However, aquatic macrophytes would also be at risk depending on concentration of herbicide in water. 2 Glyphosate - “Based on the current data, it has been determined that effects to birds, mammals, fish and invertebrates are minimal”, however, “this risk characterization strongly suggests that the use of the more toxic formulations near surface water is not prudent” (SERA 2003a).

Although herbicides become more diluted in surface waters, there is still the possibility that even in low concentrations they can upset the ecological balance, result in toxicity, or cause contamination of drinking water supplies (Van Es 1990). In addition to the design criteria being implemented to minimize this effect, most of the herbicides proposed for use under Alternatives B and C have been demonstrated to pose little toxicological risk to fish, aquatic invertebrates, or wildlife when used at specified rates and as per the label directions (Tables 2.2 and 2.3). Certain formulations of triclopyr and glyphosate are toxic to fish and aquatic invertebrates and care must be taken during applications to ensure that these herbicides are not introduced into aquatic ecosystems. Only formulations approved for aquatic use by the State of Minnesota would be used near wetlands or other waters. Following these practices and strictly limiting use within the near-bank RMZ would ensure compliance with state and federal water quality laws and that water resources were protected.

Hydrology and Water Quality in Gravel Pits Gravel pits on the CPF are characterized as being small, dispersed, and relatively remote. Surface mining for gravel typically results in the removal of vegetation, soil, and sub-soil layers. Depending on pit depth and geology, groundwater may be exposed in the process of gravel extraction. So, due to water table proximity, a pit’s deepest portions occasionally contain standing water and or saturated soils. As a result of potentially close contact with groundwater, these areas may be subject to the same mitigations as other surface waters and wetlands with regards to chemical treatment methods.

The presence of water in a gravel pit does not always mean that groundwater is being exposed. Another likely possibility is that a confining layer at or below the surface is impeding the downward

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In some cases, controlling NNIP will be essential to ensure native seedling survival when restoring gravel pits to a more natural vegetative composition. Prior to use of herbicides, water table data should be collected on site and at a minimum would include surface texture and depth to water. A centrally located soil auger hole of > 5’ would give a good indication of sub-surface texture and the presence of shallow groundwater (see project design feature 2.7.7[g]).

Since these areas are inherently “disturbed” sites, more intensive mechanical treatments within close proximity to surface water should not be restricted. These methods would not increase the level of site disturbance or cause adverse impacts to water quality beyond what has already occurred.

Alternative D This alternative would be the same as Alternative B and C, except that chemical herbicides would not be used to control NNIP. Because herbicides would not be used under Alternative D, greater use of manual or mechanical methods would be needed to achieve the same results as Alternatives B and C. However, as expressed in the Soils Section, manual and mechanical methods would likely expose/disturb soils, potentially resulting in erosion. By increasing the usage of these methods, sedimentation of aquatic ecosystems also becomes more likely. Sedimentation can negatively affect hydrology (both streams and wetlands), aquatic organisms, and is a leading cause of biological impairment in rivers, streams, and wetlands (Bryce et al. 2010, Luo et al. 1997). Following project design features would reduce or possibly eliminate any direct or indirect effects to aquatic and water resources.

3.5.4 Cumulative Effects A summary of past present and future NNIP management can be found in appendix E

Past Impacts The effects of past mechanical, manual, chemical, or biological methods of NNIP are no longer evident and so, there would be no additive effect with regards to the proposed action. Herbicide usage on CPF lands was eliminated long ago except for in campgrounds and administrative sites to control poison ivy. Even in those areas, treatment areas are small and not likely to overlap spatially with the proposed management activities.

Present and Future Treatments in this EA will be implemented over the next ten years and are expected to require follow- up treatments. In all cases the expectation is that intensity and scope of follow-up treatment would decrease over time until the NNIP population was eliminated or contained.

There are no present or reasonably foreseeable future actions that would occur within the cumulative effects analysis area that would affect water quality, aquatic organisms, or ground and surface waters.

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Alternative A Not treating NNIP on the Forest may detrimentally affect hydrology, aquatic organisms, and water quality. Some NNIP, especially reed canary grass and purple loosestrife, form dense stands in shallow waters or wetlands that sometimes alter hydrologic flow patterns. In addition, NNIP left unchecked in aquatic systems would potentially alter natural aquatic organism community structure by replacing native macrophytes. In either case, destabilization of the established ecosystem could result in water quality issues such as nutrient imbalances and or sedimentation.

Alternatives B, C, and D By adhering to project design features and BMPs, runoff is not likely and would not contribute to offsite effects. Overlap between the spatial and temporal effects is extremely limited and as such no cumulative effects to aquatic resources are expected.

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3.6 HISTORIC PROPERTIES

This section will analyze effects to historic properties most commonly subject to review under Section 106 of the National Historic Preservation Act. These kinds of properties are tangible, have relatively discrete boundaries and have an age of at least 50 years. They must also have the capability of meeting one or more of four criteria of significance required to be considered eligible for listing on the National Register of Historic Places. They most commonly include archaeological sites, old homesteads, logging camps, historic buildings etc.

3.6.1 Issue Adverse effects to historic properties caused by site disturbance from manual and mechanical treatments, biocontrols and herbicide application. (non-key issue)

Indicator: Historic properties damaged due to treatment methods.

3.6.2 Scope of the Analysis NNIPs and historic properties can occur on virtually any terrestrial site on the CPF. Time frame of analysis is the last thirteen years and the next ten years. The last 13 years was used because this the time during which we have been treating NNIP and have data and the next 10 because that is roughly the time in which this work would be accomplished.

3.6.3 Management Direction and Forest Plan Consistency

Forest Plan The Forest Plan addresses historic properties in Forest-wide Standards and Guidelines (Page IV-20d). (PR# 72) Sites would be protected.

Desired future condition for historic properties is identification and management to maintain and preserve the qualities for which they have been deemed significant, and for benefits that may include research, education, historical perspectives in land management, and the general appreciation of American heritage. Treatment of historic properties for this proposed project is consistent with this management direction.

National Historic Preservation Act The considerations of historic properties for this project follow 36 CFR 800, the implementing regulations of Section 106 of the National Historic Preservation Act. Information concerning the specific location and nature of cultural resource sites is protected from public disclosure by the National Historic Preservation Act, the Archeological Resources Protection Act (PL 96-95), and is exempt from information requests under the Freedom of Information Act.

In accordance with provisions of 36 CFR 800, the Advisory Council on Historic Preservation (ACHP), the Minnesota State Historic Preservation Office (SHPO), the Leech Lake Tribal Historic Preservation Office (THPO), and the Forest Service signed and implemented a programmatic agreement on the management of heritage resources on the Chippewa National Forest. One of the purposes of the programmatic agreement is to identify routine and recurrent undertakings whose potential effects on historic properties are foreseeable and likely to be minimal and not adverse. The signatories agreed that certain undertakings meeting those criteria may be considered as exempt from further review under

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Section 106 of the National Historic Preservation Act. The exempt undertakings include a list of NNIP control methods as proposed in this EA.

These control methods are considered exempt because they do not create serious ground disturbance and because the majority of areas identified for treatment are within contexts such as roadsides, gravel pits, or utility corridors that have already been subject to serious earth disturbance. The specific language citing the methods covered under this exemption within the Programmatic Agreement are as follows:

a) Mowing or cutting to remove the above-ground portion of the target plants. b) Hand-pulling non-woody species to eradicate or control invasive plants, that is, removal of plant and root mass with nominal soil disturbance. c) Control of certain invasive plants such as wild parsnip by root-stab, which is cutting the root below ground surface by hand using a sharp, narrow shovel or spade (this does not include the removal of the plant’s entire root mass). d) Scorching invasive plants with a propane torch. e) Incorporation of replacement plant seed by surface raking. f) Biological control with insects, that is, control of invasive plants which involves applying specific insects that feed on the target plants. g) Chemical control, that is, the application of herbicides to eradicate or control invasive plants provided that the application designs will be subject to review by THPO under NEPA and will include warnings posted on site and the use of dyes to mark treated areas.

3.6.4 Existing Condition/Affected Environment

The general area contains numerous historical properties resulting from human settlement and other activities over the last 10,000 years. These include camping sites, villages, special activity areas such as wild rice processing sites, cemeteries, and sites of spiritual and traditional use. There is also evidence of a wide range of later historic activities ranging from the fur trade up to and including Forest Service administrative sites which are still in use today. Common late historic sites include those associated with mineral exploration, settlement, logging, fur trapping, resorts, and recreational dwellings such as cabins.

When historic properties are seriously disturbed or altered by construction or other activity, their physical integrity and historic significance are lost. Areas that have been subject to serious ground alteration in the past do not have the potential to contain substantial historic properties.

3.6.5 Effects

3.6.5.1 Direct and Indirect Effects Proposed treatments are not considered to pose a threat to historic properties because none of the proposed treatments are considered to have great risk of creating serious ground disturbance. Mowing and cutting shrubs does not go into or below the humus layer. The vehicle pulling the mower would be driving on green or dead vegetation, with minor stirring of the topsoil during turns or if spinning. Herbicides and bio-control are entirely above ground and done on foot. Pulling and root stabbing

7/5/2011 10:55 AM Page - 70 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF would penetrate the topsoil, but would only affect a few inches around each individual plant. Scorching would be directed at the above-ground portion of the plant and the soil would be protected from heat by the duff layer and by not directing the fire deliberately at the soil. The competitive seeding would involve scarification of only the very top layer of soil because native plant seeds normally do not need to be covered by more than ¼" of soil.

Alternative A Under the no action alternative, no control methods would be implemented. This alternative would have no direct or indirect effects to historic properties.

Alternatives B, C and D Under Alternatives B, C, and D; the proposed treatment areas create little or no ground disturbance. These alternatives would have no new effects to historic properties eligible for listing on the National Register of Historic Places. By signed agreement among the ACHP, SHPO, THPO, and the Forest Service, the proposed treatments are considered exempt from review under Section 106 of the National Historic Preservation Act.

3.6.5.2 Cumulative Effects A summary of past present and future NNIP management can be found in Appendix E.

Past and Current Effects No effects of past and current control methods are evident so there would be no additive effect with regards to the proposed action.

Future Effects Because of the lack of reasonably foreseeable effects posed by the proposed action, cumulative effects on historic properties are not anticipated.

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3.7 VEGETATION

3.7.1 Issue Effects of invasive plant control on native plant communities. (Non-Key Issue)

Indicator: Trend of native plant communities to increase or decrease in size and number.

3.7.2 Scope of the Analysis-Direct, Indirect and Cumulative Effects The boundary for the analysis is the proclamation boundary of the Chippewa National Forest. This boundary includes all lands susceptible to infestation by NNIP

The duration of the effects varies depending on the type of treatment method. Duration of effects is assessed for the effects of the treatments on NNIP and on native plant communities. The site disturbance that results from the treatments generally lasts a growing season or less. The effects on native plant communities are anticipated to be long term in that the NNIP would be contained, reduced or eliminated and native plant communities restored and the benefits would be realized within a least a year and last for decades.

3.7.3 Existing Condition/Affected Environment Approximately 4000 acres of non-native terrestrial plant species have been inventoried on the CNF. While numerous invasive species survey and inventory records exist in the corporate database, no systematic survey or inventory has been conducted for invasive species on the CPF; so it is impossible to produce a comparative watershed-by-watershed quantitative analysis of invasive species distribution and abundance on CPF watershed at this time.

The landforms of the CPF are largely the result of past history of continental glaciations which left the area dominated by very low-relief outwash plains and a variety of low drumlin, moraine and other hills typical of post-glacial landscapes. Low relief and high water tables lead to much of the region to be dominated by wetlands and open water, including numerous lakes and ponds and low-gradient streams and rivers. Predominant vegetation is upland forest, swamps, bogs, and marshes.

Almost all of the forested land in the CPF was logged to some extent in the 20th Century, and timber production remains the dominant land use in the area, although much of it was converted to agricultural use in the early twentieth century. While much of the land cleared for agriculture reverted to forest and wetland, some percentage of private land within the CPF proclamation boundary is in agricultural use, primarily for pasture, but some field crops such as wheat and corn are also grown.

The Chippewa National Forest is extensively and uniformly roaded. Very little of the forest is more than 2000 meters from a road of some type.

The combination of low relief, extensive timber and agricultural land and an extensive road network lead to the vegetation of the Chippewa to be best described as a uniform mosaic, following a regular pattern of forest, low density housing, wetlands, open water, and agriculture that is repeated across the landscape throughout the forest.

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Because of the lack of systematic quantitative data and the uniformity of landscapes across the forest, it is impossible to produce a watershed-by-watershed comparison of invasive species distribution and abundance on the CPF; so we will instead present a qualitative discussion of invasive species on the forest as a whole.

Wetland species Three wetland species cover substantial portions of the Forest, and could be expected to be found throughout the CPF, these include hybrid cattail (Typhus x glace), common reed (Phragmites australis) and Reed canarygrass (Phalaris arundinacea). While no forest-wide quantification has been conducted, these three species probably dominate acreages numbering in the several hundred to the thousands of acres.

Ruderal Weeds Non-native ruderal weeds, species that are restricted to disturbed, open sites including roadsides, wildlife openings, gravel pits, utility rights-of-way, home sites and pasture. Notable species include spotted knapweed (Centauries strobe spp. micranthos), common tansy (Tanacetum vulgare), and hawkweeds (Hieracium spp.) Canada and bull thistles, (Cirsium arvense and Cirsium vulgare) and sowthistles (Sonchus spp.) These species may be found on most but not all open sites. They sometimes dominate open sites but are often interspersed with native ruderal species. About 3900 acres of ruderal weeds are mapped on the CNF but the number of actual infested acres is much greater.

High Priority Invasive Plants The highest priority species for control on the CNF are shade tolerant invasive plants, because these species are very invasive in forest communities and all three species, garlic mustard (Alliaria petiolata), Common buckthorn (Rhamnus cathartica) and Siberian peashrub (Caragana arborescens) are in the early stages of establishment here, as well as being notorious trouble makers elsewhere in the region. Approximately 100 acres of high priority species are known on the CNF. More acres of these species, particularly buckthorn and peashrub are likely to be found in the future.

3.7.4 Direct and Indirect Effects

Alternative A The No Action Alternative (Alternative A) proposes no treatments for non-native invasive species, beyond the normal control being done on a routine basis in recreation areas and those control activities previously covered in other environmental assessments.

Under the No Action Alternative it is expected that non-native invasive species continue to spread into more areas of the Forest. The spread of non-native invasive plants would occur on disturbed sites, and depending on the NNIP, on sites that have not been disturbed. Areas that are currently infested would see increased numbers of NNIP and areas that are currently free of NNIP would have new occurrences of NNIP. Seed from NNIP continue to spread through natural dispersal such as wind, birds, root colonization, etc. In addition, forest users can easily pick up and spread seed with their vehicles, equipment, etc. NNIP prevention practices such as equipment cleaning limit but not control the spread of NNIP.

Without adequate treatment methods to contain, reduce, or eliminate NNIP, infestations go unchecked and the diversity of native plants and community composition decline over time. Failure to control

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NNIP infestations could eventually result in a loss of native vegetation diversity and the numbers of individual plants. NNIP are able to out-compete native plants. Native environments would be altered and degraded through the invasive plants chemical and physical properties, such as creating dense thickets and the production of allelochemicals, chemicals that prevent the growth of other plants. Structural or functional changes in plant communities would occur that could have detrimental effects on native plants. Some of the NNIP grow so densely or cover the ground so completely, that native plants are pushed out or sunlight is removed. As a result, diversity in natural environments would be reduced. Native plants may be displaced or eliminated from habitats. The spread and colonization of undisturbed areas become more frequent over time and threaten native communities more than today.

Alternatives B and C With the full suite of treatments available in alternatives B and C– mechanical, cultural, biocontrol, and chemical treatments; control measures can be implemented that result in the most effective and least costly treatments to curtail spread, eliminate NNIP, restore infested lands, or protect sites from becoming infested. Treatment actions are expected to result in a substantial reduction of NNIP on sites that are still small.

The project is designed to apply the most effective treatments to each NNIP. For some invasive species, a combination of manual, mechanical, chemical, biological, and competitive seeding treatments may be used. Some established NNIP may persist for several years despite treatment. Treatments may need to be repeated. In instances of early detection, if promptly treated, NNIP species may be completely eradicated. An early detection, rapid response (EDRR) plan would be used to find new infestations of high priority species (Appendix A) before they become established and spread. As such, invasive plant sites are likely to be contained, prevented from spreading, or reduced in terms of the area infested and the number of plants present.

Effects on Native Plant Communities: Control actions, applied in accordance with mitigation measures and herbicide directions, would damage a small number of non-target native plants. All proposed treatments would be planned to minimize the undesired impacts on native vegetation. All those involved with the control of NNIP would be trained to distinguish between NNIP and native species.

In general, plants adjacent to targeted NNIP species may be damaged or killed. The potential for this is explained more fully in the discussion that follows for each of the treatment effects (mechanical, cultural, biocontrol, and chemical). Loss of a few native plants would not affect native species abundance, distribution, or population viability because within the next growing season the area repopulate from seed in the soil or vegetatively from surrounding native plants; or the site may be planted or seeded to native plants. The overall effect would be to increase the health and vigor of the native plant community by removing the competing NNIP.

In some cases where eradication or reduction of the NNIP is not possible, the treatments would contain the NNIP population and decrease the likelihood of spread into uninfested areas or areas not yet invaded by NNIP. Overall, this would reduce the likelihood of an NNIP seed source from spreading into undisturbed areas.

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Manual/mechanical control Effects: Most of the proposed manual/mechanical treatments are highly selective, with very little potential to harm adjacent non-target native plants. These include hand-pulling, hand-cutting (with saws or brush cutters), and root stabbing. The loss of an occasional non-target plant would not cause a reduction in the native plant species because surrounding native vegetation remains unharmed and repopulation the site.

When small NNIP infestations are located and treated, hand pulling, root stabbing, and hand cutting can be very effective. Early detection and manual techniques can eliminate NNIP and prevent large infestations from occurring.

Other mechanical actions that are proposed in this EA are less selective. These include mowing, mechanical cutting, and scorching. Mowing would be limited to areas that are already highly disturbed such as road-sides because it disturbs most of the vegetation in the treated area. Many of these sites are already mowed as part of the normal road maintenance programs. Although mowing can be timed in such a way that it favors native or desired plants and discourages NNIP plants, mowing is generally detrimental to non-target plants in that it may reduce the vigor and reproductive activity of native plants. Limiting this practice to disturbed areas, targeting the treatment to the infested areas, and timing the treatment to avoid spreading seeds would reduce this impact. Mowing would remove flowering heads of NNIP but would not harm native grasses. Repeated mowing would result in weakened plants and removal of the seed source. Infestations would not likely continue to spread and new infestation would be prevented. Other native roadside annual and perennial plants appear to tolerate current mowing practices.

Overall effects of manual/mechanical control on non-target plants would be minimized by project design features. Further, these impacts are generally outweighed by the beneficial effect to the native plant community as a result of reducing NNIP.

Cultural methods’ Effects Cultural methods include tillage, barriers, controlled burning, and competitive seeding that would restore sites to conditions with more native plants over time.

Tillage and barriers tend to be applied in high density patches or areas of NNIP and may be followed by seeding or planting. The plant cover must be started from scratch. Tillage would be applied in areas badly degraded that warrant restoration. Tillage may be used in combination with chemical treatments and reseeding of native species. Because tillage opens up seed banks that include weed seed, treatments may need to be repeated. Barriers use material placed on the soil to smother small infestations of NNIPs. Barriers are effective if left in place for several years. Once removed, sites are devoid of vegetation and usually must be reseeded. Both treatments would shift species composition from NNIP towards native plant communities, although the process is more intensive and may take longer before the desired result is achieved.

Controlled burning would be applied when the timing and intensity of fire favors desirable native vegetation over NNIP. Controlled burning is most effective on sites where desirable fire resistant native species are in place or can be seeded and where NNIP species is intolerant to fire.

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Competitive seeding and planting would be used to revegetate disturbed areas with native species in order to slow the spread of weeds and eliminate bare ground as quickly as possible. Noxious weeds are highly aggressive, particularly in disturbed areas. On bare ground, many noxious weeds readily out- compete native species and create NNIP monocultures. For competitive seeding and planting to be effective, it is often necessary to take steps prior to seeding or planting. Seeding or planting an area that is already highly infested with NNIP often would not work without removing the infestation by mechanical, other cultural treatments, chemical, or biological methods first. Seeding and/or planting would establish native plant species, provide additional root competition, and reduce the vigor of the invasive plants.

Many factors contribute to the success of competitive seeding and planting, such as the time of year, how soon after the disturbance seeding would take place, as well as ground and weather conditions. If seeding when weather conditions are too dry or too wet, the seeds would not germinate. That could lead to further infestations or new infestations of NNIP, as well as the potential erosion of the bare ground. Incorrect planting, can lead to planting failure which also has the potential for erosion and new infestations of NNIP.

Biological Control effects: Three targeted NNIP species would use biological control insects for reduction and/or control. The insects that are proposed to be released are commonly available and accepted in Minnesota as biological control agents. All of them have been studied and screened by APHIS. All the agents proposed have a proven track record of use in many parts of the US without non-target plant effects since at least the early 1990s (Weeden et al 2010, Weeden et al 2010a, Lang 2010, Lang 2010a, Lang 2010b, Hansen 2010a, Hansen 2010b, Hansen 2010c, Hansen 2010d.) They have a very low potential for adverse effects to non-target plants.

Chemical control effects: Herbicides may damage non-target plants in treated areas despite careful planning and implementation.

All of the herbicides proposed in these alternatives are capable of killing or injuring non-target plants. Six factors which are discussed in more detail below can greatly influence the degree to which this may occur: 1) application method, 2) application conditions (weather), 3) season of application, 4) choice of herbicide (based on selectivity), 5) operator training, and 6) application rates of herbicides.

Loss of native plants may not alter the habitat because the area can repopulate from native seed in soil, from surrounding native plants with colonizing root systems, or if need be, from seeding or planting native species. The effects of herbicides on native plants would be minimal and temporary due to small size of most NNIP sites, judicious application, and appropriate timing.

Application method Herbicide would be applied by wiping, basal bark application, cut stump application or by spot spraying. Wiping, basal bark and cut stump methods are very direct allowing the operator to selectively and directly apply herbicide to the target plants. Because contact with non-target plants is highly unlikely, neither method would have undesired affects on non-target plants. Spot spraying minimizes effects to non target plants. Broadcast applications will not be conducted.

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The foliar spray method is slightly less direct and selective, consequently has a higher risk of affecting non-target plants. This method, which typically uses a hand-held or backpack apparatus, directs a narrow spray of herbicide on the target plant with minimal drift. With this method, there is some possibility that non-target plants can be sprayed with herbicide. This method is prescribed at sites which are highly disturbed with little native vegetation (such as roadsides), or would be used only when non-target plants are dormant (early spring or late fall).

Application conditions -weather Weather conditions can influence the potential for herbicides to affect non-target plants. Windy days can cause spray drift, and heavy rainfall can wash herbicides off treated plants and carry them in surface runoff to non-target plants. High temperatures can break down chemical quickly, and make them ineffective. High temperatures can also cause volatilization (liquid to a gas or vapor) of the liquids. To minimize this risk, herbicide application would only occur when wind speeds are 10 mph or less as specified on herbicide labels to reduce herbicide drift, when heavy rain events are not anticipated, and when temperatures are below a certain high temperature according to label instructions.

Season of application Applying herbicide during the growing season can kill or injure non-target plants if the application method is not highly selective. Project design criteria limit foliar herbicide spray in areas which are not heavily disturbed to times of the year when native plants are dormant, such as very early spring or late in the fall. At those times, the native plants are not susceptible to the herbicide, so no damage can occur. For example, garlic mustard is typically green and growing very early in the spring while the native plants are dormant and largely still below-ground. Spraying the garlic mustard with the foliar spray at that time of the year would kill the garlic mustard plants while leaving the native plants unaffected.

Choice of herbicide - based on selectivity Some herbicides are more selective than others. Selective herbicides have the ability to kill certain plants without harming others. Application of more selective herbicides would leave more of the non- target, native vegetation unaffected than a more non-selective herbicide, such as Glyphosate.

The application of project design features and mitigating measures, in combination with the six factors described above, would greatly minimize the effects of control actions on non-target, native vegetation.

There is a summary of chemical treatments in Tables 2.2 and 2.3.

Alternative D Under Alternative D, hand, mechanical, cultural, and biocontrol methods would be used but no chemical controls would be employed. In many cases, non chemical methods are less effective in treating invasive plants so while adverse effects would be less than the no action alternative, native plant communities would be more open to further invasion by NNIP under Alternative D than Alternative B or C.

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Table 3.7.1 Summary of Direct and Indirect Effects to Vegetation Indicator Alternative A Alternative B and C Alternative D Native Plant Progressive losses of Plant Communities Plant communities Communities Restored native vegetation restored, minor adverse restored to a lesser effects to individual extent than Alt B. More plants offset by control impacts from NNIP of NNIP Less adverse effects to individual plants.

3.7.5 Cumulative Effects A summary of past present and future NNIP management can be found in Appendix E.

Past and Current Effects Adverse effects on native plant communities from past and current NNIP control actions are not evident.

Future Effects Based on past actions, it is expected that other agencies and adjacent land owners would maintain the current level of treatments. Levels may increase but future plans by parties other than the Chippewa National Forest within the CPF proclaimed boundary for herbicide treatment of invasive plants are not known at this time.

Treatments in this EA will be implemented over the next ten years and are expected to require follow- up treatments. In all cases the expectation is that intensity and scope of follow-up treatment would decrease over time until the NNIP population was eliminated or contained.

Alternative A Limited NNIP infestations would be treated. Limited control or eradication activities on other ownerships would contribute to an overall increase in NNIP spread. Invasive plants would continue to spread into more areas of the Forest, including less disturbed areas and high quality ecological areas. Combined with the failure of other landowners to reduce NNIP, this would result in a decline in ecological function of the natural communities within the Forest.

Past efforts on CPF lands may have curtailed the spread of NNIP but have not eradicated any species. Invasive plants still persist, some from root sprouting, others from seed in the soil; some because no effective treatment (in some cases chemicals) have been applied.

Increased development on other ownerships and forest use across the Forest also increase the potential for NNIP spread and contribute to reducing the diversity of existing natural plant communities.

Alternatives B and C The proposed treatment actions are expected to result in a noticeable reduction of NNIP within treated areas on the Forest and reduce the potential for spread to uninfested acres and to other ownerships, and vice versa. Although some treatments are occurring on other ownerships, they are limited in size and the benefits are localized. The proposed methods, especially if coordinated with other agencies and owners, could increase the effectiveness and efficiency of treating NNIP and move towards protecting or restoring native plant communities on all lands. Acres treated are expected in increase above current levels and effectively contain or eradicate new infestations.

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Adverse effects from mechanical, cultural, biocontrol, and chemical treatments on non-target plants and plant communities are expected to be minimal. Although non-target native plants could be affected by the control activities in these alternatives, there is a far greater potential for decline of these species and their habitats if no treatment occurs and NNIP continue to spread.

Alternative D The proposed treatment actions under alternative D are anticipated to be less effective than under alternative B or alternative C. Invasive plants that are not susceptible to manual, mechanical, cultural and biological control methods would continue to spread resulting in a decline in ecological function of natural communities within the forest.

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3.8 SOILS

3.8.1 Issues While none of the key issues listed in Chapter 2 specifically targets soil health and productivity, soils are however often tied closely to surface and groundwater quality. Soil texture, topographic relief, precipitation amount and timing, herbicide properties, and vegetative ground-cover all influence the degree of runoff or groundwater infiltration in any particular terrestrial system. See the Hydrology/Water Quality/Aquatic Organisms section for more discussion regarding runoff.

Management and control of NNIP on the Forest has the potential to affect the environment beyond the intended target. This includes detrimentally impacting non-target plants via herbicide runoff, efficacy of an herbicide after target species expiration, herbicide groundwater infiltration, and the erosion and deposition of disturbed soils.

Indicator 1: Offsite movement through soil percolation Depending on soil texture (sand, clay, or loam) and precipitation, some of the herbicides in our analysis, have the potential to move from the area of application to areas down-slope or into the soil column (Table 3.5.1). As a result, a map of the Forest showing soil texture was made (PR# 274) in addition to a table summarizing the acres of each soil texture category (

Table 3.8.1).

Indicator 2: Herbicide half life The risk of unintended impacts from herbicides decreases as the chemical compounds degrade. This degradation, known as “half-life” or “halftime”, is estimated for each of the proposed herbicides in Table 3.8.2.

Indicator 3: Infiltration to groundwater Several herbicides have the potential to infiltrate the groundwater. The amount and rate of infiltration is a function of: chemical properties, how they interact with soil properties (physical, chemical, and biological), and depth to groundwater (Tables 3.8.1 and 3.6.1).

Indicator 4: Erosion potential of disturbed soils Described and summarized in Table 3.8.3.

3.8.2 Scope of the Analysis The boundaries used for the analysis were the proclamation boundaries of the CPF, including National Forest System lands and lands in other ownerships, the time it takes for the proposed chemicals to degrade. This boundary has been used because of the minimal disturbance expected from manual and mechanical treatments, the rapid degradation and limited mobility of the chemicals proposed to be used, and our inability to foresee or control activities that occur outside the proclamation boundaries.

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Table 3.8.1 Area in acres of Clay, Sand, Loam, and Peat/Muck textured soil on Chippewa National Forest Lands Frequency Soil Texture acres 119 Clay 7,642 2289 Sand 205,699 2386 Loam 280,520 6525 Peat/Muck 159,448 1058 Not Rated 18,165 Total 671,473 Note: Not Rated refers to areas occupied by water. Frequency refers to the number of soil series polygons represented in each category. Peat/Muck are wetland soil textures.

3.8.3 Direct and Indirect Effects

Alternative A Taking no action to control NNIP infestations on the CPF would not result in any direct or immediate adverse impacts to the soil resource.

Alternative B and C

Movement Through Soil At higher application rates and rainfall Imazapic’s risk of loss via runoff and percolation increases, however with application rates proposed for the CPF and precipitation amount characteristic of the local climate, model estimates predict negligible movement would occur (PR#263). Due to longer half- life and low percolation rates on clay soils, generating runoff containing aminopyralid or sulfometuron methyl residue at levels having the potential to affect both sensitive and tolerant terrestrial plant species is likely. However, as long as the proposed herbicides are used as directed by label specifications and in accordance with the design criteria, minimal effects would result.

Herbicide Residues in Soil Spraying herbicides results in short-term accumulation of herbicide residues in the soil. Once in the soil, herbicides can translocate to groundwater, surface waters, or other soils via leaching and runoff. To determine the level of risk of accumulating herbicide residues on soils and possible contamination of ground and surface waters, factors such as persistence (measured as half-life), mobility, and mechanisms of degradation have been reviewed (Table 3.8.2). Factors influencing herbicide persistence can be broken into three categories: soil factors, climatic conditions, and herbicidal tendencies/properties (Hagar et al. 1999) (PR#260). The factors that influence persistence in soil interact with one another and include issues such as pH, cation exchange capacity(CEC), soil moisture, organic matter, organisms present, and molecular binding of chemicals to organic and soil particles (Hagar et al. 1999, Miller and Westra 2004a [PR#261], Tu et al. 2001 [PR#262]). Precipitation patterns following application also can influence the fate of herbicides on soils, and their potential contamination of ground and surface waters. Furthermore, different formulations of the same

7/5/2011 10:55 AM Page - 81 - Environmental Assessment Non Native Invasive Plant Management Chippewa NF herbicides (e.g. salts vs. esters or varying surfactants or formulations) would also alter persistence, degradation pathways, and mobility in soil (Miller and Westra 2004b, Tu et al. 2001).

The persistence of an herbicide is defined as the length of time that residues from an application remain active in the soil. This is typically measured in terms of half-life, which is the time it takes to degrade 50% of the herbicide into inert products. The herbicides proposed for use have soil half-lives that range from 10 days to 6 months (Table 3.8.2). In general, the herbicides proposed for use have relatively short persistence in the soil and soil microbes readily degrade most of the proposed herbicides. Herbicides that are more persistent could offer longer suppression of invasive plants, including less reestablishment from existing seed stock in the soil; however, these herbicides would also pose a greater risk to the environment and were therefore not considered for use in this project.

Off-Site Movement of Herbicides The soil mobility (movement through the soil) of the proposed herbicides is varied (Table 3.8.2). Glyphosate and ester formulations of triclopyr bind rapidly to the soil and therefore exhibit little movement (i.e. runoff or groundwater infiltration). Metsulfuron methyl has a longer half-life in soil, however, studies show no detectable amounts were found in ground or surface waters (SERA 2004a) (PR#072d).

Table 3.8.2 Indicators of risk to the soil environment associated with proposed herbicides Herbicide Soil Half-life (half-time) Solubility/Mobility Glyphosate 20 – 60 days (SERA 2003a), 47 High water solubility (SERA 2003a) day average (Tu et al. 2001) Triclopyr (ester 40 days average; 14 days in Very little translocation or runoff. formulation: TBEE) selected Canadian forest soils. Lower water solubility and higher affinity for soils Triclopyr (salt Light causes chemical to degrade Little off-site movement. formulation: Garlon 3A, (photolysis) in several hours, TEA) half-life in soil 14, 40 - 46 days

Imazapic 106 days (photolysis), Higher application rates along with 113 days (aerobic soil increased precipitation increases risk of metabolism, sandy loam) runoff. Loss via wind erosion is also a possibility

Aminopyralid 61 days (soil photolysis), Maximum depth of soil penetration Aerobic: 14 – 21 days (sandy with annual rain 20 – 25 inches: 60 loam), 25 – 49 days (loam), 46 – inches (for clay, loam, or sand soils). 60 days (silty loam), 266 – 343 1.55 – 1.79 % of applied amount lost days (clay loam), 5 days (clay) via runoff on predominantly clay soils (20 – 25 inches of precipitation). Virtually no runoff from sand or loam soils. Metsulfuron methyl 120 days; however, highly Ground-water monitoring studies variable and probably depends detected no metsulfuron methyl in areas on microbial populations in the of its usage. soil. Much more rapid

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Herbicide Soil Half-life (half-time) Solubility/Mobility degradation expected in some soils (SERA 2004a). Much slower under anaerobic conditions (i.e. wetland soils) Imazapyr 25 (clay) – 67 (loam) – 180 “At annual rainfall rates of 10 (sand) days. Highly dependent inches/year or more, imazapyr will be on microbial population (SERA removed from the soil by runoff (clay) 2004c) or percolation (sand)” (SERA 2004c). Sulfometuron methyl 10 (clay) – 30 (loam) – 100 Model suggests runoff risk exceeds (sand) days. toxicity levels apt to affect sensitive and tolerant terrestrial plant species when applied to clay soils. Note: half-life times are estimates based on the synthesis of numerous herbicide studies. Times are only approximate; site level conditions ultimately control degradation rates.

Erosion Hazard Ground disturbing control methods such as hand tool digging and tilling could temporarily increase the potential for soil erosion at some sites in limited locations. Given the small area of annual anticipated disturbance, particularly when compared to other on-going activities, the results would be negligible. Furthermore, according to project design, soil left bare of vegetative cover following treatment would be re-seeded with species deemed appropriate by the Forest Botanist. Highly erodible areas would be carefully evaluated prior to treatment and measures would be taken during treatment to minimize adverse soil impacts. The duration of these control method effects would last approximately one growing season or less depending on seeded species establishment.

The use of herbicides as a control method would not increase erosion since herbicides kill but do not physically remove plants and their root systems. The root systems of dead plants offer short-term soil stabilization thus protecting against erosion until new plants are established either naturally or via seeding and planting. By applying herbicides to cut stumps, basal bark, or live xylem of woody NNIP species such as the buckthorns and honeysuckles re-sprouting is discouraged without the soil disturbance normally accompanied by stump removal.

Table 3.8.3 Erosion Hazard Analysis for Soils on Chippewa National Forest Lands FREQUENCY Soil Texture Erosion Hazard ACRES 119 clay Slight 7,642 14 fine sand Slight 469 495 fine sandy loam Slight 84,965 217 loam Slight 13,914 297 loamy coarse sand Slight 37,339 995 loamy fine sand Slight 85,912 635 loamy sand Slight 60,247 74 loamy very fine sand Slight 1,931 4618 muck Slight 64,590 2 mucky loam Slight 0

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FREQUENCY Soil Texture Erosion Hazard ACRES 1495 mucky peat Slight 76,064 412 peat Slight 18,794 12 sandy loam Slight 28 508 silt loam Slight 23,464 807 very fine sandy loam Slight 130,635 Slight Total 605,994 76 gravelly loamy coarse sand Severe 2,024 Severe Total 2,024 1058 Not rated 18,165 Not rated Total 18,165 243 fine sandy loam Moderate 24,274 40 loam Moderate 2,045 198 loamy sand Moderate 17,776 8 sandy loam Moderate 16 36 silt loam Moderate 787 18 very fine sandy loam Moderate 393 Moderate Total 45,291 Grand Total 671,473 Note: Erosion Hazard categories include: Slight, Moderate, Severe, and Very Severe. No CPF soils were rated as Very Severe. Explanation of the Erosion Analysis is included in the Aggregate Report generated for Erosion Hazard for off-road and off-trail land management activates (e.g. logging or site prep). The “Not rated” category refers to area occupied by water.

For a discussion of mobility of herbicides in gravel pits, see water quality section 3.5.3.

Alternative D Alternative D would be the same as Alternatives B or C, except that no herbicides would be used to control NNIP. However, an existing categorical exclusion would continue to allow the use of chemicals to treat poison ivy on recreation and administrative sites. In the absence of herbicides, it can be assumed that those acres not treated with herbicide would be subject to appropriate manual, mechanical, cultural, or biological control methods. The same concerns as expressed in Alternative B and C regarding NNIP control methods that disturb soil remain true for Alternative D. Increasing the area treated with methods such as tillage or hand tool digging increases the risk of erosion in susceptible areas. A careful evaluation of erosion vulnerability is necessary in those situations. However, treated areas would remain relatively small in comparison to other activities on the forest and would be quickly re-vegetated following NNIP removal to prevent re-infestation and reduce soil erosion. Limited soil compaction is a possibility in the case of the mechanical and manual control methods, however the effects would likely be short-lived (approx. 1 season) and limited only to portions of treatment areas.

3.8.4 Cumulative Effects A summary of past present and future NNIP management can be found in Appendix E.

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Alternative A There would be no direct or indirect adverse effects on soils associated with implementing Alternative A. However, over time, NNIP can adversely impact soils by removing nutrients and increasing soil erosion (Olson, 1999) (PR#259). Allelopathic chemicals released into the soil by certain exotic plants such as common and glossy buckthorn, bush honeysuckle, and spotted knapweed can inhibit the establishment of native plants. NNIP’s ability to alter soil physical, biological, and chemical properties therefore could eventually result in adverse impacts if we fail to control their spread. However, any adverse impacts are likely to remain localized to NNIP infestation sites with little effect passing on to adjacent areas.

Alternatives B, C and D Alternatives B, C, and D would not result in effects other than those discussed for the direct and indirect effects. Because of the small size of areas to be treated by mechanical control methods, the short half-life of the herbicides proposed for use, and the limited area to be treated overall, the direct and indirect effects would be minimal. Thus, because the direct and indirect effects associated with Alternatives B. C, and D are minimal, there would be no cumulative effects when combined with the effects of past, present, or reasonably foreseeable future activities outlined in other parts of the text.

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3.9 RECREATION and Aesthetics 3.9.1 Issue: Treatments may affect the experience of recreational users of the Forest.

Indicators: Changes to scenic qualities Potential shifts in recreation experiences or opportunities

3.9.2 Scope of the Analysis The analysis is tied to potential effects on recreation use; potential effects on aesthetics, and potential for recreationists and other forest users to spread NNIP within or immediately adjacent to treatment areas.

3.9.3 Spatial and Temporal Framework NNIP treatment effects would be analyzed within the treated areas and areas adjacent to them. Most recreation and forest use follows roads and trails or occurs in developed or dispersed recreation sites. Some of these areas, particularly along roads and trails, also are the most sensitive in terms of visual quality and aesthetics. In these areas, ground disturbance, the extent and duration of dead vegetation, or lingering smoke or chemicals that accompany treatments may impact users. Recreation use may change. In some instances, recreationists may be displaced and forest users may contribute to the spread if NNIP.

The effects on visual and recreational resources are analyzed for the life of the most visually disruptive portions of the projects (e.g. ground disturbance associated with manual and mechanical methods, or killing plants with chemical, scorching, and competitive seeding). Depending on the treatment, duration of effects may range from a day to several weeks. The replacement of NNIP with a native plant community would be a long term effect that would occur within months, possibly a year or two and persist for years, hopefully decades when and where beneficial effects are attained.

3.9.4 Existing Condition/Affected Environment The Forest has a wide range of recreational and forest uses – hunting, fishing, hiking, camping, gathering berries, scenic driving, and off highway vehicle (OHV) riding are among the most popular. Most recreationists’ activities are along roads and trails or occur in developed or dispersed recreation sites. Almost all of them rely on roads and trails to some extent to get to areas of interest. NNIP are found along many of the major and minor roads used to access the Forest.

3.9.5 Effects

3.9.5.1 DIRECT AND INDIRECT EFFECTS

3.9.5.1.1 ALTERNATIVE A (NO ACTION) NNIP have been present for decades slowly changing the appearance and characteristics of the landscape. The shift to NNIP would continue for the most part slowly although there are some situations where NNIP could explode and rapidly spread.

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Failure to control the spread of NNIP could adversely affect aesthetics and future use. While some forest users may not be sensitive to the changes resulting from infestations, others may be concerned about the presence and spread of NNIP and loss of ecosystem function. For example, purple loosestrife, an attractive plant to some when in bloom, would persist in many wetlands and would be expected to expand thus altering the natural landscape. Loosestrife may also interfere with fishing or boating or swimming along some lakeshores. Some NNIP, such as wild parsnip and knapweed, may cause dermatitis on exposed human skin. The establishment of dense thickets of buckthorn may interfere with hiking, birding, or other recreational activities in forested areas. As a result, as NNIP expand, there may be changes to the kinds of recreational use and quality of the experience for some forest users.

Many known sites infested with NNIPs are along roads and trails. Vehicles using roads and trails appear to be a major vector for spreading NNIP. NNIP is also spread by OHV users in ditches and utility corridors.

3.9.5.1.2 ALTERNATIVES B and C Alternatives B and C would continue to provide for the current developed and dispersed recreation experiences and types of recreational uses. Treatments would reduce NNIP levels, thereby reducing the potential for spread.

All of the treatments may be more or less noticeable to forest users depending on the size of the area being treated and the proximity to high use areas such roads, trails, and recreation facilities. Treatments in high use areas may impact the recreational experience depending on the sensitivity of the user. In addition, scorching, controlled burning, and chemical treatments may temporarily displace users or discourage use of an area for a few hours or days, due to the smell associated with the treatments. This may result in a temporary shift in use to other areas or types of recreational activities until recovery of the site occurs.

Ground disturbance would temporarily alter the physical appearance of treated areas. Such visual impacts would be temporary and expected to last a single growing season as natural succession, growth of residual native plants, planted and/or seeded plants return the area to a more natural appearance.

Much of the public would consider the elimination of NNIP species as aesthetically beneficial. However, there may be some that prefer the appearance of NNIP species, such as purple loosestrife. The long-term aesthetic benefits from replacing near monocultures of NNIP with a diverse mixture of native plant species could outweigh any short-term adverse effects depending on the preferences of users.

Fewer NNIP on the landscape would also reduce the opportunities for spread by users, maintain or improve existing opportunities for recreationists and other forest users. In addition, there would be fewer opportunities for contacts with species that cause skin reactions such as dermatitis.

Control of NNIP would lead to more diverse vegetation, ultimately enhancing the recreational experience for most users. No changes in recreation uses are expected, beyond short term exclusion of recreationists and short term restrictions on gathering of berries and other plants.

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Manual and Mechanical treatments These control activities would have little, if any adverse impact on recreation or forest aesthetics.

Digging, stabbing, and manually pulling may leave disturbed and exposed soil but the extent would be tied to the treatment of individual plants so the disturbance would be small scale. Most treatments are expected to be restricted to a fraction of an acre.

Cultural treatments Tillage such as disking or blading would result in more soil disturbance and exposure but the rapid vegetative growth generally limits the impacts to one growing season or less. Barriers used to smother infestations of NNIP and controlled burning may be more noticeable until vegetation re-colonizes the treated site. With controlled burning, smoke may briefly impact visibility and the smell may discourage users for a few hours until it disperses. Competitive seeding with native plants, tree planting, or allowing natural succession may take months to become established but are expected with time to return the site to a more natural, desirable condition both visually and ecologically.

Biocontrol treatments Use of insects for biocontrol would be rarely detectable by the casual forest observer. Generally individual or small groupings of plants are slowly killed. As that occurs, other plants obtain a competitive edge and slowly fill in to take their place. Biocontrol agents may work for years or decades depending on the amount of host material available to sustain their population. Biocontrol agents are target specific and safe.

Chemical treatments Herbicide treatments would leave standing dead vegetation. This would take weeks to months before it falls over or is hidden by vegetative regrowth. Stumps treated with herbicides to control a NNIP brush species would require several weeks or more to be hidden by surrounding vegetation.

Sites treated with herbicides may be temporarily closed to prevent people from contacting wet herbicide solution on treated foliage, soil or water. Herbicide areas would be signed and be colored with dye so people could easily see and avoid them. The dye normally lasts about a week. Signs posted may be visually disruptive for a few days. Users may choose to avoid an area for a day or more depending on personal preferences, or their concerns about the use of chemicals, or their tolerance of chemical odors.

3.9.5.1.3 Alternative D The effects are the same as Alternative B and C with the exception that chemicals would not be used in this alternative.

3.9.5.2 Cumulative Effects A summary of past present and future NNIP management can be found in the Appendix.

Past and Current Effects The effects of past mechanical, manual, chemical, or biological methods of NNIP are no longer evident and so, there would be no additive effect with regards to the action alternatives. Herbicides are periodically used to reduce poison ivy in campgrounds and administrative sites. In these areas, treatment areas are small and not likely to overlap spatially with the proposed management activities.

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Future Effects It is expected that other agencies and adjacent land owners would maintain the current level of treatments. Levels may increase but future plans by other owners within the CPF proclaimed boundary for treatments of invasive plants are not known at this time. Treatments by other land owners would have similar affects as CPF activities with regard to aesthetics and recreational uses, although they would contribute to a reduction in NNIP and their potential for spread from off forest to on forest.

Proposed treatments covered by this EA will be implemented over the next ten years and may require some follow-up treatments. The expectation is that the intensity and scope of follow-up treatment would decrease over time until the NNIP population was contained, controlled, or eliminated.

The replacement of NNIP with diverse, native plant communities would be a beneficial long term affect that would result in a more desirable and enjoyable experience by all forest users. Temporary changes to aesthetics (up to a growing season) and recreational uses (hours to a few days) may occur due to the various treatment activities. Although sites may warrant a repeat treatment, a reduction in NNIP and increased vegetation diversity would be expected to improve or enhance the scenic values and overall recreational experience for the treated sites and the overall landscape.

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3.10 ENVIRONMENTAL JUSTICE

3.10.1 Introduction Under Executive Order 12898 (Federal Actions to Address Environmental Justice in Minority Populations and Low Income Populations) (PR# 29), when populations of low-income persons (below poverty level) or minorities of the county are greater than twice the state percentage for low-income or minority populations or there is expected to be a disparate effects on such populations, an environmental justice assessment must be conducted. Portions of Beltrami, Cass, and Itasca Counties lie within the Forest boundary.

The Leech Lake Reservation is within the forest boundary. Demographic information indicates that an analysis under EO # 12898 is relevant for Beltrami and Cass County, and the Leech lake Reservation. Because of traditional gathering activities by Native Americans, the proposed activities could potentially impact that group more than any other group of forest users.

Information in the health and safety, vegetation and traditional resource sections supports the conclusion on Environmental Justice.

3.10.2 Issue Treatments may have a disproportionate affect on minorities or low income persons.

Indicator: Adverse effects experienced by low-income persons

3.10.3 Effects

3.10.3.1 Direct, Indirect, and Cumulative Effects ALTERNATIVE A (NO ACTION) Since additional treatments would not be done, there would be no disproportionate effect on any one group. The spread of NNIP, as discussed in the vegetation section, may reduce the diversity of native plant communities, thus reduce or displace traditional gathering of some resources. However, in the next few years no major differences from those currently existing would be expected. In the long term, that is one or more decades, there may be enough acres infested that impacts to traditional resources may be more substantive.

ALTERNATIVES B, C, and D As noted in the vegetation section, treating NNIP is expected to contain, reduce, or eliminate NNIP. In the process, plant diversity and native plant communities would be maintained or improved. This would be beneficial in terms of maintaining or improving the traditional gathering resources.

Aspects of the project related to environmental justice include the opportunity to comment on the project and the potential effects on low-income persons. Numerous meetings with the Local Indian Councils of the Leech Lake Band and the Division of Resource Management personnel (DRM) provided opportunities to comment on the project. Details of these meetings are included in the project file.

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Individual concerns regarding the use of chemicals proposed in Alternatives B and C have been noted. Health and safety was discussed in an earlier section. Alternative D analyzes non-herbicide treatments.

In summary, the activities proposed would not result in demographic changes such as displacement of minorities, geographic changes such as land use, or economic hardship such as an increase in taxes. The action alternatives would not have negative effects on public health and should have beneficial effects such as increased opportunities for berries or other gathering opportunities. None of the alternatives would impose a hardship on minorities, low-income people, or local communities and would not produce hazardous waste or conditions that might adversely affect a local population.

There are no anticipated direct, indirect, or cumulative effects with regard to proposed treatments on environmental justice.

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3.11 ECONOMICS

3.11.1 Scope of the Analysis The costs and benefits of treatments would be incurred by the National Forest, but the standard economic analysis model, Quick Silver, doesn’t work well with this project for a couple of reasons. First, since this EA is programmatic, costs associated with acres of treatment, treatment methods, and timing of treatments is yet to be determined. Furthermore, the objective of this project is to apply the most effective treatments necessary to curtail or eliminate the spread of a particular species. Consequently, an evaluation of the costs of one treatment method verses another is not critical to the decision to be made by the line officer.

Second, benefits are difficult to quantify and would be subject to debate. For example, the changes in plant diversity, stand structure, among many other effects are difficult to quantify economically. In addition, NEPA does not require a quantitative, monetary analysis of non-commodity resources.

What follows is a brief qualitative discussion on long term (more than 10 years) detrimental effects as a result of loss of native plant communities, loss of ecosystem function, and the trend of future costs of treating NNIP and restoring ecosystems.

There would be no substantial direct, indirect, or cumulative effects on social conditions, local employment or revenue generated as a result of taking no action or implementing the proposed treatments because treatments are generally small in scale. This aspect of the economic impacts is not discussed further.

3.11.2 Issue The effectiveness of NNIP treatments would have an effect on future costs incurred to treat NNIP.

Indicator: Qualitative change and trend in future costs to treat NNIP and restore ecosystems.

3.11.3 Effects

3.11.3.1 Direct and Indirect Effects 3.11.3.1.1 Alternative A (No Action) Alternative A would not control the NNIP which would continue to spread making control or reduction activities in the future more costly. However, failure to effectively control the spread of NNIP species may result in long-term loss of habitat, shifts in ecosystem function, or accelerated invasion of NNIP species. This in turn would result in more expensive control measures in the future to treat NNIP and restore ecosystems.

3.11.3.1.2 Alternatives B, C and D Both alternatives would reduce the future costs of controlling NNIP by limiting their spread into new areas, controlling them in the current locations, or by eliminating current or new infestations. Because alternatives B and C use chemical treatments, the acres treated and effectiveness would be more than Alternative D. Actions on the Chippewa National Forest should help reduce future control costs by emphasizing the replacement of NNIP with native plant communities either naturally or through planting.

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3.11.3.2 CUMULATIVE EFFECTS Alternative A, no action, would result in more expensive control measures in the future.

Alternatives B, C and D would be most effective if combined with cooperative efforts for NNIP treatment activities on other ownerships. This would potentially curtail the spread of NNIP across adjacent ownerships and in the long term result in reduction of future treatment or ecosystem restoration costs.

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4. List of Preparers and Agencies Consulted

4.1 CORE INTERDISCIPLINARY TEAM

Tom Heutte Interdisciplinary Team Leader, Proposed Action, Mitigations, Background Material, Maps/GIS, Tribal Consultation, Writer-Editor

Sharon Klinkhammer NEPA Consistency Review

Mark Sommer Soils, Hydrology, Water Quality, Aquatic Organisms

Cory Mlodik Threatened, Endangered and Sensitive Species

Bill Yourd Traditional Practices, Historic properties

Leo Johnson First draft Interdisciplinary Team Leader, Scoping, Tribal Consultation

4.2 AGENCIES CONSULTED

Minnesota Center for Environmental Advocacy Mississippi Headwaters Board Beltrami County Highway Department Cass County Highway Department Minnesota Department of Transportation US Fish and Wildlife Service Leech Lake Band of Ojibwe, Division of Resource Management Leech Lake Band of Ojibwe, Tribal Historic Preservation Office Onigum Local Indian Committee Bena Local Indian Committee S Lake Local Indian Committee Oak Point Local Indian Committee Kego Lake Local Indian Committee Sugarbush Local Indian Committee

4.3 CORPORATIONS CONSULTED

UAP Timberland Weed Busters Biocontrol Lake Country Power Burlington Northern-Santa Fe Railroad Beltrami Electric Cooperative Inc.

4.4 INDIVIDUALS CONSULTED

Gene Larrimore, Barnum Lake Minnesota John Eaton, Walker MN

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APPENDIX A: Chippewa National Forest Invasive Plant Management Priority List

A list-Eradicate, goal is to completely eliminate all populations Common Name Scientific name Garlic mustard Alliaria petiolata Glossy buckthorn Frangula alnus Leafy spurge Euphorbia esula Siberian peashrub Caragana arborescens Bush honeysuckle Lonicera x bella

B list-Control-Reduce number, density or vigor of populations wherever feasible. Where more aggressive management is unfeasible employ BMPs to prevent further spread. Curly pondweed Potamogeton crispus Purple loosestrife Lythrum salicaria Wild parsnip Pastinaca sativa Spiny plumeless thistle Carduus acanthoides Meadow hawkweed Hieracium caespitosum Orange hawkweed Hieracium aurantiacum Spotted knapweed Centaurea stoebe

C list-Contain-Employ BMPs to prevent further spread, treat on active gravel pits, or in small populations in close proximity to at-risk pristine ecosystems Reed canarygrass Phalaris arundinacea Bull thistle Cirsium vulgare Canada thistle Cirsium arvense Perennial sowthistle Sonchus arvensis Common tansy Tanacetum vulgare Narrow cattail, hybrid cattail Typha angustifolia, T. x glauca Butter and Eggs Linaria vulgaris Toadflax Linaria dalmatica Field bindweed Convolvulus arvensis Hoary alyssum Berteroa incana Eurasian water milfoil Myriophyllum spicatum Solidstem burnet saxifrage Pimpinella saxifraga Sweetclovers (white and yellow) Melilotus officinalis Oxeye daisy Leucanthemum vulgare

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APPENDIX B: Invasive Plants Proposed for Treatment

Garlic mustard (Alliaria petiolata) colonizes relatively undisturbed forest understories. It competes for light and space with many spring-flowering wildflowers and tree seedlings. Garlic mustard may also inhibit the growth of mycorrhizal fungi. Mycorrhyzal fungi are important to many native plants that use the fungi to obtain nutrients from the soil (Kaufman, 2007, p.279) (PR# 98ab).

John M. Randall, The Nature Conservancy, invasives.org

Common buckthorn (Rhamnus cathartica) and Glossy Buckthorn (Frangula alnus) are a problem in open woodlands, woodland edges, and abandoned fields. They have also been successful in invading forests and wetland edges and have the ability to grow quickly in open conditions plus it can tolerate shady conditions. Buckthorns form dense thickets under which few plants are able to grow and survive. The leaf litter of stands composed of buckthorn causes the nitrogen levels in soils to increase. This favors the establishment of more buckthorn and discourages the establishment of native species that have adapted to the soil condition prior to the establishment of buckthorn (PR# 98ab). The dense thickets produced are most likely to be detrimental to native shrubs and trees that are more shade intolerant.

John M. Randall, The Nature Conservancy, invasives.org (http://www.forestryimages.org) Bush Honeysuckles (Lonicera morrowii, Lonciera maackii, Lonicera x bella, Lonicera tatarica) Lonicera x bella was found growing in a regenerating clearcut in 2010. It is not known to be widespread in the CPF but is a commonly planted ornamental shrub in local communities. In other Midwestern areas, e.g. Wisconsin it is known to form dense monocultures where it may crowd and shade out competing native plants.

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Leslie J. Mehrhoff, University of Connecticut, invasives.org Leafy spurge (Euphorbia esula) occurs mostly in open rangelands, pastures, and prairies, but also occurs along streams and in open woodlands. Leafy spurge has very dense growth that inhibits the growth of native plants, and displaces those plants. The roots also exude chemicals that deter the growth of other plants (PR# 98ab). Leafy spurge establishes more readily in disturbed soil. A study showed that within a single infestation of leafy spurge, the frequency of 5 common native species decreased significantly. Native prairie vegetation that may be displaced might be sedge, little blue stem, blue grama and porcupine grass (PR# 20). The milky sap of the plant can irritate animals that eat it, and can poison cattle, so pastures and rangelands infested can lose productivity which leads to a loss of monetary value.

Wouldiam M. Ciesla, Forest Health Management International, invasives.org

Siberian peashrub (Caragana arborescens) invades woodland edge environments where it competes with native shrubs, (PR# 189). It can invade disturbed grasslands as well. Seeds are spread by birds and mammals. (PR# 136a).

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Dave Powell, USDA Forest Service, invasives.org

Purple loosestrife is found in natural and disturbed wetlands. It forms dense homogeneous stands that restrict native wetland species (PR# 73a). It is a prolific seeder, tolerant of a variety of water regimes and soils and can reproduce from broken pieces (PR# 98ab).

Joseph M. DiTomaso, University of California-Davis, invasives.org

Plumeless thistles (Carduus nutans and Carduus atcanthoides) are found in pastures, overgrazed areas, fields, and stream valleys and on roadsides (Noxious Weeds of Minnesota, Field Guide (PR# 68a)). They are very aggressive in disturbed areas and can form dense colonies, especially along waterways, ditches, and roadsides. They can outcompete valuable forage species in natural areas and rangelands, making it hard for wildlife to obtain high quality forage and habitat resources. Plumeless thistles have been known to invade native grasslands, even when dense native vegetation is present. (PR# 72aaaa).

Todd Pfeiffer, Klamath County Weed Control, invasives.org Spotted knapweed (Centaurea stoebe ssp. micranthos) out-competes and displaces native plant species in mostly disturbed open areas. The plant produces chemicals (allelochemicals called catechins) that poison competitors. The chemicals remain in the soil (PR# 98ab). Like the plumeless thistle, knapweed also has a taproot rather than a fibrous root system, which may allow increases in erosion, surface runoff, and stream sedimentation and so degrade soil and water resources.

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Leslie J. Mehrhoff, University of Connecticut, invasives.org

Common tansy (Tanacetum vulgare) is common along roadsides, fields, pastures, and other open and disturbed areas. It out-competes native herbaceous plants and grasses. It spreads by extensive, spreading root system and profuse seed production (PR# 136). Common tansy is causing inhibition of forest regeneration on wildlife clearings on the CPF (Travis Jones, pers comm)

Mary Ellen (Mel) Harte, invasives.org

Wild parsnip (Pastinaca sativa) is tolerant of a wide range of conditions. It can occur in dry, mesic, and wet-mesic prairies, and other open habitats. Wild parsnip slowly invades an area in waves following initial infestation. Once the population builds, it spreads rapidly. It is very aggressive. It can create a skin rash and/or blistering when the juices from the plant come in contact with the skin in the presence of sunlight (PR# 135).

John Cardina, The Ohio State University, invasives.org

Meadow and Orange hawkweed. (Hieracium arantiacum and Hieracium caespitosum) are two species of hawkweeds are perennials capable of reproducing from shallow fibrous roots and runners (stolons) as well as by seed. Hawkweeds are widespread and common in northern Minnesota but spot treatment to protect natural areas of high biological value may be warranted. Manual and mechanical

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Michael Shephard, USDA Forest Service, invasives.org

Perennial or Field Sowthistle (Sonchus arvensis) is a perennial that produces long creeping horizontal roots capable of producing new shoots. Roots fragment easily and can grow ten feet deep and can grow 6 feet horizontally in a season. Sowthistles may pose a threat to wet meadows and other open wetlands. Manual and mechanical treatments such as digging and hand pulling are ineffective except for the smallest (< 1 yd 2) infestations due to the extensive root network.

Theodore Webster, USDA Agriculture Research Service, invasives.org

White and Yellow sweetclover (Melilotus officinalis) are biennials with a long seed viability in the soil. They colonize disturbed areas and are not tolerant of shade. They are widely distributed on the CPF. They are not likely to be a major focus of control efforts but would be controlled on gravel pits in order to prevent further spread.

Steve Dewey, Utah State University, invasives.org

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Canada thistle (Cirsium arvense) Is a perennial thistle that develops vast underground root systems capable of fragmenting into new plants. Manual and mechanical methods are ineffective except for the smallest newly established populations.

University of Alaska Fairbanks, invasives.org

Bull thistle (Cirsium vulgare) Is a biennial thistle that colonizes disturbed areas, pastures and openings. It is proposed as a target in cleanup of gravel pits or when small populations threaten natural habitats.

Dave Powell, USDA Forest Service, invasives.org

Reed canarygrass (Phalaris arundinacea) Is a perennial grass that takes over wetlands, displacing native species. It is widespread and common in the CPF. It would be targeted on a limited basis where high quality habitat is at risk.

Jamie Nielson, University of Alaska Fairbanks, invasives.org

St. Johns Wort An erect perennial herb typically growing 1 – 2.5 feet in height; it prefers poor, sandy, dry soils and full sun, and can be found primarily in waste areas, railroad right-of-ways, sidewalk cracks, roadsides, meadows, dry pastures, rangelands, fields, open woods, dunes, and disturbed ground. This ecologically invasive plant crowds out native species and is toxic to livestock. It contains hypericin, a toxin that

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Jamie Nielson, University of Alaska Fairbanks, invasives.org

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APPENDIX C: Literature Cited

ALF- The Aldo Leopold Foundation. 2011. Garlic Mustard Management Protocol. Retrieved March 14, 2011 from: http://www.aldoleopold.org/woodlandschool/garlicmustard.shtml

Beck, K. G. 1999. Biennial thistles. In: R. L. Sheley and J. K. Petroff (eds.). Biology and Management of Noxious Rangeland Weeds. p. 155. Oregon State University Press. Corvallis, Oregon.

Bryce, S.A., G.A. Lomnicky, and P.R. Kaufmann. 2010. Protecting Sediment-Sensitive Aquatic Species in Mountain Streams Through the Application of Biologically Based Streambed Sediment Criteria. Journal of the North American Benthological Society 29(2):657-672.

Buckley, D. S., T. R. Crow, E. A. Nauertz, and K. E. Schultz. 2003. Influence of skid trails and haul roads on understory plant richness and composition in managed forest landscapes in Upper Michigan, USA. p. 518 Forest Ecology and Management 175: 509-520.

Committee on Riparian Zone Functioning and Strategies for Management. 2002. Riparian Areas: Functions and Strategies for Management. National Academy Press. Washington, D. C. Available at: http://books.nap.edu/catalog.php?record_id=10327 Accessed in January 2011.

Converse, C. K. 2007. Element Stewardship Abstract for Rhamnus cathartica, Rhamnus frangula. The Nature Conservancy. Wildland Invasive Species Team. Arlington, Virginia. Available at: http://tncweeds.ucdavis.edu/esadocs.html.

EPA-US Environmental Protection Agency. 2009. IPM Fact Sheet. Retrieved December 1, 2009 from: http://www.epa.gov/opp00001/factsheets/ipm.htm

Erb, John. 2008. Distribution and abundance of wolves in Minnesota. Minnesota Department of Natural Resources.

Executive Order 13112 of February 3. 1999. Federal Register Vol. 64, No. 25. Available at: http://www.invasivespeciesinfo.gov/laws/execorder.shtml

Federal Interagency Committee for the Management of Noxious and Exotic Weeds (FICMNEW) . 1997. Pulling Together: The National Strategy for Invasive Plant Management. Available at http://ficinnew.fws.gov/

Flame Engineering Inc. 2003. Weed Dragon Propane Torch Kit. Web Page. La Crosse, Kansas. Available at http://ww-w.flameengineering.com/Weed Dragon.html.

Hagar, A., Sprague, C., and M. McGlamery. 1999. Factors affecting herbicide persistence. Chapter 20 in 2000 Illinois Agricultural Pest management handbook. College of Agricultural, consumer and Environmental Sciences, University of Illinois at Urbana-Champaign. Kevin Steffey, Handbook Coordinator. Accessed 01/06/2011. http://web.aces.uiuc.edu/vista/pdf_pubs/iapm2k/chap20.pdf

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Hansen, R. 2010 Apthonia lacertosa. Biological Control: A Guide to Natural Enemies in North America. Cornell University website retrieved August 25, 2010 from: http://www.nysaes.cornell.edu/ent/biocontrol/weedfeeders/a.lacertosa.html

Hansen, R. 2010b. Apthonia nigriscutis. Biological Control: A Guide to Natural Enemies in North America. Cornell University website retrieved August 25, 2010 from: http://www.nysaes.cornell.edu/ent/biocontrol/weedfeeders/a.nigriscutis.html

Hansen, R. 2010c. Apthonia flava. Biological Control: A Guide to Natural Enemies in North America. Cornell University website retrieved August 25, 2010 from: http://www.nysaes.cornell.edu/ent/biocontrol/weedfeeders/a.flava.html

Hansen, R. 2010d. Oberea erythrocephala. Biological Control: A Guide to Natural Enemies in North America. Cornell University website retrieved August 25, 2010 from: http://www.nysaes.cornell.edu/ent/biocontrol/weedfeeders/oberea.html

Hoffman, R. and K. Kearns (eds.) 1997. Wisconsin Manual of Control Recommendations for Ecologically Invasive Plants. Bureau of Endangered Resources, Wisconsin Department of Natural Resources. Available at http://www.dnr.state.wi.us/org/land/er/invasive/manual toc.htm.

Johnson, E. 1996. Berheris thunbergii. In J. M. Randall and J. Marinelli (eds.) Invasive Plants: Weeds of the Global Garden. Brooklyn Botanic Garden. Brooklyn, New York.

Kedzie, Susan, Roger Sheley, and Bruce Maxwell. 1999. Integrated Weed Management on Rangeland. In: R. L. Sheley and J. K. Petroff (eds.). Biology and Management of Noxious Rangeland Weeds. pp. 256-257. Oregon State University Press. Corvallis, Oregon.

King County. 2011. King County (Washington) Noxious Weed Control Program Best Management Practices: Hawkweeds. Retrieved March 14, 2011 from: http://your.kingcounty.gov/dnrp/library/water-and-land/weeds/BMPs/hawkweed-control.pdf

Knutson, V. (ed.). Biological Control of Weeds in the West. Pages 13-15. Western Society of Weed Science, in cooperation with USDA Agricultural Research Service, Montana Department of Agriculture, and Montana State University.

Lajeunesse, S., R. Sheley, C. Duncan, and R. Lym. 1999. Leafy spurge. In: R. L. Sheley and J. K. Petroff (eds.). Biology and Management of Noxious Rangeland Weeds. pp. 256-257. Oregon State University Press. Corvallis, Oregon.

Lang, Ronald. 2010 Cyphocleonus achates. Biological Control: A Guide to Natural Enemies in North America. Cornell University website retrieved August 24, 2010 from http://www.nysaes.cornell.edu/ent/biocontrol/weedfeeders/cyphocleonus.html

Lang, Ronald. 2010a Larinus minutus. Biological Control: A Guide to Natural Enemies in North America. Cornell University website retrieved August 24, 2010 from http://www.nysaes.cornell.edu/ent/biocontrol/weedfeeders/larinus_minutus.html

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Lang, Ronald. 2010b Larinus obtusus. Biological Control: A Guide to Natural Enemies in North America. Cornell University website retrieved August 24, 2010 from http://www.nysaes.cornell.edu/ent/biocontrol/weedfeeders/larinus_obtusus.html

Larson, Janet R. 2011. Chemical Control of Buckthorn. Retrieved March 14, 2011 from: http://www.mntrees.org/pdf/BUCKCHEM_Apr051.pdf

Luo, H.R., L.M. Smith, B.L. Allen, and D.A. Haukos. 1997. Effects of sedimentation on playa wetland volume. Ecological Applications 7:247–252.

MDA-Minnesota Department of Agriculture. Buckthorn and its Control, and MDA Pest Alert. Retrieved March 14 2011 from: http://www.mda.state.mn.us/news/publications/pestsplants/badplants/buckthornfactsheet.pdf

Mehta, Shefali, R. Haight, F. Homans, S. Plasky, R. Venette. 2007. Optimal detection and control strategies for invasive species management. Ecological Economics (61) 237-245. Elsevier.

Michigan Department of Environmental Quality, 2003. Common Aquatic Plant Species and Herbicides Used as Potential Control Agents. Michigan Department of Environmental Quality, Water Division. Available at http://www.michigan.gov/deq/O,I607,7-135-3313 3681 3710--,00.html.

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Miller, P. and P. Westra. 2004b. How Surfactants Work. Number 0.562. Colorado State University, Cooperative Extension – Agriculture. Accessed 01/06/2011.

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Invasive Species Specialist Group. IUCN, Gland Switzerland and Cambridge, UK. Pp 249-253. Erb, John. 2008. Distribution and abundance of wolves in Minnesota. Minnesota Department of Natural Resources.

Ruediger, Bill, J. Claar, S. Gniadek, B. Holt, L. Lewis, S. Mighton, B. Naney, G. Patton, T. Rinaldi, J. Trick, A. Vandehey, F. Wahl, N. Warren, D. Wenger, A. Williamson. 2000. Canada lynx conservation assessment and strategy. USDA Forest Service, USDI Fish and Wildlife Service, USDA Bureau of Land Management, and USDI National Park Service. Missoula, Montana. 124 pp. http://training.fws.gov/library/Pubs5/Lynx_consassess_2000.pdf

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Seiger, L. 1991. Element Stewardship Abstract for Polygonum cuspidatum. The Nature Conservancy. Wildland Invasive Species Team. Arlington, Virginia. Available at http://tncweeds.ucdavis.edu/esadocs.html

SERA- Syracuse Environmental Research Associates, Inc. 1997. Use and Assment of Marker Dyes used with Herbicides. SERA 5100 Highbridge St. 42C, Fayetteville NY. www.sera-inc.com

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SERA- Syracuse Environmental Research Associates, Inc. 2002. Neurotoxicity, Immunotoxicity, and Endocrine Disruption with Specific commentary on Glyphosate, Triclopyr, and Haxazinone: Final Report. SERA 5100 Highbridge St. 42C, Fayetteville NY. www.sera-inc.com

SERA- Syracuse Environmental Research Associates, Inc. 2003. Triclopyr-Revised Human Health and Ecological Risk Assessments Final Report. SERA 5100 Highbridge St. 42C, Fayetteville NY. www.sera-inc.com

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SERA- Syracuse Environmental Research Associates, Inc. 2004. Clopyralid- Human Health and Ecological Risk Assessments Final Report. SERA 5100 Highbridge St. 42C, Fayetteville NY. www.sera-inc.com

SERA- Syracuse Environmental Research Associates, Inc. 2004a. Metsulfuron- Human Health and Ecological Risk Assessments Final Report. SERA 5100 Highbridge St. 42C, Fayetteville NY. www.sera-inc.com

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SERA- Syracuse Environmental Research Associates, Inc. 2004c. Imazapyr-Human Health and Ecological Risk Assessments Final Report. SERA 5100 Highbridge St. 42C, Fayetteville NY. www.sera-inc.com

SERA- Syracuse Environmental Research Associates, Inc. 2004d. Imazapic- Human Health and Ecological Risk Assessments Final Report. SERA 5100 Highbridge St. 42C, Fayetteville NY. www.sera-inc.com

SERA- Syracuse Environmental Research Associates, Inc. 2007. Aminopyralid- Human Health and Ecological Risk Assessments Final Report. SERA 5100 Highbridge St. 42C, Fayetteville NY. www.sera-inc.com

SERA- Syracuse Environmental Research Associates, Inc. 2007a. Preparation of Environmental Documentation and Risk Assessments for the USDA/Forest Service. Syracuse Environmental Research Associates Inc. 5100 Highbriddge St., 42C Fayetteville, New York 13066-0950. SERA MD 2007-01a

Sheley, Roger, Mark Moniukian, and Gerald Marks. 1999. Preventing Noxious Weed Invasion. In Biology and Management of Noxious Rangeland Weeds. Sheley, Roger and Janet Petrof (eds). Corvallis, OSU Press.

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Sheley, R. L., J. S. Jacobs, and M. L. Carpinelli. 1999. Spotted knapweed. In: R. L. Sheley and J. K. Petroff (eds.). Biology and Management of Noxious Rangeland Weeds. pp. 256-257. Oregon State University Press. Corvallis, Oregon.

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USFS - USDA Forest Service. 1998. Stemming the Invasive Tide: Forest Service Strategy for Noxious and Nonnative Invasive Plant Management. USDA Forest Service, Washington Office. Available: http://www.fs.fed.us/r6/weeds/fs strat doc.pdf

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USFS - USDA Forest Service. 2004a. Chippewa National Forest Land and Resource Management Plan. Chippewa National Forest.

USFS - USDA Forest Service. 2004b. Regional Forester’s Sensitive Plants Biological Evaluation. Forest Plan Revision. Chippewa and Superior National Forests. 66 pp.

USFS - USDA Forest Service. 2004c. Federally listed threatened and endangered species Biological Assessment for the Revised Forest Plans: Chippewa and Superior National Forests. 224 pp.

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USFS - USDA Forest Service. 2008b. Monitoring and evaluation report for FY 2007. Chippewa National Forest.

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Westbrooks, R. G. 1998. Invasive Plants: Changing the Landscape of America. Federal Interagency Committee for the Management of Noxious and Exotic Weeds. Washington, D. C. Available at https:i/www.denix.osd.mil/denix/Public/ES-Programs/Conservation/Invasive/intro.html.

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Van Es, H. M., and N. M. Trautmann. 1990. Pesticide Management for Water Quality: Principles and Practices. Ithaca, N.Y.: Cornell University Press.

Van Driesche R., S. Lyon, B. Blossey, M. Hoddle, R. Reardon. 2002. Biological Control of Invasive Plants in the Eastern United States, pp. 79-90, 149-157, 169-180, 181-194. Available at: http://www.invasive.org/eastern/

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APPENDIX D: Maps

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Appendix E Summary of Past, Present and Future Invasive Plant Control Actions in the Vicinity of the Chippewa National Forest

We have been able to determine the following amounts of NNIP control within the last 13 years by state, county, tribal, private groups, and the Forest Service within the CPF boundary.

E.1 Manual Control

Forest Service The Forest in 1997 did 8 acres of manual control of purple loosestrife and 43 acres of bio- control, 12.5 acres of tansy manual or mechanical control, and 2.3 acres of spotted knapweed manual or mechanical control. In 2001 the Forest treated 28 acres of leafy spurge, spotted knapweed, purple loosestrife, tansy, and poison ivy manually. The garlic mustard infestation discovered in 2002 was hand pulled and torch burned in 2002 and 2003.

The Forest from 2003 to 2009 did 427 acres of NNIP control:

Garlic mustard - 101 acres hand pulling. Plumeless thistle - 54 acres mowing Spotted knapweed - 58 acres mowing Purple loosestrife - 26 acres hand pulling and 13 acres bio-control Common tansy - 71 acres mowing and 14 acres hand pulling Canada thistle - 109 acres mowing Oxeye daisy - 5 acres mowing Hoary alyssum - 3 acres mowing and 3 acres hand pulling

The forest in 2010 accomplished 225.1 acres of NNIP control:

Garlic Mustard - 80 acres hand pulling Enbridge Pipeline - 78.8 acres soil disturbance and native reseeding Spotted Knapweed - 51.3 acres mowing Purple Loosestrife - 45 acres biocontrol (Turtle Lake Association Partnership)

State, County, Township: Based on personal communications between the CPF Supervisors' Office and the Minnesota Department of Transportation (Larry Puchalski, MN DOT Botanist) (PR# 139ab) in 2008, MN DOT conducts mowing but it is not conducted with the objective of NNIP control. The mowing is done with two cuts, one in June and one in the fall for snow. Within the boundaries of the CPF, mowing is done on State Highways 2, 200, 46, 371, 84 and 6.

E.2 Biological Control

Forest Service: The Chippewa National Forest halted bio-control efforts in 2001 due to a "lack of Forest NEPA decision documents."

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Tribal: Leech Lake Reservation has been using bio-control since 1995. Galerucella beetles were released at a number of locations for purple loosestrife during the summer of 2008. Nine sites within the Leech Lake Reservation had releases. The Kabekona Bay site had 3 separate releases in slightly different locations. Total number of insects released in 2008 was 3,250 to 3,900.

State, County, Township: Based on personal communications between the CPF Supervisors' Office and the Minnesota Department of Transportation (Larry Puchalski, MN DOT Botanist) (PR# 139ab) in 2008, MN DOT decided numerous years ago not to do any release of biocontrol within the Chippewa National Forest.

DNR provided a grant to the Turtle Lake Association to treat purple loosestrife including herbicide application (approximately 20 acres annually) and biocontrol releases on Turtle Lake in Itasca County and several nearby lakes (PR# 139ab, 275).

E.3 Chemical Contol

Forest Service The Chippewa National Forest has conducted limited treatments of poison ivy in recreation and administrative sites over the last 13 years.

State, County, Township: A common use of herbicides is to control weeds by public agencies along highway rights of way. However, use of herbicides by other public agencies within the boundary of the CPF is limited.

Based on personal communications between the CPF Supervisors' Office and the Minnesota Department of Transportation (Larry Puchalski, MN DOT Botanist) (PR# 139ab) in 2008, MN DOT decided numerous years ago not to do any herbicide application within the Chippewa.. One exception occurred in 2010. The Minnesota Department of Transportation applied Triclopyr using a wetblade mower to approximately eight acres on Highway 38 from south of Bigfork to Marcell with the goal of prevention of establishment of Canada thistle on a reconstructed road seeded with native species (PR#244).

In 2010, the Cass County Highway department applied herbicides to approximately ¼ mile of highway on Highway 8 between Longville and Federal Dam while investigating methods to control common parsnip (PR#250). Beltrami County does not use herbicides on roads they maintain within the CPF. No response was obtained from the Itasca County Highway department.

Turtle River and Onigum Townships in Cass County reported that “we used to do a lot of herbicide spraying but we don’t do it anymore” (Twp Supervisor Reno Wells, personal communication). This is probably typical of townships in the CPF boundary.

Per Chris Weir-Koetter of the Minnesota Department of Natural Resources (2008, PR# 139ab) DNR does not do any invasive plant work within the Chippewa NF boundary.

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Private/Corporate: The Burlington Northern-Santa Fe (BNSF) Railroad operates a rail line parallel to US Highway 2. They regularly apply herbicides to approximately 250 acres of railway, material piles, sidings, crossings, communications facilities and fixtures within the CPF proclaimed boundary (PR#251, 252). Vegetation is managed using herbicides including fluroxypur, aminopyralid, metsulfuron methyl, picloram, diuron, glyphosate, and imazapyr, plus wetting, water conditioning and drift control agents.

Numerous homes and farms lie inside the CPF boundary. Herbicides are likely used on many of these properties. We were unable to determine the extent of herbicide use on private lands other than the BNSF railway.

In Minnesota, power line rights of way are routinely treated with herbicide to control brush. Based on personal communications between the CPF Supervisors' Office and Leech Lake Band of Ojibwe (Susan Kedzie, DRM Botanist/Invasive Control Coordinator) (PR# 139ab) in 2008, no herbicide application permits for noxious weed control were issued. However, Beltrami Electric did apply herbicides on a ROW. Based on a personal communication with Syver Kolden of Lake Country Power (LCP), no herbicide applications are done on LCP rights of way within the CPF or Leech Lake Reservation boundaries. Lake Country Power maintains over 1,000 miles of right of way in the CPF.

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