United States Noxious Weed Treatment Project Department of Agriculture

Forest Service Final Environmental Impact Statement –

Pacific Volume 1 Southwest Region

Volume 1

R5-MB-167A Modoc National Forest August 2008

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Data Accuracy—The Forest Service uses the most current and complete data available. GIS data and product accuracy may vary. They may be developed from sources of differing accuracy, accurate only at certain scales, based on modeling or interpretation, incomplete while being created revised, etc. Using GIS products for purposes other than those for which they were created may yield inaccurate or misleading results. The Forest Service reserves the right to correct, update, modify, or replace GIS products without notification. For more information, contact:

Modoc National Forest 800 West 12th Street Alturas, California 96101 530-233-8840

If a map contains contours, these contours were generated and filtered using the Digital Elevation Model (DEM) files. Any contours generated from DEMs using a scale of less than 1:100,000 will lead to less reliable results and should only be used for display purposes only.

Printed on recycled paper  August 2008 Modoc National Forest Noxious Weed Treatment Project

Final Environmental Impact Statement

Lassen, Modoc, and Siskiyou Counties, California

Lead Agency: Forest Service, Department of Agriculture

Responsible Official: Stanley G. Sylva, Forest Supervisor, 530-233-8700

Address: Modoc National Forest, 800 West 12th Street, Alturas, CA 96101

For Information Contact: Robert Haggard 530-233-8840

Abstract The Modoc National Forest proposes to reduce, control, or eliminate noxious weeds on 1.6 million acres of National Forest land. The proposed project would treat weed infestations—present and future—on all four Ranger Districts and the South Warner Wilderness. The need for the project is to eradicate, reduce, or slow the spread of invasive, non-native populations of weeds on the Forest. The alternatives analyzed in this final EIS are as follows: Alternative 1: The No-Action Alternative—no change from current management practices. Alternative 2: The Proposed Action—hand-pulling, directed-spray application of herbicides, and combinations of the two methods. Alternative 3: Hand-pulling, no herbicide application, and very limited treatment of rhizomatous weed species. Alternative 4: Alternative 2, plus an Early Detection – Rapid Response strategy. Alternative 5: Use of hand-pulling, limited mechanical treatments, limited and controlled grazing, application of tarps, and no herbicide treatments. Use of an Early Detection – Rapid Response strategy for new sites and new weed species; limited treatment of small infestations of rhizomatous weed species. The Forest would not treat sites with over 50 plants because we cannot insure removal of all roots. Alternative 6: The expanded non-herbicide treatments of Alternative 5, plus limited directed-spray applications of herbicides and herbicide mixtures on no more than 522 of the 6,908 infested acres.

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Summary The Modoc National Forest proposes to reduce, control, or eliminate noxious weed infestations on 6,908 acres at 541 specific locations throughout the forest. The area affected by the proposal includes National Forest System lands managed by the Modoc National Forest (Modoc NF) in Modoc, Lassen, and Siskiyou counties, California. Proposed Action – Alternative 2 The Proposed Action would initiate annual treatments of noxious weeds on a series of infestations ranging from an estimated low of 300 acres per year to a projected high of 1,500 acres per year (depending on annual budgets) scattered throughout the forest. The various methods analyzed under an integrated weed management approach are physical +, cultural, (throughout the EIS physical, mechanical, and cultural treatments are referred to as physical +) and limited use of herbicides. Wilderness and research natural areas would not be treated with herbicides. There would be no aerial application of herbicides by either fixed-wing or rotary aircraft. In addition, there would be no aquatic applications of herbicides. If approved, project operations would begin in 2008 and would continue for the next 5 years, barring any significant environmental changes. The Proposed Action calls for the reduction in noxious weed sites, reduction in the area covered by noxious weeds, or the eradication or control of 14 specific noxious weed species in 541 locations, covering approximately 6,908 acres. The estimated five-year discounted cost for the implementation of Alternative 2 in 2006 dollars is $1,393,760. The total discounted cost for the life of the Alternative is the same, as Alternative 2 is proposed with a five-year life span. These figures are an approximation, and are intended to allow for comparison of the Alternatives. No adjustment was made to allow for the effects of inflation on the cost of implementation, as it occurs in future years. The estimated cost is $243 per acre. Purpose and Need The purpose of this project is to economically implement those portions of the Modoc National Forest Noxious Weed Management Strategy and action plan that call for implementation of a program to reduce, control, or eliminate noxious weed infestations on 6,908 acres at 541 sites for 14 identified weed species. The eradication and control of these plants would meet the need and requirement of the forest to promote the ecosystem health of forested and rangeland habitats by eliminating or reducing noxious weed competition with native forbs and grass species, and ultimately preventing the loss of wildlife habitat. It is important to eradicate and control these plants with minimal disturbance to the soil and native and desirable non-native species to maintain habitat, prevent erosion, and prevent damage to the soil profile. Failure to reduce, control, or eradicate these small infestations at this time would mean the spread of these weeds would continue. The spread of noxious weeds on the Modoc National Forest may lead to noxious weeds out-competing desirable native plant species and thus altering native plant communities. The continued spread of these noxious weed species increases the adverse impacts to humans, wildlife, livestock, and native plant communities. Issues Issues are defined as disputes or disagreements with the Proposed Action based on its anticipated effects. Disputes or disagreements can result from differing perceptions of the existing conditions, or of the anticipated effects of the Proposed Action. These differing perceptions can result from

Summary i Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

different levels of knowledge regarding scientific or factual evidence, or differing interpretations of the same scientific or factual evidence based on perceiver values. The significant issues listed below led the agency to develop Alternatives to the Proposed Action.

Issue 1 The use of herbicides for invasive-weed control may cause health problems for people who are exposed to the herbicides and treated areas. Although federal and state licensing and certification requirements for herbicide use build in strict safety features before use, some people have reservations about the use of these products. While many believe limited use of herbicides does not pose a significant threat to human health, there are those who believe that if an Alternative is selected that authorizes the use of herbicides, there is a potential that health problems could surface.

Issue 2 The proposed application of herbicides for weed control may affect the ability of Native Americans and others to collect plants for traditional uses or medicinal reasons in specific areas. As with issue 1 above, this concern relates to potential human health problems that may be caused with the application of herbicides. In addition, herbicides may kill specific plants that are collected and used for medicinal or traditional purposes.

Issue 3 An Alternative is needed to respond to the need to evaluate an aggressive approach using additional treatment methods and adaptive management for treating more acres annually over a ten-year period to control and eradicate noxious weeds. The Proposed Action is seen as too limited and ineffective.

Issue 4 The proposed application of herbicides for weed control has the potential to harm the physical and biological resources of the forest. The use of herbicides has the potential to adversely affect the soil and water resources and therefore may harm humans, animals, and native plants. Alternatives

Alternative 1 - No Action (current management) This Alternative is required by regulation (Code of Federal Regulations 1502.8). Under current management, the forest is complying with direction in the forest land and resource management plan and the Sierra Nevada Forest Plan Amendment, to complete a noxious weed risk assessment for all planned projects on the forest. The risk assessment assigns an expected risk level to proposed activities and identifies any weed-related actions that need implementation before, during, or after project implementation. The use of herbicides has not been authorized for these weed-related actions. The forest currently has no NEPA decision that encompasses the treatment or containment of all noxious weeds on the forest. Assuming 30 acres of treatment annually, the estimated five-year discounted cost of this Alternative is $135,670. There is no time limit on implementation under this Alternative; therefore, in order to facilitate comparison with the longest term considered under the other Alternatives, ten years was used as to estimate the discounted cost of “full implementation.” The ten-year discounted cost is estimated to be $247,920. Although data about the historical rate of effectiveness was not available, it was ii Summary

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

assumed that physical + treatments would be applied to non-rhizomatous species, with an 80 % estimated rate of effectiveness. Using this assumption, the average cost is approximately $1,183 per acre.

Alternative 2 Alternative 2 is the Proposed Action and is summarized on the previous page.

Alternative 3 This Alternative calls for treating noxious weeds by pulling and grubbing, or planting native species to eliminate the identified noxious weeds at the documented sites. No herbicides are proposed in Alternative 3, and the Alternative was developed in response to issues 1, 2, and 4. This Alternative would treat 5,993 acres at 494 sites using physical methods. The estimated five- year discounted cost for the implementation of Alternative 3 in 2006 dollars is $2,225,190. Because Alternative 3 specified a life of five years, this is also the total discounted cost. Projected costs are highest under this Alternative due to the labor intensity of physical treatments. The estimated cost per effectively treated acre is $418 per acre.

Alternative 4 This Alternative was developed in response to significant issue 3. Alternative 4 builds on the Proposed Action by increasing the treatment periods from a maximum of 5 years to 10 years, with review of the NEPA document every 3 to 5 years to ensure environmental effects are within the range disclosed in this final EIS. In addition, Alternative 4 allows for treatment of expanding populations in current or newly discovered sites through adaptive management. Alternative 4 would treat 6,899 surveyed acres at 536 sites using both herbicidal and physical methods. In addition, under the early detection – rapid response strategy, an additional 200 acres may be treated over the life of the Alternative, with a cap of 100 acres treated in any one year. The estimated five-year discounted cost of Alternative 4 in 2006 dollars is $1,383,010. The total discounted cost of implementing Alternative 4 is $1,987,840. Unlike Alternatives 2 and 3, these costs would be incurred over a period of ten years rather than five. The cost is estimated at $241 per acre.

Alternative 5 Alternative 5 was developed in response to comments on the draft EIS to provide a non-herbicide Alternative that contained additional non-herbicide treatments. This Alternative would be implemented over a 10-year treatment period and provides for treatment of expanding populations of noxious weeds in current or newly discovered sites through early detection - rapid response. Alternative 5 provides several new Physical+ methods, which include clipping (including use of string trimmers), and placing of mulch or tarps, as well as goat grazing as treatments for eradicating or controlling the 14 identified species of noxious weeds. Alternative 5 would treat 380 acres at 541 sites. In addition, under the early detection – rapid response strategy, an additional 200 acres may be treated over the life of the Alternative, with a cap of 100 acres treated in any one year. The estimated five-year discounted cost for the implementation of Alternative 5 in 2006 dollars is $533,420. The total discounted cost of implementing this Alternative is $900,230. No adjustment was made to allow for the effects of inflation on the cost of implementation, as it would occur in future years. These costs would occur over a period of ten years. The average cost per effectively treated acre is $1,159.

Summary iii Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Alternative 6 Alternative 6 was developed to respond to comments that requested a more flexible approach using herbicidal treatment methods, early detection - rapid response techniques, and additional herbicides. This Alternative would be implemented over a 10-year treatment period. The Physical+ methods available in Alternative 5 are also available as treatment methods in this Alternative. Alternative 6 also includes the use of chlorsulfuron and two herbicide tank mixes. Alternative 6 would treat 341 acres at 541 sites. Under this Alternative the three of the largest sites (159-acre common crupina site, 850-acre Dalmatian toadflax site, and a 5,658 acre dyer’s woad site) would only be treated in a limited manner to contain the spread of these sites. In addition, under the early detection – rapid response strategy, an additional 200 acres may be treated over the life of the Alternative with a cap of 100 acres treated in any one year. The estimated five-year discounted cost for the implementation of Alternative 6 in 2006 dollars is $455,200. No adjustment was made to allow for the effects of inflation on the cost of implementation, as it would occur in future years. The total discounted cost of implementing this Alternative is $734,630. The average cost per acre is estimated to be $660.

Environmentally Preferred Alternative The environmentally preferred Alternative is Alternative 6, as it provides a multi-method approach to reduce or eliminate most noxious weed sites, while preventing spread of the three largest sites. Alternatives 2 and 4 include the treatment of large-acreage sites with herbicides and would result in the application of a greater amount of herbicide in the environment than in Alternative 6. Alternatives 3 and 5 (non-herbicide Alternatives) do not provide effective treatment for rhizomatous species, thus allowing for expansion of these noxious weed sites. Summary of Potential Environmental Impacts

Major conclusions Noxious weeds alter the structure, organization, and function of ecological systems (Olson 1999), including soil, plant, and animal relationships (Kurz 1995; Randall 1996). Spotted-knapweed dominance on open timber and grassland communities may be affecting soil properties such as microbial activity, nutrients and moisture, also increasing soil erosion at the site-specific scale. Native plant composition, diversity, species richness, and litter production are also affected. Changes in plant communities from native to non-native species adversely affect wildlife species that depend on open timber and grassland for forage, breeding, and nesting habitat. The health risk to the public is primarily a function of the amount of inadvertent exposure through contact with herbicide-treated vegetation, consumption of herbicide-treated vegetation, or consumption of water that has accidentally been contaminated with herbicides. Whether a person is exposed to treated vegetation is largely a function of the probability of exposure to the treated vegetation within several hours of herbicide application. Potential health risks to workers and the public would be the lowest under Alternative 3. However, the probability of a person coming in contact with treated vegetation within several hours of application is very low, since locations are generally very small, isolated, scattered, and not generally visited by the public. In addition, areas treated with herbicides would be signed to prevent public exposure to herbicide-treated vegetation.

Changes from the Draft EIS All sections have been re-formatted to eliminate duplication; correct errors, spelling, typing, and grammar; and to facilitate reading and navigation within the document. iv Summary

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Since the publication of the draft environmental impact statement for the noxious weed project, the geographical information system (GIS) data have been updated in 2005; therefore, there would be differences in the information provided between the draft EIS and the final EIS and its supporting documentation with respect to noxious weed and environmental effects analysis. Exact acreages were used from the GIS runs, but they were for tracking purposes and not to connote any undue accuracy in the values. As a result of public comment, the number of noxious weeds in the analysis dropped from 15 to 14. This was in response to a comment by the California Department of Food and Agriculture that wavyleaf thistle had been incorrectly classified on the forest. The number of acres changed due to several factors:  Adding sites identified during the development of the draft EIS  Removing sites within the forest boundary, but located on private lands (these sites and acres are used for cumulative effects analysis, but are not part of the Proposed Action or Alternatives)  Removing sites that were duplicated In the Proposed Action (Alternative 2), 5 sites of rhizomatous species were not considered for treatment because they are within 10 feet of the High Water Mark, and physical methods are not as effective at treating rhizomatous species. Also, 15 sites of rhizomatous species that have some acreage within 10 feet of the High Water Mark would receive partial treatment. On these 15 sites, the acreage within 10 feet of the High Water Mark would not be treated, and the acreage that is further than 10 feet of the High Water Mark would be treated with aquatic glyphosate. Volume 1: Final Environmental Impact Statement

Chapter 1: Proposed Action and Purpose and Need Chapter 1 has been rewritten to remove information that belonged in, or is found in, in other chapters or the appendices.

Chapter 2: Alternative Descriptions  Chapter 2 has been rewritten for ease of understanding and comparison. The range of herbicide application rates in Alternatives 2 and 4 were corrected for clopyralid, glyphosate, dicamba, and triclopyr.  Early Detection - Rapid Response (Formerly Adaptive Management): The need for the Forest Service to respond rapidly to new infestations and improve effectiveness was described in the draft EIS through Early Detection - Rapid Response. Discussion of Early Detection - Rapid Response was moved from the index, and other parts of the draft EIS were brought forward and consolidated in Chapter 2. The early detection – adaptive management has been clarified in the final EIS as the Early Detection-Rapid Response strategy in chapter 2, and does not vary significantly between Alternatives 4 through 6. (Alternative 5 does not provide for any herbicide use).  Treatment methods and descriptions of Alternatives were made in response to public comments: o Hexazinone was dropped from the analysis, as it is a pre-emergent herbicide, and the EIS calls for using only post-emergent, directed-spray applications (Alternatives 2, 4, and 6).

Summary v Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

o Chlorsulfuron was added to Alternative 6, due to comments from state and local government agencies requesting use of a widely used herbicide that is more effective and less toxic. Chlorsulfuron is a herbicide commonly used by state and local agencies for noxious weed control. It provides effective control of several noxious weeds found on the Modoc National Forest. Some benefits cited for including chlorsulfuron were (1) selectivity to target broadleaf weeds with good safety on most perennial grass species, (2) superior control of perennial pepperweed, (3) low use rates compared to most other herbicides, and (4) low toxicity to applicators and wildlife. o Two herbicide mixtures were added for analysis as a result of local government agencies’ requests to provide a more effective herbicide treatment, while applying less active ingredient per acre (Alternative 6).  Use of herbicides to treat noxious weed sites within wilderness areas was dropped. No noxious weed sites are located in the South Warner Wilderness. If herbicides are needed in the future a separate environmental analysis will be completed. This FEIS does analyze the effects of hand treatment of future noxious weed sites within the South Warner Wilderness in all action Alternatives.  Physical+ and goat grazing methods were added as potential treatments to the analysis. Summaries of treatment method effectiveness and brief descriptions of the noxious weeds were included in this chapter (Alternatives 5 and 6).  Implementation and treatment protocols are better described in chapter 2, by Alternative.  A table comparing Alternatives by differences in Design Standards is provided.

Chapter 3: Affected Environment and Environmental Consequences  The draft EIS, chapters 3 and 4, were combined for easier reading and understanding.  Consultation and Coordination: Consultation and coordination describes the process from publication of the draft EIS to publication of the final EIS. Volume 2: Index – Part 1  Appendix A: Modoc National Forest Integrated Weed Management Strategy - 2005  Appendix B: Site-Specific Information  Appendix C: Spill and Safety Management  Appendix D: Best Management Practices - Design Standards moved to chapter 2.  Appendix E: Herbicide information was published in the draft EIS. Appendix E of the draft EIS consisted of a copy of information available on the Internet, and was not republished in this FEIS to reduce costs. Summary information is found in the final EIS.  Appendix F: Risk Assessment was revised and updated.  Appendix G: Weed Species Information  Appendix H: Monitoring

vi Summary

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

 Appendix I: Appendix I now discusses the project record. Adaptive management descriptions were moved to chapter 2 and discussed as early detection – rapid response in the final EIS. At the request of several of those who commented on the draft EIS, the following Appendix items were added to display items from the project record.  Appendix J: Noxious Weed Risk Assessment  Appendix K: Vegetation Information  Appendix L: Example Participating Agreement  Appendix M: Information on the Forest GIS Database and GIS Analysis Tools Used In Conducting the Analysis for This Final EIS  Appendix N: A Map of the Special-Interest Area to Ft. Bidwell Indian Community Council for Treating Noxious Weeds with Herbicides  Appendix O: Rangelands Specialist Report  Appendix P: Social and Economic Specialist Report  Appendix Q: Civil Rights Impact Analysis  Appendix R: Tribal Specialist Report Volume 2: Index – Part 2  Appendix S: Botany Specialist Reports  Appendix T: Watershed and Soils Specialist Report  Appendix U: Aquatic Wildlife Species Reports  Appendix V: Terrestrial Wildlife Species Reports  Appendix W: Terrestrial Invertebrates Species Report  Appendix X: Heritage Resources Volume 3: Response to Comments on the Draft EIS Volume 4: Map Book

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table of Contents SUMMARY ...... i PROPOSED ACTION – ALTERNATIVE 2 ...... i PURPOSE AND NEED...... i ISSUES...... i

ISSUE 1 ...... ii ISSUE 2 ...... ii ISSUE 3 ...... ii ISSUE 4 ...... ii ALTERNATIVES ...... ii ALTERNATIVE 1 - NO ACTION (CURRENT MANAGEMENT)...... ii ALTERNATIVE 2...... iii ALTERNATIVE 3...... iii ALTERNATIVE 4...... iii ALTERNATIVE 5...... iii ALTERNATIVE 6...... iv ENVIRONMENTALLY PREFERRED ALTERNATIVE ...... iv SUMMARY OF POTENTIAL ENVIRONMENTAL IMPACTS ...... iv MAJOR CONCLUSIONS...... iv CHANGES FROM THE DRAFT EIS ...... iv TABLE OF CONTENTS...... ix Tables ...... xiv Figures...... xvi CHAPTER 1: PURPOSE OF AND NEED FOR ACTION ...... 1 DOCUMENT STRUCTURE...... 1 Volume 1 - Final Environmental Impact Statement...... 1 Volume 2 - Appendices ...... 1 Volume 3 - Response to Comment ...... 2 Volume 4 - Maps...... 2 BACKGROUND...... 2 PURPOSE OF AND NEED FOR ACTION...... 5 PROPOSED ACTION ...... 5 TREATMENT METHODS...... 8 DECISION FRAMEWORK ...... 10 FOREST PLAN DIRECTION ...... 10 INTEGRATED WEED MANAGEMENT...... 11 PUBLIC INVOLVEMENT ...... 11 SCOPING ...... 11 COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT...... 13 CONTENT ANALYSIS PROCESS...... 14 RESPONSE TO COMMENTS...... 14 TRIBAL CONSULTATION...... 15 ISSUES...... 18

Table of Contents ix Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

SCOPING ISSUES...... 18 CHAPTER 2: DESCRIPTION AND COMPARISON OF ALTERNATIVES...... 21 INTRODUCTION ...... 21 CHANGES FROM DEIS...... 21 ELEMENTS COMMON TO UNDERSTANDING ALTERNATIVES ...... 22 WEED SPECIES TO BE TREATED ...... 22 WEED SPECIES INFORMATION...... 24 WEED TREATMENT METHODS FOR SELECTED NOXIOUS WEEDS ...... 24 HERBICIDE TREATMENT METHODS PROPOSED FOR USE ...... 32 EARLY DETECTION – RAPID RESPONSE STRATEGY...... 37 NOXIOUS WEED SITE RE-TREATMENTS ...... 38 ALTERNATIVES CONSIDERED ...... 39 DESIGN STANDARDS FOR ALTERNATIVES ...... 39 ALTERNATIVE 1: NO ACTION (CURRENT MANAGEMENT)...... 43 ALTERNATIVE 2: PROPOSED ACTION ...... 44 ALTERNATIVE 3 ...... 51 ALTERNATIVE 4 ...... 52 ALTERNATIVE 5 ...... 59 ALTERNATIVE 6 ...... 61 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED STUDY...... 71 COMPARISON OF ALTERNATIVES...... 74 CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES...... 83 CHANGES FROM DEIS...... 83 GENERAL SETTING...... 83 EFFECTS ANALYSIS...... 85 BEST AVAILABLE SCIENCE ...... 85 VALUES VS. SCIENCE ...... 86 DIRECT AND INDIRECT EFFECTS ...... 86 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES ...... 86 SHORT-TERM AND LONG-TERM EFFECTS ...... 86 Cumulative Effects ...... 86 Other Federal Lands in California ...... 92 Other Federal Lands within Oregon...... 93 Tribal Lands...... 93 State and Private Lands...... 93 AIR QUALITY ...... 95 FIRE AND PRESCRIBED-FIRE MANAGEMENT...... 97 SOILS AND WATER...... 99 Analysis Area ...... 99 Regulatory Framework...... 99 Methodology for Analysis ...... 100 AFFECTED ENVIRONMENT FOR SOIL AND WATER RESOURCES ...... 101 Climate...... 101 Geology...... 102 Soils ...... 102 Water Resources ...... 107 DESIGN STANDARDS AND MONITORING ...... 118 Design Standards...... 118 x Table of Contents

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Monitoring...... 125 ENVIRONMENTAL CONSEQUENCES ...... 126 Explanation of Proposed Action and other Action Alternatives ...... 126 Effects on Soil and Water Resources ...... 129 Effects to Soils ...... 129 Water ...... 134 Comparison of Alternatives ...... 139 EFFECTS TO WATER RESOURCES ...... 142 Alternative 1 ...... 142 Alternative 2 ...... 142 Alternative 3 ...... 147 Alternative 4 ...... 148 Alternative 5 ...... 148 Alternative 6 ...... 148 Site-specific Analysis ...... 149 Cumulative Watershed Effects...... 153 Discussion of Cumulative Effects ...... 157 HERITAGE RESOURCES...... 159 HUMAN HEALTH AND SAFETY...... 161 HAND METHODS...... 161 HUMAN HEALTH AND SAFETY OF HERBICIDE USE ...... 163 HERBICIDE USE - DIRECT AND INDIRECT EFFECTS ...... 168 NOXIOUS WEEDS...... 187 RANGELANDS...... 193 RECREATION...... 196 SPECIAL DESIGNATED AREAS...... 199 Inventoried Roadless Areas ...... 199 Wilderness ...... 202 Research Natural Areas (RNA) and Special-Interest Areas (SIA)...... 203 Wild and Scenic Rivers...... 204 SOCIAL AND ECONOMIC EFFECTS ANALYSIS ...... 204 ENVIRONMENTAL JUSTICE...... 232 TRIBAL AND AMERICAN INDIAN USES ...... 234 INTRODUCTION ...... 234 EXISTING CONDITIONS ...... 235 DIRECT AND INDIRECT EFFECTS ...... 236 Under the No-Action Alternative...... 236 Alternatives 2, 4, and 6 (Herbicide Use) ...... 236 Alternative 3 (Non-Herbicide Use)...... 237 Alternative 5 (Non-Herbicide Use)...... 237 CUMULATIVE EFFECTS ...... 237 Fuels and Prescribed Fire...... 237 Range Management...... 237 Recreation...... 237 Reforestation...... 238 Roads Administration ...... 238 Timber Administration and Vegetation Treatments...... 238 Special Uses...... 238 Previous Noxious Weed and Adjacent Treatments ...... 238 Sagebrush Steppe Ecosystem Restoration Project (SSERP)...... 238 VEGETATED COMMUNITIES...... 239

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PLANT COMMUNITIES ...... 239 Direct and Indirect Effects...... 240 Cumulative Effects ...... 242 FEDERALLY LISTED AND WATCH LIST, AND PLANT SPECIES...... 245 Federally Listed Plant Species...... 245 Sensitive Plant Species...... 246 Watch List Plant Species...... 253 WILDLIFE AND FISH...... 254 FISH AND AQUATIC WILDLIFE SPECIES...... 256 Effects of Alternatives on the Lost River, Shortnose, and Modoc Suckers...... 259 Consultation to Date...... 264 DETERMINATION FOR FEDERALLY LISTED SPECIES ...... 264 FOREST SERVICE SENSITIVE FISH AND AQUATIC WILDLIFE SPECIES ...... 264 EFFECTS OF THE ALTERNATIVES ON SENSITIVE FISH AND AQUATIC SPECIES ...... 267 DETERMINATIONS OF EFFECTS ON SENSITIVE FISH AND AQUATIC SPECIES ...... 271 FOREST SERVICE AQUATIC MANAGEMENT INDICATOR SPECIES...... 271 Direction Regarding the Analysis of Project-Level Effects on MIS...... 272 Direction Regarding Monitoring of MIS Population and Habitat Trends at the Forest and Bioregional Scales ...... 272 Habitat Status and Trend...... 273 Population Status and Trend ...... 273 SELECTION OF LEVEL FISHERIES AND AQUATIC MIS...... 274 Forest Plan Monitoring Requirements for Fish and Aquatic MIS...... 274 Methodologies for MIS Monitoring ...... 275 Effects of Proposed Action on Selected Fisheries and Aquatic MIS...... 277 Goose Lake Redband Trout ...... 284 Rainbow Trout, Brown Trout, and Largemouth Bass ...... 287 TERRESTRIAL WILDLIFE SPECIES...... 291 CURRENT WILDLIFE MANAGEMENT DIRECTION...... 291 WILDLIFE RISK ASSESSMENT METHODS AND DEFINITIONS ...... 293 Federally Listed Terrestrial Wildlife Species ...... 294 CONSULTATION TO DATE...... 295 FEDERALLY LISTED THREATENED AND ENDANGERED WILDLIFE SPECIES ...... 295 T&E SPECIES (BALD EAGLE) DETERMINATION ...... 302 SENSITIVE TERRESTRIAL WILDLIFE SPECIES...... 302 REGION 5 SENSITIVE SPECIES ...... 302 California Spotted Owl ...... 302 California Wolverine and Sierra Nevada Red Fox ...... 304 Great Gray Owl ...... 308 Pallid and Townsend’s Big-eared Bats...... 310 INTRODUCTION TO MANAGEMENT INDICATOR SPECIES...... 315 REGION 5 SENSITIVE SPECIES THAT ARE ALSO MODOC NF MANAGEMENT INDICATOR SPECIES...... 317 American Marten ...... 317 Greater Sandhill Crane...... 322 Northern Goshawk...... 328 Sage Grouse...... 332 Swainson’s Hawk...... 338 Willow Flycatcher...... 343 SUMMARY OF SENSITIVE SPECIES DETERMINATIONS...... 347 MODOC NF MANAGEMENT INDICATOR SPECIES...... 347 Blue Grouse (now known as Sooty Grouse)...... 347 Canada Goose and Mallard...... 351 Golden Eagle and Prairie Falcon...... 355 Hairy Woodpecker ...... 359 Mule Deer and Pronghorn...... 364 xii Table of Contents

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Osprey ...... 370 Red-breasted and Red-naped Sapsuckers...... 373 Western Gray Squirrel...... 378 Yellow Warbler...... 381 TERRESTRIAL INVERTEBRATES ...... 384 FINDINGS ...... 387 SHORT-TERM USES AND LONG-TERM PRODUCTIVITY ...... 387 UNAVOIDABLE ADVERSE EFFECTS ...... 387 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES ...... 387 LEGAL AND REGULATORY COMPLIANCE ...... 387 CONSULTATION AND COORDINATION...... 394 PREPARERS ...... 394 CONTRIBUTORS ...... 399 DISTRIBUTION OF THE ENVIRONMENTAL IMPACT STATEMENT...... 400 GLOSSARY...... 405 ACRONYMS...... 405 DEFINITIONS ...... 409 LITERATURE CITED...... 423 INDEX...... 453

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Tables Table 1 - 1. Summary of the Known Infestation Sites by Species on Forest Service Lands (Reflects GIS Database on September 2, 2005) ...... 8 Table 1 - 2. Origin of Comment Letters...... 14 Table 1 - 3. Tribal Consultation Log ...... 16 Table 2 - 1. Noxious Weeds of Modoc County...... 22 Table 2 - 2. Descriptions of Treatment Methods Included in One or More Alternatives ...... 25 Table 2 - 3. Effectiveness of All Methods Considered for Treatment of Noxious Weed Species ...... 27 Table 2 - 4. Design Standards for Alternatives 2 through 6...... 39 Table 2 - 5. Alternative 2 Site-Specific Treatment Information ...... 45 Table 2 - 6. Alternative 3 Site-Specific Treatment Information ...... 51 Table 2 - 7. Alternative 4 Site-Specific Treatment Information ...... 54 Table 2 - 8. Alternative 5 Site-Specific Treatment Information ...... 60 Table 2 - 9. Alternative 6 Site-Specific Treatment Information ...... 63 Table 2 - 10. Treatment Methods Eliminated from Consideration ...... 71 Table 2 - 11. Comparison of Treatment Methods by Number of Sites and Acres ...... 74 Table 2 - 12. Comparison of Extent of Weed Treatments (Full, Partial, Limited, No Treatment)...... 75 Table 2 - 13. Comparison of Treatment Priorities...... 76 Table 2 - 14. Comparison of Herbicides and Application Rates for Alternatives 2, 4, and 6 ...... 77 Table 2 - 15. Total Herbicide Application for Alternatives that Utilize Herbicide Treatments...... 79 Table 2 - 16. Contribution to Total Herbicide Application in Modoc County for Alternatives that Utilize Herbicides ...... 79 Table 2 - 17. Comparison of Cost (in 2006 dollars)...... 80 Table 2 - 18. Comparison of Environmental Impacts and Significant Issues...... 81 Table 3 – 1a. Present and Reasonably Foreseeable Actions ...... 93 Table 3 – 1b. Present and Reasonably Foreseeable Timber Sales FY07 – FY09 ...... 95 Table 3 – 1c. Reasonably Foreseeable Timber Harvest Actions ...... 95 Table 3 - 2. Occurences of Noxious Weeds within Prescribed Fire Underburning Projects ...... 97 Table 3 - 3. Summary of map units and soil families on the Modoc National Forest...... 104 Table 3 - 4. Range of size in invasive plant sites within the Modoc National Forest Boundaries ...... 105 Table 3 - 5. Result of Water-Quality Monitoring on the Pit River (Lebeouf 2005)...... 111 Table 3 – 6. Documented Invasive Plant Acres Within RCAs on the Modoc National Forest ...... 112 Table 3 - 7. Documented Invasive Plant Acres Within CARs on the Modoc National Forest ...... 113 Table 3 - 8. Acres Infested by Invasive Plants for Whole 5th-Field Watersheds ...... 115 Table 3 - 9. Acres Infested by Invasive Plants for National Forest System Land by 5th-Field Watersheds 116 Table 3 - 10. Documented Invasive Plant Acres Within Lake, Spring, or Wet Meadow RCAs ...... 117 Table 3 - 11. Design Standards Pertinent to Soil or Water Resources Under Alternatives 2 and 4 ...... 119 Table 3 - 12. Design Standards Pertinent to Soil or Water Resources Under Alternatives 3 and 5 ...... 120 Table 3 - 13. Design Standards Pertinent to Soil or Water Resources Under Alternative 6 ...... 121 Table 3 - 14. Summary of Distances from High Water Mark for Herbicide Use...... 124 Table 3 – 15. Summary Comparison of Alternatives...... 125 Table 3 – 15a. Herbicide Properties Compiled from the Region 6 Invasive Plant FEIS (USDA Forest Service 2005b), SERA Risk Assessments and The Nature Conservancy Weed Manual (Tu et al. 2003) ...... 135 Table 3 - 16. Herbicide and Application Rates with Peak Water Concentrations Generated in SERA Worksheets (worksheets can be found in the project record) ...... 137 Table 3 - 17. Larger Invasive Sites on the Forest...... 144 Table 3 - 18. GLEAMS-Driver Model Results with Site-Specific Climate and Acre Data...... 146 Table 3 - 19. GLEAMS-Driver Model Parameters and Results ...... 150 Table 3 – 20. Acres of Infestations Within 100 Feet of Streams, Lakes, Springs or Meadows, by 6th-Field Watershed...... 150 Table 3 – 21. Noxious Weed Sites and Infested Acres Within RCAs of the Lahonton Water Board ...... 152 Table 3 - 22. Previous Treatments of Noxious Weeds Using Herbicides, Modoc National Forest ...... 154 Table 3 - 23. Herbicides Proposed for Use in the Western Area Power Administration Project...... 157 Table 3 - 25. Herbicide and Nonylphenol Polyethoxylate Application Rates to be Used to Treat Noxious Weeds, Including the Incidental Rate of Application of the Impurity Hexachlorobenzene ...... 169 Table 3 - 26. Short-Term Water Contamination Rates (WCR) of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity (In Mg/L Per Lb Applied)...... 171 Table 3 - 27. Longer-Term Water Contamination Rates (WCR) of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity (In Mg/L Per Lb Applied)...... 171 Table 3 - 28. Reference Doses (Rfd) in Mg/Kg/Day Of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity ...... 172 Table 3 - 29. Hazard Quotients (Non-Cancer) for Backpack Applicators – General (Non-Accidental) xiv Table of Contents

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Exposures of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity...... 173 Table 3 - 30. Hazard Quotients (Non-Cancer) for Boom Spray Applicators – General (Non-Accidental) Exposures of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity...... 174 Table 3 - 31. Hazard Quotients (Non-Cancer) for Backpack Applicators – Accidental/Incidental Exposures with Typical Application Rate of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity...... 175 Table 3 - 32. Hazard Quotients (Non-Cancer) for Backpack Applicators – Accidental/Incidental Exposures with Upper Application Rate of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity...... 175 Table 3 - 33. Hazard Quotient (Non-Cancer) for the Public – Direct-Spray Scenarios of Using Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity ...... 176 Table 3 - 34. Hazard Quotient (Non-Cancer) for the Public – Direct Spray Scenarios of Using Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity ...... 177 Table 3 - 35. Hazard Quotient (Non-Cancer) for the Public – Contaminated Fruit While Using Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity ...... 177 Table 3 - 36. Hazard Quotient (Non-Cancer) for the Public – Drinking Contaminated Water from Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity ...... 178 Table 3 - 37. Hazard Quotient (Non-Cancer) for the Public – Consumption of Contaminated Fish, Acute Exposure, as a Result of Using Herbicides, Nonylphenol Polyethoxylate, and Products Containing the Hexachlorobenzene Impurity ...... 179 Table 3 - 38. Hazard Quotient (Non-Cancer) for the Public – Consumption of Contaminated Fish, Chronic Exposure, as a Result of Using Herbicides, Nonylphenol Polyethoxylate, and Products Containing the Hexachlorobenzene Impurity ...... 180 Table 3 - 39. Weeds of Modoc County...... 187 Table 3 - 40. Previous Treatment of Invasive Species Through Use of Physical + Methods ...... 188 Table 3 - 41. Previous Treatment of Noxious Weeds on the Modoc NF Through Use of Herbicides...... 188 Table 3 - 42. Noxious Weed Infestations within 1/8 Mile of a Campground...... 197 Table 3 - 43. Inventoried Roadless Areas Containing Noxious Weed Infestation Sites ...... 200 Table 3 - 44. Racial and Ethnic Diversity (2000 Census)...... 205 Table 3 - 45. Poverty Status (2000 Census) ...... 206 Table 3 - 46. Employment (2004) ...... 206 Table 3 - 47. Farms with Grazing Permits, Modoc County...... 209 Table 3 - 48. Traditional Cultural Properties and Gathering Areas and Associated Weed Sites...... 211 Table 3 - 49. Alternative 1 Estimated Costs (2006 dollars) ...... 213 Table 3 - 50. Alternative 1 Estimated Job and Income Impacts ...... 213 Table 3 - 51. Alternative 2 Treatment Methods...... 215 Table 3 - 52. Alternative 2 Estimated Treatment Costs (2006 dollars)...... 219 Table 3 - 53. Alternative 2 Estimated Job and Income Impacts ...... 219 Table 3 - 54. Alternative 3 Treatment Methods...... 220 Table 3 - 55. Alternative 3 Estimated Treatment Costs...... 222 Table 3 - 56. Alternative 3 Estimated Job and Income Impacts ...... 222 Table 3 - 57. Alternative 4 Treatment Methods...... 223 Table 3 - 58. Alternative 4 Estimated Treatment Costs (2006 dollars)...... 225 Table 3 - 59. Alternative 4 Estimated Job and Income Impacts ...... 225 Table 3 - 60. Alternative 5 Treatment Methods...... 226 Table 3 - 61. Alternative 5 Estimated Treatment Costs (2006 dollars)...... 227 Table 3 - 62. Alternative 5 Estimated Job and Income Impacts ...... 228 Table 3 - 63. Alternative 6 Treatment Methods...... 229 Table 3 - 64. Alternative 6 Estimated Treatment Costs (2006 dollars)...... 230 Table 3 - 65. Alternative 6 Estimated Job and Income Impacts ...... 231 Table 3 - 66. Summary of Effects by Alternative...... 232 Table 3 - 67. Federally Listed Fish Species That Occur on or Downstream of the Modoc National Forest 257 Table 3 - 68. USDA Forest Service Region 5 Sensitive Aquatic Species that occur or have habitat downstream from the Modoc National Forest...... 264 Table 3 - 69. Fisheries/Aquatic Management Indicator Species Selected for Project-Level Analysis for the Noxious Weed Treatment Project, Modoc NF...... 274 Table 3 - 70. Modoc NF Forest Plan MIS Requirements for the Selected Project-Level Fisheries/Aquatic MIS for the Noxious Weed Treatment Project (USDA 2007, as Amended by the SNFPA 2004)...... 275 Table 3 - 71. Federally Listed Species Occurring On or Downstream of the Modoc National Forest ...... 294 Table 3 - 72. Selection of MIS for Project-Level Analysis for the Noxious Weed Treatment Project...... 294 Table 3 - 73. Weed Treatments by Alternative in Occupied Bald Eagle Habitat ...... 297 Table 3 - 74. Bald Eagle Breeding Population Data for California, 1990 - 1999 ...... 298 Table 3 - 75. Status of Bald Eagle Territories as of April 2006 ...... 299 Table 3 - 76. Risk Assessment Values and Hazard Quotient Ratings for Acute Toxicity Levels for the

Table of Contents xv Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Consumption of Contaminated Fish and Contaminated Small Mammals by a Predatory Bird by Chemical. (Acute scenario assumes the consumption of contaminated fish by piscivorous bird after an accidental spill of the pesticide into a pond.) ...... 300 Table 3 - 77. Summary of Approximate Annual Acres of Noxious Weed Treatment, by Jurisdiction ...... 301 Table 3 - 78. Risk Assessment Values and Hazard Quotient Ratings for Acute Toxicity Levels for the Consumption of Contaminated Small Mammals by a Predatory Bird, by Herbicide Rates...... 304 Table 3 - 79. Proposed Treatment Acres within Potential Wolverine and SNRF Habitat ...... 307 Table 3 - 80. Hazard Quotient for Acute Levels for Mammal Eating Contaminated Mammals...... 307 Table 3 - 81. Proposed Treatment Acres within Potential Pallid and Townsend’s Big-eared Bat Habitat .. 312 Table 3 - 82. Hazard Quotient for Acute Levels for Small Mammal Eating Contaminated Insects (100% of the diet) ...... 312 Table 3 - 83. Monitoring Requirements for the MIS on the Forest (USDA 2001 as amended by SNFPA 2004)...... 315 Table 3 - 84. Proposed Treatment Acres within Marten Territories, Modoc National Forest ...... 319 Table 3 - 85. Proposed Treatment Acres within Greater Sandhill Crane Habitat ...... 324 Table 3 - 86. Proposed Treatment Within Occupied and Potential Northern Goshawk Habitat ...... 330 Table 3 - 87. Proposed treatment Within Occupied and Potential Sage Grouse Habitat ...... 335 Table 3 - 88. Herbicides and their Application Rates for Chronic Exposures to Large Birds (goose sized) Consuming Contaminated Vegetation Where There is a no-Spray Buffer and a Boom-Application Method on Site...... 336 Table 3 - 89. Hazard Quotient Ratings for a Small Bird eating Contaminated Insects – Acute Toxicity (100% of diet) ...... 337 Table 3 - 90. Proposed Treatments within Occupied and Potential Swainson’s Hawk Habitat ...... 340 Table 3 - 91. Proposed treatment within Occupied and Potential Willow Flycatcher Habitat ...... 345 Table 3 - 92. Summary of Sensitive-Species Determination ...... 347 Table 3 - 93. Proposed Treatment within Potential Sooty/Blue Grouse Habitat ...... 349 Table 3 - 94. Hazard Quotient Ratings for Acute Toxicity, Small Bird Eating Contaminated Insects (100% of diet) ...... 350 Table 3 - 95. Proposed Treatment Acres within Potential Canada Goose and Mallard Habitat ...... 353 Table 3 - 96. Proposed treatment Within Golden Eagle and Prairie Falcon Habitat...... 357 Table 3 - 97. Proposed Treatment Within Potential Hairy and Pileated Woodpecker Habitat ...... 360 Table 3 - 98. Proposed Treatment Acres Within Potential Mule Deer and Pronghorn Habitat ...... 365 Table 3 - 99. Mule Deer Population Trend for DAUs covering the Eldorado, Lassen, Modoc, Plumas, Sierra, and Stanislaus NFs. 1...... 366 Table 3 - 100. Herbicides and Their Application Rates for Acute Exposures to Large Mammals, Consuming Contaminated Vegetation, Where There is no Spray Buffer and a Boom Application Method...... 367 Table 3 - 101. Herbicides and Their Application Rates for Chronic Exposures (on site) to Large Mammals Consuming Contaminated Vegetation Where There is no Spray Buffer and a Boom Application Method.. 368 Table 3 - 102. Proposed Treatment within Potential Osprey Habitat...... 371 Table 3 - 103. Proposed Treatment within Potential Red-breasted and Red-naped Sapsucker Habitat .... 375 Table 3 - 104. Proposed Treatment within Low-Incidence Potential Gray Squirrel Habitat ...... 379 Table 3 - 105. Proposed Treatment within Potential Yellow Warbler Habitat ...... 382

Figures

Figure 2 - 1. Photographs of Herbicide Application Tools Proposed ...... 32 Figure 2 - 2: Summary of Design Standards for Treatments in Relation to Surface Water 1 ...... 43 Figure 3-1. Location Map of the Modoc National Forest ...... 84 Figure 3-2. Regional Water Quality Control Boards and Their Jurisdictions on the Modoc NF ...... 108

xvi Table of Contents

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Chapter 1: Purpose of and Need for Action Document Structure The Forest Service has prepared this environmental impact statement in compliance with the National Environmental Policy Act (NEPA) and other relevant federal and state laws and regulations. This environmental impact statement discloses the direct, indirect, and cumulative environmental impacts that would result from the Proposed Action and Alternatives. The document is organized into the following: Volume 1 - Final Environmental Impact Statement Chapter 1: Purpose and Need for Action: This chapter briefly describes the Proposed Action, the need for that action, and other purposes to be achieved by the proposal. This section also details how the Forest Service informed the public of the Proposed Action and how the public responded. Chapter 2: Alternatives, Including the Proposed Action: This chapter provides a detailed description of the agency’s Proposed Action, as well as Alternative actions that were developed in response to comments raised by the public during scoping. Chapter 3: Affected Environment and Environmental Consequences: This chapter summarizes the physical, biological, and social and economic environments of the project area, and describes the environmental impacts of the Proposed Action and Alternatives. Consultation and Coordination: This section provides a list of preparers and agencies consulted during the development of the environmental impact statement. Glossary: Definition of terms and acronyms Index: The index provides page numbers by document topic. Volume 2 - Appendices The appendices provide more detailed information to support the analyses presented in the environmental impact statement. Appendix A: Modoc National Forest Integrated Weed Management Strategy - 2005 Appendix B: Site-Specific Information Appendix C: Spill and Safety Management Appendix D: Best Management Practices – Design Standards moved to chapter 2 Appendix E: Herbicide Information was published in the draft EIS. The draft EIS, appendix E, consisted of a copy of information available on the Internet, and was not republished in this final EIS to reduce costs. Summary information is found in the final EIS. Appendix F: Risk Assessment revised and updated. Appendix G: Weed Species Information Appendix H: Monitoring Appendix I: Adaptive Management descriptions moved to chapter 2 and discussed as early detection – rapid response in the final EIS. Appendix I now discusses the project record.

Chapter 1 – Purpose of and Need for Action 1

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Appendix J: Noxious Weed Risk Assessment Appendix K: Vegetation Information Appendix L: Example Participating Agreement Appendix M: Information on the forest GIS Database and GIS analysis tools used in conducting the analysis for this final EIS Appendix N: A map of the special interest area to Ft. Bidwell Indian Community Council for treating noxious weeds with herbicides Appendix O: Rangelands Specialist Report Appendix P: Social and Economic Specialist Report Appendix Q: Civil Rights Impact Analysis Appendix R: Tribal Specialist Report Appendix S: Botany Specialist Reports Appendix T: Watershed and Soils Specialist Report Appendix U: Wildlife Specialist Reports Appendix U: Aquatic Wildlife Species Reports Appendix V: Terrestrial Wildlife Species Reports Appendix W: Terrestrial Invertebrates Species Report Volume 3 - Response to Comment This volume includes Forest Service response to public comments, as well as comment letters received on the draft EIS printed in their entirety. Volume 4 - Maps Additional documentation, including the references and supporting specialist reports, may be found in the project planning record located at the Supervisor’s Office of the Modoc National Forest at 800 West 12th Street, Alturas, California 96101. Background Millions of acres of public lands in the West are rapidly undergoing degradation due to the spread of invasive, non-native plants. Nationwide, the spread of non-native, invasive species into forests and rangelands threaten forest health by displacing native species. The spread of noxious and non-native invasive plant species reduces biological diversity, impacts threatened and endangered species, degrades wildlife habitat, modifies vegetative structure and species composition, changes fire and nutrient cycles, and degrades soil structure. A weed is designated noxious when it is considered by a governmental agency to be injurious to public health, agriculture, recreation, wildlife, or property. Some general characteristics of noxious weeds are their ability to spread rapidly, reproduce in high numbers, and crowd out native plants. Noxious weeds also tend to be very difficult to control. The estimated annual loss of productivity caused by noxious weeds in sixty-four crops grown in the U.S. is $7.4 billion (California Department of Food and Agriculture). Forest Service Manual 2080.5 gives the following definition:

2 Chapter 1—Purpose of and Need for Action

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

…plants designated as noxious weeds by the Secretary of Agriculture or by the responsible state official. Noxious weeds possess one or more of the following characteristics: aggressive and difficult to manage, poisonous, toxic, parasitic, a carrier or host of serious insect or disease, and being non-native or new or not common to the United States…. The state authority for eradication and suppression of noxious weeds in California is derived from the California Food and Agriculture Code. Section 5004 defines noxious weeds as follows: Noxious weed means any species of plant that is, or is liable to be, troublesome, aggressive, intrusive, detrimental, or destructive to agriculture, silviculture, or important native species, and difficult to control or eradicate, which the director, by regulation, designates to be a noxious weed. In determining whether or not a species shall be designated a noxious weed for the purposes of protecting silviculture or important native plant species, the director shall not make that designation if the designation will be detrimental to agriculture. In the last 20 years in California, for example, studies show that yellow starthistle alone has increased from one million to at least 12 million acres - about 12 % of the state's land base (California Department of Food and Agriculture). Current inventories show that yellow starthistle is spreading into Modoc County but is still controllable on the Modoc National Forest, since only 10 sites and about 3 acres are currently found on National Forest System lands. The Forest Service, Bureau of Land Management, and the Federal Interagency Committee for the Management of Noxious and Exotic Weeds have prepared strategies for the management of noxious and noxious weeds. In February 1999, President Clinton issued Executive Order 13112 stressing the importance of addressing the noxious and invasive weed problem and created the Invasive Species Council. Increased public awareness has also prompted changes in noxious weed management in the State of California. Weed management areas (WMAs) cover much of the state, recognizing the need for coordinated management and control of noxious weeds across jurisdictional boundaries. National forests have become active participants in WMAs. The California Department of Food and Agriculture, along with county agricultural commissioners, has increased its efforts to address the state-wide noxious weed problem. Locally, the Modoc National Forest (forest) is an active participant in the county weed-management areas and groups and works cooperatively with the Lassen, Siskiyou, and Modoc county groups. Under the National Forest Management Act and the Forest and Range Renewable Resource Planning Act, forests were given the task of preparing land and resource management plans to establish management direction along with long-range goals and objectives. The increased importance of noxious weed management was recognized in the Sierra Nevada Forest Plan Amendment Record of Decision, published in January 2004. In 1995, the Forest Service revised its national policy on noxious weed management (Forest Service Manual 2080). The policy places stronger emphasis on integrated weed management. It outlines responsibilities for integrated pest management, prevention and control measures, cooperation, and information collection and reporting. The Forest Supervisor responsibilities include goals and objectives identified in the forest land and resource management plan (Forest Plan); maintaining a noxious weed inventory for the forest in accord with Forest Service Manual and Handbook direction; and coordinating with state and county agencies and landowners in prevention, control, containment, and monitoring efforts concerning the management of noxious weeds.

Chapter 1 – Purpose of and Need for Action 3

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

In 1998, the Forest Service, in conjunction with other federal agencies, developed a strategy for the management of noxious weeds. That strategy, entitled “Pulling Together: A National Strategy for Invasive Plant Management”, focused on three primary goals: prevention, control, and restoration. The Forest Service also developed its own national strategy focusing on five areas: prevention and education; control; inventory, mapping, and monitoring; research; and administration and planning. In 2003, Forest Service Chief Dale Bosworth identified four interrelated threats to our ability to protect and restore our forests to healthy conditions. The major threats identified are fuels and fires, invasive species, loss of open space, and unmanaged recreation. In 2007, our current chief, Abigail Kimbell, confirmed that the Forest Service will continue to respond to these major threats. In response to national direction and regional needs, the Modoc National Forest developed the Noxious Weed Management Strategy and Action Plan (2003) in conjunction with the Modoc County Noxious Weed Working Group. The Noxious Weed Management Strategy & Action Plan of 2003 was updated in 2005 as the Integrated Weed Management Strategy, based on work with the working group and comments received during the Noxious Weed Treatment Project draft EIS comment period. Based on the regional and national strategies, the forest strategy stresses actions that (1) promote the management of noxious weeds, prevent the spread of noxious weeds, (2) control noxious weed infestations, and (3) promote noxious-weed management into all Forest Service activities. Per the strategy, noxious weed risk assessments are completed during planning for all site-specific projects on the forest. The risk assessment assigns an expected risk level to proposed activities and identifies any weed-related actions that need implementation before, during, or after project implementation. The use of herbicides has not been authorized for these weed-related actions. The forest currently has no NEPA decision that encompasses the treatment or containment of all noxious weeds on the forest. The Modoc National Forest is implementing the prevention, education, cooperation and coordination, and inventory and monitoring efforts called for in the Integrated Weed Management Strategy. Other local agencies, including the Bureau of Land Management, National Park Service, and the Fish and Wildlife Service, are partners with the Modoc County Weed Abatement Area and have active noxious weed programs on lands they administer. Two federally recognized tribes, the Pit River Tribe and the Fort Bidwell Indian Council, have active noxious-weed eradication programs on trust lands in partnership with the Bureau of Indian Affairs and the Bureau of Land Management. In October 1993, the Modoc National Forest published a notice of intent (NOI) to prepare an environmental impact statement to control approximately 30 acres of noxious weeds annually, beginning in 1994. It targeted 12 noxious weeds using six herbicides (2, 4-D, dicamba, hexazinone, glyphosate, triclopyr, and picloram). Scoping was completed, and the development of the draft EIS continued for several years. The project was eventually dropped due to lack of funds. In April 1998, the Modoc National Forest published a notice of intent to prepare an environmental impact statement to control between 100 and 300 acres of noxious weeds. Treatment was to begin in 1999, treating 15 noxious weed species and using a wider range of herbicides, including aerial application of the large infestations of common crupina. Herbicide treatment also included both spray and granular applications. Scoping and development of the draft EIS continued on this project for several years. In 2002 the forest issued an amended notice of intent to control 15 noxious weed species using five herbicides (2, 4-D, dicamba, hexazinone, glyphosate, and triclopyr) in conjunction with hand pulling, on 100 to 300 acres annually. The amended notice of intent also dropped the use of aerial spraying, restricted herbicide use to specific areas, and dropped the use of granular applications. Scoping for this project was completed in 2001, and the draft EIS was published on December 29, 2004.

4 Chapter 1—Purpose of and Need for Action

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Between July of 1981 and 2002, the forest treated noxious weeds in accordance with an environmental assessment completed in 1981. In 2002, all herbicidal noxious weed treatments and most hand treatments were halted due to the age of the environmental assessment. As described above, in 2003 the forest completed an integrated weed management strategy, and under that strategy limited physical treatment of noxious weeds has been accomplished on site- specific projects. However, to accomplish noxious weed control and eradication across the Modoc National Forest, the forest must complete an environmental analysis. Purpose of and Need for Action Millions of acres of public lands in the West, including lands on the Modoc National Forest, are rapidly undergoing degradation due to the spread of invasive, non-native plants. Nationwide, the spread of non-native, invasive species into forests and rangelands threatens forest health by displacing native species. In 2003, Forest Service Chief Dale Bosworth identified four interrelated threats to our ability to protect and restore our forests to healthy condition: fuels and fires, loss of open space, unmanaged recreation, and invasive species. These four threats are further emphasized in the USDA Forest Service Strategic Plan FY 2007-2012 (Forest Service, USDA FS-880 July 2007). The State of California identifies as noxious weeds those non-native invasive species that threaten our natural and human environment. These noxious weeds threaten public and private lands in numerous ways. The spread of noxious weeds reduces ecosystem diversity and health. A decline in ecosystem diversity, in turn, affects human uses such as agriculture, hunting, fishing, plant gathering, and recreation. The spread of noxious weeds increases the amount of bare soil, resulting in a decline in the watershed condition. It impacts threatened and endangered species by reducing the quality of their habitat, modifies vegetative structure and species composition, changes fire and nutrient cycles, and degrades soil structure. Noxious weeds on National Forest lands can readily spread to surrounding private, state, county, other federal agency, and tribal lands. The Forest has received concerns from adjacent landowners, Native American tribes, and county officials concerning growing infestations on Modoc National Forest lands that could spread to surrounding ownerships. Action is needed because inventories on the National Forest show that noxious weed populations have expanded from a few, small infestations to over 6,000 acres (e.g., dyer’s woad in the area of the Long Damon wildfire area). Studies completed in other parts of the country show that many invasive plants have the ability to replace all native plants within a given area. These species pose a serious threat to ecosystem diversity and have a high potential to harm native plants and wildlife, especially threatened, endangered, and sensitive species. The consequences of continuing to treat noxious weeds under current management on the Modoc National Forest (No-Action Alternative) include:  The Forest would continue treating 20 to 30 acres per year, using only physical methods such as hand pulling and hoeing, and no herbicides.  Ecosystem diversity and health would decline.  Noxious weeds would continue to regenerate and spread within the Forest. New noxious weeds would invade the Forest. As weeds increase, there would be a corresponding increase in weed propagules, such as seeds and rhizomes, which would continue to spread the infestations.  The spread of noxious weeds may lead to noxious weeds out-competing desirable native plant species, thus altering native plant communities and impacting native wildlife populations.

Chapter 1 – Purpose of and Need for Action 5

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

 Noxious weed spread would impact the livestock industry by lowering yield and quality of forage. As noxious weeds spread, the Forest would not meet the following Modoc National Forest Land and Resource Management Plan (Forest Plan) goals:  Maintaining lasting populations of all native and non-native desired vertebrate species (Forest Plan p. 4-1)  Higher populations of threatened and endangered species …and early successional wildlife, and improved fisheries production (Forest Plan p. 4-1)  Improved water quality and riparian areas (Forest Plan p. 4-1)  Improved rangeland condition, with permitted grazing and forage capacity in balance (Forest Plan p. 4-1)  Riparian Areas: Manage lakes, perennial reservoirs, meadows, seeps, wetlands, springs, and Streamside Management Zones (including perennial and seasonally flowing) to maintain or improve riparian-dependent resources (Forest Plan p. 4-3)  Sensitive Plants: Protect habitat for sensitive species necessary for eventual de-listing. (Forest Plan p. 4-3)  Soil: Maintain natural nutrient balance to ensure long-term soil productivity. Restore areas of soil degradation. Enhance soil productivity on selected sites (Forest Plan p. 4-3) In 2005, the Forest completed an Integrated Weed Management Strategy (Forest Service, USDA, Modoc National Forest September 2005), responding to one the four threats articulated by then- Forest Service Chief Dale Bosworth. The Strategy includes an array of goals and objectives for noxious weed prevention and control. Among the key objectives of the Strategy are to:  Determine the distribution of noxious weed species on the Forest through systematic inventories.  Re-inventory at set intervals to determine the rate of spread and detect new weed infestations.  Complete Noxious Weed Treatment EIS to allow the treatment of existing noxious weed sites to control or eradicate noxious weeds.  Conduct early treatment of new infestations. The Purpose and Need of the Noxious Weed Treatment Project is to implement the Forest Plan and meet key objectives of the Forest Weed Management Strategy as follows:  Implement an aggressive inventory and treatment program to reduce, control, or eliminate noxious weed infestations on the Modoc National Forest, including 14 currently identified weed species, on 541 inventoried sites spread over 6,908 acres.  Ensure that noxious weeds are treated with minimal risks to human health.  Ensure that noxious weeds are treated with minimal disturbance to the soil, and native and desirable non-native plants and animals.  Minimize overall costs of noxious weed control and eradication through careful selection of treatment methods.  Minimize overall costs of noxious weed control and eradication by treating small weed infestations, enabling the Forest to avoid the high, sometimes prohibitive costs associated with control and eradication of large infestations.

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

 Provide for aggressive treatment of new infestations of the currently identified 14 noxious weed species, as well as treatment of newly detected species of noxious weeds, allowing for rapid treatment of small infestations. Proposed Action The Proposed Action published in the draft EIS was modified to reflect updated information and information provided through comments on the draft EIS. The site-specific information has been updated to reflect noxious weed infestations on 541 sites (rather than 645), covering approximately 6,908 gross acres1 (rather than 8,835.91) found on Forest Service lands. Of these sites, 520 are proposed for treatment. In the Proposed Action, after implementation of Design Standards, 5 sites of rhizomatous species were not considered for treatment because they are located within 10 feet of water and physical methods are not as effective at treating rhizomatous species. Also, 15 sites of rhizomatous species that have some acreage within 10 feet of water would receive partial treatment. On these 15 sites, the acreage within 10 feet of water would not be treated, and the acreage that is further than 10 feet of water would be treated with aquatic glyphosate. Noxious weed sites are summarized in Table 1-1. The number of species proposed for treatment has been reduced from 15 to 14, to correct errors due to counting non-federal sites, duplication of sites, and misclassification of a plant species (see page v). To meet the Purpose and Need, the Forest Service proposes the following:  To eradicate, or control and contain the occurrences of 14 specific noxious weed species (Table 1-1) from Modoc National Forest lands  To use hand-pulling, directed spray applications of selected herbicides, or a combination of these to treat noxious weeds  To treat between 300 to 1,500 net acres2 annually for the next five years  A total of 520 sites will be fully treated and 16 sites will be partially treated.  To minimizing risk to wildlife and people  To create as little soil disturbance as possible  To minimize risks to desired plant species where noxious weed treatments occur  Retreatment of the treated sites until weeds are eliminated is not counted as new acres treated. The 14 species of noxious weeds identified for treatment through implementation of the Proposed Action occur on approximately 536 sites comprising approximately 6,899 acres, as shown on the enclosed map book. The total number of noxious weed sites on the forest is 541 sites, comprising 6,908.43 acres that are infested with these 14 noxious weeds (Table 1-1).

1 “Gross acres” refers to the site size used for analysis. Noxious-weed inventories use points and polygons to identify sites. In this analysis, all points were counted as a tenth (0.10) of an acre, although they may actually cover less area. Following this logic, an infestation that was identified as 200 acres may actually have noxious weeds covering only 10% of that area, or 20 acres. But the 20 acres would be evaluated at the larger, 200-acre size. For this analysis, effects were analyzed on the gross (200) acres of the site, while the Proposed Action is to treat the net (20) acres.

2 Net acres refer to the actual area covered by a noxious-weed species that would be treated. Using the example in the above footnote would mean treating the 20 acres of the 200-acre site.

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 1 - 1. Summary of the Known Infestation Sites by Species on Forest Service Lands (Reflects GIS Database on September 2, 2005)

Number of Gross Common Name Species Objective Sites Acres eradicate small isolated Canada thistle Cirsium arvense 33 13.09 occurrences and control larger occurrences Common crupina or Crupina vulgaris 1 158.65 contain/control bearded creeper Dalmatian toadflax Linaria dalmatica 12 902.45 contain/control Diffuse knapweed Centaurea diffusa 12 3.77 eradicate Dyer’s woad Isatis tinctoria 64 5,725.29 contain/control Klamathweed or St. Hypericum perforatum 9 2.61 contain/control Johnswort Mediterranean sage Salvia aethiopis 26 8.91 contain/control Musk thistle Carduus nutans 12 9.31 eradicate Plumeless thistle Carduus acanthoides 1 0.09 eradicate eradicate small, isolated Scotch thistle Onopordum acanthium 340 77.22 occurrences and control larger occurrences Centaurea stoebe ssp. Spotted knapweed 14 3.83 eradicate micranthos Squarrose knapweed Centaurea squarrosa 5 0.45 eradicate Tall Whitetop or Perennial Lepidium latifolium 2 0.19 eradicate pepperweed Yellow starthistle Centaurea solstitialis 10 2.57 eradicate Total Sites 541 Total Acres 6,908.43 The Forest Service proposes to authorize annual treatments of weed infestations ranging from an estimated 300 to 1,500 acres annually scattered throughout the Modoc National Forest’s 1.6 million acres (see Figure 3.1). Of the 1.6 million acres, approximately 6,908 acres have been identified as being impacted with these 14 species of noxious weeds. Communities in or next to the forest are Alturas, Adin, Bieber, NuBieber, Lookout, Tulelake, Tionesta, Davis Creek, New Pine Creek, Likely, Fort Bidwell, Lake City, Cedarville, and Eagleville (see map book). The majority of treatments would occur within the ponderosa pine ecosystem and the sage-steppe ecosystem within the Modoc National Forest, as well as along travel corridors (e.g., railroads, Forest Service roads, county roads, and state highways). Major paved roads are state routes 299, 139, and US Highway 395. Many unpaved forest and county roads are found in the project area. These travel corridors serve as a means for spreading and transporting noxious weed seeds. The number of forest roads is the result of past activities, such as timber sales, camping, hunting, and off-road vehicle use. Treatment Methods  Physical treatment – This consists of hand pulling, grubbing, and excavation of plants with a shovel at or just below the soil surface. This treatment is proposed within 10 feet of the High Water Mark on all streams where deemed necessary for resource concerns, or when occurrences are small, consisting of fewer than 100 plants or the site is less than 0.10 acre (sites over 100 plants in areas less than 0.10 acre would likely be treated with

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

herbicides). This treatment may not be appropriate for all noxious species (rhizomatous species, unless small in number, would not be treated using this method). Hand pulling and hoeing are the oldest forms of weed control used by humans. Although they are labor intensive and relatively ineffective for the control of perennial weeds (with exception of the weed wrench on some shrubs such as the brooms), they typically cause minimal environmental impact. When using physical and mechanical (throughout the EIS physical, mechanical, and cultural treatments are referred to as physical +) removal techniques, it is important to minimize soil disturbance around the removed plants. Disturbance can create an ideal site for re-establishment of new seedlings or rapid invasion of another undesirable species (DiTomaso 1997).  Herbicide treatment – Noxious weed sites may be treated with any of the herbicides identified, and would be determined by treatment timing, treatment strategy, or application method. Herbicide treatments are less labor and time intensive than physical + treatments They are most effective on rhizomatous species and larger infestations (Tu et al. 2001).  Combination treatment – Some sites could be treated with a combination of treatments. Since this is a long-term strategy for treatment, increases or reductions of numbers of plants or size of a site may move it from one treatment method to another. For example, after several applications of herbicides a site may have few enough plants to effectively treat it using physical + treatment. Physical + techniques are generally favored against small infestations, or where a large pool of volunteer labor is available. They are often used in combination with other techniques, for example, when shrubs are pulled and cut, and re-sprouts and seedlings are treated with herbicides or fire several weeks or months later (Tu et al. 2001). The annual combination of treatment methods would vary, depending on specific conditions. There would be no applications of herbicides on aquatic species; aquatic species control would be addressed in a separate analysis. However, riparian noxious weeds could be treated using non- chemical means within 10 feet of the stream, and using directed spray applications of glyphosate from 10 feet to the outside edge of the identified Streamside Management Zone. Hand pulling and grubbing, when species appropriate, would be the primary treatment within riparian areas. See Appendix B, Site-Specific Information, for an explanation of how site-specific information was used in this analysis. It also shows how the Forest, in doing its annual work planning, will evaluate, verify, and modify treatments to insure that treatment effects remain within the parameters of the analysis in the FEIS. Infestation sites planned for treatment range in size from single plants on less than 0.10 acre, to occupancy of the species covering the entire acre to occupancy of multiple acres at various levels of infestation. High treatment priority is placed on inventoried sites and pathways of spread from those sites, such as areas adjacent to stream courses and road and trail systems. These sites have great potential for spread, as well as locations within administrative sites (campgrounds, parking lots, trailheads, and river accesses). The Proposed Action would not include aerial spraying of herbicides or treatment of aquatic species or applications of herbicides within 10 feet of live water. The Proposed Action is described in more detail in chapter 2, under Alternative 2.

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Decision Framework This final EIS (FEIS) is not a decision document. It is a document disclosing the environmental consequences of implementing the different Alternatives, including the no-action Alternative. Given the Purpose and Need, the deciding official reviews the Proposed Action, the Alternatives, and their environmental consequences, and decides whether to implement the Proposed Action as described, select a different Alternative, modify an Alternative, or take no action. Factors influencing the decision on selection of an Alternative include (1) how well the Alternative meets the underlying need for action, (2) the potential effects to human health and the environment, and (3) the associated costs. Forest Plan Direction The Proposed Action and Alternatives are guided by the Modoc National Forest Land and Resource Management Plan (Forest Plan), as amended. This project-level analysis is designed to comply with applicable Forest Plan management direction (goals and objectives as well as standards and guidelines). The forest plan does not deal with noxious and invasive weed control to a great extent, since the situation with noxious weeds was considered controllable under the existing environmental documents and agreements with the county to treat weed occurrences.Numerous goals, objectives, standards, and guidelines are found in the forest plan that direct the forest to (1) manage RCAs in satisfactory or better condition, (2) improve wildlife habitat quality as well as protect of key habitat, and (3) maintain or increase soil productivity. The management directions from the forest plan that apply to the project described in this FEIS are primarily those regarding protection and improvement of wildlife habitat, soil and water resources, and riparian habitat. Unchecked invasion of noxious weeds could result in the forest not meeting the following management goals:  “Improved rangeland condition, with permitted grazing and forage capacity in balance” (forest plan, page 4-1)  “Improved water quality and riparian areas ” (forest plan, page 4-1)  “Higher populations of threatened and endangered species …and early successional wildlife, and improved fisheries production” (forest plan, page 4-1)  “Maintaining lasting populations of all native and non-native desired vertebrate species” (forest plan page, 4-1) The invasion of noxious weeds and the treatment to remove noxious weeds may also hinder meeting the following Modoc National Forest Program Goals for  Riparian Areas: “Manage lakes, perennial reservoirs, meadows, seeps, wetlands, springs, and streamside management zones (including perennial and seasonally flowing) to maintain or improve riparian-dependent resources.” (forest plan, page 4-3)  Sensitive Plants: “Protect habitat for sensitive species necessary for eventual de-listing.” (forest plan, page 4-3)  Soil: “Maintain natural nutrient balance to ensure long-term soil productivity. Restore areas of soil degradation. Enhance soil productivity on selected sites.” (forest plan, page 4-3)  Watershed: “Rehabilitate degraded watershed areas impairing water quality.” (forest plan, page 4-4)  Wildlife and Fish: “Maintain or improve in-stream habitat for desired fish. Manage riparian areas to optimize fish habitat or populations. Maintain or exceed habitat quality

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

and quantity necessary for viable populations of sensitive species. Meet habitat or population objectives for management indicator species.” (forest plan, page 4-4). Integrated Weed Management The Proposed Action and Alternatives are also guided by the Modoc National Forest’s Integrated Weed Management Strategy of 2005 (appendix A). The Integrated Weed Management Strategy was developed by compiling existing national and regional direction, policy, programs, and laws into a short operational guide for the Modoc National Forest. It outlines an integrated management approach necessary to prevent, control, and/or eliminate noxious weeds on the Modoc National Forest. The forest strategy uses six emphasis areas to address the goals of controlling and eradicating noxious weeds. They are coordination and cooperation; prevention and education; control and project planning; administration and planning; inventory, mapping, and monitoring; and research. Within each emphasis area, the strategy identifies objectives and action items to carry forward in the forest noxious weed program. The National Environmental Policy Act (42 U.S.C. 4321-4346) and implementing regulations found at 40 CFR parts 1500-1508 (FSM 1950; FSH 1909.15) govern environmental analysis and disclosure requirements conducted by the Forest Service on National Forest System lands for proposed noxious weed control activities, such as ground-disturbing activities, herbicide application, or changes in use of resources. The Modoc National Forest Integrated Weed Management Strategy does not require NEPA analysis; it is an administrative document that synthesizes the various laws, regulations, and policies. Public Involvement

Scoping Scoping is an early and open process for determining the scope of the issues to be addressed, and for identifying the significant issues that are listed beginning on page 17 and related to the Proposed Action (40 CFR 1501.7). Initial scoping began on April 24, 1998. A notice of intent to prepare an environmental impact statement was published in the Federal Register, and the proposal for the treatment of noxious weeds was mailed to concerned citizens, federal and state agencies, and environmental organizations identified within the forest’s NEPA mailing lists. The 1998 Proposed Action called for the herbicide treatment of noxious weeds at a rate of 100 to 300 acres annually on 15 weed species, using 10 different herbicides. Other treatment methods were not proposed. Treatment was generally confined to major transportation and utility corridors, which are the most prone to invasion. A one-time aerial application of herbicides was proposed to treat common crupina that occurred on federal and private lands, to be followed up by ground applications. In March 1998, the California Indian Basket weavers’ Association (CIBA) and the California Department of Pesticide Regulation were contacted to obtain lists of individuals who were weavers. A public meeting was planned to solicit input from weavers. Letters and follow-up phone calls to individual weavers were sent for the public meeting to be held in June 1998. A form was developed for individual weavers to mail in, to indicate their interest in participation of the public meeting. The form was mailed to 36 individual weavers with a pre-addressed envelope enclosed. One form was returned by a person that was unable to attend the meeting and wanted to continue to receive information about the development of the environmental assessment. The public meeting was held to accommodate individuals that failed to reply, but still wanted to attend. The result was no participation.

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

As a result of analysis of all the public comments, the forest revised the Proposed Action. In May 2001, a project update letter was mailed to individuals, groups, and other governmental organizations in which we detailed the process and timeline the agency was going to follow. Comments and recommendations made during previous scoping and tribal consultation were used to revise the 1998 notice of intent. A revision to the 1998 notice of intent (NOI) was published in the Federal Register on November 4, 2002. The 2001 proposal was published in the Federal Register and was sent to interested individuals, groups, agencies, and tribes. It proposed treating 15 weed species, using hand grubbing and pulling, or herbicide applications of six herbicides on up to 1,500 acres annually throughout the national forest. No aerial application of herbicide treatments was to be applied, and only hand treatments were proposed within 10 feet of high-water marks of lakes, streams, and ponds. New mailing lists for individual weavers were requested. The weavers on the CIBA mailing list told the forest of additional weavers that might be interested. Scoping meetings with weavers were held in Alturas, Susanville, and Redding, California and Klamath Falls, Oregon. Scoping letters were sent to new contacts, and the forest sent invitations to the meetings. Nineteen telephone calls were made to coordinate the meetings. Six home visits were made to determine interest. Because many of the weavers of the Klamath Tribes do not belong to the CIBA, the Culture and Heritage Department of the Klamath Tribes suggested an article be placed in the tribal newsletter to invite weavers to the meeting in Oregon. A news article was developed to invite weavers to the public meetings. The forest botanist and the forest tribal relations program manager met with weavers in Chiloquin and Klamath Falls, Oregon. One weaver known to live in Alturas was contacted at home and a meeting was held in the Alturas Supervisor’s Office to identify scoping issues from a weaver’s perspective. Meeting with weavers brought forth concerns related to several topics. Weavers identified the following:  Weavers may suffer health effects due to exposure to herbicides, because raw weaving materials are processed with hands, teeth, and mouth  Consider other weed treatment methods that do not include the use of herbicides  Klamathweed has medicinal value and should not be treated  Biological controls may create other impacts because insects don’t recognize boundaries  Herbicide use near water may impact water quality and increase weaver exposure  Herbicide applicators need to have adequate training and certification in handling and application  Weavers need to know specific locations that herbicides have been or will be applied  Specific locations treated with herbicides should be identified by posting at the site location, at tribal health clinics, tribal EPA offices, libraries, post offices, and Web sites In January 2005, the forest tribal relations program manager made phone calls to individual weavers to arrange distribution of the draft EIS, either through hard copy or compact disk. The Proposed Action reflected in the draft EIS and the two additional Alternatives published in the draft EIS were based on the public comments received between March, 1998 and June, 2001.

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Comments on the Draft Environmental Impact Statement A reproduction of public comment letters and the Modoc National Forest response to each concerning the content of the draft EIS, are published in Volume 3, Response to Comments and Letters. The notice of availability of the draft EIS was published in the Federal Register on December 30, 2004. On that same date, a legal notice was published in The Modoc Record, the newspaper of record for the Modoc National Forest. The public comment period ended 47 days later on Monday, February 14th (the first full working day after the scheduled 45-day comment period). The draft EIS was also published on the Internet on December 15, 2004. During the public comment period, Forest Service representatives were invited to make presentations to the Modoc, Lassen, and Siskiyou county boards of supervisors, the Modoc County Land Use Committee, the Lassen County Weed Group, the Siskiyou County Weed Group, and the Alturas Rotary Club. The Forest received 39 (29 timely) unique responses to the draft EIS request for comments. Twelve of these requests were for further information or copies of the draft EIS. Three substantive comment letters were dated after the close of the comment period. These three letters did not contain comments or information that were not included in the timely responses. Due to the complexity of comments received by several organizations and agencies, individual meetings were held between the Forest Service and representatives of the organizations or agencies to insure the Forest Service correctly understood and responded to the comments received. A meeting was held on March 11, 2005, and attended by representatives of Californians for Alternatives to Toxics, the Salmon River Restoration Council, and the Klamath Forest Alliance. Meetings were held with Modoc County representatives on April 26, 2005. The California Indian Basketweavers declined to meet individually in relation to their comments. As a result of public comments submitted and the clarifying meetings, the Forest Service agreed to develop two additional Alternatives: one analyzing the effects of additional non-herbicidal treatments, and a second adding chlorsulfuron and two herbicide mixtures (2, 4-D and chlorsulfuron; and 2, 4-D and dicamba). After development of the two additional Alternatives, all individuals and agencies that provided substantive comments were invited to a workshop in Redding, California on May 31, 2005 to discuss the Alternatives and development of the final environmental impact statement. In addition to Forest representatives, nine other people were in attendance. They were Don Lancaster – University of California Cooperative Extension for Modoc County, Regina Chichizola – Klamath Forest Alliance and Klamath Siskiyou Wildland Center, Craig Hemphill – Lassen County Department of Agriculture, Dale Albaugh – grazing permittee on the Big Valley Ranger District, Pete Harrison – Californians for Alternatives to Toxic Substances, Sean Curtis – Advisor to the Modoc County Land Use Committee, Wally Preston – Pit River Tribe Atwamsini alternate and cultural representative and XL Ranch Manager, Chris Piroska – Pit River Tribe natural resources director, and Michelle Berditschevsky – Pit River Tribe environmental coordinator. The Forest Service’s Environmental Policy and Procedures Handbook 1909.15-92-1 and 40 CFR 1503.4 give direction on what to do with comments received on a draft EIS. The Forest Service must review, analyze, evaluate, and respond to substantive comments on the draft EIS. All comment letters were reviewed in full by the interdisciplinary team. They are contained in Volume 3, Response to Comments and Letters, together with the Forest’s response.

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Analysis of comments also included tracking the origin of the comments and their form. The mail log (the register of incoming letters and messages) can be found in Volume 2. The analysis is summarized in Table 1-2.

Table 1 - 2. Origin of Comment Letters

Number of Unique Letter Classification Commentors Within California 22 Other States 1 Groups or Organizations 5 Individuals 5 Local Governments 6 State Agencies 2 Federal Agencies 2 Tribal Governments 3 Total 23

Content Analysis Process Content analysis is a method developed by a specialized Forest Service unit, the Content Analysis Team (CAT), for analyzing public comments. This method uses both qualitative and quantitative approaches. It is a systematic process designed to provide a mailing list of respondents and to distinguish specific comments in each response. Responses refer to single, whole submissions from respondents, e.g., letters, e-mails, faxes, presentations at public meetings, etc. Comments refer to identifiable expressions of concern made within responses. The comment analysis process also evaluates similar comments from different responses, and from those identifies specific concerns. The process provides a relational database capable of reporting various types of information, while linking comments to original letters. Through the content analysis process, the interdisciplinary team strives to identify all relevant issues, not just those represented by the majority of respondents. Breadth and depth of comment are important. In addition to capturing relevant factual input, the process identifies the relative strength of public sentiment behind particular viewpoints. The intention is to represent the public’s viewpoints and concerns as fairly as possible, and to present those concerns in such a way as to assist the team in effectively responding to them. Although this analysis attempts to capture the full range of public issues and concerns, it should be used with caution. The respondents are self-selected; therefore, their comments do not necessarily represent the sentiments of the entire population. However, the analysis does attempt to provide fair representation of the wide range of views submitted. In considering these views, it is important for the public to understand that this process makes no attempt to treat input as if it were a vote. In no way do the results of content analysis attempt to sway decision makers toward the will of any identifiable majority. What the content analysis process does is ensure that every comment is considered at some point in the decision process.

Response to Comments The responses to comments by the Modoc National Forest were handled in accordance with 40 CFR 1503.4: An agency preparing a final environmental impact statement shall assess and consider comments both individually and collectively, and shall respond by one or more of the means listed below, stating its response in the final statement. Possible responses are to:

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 Modify Alternatives, including the Proposed Action  Develop and evaluate Alternatives not previously given serious consideration by the agency  Supplement, improve, or modify its analyses  Make factual corrections  Explain why the comments do not warrant further Agency response, citing the sources, authorities, or reasons which support the Agency’s position and, if appropriate, indicate those circumstances which would trigger Agency reappraisal or further response.

Tribal Consultation Three major groups of Indians represented by five federally recognized tribes have cultural interests in the noxious weed-treatment project area. The major groups are the Modoc, the Northern Paiute, and the Pit River Indians (See map, appendix N). They are represented by the Alturas Rancheria, the Cedarville Rancheria, the Ft. Bidwell Paiute Tribe, the Klamath Tribes and the Pit River Tribe. Each of the five tribes is a separate, sovereign government with its own governing body and elected officials. The tribes’ cultural interests are based on ongoing ceremonial and spiritual activities. Some of the interests are based on animal resources and plant gathering for medicinal and contemporary use. They also include archaeological resources and, in some cases, burial sites. The Klamath Tribes have interests in the northern portion of the forest. Their interest area is described as lands ceded by the Modoc Indians in the treaty of 1864. That area is generally north of a line from the Medicine Lake Highlands, east to the southern tip of Goose Lake. The Pit River Tribe has interests based on the 100-mile square described in the Indian Claims Commission, Docket 347, 1959. That area is generally south of that Highlands to Goose Lake line and continues east to the crest of the Warner Mountains. The Warner Mountains are a major north - south divide between the aboriginal territories of two tribal groups. Pit River Indians generally occupy the western portion of the mountains and extend along the Pit River proper. Northern Paiute Indians generally occupy the eastern portion of the mountains and extend into the Great Basin. On the western side of the Warner Mountains are the Alturas Rancheria and the Pit River Tribe. On the eastern side of the Warner Mountains are the Cedarville Rancheria and Ft. Bidwell Paiute Tribe. Additionally, the unrecognized Shasta Tribe, Inc. and the Shasta Nation, Inc. have cultural interests in the project area. Both have interests in the Medicine Lake Highlands. Tribal consultation with the federally recognized tribes began in March, 1998 with preliminary telephone calls to individual tribes (see Table 1-3). Later, formal letters were sent to each tribe and face-to-face consultation meetings were held between Forest Service line officers and tribal officials. Line officers traveled to each tribe’s preferred meeting location. In January 2001, tribal consultation with federally recognized tribes was re-initiated with telephone calls, formal letters, and face-to-face meetings between line officers and tribal officials. Line officers met with tribal officials at the tribal offices of each respective tribe. Telephone calls and letters were sent to unrecognized tribes whose relationship with the forest had begun to develop. In February 2001, the forest botanist and the forest tribal relations program manager traveled to Yreka, California to solicit input from one of the unrecognized tribes. In November 2004, tribal consultation was re-initiated with line officer consultation meetings and staff presentations. In March 2005, formal letters were sent to the three tribes (Alturas Rancheria,

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Ft. Bidwell Indian Community Council, and The Pit River Tribe) that had submitted written comments. Formal meetings were requested to map important locations, clarify issues, develop partnerships, and continue work on the annual work plans and adaptive management. Between November 2004 and November 2006, seventeen meetings were held.

Table 1 - 3. Tribal Consultation Log

Date Tribe Type of Contact Location 1998 tribal fish hatchery in Chiloquin, June 16 The Klamath Tribes culture and heritage department OR Ft. Bidwell tribal community October 24 Ft. Bidwell Paiute Tribe line officer and tribal council building, CA 2000 Cedarville Rancheria Ft. Bidwell Paiute Tribe Klamath Tribes official correspondence requesting December 14 Pit River Tribe consultation meetings. Confederated Bands of Shasta and Upper Klamath River Indians 2001 Quartz Valley Road, Ft. Jones, February 10 The Shasta Tribes staff and tribal council CA Modoc NF Supervisor’s Office, February 13 The Pit River Tribe line officer and tribal council Alturas, CA Ft. Bidwell tribal community March 24 Ft. Bidwell Paiute Tribe line officer and tribal council building, CA tribal community building, March 26 Cedarville Rancheria line officer and tribal council Cedarville, CA tribal fish hatchery in Chiloquin, April 17 The Klamath Tribes culture and heritage department OR 2004 Ft. Bidwell tribal community November 4 Ft. Bidwell Paiute Tribe line officer and tribal council building, CA Alturas Rancheria Cedarville Rancheria official correspondence requesting December 17 Ft. Bidwell Paiute Tribe consultation meetings. Klamath Tribes Pit River Tribe 2005 staff phone call offer to give Ft. Bidwell Paiute Tribe January 24 presentations on draft EIS to solicit Pit River Tribe comments Alturas Rancheria staff phone call offer to give Cedarville Rancheria January 28 presentations on draft EIS to solicit Klamath Tribes comments Pit River Tribe Ft. Bidwell tribal community February 7 Ft. Bidwell Paiute Tribe staff to staff building, CA Modoc NF Supervisor’s Office, March 8 Pit River Tribe quarterly meeting Alturas, CA official correspondence, request for March 10 Ft. Bidwell Paiute Tribe meeting to resolve written comments official correspondence, request for Alturas Rancheria March 31 meeting to resolve written Pit River Tribe comments staff and designated cultural April 6 Alturas Rancheria conference call representative

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Date Tribe Type of Contact Location Pit River Tribe environmental May 5 Pit River Tribe stat to staff meeting office, Burney, CA Ft. Bidwell tribal housing offices, May 14 Ft. Bidwell Paiute Tribe staff to council CA Shasta-Trinity NF Supervisor’s June 1 Pit River Tribe designated representatives Office, Redding, CA Ft. Bidwell tribal community June 10 Ft. Bidwell Paiute Tribe staff and council members building, CA 2006 Modoc NF Supervisor’s Office, March 1 Pit River Tribe quarterly meeting Alturas, CA Ft. Bidwell tribal community April 6 Ft. Bidwell Paiute Tribe line officer and tribal council building, CA Pit River Tribe environmental June 7 Pit River Tribe quarterly meeting office, Burney, CA November 6 Alturas Rancheria staff and cultural representatives field trip

The tribes have expressed concerns about the following:  The location of and population sizes of weeds  Weeds encroaching on tribal lands  Herbicides entering sub-watersheds that provide community drinking water  The forest’s inventorying ethno-botanical resources  Protecting gathering areas from both encroaching weeds and herbicide treatments  Weavers suffering health effects due to exposure from herbicides because raw weaving materials are processed with hands, teeth and mouth  Herbicide use near water, impacting water quality and increasing weaver exposure  Biological controls creating other impacts because insects don’t recognize boundaries  Herbicide applicators having adequate training and certification in handling and application  Riparian heath  Treatment effects to wildlife The Ft. Bidwell Indian Community Council expressed specific concerns about herbicide use within the watershed that provides drinking water for the reservation. A map was developed and consultation was done. The map was redrawn based on the consultation with the tribal council (see appendix N). Through consultation, the Alturas Rancheria identified three individual plant gathering areas that are important to them on National Forest System lands. One gathering area is 184 acres, another is 103 acres, and the last is 80 acres. The combined total area of these sites is 367 acres. Two of the areas do not have weed infestations in or near the gathering areas. Total area for these two non-infested areas is 183 acres. The 184-acre site is infested with Dalmatian toadflax. One infestation is 44.33 acres, and the second is 0.09 acres. A plant gathering area important to the Pit River Tribe was mapped by forest staff, based on ethnographies and staff knowledge of the area. Through consultation with the tribe, the initial boundary was adjusted and a revised map was developed. Total area of the gathering site is 285,351 acres. There are 27 weed sites in the gathering area. Twenty-six weed sites are less than 0.10 acre. One site is 0.16 acre.

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Two federally recognized tribes, the Pit River Tribe and the Fort Bidwell Indian Council, have active noxious-weed eradication programs on trust lands in partnership with the Bureau of Indian Affairs and the Bureau of Land Management. The Pit River Tribe’s program includes physical +, biological and herbicide treatment methods. The Ft. Bidwell Indian Community Council program uses physical + treatments. Issues Issues are defined as disputes or disagreements with the Proposed Action based on its anticipated effects. Disputes or disagreements can result from differing perceptions of the existing conditions, or of the anticipated effects of the Proposed Action. These differing perceptions can result from different levels of knowledge regarding scientific or factual evidence, or differing interpretations of the same scientific or factual evidence based on the perceiver’s values. Comment letters from the public, other agencies, organizations, groups, The Pit River Tribe – Environmental Department, Alturas Rancheria, and the Gidutikad Band of the Northern Paiute Nation, Ft. Bidwell Indian Community were used to formulate issues concerning the Proposed Action. The Forest Service separated the issues into two groups, significant and non-significant. Significant issues were defined as those directly or indirectly caused by implementing the Proposed Action. Non-significant issues were identified as those (1) outside the scope of the Proposed Action; (2) already decided by law, regulation, forest plan, or other higher-level decision; (3) irrelevant to the decision to be made; or (4) conjectural and not supported by scientific or factual evidence. The Council on Environmental Quality (CEQ) NEPA regulations explain this delineation in Sec. 1501.7: “…identify and eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review (Sec. 1506.3)….”

Scoping Issues Scoping of the initial 1998 and the revised 2001 proposals resulted in 64 letters, e-mails, and documented phone conversations. All letters received during 1998 and 2001 scoping were processed and comments placed into one of six categories:  Issues used to drive or partially drive an Alternative  Issues Addressed by Design Standards  Issues addressed in the effects analysis  Issues beyond scope of Purpose and Need  Issue already decided (addressed through law, regulation, and policy)  No issues – request for copies of documents and information This analysis indicated that most of the comments identified were either outside the scope of the Proposed Action, would be a component of the analysis itself, or were addressed by law, regulation, or policy. Based on the assessment of comments, the interdisciplinary team identified four significant issues during development of the draft EIS that were subsequently approved by the responsible officials. Additional specific issues were not identified during the response to comments on the draft EIS. For detailed discussion of the response to comments on the draft EIS, please see volume 3. The Forest Service identified the following significant issues during scoping. Analysis of comments on the draft environmental impact statement did not reveal additional issues.

18 Chapter 1—Purpose of and Need for Action

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Issue 1 The use of herbicides for invasive weed control may cause health problems for people who are exposed to the herbicides and/or treated areas. Although federal and state licensing and certification requirements for herbicide use build in strict safety features before use, some people have reservations about the use of these products. While many believe limited use of herbicides does not pose a significant threat to human health, there are those who believe that, if an Alternative is selected that authorizes the use of herbicides, there is a potential that health problems could surface.

Issue 2 The proposed application of herbicides for weed control may affect the ability of Native Americans and others to collect plants for traditional uses or medicinal reasons in specific areas. As with issue 1 above, this concern relates to potential human health problems that may be caused with the application of herbicides. In addition, herbicides may kill specific plants that are collected in specific areas and used for medical or traditional purposes.

Issue 3 An Alternative is needed to respond to the need to evaluate an aggressive approach using additional treatment methods and adaptive management for treating more acres annually over a ten-year period to control and eradicate noxious weeds. The Proposed Action is seen as too limited and ineffective.

Issue 4 The proposed application of herbicides for weed control has the potential to harm the physical and biological resources of the forest. The use of herbicides has the potential to adversely affect the soil and water resources and therefore may harm humans, animals, and native plants.

Chapter 1 – Purpose of and Need for Action 19

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Chapter 2: Description and Comparison of Alternatives Introduction This chapter describes and compares the Alternatives considered for the Modoc National Forest Noxious Weed Treatment Project. It describes both Alternatives considered in detail and those eliminated from detailed study. The Alternatives are presented in tabular format (Table 2-18) so that the Alternatives and their environmental impacts can be readily compared. Changes from the Draft Environmental Impact Statement (DEIS)

Alternative Descriptions Chapter 2 has been rewritten for ease of understanding and comparison of Alternatives. The range of herbicide application rates in Alternatives 2 and 4 were corrected for clopyralid, glyphosate, dicamba, and triclopyr.

Design Standards  A few of the Design Standards (DS) were rewritten for clarity and to be consistent with herbicide label directions.  Design Standards were added to clarify and bring together direction that was somewhat scattered in the DEIS.  Design Standards were modified or developed in response to suggestions made by the public, other government agencies, or Indian tribes.

Early Detection - Rapid Response The need for the Forest Service to respond rapidly to new infestations and improve effectiveness was described in the DEIS through Early Detection - Rapid Response. Discussion of Early Detection - Rapid Response was moved from the index, and other parts of the DEIS were brought forward and consolidated in Chapter 2. The Early Detection - Rapid Response Strategy has been clarified in Chapter 2 and does not vary between Alternatives 4-6. Alternative 5 does not prescribe any herbicide use.

Treatment Methods and Alternative Descriptions made in response to public comments:  Hexazinone was dropped from the analysis, as it is a pre-emergent herbicide and the FEIS calls for utilizing only post-emergent, directed spray applications.  Chlorsulfuron was added to Alternative 6 due to comments from state and local government agencies requesting utilization of a widely used herbicide that is more effective and less toxic. Chlorsulfuron is an herbicide commonly used by state and local agencies for noxious weed control. It provides effective control of several noxious weeds found on the Modoc National Forest. Some benefits cited for including Chlorsulfuron

Chapter 2 – Alternatives Description 21 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

were: 1) selectivity to target broadleaf weeds with little to no effect on most perennial grass species; 2) superior control of perennial pepperweed; 3) low use rates compared to most other herbicides; and 4) low toxicity to applicators and wildlife.  Two herbicide mixtures were added for analysis as a result of local government agencies requests to provide a more effective herbicide treatment while applying less active ingredient per acre (Alternative 6).  Use of herbicides to treat noxious weed sites within designated wilderness areas was dropped. Updated inventories show no noxious weed sites are currently in the South Warner Wilderness. If herbicides are needed in the future a separate environmental analysis will be completed. This FEIS does analyze the effects of hand treatment of future noxious weed sites within the South Warner Wilderness in all action Alternatives.  Physical+ and goat grazing methods were added as potential treatments to the analysis. Summaries of treatment method effectiveness and brief descriptions of the noxious weeds were included in this chapter (Alternatives 5 and 6).  Implementation and Treatment Protocols are better described in Chapter 2 by Alternative.  A table comparing Alternatives by differences in Design Standards is provided.  Hand-clipping plants or seedpods to prevent seed production as not discussed in the DEIS; however, the impacts are considered in this FEIS in Alternatives 5 and 6 in response to comments received on the DEIS. Elements Common to Understanding Alternatives The following sub-sections provide information that will be useful in understanding noxious weeds species and general information (i.e., not specific to Alternatives) about treatment options.

Weed Species to be Treated Thirty-two different noxious weeds are believed to be present in Modoc County and may occur on the Modoc National Forest (Table 2-1). California Department of Food and Agriculture has developed a rating for noxious weeds. Each pest rating represent’s the Department’s assessment of the statewide risk of the pest to the agricultural, horticultural, forestry and public health interests of California. The ratings are intended as aids for managers to assess a particular pest’s environmental, agricultural and biological significance and control action(s) recommended by the Department. Rating “A” refers to “an organism of known economic importance subject to state (or commissioner when acting as a state agent) enforced action involving: eradication, quarantine regulation, containment, rejection, or other holding action.” There are 14 noxious weed species within Modoc County with a “A” rating. Rating “B” refers to “an organism of known economic importance subject to: eradication, containment, control or other holding action at the discretion of the individual county agricultural commissioner. There are 11 noxious weed species within Modoc County with a “B” rating. Rating “C” refers to “an organism of no state enforced action outside of nurseries except to retard spread” at the discretion of the county agricultural commissioner. There are seven noxious weed species within Modoc County with a “C” rating.

Table 2 - 1. Noxious Weeds of Modoc County

“A” Rated Common Crupina Crupina vulgaris Proposed to be treated Dalmatian toadflax Linaria dalmatica Proposed to be treated

22 Chapter 2—Alternatives Description

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Diffuse knapweed Centaurea diffusa Proposed to be treated Halogeton Halogeton glomeratus Not known to occur on the Modoc NF Leafy spurge Euphorbia esula Not known to occur on the Modoc NF Longleaf ground cherry Physalis longifolia Not known to occur on the Modoc NF Musk thistle Carduus nutans Proposed to be treated Perennial sowthistle Sonchus arvensis Not known to occur on the Modoc NF Plumeless thistle Carduus acanthoides Proposed to be treated Scotch thistle Onopordum acanthium Proposed to be treated Skeletonweed Chondrilla juncea Not known to occur on the Modoc NF Spotted knapweed Centaurea stoebe ssp. micranthos Proposed to be treated Squarrose knapweed Centaurea squarrosa Proposed to be treated Yellowspine thistle Cirsium ochrocentrum Not known to occur on the Modoc NF “B” Rated Austrian fieldcress Rorippa austriaca Not known to occur on the Modoc NF Canada thistle Cirsium arvense Proposed to be treated Dyer's woad Isatis tinctoria Proposed to be treated Globepodded hoarycress Cardaria pubescens Recently detected on the Modoc NF Heart-podded hoarycress Cardaria draba Not known to occur on the Modoc NF Japanese knotweed Polygonum cuspidatum Not known to occur on the Modoc NF Mediterranean sage Salvia aethiopis Proposed to be treated Purple loosestrife Lythrum salicaria Not known to occur on the Modoc NF Quackgrass Agropyron repens Not known to occur on the Modoc NF Russian knapweed Acroptilon repens Recently detected on the Modoc NF Tall whitetop Lepidium latifolium Proposed to be treated “C”Rated Common Russian thistle Salsola tragus Occur at rates beyond control Field bindweed Convolvulus arvensis Occur at rates beyond control Klamathweed Hypericum perforatum Proposed to be treated Medusahead Taeniatherum caput-medusae Occur at rates beyond control Povertyweed Iva axillaris Occur at rates beyond control Puncturevine Tribulus terrestris Not known to occur on the Modoc NF Yellow starthistle Centaurea solstitialis Proposed to be treated

The fourteen species that are proposed to be treated under this FEIS were chosen because their populations are currently at a low enough level where they can be eradicated and/or controlled within the boundaries of the Modoc National Forest. Other than three large sites, their populations are small enough that they can be treated efficiently and effectively; however, if these species are left untreated, their populations could spread so that treatment would be difficult. The three large sites of noxious weed infestations on the Modoc National Forest include 5,658 acre dyer’s woad, 159 acres common crupina and 850 acres Dalmatian toadflax. Treatment of these sites varies by Alternative. All species with a rating of “A” and “B” that are known to occur on the Modoc National Forest are proposed for treatment. Recently, globepodded hoary cress and Russian knapweed were detected on the Forest. Because these sites were recently detected they were not analyzed in this FEIS; however, they could be treated under the Alternatives with Early Detection Rapid Response. Two “C” rated species, yellow starthistle and Klamathweed, are not predominant in the County and are proposed for treatment under this proposal in an attempt to eradicate them from the County. Four “C” rated noxious weed species; common Russian thistle, field bindweed, medusahead and povertyweed, occur at population levels that are currently beyond control within the Modoc National Forest. These species have spread to such an extent that, given the current treatment methods and cost of treatment, it is currently not feasible to treat them. Ten noxious weed species that occur elsewhere within Modoc County are not known to occur within the Modoc National Forest.

Chapter 2 – Alternatives Description 23 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Weed Species Information Detailed descriptions of the 14 noxious weeds were provided in Appendix G of the DEIS. The information contained in Appendix G of the DEIS was from the weed sheets gathered and prepared by staff in the Non-Cropland Weed group of the University of California Cooperative Extension Service, in the Weed Science Program, Department of Vegetable Crops, University of California, Davis, CA 95616 (http://www.cdfa.ca.gov/phpps/ipc/encycloweedia/), and the book Invasive Plants of California’s Wildlands edited by Carla C. Bossard, John M. Randall, and Marc C. Hoshovsky, University of California Press, 2000 (http://groups.ucanr.org/ceppc/Invasive_Plants_of_California's_Wildlands/). Appendix G of the FEIS does not provide the detailed descriptions that were provided in the DEIS. Instead, Appendix G of the FEIS provides numerous links to locations for noxious weed information, including the Internet links above.

Weed Treatment Methods for Selected Noxious Weeds Weed eradication, control, and containment can be accomplished by several methods. The methods vary in cost and effectiveness. The Alternatives considered in this FEIS vary by treatment methods in response to public comments and the need to develop effective and economical treatment methods. This FEIS does not consider using biological methods or prescribed fire. Limited grazing and mechanical methods are considered. This FEIS primarily relies on hand-pulling, digging, and herbicide treatment methods. Table 2-2 describes the treatment methods that are included in one or more of the Alternatives. Table 2 -3 describes the effectiveness of weed treatment methods by noxious weed species. Of the treatments proposed, consideration of herbicides brought the most attention in comments on the DEIS. In response to these comments, the Forest added two Alternatives, clarified the Design Standards, and expanded the effects analysis in the FEIS. The purpose of this expanded analysis is not to emphasize treatment with herbicides; it is to provide a broad base of reasonable treatment methods and thorough analysis from which both the agency and the public could understand how best to address treatment of noxious weeds. The EIS will not evaluate the use of herbicides for commercial timber enhancement or livestock forage production.

24 Chapter 2—Alternatives Description

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 2 - 2. Descriptions of Treatment Methods Included in One or More Alternatives

Method Description Discussion Hand pulling, “Hand pulling is easy to plan and implement, The Modoc NF has conditions that grubbing, and is often the best way to control small may limit the amount and season digging, infestations, such as when a weed is first of hand pulling, grubbing, or detected in an area. Hand pulling may be a digging. Most of the Forest is rock good Alternative in sites where herbicides or covered with shallow soils which other methods cannot be used. The key to hinders the removal of the entire effective hand pulling is to remove as much of root system. In addition, once the the root as possible while minimizing soil area has dried out, the ground can disturbance. For many species, any root become hard as cement. fragments left behind have the potential to re- sprout, and pulling is not effective on plants with deep and/or easily broken roots. Annuals and tap-rooted plants are particularly susceptible to control by hand-pulling. It is not as effective against many perennial weeds with deep underground stems and roots that are often left behind to re-sprout.” (Tu et al. 2001)

clipping Hand clipping the plant or seedpod to prevent Clipping was not discussed in the seed production. Method does not remove DEIS, however the impacts are infestation. Requires several visits to site considered in this FEIS in annually to insure plant does not produce Alternatives 5 and 6 in response to seeds. comments received on the DEIS. Hand-held Hand-held string trimmer used to cut the plant Does not remove the plant or string or seed pod. infestation. It does prevent the trimmer spread of new seeds. Not discussed in the DEIS, however the impacts are considered in this FEIS in Alternatives 5 and 6 in response to comments received on the DEIS. Competitive Used after populations have been reduced by seeding other control actions. Grazing Grazing can either promote or reduce weed Not discussed in the DEIS, animals abundance at a particular site. By itself, grazing however the impacts are intensely on will rarely, if ever, completely eradicate invasive considered in this FEIS in 4-25 acres plants. However, when grazing treatments are Alternatives 5 and 6 in response to for specific combined with other control techniques, such as comments received on the DEIS. plants herbicides or biocontrol, severe infestations can EPA pointed out goat utilization be reduced and small infestations may be assists in control of musk thistle. eliminated. Grazing or other actions of grazing animals (wallowing, pawing up soil) can cause significant damage to a system, and promote the spread and survival of noxious weeds. Overgrazing on weed sites can reduce native plant cover, disturb soils, weaken native communities, and allow exotic weeds to invade. In addition, animals that are moved from pasture to pasture can spread invasive plant seeds. In general, the specific weed and desirable native plants will determine the number and species of animal grazers and the duration and frequency of grazing. (Tu et al. 2001) Mulching Cover the ground and/or weed seedlings with Mulching can be used on mulch (hay, grass clippings, wood chips, etc.) or relatively small areas, but will often other type of ground cover (newspaper stunt or stop growth of desirable clippings). This prevents weed seeds and native species. Mulching cannot seedlings from receiving sunlight necessary to control some perennial weeds survive and grow. because their extensive food

Chapter 2 – Alternatives Description 25 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Method Description Discussion reserves allow them to continue to grow up through the mulch. (Tu et al. 2001) Placing Placing Tarps over an area to shade out The Salmon River Restoration Tarps on undesirable plants. “Soil solarization is the Council on the Six Rivers National Plants (Soil technique of placing a cover (usually black or Forest has used this method on a solarization) clear plastic) over the soil surface to trap solar limited basis on a few sites. It is radiation and cause an increase in soil not considered for widespread use temperatures to levels that kill plants, seeds, in this FEIS because of concerns plant pathogens, and insects. In addition, when about visual impacts, adverse black plastic or other opaque materials are impacts to non-target species and used, sunlight is blocked which can kill existing soil, and the high winds plants (Katan et al. 1987). Soil solarization experienced over long periods of however, can cause significant biological, time on the Modoc National physical, and chemical changes in the soil that Forest. can last up to two years, and deter the growth of In addition the Salmon River area desirable native species. Soil solarization is receives over 4 times as much used in horticulture and for a few high value rainfall as the Modoc NF annually. agriculture crops like strawberries. This method The dry conditions on the Modoc has not been used extensively for weed control NF soils are not conducive to in natural settings. The effectiveness of soil widespread use of this method. solarization depends, in part, on how susceptible weed seeds are to temperature “Soil solarization is beneficial in increases. It is most effective against winter that it releases nutrients that are annual weeds that germinate under cool tied up in the organic component conditions (Elmore 1990). Summer annuals and of the soil, and that it can kill other species adapted to higher temperatures, unwanted plants without the use of which germinate during warmer parts of the chemicals (Stapleton 1990). year, are less susceptible. Soil solarization is However, solarization leaves an most effective during the summer months, and open substrate that can be readily may be less effective in cooler climates (DeVay invaded by new organisms, both 1990). The higher the temperature, the more native and non-native once the quickly a kill is achieved. Solarization is effective plastic is removed (Stapleton only if done in wet soil. Where soils are typically 1990). The influx of nutrients that dry, they must first be irrigated until soil from the results from solarization can be surface to 50 to 60 cm deep is at field capacity advantageous to restoration (Grinstein & Hetzroni 1991). “(Tu et al. 2001) efforts, but can promote aggressive, ruderal plants that typically thrive in nutrient-rich soils.” (Tu et al. 2001) Physical+ Hand-pulling, hoeing, grubbing, clipping seed See hand-pulling, grubbing, head or plant, trimming with hand-held string digging, and clipping (above). trimmer, covering with mulch or tarp Ground Herbicide applied directly to the plant with a Application as indicated minimizes Application wick is much like applying paint to a wall with a herbicide spray reaching non- with Directed roller. Provides maximum control of herbicide target plants or water. It also Spray or application directly to plants without drift or minimizes risk to soil & soil wicks applied droplets hitting the ground. Used most organisms. directly to effectively in riparian areas. Directed Spray individual hand application is accomplished by wand with plants regulated nozzle in such a fashion that spray is directed within 1 to 2 feet of the target vegetation. This spraying is done at an angle to reduce overspray. Plants that are three feet tall are left standing. Taller plants are will need to be cut or bent to insure that spray is within three feet of the ground.

26 Chapter 2—Alternatives Description

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 2 - 3. Effectiveness of All Methods Considered for Treatment of Noxious Weed Species

Common Scientific Cat Life History Hand Pulling Mechanical Biological Rx Fire Herbicide Grazing Name Name Dalmatian Linaria A Perennial Not Effective Not Effective Yes Not Effective Yes - Dicamba Not Effective Toadflax dalmatica Rhizomatous – complete Glyphosate removal of roots with numerous dormant root buds is generally infeasible. Diffuse Centaurea A Biennial Caution, use May reduce but Yes - Several Yes - if followed Yes - 2, 4-D, Not Effective Knapweed diffusa only on sites not eliminate insect agents by herbicides Dicamba, and with few seed greatly vary in Clopyralid; or plants. Re- production. their ability to Tank Mix 2.1 sprouting can Rosettes are reduce occur. Hand generally too knapweed seed pulling must low for mowing. and vegetative be repeated Tillage is not reproduction. 2-4 times a recommended. Establishment year. may take from one to several years. Will not eradicate knapweeds, but may be utilized to reduce knapweed populations over time.

Chapter 2 – Alternatives Description 27

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Common Scientific Cat Life History Hand Pulling Mechanical Biological Rx Fire Herbicide Grazing Name Name Musk Thistle Carduus A annual or Yes No Mowing 3 ft Yes – but can Yes – Fire will Yes - Limited Goats – nutans biennial tall musk thistle attack other remove dense chlorsulfuron Many thistle plants to a 6 in thistle species – stands of (0.37 - 0.75 oz problems occur stubble will possible risk to mature thistles. ai/A) applied when range or prevent seed native thistles. during early pastures are production, but bloom stage overgrazed in thistles quickly reduced seed summer and recover from production by early fall, or remaining buds over 99%. when near the base. Dicamba, 2, 4- conditions, Tillage is not D, Clopyralid, such as drought always practical Glyphosate and stress or poor in non-crop combination will fertility in soils areas. be effective. (; are present. or Tank Mix1 1 or 2). Plumeless Carduus A winter annual Yes Same as Musk Same as Musk Same as Musk Same as Musk Same as Musk Thistle acanthoides or biennial Thistle Thistle Thistle Thistle Thistle Scotch Thistle Onopordum A Biennial Caution, use May reduce No No Dicamba, 2, 4- No acanthium only on sites seed production D, Clopyralid; with few or Tank Mix1 1 plants. Make or 2. sure to remove entire root re- sprouting can occur. Hand pulling must be repeated 2-4 times a year Spotted Centaurea A Biennial Caution, Same as Same as Same as Same as Same as Knapweed stoebe ssp. Same as Diffuse Diffuse Diffuse Diffuse Diffuse micranthos Diffuse knapweed knapweed knapweed knapweed knapweed knapweed Squarrose Centaurea A Perennial Caution, Same as Same as Same as Same as Same as Knapweed squarrosa Same as Diffuse Diffuse Diffuse Diffuse Diffuse Diffuse knapweed knapweed knapweed knapweed knapweed knapweed

28 Chapter 2—Alternatives Description

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Common Scientific Cat Life History Hand Pulling Mechanical Biological Rx Fire Herbicide Grazing Name Name Crupina Crupina A winter annual Yes - Before Limited on Not Effective Not Effective Since other Not Effective vulgaris flowering steep slopes or control small rugged range strategies are infestations. areas. limited Infestations herbicides may should be be the most checked effective means every two to for eradicating four weeks larger infestations. Dicamba (0.5 lb ae/A) + 2, 4-D (1.0 lb ae/A). Glyphosate (1.0 lb ae/A). Clopyralid (0.13 lb ae/A). Triclopyr (.25 lb ae/A ; or Tank Mix1 2. Canada Cirsium B Perennial No – but may Not Effective - Not Effective Not Effective - Yes - The rate, Not Effective Thistle arvense Rhizomatous work on Does not result Canada thistle timing, and small in complete kill. may respond effectiveness of infestations. May be more both positively these effective when and negatively treatments may combined with to burning. vary. herbicide Chlorsulfuron, treatments. Clopyralid, Must be Dicamba, repeated every Glyphosate; or 7-21 days. Tank Mix1 1 or 2. Dyer’s Woad B Biennial Caution - No - Not No – not No – too sparse 2, 4-D Not Effective Isatis make sure to effective due to approved in to carry fire. chlorsulfuron tinctoria remove the re-sprouting of CA. entire root; root crown re-sprouting from the crown can occur.

Chapter 2 – Alternatives Description 29

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Common Scientific Cat Life History Hand Pulling Mechanical Biological Rx Fire Herbicide Grazing Name Name Mediterranean B Biennial/ Caution - re- No -Not Yes – effective- Not Effective Dicamba, 2, 4- Not Effective Sage Salvia perennial sprouting effective due to ness spotty D aethiopis from the prostrate crown can growth habit of occur. Make the rosettes. sure to sever Tillage is the root at generally not an least 3 option in areas inches below these plants the soil infest. surface. A shallower depth will result in crown re- sprouting Tall Whitetop B Perennial Not Effective Limited long- Yes No Dicamba and 2, No (Perennial Lepidium Rhizomatous term impact 4-D Pepperweed) latifolium Chlorsulfuron; or Tank Mix1 2. Klamathweed C Perennial; Caution, No - Promotes Yes No – Spreads No No Hypericum used removal of vegetative Infestation perforatum medicinally the entire spread of root structure rhizomes is necessary as re- sprouting from the crown can occur.

30 Chapter 2—Alternatives Description

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Common Scientific Cat Life History Hand Pulling Mechanical Biological Rx Fire Herbicide Grazing Name Name Yellow C annual/ Yes only very No -Will not Yes – but not Prescribed 2, 4-D, No - Will not Starthistle Centaurea biennial small provide sufficient to burns can Dicamba, control solstitialis infestations. complete provide long- provide control Triclopyr, populations but Take care control, term starthistle if implemented Glyphosate, may reduce not to disturb although it can management after annual Chlorsulfuron; seed production soil. be effective and is rated as plants have or Tank Mix1 1 if done with moderate low and dried, but or 2. intensely at the infestations and moderate in before yellow right time. erect growth reducing starthistle seed form. infestations. is produced. Note 1: Definitons of the various treatment methods are found in tables 2-2 and 2-10. Note 2: This Table is based on information from the State of Californa, Department of Food and Agriculture, Division of Plant Health and Pest Prevention Services web site at: http://www.cdfa.ca.gov/phpps/ipc/weedinfo/winfo_list-commname.htm 1 Tank mixes were added to Alternative 6 to use combinations of pesticides when the tank mix would be more effective and would utilize less active ingredients. Tank Mix 1 is a mixture of chorsulfuron and 2, 4-D and Tank Mix 2 is a mixture of dicamba and 2, 4-D. (2, 4-D is could be the amine or ester formulation depending on the distance from water.

Chapter 2 – Alternatives Description 31

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Herbicide Treatment Methods Proposed for Use Herbicides would be applied directly to weed leaves and stems using directed spray or wick applicators. Surfactants may be used to impart spreading, wetting, dispersal, and/or emulsification of herbicides. Directed spray applicators, one type of foliar applicator, spray herbicide directly onto target plants from containers with spray hose and appropriate nozzle. Other desirable plants are avoided. Directed spray applicators will be brought to infestation sites by motorized vehicles with spray hoses and or by backpack as appropriate. Crook-necked spray bottles and similar equipment may be used to carry herbicide over distances and through dense vegetation for safety reasons. These sprayers, particularly hand-pumped spray or spray bottles can target very small plants or parts of plants. Wicking is a technique that uses a sponge or wick on a handle to wipe herbicide directly onto weed foliage and stems. The wick generally prevents drift or droplets from falling onto non-target plants and soil. Other methods of application maybe used based on technology and effectiveness.

Figure 2 - 1. Photographs of Herbicide Application Tools Proposed

Truck-Mounted Pressurized Sprayer ATV-Mounted Pressurized Sprayer Towed Pressurized Sprayer

Wick Applicator Wick Applicator (closeup) Backpack Sprayer All registered herbicides must have a label certifying that the Federal Environmental Protection Agency (EPA) and the California Department of Pesticide Regulation (DPR) have approved the herbicide for use. Product labels are legal documents whose language is determined and approved by the EPA during the pesticide registration process. All herbicides proposed for use are registered in the U.S. and California and have a label certifying that the EPA and the DPR have approved the herbicide for proposed uses. The label contains information about the product, including its relative toxicity, potential hazard to humans and the environment, directions for use, storage and disposal, and first aid treatment in case of exposure. These label directions provide for public and worker safety by requiring posting of treated areas, pre-designation of mixing, storage and filling sites, and transportation and handling practices in accordance with toxicity of each formulation. The length of time each herbicide controls noxious weeds varies with the type of herbicide, environmental conditions, and target weed. Some herbicides control weeds for a short time period, while others can provide several years of control from one application. EPA approved

32 Chapter 2—Alternati

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

herbicide labels include safe handling practices, application rates, and labels, susceptibility of weeds to different herbicides, Material Safety Data Sheets, guidelines, and an Emergency Spill Response proposed for use on this project are contained in the project file at the Supervisor’s Office in Alturas, California. Use of herbicides for noxious weed treatment involves application of products developed, labeled, and produced to treat weed species at certain stages of plant growth. Most herbicides considered in this analysis are “selective” which means they control certain plant species while allowing other species to remain unaffected. Several herbicides are considered because they vary in effectiveness on different noxious weeds. As stated in the DEIS, Alternatives 2 and 4 will include analysis of pesticide treatment using 2, 4-D, clopyralid, dicamba, glyphosate, and triclopyr, applied at appropriate rates according to label directions determined by EPA and DPR requirements (Table 2-14). As a result of public comment, Chlorsulfuron and specific mixtures of 2, 4-D, with Dicamba or chlorsulfuron are considered in Alternative 6. The DEIS listed hexazinone as an herbicide to be utilized in the treatment of three noxious weed species on less than 15 acres. As a result of public comment, the proposed use of hexazinone was reevaluated. Subsequently, it was dropped from analysis in this FEIS for two reasons. First, it is registered primarily for use as a pre-emergent soil treatment, which is not a treatment method being proposed. Second, the three weed species it was proposed to treat can each be successfully treated with other herbicides proposed for use. Herbicide selection depends on weed species, level of infestation, location, other resource concerns (see Best Management Practices), and the applicability of herbicides. Herbicide selection considers, but is not limited to, the following criteria:  Herbicide effectiveness on target weed species;  Proximity to water or other sensitive areas;  Soil characteristics;  Potential unintended impacts to non-target species such as conifers or shrubs;  Adjacent treatments (private or state land); and  Timing of treatment. Herbicides in the action Alternatives and targeted weed species are shown in Table 2-14. The herbicides were selected for inclusion into the noxious weed treatment program because of their proven effectiveness on the selected noxious weeds and their characteristics and selectivity. Information on the use and restrictions of herbicides is continually changing. New restrictions or elimination of use of analyized herbicides may occur. Updated formulations and herbicides with less toxic herbicides and lower rates also may be likely to be developed. During annual work planning additional chemicals and lower rates may be considered for site specific applications as long as the effects are within the range of effects analyzed, chemicals are applied under label instructions and a risk assessment for the chemical has been prepared that demonstrates less environmental or human risk are shown. The new chemicals and/or lower rates risk assessments conducted during annual work planning will be analyzed and considered like any other new information as specified in FSH 1909.15.18.

Herbicide Characteristics and Selectivity Clopyralid: Clopryalid is a selective herbicide used to kill unwanted annual and perennial broadleaf plants.

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Clopyralid is relatively persistent in soil and is degraded by soil microbes and not susceptible to photo or chemical degradation. Once Clopyralid has been applied to soils, it rapidly disassociates (Shang and Arshad 1998), becoming extremely soluble in water and does not bind strongly with soil particles. Lack of adsorption means that Clopyralid has the potential to be mobile and could contaminate ground and surface waters via leaching. The average half life of Clopyralid is one to two months but can range from one week to one year depending on the soil type, temperature and rates of application. Do not apply Clopyralid to areas where soils are very permeable and the water table is shallow. Because Clopyralid is highly soluble in water, there is a potential for it to move off site during summer thunderstorm activity that has high intensity and short duration precipitation events (Source- Weed Control Methods Handbook, The Nature Conservancy, Tu et al.). Clopyralid has been identified as extremely water-soluble and has a high potential for mobility and leaching into the soil profile. It is not approved for application on or near water. Do not apply Clopyralid to areas where soils are very permeable and the water table is shallow. The usage of this herbicide in areas where soils are considered to be sensitive, shallow depth or where the water table is shallow may result in groundwater contamination. Because Clopyralid is highly soluble in water, there is a potential for surface waters to be contaminated if Clopyralid is applied directly to bodies of water or wetlands. (Source-- Weed Control Methods Handbook, The Nature Conservancy, Tu et al.). From the Specimen Label for Transline (EPA Reg. No. 62719-259 revised 07-26-99) Clopyralid should not be applied where soils have a rapid to very rapid permeability or the depth to groundwater is shallow. Dicamba: Dicamba is a selective herbicide used to kill broadleaf weeds before and after they sprout; however, the only dicamba formulations that are being considered in this FEIS are those that would be applied after weeds sprout. Dicamba is not adsorbed by most soils. It is highly mobile and is moderately persistent in most soils. Dicamba has a half-life of 1 to 6 weeks in soil and the method of degradation by soil microbial activity. The rate of degradation of Dicamba is slower at low temperature and low soil moisture (Source: Pesticide Fact Sheet prepared by Information Ventures, Inc.). Dicamba can be introduced to groundwater and surface water. Application of Dicamba or in combination with 2, 4-D on sensitive or shallows soils can introduce the active ingredient into the groundwater table. Glyphosate: Glyphosate is a broad-spectrum, non-selective herbicide that kills all plants, including grasses, broadleaf and woody plants. Glyphosate is highly water-soluble but unlike most water-soluble herbicides has a very high adsorption capacity. Once Glyphosate contacts soil it is rapidly bound to soil particles rendering it essentially immobile (Roy et al. 1989a). Unbound or free Glyphosate molecules are degraded at a steady and relatively rapid rate by soil microbes (Nomura and Hilton 1977, Rueppel et al 1977 and Busse 2001). Because Glyphosate binds strongly to soils, it is unlikely to enter waters through surface or sub- surface runoff except when the soil itself is washed away by runoff, and even then, it remains bound to soil particles and unavailable to plants (Rueppel et al. 1977, Malik et al. 1989). Most Glyphosate found in waters likely results from runoff from vegetation surfaces, spray drift and direct over spray. Bakke (2001) summarized water quality monitoring following ground based application of herbicides for herbicide residues in USFS Region 5 from1991 to 1999. For Glyphosate, distances where the application was not allowed ranged from 200 feet to 0 feet from water bodies. There

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

were no detections of herbicide residues in water or sediments in any of the samples with the exception of one noxious weed treatment that occurred within the riparian zone. Even within the riparian zone, only one of twelve samples had a detection, and that was at a level below any level of concern for human health or aquatic resources. Two sites on the Stanislaus NF where a 10-foot no application distance was used, showed no detection of residues immediately post-treatment and post-treatment after the first storm flow. Glyphosate has been shown to bind with the soil particle when it is applied to the soil, it has been shown by current research at the USDA Forest Service Pacific Southwest Research Station in Redding, California that the microbial activity of the soil is not adversely affected by Glyphosate and that soil microorganisms break down the active chemical ingredient within 24 to 72 hours after application (Busse et al. 2001). Triclopyr: Triclopyr is a selective herbicide used to kill unwanted broadleaf plants. Microbial metabolism accounts for a significant percentage of Triclopyr degradation in soils. In general, warm moist soils with a high organic will support the largest microbial populations and the highest rate of herbicide metabolism. The reported half-life of Triclopyr in soil varies from 3.7 to 314 days depending on specific soil and environmental conditions (Newton et al. 1990). Coarse textured soils that are highly permeable may therefore retain Triclopyr but most studies have found that Triclopyr does not tend to move in significant quantities below the top 15 cm (.50 in) of soil (Norris et al. 1987; Newton et al. 1990; Stephenson 1990 and Johnson et al. 1995a). From the Specimen Label for Garlon 3A (EPA Reg. No. 6271937) treatment of aquatic weeds can result in oxygen depletion or loss due to the decomposition of dead plants. To minimize this hazard do not treat more then one-third to one-half of the water area in a single operation. This chemical has properties and characteristics associated with chemicals detected in groundwater. The use of this chemical in areas where soils are permeable, shallow depth or where the water table is shallow may result in groundwater contamination. Do not apply directly to un-impounded rivers or streams. Applications should be made only where there is little or no hazard from spray drift (Source Specimen: Label Garlon 3A Revised 03-19-03). In water, the two formulations of triclopyr (water soluble salt and ester formulas) can behave very differently. The water-soluble salt is degraded in the water column through photolysis and hydrolysis (McCall & Gavit 1985). The ester is not water soluble and can be persistent in the aquatic environment. The ester binds to organic particles in the water column and precipitates to the sediment layers (McCall & Gavit 1986). Bound ester molecules will degrade through hydrolysis and photolysis to Triclopyr acid (Smith 1976) which move back into the water column and continue to degrade. The rate of degradation is dependent on the water temperature, pH, and sediment content. Triclopyr acid has an intermediate soil adsorption capacity resulting in the potential for the movement of small amounts of Triclopyr following the first significant rainfall (McCall & Gavit 1986), but further leaching is believed to be minor (Newton et al. 1990; Stephenson et al. 1990 and Thompson et al. 1991). Movement of Triclopyr through surface and subsurface runoff in areas with minimal rainfall is believed to be negligible (Newton et al. 1990; Stephenson et al. 1990) (Source- Weed Control Methods Handbook, The Nature Conservancy, Tu et al.). Garlon 4 includes kerosene as an inert ingredient. Triclopyr is active in the soil and adsorbed by clay particles and organic matter in the soil. Microorganisms degrade Triclopyr and have a relatively short half-life of 46 days under ideal conditions (warm moist soil conditions). It is highly mobile and is moderately persistent in most soils. The rate of degradation of Dicamba is slower at low temperature and low soil moisture (Source: Pesticide Fact Sheet prepared by Information Ventures, Inc.).

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Triclopyr has been identified for treatment of aquatic weeds associated with impounded waters (i.e. lakes, ponds and reservoirs) but not free flowing streams. This herbicide has properties and characteristics associated with chemicals detected in groundwater. The usage of this herbicide in areas where soils are considered to be sensitive, shallow depth or where the water table is shallow may result in groundwater contamination. Triclopyr binds to clay (fine textured soils) and organic matter and has a mobility of low to moderate. Bakke (2001) summarized water quality monitoring following ground based application of herbicides for herbicide residues in USFS Region 5 from1991 to 1999. For Triclopyr, no application distances ranged from 200 feet to 10 feet. Monitoring results showed residual detections of Triclopyr for no application distances less than 15 feet. With a 20 foot no application distance, no detections were found. 2, 4-D: 2, 4-D is used as a systemic herbicide used to selectively control broadleaf weeds. 2, 4-D is degraded in soils primarily by microbes. Hemmett and Faust (1969) concluded that the size of the microbial population, the concentration of 2, 4-D and the ratio of the two factors determine 2, 4-D degradation rates. Soil conditions that enhance microbial populations (i.e. warm and moist) facilitate 2, 4-D degradation rates (Foster & McKercher 1973). Wilson et al (1997) found that adequate soil moisture was the most influential parameter affecting the degradation rates. Lag times of up to eight weeks during which 2, 4-D degradation is slow, have been reported following the first application of 2, 4-D to soil (Audus 1960). Most formulations of 2, 4-D do not bind tightly with soils and have the potential to move down into the soil column. This herbicide is considered to be highly mobile, it is prone to move off site in surface runoff and sub surface flow (Source Weed Control Methods Handbook, The Nature Conservancy, Tu et al.). 2, 4-D is identified by the EPA as having characteristics that make it an herbicide with high leaching potential and very water soluble thereby making it subject to movement by runoff when applied adjacent to or near water. The EPA identifies that 2, 4-D is broken down into inert particles by soil microbial activity within 7 days following application. The EPA reports that 2, 4-D has low soil persistence. The half-life in soil is less than 7 days. Soil microbes are primarily responsible for its disappearance. Despite its short half-life in soil and in aquatic environments, the compound has been detected in groundwater supplies in at least five States and in Canada. Very low concentrations have also been detected in surface waters throughout the U.S. Chlorsulfuron: Chlorsulfuron is a selective herbicide used to kill annual, biennial, and perennial broadleaf weeds before and after they sprout; however, the only chlorsulfuron formulations that are being considered in this FEIS are those that would be applied after weeds sprout. Chlorsulfuron should not be applied to soils when they are saturated or when they are subject to periods of intense rainfall. Aerial drift potential increases at wind speed of less than 3 mph (due to variable direction and inversion potential) or more than 10 mph. Drift potential is high during a surface inversion (Source- Specimen Label Telar DF (EPA Reg. No. 352-522)). A tank mix of 2, 4-D and chlorsulfuron should not be applied to saturated or coarse textured soils or when intense rainfall (summer thunderstorm) is likely to occur within 7 days of application. Both of these chemicals are highly mobile and can be transported by surface runoff into the streams and lakes. Tank Mixes: Two tank mixes are proposed to be applied under Alternative 6. These tank mixes are as follows: Tank Mix #1—chlorsulforon mixed with 2, 4-D; Tank Mix #2—dicamba mixed with 2, 4-D. Tank Mix #1 (Chlorsulfuron + 2, 4-D): 2, 4-D is identified by the EPA as having characteristics that make it an herbicide with a high leaching potential and is very water-soluble, thereby making

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

it subject to movement by runoff when applied adjacent to or near water. Chlorsulfuron has been shown to be highly mobile and is moderately persistent in most soils. Chlorsulfuron should not be applied to soils when they are saturated or when they are subject to periods of intense rainfall. Both chlorsulfuron and 2, 4-D are highly mobile and can be transported by surface runoff into streams and lakes. Tank Mix #2 (Dicamba + 2, 4-D): Application of dicamba or in combination with 2, 4-D on sensitive or shallows soils can introduce the active ingredient into the groundwater table. Tank Mix #2 should not be applied to saturate or coarse textured soils or when intense rainfall (summer thunderstorm) is likely to occur within 7 days of application. Both of these chemicals are highly mobile and can be transported by surface runoff into the streams and lakes Dicamba is not adsorbed by most soils. It is highly mobile and is moderately persistent in most soils. Application of dicamba or in combination with 2, 4-D on sensitive or shallows soils can introduce the active ingredient into the groundwater table. Selection of weed management treatment is not a choice of one treatment over another, but rather a selection of a combination of treatments that would be most effective on the target species for a particular location.

Early Detection – Rapid Response Strategy An integrated weed management approach for addressing invasive plant problems calls for Early Detection – Rapid Response for newly discovered sites to insure weed infestations are removed upon discovery. During development of the FEIS and finalizing the response to comments the Modoc National Forest decided to clarify adaptive management to a narrower definition and to clarify that the program was in line with National, Regional and Forest Integrated Weed Management principles. Therefore; adaptive management discussions and program have been replaced with what is more appropriately called Early Detection - Rapid Response Strategy. An Early Detection – Rapid Response Strategy offers an avenue to describe and evaluate the consequences of changing invasive plant infestations and treatment. The following paragraphs cover Early Detection – Rapid Response as it relates to project design, environmental effects analysis, and monitoring, evaluation, and change. This section also covers using Forest Service Handbook procedures for addressing new information and changed circumstances after decisions are made. Under an Early Detection - Rapid Response Strategy, new or previously undiscovered infestations would be treated according to approved methods and Design Standards. Treatments may occur in all Forest Plan land allocations and may include invasive species that are not listed in Table 1-1. A treatment and restoration plan would be developed for new infestations, based on the process outlined in the section on Implementation Planning below. The IDT considered the kinds of site conditions encountered throughout the treatment areas and analyzed the effects of applying a range of treatment prescriptions to these situations. The Implementation Planning process would ensure that treatments of currently undetected invasive plants would have effects within the scope of those disclosed in this FEIS, because the Design Standards were developed considering a wide range of conditions that occur throughout the Forest. The Design Standards serve to eliminate or minimize the risk of significant effects to such a degree that even though precise treatment locations may not be known, the effects of treatment are known.. Rapid Response for this analysis anticipates that existing sites may increase in the number of plants by approximately 10 % per year. The number of new sites found is anticipated to be less than 50 per year based on the inventories carried out as part of other projects. Proposed treatment

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

of acres identified under Early Detection - Rapid Response would be capped at no more than 100 acres being treated in any given year, and no more than 200 acres in total. The rationale for this cap is to provide flexibility to treat new and/or expanding weed sites while remaining within the range of effects as displayed in this analysis. The current invasive plant list for the Modoc National Forest is included in the Modoc National Forest Integrated Weed Management Strategy of 2005, the database maintained for noxious weed inventory is maintained electronically and is updated as new occurrences are found or information on existing sites is developed. The intent of an Early Detection - Rapid Response Strategy is to treat new infestations when they are small so that the likelihood of adverse treatment effects is minimized. In addition, the precise location of individual target plants, including those mapped in the current inventory is subject to change. Thus, the Early Detection - Rapid Response Strategy included in Alternatives 4,5, and 6 allows the Forest Service to treat across the Forest where the need exists, based on, but not limited to the current inventory and anticipated rates of spread. The annual implementation planning process is intended to ensure that effects are within the scope of those disclosed in this FEIS.

Noxious Weed Site Re-treatments Some noxious weed sites may require re-treatment to fully control or eradicate the site. Re- treatment of noxious weed sites within the same season will normally be done physical+ treatments. Herbicide treatments will occur only once per year. Phyiscal + treatment will not exceed one cubic meter per acre without prior authorization from the heritage resources specialist. Re-treatment of noxious weed sites may be needed to manage the seed bank. This need to retreat noxious weed sites was identified in the DEIS and is clarified here as Seed Bank Management. Seed Bank Management includes visiting previously treated sites on an annual basis to treat newly germinated weeds. Seed Bank Management is included in all action Alternatives. The extent of proposed treatments and herbicide treatments is summarized in Table 2-12. The most extensive proposed herbicide treatment under this FEIS would occur if either Alternative 2 or 4 are selected. Under Alternatives 2 and 4, up to 6,639 acres could receive some form of herbicide treatment. However, this represents less than ½ of 1 % of the total land area of the Modoc National Forest, or stated differently, for each 288 acres of Forest, just 1 acre, on average, could be treated with herbicides under this Alternative. Alternative 6 limits possible herbicide treatments to 541 acres (7/100s of one % of the Forest). In addition to the very limited percentages of the Forest that could be treated with herbicides under this FEIS, the majority of the sites are small and scattered (most are 1/10 acre or less in size). This further reduces the potential for concentrated impacts of herbicides on people or wildlife in localized areas. Also, within identified weed sites, weed plants frequently constitute less than complete ground cover, often much less, with only a few plants scattered across some weed sites. Thus herbicide treatment will result in a patchwork of treated and untreated areas even within the confines of many weed sites. This again reduces the potential for concentrated impacts on people or wildlife in localized areas. The primary objective of the herbicide treatment methods, proposed for use in this FEIS, is to efficiently kill weeds by delivering the herbicide directly to the leaves and stems of the weed plants using directed spraying and/or wicking methods. Application of herbicides to non-target plants would be counterproductive, as this may create bare areas, especially so in the case of Glyphosate which is generally effective against all types of green plants. Bare areas are typically the preferred habitats of weeds. Any inadvertent spraying of the soil surface or non-target plants 38 Chapter 2—Alternati

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

is also unproductive, as it adds to the cost of treatment without killing weeds. These considerations for economy and effectiveness of the weed treatments will act to reduce the total quantities of herbicides applied to weed sites. A comparison of environmental impacts and significant issues is presented in Table 2-18. The potential impact for each Alternative is displayed for each of the four Significant Issues, as well as for threatened and endangered wildlife, threatened and endangered aquatic species, threatened and endangered plants, and cultural plants. The total amount of herbicides applied by implementing any of the Alternatives utilizing herbicides is displayed in Table 2-15. Table 2-16 displays the contribution of total herbicide application by each herbicide to the total applied in Modoc County over the 2003 and 2004 calendar years as reported by the California Department of Pesticide Regulation. Alternatives Considered Based on the significant issues identified through public comment on the DEIS, the Forest Service developed two additional Alternatives that address the Purpose and Need to a different degree than the three action Alternatives in the DEIS. In addition, the Forest Service is required to analyze a No Action Alternative (current management). The Proposed Action, No Action Alternative, and the four action Alternatives are described in detail below. Alternatives 1-4 are the Alternatives from the DEIS with corrections and clarifications in data and statements as a result of the DEIS comments. Alternatives 5 and 6 expand on Alternatives 3 and 4 in response to comments on the DEIS and reduce the scope of treatment in size and intensity. A wide range of Alternatives is provided by the No Action Alternative (Alternative 1, current management), the Proposed Action (Alternative 2), and the four action Alternatives. The action Alternatives vary in acres treated, types of treatments, and treatment design. The Alternatives depict treatment methods that can reasonably be expected to be implemented given anticipated budgets, treatment timeframes, and availability of equipment and procedures available to the Modoc National Forest. Experimental and/or newly developing techniques are not analyzed.

Design Standards for Alternatives Design Standards guide implementation of Alternatives 2 through 6. All Design Standards are described in Table 2-4, and a summary of Design Standards related to surface water is displayed in Figure 2-2. Design Standards ensure that noxious weed treatments result in environmental effects that are within the direct, indirect, and cumulative effects described in Chapter 3. Examples of how Design Standards are applied are presented in Appendix B.

Table 2 - 4. Design Standards for Alternatives 2 through 6

Code Design Standard 2 3 4 5 6 DS-01 Planning: The Forest will develop an annual work plan for treating noxious weeds, specifying locations and treatments. The annual work plan will be provided to the US Fish and Wildlife Service, California Department of Fish and Game and the appropriate Regional Water X X X X X Quality Control Boards, well in advance of treatment initiation for their review and comment. Consultation on the annual work plan will be conducted with all affected tribes. DS-02 Planning: Treatment priorities for sites and methods are listed in Table 2- X X X X X 13, Comparison of Treatment Priorities DS-03 Planning - Time Period: Time Frame for Implementation is 5 years. X X

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Code Design Standard 2 3 4 5 6 DS-04 Planning - Time Period: Time Frame for Implementation is 10 years or longer (FSH 1909.15 section 18.03). Review the environmental documentation of actions awaiting implementation and those of ongoing programs or projects at least every 5 years to determine if the X X X environmental analysis and documentation is still current. If the responsible official determines that it is current and a correction, supplement, or revision is not necessary, implementation would continue. The results of the review will be documented in the project file. DS-05a Physical treatment will be used when occurrences are small consisting of having fewer than 100 weed plants or are a tenth (0.10) of an acre or X X less. Sites of 0.10 acre or less with over 100 plants may be treated with herbicides until the population is reduced to less than 100 plants. DS-05b Physical+ treatment will be used when occurrences are small consisting of having fewer than 25 weed plants or are a tenth (0.10) of an acre or X less. Sites of 0.10 acre or less with over 25 plants may treated with herbicides until the population is reduced to less than 25 plants. DS-06 Physical+ treatment of rhizomatous species would not be used. X X X DS-07 Physical+ treatments may be used on rhizomatous species weed sites smaller than 1/10 of an acre in size, and that have young, small plants X X that can be totally removed, including the rhizomatous roots. DS-08 Physical treatment: To reduce seed spread, disposal of noxious weeds that are grubbed or manually removed will be as follows: If no flowers or seeds are present, pull the weed and place it on the ground to dry out if X X X X X species is not rhizomatous or there is a potential for re-sprouting. If flowers or seeds are present, pull the weed carefully to prevent seeds from falling, and place in an appropriate container for disposal. DS-09 Heritage Resources: Weed treatments will be coordinated with the Forest heritage resource specialist and Forest tribal relations manager to protect heritage resources such as traditional plant gathering areas, rock art, and historic structures. Soil disturbance will be limited to cubic meter per acre, X X X X X without prior authorization from the heritage resources specialist. (R5 Programmatic Agreement for minimum disturbance activities with State Historic Preservation Officer) DS-10 Wildlife and Fish - Terrestrial: Limited Operating Periods for TE&S and MIS species, as called for in the Forest Plan and the Sierra Nevada Framework, will be implemented if weed infestations occur within the X X X X X specified protection areas. An additional LOP for sandhill crane will be implemented from 1 April to 30 August for all active crane nests. DS-11 Wildlife and Fish – Aquatic TES: Herbicides will not be applied within 100 feet of habitats of TES aquatic species, with the exception of aquatic X formulations of Glyphosate which may be used within this zone. DS-12a Wildlife and Fish – No Dicamba or 2, 4-D (either alone or in tank mix) will be used within occupied sage grouse habitat. The range for this species X X X is very restricted on this forest. DS-12b Wildlife and Fish – No 2, 4-D on weed occurrences greater than 2 acres X in size. DS-13 Wildlife and Fish – No 2, 4-D (either alone or in tank mix) will be used X X X within 25 feet of the water’s edge in occupied bald eagle habitat. DS-14 Water: Annually the amount of physical disturbance and/or herbicide application would be limited to no more than 15% of each 6th Field Sub- X X X X X watershed.

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Code Design Standard 2 3 4 5 6 DS-15 The specified distances for perennial streams, lakes and special aquatic features are 300 feet and 150 feet for seasonally flowing streams, both of which are consistent with Riparian Conservation Areas as defined the Sierra Nevada Framework (SNF) ROD, 2001. For the Noxious Weed FEIS, the designated zone for all Streamside Management Zones is the Riparian Conservation Areas (RCAs) on the Modoc National Forest. See X X X X X the definition for Riparian Conservation Area in the glossary. Therefore, for the Noxious Weeds FEIS, the terms SMZ and RCA are interchangeable. For the purpose of noxious weed treatments, SNF RCA standards will apply Forest wide. Within these prescribed RCAs, limited hand treatments may occur for a distance of 10 feet outward from the edge of the High Water Mark. DS-16 The RCAs will be maintained with 50% of the acreage of the RCA as undisturbed; disturbance will be limited to no more than 25% of the X X X X X acreage of the inner half of the RCA. DS- 17 Water - RCA Treatments: Herbicide treatment within the Riparian Conservation Areas (RCAs) will be as follows: -From the High Water Mark outward to 10 feet, no herbicide use (only Physical Methods). -From a distance of 10 feet to the outer edge of RCAs for Seasonally Flowing or Perennial Streams, only Aquatic Glyphosate may be applied X X by wicking it onto the plant. -From the outer edge of RCAs for Seasonally Flowing or Perennial Streams, Glyphosate, Clopyralid, Dicamba, and Triclopyr may be applied. -2, 4-D will not be applied within 1,000 feet of the High Water Mark of Seasonally Flowing or Perennial Streams. DS-18a Water - RCA Treatments: Within the Riparian Conservation Areas (RCAs) outside of the Lahontan Regional Water Board area of jurisdiction, herbicide treatments will be as follows: -From the High Water Mark outward, aquatic formulations of Glyphosate may be used in RCAs for Seasonally Flowing or Perennial Streams (as well as Physical (+) Methods. -From a distance of 10 feet from the High Water Mark outward to the outer edge of RCAs for Seasonally Flowing or Perennial Streams, Glyphosate and Amine forms of 2, 4-D may be used. X -From 25 feet from the High Water Mark outward to the outer edge of RCAs for Seasonally Flowing or Perennial Streams, Chlorsulfuron, Dicamba, Clopyralid, Triclopyr; and Tank Mixes 1 and 2 with only amine forms of 2, 4-D. -From 100 feet from the High Water Mark outward to the outer edge of RCAs for Seasonally Flowing or Perennial Streams, Chlorsulfuron, Dicamba, Clopyralid, Triclopyr; and Tank Mixes 1 and 2 with either ester or amine forms of 2, 4-D. DS-18b No more than 10 percent of the acreage with RCAs for the Frog Waterhole (6th Field HUC 180200021103) and RCAs for lakes found within Clarks Valley (6th Field HUC 18020030106) would be treated with herbicide each year, from the edge of the High Water Mark for a distance X of 100 feet. When applied from the High Water Mark to a distance of 25 feet from water, herbicides would be applied by wicking them directly on the plant. DS-19a In the areas under the Lahontan Water Quality Control Board jurisdiction (see Figure 3-2), with Alternative 6 no herbicide treatment will occur from the High Water Mark for a distance of 10 feet. From a distance of 10 to X 100 feet from the High Water Mark, only aquatic Glyphosate will be used. At a distance greater than 100 feet from the High Water Mark, the other herbicides shown in the Alternative may be applied. DS-19b Do not use herbicides to treat noxious weeds in the Area of Concern that supplies the Ft. Bidwell Reservation with drinking water (see map in Appendix N). If weeds become established in the future, consult with the X X X Ft. Bidwell Tribe to determine suitable treatment methods under Early Detection – Rapid Response.

Chapter 2 – Alternatives Description 41

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Code Design Standard 2 3 4 5 6 DS-20 Soils: Areas with bare soil resulting from noxious weed treatments that are greater than ¼ acre in size will be assessed for need for X X X rehabilitation. DS-21 Soils: Areas with bare soil created by the treatment of noxious weed, the X X site would be evaluated for rehabilitation. DS-22 Annually the Forest Hydrologist, Watershed Specialist or Soil Scientist determines the location of the noxious weed occurrence to be treated to determine if the site to be treated is located on sensitive or shallow soils. X X X If it is determined that the site to be treated contains sensitive or shallow soils then either DS 23 or 24 would be applied, depending on Alternative selected. DS-23 Soils: On noxious weed sites identified as having sensitive soils and or shallow soils, do not use herbicides with high leaching potential to treat X X noxious weeds. DS-24a Soils: Treatment of noxious weeds on sensitive and/or shallow soils utilizing herbicides other than Glyphosate will not exceed 1 acre per 6th X field sub-watershed on an annual basis. DS-24b Soils: Limit annual herbicide treatments in 6th field sub-watersheds to no X more than 10% of the acreage of the 6th field sub-watershed. DS-25 Soils: On those sites with soils identified as having a high or very high erosion potential or a rapid or very rapid risk to runoff do not use Physical and Physical+ methods to treat noxious weeds when the fire weather X X X X X forecast for the next 24 hours states there is a likely chance of thunderstorms (generally 60-70% or greater as defined by the National Weather Service). DS-26 Herbicides: No mixing of herbicides will take place. X X Herbicides: Two herbicide mixtures are available for application. Mixture 1 DS-27 X (Chlorsulfuron + 2, 4-D) and mixture 2 (Dicamba + 2, 4-D). Herbicides: Herbicide treatments will include use of surfactants and dyes. DS-28 Surfactants increase the absorption of herbicide by the target weeds, and X X X dyes assist the applicator in efficiently treating target weeds. Herbicides: When applying herbicides within RCAs, from the High Water Mark outward to a distance of 25 feet, all directed spray must be done in a downward direction. In addition, when the height of a weed is greater than 36 inches, the weed will be laid on the ground and sprayed in a DS-29 downward direction. This will minimize herbicide drift and confine the X X X herbicide to the drop zone of the individual weed plant being treated. Beyond 25 feet within RCAs and outside of RCAs, herbicides will be applied by on-the-ground applicators directly spraying or wicking the target noxious weed. Spraying will be done in a downward direction to the extent possible. Herbicides: All herbicide spray tanks will be equipped with a pressure DS-30 X gauge to ensure that low pressure application of herbicides is achieved. DS-31 TES Plants: Vehicle-based herbicide application will not take place within 50 feet of any TES plant location. Hand spraying or non-herbicide X X treatment may be conducted. DS-32 Sensitive Plants: No spraying of herbicides within 50 feet of sensitive plant species. Wicking and Physical+ treatments may take place within 50 X feet of sensitive plants. DS-33 Threatened and Endangered Plants: Herbicide treatments will not take place within 100 feet of Threatened or Endangered plant locations, X however, non-herbicide treatments may be conducted. DS-34 Control of Drift or Herbicide Migration: All herbicide application will follow EPA approved label directions in regards to control of drift of herbicides during spraying. These directions have specific wind speeds and air X X X temperatures for application of each herbicide. In addition, applicators will utilize droplet size and spray pressure to insure droplets do not travel outside of the drip line target plant. DS-35 Safety and Health: All Personal Protective Equipment, required by state and federal regulations, for the specific type of treatment being X X X X X implemented, will be used during field operations.

42 Chapter 2—Alternati

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Code Design Standard 2 3 4 5 6 DS-36 Safety and Health: Signs regarding herbicide use will be placed at access points to treatment areas prior to initiating treatment. Signs will list X X X herbicides to be used, effective dates, and name and phone number of Forest contact. DS-37 Safety and Health: Herbicides will only be applied by trained and/or certified applicators in accordance with label instructions and applicable X X X federal and state pesticide laws. DS-38 Safety and Health: Klamathweed (St. Johnswort) will not be treated with X X X herbicides due to its use as a medicine by some.

Figure 2 - 2: Summary of Design Standards for Treatments in Relation to Surface Water

150’ 300’ High Water Distance from High Water Mark (Seasonally (Perennial Flowing Mark Streams) Streams) 10’ 25’ 100’ 1000’

Physical Methods

Aquatic Glyphosate

Alt. Glyphosate, Dicamba, Clopyralid, Triclopy r 2 & 4 Glyphosate, Dicamba, Clopyralid, Triclopyr

2, 4-D

Physical (+) Methods

Aquatic Glyphosate Alt. Glyphosate, Amine forms of 2, 4-D 6 See Chlorsulfuron, dicamba, clopyralid, triclopyr, tank mixes foot- note1 Ester forms of 2, 4-D, tank mixes

1 Under Alternative 6, Design Standard-19a applies in the areas under the jurisdiction of the Lahontan Water Quality Control Board (east side of the Warner Mountains; see Figure 3-2): No treatments would occur from the high-water mark for a distance of 10 feet; only aquatic glyphosate would be used from 10 to 100 feet of the high-water mark; further than 100 feet from the high-water mark, the other herbicides displayed in the Alternative may be applied. Under Alternative 6, Design Standard-11, in habitat for TES aquatic species, aquatic glyphosate is the only herbicide that may be used within 100 feet of the High Water Mark.

Alternative 1: No Action (Current Management) This Alternative is required by regulation (CFR 1502.8) and provides a baseline for comparison and analysis of effects. Under Current Management the Forest is implementing direction in the Forest Land and Resource Management Plan, the Sierra Nevada Forest Plan Amendment, and the Modoc National Forest Integrated Weed Management Strategy (Sylva 2005). Under this direction, a Noxious Weed Risk

Chapter 2 – Alternatives Description 43

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Assessment is completed for all projects planned on the Forest. The risk assessment assigns an expected risk level to proposed activities and identifies inventory, monitoring, and physical + weed-related actions to be included in project implementation. The use of herbicides has not been authorized for these weed related actions. On average, the Forest treats 20 to 30 acres per year with physical + methods covered under project environmental analysis. The Forest currently has no NEPA decision that encompasses the treatment and/or containment of all noxious weeds on the Forest. Under this Alternative, a Forest wide noxious weed control program would not be implemented.

Alternative 2: The Proposed Action This Proposed Action was created to respond to the Purpose and Need as described in Chapter 1. Under this Alternative, the Modoc National Forest proposes to treat noxious weeds on 536 existing sites comprising approximately 6,899 acres using herbicides and physical methods over a five-year time frame. Listed below are features of Alternative 2:  Treating between 300 to 1,500 acres annually for the next five years.  A total of 536 sites will be treated as detailed in Table 2-5.  Physical + methods would be used at 161 sites (31 acres) that are less than 10 feet from any water source, to include hand pulling, digging, grubbing, and hoeing.  Use of physical and/or herbicide methods on 333 sites (5,961 acres) located greater than 10 feet from any water source targeting non rhizomatous noxious weed species.  Twenty-six sites (2.4 acres) located greater than 10 feet from any water source and comprised of rhizomatous species will be treated with herbicides.  Sixteen sites of rhizomatous species that have some acreage within 10 feet of water will receive partial treatment. The acreage within 10 feet of water will not be treated and the acreage that is further than 10 feet of water would be treated with aquatic Glyphosate (904.3 acres).  Herbicides would only be applied using hand-held spray equipment with directed spray and wicking treatments.  Herbicides used would be clopyralid, dicamba, glyphosate, triclopyr, and 2, 4-D.  Design Standards applicable to this Alternative are listed in Table 2-4.  Retreatment of the treated sites until weeds are eliminated is not counted as new acres treated.  The annual combination of methods used would vary depending on noxious weed species, distance from water or other sensitive areas, and the most economical and efficient treatment methods available.

44 Chapter 2—Alternati

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 2 - 5. Alternative 2 Site-Specific Treatment Information 1

Rhizom / W/in W/in W/in Proposed Potential Total Amount Trmt. Distance Number Surveyed Species non 1000 ft 150 ft 300 ft Treatment of Herbicide Code to Water of Sites Acres Rhizom of H2O SMZ SMZ Acres Application2

Canada Thistle NT rhizom H2O<10ft Yes 5 0.45 0 NT H2O<10ft 0.23 0 Canada Thistle rhizom Yes No Yes 6 0.16 – 1.2 lbs ae Aquatic 0.32 0.32 PT -H H2O>10ft Glyphosate NT H2O<10ft 1.48 0 Canada Thistle rhizom Yes Yes Yes 4 4.4 – 32.96 lbs ae 8.79 8.79 PT -H H2O>10ft Aquatic Glyphosate NT H2O<10ft 0.04 0 Canada Thistle rhizom Yes Yes No 2 0.11 – 0.83 lbs ae 0.22 0.22 PT -H H2O>10ft Aquatic Glyphosate NT H2O<10ft 6.5 0 Dalmatian Toadflax rhizom Yes Yes Yes 2 444.45 – 3,333.33 lbs ae 888.89 888.89 PT -H H2O>10ft Aquatic Glyphosate NT H2O<10ft 0.29 0 Dalmatian Toadflax rhizom Yes Yes No 2 3.04 – 22.8 lbs ae 6.08 6.08 PT -H H2O>10ft Aquatic Glyphosate non 5 2.48 2.48 Diffuse Knapweed P rhizom H2O<10ft non 26 4.65 4.65 Dyer’s woad P rhizom H2O<10ft Klamathweed (a.k.a. rhizom 9 2.61 2.61 St. Johnswort) P H2O<10ft non 16 7.1 7.1 Mediterranean Sage P rhizom H2O<10ft non 4 0.45 0.45 Musk Thistle P rhizom H2O<10ft non 1 0.09 0.09 Plumeless Thistle P rhizom H2O<10ft

Chapter 2 – Alternatives Description 45

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Rhizom / W/in W/in W/in Proposed Potential Total Amount Trmt. Distance Number Surveyed Species non 1000 ft 150 ft 300 ft Treatment of Herbicide Code to Water of Sites Acres Rhizom of H2O SMZ SMZ Acres Application2

non 90 11.49 11.49 Scotch Thistle P rhizom H2O<10ft non 4 1.26 1.26 Spotted Knapweed P rhizom H2O<10ft non 3 0.27 0.27 Squarrose Knapweed P rhizom H2O<10ft non 3 0.27 0.27 Yellow Starthistle P rhizom H2O<10ft 0.06 - 0.15 lbs ae Clopyralid, or 0.15 – 1.22 Canada Thistle H rhizom H2O>10ft Yes No No 6 0.61 0.61 lbs ae Dicamba, or 0.31 - 2.29 lbs ae Glyphosate 0.05 - 0.38 lbs ae Canada Thistle H rhizom H2O>10ft Yes Yes Yes 1 0.1 0.1 Glyphosate 0.33 - 2.44 lbs ae Canada Thistle H rhizom H2O>10ft Yes No Yes 7 0.65 0.65 Glyphosate 0.02 - 0.05 lbs ae Clopyralid, or 0.05 – 0.4 Canada Thistle H rhizom H2O>10ft No No No 2 0.2 0.2 lbs ae Dicamba, or 0.1 – 0.75 lbs ae Glyphosate 0.04 - 0.3 lbs ae Dalmatian Toadflax H rhizom H2O>10ft Yes No Yes 1 0.08 0.08 Glyphosate 0.15 - 1.22 lbs ae Dalmatian Toadflax H rhizom H2O>10ft No No No 7 0.61 0.61 Dicamba, or 0.31 – 2.29 lbs ae Glyphosate 0.10 - 0.71 lbs ae Tall Whitetop H rhizom H2O>10ft Yes No No 2 0.19 0.19 Glyphosate 78.29 – 587.14 lbs ae Aquatic Glyphosate, or P or non Crupina H2O<10ft 1 158.65 158.65 15.66 – 39.14 lbs ae H rhizom Clopyralid, or 78.29 – 234.86 lbs ae Triclopyr

46 Chapter 2—Alternatives Description Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Rhizom / W/in W/in W/in Proposed Potential Total Amount Trmt. Distance Number Surveyed Species non 1000 ft 150 ft 300 ft Treatment of Herbicide Code to Water of Sites Acres Rhizom of H2O SMZ SMZ Acres Application2

0.44 - 1.74 lbs ae 2, 4-D, P or non or 0.22 – 1.74 lbs ae Diffuse Knapweed H2O>10ft No No No 3 0.87 0.87 H rhizom Dicamba, or 0.09 – 0.22 lbs ae Clopyralid 0.08 - 0.66 lbs ae P or non Diffuse Knapweed H2O>10ft Yes No No 3 0.33 0.33 Dicamba, or 0.03 -0.08 H rhizom lbs ae Clopyralid

P (0.02 - 0.18 lbs ae P or non Diffuse Knapweed H2O>10ft Yes No Yes 1 0.09 0.09 Dicamba, or 0.01 – 0.02 H rhizom lbs ae Clopyralid >SMZ)

P or non 1.06 – 8.74 lbs ae Dyer’s Woad H2O<10ft Yes Yes Yes 2 2.33 2.33 H rhizom Aquatic Glyphosate P or non 17.08 – 128.10 lbs ae Dyer’s Woad H2O<10ft Yes Yes No 5 34.16 34.16 H rhizom Aquatic Glyphosate P or non 0.51 – 4.5 lbs ae Aquatic Dyer’s woad H2O<10ft Yes No Yes 1 1.2 1.2 H rhizom Glyphosate P or non Dyer’s woad H2O>10ft No No No 10 2.8 2.8 1.4 - 5.6 lbs ae 2, 4-D H rhizom

P or non P (0.5 - 1.98 lbs ae 2, 4- Dyer’s woad H2O>10ft Yes Yes Yes 1 0.99 0.99 H rhizom D >1000 ft H2O)

P (2832.41 - 11329.62 P or non Dyer’s woad H2O>10ft Yes Yes No 3 5664.81 5664.81 lbs ae 2, 4-D >1000ft H rhizom H2O)

P or non P (0.49 - 1.94 lbs ae 2, Dyer’s woad H2O>10ft Yes No Yes 4 0.97 0.97 H rhizom 4-D >1000ft H2O)

Chapter 2 – Alternatives Description 47

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Rhizom / W/in W/in W/in Proposed Potential Total Amount Trmt. Distance Number Surveyed Species non 1000 ft 150 ft 300 ft Treatment of Herbicide Code to Water of Sites Acres Rhizom of H2O SMZ SMZ Acres Application2

P or non P (6.75 - 24.30 lbs ae 2, Dyer’s woad H2O>10ft Yes No No 12 12.15 12.15 H rhizom 4-D >1000ft H2O)

0.11 - 0.90 lbs ae P or non Mediterranean Sage H2O>10ft No No No 5 0.45 0.45 Dicamba, or 0.23 – 0.9 H rhizom lbs ae 2, 4-D P or non 0.30 - 2.36 lbs ae Mediterranean Sage H2O>10ft Yes No No 3 1.18 1.18 H rhizom Dicamba

P or non P (0.05 - 0.36 lbs ae Mediterranean Sage H2O>10ft Yes No Yes 2 0.18 0.18 H rhizom Dicamba > SMZ)

1.51 - 12.10 lbs ae Dicamba, or 0.61 – 1.51 P or non Musk Thistle H2O>10ft No No No 2 6.05 6.05 lbs ae Clopyralid, or 3.01 H rhizom – 22.69 lbs ae Glyphosate 0.11 - 0.90 lbs ae Dicamba, or 0.05 – 0.11 P or non Musk Thistle H2O>10ft Yes No No 5 0.45 0.45 lbs ae Clopyralid, or 3.01 H rhizom – 22.69 lbs ae Glyphosate P or non 1.18 - 8.85 lbs ae Musk Thistle H2O>10ft Yes No Yes 1 2.36 2.36 H rhizom Glyphosate

P or non 10.65 – 79.88 lbs ae Scotch Thistle H2O<10ft Yes Yes No 3 22.96 22.96 H rhizom Aquatic Glyphosate 1.49 - 11.9 lbs ae P or non Dicamba, or 2.98 – 11.9 Scotch Thistle H2O>10ft No No No 63 5.95 5.95 H rhizom lbs ae 2, 4-D, or 0.60 – 1.49 lbs ae Clopyralid

48 Chapter 2—Alternatives Description Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Rhizom / W/in W/in W/in Proposed Potential Total Amount Trmt. Distance Number Surveyed Species non 1000 ft 150 ft 300 ft Treatment of Herbicide Code to Water of Sites Acres Rhizom of H2O SMZ SMZ Acres Application2

7.93 – 63.44 lbs ae P or non Scotch Thistle H2O>10ft Yes No No 161 31.72 31.72 Dicamba, or 2.37 – 5.94 H rhizom lbs ae Clopyralid

P (0.79 - 6.34 lbs ae P or non Scotch Thistle H2O>10ft Yes No Yes 21 3.17 3.17 Dicamba, or 0.32 – 0.79 H rhizom lbs ae Clopyralid > SMZ)

P (0.32 - 2.52 lbs ae P or non Scotch Thistle H2O>10ft Yes Yes No 14 1.26 1.26 Dicamba, or 0.13 – 0.32 H rhizom lbs ae Clopyralid > SMZ)

P (0.1 - 0.8 lbs ae P or non Scotch Thistle H2O>10ft Yes Yes Yes 4 0.4 0.4 Dicamba, or 0.04 – 0.1 H rhizom lbs ae Clopyralid >SMZ)

1.28 - 5.12 lbs ae 2, 4-D, P or non or 0.64 – 5.12 lbs ae Spotted Knapweed H2O>10ft No No No 9 2.56 2.56 H rhizom Dicamba, or 0.26 – 0.64 lbs ae Clopyralid P (0.003 - 0.02 lbs ae P or non Dicamba, or 0.001 – Spotted Knapweed H2O>10ft Yes Yes No 1 0.01 0.01 H rhizom 0.003 lbs ae Clopyralid >SMZ) 0.05 - 0.18 lbs ae 2, 4-D, P or non or 0.02 – 0.18 lbs ae Squarrose Knapweed H2O>10ft Yes No No 1 0.09 0.09 H rhizom Dicamba, or 0.01 – 0.02 lbs ae Clopyralid

P (0.3 - 0.18 lbs ae P or non Squarrose Knapweed H2O>10ft Yes No Yes 1 0.09 0.09 Dicamba, or 0.01 – 0.02 H rhizom lbs ae Clopyralid >SMZ)

Chapter 2 – Alternatives Description 49

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Rhizom / W/in W/in W/in Proposed Potential Total Amount Trmt. Distance Number Surveyed Species non 1000 ft 150 ft 300 ft Treatment of Herbicide Code to Water of Sites Acres Rhizom of H2O SMZ SMZ Acres Application2

P or non 0.48 – 3.56 lbs ae Yellow Starthistle H2O<10ft Yes Yes Yes 1 1.03 1.03 H rhizom Aquatic Glyphosate 0.18 - 0.72 lbs ae 2, 4-D, or 0.09 – 0.72 lbs ae P or non Yellow Starthistle H2O>10ft No No No 4 0.36 0.36 Dicamba, or 0.18 – 0.54 H rhizom lbs ae Triclopyr, or 0.18 – 1.35 lbs ae Glyphosate 0.23 - 1.82 lbs ae P or non Dicamba, or 0.46 – 1.37 Yellow Starthistle H2O>10ft Yes No No 2 0.91 0.91 H rhizom lbs ae Triclopyr, or o.46 – 3.41 lbs ae Glyphosate

0.08 - 0.2 lbs ae Clopyralid; 2843.5 - 11371.2 lbs ae 2, 4-D; 13.46 – 105.7 lbs ae Total sites and acres being treated under this Alternative 536 6899.44 6899.44 Dicamba; 1.70 - 12.68 lbs ae Glyphosate; 560.23 – 4,203.04 lbs ae Aquatic Glyphosate 1. Explanation of treatment codes: P – hand pulling, hoeing, grubbing. P+ (physical plus) – hand pulling, hoeing, grubbing, clipping seed head or plant, trimming with string trimmer, covering with mulch or tarp. H – herbicide. NT – no treatment. LT – limited treatment. G – goat grazing. PT-H – partial treatment of site with herbicides. NT – not treated. Notes: The treatment method is listed for each site. Herbicide treatments are listed in order of preference according to Table 2-3, along with other effective herbicides that may be used. The most effective herbicide is in bold. 2. The total amount of herbicide application is based on the preferred herbicide for the given noxious weed species, and is based on the application rates listed in Table 2-14 (in bold). The potential amounts of the other herbicides available for use are also listed. The summary and total amount of potential application is based on the most effective herbicide that is available for use. The effects analysis section evaluates the effects of all herbicides available for use.

50 Chapter 2—Alternatives Description Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Alternative 3 Alternative 3 responds to Significant Issues 1, 2, and 4; which concern anticipated negative effects of herbicide use. Alternative 3 does not include the use of herbicides. Under this Alternative, the Modoc National Forest proposes to treat noxious weeds on a total of 494 existing sites comprising approximately 5,993 acres through physical methods over a five-year time frame. Listed below are features of Alternative 3:  Treating between 300 to 1,500 acres annually for the next 10 years,  494 sites (5,993 acres) would be treated using physical methods, to include hand pulling, digging, grubbing, and hoeing.  47 sites (916 acres) would not be treated as these sites are composed of rhizomatous species, and physical methods are ineffective in treating rhizomatous species.  A description is given in Table 2-6.  Re-treatment of the treated sites until weeds are eliminated is not counted as new acres treated.

Table 2 - 6. Alternative 3 Site-Specific Treatment Information1

Proposed Trmt. Distance Rhizom / Number Surveyed Species Treatment Code to Water non Rhizom of Sites Acres Acres Canada Thistle NT H2O<10ft rhizom 33 13.09 0 Dalmatian Toadflax NT H2O>10ft rhizom 12 902.45 0 Tall Whitetop NT H2O>10ft rhizom 2 0.19 0 Summary for NT Treatment 47 915.73 0 Crupina P H2O<10ft non rhizom 1 158.65 158.65 Diffuse Knapweed P H2O<10ft non rhizom 5 2.48 2.48 Diffuse Knapweed P H2O>10ft non rhizom 7 1.29 1.29 Dyer’s woad P H2O>10ft non rhizom 31 5682.71 5682.71 Dyer’s woad P H2O<10ft non rhizom 33 42.58 42.58 Klamath Weed P H2O<10ft non rhizom 9 2.61 2.61 Mediterranean Sage P H2O<10ft non rhizom 15 6.44 6.44 Mediterranean Sage P H2O>10ft non rhizom 11 2.47 2.47 Musk Thistle P H2O<10ft non rhizom 4 0.45 0.45 Musk Thistle P H2O>10ft non rhizom 8 8.86 8.86 Plumeless Thistle P H2O<10ft non rhizom 1 0.09 0.09 Scotch Thistle P H2O<10ft non rhizom 89 42.05 42.05 Scotch Thistle P H2O>10ft non rhizom 251 35.17 35.17 Spotted Knapweed P H2O<10ft non rhizom 4 1.26 1.26 Spotted Knapweed P H2O>10ft non rhizom 10 2.57 2.57 Squarrose Knapweed P H2O<10ft non rhizom 3 0.27 0.27 Squarrose Knapweed P H2O>10ft non rhizom 2 0.18 0.18

Chapter 2 – Alternatives Description 51

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Proposed Trmt. Distance Rhizom / Number Surveyed Species Treatment Code to Water non Rhizom of Sites Acres Acres Yellow Starthistle P H2O<10ft non rhizom 4 1.3 1.3 Yellow Starthistle P H2O>10ft non rhizom 6 1.27 1.27 Summary for physical treatment: Physical methods can include hand pulling, hoeing, and/or 494 5992.7 5992.7 grubbing.

Total sites and acres considered in this Alternative 541 6908.43 5992.7

Total sites and acres being treated under this Alternative 494 5992.7 5992.7

1. Explanation of treatment codes: P – hand pulling, hoeing, grubbing. P+ (physical plus) – hand pulling, hoeing, grubbing, clipping seed head or plant, trimming with string trimmer, covering with mulch or tarp. H – herbicide. NT – no treatment. LT – limited treatment. G – goat grazing. PT-H – partial treatment of site with herbicides. NT – not treated.

Alternative 4 Alternative 4 responds to Significant Issue 3, which focuses on providing flexibility in physical and herbicide treatment methods for current occurrences and expanding or new infestations of noxious weeds. Alternative 4 includes an Early Detection - Rapid Response Strategy not included in Alternatives 2 and 3. Under this Alternative, the Modoc National Forest proposes to treat noxious weeds on a total of 536 existing sites comprising approximately 6,899 acres through physical and herbicide methods over a ten-year time frame. Listed below are features of Alternative 4:  Treating a total of 7,099 acres at 536 sites over the next ten years (average annual 500- 1,500). This includes 200 acres treated through Early Detection-Rapid Response.  Physical treatment methods would be utilized at 161 sites (31 acres) that are less than 10 feet from any water source.  Use of physical and/or herbicide methods on 333 sites (5,961 acres) located greater than 10 feet from any water source and with non-rhizomatous noxious weed species.  26 sites (2.4 acres) located greater than 10 feet from any water source and composed of rhizomatous species would be treated with herbicides.  16 sites of rhizomatous species that have some acreage within 10 feet of water would receive partial treatment. The acreage within 10 feet of water would not be treated, and the acreage that is further then 10 feet of water would be treated with aquatic Glyphosate (904.3 acres).  No treatment would occur at 5 sites (9 acres). These sites are composed of rhizomatous species and are within 10 feet of water.  Herbicides would only be applied using hand-held spray equipment with directed spray and wicking treatments.  Herbicide used would be clopyralid, dicamba, glyphosate, triclopyr, and 2-4-D.  An Early Detection - Rapid Response Strategy would be implemented in this Alternative. This strategy will provide the opportunity to treat new sites of the identified species that have developed, existing sites that have expanded, and new sites of new noxious weeds using the same treatments as outlined for the noxious weed species identified provided

52 Chapter 2 – Alternatives Description Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

that environmental effects are within the Design Standards, and effects analyses are reflected in this FEIS. Proposed treatment under Early Detection – Rapid Response would be capped at no more than 100 acres per year, and no more than a total of 200 acres. The rationale for this cap is to provide limited flexibility to treat new and/or expanding weed sites while remaining within the range of effects as displayed in this analysis.  A description is given in Table 2-7.  Design Standards applicable to this Alternative are listed in Table 2-4.  Retreatment of the treated sites until weeds are eliminated is not counted as new acres treated.

Chapter 2 – Alternatives Description 53

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 2 - 7. Alternative 4 Site-Specific Treatment Information1

Rhizom / W/in W/in W/in Proposed Potential Total Amount Trmt. Distance Number Surveyed Species non 1000ft 150 ft 300 ft Treatment of Herbicide Code to Water of Sites Acres Rhizom H2O SMZ SMZ Acres Application2

Canada Thistle NT rhizom H2O<10ft Yes 5 0.45 0

NT H2O<10ft 0.23 0 Canada Thistle rhizom Yes No Yes 6 0.16 – 1.2 lbs ae Aquatic 0.32 0.32 PT-H H2O>10ft Glyphosate NT H2O<10ft 1.48 0 Canada Thistle rhizom Yes Yes Yes 4 4.4 – 32.96 lbs ae Aquatic 8.79 8.79 PT-H H2O>10ft Glyphosate NT H2O<10ft 0.04 0 Canada Thistle rhizom Yes Yes No 2 0.11 – 0.83 lbs ae Aquatic 0.22 0.22 PT-H H2O>10ft Glyphosate NT H2O<10ft 6.5 0 Dalmatian Toadflax rhizom Yes Yes Yes 2 444.45 – 3,333.33 lbs ae 888.89 888.89 PT-H H2O>10ft Aquatic Glyphosate NT H2O<10ft 0.29 0 Dalmatian Toadflax rhizom Yes Yes No 2 3.04 – 22.8 lbs ae Aquatic 6.08 6.08 PT-H H2O>10ft Glyphosate Diffuse Knapweed P non rhizom H2O<10ft 5 2.48 2.48

Dyer’s woad P non rhizom H2O<10ft 26 4.65 4.65 Klamath Weed P non rhizom H2O<10ft 9 2.61 2.61

Mediterranean Sage P non rhizom H2O<10ft 16 7.1 7.1 Musk Thistle P non rhizom H2O<10ft 4 0.45 0.45 Plumeless Thistle P non rhizom H2O<10ft 1 0.09 0.09 Scotch Thistle P non rhizom H2O<10ft 90 11.49 11.49 Spotted Knapweed P non rhizom H2O<10ft 4 1.26 1.26 Squarrose Knapweed P non rhizom H2O<10ft 3 0.27 0.27 Yellow Starthistle P non rhizom H2O<10ft 3 0.27 0.27

54 Chapter 2 – Alternatives Description

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Rhizom / W/in W/in W/in Proposed Potential Total Amount Trmt. Distance Number Surveyed Species non 1000ft 150 ft 300 ft Treatment of Herbicide Code to Water of Sites Acres Rhizom H2O SMZ SMZ Acres Application2 0.06 - 0.15 lbs ae Clopyralid, or 0.15 – 1.22 Canada Thistle H rhizom H2O>10ft Yes No No 6 0.61 0.61 lbs ae Dicamba, or 0.31 – 2.29 lbs ae Glyphosate 0.05 - 0.38 lbs ae Canada Thistle H rhizom H2O>10ft Yes Yes Yes 1 0.1 0.1 Glyphosate 0.33 - 2.44 lbs ae Canada Thistle H rhizom H2O>10ft Yes No Yes 7 0.65 0.65 Glyphosate 0.02 - 0.05 lbs ae Clopyralid, or 0.05 – 0.40 Canada Thistle H rhizom H2O>10ft No No No 2 0.2 0.2 lbs ae Dicamba, or 0.10 – 0.75 lbs ae Glyphosate 0.04 - 0.3 lbs ae Dalmatian Toadflax H rhizom H2O>10ft Yes No Yes 1 0.08 0.08 Glyphosate 0.15 - 1.22 lbs ae Dalmatian Toadflax H rhizom H2O>10ft No No No 7 0.61 0.61 Dicamba, or 0.31 – 2.29 lbs ae Glyphosate 0.10 - 0.71 lbs ae Tall Whitetop H rhizom H2O>10ft Yes No No 2 0.19 0.19 Glyphosate 78.29 – 587.14 lbs ae Aquatic Glyphosate, or P or Crupina non rhizom H2O<10ft 1 158.65 158.6515.66 – 39.14 lbs ae H Clopyralid, or 78.29 – 234.86 lbs ae Triclopyr 0.44 - 1.74 lbs ae 2, 4-D, P or or 0.22 – 1.74 lbs ae Diffuse Knapweed non rhizom H2O>10ft No No No 3 0.87 0.87 H Dicamba, or 0.09 – 0.22 lbs ae Clopyralid 0.08 - 0.66 lbs ae P or Diffuse Knapweed non rhizom H2O>10ft Yes No No 3 0.33 0.33 Dicamba, or 0.03 – 0.08 H lbs ae Clopyralid P (0.02 - 0.18 lbs ae P or Diffuse Knapweed non rhizom H2O>10ft Yes No Yes 1 0.09 0.09 Dicamba, or 0.01 – 0.02 H lbs ae Clopyralid >SMZ) P or 1.06 – 8.74 lbs ae Aquatic Dyer’s woad non rhizom H2O<10ft Yes Yes Yes 2 2.33 2.33 H Glyphosate P or 17.08 – 128.10 lbs ae Dyer’s woad non rhizom H2O<10ft Yes Yes No 5 34.16 34.16 H Aquatic Glyphosate

Chapter 2 – Alternatives Description 55

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Rhizom / W/in W/in W/in Proposed Potential Total Amount Trmt. Distance Number Surveyed Species non 1000ft 150 ft 300 ft Treatment of Herbicide Code to Water of Sites Acres Rhizom H2O SMZ SMZ Acres Application2 P or 0.51 – 4.5 lbs ae Aquatic Dyer’s woad non rhizom H2O<10ft Yes No Yes 1 1.2 1.2 H Glyphosate P or Dyer’s woad non rhizom H2O>10ft No No No 10 2.8 2.8 1.4 - 5.6 lbs ae 2, 4-D H P or P (0.5 - 1.98 lbs ae 2, 4-D Dyer’s woad non rhizom H2O>10ft Yes Yes Yes 1 0.99 0.99 H >1000 ft H2O)

P or P (2832.41 - 11329.62 lbs Dyer’s woad non rhizom H2O>10ft Yes Yes No 3 5664.81 5664.81 H ae 2, 4-D >1000ft H2O)

P or P (0.49 - 1.94 lbs ae 2, 4- Dyer’s woad non rhizom H2O>10ft Yes No Yes 4 0.97 0.97 H D >1000ft H2O)

P or P (6.75 - 24.30 lbs ae 2, Dyer’s woad non rhizom H2O>10ft Yes No No 12 12.15 12.15 H 4-D >1000ft H2O) 0.11 - 0.90 lbs ae P or Mediterranean Sage non rhizom H2O>10ft No No No 5 0.45 0.45 Dicamba, or 0.23 – 0.9 lbs H ae 2, 4-D P or 0.30 - 2.36 lbs ae Mediterranean Sage non rhizom H2O>10ft Yes No No 3 1.18 1.18 H Dicamba

P or P (0.05 - 0.36 lbs ae Mediterranean Sage non rhizom H2O>10ft Yes No Yes 2 0.18 0.18 H Dicamba > SMZ) 1.51 - 12.10 lbs ae P or Dicamba, or 0.61 – 1.51 Musk Thistle non rhizom H2O>10ft No No No 2 6.05 6.05 H lbs ae Clopyralid, or 3.03 – 22.69 lbs ae Glyphosate 0.11 - 0.90 lbs ae P or Dicamba, or 0.05 – 0.11 Musk Thistle non rhizom H2O>10ft Yes No No 5 0.45 0.45 H lbs ae Clopyralid, or 0.23 – 1.69 lbs ae Glyphosate P or 1.18 - 8.85 lbs ae Musk Thistle non rhizom H2O>10ft Yes No Yes 1 2.36 2.36 H Glyphosate

P or 10.65 – 79.88 lbs ae Scotch Thistle non rhizom H2O<10ft Yes Yes No 3 22.96 22.96 H Aquatic Glyphosate

56 Chapter 2 – Alternatives Description

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Rhizom / W/in W/in W/in Proposed Potential Total Amount Trmt. Distance Number Surveyed Species non 1000ft 150 ft 300 ft Treatment of Herbicide Code to Water of Sites Acres Rhizom H2O SMZ SMZ Acres Application2 1.49 - 11.9 lbs ae P or Dicamba, or 2.98 – 11.9 Scotch Thistle non rhizom H2O>10ft No No No 63 5.95 5.95 H lbs ae 2, 4-D, or 0.60 – 1.49 lbs ae Clopyralid 7.93 – 63.44 lbs ae P or Scotch Thistle non rhizom H2O>10ft Yes No No 161 31.72 31.72 Dicamba, or 2.37 – 5.94 H lbs ae Clopyralid P (0.79 - 6.34 lbs ae P or Scotch Thistle non rhizom H2O>10ft Yes No Yes 21 3.17 3.17 Dicamba, or 0.32 – 0.79 H lbs ae Clopyralid > SMZ) P (0.32 - 2.52 lbs ae P or Scotch Thistle non rhizom H2O>10ft Yes Yes No 14 1.26 1.26 Dicamba, or 0.13 – 0.32 H lbs ae Clopyralid > SMZ) P (0.1 - 0.8 lbs ae P or Scotch Thistle non rhizom H2O>10ft Yes Yes Yes 4 0.4 0.4 Dicamba, or 0.04 – 0.10 H lbs ae Clopyralid >SMZ) 1.28 - 5.12 lbs ae 2, 4-D, P or or 0.64 – 5.12 lbs ae Spotted Knapweed non rhizom H2O>10ft No No No 9 2.56 2.56 H Dicamba, or 0.26 – 0.64 lbs ae Clopyralid P (0.003 - 0.02 lbs ae P or Spotted Knapweed non rhizom H2O>10ft Yes Yes No 1 0.01 0.01 Dicamba, or 0.001 – 0.003 H lbs ae Clopyralid >SMZ) 0.05 - 0.18 lbs ae 2, 4-D, P or or 0.02 – 0.18 lbs ae Squarrose Knapweed non rhizom H2O>10ft Yes No No 1 0.09 0.09 H Dicamba, or 0.01 – 0.02 lbs ae Clopyralid P (0.3 - 0.18 lbs ae P or Squarrose Knapweed non rhizom H2O>10ft Yes No Yes 1 0.09 0.09 Dicamba, or 0.01 – 0.02 H lbs ae Clopyralid >SMZ)

P or 0.48 – 3.56 lbs ae Aquatic Yellow Starthistle non rhizom H2O<10ft Yes Yes Yes 1 1.03 1.03 H Glyphosate 0.18 - 0.72 lbs ae 2, 4-D, or 0.09 – 0.72 lbs ae P or Yellow Starthistle non rhizom H2O>10ft No No No 4 0.36 0.36 Dicamba, 0.18 – 0.54 lbs H ae Triclopyr, or 0.18 – 1.35 lbs ae Glyphosate

Chapter 2 – Alternatives Description 57

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Rhizom / W/in W/in W/in Proposed Potential Total Amount Trmt. Distance Number Surveyed Species non 1000ft 150 ft 300 ft Treatment of Herbicide Code to Water of Sites Acres Rhizom H2O SMZ SMZ Acres Application2 0.23 - 1.82 lbs ae P or Dicamba, or 0.46 – 1.37 Yellow Starthistle non rhizom H2O>10ft Yes No No 2 0.91 0.91 H lbs ae Triclopyr, or 0.46 - 3.41 lbs ae Glyphosate 0.08 - 0.2 lbs ae Clopyralid; 2843.5 - 11371.2 lbs ae 2, 4-D; 13.46 – 105.7 lbs ae Total sites and acres being treated under this Alternative 536 6899.44 7099.44 Dicamba; 1.70 - 12.68 lbs ae Glyphosate; 560.23 – 4,203.04 lbs ae Aquatic Glyphosate 1. Explanation of treatment codes: P – hand pulling, hoeing, grubbing. P+ (physical plus) – hand pulling, hoeing, grubbing, clipping seed head or plant, trimming with string trimmer, covering with mulch or tarp. H – herbicide. NT – no treatment. LT – limited treatment. G – goat grazing. PT-H – partial treatment of site with herbicides. NT – not treated. Notes: The treatment method is listed for each site. Herbicide treatments are listed in order of preference according to Table 2-3 along with other effective herbicides that may be used. The most effective herbicide is in bold. 2. The total amount of herbicide application is based on the preferred herbicide for the given noxious weed species, and is based on the application rates listed in Table 2-14 (in bold). The potential amounts of the other herbicides available for use are also listed. The summary and total amount of potential application is based on the most effective herbicide that is available for use. The effects analysis section evaluates the effects of all herbicides available for use.

58 Chapter 2 – Alternatives Description

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Alternative 5 Alternative 5 responds to comments on the DEIS to provide a non-herbicide Alternative that contains additional non-herbicide treatments, and an Early Detection - Rapid Response Strategy. Alternative 5 responds to Significant Issues 1, 2, 3, and 4. Alternative 5 does not include the use of herbicides. It includes goat grazing and physical treatment methods that are not included in Alternatives 2 and 3. Alternative 5 includes an Early Detection - Rapid Response Strategy, which responds to new species and new sites using treatment methods analyzed in this FEIS. During analysis of responses to the DEIS, the Agency determined that it was economically prohibitive to treat the entire 5,658 acre site number DH013ISTI of dyer's woad with either herbicide or physical+ methods (referred to as “limited treatment”). Under Alternative, 5 only the perimeter of this site would be treated. Therefore, under Alternative 5, the Modoc National Forest proposes to treat noxious weeds on a total of 541 existing sites comprising approximately 280 acres through Physical+ methods over a ten year time frame. Listed below are features of Alternative 5:  Use non-herbicide methods to eradicate, control, or contain approximately 480 acres at 541 sites of noxious weed species. This includes 200 acres treated under Early Detection- Rapid Response.  5 sites (41 acres) may potentially be treated using goat grazing. These sites may alternatively be treated using Physical+ methods.  527 sites (139 acres) would be treated using physical + methods, to include hand pulling, grubbing, hoeing, clipping (including use of hand-held string trimmers), and use of mulch and tarps.  9 sites (100 acres) would receive limited treatment to contain infestations. These sites include the large dyer’s woad site (5,658 acres), one crupina site (159 acres) and 7 sites of rhizomatous noxious weeds (913 acres). The common crupina site is part of a larger site on adjacent private lands (an additional 586 acres). Limited treatment of these sites is expected to be 100 acres. Design Standards have been implemented in determining the treatment method that these acres would receive. These sites are made up of rhizomatous species and are greater than 0.10 acre. Physical+ methods are not as effective as herbicides in treating rhizomatous species; thus, the treatment goal would be only containment of the current infestation.  An Early Detection - Rapid Response Strategy would be implemented in this Alternative. This strategy would provide the opportunity to treat new sites of the identified species that have developed, existing sites that have expanded, and new sites of new noxious weeds using the same treatments as outlined for the noxious weed species identified provided that environmental effects are within the Design Standards, and effects analyses are reflected in this FEIS. Proposed treatment under Early Detection – Rapid Response would be capped at 100 acres per year or 200 acres total over the life of the Alternative. The rationale for this cap is to provide limited flexibility to treat new and/or expanding weed sites, while remaining within the range of effects as displayed in this analysis.  A description is given in Table 2-8.  Design standards applicable to this Alternative are listed in Table 2-4.  Retreatment of the treated sites until weeds are eliminated is not counted as new acres treated.

Chapter 2 – Alternatives Description 59

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 2 - 8. Alternative 5 Site-Specific Treatment Information1

Proposed Trmt. Distance Rhizom / Number Surveyed Species Treatment Code to Water non Rhizom of Sites Acres Acres Musk Thistle G H2O>10ft non rhizom 1 5.21 5.21 Scotch Thistle G H2O>10ft non rhizom 4 36 36 Summary for Goat Grazing Treatment 5 41.21 41.21 These sites may also be treated using physical +. Canada Thistle LT H2O>10ft rhizom 3 10.31 1 Crupina LT H2O<10ft non rhizom 1 158.65 2 Dalmatian Toadflax LT H2O<10ft rhizom 4 901.76 13 Dyer’s woad LT H2O>10ft non rhizom 1 5657.75 84 Summary for LT Treatment Limited treatment will consist of physical + treatments along major travel ways and around the perimeter of these sites to reduce potential for spread of and to 9 6728.47 100 contain the infestations. The estimated number of acres treated would be 100 acres. This acreage was chosen due to budgetary concerns and the acreage is estimated proportionally to the size of each of the nine sites. Canada Thistle P+ H2O>10ft rhizom 25 2.32 2.32 Canada Thistle P+ H2O<10ft rhizom 5 0.46 0.46 Dalmatian Toadflax P+ H2O>10ft rhizom 8 0.69 0.69 Diffuse Knapweed P+ H2O<10ft non rhizom 5 2.48 2.48 Diffuse Knapweed P+ H2O>10ft non rhizom 7 1.29 1.29 Dyer’s woad P+ H2O<10ft non rhizom 33 42.58 42.58 Dyer’s woad P+ H2O>10ft non rhizom 30 24.96 24.96 Klamath Weed P+ H2O<10ft non rhizom 9 2.61 2.61 Mediterranean P+ H2O<10ft non rhizom 15 6.44 6.44 Sage Mediterranean P+ H2O>10ft non rhizom 11 2.47 2.47 Sage Musk Thistle P+ H2O<10ft non rhizom 4 0.45 0.45 Musk Thistle P+ H2O>10ft non rhizom 7 3.65 3.65 Plumeless Thistle P+ H2O<10ft non rhizom 1 0.09 0.09 Scotch Thistle P+ H2O<10ft non rhizom 86 15.77 15.77 Scotch Thistle P+ H2O>10ft non rhizom 250 25.45 25.45 Spotted Knapweed P+ H2O<10ft non rhizom 4 1.26 1.26 Spotted Knapweed P+ H2O>10ft non rhizom 10 2.57 2.57 Squarrose P+ H2O<10ft non rhizom 3 0.27 0.27 Knapweed Squarrose P+ H2O>10ft non rhizom 2 0.18 0.18 Knapweed Tall Whitetop P+ H2O>10ft rhizom 2 0.19 0.19 Yellow Starthistle P+ H2O<10ft non rhizom 4 1.3 1.3 Yellow Starthistle P+ H2O>10ft non rhizom 6 1.27 1.27

60 Chapter 2 – Alternatives Description

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Proposed Trmt. Distance Rhizom / Number Surveyed Species Treatment Code to Water non Rhizom of Sites Acres Acres Summary for P+ treatment P+ Treatments can include hand pulling, hoeing, 527 138.75 138.75 grubbing, clipping seed head or plant, hand-held string trimmer, and/or mulching/tarping.

Total sites and acres considered in this Alternative 541 6908.43 279.96

Early Detection – Rapid Response 200

Total sites and acres being treated under this Alternative 541 6908.43 479.96

1. Explanation of treatment codes: P – hand pulling, hoeing, grubbing. P+ (physical plus) – hand pulling, hoeing, grubbing, clipping seed head or plant, trimming with string trimmer, covering with mulch or tarp. H – herbicide. NT – no treatment. LT – limited treatment. G – goat grazing. PT-H – partial treatment of site with herbicides. NT – not treated.

Alternative 6 Alternative 6 responds to comments on the DEIS that requested the consideration of additional herbicide formulations, while treating fewer acres with herbicides; and the consideration of additional Physical+ treatment methods. Alternative 6 responds to Significant Issues 1, 2, 3 and 4. It provides the opportunity to use three additional herbicide formulations not included in Alternatives 2 and 4. Alternative 6 also includes the additional Physical+ treatment methods and the Early Detection - Rapid Response Strategy included in Alternative 5. During analysis of responses to the DEIS, the Agency determined that it was economically prohibitive to treat the entire 5,658-acre site DH013ISTI of dyer's woad with either herbicide or Physical+ methods. Under Alternative 6, only the perimeter of this site would be treated. Therefore under Alternative 6, the Modoc National Forest proposes to treat noxious weeds on a total of 541 existing sites comprising approximately 341 acres through Physical+, goat grazing, and herbicide methods over a 10-year time frame. Listed below are features of Alternative 6. Alternative 6 would:  Treat 541 sites on 541 acres (includes 200 acres treated through Early Detection-Rapid Response), for 14 currently identified species of noxious weeds.  Treat 116 inventoried sites (19 acres) using Physical + methods, including hand pulling, grubbing, hoeing, clipping, string trimmers, and placing of mulch or tarps.  Treat 371 inventoried sites (116 acres) using the physical + methods described above, with herbicides, or both.  Treat 46 inventoried sites (65 acres) using herbicide methods.  Treat 5 inventoried sites (41 acres) using goat grazing or Physical+ and/or herbicide methods.  Treat 3 inventoried sites (5,658 acre dyer’s woad site, 159 acre common crupina site, and 850 acre Dalmatian toadflax site) using limited treatment methods along major travel

Chapter 2 – Alternatives Description 61

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

ways to reduce potential for spread. These sites would be treated around the borders to contain the infestations. The estimated area treated would be 100 acres along the borders. These treatment acres are estimated proportionally to the size of the current inventoried acres for these three sites.  Herbicides authorized for specific weeds and locations are chlorsulfuron, clopyralid, dicamba, glyphosate, triclopyr, 2-4-D, and two herbicide mixtures (mix 1: chlorsulfuron + 2, 4-D, and mix 2: dicamba + 2, 4-D).  Herbicides would only be applied using hand-held spray equipment with directed spray and wicking treatments.  Implement an Early Detection - Rapid Response Strategy. This strategy provides the opportunity to treat new sites of the 14 currently identified noxious weed species, new acres of weed expansion at existing sites, and occurrences of new noxious weed species if they can be effectively treated using the methods and Design Standards authorized under Alternative 6. Acres treated under Early Detection - Rapid Response would be capped at no more than 100 acres treated in any given year, and no more than 200 acres in total.

62 Chapter 2 – Alternatives Description

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 2 - 9. Alternative 6 Site-Specific Treatment Information1

>10ft Rhizom Proposed Trmt. Distance >25ft and >100ft Number Surveyed Potential Total Amount Species / non Trmt. Code to Water H2O <100ft H2O of Sites Acres of Herbicide Application2 Rhizom Acres H2O 3.9 - 5.21 oz ai Chlorsulfuron, or 1.30 – 10.42 lbs ae Dicamba, or 2.61 – 10.42 lbs ae 2, 4-D, or 0.52 – 1.30 lbs ae G or non Musk Thistle H2O>10ft Yes 1 5.21 5.21 Clopyralid, or Mix 1(3.91 – H rhizom 5.21 oz ai Chlorsulfuron + 2.61 – 7.82 lbs ae 2, 4-D), or Mix 2 (1.3 – 5.21 oz ai Dicamba + 2.61 – 7.82 lbs ae 2, 4-D) P+ (5.3-42.6 lbs ae Dicamba, or 10.65 – 42.58 lbs ae 2, 4-D, or 2.13 – 5.32 lbs ae Clopyralid, or G or non Mix 1 (15.97 – 21.29 oz ai Scotch Thistle P+ or H2O<10ft 2 21.29 21.29 rhizom Chlorsulfuron + 10.65 – H 31.94 lbs ae 2, 4-D) or Mix 2 (5.32 – 21.29 oz ai Dicamba + 10.65 – 31.94 lbs ae 2, 4-D) >10ft H2O) 3.8 - 29.4 lbs ae Dicamba, or 7.36 – 29.42 lbs ae 2, 4- D, or 1.47 – 3.7 lbs ae Clopyralid, or Mix 1 (11.03 G or non Scotch Thistle H2O>10ft Yes 2 14.71 14.71 – 14.71 oz ai Chlorsulfuron H rhizom + 7.36 – 22.07 lbs ae 2, 4- D), or Mix 2 (3.68 – 14.71 oz ai Dicamba + 7.36 – 22.07 lbs ae 2, 4-D) Summary for Goat Grazing Treatment 3.9 - 5.21 oz ai 5 41.21 41.21 These sites may also be treated with herbicides and/or P+ methods. Chlorsulfuron, 9.1 - 72 lbs

Chapter 2 – Alternatives Description 63

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

>10ft Rhizom Proposed Trmt. Distance >25ft and >100ft Number Surveyed Potential Total Amount Species / non Trmt. Code to Water H2O <100ft H2O of Sites Acres of Herbicide Application2 Rhizom Acres H2O ae Dicamba 1.5 - 11.25 lbs ae Aquatic Glyphosate, or Mix 2 (2.25 non – 3 oz ai Dicamba + 1.5 – Crupina LT H2O<10ft 1 158.65 3 rhizom 4.5 lbs ae 2, 4-D), or 0.3 – 0.75 lbs ae Clopyralid, or 1.5 – 4.5 lbs ae Triclopyr

3.25 - 26 lbs ae Dicamba, Dalmatian LT rhizom H2O<10ft Yes 1 850.82 13 or 6.5 – 48.75 lbs ae Toadflax Glyphosate

48.5 - 194 lbs ae 2, 4-D, or non 72.75 – 97 oz ai Dyer’s Woad LT H2O>10ft Yes 1 5657.75 97 rhizom Chlorsulfuron, or 48.5 – 194 lbs ae 2, 4-D Summary for LT Treatment Limited treatment will consist of herbicide treatments along major travel ways and around the perimeter of these sites to reduce potential for spread of and to 1.5 - 11.25 lbs ae Aquatic Glyphosate, 3.25 - 26 lbs contain the infestations. The estimated number of acres treated would be 100 3 6667.22 100 acres. This acreage was chosen due to budgetary concerns and the acreage is ae Dicamba; 42 - 164 lbs estimated proportionally to the size of each of the three sites. ae 2, 4-D

Diffuse non H2O<10ft 2 0.18 0.18 Knapweed P+ rhizom non H2O<10ft 22 2.3 2.3 Dyer’s woad P+ rhizom non H2O>10ft 1 0.99 0.99 Dyer’s woad P+ rhizom non H2O<10ft 9 2.61 2.61 Klamath Weed P+ rhizom Mediterranean non H2O<10ft 13 2.07 2.07 Sage P+ rhizom non H2O<10ft 2 0.18 0.18 Musk Thistle P+ rhizom

64 Chapter 2—Alternatives Description Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

>10ft Rhizom Proposed Trmt. Distance >25ft and >100ft Number Surveyed Potential Total Amount Species / non Trmt. Code to Water H2O <100ft H2O of Sites Acres of Herbicide Application2 Rhizom Acres H2O Plumeless non H2O<10ft 1 0.09 0.09 Thistle P+ rhizom non H2O<10ft 57 8.93 8.93 Scotch Thistle P+ rhizom non H2O>10ft 1 1.42 1.42 Scotch Thistle P+ rhizom Spotted non H2O<10ft 3 0.27 0.27 Knapweed P+ rhizom Squarrose non H2O<10ft 3 0.27 0.27 Knapweed P+ rhizom Yellow non H2O<10ft 2 0.18 0.18 Starthistle P+ rhizom

Summary for physical + Treatment Physical + methods can include hand pulling, hoeing, grubbing, clipping of the 116 19.49 19.49 seed head or plant, mowing with string trimmers, and/or mulching/tarping.

1 - 1.3 oz ai Chlorsulfuron, or 0.13 – 0.33 lbs ae Clopyralid, or 0.33 – 2.6 lbs ae Dicamba, or 0.65 – 4.88 lbs ae Glyphosate, or Canada Thistle H rhizom H2O>10ft Yes 14 1.3 1.3 Mix 1 (0.98 – 1.3 oz ai Chlorsulfuron + 0.65 – 1.95 lbs ae 2, 4-D), or Mix 2 (0.33 – 1.3 oz ai Dicamba + 0.65 – 1.95 lbs ae 2, 4- D) 0.33 - 0.44 oz ai Chlorsulfuron, or 0.04 – 0.11 lbs ae Clopyralid, or 0.11 – 0.88 lbs ae Canada Thistle H rhizom H2O>10ft Yes 4 0.44 0.44 Dicamba, or Mix 1 (0.33 – 0.44 oz ai Chlorsulfuron + 0.22 – 0.66 lbs ae 2, 4-D), or Mix 2 (0.33 – 1.3 oz ai

Chapter 2 – Alternatives Description 65

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

>10ft Rhizom Proposed Trmt. Distance >25ft and >100ft Number Surveyed Potential Total Amount Species / non Trmt. Code to Water H2O <100ft H2O of Sites Acres of Herbicide Application2 Rhizom Acres H2O Dicamba + 0.65 – 1.95 lbs ae 2, 4-D) 5.68 - 42.56 lbs ae Aquatic Canada Thistle H rhizom H2O<10ft 15 11.35 11.35 Glyphosate 0.17 - 1.4 lbs ae Dicamba, Dalmatian H rhizom H2O>10ft Yes 8 0.69 0.69 or 0.35 – 2.59 lbs ae Toadflax Glyphosate 25.47 – 191.03 lbs ae Dalmatian Aquatic Glyphosate, or H rhizom H2O<10ft 3 50.94 50.94 Toadflax 12.74 - 101.88 lbs ae Dicamba (>25 ft H2O) 0.14 - 0.19 oz ai Chlorsulfuron, or 0.10 – Tall Whitetop H rhizom H2O>10ft Yes 2 0.19 0.19 0.38 lbs ae 2, 4-D, or 0.10 – 0.71 lbs ae Glyphosate 1.47 – 1.93 oz ai Summary for Herbicide Treatment Chlorsulfuron, 31.15 – Herbicides available for use in this Alternative include Chlorsulfuron, Clopyralid, 46 64.91 64.91 233.59 lbs ae Aquatic Dicamba, Glyphosate, Triclopyr, 2-4-D, and two herbicide mixtures (Mix 1: Glyphosate, 0.17 - 1.4 lbs Dicamba + 2, 4-D, and Mix 2: Chlorsulfuron + 2, 4-D). ae Dicamba 0.56 - 2.22 lbs ae 2, 4-D, or 0.28 – 2.22 lbs ae Dicamba, or 0.11 – 0.28 Diffuse P+ or non H2O>10ft Yes 5 1.11 1.11 lbs ae Clopyralid, or Mix 2 Knapweed H rhizom (0.28 – 1.11 oz ai Dicamba + 0.56 – 1.67 lbs ae 2, 4- D) 0.09 - 0.36 lbs ae amine 2, 4-D, or 0.02 – 0.05 lbs ae Clopyralid, or 0.05 – 0.36 Diffuse P+ or non H2O>10ft Yes 2 0.18 0.18 lbs ae Dicamba, or Mix 2 Knapweed H rhizom (0.05 – 0.18 oz ai Dicamba + 0.09 – 0.27 lbs ae 2, 4- D)

66 Chapter 2—Alternatives Description Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

>10ft Rhizom Proposed Trmt. Distance >25ft and >100ft Number Surveyed Potential Total Amount Species / non Trmt. Code to Water H2O <100ft H2O of Sites Acres of Herbicide Application2 Rhizom Acres H2O

Diffuse P+ or non 1.15 - 8.63 lbs ae Aquatic H2O<10ft 3 2.3 2.3 Knapweed H rhizom Glyphosate 7.52 - 30.10 lbs ae 2, 4-D, P+ or non Dyer’s woad H2O>10ft Yes 23 15.03 15.03 or 11.27 – 15.03 oz ai H rhizom Chlorsulfuron 4.47 - 17.88 lbs ae amine P+ or non Dyer’s woad H2O>10ft Yes 6 8.94 8.94 2, 4-D, or 6.71 – 8.94 oz ai H rhizom Chlorsulfuron P+ (20.14 - 80.56 lbs ae 2, P+ or non Dyer’s woad H2O<10ft 11 40.28 40.28 4-D, or 30.21 – 40.28 oz ai H rhizom Chlorsulfuron >10ft H2O) 0.45 - 3.62 lbs ae Dicamba, or 0.91 – 3.62 Mediterranean P+ or non lbs ae 2, 4-D, or Mix 2 H2O>10ft Yes 10 1.81 1.81 Sage H rhizom (0.45 – 1.81 oz ai Dicamba + 0.91 – 2.72 lbs ae 2, 4- D) 0.33 - 1.32 lbs ae 2, 4-D, or 0.17 – 1.32 lbs ae Mediterranean P+ or non Dicamba, or Mix 2 ( 0.17 – H2O>10ft Yes 1 0.66 0.66 Sage H rhizom 0.66 oz ai Dicamba + 0.33 – 0.99 lbs ae 2, 4-D)>25ft H2O P+ (2.19 - 8.74 lbs ae 2, 4- D >10ft H2O, or 1.09 – Mediterranean P+ or non 8.74 lbs ae Dicamba, or H2O<10ft 2 4.37 4.37 Sage H rhizom Mix 2 (1.09 – 4.37 oz ai Dicamba + 2.19 – 6.56 lbs ae 2, 4-D) >25 ft H2O) 0.9 - 1.2 oz ai Chlorsulfuron, 0.3 – 2.4 lbs P+ or non Musk Thistle H2O>10ft Yes 5 1.2 1.2 ae Dicamba, or 0.12 – 0.3 H rhizom lbs ae Clopyralid, or 0.6 – 4.5 lbs ae Glyphosate

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

>10ft Rhizom Proposed Trmt. Distance >25ft and >100ft Number Surveyed Potential Total Amount Species / non Trmt. Code to Water H2O <100ft H2O of Sites Acres of Herbicide Application2 Rhizom Acres H2O 1.8 - 2.45 oz ai Chlorsulfuron, or 0.25 – 0.61 lbs ae Clopyralid, or P+ or non Musk Thistle H2O>10ft Yes 2 2.45 2.45 1.23 – 9.19 lbs ae H rhizom Glyphosate, or 0.61 – 4.9 lbs ae Dicamba (>25ft H2O) P+ or non 0.14 - 1.01 lbs ae Aquatic Musk Thistle H2O<10ft 2 0.27 0.27 H rhizom Glyphosate 3.85 - 38.54 lbs ae Dicamba, or 9.64 -38.54 lbs ae 2, 4-D, or 1.93 – Yes 196 19.27 19.27 4.82 lbs ae Clopyralid, or Mix 2 ( 4.82 – 19.27 oz ai Dicamba + 9.64 – 28.91 P+ or non lbs ae 2, 4-D) Scotch Thistle H2O>10ft H rhizom 1.19 - 9.52 lbs ae Dicamba, or 2.38 – 9.52 lbs ae 2, 4-D, or 0.48 – Yes 53 4.76 4.76 1.19 lbs ae Clopyralid, or Mix 2 (>25ft H20, 1.19 – 4.76 oz ai Dicamba + 2.38 – 7.14 lbs ae 2, 4-D) P+ or non P+ (0.68 - 1.71 lbs ae Scotch Thistle H2O<10ft 29 6.84 6.84 H rhizom Clopyralid >25 ft H2O) 1.28 - 5.12 lbs ae 2, 4-D, or 0.64 – 5.12 lbs ae Dicamba, or 0.26 – 0.64 Spotted P+ or non H2O>10ft Yes 9 2.56 2.56 lbs ae Clopyralid, or Mix 2 Knapweed H rhizom (0.64 – 2.56 oz ai Dicamba + 1.28 – 3.84 lbs ae 2, 4- D)

68 Chapter 2—Alternatives Description Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

>10ft Rhizom Proposed Trmt. Distance >25ft and >100ft Number Surveyed Potential Total Amount Species / non Trmt. Code to Water H2O <100ft H2O of Sites Acres of Herbicide Application2 Rhizom Acres H2O 0.003 - 0.02 lbs ae Dicamba (>25ft H2O), or 0.01 – 0.02 lbs ae amine 2, Spotted P+ or non 4-D, or 0.001 – 0.003 lbs H2O>10ft Yes 1 0.01 0.01 Knapweed H rhizom ae Clopyralid, or Mix 2 (>25ft H2O, 0.003 – 0.01 oz ai Dicamba + 0.01 – 0.02 oz ae 2, 4-D) Spotted P+ or non 0.5 - 3.71 lbs ae Aquatic H2O<10ft 1 0.99 0.99 Knapweed H rhizom Glyphosate 0.09 - 0.36 lbs ae 2, 4-D, or 0.05 – 0.36 lbs ae Dicamba, or Mix 2 (0.05 – 0.18 oz ai Dicamba + 0.09 Squarrose P+ or non H2O>10ft Yes 2 0.18 0.18 – 0.27 lbs ae 2, 4-D), or Knapweed H rhizom Mix 1 (0.14 -0.18 oz ai Chlorsulfuron + 0.09 – 0.27 lbs ae 2, 4-D), or 0.02 – 0.05 lbs ae Clopyralid 0.6 - 2.54 lbs ae 2, 4-D, or 0.32 – 2.54 lbs ae Dicamba, or Mix 2 ( 0.32 – 1.27 oz ai Dicamba + 0.64 – 1.91 lbs ae 2, 4-D), or Yellow P+ or non H2O>10ft Yes 6 1.27 1.27 Mix 1 (0.95 – 1.27 oz ai Starthistle H rhizom Chlorsulfuron + 0.64 – 1.91 lbs ae 2, 4-D), or 0.64 – 1.91 lbs ae Triclopyr, or 0.95 – 1.27 oz ai Chlorsulfuron Yellow P+ or non 0.56 - 4.2 lbs ae Aquatic H2O<10ft 2 1.12 1.12 Starthistle H rhizom Glyphosate

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

>10ft Rhizom Proposed Trmt. Distance >25ft and >100ft Number Surveyed Potential Total Amount Species / non Trmt. Code to Water H2O <100ft H2O of Sites Acres of Herbicide Application2 Rhizom Acres H2O

32.71 - 131.32 lbs ae 2, 4- Summary for P+ or H Treatment D, 4.56 - 18.24 lbs ae Treatments for sites in this treatment category may be treated with any of the amine 2, 4-D, 2.35 - 17.55 treatment methods available in the physical + or Herbicide treatment categories. 371 115.6 115.6 lbs ae Aquatic Glyphosate, Following the Design Standards, sites under this category treated with herbicides 5.5 - 42.18 lbs ae may be treated with P+ methods as the size and density of weeds decreases. Dicamba, 2.7 - 3.65 oz ai Chlorsulfuron

Total sites and acres considered in this Alternative 541 6908.43 341.21

Early Detection – Rapid Response 200

16.07 - 125.98 lbs. ae Dicamba, 8.07 - 10.79 oz ai Chlorsulfuron, 35 – Total sites and acres being treated under this Alternative 541 6908.43 541.21 262.39 lbs ae Aquatic Glyphosate, 81.21 - 325.32 lbs ae 2, 4-D, 4.56 - 18.24 lbs ae amine 2, 4-D

Notes: 1. The treatment method is listed for each site. Herbicide treatments are listed in order of preference according to Table 2-3, along with other effective herbicides that may be used. The most effective herbicide is in bold. 2. The total amount of herbicide application is based on the preferred herbicide for the given noxious weed species and is based on the application rates listed in Table 2-14 (in bold). The potential amounts of the other herbicides available for use are also listed. The summary and total amount of potential application is based on the most effective herbicide that is available for use. The effects analysis section evaluates the effects of all herbicides available for use. 3. Under Alternative 6, Design Standard-19a applies in the areas under the jurisdiction of the Lahontan Water Quality Control Board (east side of the Warner Mountains; see Figure 3-2): No treatments would occur from the high-water mark for a distance of 10 feet; only aquatic glyphosate would be used from 10 to 100 feet of the high-water mark; further than 100 feet from the high-water mark, the other herbicides displayed in the Alternative may be applied.

70 Chapter 2—Alternatives Description Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Alternatives Considered but Eliminated from Detailed Study The National Environmental Policy Act directs agencies to inform decision makers and the public of reasonable Alternatives which avoid or minimize adverse impacts or enhance the quality of the human environment. Agencies shall focus on significant environmental issues and Alternatives and shall reduce paperwork and the accumulation of extraneous background data (40 CFR 1502.1). Public comments received in response to the Proposed Action provided suggestions for additional treatment methods within the existing Alternatives for achieving the Purpose and Need. Some of these methods may have been outside the scope of the need for the proposal, duplicative of the Alternatives considered in detail, or determined to be components that would cause unnecessary environmental harm. Complete new Alternatives were not proposed during the public comment period. Those treatments not considered for inclusion in Alternatives 2 through 6 are addressed in Table 2-10: Treatment Methods Eliminated from Consideration. The National Environmental Policy Act directs agencies to briefly discuss reasons for eliminating Alternatives from detailed consideration.

Table 2 - 10. Treatment Methods Eliminated from Consideration

Method Description Discussion Mowing Mowing can reduce seed production and restrict Mowing is not considered in this FEIS as the weed growth, especially in annuals cut before rocky terrain damages equipment and when the they flower and set seed. Some species rocks are hit by mowing equipment fires can however, re-sprout vigorously when cut, easily be started. In addition mowing adversely replacing one or a few stems with many that can affects native plant populations. Mowing was not quickly flower and set seed. added to the analysis even though comments requested mowing be included due to the potentially adverse impacts to the environment and the small size of 85 % of the invested sites. This method may be used in the future after appropriate NEPA analysis. Tilling Tilling, or the turning-over of soil, is often used Tilling destroys the soil profile and produces for weed control in agricultural crops. large bare areas for noxious weeds to invade. The extremely rocky and shallow soils of the Modoc National Forest do not lend to utilization of this method. This method may be used in the future after appropriate NEPA analysis. Grazing Intensive grazing requires grazing livestock at Eliminated from consideration since this method animals levels above forest wide standard and guidelines is non-selective and may provide for noxious intensely to remove noxious weeds. Not practical as this weed re-establishment in a denser stand. over large method is non-selective and may provide for Intensive grazing also damages watersheds and areas noxious weed reestablishment in a denser stand. increases soil compaction. This method may be Intensive grazing also damages watersheds and used in the future after appropriate NEPA Increases soil compaction. “Cattle will graze analysis as part of another project. Furthermore, invasive grasses, can trample inedible weed the vast majority of noxious weed sites currently species, and can inventoried on the Modoc National Forest are Incorporate native seeds into soil. Horses can 0.10 acre or less in size. If noxious weed sites also be used to control invasive grasses, but increase in size, then a targeted grazing horses tend to be more selective than cattle.” (Tu approach may be developed in the future to et al. 2001) include appropriate environmental analysis in consultation with the Targeted Grazing Handbook (Targeted Grazing: A Natural Approach for Vegetation Management, Peischel and Henry eds. 2006). Fertilization Application of fertilizers to stimulate the growth of While fertilization could improve the success of desired species. desirable species it could also improve growth and spread of noxious weeds. Parasites, Most effective when integrated with other Biological Controls were analyzed and then Predators, strategies; does not achieve eradication; not dropped from inclusion within the Proposed

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Method Description Discussion and effective on all invasive plants; long term process Action for the following reasons: Most of the Pathogens required. weeds that have the potential for this type of “Biological control (biocontrol for short) is the use treatment are .1 acre in size with the largest of animals, fungi, or other microbes to feed upon, occurrence 7.5 acres, Usually Biological Controls parasitize or otherwise interfere with a targeted are utilized on larger weed occurrences that can pest species. Successful biocontrol programs support insect population growth and dispersal usually significantly reduce the abundance of the over the time it takes for total control of the pest, but in some cases, they simply prevent the weed. A population of 50 plants for example may damage caused by the pest (e.g., by preventing not have the resources to permit this to occur. it from feeding on valued crops) without reducing Biological controls take years and sometimes pest abundance (Lockwood 2000). Biocontrol is decades to become effective. Insect populations often viewed as a progressive and must be of sufficient size that no seeds are environmentally friendly way to control pest allowed to mature and disperse (i.e. 100% of the organisms because it leaves behind no chemical seed source has been destroyed). Of greatest residues that might have harmful impacts on concern is the potential for introduced exotic humans or other organisms, and when biological agents to cause unanticipated negative successful, it can provide essentially permanent, effects on the environment. These effects could widespread control with a very favorable cost- include, but are not limited to insects damaging benefit ratio. However, some biocontrol native plant occurrences and indirect changes to programs have resulted in significant, irreversible the food web. This method may be used in the harm to untargeted (non-pest) organisms and to future after appropriate NEPA analysis in ecological processes. Of course, all pest control cooperation with APHS or State agencies. methods have the potential to harm non-target native species, and the pests themselves can cause harm to non-target species if they are left uncontrolled. Therefore, before releasing a biocontrol agent (or using other methods), it is important to balance its potential to benefit conservation targets and management goals against its potential to cause harm.” (Tu et al. 2001)

Ground Most appropriate for large areas on flat ground. Potential for effects on non-target species. Most application Herbicide is delivered by tractor, truck, trailer or infestation sites being considered for treatment with booms ATV mounted pressurized tanks with 6 foot or are too small for consideration of boom or larger booms which spray all plants in an application. This method may be used in the broadcast infested area. future after appropriate NEPA analysis. applications of granules Aerial Most appropriate for large, relatively inaccessible Potential for off-site drift and effects on-non application infestations. target species. Most infestation sites being considered for treatment are too small for consideration of aerial application. This method may be used in the future after appropriate NEPA analysis. Prescribed Fire can be used to remove flammable fuels, Site specific analysis needed since prescribed Fire such as stands of annual grasses, to reduce the fire of existing weed sites may promote further risk of a wildfire. However, a single, low intensity introduction of new species or spread of existing fire will not effectively control most weeds noxious weed species into denser stands. because it does not get hot enough to prevent re-sprouting from crowns or re-establishment from seeds in the soil. Fire may create the type of disturbance that promotes the colonization of many weeds. However, when prescribed burns are coordinated in conjunction with other vegetation management techniques, it can be a very effective means of increasing the vulnerability and susceptibility of species such as Buffalo grass to other methods of control. (Tu et al. 2001). The FS must approve a Burn Plan

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Method Description Discussion prior to any burn activities. Burning Directed-burning of noxious weeds with a Cost of implementation, burn plan development, using propane torch can be more cost effective and and limited burn days may be too restrictive. torches easier than implementing a prescribed fire Burning can unexpectedly promote an invasive, (permits are still required), but is only effective such as when their seeds are specially adapted when the infestation is small. Directed-burning to fire, or when they re-sprout vigorously. can be used to burn individual plants, groups of plants in a small area, or to ignite brush piles. Propane torches can be used in areas where there is little or no fine fuel to carry a prescribed burn, and can also be used to kill plants when conditions are wet. (Tu et al. 2001) Native Cost of implementation, burn plan development, American and limited burn days may be too restrictive. Burning Description of how this proposal varies from Forest Service Prescribed Fire was not available for analysis. Burning Use of laser technology to cut or kill specific Sufficient scientific documentation concerning using Laser plants. the effects, efficiency, costs, and dangers of utilizing laser technology is not available for analysis during this effort. Burning Use of trailer mounted boiler and steam pressure Distance to available clean water to refill steam using steam to kill plants with steam. equipment is a limiting factor. Cost of implementation, burn plan development, and limited burn days may be too restrictive. Steam burning can unexpectedly promote an invasive, such as when their seeds are specially adapted to heat, or when they re-sprout vigorously. Further analysis of effectiveness, availability, and costs would be necessary.

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Comparison of Alternatives A number of different tables are included in this section. Each of these tables compares different aspects of the Alternatives that are being considered.

Table 2 - 11. Comparison of Treatment Methods by Number of Sites and Acres

Alternative 1 (No Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6 Action) Treatment Time Frame Ongoing 5 years 10 years 10 years 10 years 10 years Sites Acres Sites Acres Sites Acres Sites Acres Sites Acres Sites Acres Physical– hand pulling, hoeing, grubbing 0 0 161 31 494 5993 161 31 0 0 0 0 Physical+ --clipping seed head or plant, using hand-held string trimmer, placing mulch or tarp 20-30/yr 0 0 0 0 0 0 527 139 116 19 Herbicide and/or Physical + Treatments 0 0 333 5961 0 0 333 5961 0 0 371 116 Herbicide 0 0 42 907 0 0 42 907 0 0 46 65 Limited Treatment1 0 0 0 0 0 0 0 0 9 100 3 100 Goat Grazing (potential) (physical + /herbicide) 0 0 0 0 0 0 0 0 5 41 5 41 Total Sites and Acres Potentially Treated with Herbicides (includes ED-RR acres) 0 0 355 6868 2 0 355 7068 3 0 0 425 522 4 Total Inventoried Acres Treated 0 0 536 6899 494 5993 536 6899 532 280 541 341 1 Includes treating along borders of infestations to prevent spread, using the methods specific to each Alternative. Treatment is estimated at 100 acres, to be proportionally distributed based on the size of the individual infestations. These acres are included in the Inventoried Noxious Weeds Treated acreage. 2 This includes acres under the physical and/or herbicide method, plus the herbicide-treated acres. 3 This includes acres under the physical and/or herbicide method, the herbicide-treated acres, and the potentially treated areas under Early Detection – Rapid Response (200 acres). 4 This acreage includes the Physical+ and/or herbicide acres, the herbicide acres, the acres under goat grazing, the acres under the limited-treatment category, and the 200 acres potentially treated under Early Dection – Rapid Response. Total Inventoried Weeds (2004): 541 sites covering 6908 acres.

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Table 2 - 12. Comparison of Extent of Weed Treatments (Full, Partial, Limited, No Treatment)

Alternative 1 (No Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6 Action) Treatment Time Frame Ongoing 5 years 10 years 10 years 10 years 10 years Sites Acres Sites Acres Sites Acres Sites Acres Sites Acres Sites Acres Inventoried Weeds Full Treatment 20-30/yr1 520 5995 494 5993 520 5995 520 180 538 241 Inventoried Weeds Partial Treatment 0 0 16 2 904 3 0 0 16 2 904 5 0 0 0 0 Inventoried Weeds Limited Treatment 0 0 0 0 0 0 0 0 9 100 3 100 6 Not Inventoried - Treated Through Early Detection – ) 8 0 0 0 0 0 0 200 200 200 Rapid Response (100 acres max/yr Total Acres of Weeds Treated 20-30/yr 6899 5993 7099 480 541 Total Acres of Inventoried Weeds Treated 20-30/yr 6899 5993 6899 280 341 % of Total Inventoried Weeds Treated .3 - .4% 87% 87% 99% 4% 5% Inventoried Weeds with No Treatment 6878 5 2 9 47 4 916 5 2 9 5 2 5515 6567 7 Total Inventoried Weeds (2004) 541 6908 541 6908 541 6908 541 6908 541 6908 1Under current management, approximately 20 to 30 acres of noxious weeds ares treated each year through other site-specific NEPA decisions, as part of other projects, in accordance with the Modoc NF Integrated Weed Management Strategy (2005). 2 Excluded 5 sites of rhizomatous species that are within 10’ of live water, and partial acreage of 16 sites of rhizomatous species that are within 10’ of live water. Rhizomatous species will not be treated by physical means. 3 These sites have rhizomatous species that occur within 10’ of water. Acreage within that zone would not be treated. Acreage outside the zone would receive partial treatment with herbicides. 4 Excluded 47 sites of rhizomatous species composed of 916 acres. 5 These sites have rhizomatous species that occur within 10’ of water. Acreage within that zone would not be treated. Acreage outside that zone would receive partial treatment and be treated with herbicides. 6 These sites will receive limited treatment around the perimeter, estimated at 100 acres proportionally distributed based on the size of these sites. 7 Excluded 5,658 acres of dyer’s woad, 850 acres of Dalmatian toadflax, and 159 acres of crupina. 8Acres treated with Early Detection – Rapid Response may use any of the methods approved for use in this decision. Re-treatment of the Same Acres in all Alternatives is not considered new acres treated.

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Table 2 - 13. Comparison of Treatment Priorities

Alternatives 2 through 4 Alternatives 5 and 6

Priority for Treatment (in order of Priority for Treatment (in order of Category Category Treatment preference) Treatment preference)

First Species with limited 1. Use physical First Isolated plants or sites 1. Use Physical+ site occurrences methods to treat less than 1/10 acre, new methods to treat isolated plants on sites species, and new isolated plants where Modoc County less than 1/10 acre and infestations, or species effective. Category A species fewer than 100 plants. with fewer than 25 plants. 2. Use herbicides. Areas of high traffic and 3. Remove seed heads. 2. Use herbicides. sources of infestation, parking lots, trailheads, horse ramps, gravel pits. Areas of special concern such as botanical areas or Research Natural Areas. Second Containment of existing 1. Use Physical+ infestations methods to treat Second Category B species 1. Use physical Roadsides isolated plants methods to treat Category A species 2. Use herbicides on isolated plants. roadsides and Category A weeds. 2. Use herbicides on roadsides and Category Third Control or Eradication of 1. Use Physical+ A weeds. existing infestations methods to treat Treatment of Category B isolated plants or plant Third Treatment of 1. Use physical species clumps. Category C species methods to treat 2. Use herbicides. isolated plants or plant 3. Use goat grazing. clumps. 4. Use hand-held string trimmers. 2. Use herbicides. Fourth Control of Category C and 1. Use Physical+

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Alternatives 2 through 4 Alternatives 5 and 6

Priority for Treatment (in order of Priority for Treatment (in order of Category Category Treatment preference) Treatment preference)

Fourth not applicable not applicable Fourth Eradication of Category A methods to treat small areas along highways to prevent spread. 2. Use herbicides along perimeters

Table 2 - 14. Comparison of Herbicides and Application Rates for Alternatives 2, 4, and 6

Mix 2: Mix 1: Dicamba Chlorsulfuron Clopyralid Dicamba Glyphosate Triclopyr 2, 4-D Chlorsulfuron and 2, 4- and 2, 4-D D Dicamba Chlorsulfuron 0.25-1.0 0.75-1.0 oz 0.75 – 1.0 oz 0.10 to 0.25 .25 – 2 0.50 – 3.75 0.5 – 1.5 lbs 0.5-2 lbs oz ai/ac Typical Application Rates ai/ac + 2, 4-D ai/ac lbs ae/ac lbs ae/ac lbs ae/ac ae/ac ae/ac + 2, 4-D 0.5-1.5 lbs 0.5-1.5 ae/ac lbs ae/ac Canada Thistle 6 2,4,6 2,4,6 2,4,6 6 6 Common Crupina 6 2,4,6 6 2,4,6 2,4,6 6 6 6 Dalmatian Toadflax 6 6 2,4,6 6 Diffuse Knapweed 2,4,6 2,4,6 6 2,4,6 6 6 Dyer's Woad 6 2,4 2,4,6 2,4,6 2,4 2,4,6 6 Klamath Weed or St. 6 6 Johnswort Mediterranean Sage 2,4 2,4,6 6 2,4,6 6 6 Musk Thistle 6 2,4,6 2,4,6 2,4,6 2,4,6 6 6 Plumeless Thistle 6 2,4,6 2,4,6 6 2,4,6 6 6 Scotch Thistle 6 2,4,6 2,4,6 2,4 2,4,6 6 6 Spotted Knapweed 2,4,6 2,4,6 2,4,6 6 2,4,6 6 6

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Mix 2: Mix 1: Dicamba Chlorsulfuron Clopyralid Dicamba Glyphosate Triclopyr 2, 4-D Chlorsulfuron and 2, 4- and 2, 4-D D Dicamba Chlorsulfuron 0.25-1.0 0.75-1.0 oz 0.75 – 1.0 oz 0.10 to 0.25 .25 – 2 0.50 – 3.75 0.5 – 1.5 lbs 0.5-2 lbs oz ai/ac Typical Application Rates ai/ac + 2, 4-D ai/ac lbs ae/ac lbs ae/ac lbs ae/ac ae/ac ae/ac + 2, 4-D 0.5-1.5 lbs 0.5-1.5 ae/ac lbs ae/ac Squarrose Knapweed 6 2,4,6 2,4,6 2,4,6 2,4,6 6 6 Tall White Top (Perennial 6 2,4,6 2,4,6 2,4 6 pepperweed) Yellow Star Thistle 2,4,6 2,4,6 2,4,6 2,4,6 2,4,6 6

Note: The information for Alternatives 2 and 4 in this table was developed from information in the DEIS and the 2002 Modoc National Forest Weed Management Strategy and Action Plan. The information for Alternative 6 in this table was developed based on information provided by the UC Davis Extension Agent for Modoc County, Don Lancaster, and is based on label instructions for the herbicides.

78 Chapter 2—Alternatives Description

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Table 2 - 15. Total Herbicide Application for Alternatives that Utilize Herbicide Treatments

Modoc County Herbicide Alternative 2 Alternative 4 Alternative 6 2005 Data* 0.08 - 0.2 lbs Clopyralid 48.5 lbs ae/55 acres 0.08 - 0.2 lbs ae/0.81 acres n/a ae/0.81 acres 13.46 – 105.7 lbs ae/52.85 13.46 – 105.7 lbs 16.07 - 125.98 lbs Dicamba 947.40 lbs ae/9,963 acres acres ae/52.85 acres ae/62.54 acres 4,195.49 lbs ae/3,456 483.64 – 3,640.98 lbs 483.64 – 3,640.98 35 – 262.39 lbs Glyphosate acres ae/970.59 acres lbs ae/970.59 acres ae/69.97acres 8,913.34 lbs ae/10,419 2,843.5 – 11,371.2 lbs 2,843.5 – 11,371.2 85.77 - 443.56 lbs 2, 4-D acres ae/5685.6 acres lbs ae/5685.6 acres ae/171.58 acres 8.07 - 10.79 oz ai/10.79 Chlorsulfuron 0.51 lbs ae/50 acres n/a n/a acres Total Herbicide 3,341– 15,118 lbs 137 – 832 lbs ae; 14,105 lbs ae 3,341– 15,118 lbs ae Application ae 8 - 11 oz ai

* Data is from California Department of Pesticide Regulation 2005 Annual Pesticide Use Report for Modoc County.

Table 2 - 16. Contribution to Total Herbicide Application in Modoc County for Alternatives that Utilize Herbicides

Total Herbicide Year Modoc County Alternative 2 Alternative 4 Alternative 6 (lbs ae)*

2003 232,839 lbs ae 1.4% - 6.4% 1.4% - 6.4% 0.06% - 0.36% 2004 385,516 lbs ae 0.86% - 3.9% 0.86% - 3.9% 0.04% - 0.22% 2005 440,263 lbs ae 0.80% - 3.4% 0.80% - 3.4% 0.03% - 0.12% * Data is from California Department of Pesticide Regulation Annual Pesticide Use Reports for Modoc County. 117 chemical formulations were applied in Modoc County in 2005.

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Table 2 - 17. Comparison of Cost (in 2006 dollars)

Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6 (No Action)

Estimated 5-year Discounted Cost $135,670 $1,393,760 $2,225,190 $1,383,010 $533,420 $455,200

Estimated 10-year Discounted Cost $247,920 N/A N/A $1,987,840 $900,230 $734,630

Estimated Cost per Effectively Treated Acre $1,183 $243 $418 $241 $1,159 $660

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 2 - 18. Comparison of Environmental Impacts and Significant Issues

Alternative 2 Alternative 1 Issues Proposed Alternative 3 Alternative 4 Alternative 5 Alternative 6 No Action Action Issue 1 - The use of herbicides for noxious weed Herbicides will not There is a very Herbicides will not There is a very Herbicides will not There is a very control may cause health problems for people affect people; little possibility affect people; little possibility of affect people; little possibility of who are exposed to the herbicides and/or however the of a small however the a small number however the a small number treated areas. Although federal and state potential for number of potential for of individuals to potential for of individuals to licensing and certification requirements for increased individuals to increased be affected by increased be affected by herbicide use builds in strict safety features exposure of people be affected by exposure of people the use of exposure of people the use of before use (such as a minimum and maximum to the adverse the use of to the adverse herbicides. to the adverse herbicides. amount that can be applied), some people have effects of noxious herbicides. effects of noxious effects of noxious reservations about the use of these products. If weeds will weeds will weeds will an Alternative is selected which authorizes the increase. increase. increase. use of herbicides, there is a potential that health problems could surface. Issue 2 - The proposed application of herbicides May Not Affect. May Affect May Not Affect May Affect May Not Affect May Affect for weed control may affect the ability of Native However, noxious Specific Sites Specific Sites for Specific Sites for Americans and others to collect plants for weed infestations for short short period of short period of traditional uses or medicinal reasons in specific have the potential period of time time but will not time but will not areas. Also herbicides may kill specific plants to displace but will not eliminate any eliminate any that are collected and used for medical or culturally important eliminate any species over a species over a traditional purposes in specific areas. plants and continue species over a large area. large area. to encroach on large area. trust lands. Issue 3 - An Alternative is needed to respond to 0 5 years of 5 years of 10 years of 10 years of 10 years of the need to evaluate an aggressive approach Treatments Treatments Treatments Treatments Treatments using additional treatment methods and adaptive management for treating more acres annually over a ten-year period to control and eradicate noxious weeds. The Proposed Action is seen as too limited and ineffective.

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Alternative 2 Alternative 1 Issues Proposed Alternative 3 Alternative 4 Alternative 5 Alternative 6 No Action Action Issue 4 - The proposed application of herbicides Herbicides will not There is very Herbicides will not There is very Herbicides will not There is a very for weed control has the potential to harm the affect the little possibility affect the little possibility affect the little possibility of physical and biological resources of the Forest. environment; (but greater environment; (but greater than environment; the use of The use of herbicides has the potential to however the than however the Alternative 6) of however the herbicides to adversely affect on the soil and water resources potential for Alternative 6) potential for the use of potential for adversely affect and harms the native plants and animals increased adverse of the use of increased adverse herbicides to increased adverse the environment. effects of noxious herbicides to effects of noxious adversely affect effects of noxious weeds will adversely weeds will the environment. weeds will increase. affect the increase. increase. environment. Impact to T&E Wildlife Bald Eagle -May Bald Eagle - Bald Eagle -May Bald Eagle -May Bald Eagle -May Bald Eagle -May Affect, Not Likely to May Affect, Affect, Not Likely to Affect, Not Likely Affect, Not Likely to Affect, Not Likely Adversely Affect. Not Likely to Adversely Affect. to Adversely Adversely Affect. to Adversely Northern Spotted Adversely Northern Spotted Affect. Northern Spotted Affect. Owl – No Effect. Affect. Owl – No Effect. Northern Spotted Owl – No Effect. Northern Spotted Shasta Crayfish – Northern Shasta Crayfish – Owl – No Effect. Shasta Crayfish – Owl – No Effect. No Effect. Spotted Owl – No Effect. Shasta Crayfish No Effect. Shasta Crayfish No Effect. – No Effect. – No Effect. Shasta Crayfish – No Effect. Impact to T&E Aquatic Species Lost River Sucker, Lost River Lost River Sucker, Lost River Lost River Sucker, Lost River Short Nose Sucker, Sucker, Short Short Nose Sucker, Sucker, Short Short Nose Sucker, Sucker, Short Modoc Sucker, Nose Sucker, Modoc Sucker, Nose Sucker, Modoc Sucker, Nose Sucker, Warner Sucker - Modoc Sucker, Warner Sucker - Modoc Sucker, Warner Sucker - Modoc Sucker, Not Likely to Warner Sucker Not Likely to Warner Sucker - Not Likely to Warner Sucker - Adversely Affect - Not Likely to Adversely Affect Not Likely to Adversely Affect Not Likely to Adversely Adversely Affect Adversely Affect Affect Impact to T&E Plants No Effect No Effect No Effect No Effect No Effect No Effect Impact to cultural plants May Affect, Not May Affect, May Affect, Not May Affect, Not May Affect, Not May Affect, Not Likely to Adversely Not Likely to Likely to Adversely Likely to Likely to Adversely Likely to Affect Adversely Affect Adversely Affect Affect Adversely Affect Affect

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Chapter 3: Affected Environment and Environmental Consequences Introduction This Chapter describes aspects of the environment that may be affected by the Proposed Action and Alternatives. Also described are the environmental effects (direct, indirect, and cumulative) that would result from undertaking the Proposed Action or an Alternative. Together, these descriptions form the scientific and analytical basis for the comparison of the Alternatives described in Chapter 2. Changes from DEIS The DEIS Chapters 3 and 4 were combined so the existing conditions for each resource area is followed by the consequences of implementing the various Alternatives. General Setting The area included in the analysis consists of Modoc National Forest System lands within Modoc, Lassen, and Siskiyou Counties. The Forest encompasses about 2 million acres on four Ranger Districts: Warner Mountain, Big Valley, Devil's Garden, and Doublehead. Of this, Forestlands actually total only 1.6 million acres while private landowners and other public agencies administer the remaining land. Elevations range from 4,000 to almost 10,000 feet above sea level.

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Figure 3-1. Location Map of the Modoc National Forest

The eastern portion of the Forest consists of the southern portion of the Warner Mountain Range and is administered by the Warner Mountain Ranger District in Cedarville, California. The Warner Mountains are a westward-dipping range that extend north and south for 80 miles and are approximately 10 miles wide. The western face has moderate to steep slopes, while the eastern aspect is very steep and often precipitous. Elevations range from 5,000 feet to almost 10,000 feet at Eagle Peak, the Forest's highest point. The south-central portion of this district consists primarily of the South Warner Wilderness area, which encompasses over 70,385 acres of relatively undeveloped land. At lower elevations, sagebrush, bunchgrass, and juniper are the common vegetative types. Higher elevations include meadows, mixed stands of ponderosa and Jeffrey pine, lodgepole and western white pine, and white fir with bitterbrush, mahogany, and sagebrush. Extensive aspen stands can be found scattered throughout the Warner Mountains at all elevations. Many creeks flow from the Warner Mountain Range into the North and South Forks of the Pit River, an important tributary to the Sacramento River. The Devil's Garden is a relatively flat, volcanic plateau that encompasses the entire Devil's Garden Ranger District and parts of the Doublehead and Big Valley Ranger Districts. With an average elevation of 4,800 feet, the plateau covers approximately 700 square miles and supports the largest continuous stand of western juniper in the western United States. Other vegetation on the Devil’s Garden includes sagebrush, rabbit brush, and bunchgrass. The timbered lands are stands of eastside ponderosa pine and Jeffrey pine, mixed with white fir and incense cedar on the north slopes above 5,500 feet. Unique areas include the Devil's Garden Research Natural Area, and over 35,000 acres of expansive man-made and natural wetlands scattered throughout the District.

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Beyond the juniper plateau to the west lie the Medicine Lake Highlands on the Doublehead Ranger District. This area includes geologic features of volcanic origin, such as numerous explosion craters, lava flows, and lava tube ice caves. The Highlands, an inactive broad shield volcano approximately 20 miles in diameter, rise 4,000 feet above the level of the surrounding plateau. They are considered an eastern extension of the Cascade Range that includes other volcanoes such as Mt. Shasta and Mt. Lassen. Dominant vegetation on this part of the Forest includes sagebrush mixed with juniper, and ponderosa pine at lower elevations. Other vegetation found here includes mixed conifer and lodgepole pine Forests. This is the only area on the Forest where stands of red fir and hemlock can be found. With elevations ranging from 4,500 to 7,800 feet, the topography of the southwest portion of the Forest on the Big Valley Ranger District is a mixture of basalt-capped plateaus and moderately steep mountainous uplands. Vegetation common at lower elevations includes sagebrush, juniper, bunchgrass, and bitterbrush. Ponderosa and Jeffrey pine, mixed with white fir and incense cedar, are found on north slopes above 5,500 feet. Most of the oak on the Forest grows on this district. The climate for most of the Forest ranges from warm, dry summers to cold, moderately wet winters. Weather varies considerably with elevation, slope, aspect, and season. Precipitation ranges between 5 inches on the Madeline Plains to 35 inches per year in the Warner Mountains and the Medicine Lake Highlands, with an average annual precipitation of 12 inches. Snow provides anywhere from 25% to nearly all of the total precipitation, depending on the location. Prevailing southwest breezes blow daily, clearing the air, and bringing frequent weather changes. Effects Analysis The FEIS summarizes specialist reports, the human risk assessment, and herbicide information discussed in more detail in the FEIS Appendix Volume. The Appendix Volume and the Response to Comments Volume are incorporated by reference into this FEIS. The FEIS effects analysis (as did the DEIS) is confined to the implementation of specific measures to control, contain, or eradicate noxious weed sites within the Modoc National Forest. Comments on the DEIS wanted the analysis to include the effects of prevention; education; research; inventory, mapping, and monitoring; cause of noxious weed spread; and/or other matters of noxious weed management which are contained in overriding Forest Service Management and Policy found in Forest Service Manuals, Handbooks, Policy, or Strategies, and outside the scope of this analysis.

Best Available Science Comments received on the DEIS analysis indicated that the Forest needed to utilize the best available science, and undertake further analysis and data gathering. This FEIS relies on the best available science, including peer reviewed journals, EPA documents, SERA reports, and other sources. The literature cited section of the FEIS indicates numerous documents were utilized and relied on in the analysis. DEIS Appendix E Herbicide Information and DEIS Appendix G – Weed Species Ecology and Impact provide the general public with an easy to read example of the literature available and utilized in the analysis. The FEIS further clarifies and analyzes the effects of implementation of each of the Alternatives. The effects analyses have been conducted using the best available science as disclosed in the FEIS. In addition, public comments and additional scientific literature suggested through the public comment period were used in formulating the FEIS. The objective of the FEIS is to be

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consistent with state and federal laws and regulations, and to disclose the effects of the Proposed Action and Alternatives.

Values vs. Science Some of the comments on the DEIS displayed a bias that reflected personal values for no use of herbicides, or the aggressive use of herbicides. Both value-driven views referenced statements from various studies, reports, and journals. This FEIS is focused on displaying the effects of the Alternatives in an unbiased manner and does not address individuals or organizational values. The Record of Decision will display the rationale for the decision and how consideration of the values and comments were utilized in making the final decision.

Direct and Indirect Effects Direct effects are caused by the action and occur at the same time and place as the action. Indirect effects are caused by the action and occur later in time or farther removed in distance, but are still reasonably foreseeable. Direct and indirect effects analysis for each Alternative and each resource are based on descriptions of the Alternatives provided in Chapter 2, including the Design Standards for each Alternative, and implementation of the Modoc National Forest Integrated Weed Management Strategy of 2005. Due to the way the inventory and mapping was done, treatment acres may be less than those indicated. This is mostly caused by areas of no or light weed infestation included within a weed location “polygon” in the GIS data. The minimum size of a GIS weed polygon is 0.10 acres, where the actual size might be one plant or a small patch.

Irreversible and Irretrievable Commitment of Resources NEPA requires identification of irreversible and irretrievable commitments of resources. These effects are identified in resources where they may occur including: soils, vegetation, and wilderness and inventoried roadless areas.

Short-Term and Long-Term Effects Unless otherwise specified, short-term effects are those that occur within three years after treatment, and long-term effects are those that occur in three to ten years after treatment. Cumulative Effects Cumulative impacts are impacts on the environment that result from incremental impact of an action when added to other past, present, and reasonably foreseeable future actions. For each resource, an analysis area was determined that could be used to adequately measure cumulative effects of the proposed Alternative. Unless otherwise stated, the cumulative effects area is the treatment area. Direct, indirect, and cumulative effects are limited to geographic and temporal scope of the project discussed above and in Chapter 1.

Past, Present and Reasonably Foreseeable Actions The following actions were considered in cumulative effects analysis for each resource: Fuel Treatments and Fire, Range Management, Dam Construction and Maintenance, Recreation,

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Timber Management and Vegetation Treatment, Reforestation, Road Management, Special Uses, and Past Noxious Weed Treatment. Below is a description of these actions. Reasonably foreseeable and present actions on national forest system lands considered in cumulative effects analysis are shown in Table 3-1a, which was developed by reviewing both the 2007 Program of Work and the Oct.-Dec. 2007 Schedule of Proposed Actions. A GIS analysis of known weed occurrence locations in the noxious weed database in relation to the FACTS database was completed. In this analysis, all weed occurrences were queried to determine whether they are within ¼ miles of roads and waterways. Over 90% of known weed sites occur along roads. Of the 169,939 acres of land treatments on the Modoc National Forest, only 2.2% percent of these acres (3,770 acres) are infested with noxious weeds. Of these 3,770 acres, 3,717 acres are part of the large 5,658 acre dyer’s woad infestation. The remaining 53 acres occur in other areas of past land treatments. This represents approximately 3/100s of a percent of the total acres of past land treatments. Over 90% of known noxious weed infestations occur along roads indicating that roads are the major vector for the introduction and spread of noxious weeds on the Forest. Many actions carry a risk of spreading noxious weeds including timber management (site preparation, planting, thinning, harvesting), prescribed fire, juniper removal and aspen enhancement project, wetlands creation and maintenance and recreational site development and maintenance. Ground disturbance creates exposed soil and decreases native plant cover. Noxious weeds can colonize these disturbed areas. Equipment can move soil containing weed seeds from one area to another. Grazing has the potential to spread noxious weeds through vegetation trampling, herbivory and spreading seed through their hooves and hair. However, as previously mentioned the majority of known noxious weed sites on the Modoc NF occur along roads. Additionally, the Modoc NF developed an Integrated Weed Management Strategy in 2005. This strategy outlines such things as prevention measures to consider during project implementation, educational activities, and inventory and monitoring the spread of weeds on the Forest. A Noxious Weed Risk Assessment (FSM 2081.03) is currently required for all projects on the Forest prior to implementation. Project analyses also consider the prevention practices listed in the Integrated Weed Strategy for inclusion in project design. Before this requirement, a number of forest activities contributed to the spread of noxious weeds due to the soil disturbance creating a good environment for noxious weeds. The spread of noxious weeds with projects has been greatly reduced by implementing practices that reduce the spread of weeds into new areas.

Fuel Treatments and Fire Approximately 17,000 acres are proposed for fuel treatments per year across the Forest: 5,000 acres of prescribed burns and 12,000 acres of mechanical and physical fuel treatment. A list of present and reasonably foreseeable fuel projects are listed in Table 3-1a. The fuels program does not use herbicides for implementation. Mechanical treatments, such as brush mowing and coniferous tree understory thinning, are less likely to have potential to spread noxious weeds. Activities associated with mowing are not likely to leave bare space upon completion of the project. Plus, areas will be mowed when there is less of a chance of equipment spreading seed. Understory thinning will have the guidelines stated in the Timber Harvest and Vegetation Management section. Prescribed burns have a potential to increase noxious weeds on the Forest by creating bare ground where the weeds can get established and by potentially reducing native plant vigor. Wildfire and associated suppression and rehabilitation measures also may provide both an excellent seed source and seed bed. There is no way of quantifying the location and extent of

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future wildlife fires, therefore a determination of the cumulative effects of fire is not possible. One large known infestation of noxious weeds (5,658 acres of dyer’s woad) is on a site where a wildfire burned. The weed was initially along a road in the fire area and spread after the wildfire created bare ground conditions where the weed could flourish.

Range Management Grazing allotments occur across the Modoc National Forest; however, roughly 10% of these allotments are vacant and about 2% are in non-use. Approximately 122,500 animal unit months of grazing occurs annually. There is also one wild horse territory with approximately 425 head. The range program does not use herbicides. Individual range management projects include installing cattle guards, fencing, developing water sources, and thinning juniper. Projects, such as fencing and juniper thinning, and administering permits (e.g., scheduling on and off dates) have restored riparian areas. A list of present and reasonably foreseeable range projects is included in Table 3-1a. There is the potential for livestock grazing to spread noxious weeds through transporting seed in the animal’s hair and creating bare ground by livestock gathering. If weed occurrences were adjacent , the bare ground could provide a seed bed. However, a GIS analysis of known weed occurrences shows that over 90% of the weed occurrences occur along roads.

Dam Construction and Maintenance There are 152 dams and water impoundments on the Forest which serve several functions from livestock ponds, irrigation, recreation, and wildlife habitat, with 34 of these considered as dams by the State of California. Associated with irrigation dams are canals used to transport water. Dams, canals and impoundments, because they are areas of bare ground, can be sites of noxious weeds and susceptible to noxious weed infestations. Maintenance of these structures can spread noxious weeds to other areas of the Forest. Many of these structures are maintained by range permittees.

Recreation On the Modoc National Forest, there are 34 developed campgrounds and several other developed sites, including boat launch facilities, trailheads, etc., and numerous dispersed recreation sites (primarily dispersed campgrounds). A list of present recreation projects is included in Table 3-1a. The recreation program does not use herbicides for treating weeds or other vegetation within recreation sites; rather, weeds are hand pulled. Recreation use that has likely contributed the most to the spread of weeds is recreation users traveling Forest roads. There are no known weed occurrences within the noxious weed database for developed recreation sites; however, it is likely that noxious weeds do occur at some sites. There are a variety of recreation associated activities that have the potential to spread noxious weeds including firewood gathering, mineral gathering, hiking, camping, off-highway vehicle use and horse use. The degree that these activities contribute to the spread of noxious weeds is likely relatively small compared to the primary source of known noxious weeds - vehicle travel on system roads. The Modoc NF is beginning the process of designating motorized routes for off-highway travel. Approximately 491 miles of non-system roads have been identified. The Forest will work with the public to identify routes to add to system from the non-system routes while considering such things as impacts to wildlife, vegetation and the presence of noxious weeds, among other things.

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Timber Harvest and Vegetation Treatments Past vegetation management actions are tracked in the FACTS (Forest Activity and Tracking System) database. This database contains information about vegetation management activities back to 1954. Since 1954, there have been over 169,939 acres of vegetation treatments on the Forest. On average, 2,500 acres are harvested annually for saw logs with an additional 3,000 acres for wood fiber. Harvest prescriptions vary from clearcutting to understory thinning; however, clearcutting has been greatly reduced over the past ten years. Reasonably foreseeable actions timber harvest actions are displayed in Table 3-1c. In the past, road construction was supported by timber harvest. The existing Forest transportation system was developed, in part, through the need to provide timber to the public after WWII. This trend continued until the late ‘70s or early ‘80s. Some weed sites have been identified in old landings that were created to deck logs after harvest to move along the Forest transportation system. Following timber harvest, a fungicide, borax (trade name SPORAX) may be applied to pine stumps larger than 14 inches in diameter to inhibit the spread of Heterobasidion annosum, a tree disease spread through infected stumps and root contact. The use of borax is limited to tree stumps after harvest. Noxious weed prevention measures are expected to significantly reduce the spread of noxious weeds during future timber and silvicultural activities. Noxious weed locations are presented as part of the planning process so that activities can avoid or mitigate the spread of noxious weeds (e.g., timing projects outside of high risk seasons). Logging systems design will maintain ground cover by minimizing ground disturbance and avoid opening up the overstory adjacent to noxious weed populations. Logging equipment will be washed to stem the transfer of noxious weeds (timber sale clause CT 6.343). Timber sale contract clauses C5.12 (Use of Road Purchaser), C5.4 (General and Special Maintenance Requirements), and C6.315 (Sale Operation Schedule) are used to keep vehicles and equipment out of high-risk areas during weed seed production periods. The Sage Steppe Ecosystem Restoration Strategy, a reasonably foreseeable action, is a programmatic analysis for treating 1,254,200 acres of juniper on the Modoc National Forest, BLM Alturas Field Office and surrounding federal agencies that lie within the sage steppe ecosystem. Treatment would be through mechanical treatments, hand treatments or prescribed fire. This project consists of restoring sagebrush communities that have been invaded by juniper over the last 100-150 years.

Reforestation Reforestation will occur as needed after wildfires or timber management. Past associated activities with replanting trees included the use of herbicides and/or mechanical and physical site preparation to reduce the competition for soil nutrients and sunlight from grasses and shrubs (release); another associated activity includes the use of strychnine for gopher control to reduce seedling mortality. Between 1979 and 1984, 5,122 acres were treated with herbicides for reforestation. The primary herbicide used was atrazine with 2, 4-D, Velpar L, and dalapon. The Forest has not used herbicides for reforestation since 1984. There are no projects identified in Table 3-1c to use herbicides for site preparation. Strychnine has been and continues to be used for gopher control in plantations. This activity involves placing strychnine laced oats under the ground in burrows to control gophers.

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Road and Right-of-Way Management A system of federal, state and county highways provide access to the Modoc National Forest. Forest system roads are extensions of these highways, and provide access to and mobility within the Forest. Roads allow protection, management, use, and development of Forest resources on which local communities are dependent. The Forest road system consists of approximately 4,600 miles. Integrated with the system are over 300 miles of private roads. There are also approximately 525 miles of non-system roads on the Forest. Roads and trails serve as primary corridors for movement of noxious weeds into non-infested sites, and are high- risk areas for invasion by new weed species. As mentioned previously, over 90% of known noxious weed infestations occur along roads indicating that roads are the major vector for the introduction and spread of noxious weeds on the Forest. Management of weeds along roadsides is a high priority with the Forest. Noxious weed seeds are often brought to these areas by vehicles, people, and livestock. They can also be spread by road maintenance. Gravel and cinderpits that provide a source of materials used in road maintenance can be a source of noxious weeds. Noxious weed sites along roads can serve as sources to further spread of weeds into non-infested areas.

State and County Easements Some 60 miles of State highway cross portions of the Modoc National Forest. The highway right- of-way is managed according to the terms of the specific easement and for the purpose of vehicle transportation. Vegetation management within the right-of-way is done according to the laws and regulations of the State of California and State standards for maintenance of a safe travel-way. Any application of herbicides within the right-of-way is included within the total application for the County. The County of Modoc maintains about 1,040 miles of roadway through the Modoc National Forest. These roads are maintained by agreement with the Forest or as easements. The rights-of- way are maintained according to County standard and any application of herbicide is done in accordance with State law and regulation and is recorded in the total application within the County.

Railroads Two railroads cross portions of the Modoc National Forest. Railroad rights-of way are embedded in the Forest and can be a source of weeds. The rights-of-way are owned by the railroad and herbicides are known to be periodically used for the control of vegetation. Herbicide use is reported in the total application within the County.

Special Uses Approximately 325,000 acres of privately owned lands lie within the Forest boundary (2,000 acres state; 1,000 acres tribal; and 323,000 acres of land owned by companies and individuals). The Modoc National Forest has a case load of about 160 special use authorizations annually for apiaries, ditches, dams, water sources, roads, recreational residences, utility transmission and communication sites, outfitters and guides, a ski hill, and miscellaneous permits. Special uses on the Forest encompass over 125,000 acres and result in a return of over $70,000 in fees to the U.S. Treasury. Special use permits authorize facilities and services necessary for public health, welfare, safety and security, such as communications sites for local 911 radio repeaters to support

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local law enforcement and emergency response entities. Others provide basic needs such as power and telephone lines to private homeowners. All new authorizations are issued with terms and conditions aimed at reducing potential spread of noxious weeds on the National Forest. Those conditions include but are not limited to cleaning of all vehicles prior to entry on National Forest lands, use of weed-free feed products, and reporting of noxious weed populations within the authorized area. All special use permits contain requirements for reporting and controlling noxious weeds. The Modoc National Forest administers slightly over 3,000 acres authorized for the purpose of transmitting or distributing power in the form of electricity and natural gas. In many cases these acres overlap because power and pipeline facilities are located within designated corridors. These utility authorizations are governed by terms and conditions that require prior authorization for implementing vegetation management varying from grubbing to whole-tree removal and use of herbicides. All power corridor authorized areas have been analyzed in separate environmental studies that include vegetation management required to be consistent with utility industry standard. Herbicides are currently approved for use on less than 10% of the authorized area in accordance with the standards set by environmental analysis and safety standards. The quantity of application is included in the Modoc County annual total. Inspection and reporting of herbicide application is the responsibility of the authorization holder under the terms and conditions of the authorization. The Forest does not routinely inspect these applications and reports of application are made to the County and State by the holder’s qualified applicator. Currently there is ongoing analysis for the vegetation maintenance for the U.S. Department of Energy’s Western Area Power Authority Sierra Nevada Region (High Voltage Powerline Right- of-Way Vegetation Maintenance), including two 500-kV transmission lines through the Doublehead Ranger District. Their proposal includes the maintenance of vegetation within the right-of-way with manual (cutting, girdling, topping and trimming), mechanical (mowing) and herbicides. The proposal is to use these techniques to maintain 30 feet of clearance around each transmission tower or structure. They would use only herbicides that have been approved for use in ROW maintenance and registered for use in California by the Environmental Protection Agency. The herbicides proposed for use on federal lands are: Chlorsulfuron, Clopyralid, 2, 4-D, Dicamba, Glyphosate, Imazapyr, Oxyfluorfen, and Triclopyr. The Modoc National Forest administers some 1,460 acres rented to public and private agencies for communications purposes. Over 900 acres of that is authorized to the Department of Defense for a radar installation. The remaining acres are within nine designated communications sites or are parallel to transportation, power line and/or pipeline facilities. These authorizations require prior approval for removal of vegetation, including use of herbicides. There have been no requests for herbicide application within these authorized areas in the last 5 years. Should herbicide application occur following written approval, inspection and reporting would be done by the authorization holder’s qualified applicator to the County and State.

Past Noxious Weed Treatments and Adjacent Treatments Prior to 2002, Modoc County Department of Agriculture treated weeds on the Forest through a Memorandum of Understanding. Billing records and correspondence between the Forest and Modoc County indicate treatments were done for about 30 years. Table 3-22 displays the previous treatment of noxious weeds with herbicides. Based on a comparison of Forest Service annual pesticide-use reports for 2002 and 2003 and California Department of Pesticide Regulation reports for 2002 and 2003, the majority of

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herbicides used on timberlands in the Modoc National Forest area are on private lands. The Forest has not been extensively involved in herbicide application in the last five years (for 2002, there was minor use for clopyralid, 2, 4-D, dicamba, glyphosate, and hexazinone, all for noxious weed control). From 2003 through 2007, no herbicides were applied on the Forest outside of existing permits. Tables F5-11, F5-12a, F5-12b in Appendix F displays the use of herbicides on public and private timberlands, rangeland, and road rights-of-ways, (the latter assumed to be primarily for noxious weed work) within the four-counties that make up the Modoc National Forest (Lassen, Modoc, Shasta, and Siskiyou Counties). Other Federal Lands in California The Modoc National Forest abuts the Klamath and Shasta-Trinity National Forests on the western flank. The Lassen National Forest administers some of these lands, and also has land that lies roughly 2 to 4 miles south of the Big Valley District. Klamath National Forest-Goosenest District: Currently, their weed control activities have focused on survey, although they have done a small amount of mechanical treatments (less than 1 acre). Lassen National Forest – Hat Creek District: There is roughly 40 acres on the areas adjacent to the Modoc National Forest that receives control for noxious weeds. The species targeted include dyer’s woad, Scotch thistle, and squarrose knapweed. Shasta-Trinity National Forest – McCloud District: There is no noxious weed control occurring on the portion of the District administered by the Shasta-Trinity National Forest at this time. There are roughly 10 acres of noxious weeds controlled on the portion of the District administered by the Lassen. Additional lands administered by the federal government outside of Forest Service jurisdiction include 2 wildlife refuges, 1 national park, and 2 BLM resource areas. All of these agencies have noxious weed management programs in place, which include the use of herbicides. An estimation of these agencies programs is as follows: Klamath Basin National Wildlife Refuge: The Klamath Basin has weed treatments both as part of their noxious weed eradication program as well as farming that occurs within its jurisdiction. On the Tule Lake unit there is roughly 20-30 acres that are treated with Rodeo in order to control purple loosestrife. In the Lower Klamath unit, there is another 50 acres of upland sites that are treated with Banvel and Round up to control pepperweed. There is no control occurring on the Clear Lake unit. Modoc National Wildlife Refuge: Approximately 200 acres are treated annually to control scotch thistle. Rodeo, Roundup, 2, 4-D and other chemicals are applied by hand, ATV, and truck in addition to a limited amount of hand grubbing that occurs. BLM-Alturas and Surprise Valley Offices: About 50 acres in Modoc County are treated annually for the control of primarily Scotch thistle and Mediterranean Sage. Both Telar and 2, 4-D are applied using both trucks and helicopters. There are approximately 425 acres of various weed occurrences on the BLM lands in Modoc and Lassen Counties that have been physically (which includes prescribed fire) or chemically controlled from 1997 to 2002; the vast majority is medusahead (410 acres out of 425 acres total). In May of 2007 the Alturas, Eagle Lake and Surprise Field Offices issued an Finding of no Significant Impact for treating 3,500 acres of exotic invasive plant species scattered over 3.34 million acres annual through a combination of manual, mechanical, chemical (ground and aerial applications), grazing, biological and prescribed fire methods.

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Lava Beds National Monument: Weed treatments on the Lava Beds National Monument consist of a combination of mechanical and chemical treatment using Roundup. Weeds that can not be extracted by hand (using a pulaski) are sprayed by hand with Roundup. This occurs on approximately 170 acres. The main weed species of concern are: mullein, hoarhound mint, bull thistle, stinging nettle, and sweet clover. Other Federal Lands within Oregon Fremont National Forest: Currently, there are approximately 200 acres per year that are sprayed on the Fremont National Forest. Chemical control is focused on spotted knapweed, dalmation toadflax, and Canada thistle. The Forest also has a hand treatment program. The entire Forest encompasses 1.2 million acres. BLM-Lakeview: This Resource Area uses both mechanical and physical, and herbicidal methods to treat various noxious weeds. There are approximately 250 acres of herbicide treatments that occur per year using picloram, glyphosate, and 2, 4D (amine). Herbicides are used to treat the following weed species: Russian knapweed, hoary cress, Mediterranean sage, Canada thistle, and medusahead. There is an additional 40 acres per year treated by mechanical and physical means to control musk thistle and Mediterranean sage. There are 3.2 million acres within the boundaries of this Resource Area. Tribal Lands The Pit River Tribe has a treatment program and trained crew that uses a combination of herbicide and mechanical and physical methods to control and eradicate noxious weeds from their lands. State and Private Lands There are roughly 10,000 acres a year that are treated with herbicides on private, commercial farm ground, and private forests for noxious weed treatment within Modoc County as a whole (Joseph Moreo, pers. comm.). In addition, 1,000 acres of regulatory noxious weed control occurs. Roughly 11 acres have been treated on the Ft. Bidwell Reservation; Mediterranean sage, scotch thistle, and dyer’s woad were controlled using mechanical and physical means.

Table 3 – 1a. Present and Reasonably Foreseeable Actions

Activity NEPA Project Name District Fuels Ash Vegetation Treatment * Fuels Crowder Block Wildlife Habitat Improvement Project (prescribed burns)* DG Fuels Cedar Pass Forest Health* WM Fuels Lassen Creek Watershed Forest Health and Restoration Project* WM Fuels North Warner Roadside Safety Improvement Project * WM Fuels Cal Pines Fuelbreak BV Fuels Carey Vegetation Mgt BV Fuels Hackamore Rx burn DH Fuels OSU Sagebrush Fire Effects Study* DH Fuels Bolan Rx burn WM Fuels COTP Rx burn BV Fuels Fandango Juniper removal & Underburn WM Fuels Fender Rx burn DG Fuels Lost Valley Mountain Fuels Reduction BV Fuels Pull Plug Rx burn DG Fuels Shin Rx burn WM Range Bitterbrush Spring BV

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Activity NEPA Project Name District Range Blue Mtn. Juniper Thinning DG Range Dry Lake pasture fence & cattle guard DH Range Lone Spring DH Range Devil’s Garden 2007 Range NEPA (Reissue 4 Allotments) DG Devils Garden Range Allotment Management Plans (Reissue 4 Range DG Allotments) Range Everly Range Improvements DG Turner Creek Habitat Improvement Project (fencing, removing Range DG encroaching conifers, and provide off-site livestock water) Range Crumes and Tucker Grazing Allotment EA DH Range Pothole Valley Spring Exclosures (fence construction) DH Range Reissue 5 Allotments Doublehead R.D. DH Range Reissue 6 Allotments Big Valley R.D. BV Range Timbered Mtn. Juniper Thinning DG Range Triangle Allotment Range Improvements DG Recreation DG/WM Campground Vegetation Management DG/WM Recreation Medicine Lake Interpretive Signing DH Recreation East Creek Trailhead Improvement WM Reforestation Badger 2 DG Reforestation Badger and Green Springs Sale Area Improvements DG Reforestation Blue Bird DG/DH Reforestation Blue Fire (tree planting and gopher baiting) WM Timber Harvest Black Stain BV Timber Harvest Blue Fire Salvage WM Timber Harvest Cinder Corp WM Timber Harvest Ditch BV Timber Harvest East Bridge Fire Salvage WM Timber Harvest Long Hill SSTS BV Timber Harvest Lost DG Timber Harvest Pull Plug WM Timber Harvest Long Valley Biomass Fire Salvage WM Vegetation Treatment Johnson Creek Fish Barrier Maintenance BV Vegetation Treatment Sugar Hill FH WM, Vegetation Treatment Bluebird Precommercial Thinning DG/DH Vegetation Treatment Black Mountain Forest Health DH Vegetation Treatment Day Bench Fuels Reduction BV Vegetation Treatment Sage Steppe Ecosystem Restoration Strategy FS/BLM/PVT Vegetation Treatment Cedar Pass Summer Lands Vegetation Management WM Vegetation Treatment Clear Lake Quaking Aspen Restoration Project DH Watershed/Road Parker Creek Slide Rehabilitation WM Management Watershed Weed Valley & 4-Mile Dam Maintenance DG Wild Horses Wild Horse Well Development DG Wildlife Howard’s Gulch Meadow Restoration DG Wildlife BV Guzzler retrofit BV Wildlife DG Guzzler retrofit DG Wildlife DH Guzzler installation DH Wildlife Howard’s Gulch Meadow Restoration DG Wildlife Mill Cr/Tamarack Aspen Release WM Wildlife Pit River Worker’s COOP Forest Wildlife West Valley Juniper Thin WM Wildlife Mountain Big Sage Maintenance Project DH Wildlife Mt. Dome Feral Horse removal DH Wildlife Rose Cr. Meadow Restoration BV Special Use High Voltage Powerline Right-of-Way Vegetation Maintenance* DH Management Special Use PacifiCorp Special Use Permit Update and Consolidation* DH/WM Management

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Activity NEPA Project Name District Special Use Briles Reservoir and Ditch Use Continuation (reissue permit)* WM Management Special Use Fandango Pass Wind Energy Project* WM Management Road Management Willow Creek Highway Safety Improvement (cut trees along road)* BV Road Management BIA Road Improvement Lauer Reservoir Access* DG Road Management Medicine Lake Highlands Motorized Wheeled Vehicle Restriction* DH Road Management Briles Reservoir Access Road* WM * Projects listed on the 10/1/2007 to 12/31/07 Schedule of Proposed Actions for the Modoc National Forest

Table 3 – 1b. Present and Reasonably Foreseeable Timber Sales FY07 – FY09

Timber Sale Name Ranger District Tamarck Aspen Warner Mountain Raptor Devil’s Garden F Reservoir Devil’s Garden Crystal Fire Salvage Doublehead Warner Roadside Warner Mountain Bench Doublehead Hiway 139 Safety Big Valley Miller Big Valley Bluebird Biomass Devil’s Garden Carr Juniper Doublehead Sunflower Cull Warner Mountain COTP Biomass Doublehead Rush 1 Phase I Big Valley Rush 1 Phase II Big Valley Trichnor Devil’s Garden Craig Devil’s Garden Turner Devil’s Garden Deep Aspen Warner Mountain Bald Aspen Warner Mountain Grouser Devil’s Garden Dry Aspen Warner Mountain Widow Devil’s Garden

Table 3 – 1c. Reasonably Foreseeable Timber Harvest Actions

Action NEPA Project Name Acres Regeneration harvest Ash Vegetation Treatment 1,070 Clear Lake Aspen Regeneration Project 26 OSU Sagebrush Fire-Effects Study 36 Commercial thinning Ash Vegetation Treatment 5,100 Rush2 Vegetation Treatment 3,997 Fletcher Fire Salvage 99 Selective Thinning Happy Sugar Pine 261 Cedar Pass Forest Health 520 Clear Cutting Fox Fire Salvage 20

Air Quality Crisp, clean mountain air is a hallmark of the Forest, which is geographically within the Northeast Plateau Air Basin under the jurisdiction of County Air Pollution Control officers in

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Lassen, Siskiyou and Modoc counties. The area designation for the project area, California National Ambient Air Quality Standards by Region 9 EPA, has been classified as “attainment or unclassified”, also called non-attainment/maintenance. Federal actions are not subject to conformity determinations under 40 CFR93. Air quality in the area is generally good, due to the remoteness and limited amount of development/activity taking place within the project area. Air pollution in the project area can come from a variety of sources, including vehicle travel along dirt and gravel roads, agricultural activities, and smoke from prescribed burns (both private and agency lands) and wildfires. Pollution from these sources would result in localized increases in fugitive dust that would be temporary and would not exceed air quality standards. The South Warner Wilderness within the Forest and the Lava Beds Wilderness in the Lava Beds National Monument in the northwest corner of the Forest, are rated as Class I air shed areas. The rest of the Forest is designated Class II. In Class I areas, even a minimal change in air quality is considered significant, while Class II areas can have changes in air quality if they are the result of moderate, well-controlled growth. The effects section below discusses the air quality concern that the FEIS should disclose the effects of herbicide Volatization caused by fire. Volatization is the converting of a normally solid or liquid material into a gas or vapor state. The potential effects of combustion products is common to all risk assessments of materials that might be subject to burning. The combustion products of burning wood and vegetation are respiratory irritants as well as carcinogens, and exposure to these combustion products should be avoided. There is no basis for believing that the presence of low or even high levels of Glyphosate or other herbicide residues would have a significant impact on this hazard (Dost 1982).

Direct and Indirect Effects Physical Treatments (All Alternatives): The effect of all Alternatives on air quality would be increases in fugitive dust generated from the use of vehicles to get to infested sites and use of hand tools. Fugitive dust impacts would be temporary, small in scale, and quickly dispersed through the project area. Gaseous emissions, including sulfur dioxide (S02), carbon monoxide (CO), oxides of nitrogen (NOx) and volatile organic compounds (VOCs), would result from combustion of fuel used during applications. The amount of gaseous exhaust emissions depends on size, age, and fuel efficiency of the engines. Sulfur dioxide emissions would be limited by using fuel that meets regulatory standards for the amount of contained sulfur. Other gaseous emissions would be minimized through proper operation and maintenance of engines. The amount of Hazardous Air Pollutants released during combustion of fossil fuels is very low and would pose no threat to health or environment. Herbicide Treatments (Alternatives 2, 4, and 6): Air quality impacts from use of herbicides include drift and volatization are expected to be short-term and restricted to the localized area and time of treatment because of application prescriptions during conditions of low winds speed and moderate temperature. Impacts would be temporary, small in scale, and quickly dispersed throughout the area project area. The application of herbicides would have short term minimal effects (odor) on the air quality immediately within and adjacent to application sites. During herbicide application spray drift of herbicides is possible. Studies show that during ground application (boom spraying from vehicles), greater than 90 % of the spray droplets are released on lands within the treatment area, with 10 % or less moving off-target. Of the 10 % that move off-site, most droplets deposit within

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100 feet of the treatment area boundary (Felsot 2001). Note: Data for boom-sprayer application is for comparison purposes only. The Forest does not propose using boom sprayers. Wick and directed spray as called for in this project are expected to have a spray distance less than 25 feet.

Cumulative Effects Other activities and natural occurrences (such as wildfire) will affect air quality during treatments in Alternatives 2-6. In all Alternatives, dispersion and the small amount of emissions produced by treatments at any given area will result in no noticeable increase in emissions within the airshed. The treatment methods proposed in Alternatives 2-6 would not result in a measurable air quality impact. The cumulative effects to air quality from the implementation of Alternatives 2-6 would be negligible. The effects to air quality from other activities such as prescribed fire or wildfire would be of more concern then the effects from the noxious weed treatment program. The noxious weed treatment program will not significantly add to the cumulative impacts to air quality. Since impacts will be distributed across the forest and over time, concentrations of air contaminants will not accumulate to the point of violating air quality standards for any area.

Consistency with Forest Plans and Other Laws and Policies All Alternatives are consistent with Modoc NF Forest Plan standards and guidelines regarding air quality (Modoc NF Forest Plan 4-13 to 4-14). In addition, all Alternatives are consistent with the Federal Clean Air Act and air quality standards on the Forest will be maintained as acknowledged under standards set by the Federal Clean Air Act. Fire and Prescribed-Fire Management In response to the need to reduce the potential for catastrophic fires called for under the Sierra Nevada Forest Plan Amendment of 2004, the National Fire Plan, and the Healthy Forest Initiative, the number of acres treated for timber stand improvement and fuels reduction has increased from 11,200 acres projected in the 1991 Forest Plan, to over 17,000 acres annually. Prescribed fire history is now tracked in the NFPORS database. In 2004, 3,634 acres were treated with prescribed fire, and in FY 2005; 2,202 acres were treated with prescribed fire. Prescribed fire treatments are applied across the Forest in all types of vegetation to reduce fuel buildup which could cause larger wildfires that are harder to control, or to improve wildlife habitat and/or range conditions.

Table 3 - 2. Occurences of Noxious Weeds within Prescribed Fire Underburning Projects

Year and Project Population Acres NW Species NW Site ID Acres Name Size 04 Hackamore 263 Plumeless Thistle DG001CAAC >10 0.10 04 Hackamore 263 Scotch Thistle DG029ONAC 50 0.10 05 Plum Valley 194 Scotch Thistle WM051ONAC 0.12 The Modoc NF has a well-documented fire history, with fire records dating back to 1910. A review of fires from 1910 through 2003 indicates valuable trends. Fire suppression efforts were successful on 97% of fires (Size Classes A through D fires that are between .1 to 99.9 acres in size). Fires in Size Class E (100-299.9 acres) occur every year, Class F fires (300-4999.9) occur 1.6 times per year, and Class G fires (5000+) occur every three years. There is an even distribution of Class G fires ranging from 5,000 acres to 30,000 acres, then a significant jump to 80,000, 87,000 and 196,000 acres. These large fires occurred in 1910, 1941 and 1977, indicating a 30 to 40-year trend for large wildland fire disturbance events. An intersect of noxious weeds

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occurrences with the Fire History data layer indicates 131 noxious weed sites occur within an area of historic burns. The public concern for the disclosure of the effects fire would have on the volatization of herbicide residue is disclosed and discussed in the Air Quality Section, above.

Direct and Indirect Effects Public comments expressed concern that wildland fire burning in areas that had been treated with herbicides would endanger the public and firefighters in the short term, through volatization of the chemicals. Products of combustion of wood and vegetation include particulate matter, oxides of nitrogen, carbon monoxide, and volatile organic compounds (VOCs). Other constituents of smoke include toxins such as benzene and formaldehyde, which are recognized as hazardous air pollutants by EPA and are carcinogenic (HFQLG SFEIS, page 285). Degradation of herbicides over time would reduce the amount of Glyphosate, reducing the potential amount of products produced. Glyphosate residues on plants were reduced 90 % after 6- 7 months, and 99 % after 10 months (Segawa et al, 2001). Additionally, not all of the herbicide would be converted to one product, further reducing potential exposure. Based on very conservative assumptions (no degradation of herbicide, the entire amount of herbicide is converted to each possible product) phosphoric acid intake by firefighters at the maximum rate on this project is estimated at 0.08 mg per cubic meter (based on 0.02 mg per cubic meter per pound of Glyphosate per acre (Dost 1982)). This is a factor of 13 below the OSHA permissible exposure limit of 1 mg per cubic meter. Potential exposure to non-firefighters and terrestrial and aquatic environments would be reduced with distance from a fire, as smoke is diluted with air. The potential effects of combustion products are common to all risk assessments of materials that might be subject to burning. The combustion products of burning wood and vegetation are respiratory irritants as well as carcinogens, and exposure to these combustion products should be avoided. There is no basis for believing that the presence of low or even high levels of Glyphosate residues will have a significant impact on this hazard (Dost 1982). “The combination of low herbicide application rates, environmental degradation, and thermal decomposition, coupled with natural ventilation in prescribed burning zone, precludes hazardous levels of airborne herbicide residues from forming.” (McMahon and Bush, 1992). David Bakke, Forest Service Region 5 Pesticide-Use Specialist, prepared a PowerPoint presentation on “Prescribed Burning and herbicides, The Risk From Burning Herbicide-Treated Brush” in 2007. Based on review of published studies and Forest Service risk assessments completed in Region 5 and Region 8 he concluded:  Herbicides will be present on fuels after application, although will decrease with time  Burning will further reduce herbicide amounts, and dispersion in smoke will reduce concentrations in air  There is no test evidence to suggest that workers in prescribed fires will be exposed to relevant concentrations of herbicides in smoke.  Even under worst-case assumptions, exposure modeling results in measures of risk that are at acceptable levels.  The compounds of concern during burning of treated vegetation for prescribed fire personnel are going to be the familiar ones (CO, CO2, particles, benzene, etc.) that come from burning vegetation.

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Cumulative Effects Due to the establishment of the National Fire Plan, the Modoc has increased its Fuels Treatment activities from 1,571 acres in FY2000 to 22,000 acres in FY2004. These treatments include physical, mechanical, and prescribed fire. Standard protocols are followed on all of these projects. There would be no cumulative effects from herbicide treatment on vegetation, if burned. Soils and Water The effect of invasive plant treatments on soil and water is of public concern. There is concern that herbicide treatment on riparian areas could adversely impact water quality and aquatic ecosystems. The purpose of this section is to analyze, interpret and discuss potential effects of invasive plant treatments on soil and water resources, located on the Modoc National Forest. Design Standards (DS) were developed to minimize the effects of invasive plant treatments on these resources. The Modoc National Forest is proposing to treat noxious weeds across the Forest by using herbicides, physical methods, and cultural treatments, or a combination of these approaches, over a 5- to 10-year timeframe (USDA Forest Service 2007). The noxious weeds are located in approximately 50 6th-field watersheds across the forest and could potentially affect 0.61 percent of soil map units located on the Modoc National Forest. Please refer to Table 3-3 and Appendix A for descriptions of the soil map units that have either sensitive or shallow soils on sites that contain noxious weeds. (Appendix A is part of the Watershed and Soils specialist report, found in Appendix T, Watershed and Soils, of this final EIS.) The 39 5th-field watersheds that are proposed to be treated under this decision lie within the jurisdictional area of three different regional water boards (RWB): Central Valley, Lahonton and North Coast. There are 143 6th-field watersheds within the 39 5th-field watersheds. Approximately 80 percent of these 6th-field watersheds are located within the Central Valley RWB and the remainder is divided between the Lahontan and North Coast RWBs. Each RWB has a different water quality standard for pesticide delivery to the surface and ground waters, with the Lahonton RWB having a no-herbicide-detected standard. Standards for the other RWB are a limit of 0.07 mg/l for 2, 4-D and a limit of 0.7 mg/l for glyphosate. All three of the RWB Basin Water Quality Plans meet the State of California standard for water quality. Analysis Area The analysis area for direct and indirect effects is the Modoc National Forest and lands administered by the Forest. The total acreage within the Forest’s boundary consists of approximately 2,029,647.7 acres. Of those acres, 1,679,007.3 are administered by the Forest Service, which is approximately 83 percent of the area. The Modoc National Forest is located in the extreme northeastern corner of California. The cumulative effects analysis area is comprised of the 39 5th-field watersheds that are either totally or partially found within the Forest’s administrative boundary. Approximately 39 percent of the total area of these 39 5th-field watersheds is located within the Forest boundary. Regulatory Framework

Federal Legislation Federal and state laws, policies, and regulations control the use of herbicides on National Forest System lands, including the Clean Water Act and the Federal Water Pollution Control Act. Section 208 of the 1972 amendments to the Federal Water Pollution Control Act (Public Law 92-

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500) specifically mandated identification and control of non-point source pollution. Clean Water Act Section 303(d) directs the State of California to list Water Quality Limited Water bodies (303(d)-listed streams) and develop total maximum daily loads (TMDL) to control the non-point source pollutant causing loss of beneficial uses. In the State of California, the Central Valley, Lahonton and North Coast RWBs compile this information for each region. The information is then combined into a single report by the State Water Resources Control Board. The Safe Drinking Water Act and its 1996 amendments require states to delineate public water sources, to determine potential sources of contamination, and to determine the most susceptible areas at risk for contamination. This project would comply with the standards and criteria determined by each of the three regional water quality boards.

Forest Service-Related Regulation The regulatory framework of the Modoc is guided by federal laws and regulations as well as direction from three separate forest plans. In general, the applications of these three guiding documents are as follows: the Big Valley Sustained Yield Unit is managed under the 1991 Modoc National Forest Land and Resource Management Plan (Forest Plan). The Medicine Lake Highlands are guided by the Northwest Forest Plan and the rest of the Forest is administered under the Sierra Nevada Framework amendment of 2004. Forest plan direction is found in the 1991 Modoc National Forest Plan, the Sierra Nevada Forest Plan Amendment (SNFPA) of 2004, and the plan referred to as the Northwest Forest Plan (USDA Forest Service 1991). Each of these guiding documents has differing direction for riparian areas. Management direction for soils, found in these three guiding documents, focuses on maintaining soil productivity and the restoration and maintainance of the physical, chemical and biological integrity of the Forest’s waters, as directed by the Clean Water Act. For consistency in the Noxious Weed Treatment Project, the Forest Supervisor determined that the Sierra Nevada Forest Plan Amendment Record of Decision direction for riparian-area management will be followed Forest wide, since it provides the highest level of protection to the aquatic resource. To help restore and maintain these aspects of water-related resources, riparian conservation objectives (RCOs) and aquatic conservation strategy objectives (ACSOs) were developed to provide specific management direction. This approach also supports the Forest’s mission to provide habitat for riparian and aquatic-dependent species as directed by the National Forest Management Act, Organic Act, and Safe Drinking Water Acts. Maintenance of soil productivity is essential to sustaining ecosystems and is mandated by every act of Congress directing national forest management. Region 5 Forest Service Handbook 2509.18.2 (USDA Forest Service 1995a) establishes regional objectives for the soils management program. The Modoc Forest Plan directs that soil productivity be maintained by applying guidelines to areas where management prescriptions are applied and that, as a minimum, 85 percent of areas affected by soil-disturbing activities will not exceed soil property thresholds, as defined in guidelines A-G. (Modoc National Forest Plan pages 4-21 to 4-22). Methodology for Analysis Design Standards were developed to ensure compliance with Region 5 direction, the Modoc National Forest Plan, the Sierra Nevada Framework, and the Northwest Forest Plan direction. Information used to develop these Design Standards include analysis of herbicide properties from SERA (Syracuse Environmental Research Associates, Inc.) risk assessments, soil characteristics and properties relative to herbicide properties and the proximity of treatment sites to streams. The acres to be treated under each Alternative by non-herbicide and herbicide methods, as well as types of herbicides used, were compared by Alternative.

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Herbicide degradation in the environment is tied strongly to soils. The analysis focuses on herbicide application since this is the highest risk of the Proposed Actions. Main topics compared across the Alternatives are (1) the risks to soil biology, (2) soil and water interactions, and (3) vegetation cover and soil erosion. The Forest Service has a contract with Syracuse Environmental Research Associates, Inc. (SERA) to conduct human health and ecological risk assessments. These assessments are for herbicides that may be proposed for use on National Forest System lands. The information contained in this report, and in the FEIS, relies on these risk assessments. Herbicide effects to stream aquatic resources were analyzed in risk assessments for each of the five herbicides included in the Alternatives. The risk assessments considered worst-case scenarios including accidental exposures and application at maximum reported rates. Although the risk assessments have limitations (see R6 2005 FEIS pages 3-95 through 3-97, and the Human Health section of the Modoc Invasive Weed FEIS), they represent the best science available. The GLEAMS (Groundwater Loading Effects of Agricultural Management Systems) model examines the fate of herbicides in various soils under a variety of environmental conditions. This model was used for all the Forest Service SERA risk assessments. This is a well-validated model for herbicide transport and is the best available at this time. The SERA Risk Assessment analysis takes the herbicide concentration provided by GLEAMS and uses them in a dilution model for a stream or pond to get the water contamination rates for specific scenarios. The risk assessment model assumes broadcast treatment along a small perennial stream. The model ran a 10-acre square field as well as a treatment area modeled as 50 feet wide and 1.6 miles long (10 acres). The model also assumes even rainfall every 10 days. The herbicide concentration was very similar for both scenarios. Modeling 10 acres along a stream would overestimate herbicide in streams on the Forest as no broadcast of herbicide is proposed anywhere, and no herbicide distances are required on streams, which vary by Alternative. The SERA worksheets were adjusted for the application rates to be used under this project. While the parameters do not always accurately reflect parameters at treatment sites, using this approach is considered conservative because the infestations are scattered, streams have specific no-herbicide application distance Design Standards, and broadcast applications are not allowed. For two sites, the GLEAMS-Driver 1.8 model was used because it allows the user to input more site-specific data, particularly local climate data and treatment acreage. The model is conservative and probably overestimates herbicide concentrations because it assumes broadcast application along a stream as opposed to the targeted treatment proposed with this project. The risk assessments, interdisciplinary team discussions, and monitoring studies of herbicide use in forested areas were used to create Design Standards, particularly for no-herbicide application distances from surface water, to protect streams from potential adverse effects of treatments.

Affected Environment for Soil and Water Resources Climate The climate for most of the Forest ranges from warm, dry summers to cold moderately wet winters. Weather varies considerably with elevation, slope, aspect, and season. Winters are marked by the occurrence of frequent low-pressure systems and cooler temperatures reflect the influence of maritime polar air. Precipitation tends to be lighter on the Modoc Plateau, increasing in amount in the mountain areas and falls mainly as snow. Precipitation tends to taper off after March, as the flow pattern of storms shifts to the north, resulting in warm summers with light precipitation (USDA Forest Service 1983).

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These patterns are reflected in the mean precipitation for Alturas, California. Mean precipitation is highest between the months of November through March, where the average precipitation is greater than 1 inch per month. The average annual precipitation is 12.2 inches per year. Correspondingly, the warmest months, which range from June through September, have the lowest precipitation averages for these months. During these months, the precipitation averages between 0.24 inches per month to a high of 0.99 inches per month (http://forest.moscowfsl.wsu.edu/cgi-bin/fswepp/rc/copypar.pl). Rainfall intensities vary from low to moderate. Rainfall intensities may vary from 1.4 to 3.0 inches for a two-year, 24-hour storm event, although the amount varies across the Forest (USDA Forest Service 1983). Geology The geology on the Forest has been influenced predominantly by faulting, volcanic activity, and erosion. From 60 million years ago to the present, the area has experienced volcanic activity. The Forest’s three major geomorphic provinces evolved from these dominating geologic processes. The provinces are: the Cascade Range, Great Basin and Modoc Plateau (USDA Forest Service 1983). The Cascade Range province is dominated by the Medicine Lake Highlands, which is a broad shield volcano, and considered to be active. It is currently among the top five candidates in California for future activity. Cinder cones are common and the associated bedrock is dominated by andesitic flows and pyroclastics. In recent geologic time, there has been additional activity resulting in domes and flows of rhyolitic obsidian, rhyodacites, and rhyolitic pumice. Basaltic lavas are also present, comprising a series of flows, such as the Modoc Basalt, Burnt Lava, and Black (Callaghan) and Point Pot Crater flows. The Modoc Plateau province is relatively flat and the monotonous central portion of the survey area is called Devil’s Garden. The area is capped by fissure erupted basalts that range in age from 25,000 to 20 million years ago and andesitic volcanic rocks are also present. Geologically recent basaltic cinder cones are scattered across the Plateau, and are generally associated with northwest-southeast trending faults. The Basin and Range province is located around the Warner Mountain area, and reflects the extreme western extent of this province. Warner Mountain is formed by a westward-tilting fault block. Bedrock in this area is almost entirely volcanic in origin. Pyroclastics dominated the majority of the mountain range, with minor amounts of andesite and basalts, obsidian flows, rhyolitic rocks, volcanic mudflows and welded tuffs occurring. Sedimentary rocks of volcanic origin are present; glacial deposits may exist but have been difficult to identify. The Adin Mountains are also present in this province and represent a series of anticlines and synclines, which have been dissected by faults (USDA Forest Service 1983). Soils There are approximately 2 million acres of soils mapped within the Modoc National Forest. These soils have been grouped into 22 map units, each of which consists of numerous individual soils and a wide variety of land types (USDA Forest Service 1983). These soils reflect the region’s ongoing volcanogenic history, and are derived primarily from basalts, andesite, tuff, pyroclastic pumice, cinders and volcanic ash, of various ages; although some other parent material is present. Map units defined during soil mapping on the Forest, in the early 1980s, were grouped into seven general assemblages, reflecting differing landscapes and land capabilities. These assemblages and their characteristics are summarized below in Table 3-3, from the Modoc Soil Survey dated 1983.

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Based on a review of Table 3-3, it is obvious that the parent material for soils on the Forest is volcanogenic in nature. Soils in the vicinity of the Warner Mountain Ranger District are generally more erosive then elsewhere on the Forest due to recent geologic uplift of area. On the Basalt Plateau, silica duripans are found under shallow soils in this area. Where these shallow soils directly overlie the underlying basalts, the duripans, once they are well developed, thick and highly cemented, function as a barrier to water moving from the soil horizon into the groundwater table The seven general assemblages in Table 3-3, reflecting differing landscapes and land capabilities have been further subdivided into over 100 soil types and grouped into 207 soil mapping units (USDA Forest Service 1999). Within this survey, soils of concern were identified based on a soil’s depth to bedrock, soil internal drainage, and permeability. Soil infiltration is a measurement of how quickly water can infiltrate into the soil from the surface, and soil drainage is a measurement of how quickly water can move through the soil profile. Soil permeability is measured as the number of inches per hour that water moves downward through the saturated soil. Soil drainage is a measurement of the frequency and duration of periods of saturation or partial saturation during soil formation (Adams 2007a). A sensitive soil is defined as a soil with soil permeability of “moderately rapid” or greater, or soil drainage of “somewhat excessively drained” or greater. Soils with the following characteristics were defined as of concern:  Soils with a lithic or para-lithic contact (soil depth of less than 12 inches to bedrock) or a soil with a depth to bedrock of less than 20 inches. These soils are defined as “shallow”  Soils with moderately rapid to rapid permeability  Soils with ratings of somewhat excessive to excessive soil drainage  Soils having maximum erosion hazard ratings of high to very high, and those with a runoff potential rating of high to very high.  Those areas classified as rubble lands, lava fields and rock outcrops, due to high incidences of fracturing.

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Table 3 - 3. Summary of map units and soil families on the Modoc National Forest

Geomorphic Permeability Maximum Erosion Map Unit Soil Families Parent Material Position Range hazard Potential Lower Elevation Basalt and volcanic Basalt plateaus and Predominantly Woodland Lawyer-Elmore & Jacket-Deven- tuff derived volcanogenic Slow-Moderate Low to High Soils, Primarily 0-40% Hibner families principally from mountain uplands Slope basic igneous rock Bakeoven family-lava flow-Searles family; Puls-Indian creek-Simpson Lower Elevation families; Deven-Bieber-Pass Canyon Basalt plateaus and Basalt, cinder Very Slow to Rangeland soils, Primarily families; Gwin-Ruckles_Pass Canyon volcanogenic Low to High cones, tuff, Moderately Rapid 0-40% slope families; Supan-Los Gatos-Pass mountain uplands Canyon families; Deven-Keating-Pass Canyon families** Predominantly Nearly Clay basins and Volcanogenic Level Alluvial Soils That Aikman-Cardon family drainages of basalt Very Slow Moderate sediments are Subject to Flooding plateaus Alcot-Sadie-Germany deep families; Lower to Mid Elevation Alcot-Holland families, pumice Volcanic ash, Old alluvial fans on Dominantly Woodland overburden; Lava flow-Germany cinders and recent basalt plateaus and Moderately Rapid Soils Which Have formed Low to High family-Lithic Xerumbrepts; Stonewell- pyroclastic material, volcanogenic to Rapid in Relatively Recent Yallani families; Stonewell-Yallani- basalt or andesite mountain uplands Volcanic Parent Materials Inville families, pumice overburden Mid Elevation Soils on Gently Sloping to Smarts-DeMasters-Patio families; Basalts, andesites Slow to Moderate extremely Steep Bertag-Smarts-Cavanaugh families; Mountain uplands Moderate to High or tuff Slow Mountains in the Eastern Anatone-Bearskin-Merlin families Half of the Survey Area High elevation Nearly Higher elevations on Level to extremely Steep Divers-Lapine-Kinzel families; both the Medicine Andesite, basalt, tuff Soils on the Medicine Lake Behanin deep-Gralic-Loberg families; Lake shield volcano Slow to Rapid Moderate to High cinders or obsidian Highlands and on the Cheadle-Supervisor-Behanin families and the Warner Warner Mountains Mountain range Medicine Lake Highlands, east side of the Warner Miscellaneous Areas with Vesicular basalt Lava flow rock-Rock outcrop; Water Mountain range; Not Applicable Not Applicable Little or No Soil Present flows or obsidian Medicine Lake, Clear lake Reservoir and Big Sage Reservoir ** Approximately 85% of the acreage involved in this map unit is composed of shallow soils overlying a silica duripan, or over basal or tuff bedrock (USDA Forest Service 1983).

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There are 127 soil map units rated as sensitive and/or shallow. They comprise 1,226,588 acres, or approximately 60.4 percent of the area within the Forest. This information is summarized in Appendix A to this report. (Appendix A is part of the Watershed and Soils specialist report, found in Appendix T, Watershed and Soils, of this final EIS.) Based on Best Management Practices Evaluation Program (BMPEPs) for a multitude of projects including grazing, road maintenance, fuels reduction, timber harvest and prescribed fire, soils on the Modoc National Forest are meeting R5 soil quality standards and Modoc Forest Plan objectives (USDA Forest Service 2004). Soils are in a natural condition, with soil loss not greater than the soil quality standards and within acceptable levels as specified in the Modoc Forest Plan.

Soil Conditions within Treatment Areas A GIS query of known weed occurrences in relation to the Forest Activity Tracking System (FACTS) data was completed. The analysis determined that over 90 percent of known weed locations are found within one-quarter mile of roads. These areas have highly disturbed soil conditions. Disturbance typically includes the loss or mixing of surface organics and mineral soil into subsurface mineral soil horizons. This is often due to soil displacement, and/or altered soil structure and porosity, as a result of mineral soil compaction. Conditions affecting vegetative growth, such as available moisture holding capacities and soil porosity, are likely to also have been altered. Because many invasive plants prefer disturbed sites, this creates conditions in which invasive species are able to out-compete native species.

Table 3 - 4. Range of size in invasive plant sites within the Modoc National Forest Boundaries

Percent of Inventoried Size of Infestation No. of Invasive Plant Sites sites Less than 1 acre 652 94 1 to 5 acres 27 27 5 to 10 acres 6 <1 10 to 50 acres 8 <1 50 to 100 acres 0 <1 More than 100 acres 3 <1 Total 6961 100% 1 Includes private lands Ninety-four percent of the areas in which invasive species occur on the Modoc National Forest are less than 1 acre in size. The largest defined area of noxious weeds on the Forest is 5,657.8 acres infested with dyer’s woad. Infested sites not along roads can include areas burned by fires and areas where streams have acted as a corridor for movement of plants downstream. Burned areas lack plant cover, generally include disturbances from heavy equipment creating firebreaks, and can have changed soil properties from soil heating. Where streams have acted as a corridor for movement of invasive plants downstream, soils are fairly undisturbed. As discussed above, there are approximately 2 million acres of soils mapped on the Modoc National Forest. Approximately 64 percent, or 1, 273, 954 of these acres, have soils that contain either a sensitive or shallow soil component. The known or identified noxious weed sites occur on 0.5 percent of the shallow and sensitive soils found on Forest (Adams 2007a).

Effect of Invasive Plants on Soils Invasive plants can alter soil properties such as pH, nutrient cycling, and changes in composition or activity of soil microbes. Reductions in soil nutrient levels make it difficult for native plants to

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compete with the invasive plants, and probably affect the soil biotic community health. However, the long-term effects of these changes are not known (USDA Forest Service 2006). As shown in Table 3-4, 94 percent of the sites are less than an acre, 27 percent are between 1 and 5 acres, and less than 1 percent are greater than 5 acres. See Appendix B of the Modoc Noxious Weed FEIS for more details on existing sites.

Soil and Water Interactions Water infiltration rates and volumes can be reduced on weed-infested sites due to reduced cover (DiTomaso 2000). Significantly greater surface water runoff, indicating less infiltration, has been measured from spotted knapweed-dominated sites compared to adjacent native grass-dominated sites (Lacey, Marlow, and Lane 1989). Compaction, which is present in many weed-infested sites, also tends to reduce infiltration rates. Reductions in soil organic matter can also reduce the amount of water held in the soil profile, especially near the surface (Brady and Weil 1999, Tisdall and Oades 1982).

Vegetative Cover Total vegetative cover may be reduced on weed-infested sites from that provide by native vegetation and can result in higher evaporation from exposed mineral soil on the surface (Lauenroth, et al. 1994). Soil water stored deeper in the profile may also be depleted more rapidly on sites where vegetative cover provided by weeds is dense and associated transpiration rates are high (Olson 1999).

Soil Erosion Weed-infested soil has been shown to be more susceptible to erosion than soil occupied by native grass species (Lacey, Marlow, and Lane 1989). Soil erosion in a simulated rainfall test more than doubled in spotted knapweed-dominated rangeland areas when compared to natural bunchgrass/forb grasslands. This is primarily due to significantly lower infiltration rates and higher levels of bare ground on the knapweed-dominated site compared to the uninfested areas (ibid.). Weeds are less able to dissipate the kinetic energy of rainfall, overland flow, and wind that cause soil erosion, primarily due to the loss of cover provided by native species on site (Torri and Borselli 2000, Fryrear 2000).

Soil Biota Plants and mycorrhizal fungi are strongly dependent on each other, and species of fungi are associated with specific plants. Presence of non-native plants also leads to changes in the mycorrhizal fungus community (ibid.). These changes could increase the difficulty of reestablishing native vegetation after the invasive plants are removed.

Soil Nutrient Availability Noxious weeds directly limit nutrient availability by out-competing native species for limited soil resources. Weeds have high nutrient uptake rates and can deplete soil nutrients to very low levels, especially in cases where weed species germinate prior to native species and exploit nutrient and water resources, before native species are actively growing (Olson 1999). Spotted knapweed has been implicated in reducing available potassium and nitrogen (Harvey and Nowierski 1989). Potassium, nitrogen, and phosphorous levels were shown to be 44, 62, and 88 percent lower, respectively, in spotted knapweed-infested soil than in adjacent grass covered soil

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(Olson 1999). Some invasive plants are allelopathic to other plants, and produce secondary compounds that can directly increase the population of soil microbes capable of metabolizing this compound, while decreasing the populations of other microbes (ibid.). Allelopathic is defined as suppression of growth of a plant by a toxin released from a nearby plant of the same or another species. These changes will affect the soil food web and nutrient cycling, and may have impacts on the native plant community. Weed-infested areas may also indirectly limit nutrient availability as a result of soil erosion from compacted conditions or reduced effective cover. Erosion selectively removes organic matter and the finer sized soil particles that store nutrients for plant use, leaving behind soil with a reduced capacity to supply nutrients. Water Resources

Overall Watershed Conditions Stream surveys and stream condition assessments have been conducted since the completion of the 1991 FEIS and Forest Plan for the Modoc National Forest. Stream surveys and condition assessments have been completed for other analyses from 1995 to the present, both at the project level and cumulative effects levels. Based on gathered information, and the completion of the Modoc NF Watershed Condition Assessment (2001), Forest watersheds are hydrologically stable, with isolated stream reaches that have bank erosion, due to the effects of activities related to Forest management. These reaches were noted to have sustained periods of flow. In addition, review of data mentioned above indicates the majority of streams are considered to be in proper functioning condition (PFC) (Brady and Weil 1999). Water quality and riparian condition are the two elements potentially affected by invasive plant treatments. The approximately 6,908.4 acres of invasive plants identified for treatment are scattered across the Forest in 29 of 39 5th-field watersheds. Of the 6,908.4 acres identified as having invasive plants, 136.5 acres, or 1.4 percent, are located within areas identified as part of critical aquatic refuges. An additional 2.8 percent of the acres infested with noxious weeds are located within riparian conservation areas.

Water Quality As stated on page 3, water quality in California is regulated by the Clean Water Act and the Regional Water Boards (RWBs) identify and establish beneficial uses for surface and groundwater. Each RWB has developed water quality control plans, also known as basin plans, which provide the basis for protecting water quality in the state of California. Included in each plan are water quality objectives, which the RWB has determined will ensure reasonable protection of beneficial uses identified by the RWB for surface and groundwater (http://www.waterboards.ca.gov/northcoast/programs/basinplan/basin.html). The three RWBs that include various parts of the Modoc National Forest include the Central Valley Regional Board in areas that drain to the Pit River, the North Coast Regional Board in Klamath Basin lands, and the Lahontan Regional Board in Great Basin lands (Figure 2). By direction of the Clean Water Act, where water quality is limited, state agencies develop total maximum daily load (TMDL) plans to improve water quality to support the beneficial uses of water. For water-quality-limited streams on National Forest System lands, the Forest Service provides information, analysis, and site-specific planning efforts to support State processes to protect and restore water quality.

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The most recent listing was approved for the state of California in 2002, which compiles all the information from each regional water board3. GIS data from the State was downloaded and reviewed in context of the Forest boundary and defined areas of noxious weed concentrations. No impaired stream reaches were found to be within defined noxious weed sites on the Forest.

Figure 3-2. Regional Water Quality Control Boards and Their Jurisdictions on the Modoc NF

Water Quantity and Timing There are approximately 5,922.2 miles of stream within the boundaries of the Modoc National Forest. Of these, 3,229.3 miles are seasonally flowing, which equates to 55 percent of the total stream miles within Forest boundaries. Approximately 36 percent, or 2,114.9 miles, are seasonally flowing, and 9 percent of the stream miles, or 578 miles, are perennial. The majority of the seasonally flowing streams flow during spring snowmelt, and are predominantly dry in later summer and fall. The exception is that flow can occur following a major precipitation event (Adams 2007a). Twenty of the 39 watersheds involved with the Forest produce a cumulative annual yield of 565,800 acre-feet of water per year. This does not include water yield from private lands found with the Forest boundary (USDA Forest Service 1999). The amount of water that runs off these watersheds is related to the type of precipitation events (snowmelt versus rainfall) and rainfall intensity. High-intensity and short-duration summer

3 http://www.waterboards.ca.gov/rwqcb5/water_issues/tmdl/impaired_waters_list/index.html

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storms have a tendency to yield more runoff than fall and winter storms. As the runoff increases, so does the energy to erode hillsides and transport sediment to the stream network.

Channel Morphology Stream surveys and stream condition assessments have been conducted on selected perennial streams on the Forest. Specified and approved stream survey protocols have been used to complete stream condition assessment, including stream condition inventory (SCI), Pfankuch ratings, and proper functioning condition (PFC). The results of stream condition assessments indicate that the majority of streams surveyed are considered to be “in equilibrium” with their geomorphic setting and are considered to be in proper functioning condition. Some channels are considered to be “functioning at risk” due to land management activities on the Forest based on their PFC ratings. Hardcopies of data collected from 1995 to the present are on file at the Forest Supervisor’s office in Alturas, California (Adams 2007b). Those streams that are in the functioning-at-risk category are considered to be affected by site- specific disturbances. Localized disturbances are more related to site-specific impacts from logging and related infrastructure, such as landings, temporary roads, and skid trails. Additional causes of site-specific disturbances included livestock grazing, road construction, and wildfire (Adams 2007a).

Riparian and Wetland Conditions Native riparian vegetation plays a key role in forming aquatic habitat for fish and other aquatic species. Roots help stabilize stream banks, preventing accelerated bank erosion and providing for the formation of undercut banks, important cover for juvenile and adult fish. Riparian areas with native vegetation supply downed trees (large wood) to streams. Riparian vegetation stabilizes stream banks, and serves as a filter to prevent the runoff of soil into streams. Riparian vegetation also provides large and small wood to streams, adding to habitat complexity, and providing cover and food sources for aquatic organisms. Aquatic ecosystems have evolved with certain vegetation types; invasive plants do not necessarily provide similar habitat. The 1991 FEIS to the Modoc Forest Plan states that there were almost 19,000 acres of riparian area found on the Forest. It states that 13, 473 of these acres were adjacent to streams, 2, 803 acres adjacent to springs and seeps; 122 acres adjacent to lakes and 2,583 acres were adjacent to wet meadows. The FEIS indicates that approximately 60 percent of riparian areas were located in the Warner Mountain District, with 20 percent in the Devil’s Garden District, and only 10 percent each on the Big Valley and Doublehead Districts. Five hundred fifty-two miles of stream were found to contain riparian habitat. Riparian vegetation was described to consist of three primary types: grass-forb understory with a willow midstory and no overstory (which was defined as the most common); a grass forb understory with no midstory or overstory (generally associated with wet meadows); and a conifer overstory with mixed-deciduous midstory and an understory, associated with perennial streams, particularly at high elevations (USDA Forest Service 1999). The FEIS also states that at the time of publication there was approximately 233 wetlands covering approximately 35,000 acres of Forest Service administered lands. The 2004 amendment to the Sierra Nevada Framework defines two areas of interest: riparian conservation areas and critical aquatic refuges. Riparian conservation areas (RCAs) are defined areas buffering streams. The delineations of Riparian Conservation Area for this FEIS from the Sierra Nevada Forest Plan Amendment FEIS Record of Decision (USDA Forest Service Pacific Southwest Region 2004 p.42) are as follows:

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Perennial Stream RCA: 300 feet on each side of the stream, measured from the bank full edge of the stream. Seasonally Flowing Stream RCA (includes intermittent and ephemeral streams): 150 feet on each side of the stream, measured from the bank full edge of the stream Special Aquatic Feature RCA (includes lakes, wet meadows, bogs, fens, wetlands, vernal pools, and springs): 300 feet from edge of feature or riparian vegetation, whichever width is greater. For this FEIS, the terms RCA and Streamside Management Zone (SMZ) are interchangeable. See definition of Streamside Management Zone in the glossary. The primary role of Critical Aquatic Refuges (CARs) is to preserve, enhance, restore or connect habitats for aquatic or riparian dependent species at the local level and to ensure the viability of these species. In many cases, CARs support the best remaining populations of native fish, amphibian, and plant species whose distributions have been substantially reduced elsewhere in the Sierra Nevada. CARs primarily protect occupied habitat of threatened, endangered, or sensitive animal species.4 Since the 2004 direction applies to this project, acreages for CARs and RCAs were determined at the time of this report being written. Based on currently available GIS data, analysis determined that there are approximately 127,716 acres of defined CARs within the Forest, 226,693.7 acres of RCAs associated with streams, and 117, 285.9 acres associated with meadows, lakes and springs. Wetlands are often used for recreation and are at risk from invasive plants, such as knotweeds that colonize areas downstream of the original infestation along a stream. Wetlands can be inundated with water year-round, and others are wet only seasonally. Areas that are wet only seasonally can be infested with upland species as well as those species adapted specifically to wetland areas. Existing conditions for CARs and RCAs were documented in the FEIS for the Forest Plan. It indicated that in the past, logging practices, road construction, and improper grazing practices contributed to riparian and wetland area degradation. Forest riparian areas were described as generally lacking the desired vegetation expressions to achieve overall management objectives. Riparian areas were noted to not have improved where livestock grazing was season long and where few or no structural improvements had been made. However, from 1995 to the present, surveys have been completed and a WSA completed. Results indicate that a majority of streams surveyed were considered in proper functioning condition (PFC). Watersheds are considered hydrologically stable. However, isolated reaches were noted where there was stream bank erosion or other types of site-specific disturbance are present. Periods of elevated stream flow were also noted (Adams 2007b). Where riparian vegetation is present and that reach has been documented as in PFC, riparian also would be considered in PFC. Data is on file at the Supervisor’s Office in Alturas, California.

Lakes and Floodplains Lakes and floodplain areas are often popular for recreation. As a result, these areas are at risk from invasive plants brought in by visitors, as plant parts and seeds can be carried downstream of the original infestation at high flows. There are numerous lakes and reservoirs that total an estimated 18,115.6 acres, based on current GIS data. GIS layers of floodplains were not available for the Forest and they are not discussed in

4 http://www.fs.fed.us/r5/rsl/projects/frdb/layers/cars.html

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the Forest Plan. However, perennial streams of lower gradients often have floodplains associated with them. Existing-condition information for lakes and floodplains is absent in the 1991 FEIS. However, as discussed above, data has been collected from 1995 to the present and the Watershed Condition Assessment for the Modoc National Forest was completed by Sue Becker et al. in 2000. Watersheds are considered hydrologically stable, and many stream reaches are in PFC. For those stream reaches involving watersheds that have received a PFC rating, it can be inferred that their floodplains are functioning properly. Data is on file at the Supervisors Office in Alturas, California.

Municipal Watersheds and Domestic Water Supplies A municipal supply watershed is one that serves a public water system as defined in Public Law 93-523 (Safe Drinking Water Act) or as defined in State safe drinking water regulations. No formal municipal watersheds or whole communities use water on-Forest. There are, however, several domestic water users scattered throughout or downstream from the Forest on numerous streams (USDA Forest Service 1991). While not a formal municipal watershed, the Fort Bidwell Indian Community gets drinking water from an area on National Forest System land. Through formal consultation with the Fort Bidwell Indian Community Council (April 6, 2006), the Forest agreed not to use herbicides to treat noxious weeds in the area of concern that supplies the community with drinking water. This area of concern is depicted on the map in Appendix N of the Noxious Weed FEIS. At this time, noxious weeds have not been identified in this area of concern. Further consultation would continue to identify suitable treatment methods under Early Detection-Rapid Response if sites are identified in the future. Alturas is the only incorporated town in Modoc County that is adjacent to the Forest boundary. The water supply for Alturas comes from groundwater wells. Neither the State Water Resources Control Board nor the Central Valley and North Coast Regional Waterboards identify any municipal watersheds on the Forest. The California Department of Water Resources (DWR) sampled for herbicide contamination in the Pit River near Alturas, California. The results of the water quality monitoring for the years of 2001 to 2005 is summarized below in Table 3-5. The results of the monitoring shows that while Glyphosate, Tricloypr, 2, 4-D and Dicamba were found in the water samples for the Pit River and the North Fork of the Pit River, none of the samples exceeded the “reporting limit”. The reporting limit triggers a report by the sampling agency to the EPA via the State or Regional Water Boards.

Table 3 - 5. Result of Water-Quality Monitoring on the Pit River (Lebeouf 2005)

Monitoring Results: 2001 through 2005-Pit River, North Fork, Station # A1210000 Did the sample exceed Chemical Reporting Limit (ug/L) Results Reported the Reporting Limit? Dicamba <0.1 <0.1 N Glyphosate <25 <25 N Tricloypr <0.1 <0.1 N 2, 4-D <0.1 <0.1 N

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Roads GIS analysis of known weed occurrences showed that over 90 percent of known weed occurrences are found along roads. In conducting the analysis, a distance of 1,320 feet (1/4 mile) was analyzed along system roads. For this project, roads within Riparian Conservation Areas are considered hydrologically connected to streams. The total number of miles of forest road, user-created roads, and railroads within the project area totals an estimated 3,900 miles, based on current GIS. In RCAs associated with streams, there are an estimated 578.0 miles of road, or 15 percent of the total road miles. In RCAs associated with springs, lakes, and reservoirs, there are an estimated 248.3 miles or 6.4 percent of the total road miles. Miles of road within noxious weed polygons, on the forest, total 26.6 miles, which is less than 1 percent of the total road miles.

Water Resources within Riparian Conservation Areas and Critical Aquatic Refuges

Invasive Plants within Riparian Conservation Areas and Critical Aquatic Refuges Tables 3-6 and 3-7 (below) show acres of invasive plants within RCAs and CARs of both perennial and seasonally flowing streams. None of these species is considered specifically riparian. Canada thistle can be found in riparian areas as can Scotch thistle and spotted knapweed. Scotch thistle and spotted knapweed can also be found in wet meadows. The other noxious weed species listed in Tables 3-6 and 3-7 are generally forest and upland species. However, spotted knapweed may be found in both moisture loving areas and more forested and upland settings.5 Canada thistle, spotted knapweed and Dalmatian toadflax have either all or most of their acreage within RCAs associated with perennial streams. dyer’s woad, Klamathweed, musk thistle, and Scotch thistle have most of their acreages within RCAs associated with seasonally flowing streams (Tables 3-6 and 3-7).

Table 3 – 6. Documented Invasive Plant Acres Within RCAs on the Modoc National Forest

Acres within Total Acres within Seasonally Acres Primary Invasive Plant Perennial Flowing in Stream RCAs Stream RCAs RCAs

Canada Thistle 1.2 7.7 8.9 Crupina 5.8 29.3 35.2 Dalmatian Toadflax 23.9 32.2 56.1 Diffuse Knapweed 1.2 1.1 2.3 Dyer’s Woad 3.7 16.3 20.0 Klamathweed (St. 0.1 0.5 0.6 Johnswort) Mediterranean Sage 4.7 0.8 5.5 Scotch Thistle 3.8 27.7 31.4 Spotted Knapweed 1.1 0.1 1.2

5 http://www.cal-ipc.org/ip/inventory/weedlist.php

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Acres within Total Acres within Seasonally Acres Primary Invasive Plant Perennial Flowing in Stream RCAs Stream RCAs RCAs

Yellow Starthistle 1.1 0.0 1.1 Musk Thistle 0.0 0.4 0.4 Total 46.6 116.1 162.7 There are three critical aquatic refuges on the Forest. Mill Creek 1 has no identified invasive weed sites. The sites within riparian areas of Goose Lake and Turner Creek CARs are shown below in Table 3-7.

Table 3 - 7. Documented Invasive Plant Acres Within CARs on the Modoc National Forest

Perennial Seasonal Seasonal % Acreage % Acreage Stream Stream Stream Total Associated Associated Primary Invasive Acres Acres Acres Acres with with Plant within within within within Perennial Seasonal Goose Goose Turner CARs Streams Streams Lake CAR Lake CAR Creek CAR Canada Thistle 0.2 0.0 0.0 0.2 100.0 0.0 Dalmatian Toadflax 23.9 19.1 0.0 43 55.6 44.4 Dyer’s woad 0.1 12.2 0.0 12.3 0.8 99.2 Klamath Weed 0.0 0.0 0.1 0.1 0.0 100.0 Musk Thistle 0.0 0.0 0.3 0.3 0.0 100.0 Scotch Thistle 0.1 0.7 0.1 0.9 11.1 88.9 Spotted Knapweed 0.1 0.0 0.0 0.1 100.0 0.0

While most invasive plants first occupy disturbed sites, once established, any of these species can begin to invade undisturbed sites (Stohlgren et al. 1999). Noxious weed acreage comprises 0 - 2.3 percent of the area of 5th-field watersheds (Table 3-8). Twenty-eight out of 39 5th-field watersheds involved within the Forest’s boundary, or 71 percent, have some acreage involved with noxious weeds. However, only two watersheds or 0.05 percent of the total number of watersheds, have acreages totaling greater than 1 percent of the 5th-field watershed’s total acreage (table3-8). For Copic Bay watershed, the large percentage of infestation is due to the large dyer’s woad site, which consists of 5,676.5 acres. For Round Valley watershed, the large percentage of infestation is due to the Common Crupina site that is on both public and private land. As treatments under this project would take place only on National Forest System lands, watershed involvement was reassessed by considering only those acres within the Forest boundary. When considering only those lands within the Forest boundary, by 5th-field watershed, then only the Copic Bay watershed has greater than 1 percent of its land infested with noxious weeds. This is due to one large dyer’s woad-infested site. Temperature - While invasive plants may provide some shade, they are replacing native forbs and grasses that are better bank stabilizers and promote narrower and deeper channels. Stable banks tend to provide more shade and consequently keep stream water temperatures lower. Sediment - There are 8.8 acres of spotted knapweed and 4.1 acres of diffuse knapweed identified for treatment on the Forest. There are 1.1 acres of spotted knapweed within RCAs associated

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with perennial streams and 0.1 acre within RCAs associated with seasonally flowingstreams. Diffuse knapweed acreage is not associated with either RCAs or CARs. Lacey et al. (1989) reported higher runoff and sediment yield on sites dominated by knapweed versus sites dominated by native grasses.

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Table 3 - 8. Acres Infested by Invasive Plants for Whole 5th-Field Watersheds

Percentage of Entire 5th-field Watershed Hydrologic Infested Acres 5th-field Watershed Name Unit Code Acres Infested

Ash Valley-Cottonwood 1802000212 102250.9 9.8 0.0 Creek Big Valley 1802000217 87632.0 3.0 0.0

Boles-Fletcher Creek 1801020401 216746.0 3.9 0.0

Canby-Pit River 1802000209 157640.0 28.8 0.0 Canyon Creek 1802000207 61749.4 0.4 0.0 Clear Lake 1801020403 143249.0 0.2 0.0

Clover Swale Creek 1802000208 57672.8 0.4 0.0

Copic Bay 1801020411 243169.6 5676.5 2.3 Goose Lake East 1802000103 156132.8 133.3 0.1 Shore Goose Lake West 1802000104 96239.2 1.6 0.0 Shore Horse Creek 1802000301 164558.4 3.5 0.0 Jess Valley 1802000201 64125.0 1.3 0.0 Juniper Creek 1802000216 50660.3 9.5 0.0 Lower Alkali Lake 1808000103 133914.8 0.1 0.0 Lower Ash Creek 1802000215 84393.1 3.7 0.0 Lower South Fork Pit 1802000203 139538.5 0.3 0.0 River Middle Alkali Lake 1808000102 240481.2 0.9 0.0

North Fork Pit River 1802000204 139287.9 2.7 0.0

North Fork Willow 1801020402 90356.0 0.6 0.0 Creek Rattlesnake Creek 1802000205 124105.7 0.8 0.0 Round Valley 1802000213 60382.3 770.1 1.3 Taylor Lake 1802000211 235602.2 883.7 0.4 Tule Lake Sump 1801020410 127974.8 0.1 0.0 Turner Creek 1802000210 49069.5 3.3 0.0 Upper Alkali Lake 1808000101 201463.6 19.8 0.0 Upper South Fork Pit 1802000202 208686.0 6.4 0.0 River

Warm Springs Valley 1802000206 44037.9 28.5 0.1

Willow Creek 1802000214 49869.2 0.9 0.0

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 3 - 9. Acres Infested by Invasive Plants for National Forest System Land by 5th-Field Watersheds

Fifth Field Percent Watershed Watershed Hydrologic Watershed Infested Acres Within Forest That Name/Clipped to Unit Code Acres Is Infested FS boundary Ash Valley- Cottonwood 1802000212 42543.0 9.8 0.0 Creek Big Valley 1802000217 9554.3 3.0 0.0 Boles-Fletcher 1801020401 216746.0 3.9 0.0 Creek Canby-Pit River 1802000209 109690.8 28.8 0.0 Canyon Creek 1802000207 16276.8 0.4 0.0 Clear Lake 1801020403 109940.6 0.2 0.0 Clover Swale 1802000208 41637.3 0.4 0.0 Creek Copic Bay 1801020411 222634.5 5676.2 2.5 Goose Lake East 1802000103 67613.9 133.2 0.2 Shore Goose Lake West 1802000104 49473.1 1.6 0.0 Shore Horse Creek 1802000301 18440.0 3.5 0.0 Jess Valley 1802000201 64125.0 1.3 0.0 Juniper Creek 1802000216 33326.0 9.5 0.0 Lower Alkali Lake 1808000103 21967.9 0.1 0.0 Lower Ash Creek 1802000215 14842.0 3.5 0.0 Lower South Fork 1802000203 28964.5 0.3 0.0 Pit River Middle Alkali Lake 1808000102 41512.8 0.8 0.0 North Fork Pit 1802000204 64273.3 2.6 0.0 River North Fork Willow 1801020402 62555.5 0.6 0.0 Creek Rattlesnake 1802000205 114438.0 0.8 0.0 Creek Round Valley 1802000213 47791.3 182.5 0.4 Taylor Lake 1802000211 201380.3 878.8 0.4 Tule Lake Sump 1801020410 84210.1 0.1 0.0 Turner Creek 1802000210 49069.5 3.3 0.0 Upper Alkali Lake 1808000101 42668.0 17.4 0.0 Upper Lost River 1801020404 30723.4 2.0 0.0 Upper South Fork 1802000202 69890.0 2.3 0.0 Pit River Warm Springs 1802000206 7665.1 3.0 0.0 Valley Willow Creek 1802000214 33936.1 0.9 0.0

116 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Channel Morphology and Riparian Condition In the Forest, there are approximately 46.6 acres of noxious weeds associated with perennial streams, and 116.2 acres associated with seasonally flowing streams in RCAs. In CARs there are approximately 24.4 acres found associated with perennial streams in the Goose Lake CAR, while 32 acres are associated with seasonally flowing streams. In the Turner Creek CAR there is only 0.5 acre associated with seasonally flowing streams and there is no perennial stream association. Native riparian vegetation plays a key role in forming aquatic habitat for fish and other aquatic species. Tree roots help stabilize stream banks, preventing accelerated bank erosion and providing for the formation of undercut banks, important cover for juvenile and adult fish. Riparian areas with native vegetation supply downed trees (large wood) to streams. In turn, downed trees in streams influence channel morphology characteristics such as longitudinal profile; pool size, depth, and frequency; channel pattern; and channel geometry. Turbulence created by large wood increases dissolved oxygen in the water needed by fish, invertebrates, and other biota. Invasive plants could slow down or prevent the establishment of native trees, decreasing or delaying the future supply of large wood in stream channels (USDA Forest Service 2005) While invasive grasses and forbs would not directly replace riparian shrubs, in degraded areas where shrubs are no longer present, invasive plants can occupy sites and out-compete native vegetation, limiting opportunities for native shrubs to reoccupy the site.

Lakes and Wetlands There are 153,187 acres of RCAs surrounding wet meadows, lakes, and springs. Within these areas, approximately 128 acres of invasive plants have been identified. Of these, approximately 66 are near lakes, 11 are near springs, and 40 are in meadows. Many of the lakes and springs are within the larger Dalmatian toadflax treatment area.

Table 3 - 10. Documented Invasive Plant Acres Within Lake, Spring, or Wet Meadow RCAs

Invasive Plant Acres Canada Thistle 10.8 Crupina 0.7 Dalmatian Toadflax 98.4 Dyer’s woad 3.0 Klamath Weed 0.3 Mediterranean Sage 5.3 Musk Thistle 1.1 Scotch Thistle 8.3 Spotted Knapweed 0.0 Squarrose Knapweed 0.1 Yellow Starthistle 0.1 Total 128.0

General Watershed Function Water temperature regimes promote recovery or enhancement of riparian vegetation. Management activities provide high levels of protection to streams, stream banks, riparian areas, and wetlands. Riparian areas in less than desirable condition have been improved to provide for riparian-dependent resources. These improvements have resulted from better control and

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

administration of livestock use in riparian areas, reduced timber harvest in forested riparian areas, and more roads being closed or obliterated. Watershed and fisheries habitat improvement projects have been completed on priority streams, and riparian hardwood communities have been increased or reestablished. Bank stability, water quality, fish and wildlife habitat, recreation opportunities, and aesthetics have improved. Streamside vegetation is more diverse and abundant with native species. Any significant change in total stream flow or timing of high and low flow has primarily been a result of naturally occurring events and conditions.

Design Standards and Monitoring Design Standards Design Standards were developed for each of the proposed Alternatives. Design Standards are developed to reduce or eliminate impacts related to analysis issues and affected resources areas, and are incorporated as an integrated part of the Proposed Action and any action Alternatives. While developing the Design Standards for the Proposed Action and the other action Alternatives, the following soil and water quality characteristics were considered:  Soil permeability of moderately rapid to rapid (herbicide)  Soil drainage of somewhat excessively drained to excessively drained (herbicide).  Soil depth of less then 20 inches to bedrock when a silica duripan does not underlie the soil (herbicide).  Unique or specialized land forms such as rubble land, rock outcrop, lava flows and saturated water tables (herbicide).  Distance to High Water Mark of streams, lakes, ponds, springs and meadows from the application of herbicides  Mobility of herbicides and considering the method of application within 100 feet of High Water Mark of streams, lakes, ponds, springs and meadows (herbicide).  Maximum soil erosion hazard rating of high or very high and water runoff potential (herbicide and physical). The Design Standards are listed in Tables 3-11 through 3-13. Alternatives 2 and 4 share the same Design Standards, while Alternatives 3 and 5 share similar Design Standards. The Design Standards for Alternative 6 apply to that Alternative alone, and Alternative 1 is the no-action Alternative. They are based on Best Management Practices (BMPs) that have proven to be effective under similar circumstances and conditions (Bakke 2001, USDA Forest Service 2004), and best available science. Implementation of Design Standards would be mandatory for the Alternative selected. This would ensure that treatments would have effects within the scope of analysis.

118 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 3 - 11. Design Standards Pertinent to Soil or Water Resources Under Alternatives 2 and 4

Design Purpose of Design Source of Design Soil and Water Design Standard Standard Standard Standard To reduce the Water: Annually the amount of physical potential for indirect disturbance and/or herbicide application would be Modoc Forest Plan DS-14 or cumulative effects limited to no more than 15% of each 6th Field Pg 4-22, S&G Soils #2 to 6th field Sub-watershed. watersheds The specified distances for perennial streams, lakes and special aquatic features is 300 feet and 150 feet for seasonally flowing streams, both of which are consistent with Riparian Conservation Areas as defined the Sierra Nevada Framework (SNF) ROD, 2001. For the Noxious Weed FEIS, To protect water the designated zone for all SMZs is the Riparian quality and stream Modoc Forest Plan as Conservation Areas (RCAs) on the Modoc health from the Modified by the 2002 DS-15 National Forest. See the definition for Riparian potential indirect and Amendment to the Sierra Conservation Area in the glossary. Therefore, for cumulative effects of Nevada Framework the Noxious Weeds FEIS, the terms SMZ and proposed noxious RCA are interchangeable. For the purpose of weed treatment noxious weed treatments, SNF RCA standards will apply forest wide. Within these prescribed RCAs, limited hand treatments may occur for a distance of 10 feet outward from the edge of the High Water Mark. The RCAs will be maintained with 50% of the To protect water acreage of the RCA as undisturbed; disturbance quality, stream health BMP 1.8 Designation of will be limited to no more than 25% of the and runoff patterns of Streamside Management acreage of the inner half of the RCA. the RCAs from Zones DS-16 potential indirect and BMP Stream Course and cumulative effects Aquatic Protection 1.19 related to proposed noxious weed (FSHB 2509.22) treatments. Water - RCA Treatments: Herbicide treatment within the Riparian Conservation Areas (RCAs) To protect water will be as follows: quality from the -From the High Water Mark outward to 10 feet, potential Developed via IDT no herbicide use (only Physical Methods). contamination of the discussion to tier to BMP -From a distance of 10 feet to the outer edge of water column from 5.12: Streamside Wet Area RCAs for Seasonally Flowing or Perennial the application of Protection During Pesticide DS-17 Streams, only Aquatic Glyphosate may be those herbicides with Spraying; 1, 000 ft distance applied by wicking it onto the plant. the identified from surface or live water -From the outer edge of RCAs for Seasonally potential to move off developed in consultation Flowing or Perennial Streams, glyphosate, site and adversely with USFWS. clopyralid, dicamba, and triclopyr may be applied. affect soil or water -2, 4-D will not be applied within 1,000 feet of the quality. High Water Mark of Seasonally Flowing or Perennial Streams. BMP 5-4: Revegetation of To provide guidance Surface Disturbed Areas Soils: Areas with bare soil resulting from noxious for assessing treated Soil S&G E, Chapter 4 DS-20 weed treatments that are greater than ¼ acre in areas for Modoc Forest Plan size will be assessed for need for rehabilitation. rehabilitation Regional Soil Quality Standards, FSHB 2509.18 Annually the Forest Hydrologist, Watershed Specialist or Soil Scientist determines the BMP 5.7: Pesticide Use location of the noxious weed occurrence to be Planning Process; BMP 5-8: To provide guidance treated to determine if the site to be treated is Pesticide Application DS-22 in protecting shallow located on sensitive or shallow soils. If it is According to Label and sensitive soils determined that the site to be treated contains Directions and Applicable and water quality sensitive or shallow soils then either DS 23 or 24 Legal Requirements (FSHB would be applied, depending on Alternative 2509.22) selected.

Chapter 3—Affected Environment & Environmental Consequences 119 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Design Purpose of Design Source of Design Soil and Water Design Standard Standard Standard Standard BMP 5.7: Pesticide Use To prevent or Planning Process; BMP 5-8: Soils: On noxious weed sites identified as having mitigate the Pesticide Application DS-23 sensitive soils and/or shallow soils, do not use incorporation of According to Label herbicides with high leaching potential to treat pesticides into Directions and Applicable noxious weeds. groundwater Legal Requirements (FSHB 2509.22) Soils: On those sites with soils identified as having a high or very high erosion potential or a To protect Soil rapid or very rapid risk to runoff do not use Region 5 Soil Quality Quality Standards DS-25 Physical and Physical+ methods to treat noxious Standards FSHB 2509.18 soil productivity and weeds when the fire weather forecast for the next S&G #1, Modoc Forest Plan soil hydrologic 24 hours states there is a likely chance of Chapter 4 function thunderstorms (generally 60-70% or greater as defined by the National Weather Service). Herbicides: When applying herbicides within RCAs, from the High Water Mark outward to a distance of 25 feet, all directed spray must be done in a downward direction. In addition, when BMP 5-12: Streamside Wet the height of a weed is greater than 36 inches, area Protection During the weed will be laid on the ground and sprayed Pesticide Spraying To control drift within DS-29 in a downward direction. This will minimize BMP 5-13: Controlling the inner third of the herbicide drift and confine the herbicide to the Pesticide Drift During Spray RCA drop zone of the individual weed plant being Application treated. Beyond 25 feet within RCAs and outside Modoc Forest Plan Water of RCAs, herbicides will be applied by on-the- S&G’s 1 and 2 ground applicators directly spraying or wicking the target noxious weed. Spraying will be done in a downward direction to the extent possible. Control of Drift or Herbicide Migration: All herbicide application will follow EPA approved label directions in regards to control of drift of BMP 5-8: Pesticide herbicides during spraying. These directions have Application According to To control drift of DS-34 specific wind speeds and air temperatures for Label Directions and herbicides application of each herbicide. In addition, Applicable Legal applicators will utilize droplet size and spray Requirements pressure to insure droplets do not travel outside of the drip line target plant.

Table 3 - 12. Design Standards Pertinent to Soil or Water Resources Under Alternatives 3 and 5

Design Purpose of Design Soil and Water Design Standard Source of Design Standard Standard Standard Water: Annually the amount of physical To reduce the potential DS-14 disturbance and/or herbicide application would for indirect or Modoc Forest Plan be limited to no more than 15% of each 6th cumulative effects to Pg 4-22, S&G Soils #2 Field Sub-watershed. 6th field watersheds The specified distances for perennial streams, lakes and special aquatic features is 300 feet and 150 feet for seasonally flowing streams, both of which are consistent with Riparian To protect water quality Conservation Areas as defined the Sierra and stream health from Modoc Forest Plan as DS-15 Nevada Framework ROD, 2001. RCAs contain the potential indirect Modified by the 2002 Streamside Management Zones (SMZs) which and cumulative effects Amendment to the Sierra are defined in the 1991 Modoc Land and of proposed noxious Nevada Framework Resource Management Plan. Within these weed treatment prescribed RCAs, limited hand treatments may occur for a distance of 10 feet outward from the edge of the High Water Mark. The RCAs will be maintained with 50% of the To protect water BMP 1.8 Designation of acreage of the RCA as undisturbed; quality, stream health DS-16 Streamside Management disturbance will be limited to no more than 25% and runoff patterns of Zones of the acreage of the inner half of the RCA. the RCAs from BMP Stream Course and potential indirect and

120 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Design Purpose of Design Soil and Water Design Standard Source of Design Standard Standard Standard cumulative effects Aquatic Protection 1.19 related to proposed (FSHB 2509.22) noxious weed treatments. BMP 5-4: Revegetation of Soils: Areas with bare soil resulting from Surface Disturbed Areas To provide guidance DS-20 noxious weed treatments that are greater than Soil S&G E, Chapter 4 for assessing treated ¼ acre in size will be assessed for need for Modoc Forest Plan areas for rehabilitation rehabilitation. Regional Soil Quality Standards, FSHB 2509.18 To ensure that the BMP 5-4: Revegetation of treatment of noxious Surface Disturbed Areas Soils: Areas with bare soil created by the weeds is not creating Soil S&G E, Chapter 4 DS-21 treatment of noxious weed, the site would be open areas or bare Modoc Forest Plan evaluated for rehabilitation (Alternative 5). areas for spread of Regional Soil Quality noxious weeds. Standards, FSHB 2509.18 Soils: On those sites with soils identified as having a high or very high erosion potential or a rapid or very rapid risk to runoff do not use To protect Soil Quality Region 5 Soil Quality DS-25 physical methods to treat noxious weeds when Standards soil Standards FSHB 2509.18 the fire weather forecast for the next 24 hours productivity and soil S&G #1, Modoc Forest Plan there is a likely chance of thunderstorms hydrologic function Chapter 4 (generally 60-70% or greater as defined by the National Weather Service). Herbicides: When applying herbicides within RCAs, from the High Water Mark outward to a distance of 25 feet, all directed spray must be done in a downward direction. In addition, when BMP 5-12: Streamside Wet the height of a weed is greater than 36 inches, area Protection During the weed will be laid on the ground and sprayed Pesticide Spraying in a downward direction. This will minimize To control drift within DS-29 BMP 5-13: Controlling herbicide drift and confine the herbicide to the the inner third of the Pesticide Drift During Spray drop zone of the individual weed plant being RCA Application treated. Beyond 25 feet within RCAs and outside of RCAs, herbicides will be applied by Modoc Forest Plan Water on-the-ground applicators directly spraying or S&G’s 1 and 2 wicking the target noxious weed. Spraying will be done in a downward direction to the extent possible.

Table 3 - 13. Design Standards Pertinent to Soil or Water Resources Under Alternative 6

Design Purpose of Design Source of Design Soil and Water Design Standard Standard Standard Standard Water: Annually the amount of physical To reduce the potential DS-14 disturbance and/or herbicide application would for indirect or Modoc Forest Plan be limited to no more than 15% of each 6th cumulative effects to 6th Pg 4-22, S&G Soils #2 Field Sub-watersheds. field watersheds The specified distances for perennial streams, lakes and special aquatic features are 300 feet and 150 feet for seasonally flowing streams, both of which are consistent with Riparian Conservation Areas as defined the Sierra To protect water quality Nevada Framework (SNF) ROD, 2001. For the and stream health from Modoc Forest Plan as Noxious Weed FEIS, the designated zone for DS-15 the potential indirect Modified by the 2002 all Streamside Management Zones is the and cumulative effects Amendment to the Sierra Riparian Conservation Areas (RCAs) on the of proposed noxious Nevada Framework Modoc National Forest. See the definition for weed treatment Riparian Conservation Area in the glossary. Therefore, for the Noxious Weeds FEIS, the terms SMZ and RCA are interchangeable. For the purpose of noxious weed treatments, SNF RCA standards will apply Forest wide. Within

Chapter 3—Affected Environment & Environmental Consequences 121 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Design Purpose of Design Source of Design Soil and Water Design Standard Standard Standard Standard these prescribed RCAs, limited hand treatments may occur for a distance of 10 feet outward from the edge of the High Water Mark. The RCAs will be maintained with 50% of the To protect water acreage of the RCA as undisturbed; quality, stream health disturbance will be limited to no more than 25% and runoff patterns of BMP 1.8 Designation of Streamside Management of the acreage of the inner half of the RCA. the RCAs from DS-16 Zones potential indirect and BMP Stream Course and cumulative effects Aquatic Protection 1.19 related to proposed (FSHB 2509.22) noxious weed treatments. Water - RCA Treatments: Within the Riparian Conservation Areas (RCAs) outside of the Lahontan Regional Water Board area of jurisdiction, herbicide treatments will be as follows: -From the High Water Mark outward, aquatic formulations of Glyphosate may be used in RCAs for Seasonally Flowing or Perennial Streams (as well as Physical (+) Methods. To protect water quality -From a distance of 10 feet from the High from the potential Gill, R., 1993. Letter from Water Mark outward to the outer edge of RCAs contamination of the California Regional Water for Seasonally Flowing or Perennial Streams, water column from the Quality Control Board - Glyphosate and Amine forms of 2, 4-D may be application of those Lahontan Region to Diane DS-18a used. herbicides with the K. Henderson, Forest -From 25 feet from the High Water Mark identified potential to Supervisor on Noxious outward to the outer edge of RCAs for move off site and Weed Control EIS. Nov. 4, Seasonally Flowing or Perennial Streams, adversely affect soil or 1993. Chlorsulfuron, Dicamba, Clopyralid, Triclopyr; water quality. and Tank Mixes 1 and 2 with only amine forms of 2, 4-D. -From 100 feet from the High Water Mark outward to the outer edge of RCAs for Seasonally Flowing or Perennial Streams, Chlorsulfuron, Dicamba, Clopyralid, Triclopyr; and Tank Mixes 1 and 2 with either ester or amine forms of 2, 4-D. No more than 10 percent of the acreage with RCAs for the Frog Waterhole (6th Field HUC 180200021103) and RCAs for lakes found within Clarks Valley (6th Field HUC To protect water quality 18020030106) would be treated with herbicide Developed by Peter Adams, DS-18b and avoid cumulative each year, from the edge of the High Water Forest Hydrologist effects. Mark for a distance of 100 feet. When applied from the High Water Mark to a distance of 25 feet from water, herbicides would be applied by wicking them directly on the plant. In the areas under the Lahontan Water Quality Control Board jurisdiction (see Figure 3-2), with Alternative 6 no herbicide treatment will occur To meet Lahontan RWB from the High Water Mark for a distance of 10 Objective of No BMP 1.19 Stream course DS-19a feet. From a distance of 10 to 100 feet from the detectable Pesticides in and Aquatic Protection High Water Mark, only aquatic glyphosate will the water column. be used. At a distance greater than 100 feet from the High Water Mark, the other herbicides shown in the Alternative may be applied. Do not use herbicides to treat noxious weeds in To protect water quality the Area of Concern that supplies the Ft. from the potential Bidwell Reservation with drinking water (see contamination of the P. Adams and D. Meza, DS-19b map in Appendix N). If weeds become water column from the 2006 established in the future, consult with the Ft. application of those Bidwell Tribe to determine suitable treatment herbicides with the methods under Early Detection – Rapid identified potential to

122 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Design Purpose of Design Source of Design Soil and Water Design Standard Standard Standard Standard Response. move off site and adversely affect soil or water quality. BMP 5-4: Revegetation of Soils: Areas with bare soil resulting from Surface Disturbed Areas To provide guidance for DS-20 noxious weed treatments that are greater than Soil S&G E, Chapter 4 assessing treated areas ¼ acre in size will be assessed for need for Modoc Forest Plan for rehabilitation rehabilitation. Regional Soil Quality Standards, FSHB 2509.18 To ensure that the BMP 5-4: Revegetation of treatment of noxious Surface Disturbed Areas Soils: Areas with bare soil created by the weeds is not creating Soil S&G E, Chapter 4 DS-21 treatment of noxious weed, the site would be open areas or bare Modoc Forest Plan evaluated for rehabilitation (Alternative 5). areas for spread of Regional Soil Quality noxious weeds. Standards, FSHB 2509.18 Annually the Forest Hydrologist, Watershed Specialist or Soil Scientist determines the BMP 5.7: Pesticide Use location of the noxious weed occurrence to be Planning Process; BMP 5-8: To provide guidance in treated to determine if the site to be treated is Pesticide Application DS-22 protecting shallow and located on sensitive or shallow soils. If it is According to Label sensitive soils and determined that the site to be treated contains Directions and Applicable water quality sensitive or shallow soils then either DS 23 or Legal Requirements (FSHB 24 would be applied, depending on Alternative 2509.22) selected. Soils: Treatment of noxious weeds on sensitive To reduce the potential and/or shallow soils utilizing herbicides other for an indirect or FSH 2509.18 R5 than glyphosate will not exceed 1 acre per 6th cumulative effect to soil Supplement No. 2509.18.95- DS-24a field sub-watershed on an annual basis. and watershed 1 (R5 Soil Quality resources from the Standards) treatment of noxious weeds. Soils: Limit annual herbicide treatments in 6th To reduce the potential field sub-watersheds to no more than 10% of for an indirect or FSH 2509.18 R5 the acreage of the 6th field sub-watershed. cumulative effect to soil Supplement No. 2509.18.95- DS-24b and watershed 1 (R5 Soil Quality resources from the Standards) treatment of noxious weeds. Soils: On those sites with soils identified as having a high or very high erosion potential or a rapid or very rapid risk to runoff, do not use To protect Soil Quality Region 5 Soil Quality DS-25 Physical+ methods to treat noxious weeds Standards soil Standards FSHB 2509.18 when the fire weather forecast for the next 24 productivity and soil S&G #1, Modoc Forest Plan hours there is a likely chance of thunderstorms hydrologic function Chapter 4 (generally 60-70% or greater as defined by the National Weather Service). Herbicides: When applying herbicides within RCAs, from the High Water Mark outward to a distance of 25 feet, all directed spray must be done in a downward direction. In addition, when BMP 5-12: Streamside Wet the height of a weed is greater than 36 inches, area Protection During the weed will be laid on the ground and Pesticide Spraying sprayed in a downward direction. This will DS-29 BMP 5-13: Controlling minimize herbicide drift and confine the To control drift Pesticide Drift During Spray herbicide to the drop zone of the individual Application weed plant being treated. Beyond 25 feet within RCAs and outside of RCAs, herbicides will be Modoc Forest Plan Water applied by on-the-ground applicators directly S&G’s 1 and 2 spraying or wicking the target noxious weed. Spraying will be done in a downward direction to the extent possible. Control of Drift or Herbicide Migration: All BMP 5-8: Pesticide herbicide application will follow EPA approved To control aerial drift of Application According to DS-34 label directions in regards to control of drift of herbicides Label Directions and herbicides during spraying. These directions Applicable Legal

Chapter 3—Affected Environment & Environmental Consequences 123 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Design Purpose of Design Source of Design Soil and Water Design Standard Standard Standard Standard have specific wind speeds and air temperatures Requirements for application of each herbicide. In addition, applicators will utilize droplet size and spray pressure to insure droplets do not travel outside of the drip line target plant. Note: In the areas under the Lahontan Water Quality Control Board jurisdiction (see Figure 3-2), with Alternative 6 no herbicide treatment will occur from the high-water mark for a distance of 10 feet. From a distance of 10 to 100 feet from the high-water mark, only aquatic glyphosate will be used. At a distance greater than 100 feet from the high-water mark, the other herbicides shown in the Alternative may be applied.

The distances shown below by Alternative are summarized from the above Design Standards for all Alternatives that allow herbicide use.

Table 3 - 14. Summary of Distances from High Water Mark for Herbicide Use

Distance from High Water Mark (feet) Herbicide Alt 6 within Alt 2 Alt 4 Alt 6 CARs High Water High Water Aquatic Glyphosate 10 10 Mark Mark 2-4-D (amine form) 1000 1000 10 100 2-4-D (ester form) 1000 1000 100 100 Non-aquatic Glyphosate 150/3001 150/3001 10 100 Dicamba 150/3001 150/3001 25 100 Clopyralid 150/3001 150/3001 25 100 Triclopyr 150/3001 150/3001 25 100 None None Chlorsulfuron 25 100 Allowed Allowed Mixture 1 (Chlorsulfuron + 2, None None 25 100 4-D) Allowed Allowed None None Mixture 2 (Dicamba + 2, 4-D) 25 100 Allowed Allowed Note: In the areas under the Lahontan Water Quality Control Board jurisdiction (see Figure 3-2), with Alternative 6 no herbicide treatment will occur from the high-water mark for a distance of 10 feet. From a distance of 10 to 100 feet from the high-water mark, only aquatic glyphosate will be used. At a distance greater than 100 feet from the high-water mark, the other herbicides shown in the Alternative may be applied.

1150 ft. for seasonally flowing streams/300 ft. for perennial streams

These Design Standards are assumed to protect the treatment areas presently inventoried as well as new or previously undiscovered infestations that would be treated using the range of methods described in detail in the Proposed Action of the Modoc National Forest Noxious Weed Treatment Project FEIS. The intent of the Early Detection/Rapid Response approach is to treat new infestations when they are small so that the likelihood of adverse treatment effects is minimized. The approach is based on the premise that the impacts of similar treatments to similar acreages are predictable, even though the precise location or timing of the treatment may be unpredictable. Herbicide use would become more restrictive as treatment occurs closer to water. Design Standards within RCAs and CARs were developed based on label advisories, interdisciplinary

124 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

team discussions ((Table 9, Table 10, Table 11, Bakke 2001) SERA risk assessments, and monitoring results from previous monitoring for Region 5. Monitoring The Modoc National Forest Noxious Weed Treatment Project FEIS Appendix H documents, in detail, the monitoring approach that will be used for both implementation and effectiveness monitoring (USDA Forest Service 1991, Appendix H-Monitoring). Implementation monitoring would determine whether the selected Alternative was implemented as directed, and whether the objectives and priorities were realistic and achievable. Effectiveness monitoring would determine if the treatments were effective in meeting the planned objectives. It would also determine if the noxious weeds were continuing to spread beyond the control actions and if treatment methods were effective in preventing the spread of noxious weeds into traditional Tribal gathering areas.

Table 3 – 15. Summary Comparison of Alternatives

Alternative Alternative Alternative Alt 1 Alternative 4 Alternative 5 Alternative 6 Features 2 3

Number of 0 5 0 5 0 6+ 2 mixes herbicides used

Containment versus - no no no yes yes eradication at large sites Early 100acres/year 100acres/year 100acres/year Detection/Rapid no no no 200 acres 200 acres 200 acres Response total total total Treatment Sites/Acres Sites/Acres Sites/Acres Sites/Acres Sites/Acres Sites/Acres Methods physical 20-30 161/31 494/5993 161/31 Physical+ 527/139 116/19 Physical or 333/5961 333/5961 371/116 chemical chemical 42/907 42/907 46/65 3,341- Total pounds of 3,341-15118 137-1832 lbs 0 15118 lbs herbicide used lbs ae ae ae Goats 0 0 0 0 5/41 5/41 Total Acres 20-30 6899 5993 7099 480 541 Treated

Note: In the areas under the Lahontan Water Quality Control Board jurisdiction (see Figure 3-2), with Alternative 6 no herbicide treatment will occur from the high-water mark for a distance of 10 feet. From a distance of 10 to 100 feet from the high-water mark, only aquatic glyphosate will be used. At a distance greater than 100 feet from the high-water mark, the other herbicides shown in the Alternative may be applied.

Chapter 3—Affected Environment & Environmental Consequences 125 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Environmental Consequences Explanation of Proposed Action and other Action Alternatives Six Alternatives have been proposed for analysis. The characteristics of each Alternative are summarized in below: Alternative 1 A forest-wide noxious weed program would not be implemented. Alternative 2 Under this Alternative, the Modoc National Forest proposes to treat noxious weeds using herbicides and physical methods over a five-year time frame. The annual combination of methods used would vary depending on noxious weed species, distance from water or other sensitive areas, and the most economical and efficient treatment methods available. There would be no aerial spraying of herbicides and there would be no herbicide use within 10 feet of water. Listed below are features of Alternative 2:  Between 300 to 1,500 acres would be treated annually for the next five years.  A total of 536 sites would be treated.  Physical methods would be used at 161 sites (31 acres) that are less than 10 feet from any water source to include manual hand pulling, digging, grubbing, and hoeing.  Use of physical and/or herbicide methods on 333 sites (5,961 acres) located greater than 10 feet from any water source targeting nonrhizomatous noxious weed species.  Treatment using herbicide would occur on 26 sites (2.4 acres) located greater than 10 feet from any water source and comprised of rhizomatous species.  Partial treatment would occur on 16 sites of rhizomatous species that have some acreage within 10 feet of water. On these 16 sites, the acreage within 10 feet of water would not be treated and the acreage that is further than 10 feet from water would be treated with aquatic glyphosate (904.3 acres).  No treatment would occur at five sites (0.45 acres). These sites are comprised of rhizomatous species and are within 10 feet of water.  Herbicides would be applied by directed spray and wicking treatments.  Herbicides include: Clopyralid, Dicamba, Glyphosate, Triclopyr, and 2, 4-D.  Herbicide treatments would include use of surfactants and dyes. Surfactants increase the absorption of herbicide by the weeds, and dyes assist the applicator in efficiently treating target weeds.

Alternative 3 Alternative 3 does not include the use of herbicides. Listed below are features of Alternative 3:  Treating between 300 to 1,500 acres annually for the next five years,  Treatment using physical methods to include manual hand pulling, digging, grubbing, and hoeing would occur on 494 sites (5,993 acres).

126 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

 No treatment would occur on 47 sites (916 acres) as these sites are comprised of rhizomatous species and physical methods are ineffective in treating rhizomatous species. Alternative 4 Alternative 4 focuses on providing flexibility in physical and herbicide treatment methods for current occurrences and expanding or new infestations of noxious weeds. Alternative 4 includes an Early Detection - Rapid Response Strategy not included in Alternatives 2 and 3. Listed below are features of Alternative 4:  Treating a total of 6,899 acres at 536 sites over the next 10 years (average annual 500- 1,500 acres)  Physical treatment methods would be utilized at 161 sites (31 acres) that are less than 10 feet from any water source.  Use of physical and/or herbicide methods on 333 sites (5,961 acres) located greater than 10 feet from any water source and with nonrhizomatous noxious weed species.  Treatment with herbicides would occur on 26 sites (2.4 acres) located greater than 10 feet from any water source and comprised of rhizomatous species.  Partial treatment would occur on 16 sites of rhizomatous species that have some acreage within 10 feet of water. On these 16 sites, the acreage within 10 feet of water will not be treated and the acreage that is further than 10 feet of water would be treated with aquatic glyphosate (904.3 acres).  No treatment would occur at five sites (9 acres). These sites are comprised of rhizomatous species and are within 10 feet of water.  Herbicides would be applied by directed spray and wicking treatments.  Herbicide treatments include: Clopyralid, Dicamba, Glyphosate, Triclopyr, and 2-4-D.  Herbicide treatments in Alternative 4 would include use of surfactants and dyes. Surfactants increase the absorption of herbicide by the target weeds, and dyes assist the applicator in efficiently treating target weeds.

 An Early Detection - Rapid Response Strategy would be implemented in this Alternative. This strategy would provide the opportunity to treat new sites of the identified species that have developed, existing sites that have expanded, and new sites of new noxious weeds using the same treatments as outlined for the noxious weed species identified, provided that environmental effects are within the Design Standards, and effects analyses are reflected in this FEIS. Proposed treatment under Early Detection – Rapid Response would be capped at 200 acres over the life of the Alternative with no more than 100 acres being treated in any given year. The rationale for this cap is to provide limited flexibility to treat new and/or expanding weed sites while remaining within the range of effects as displayed in this analysis.

Alternative 5 Alternative 5 provides a non-herbicide Alternative with additional non-herbicide treatments, and an Early Detection - Rapid Response Strategy. Alternative 5 includes additional manual treatment methods not included in Alternatives 2 and 3. Alternative 5 includes an Early Detection - Rapid Response Strategy. Under Alternative 5, only the perimeter of a 5,658-acre site (DH013ISTI) of dyer’s woad would be treated with physical methods. Listed below are features of Alternative 5:

Chapter 3—Affected Environment & Environmental Consequences 127 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

 Utilize non-herbicide methods to eradicate, control, or contain approximately 280 acres at 532 inventoried sites of noxious weed species.  There is potential to treat 5 sites (41 acres) using goat grazing. These sites may alternatively be treated using physical methods.  Treatment using physical+ methods, including manual hand pulling, grubbing, hoeing, clipping (including use of hand-held string trimmers), and mulching/tarping would occur on 527 sites (139 acres).  There would be limited treatment to contain infestations on 9 sites (6,728 acres). These sites include the large dyer’s woad site (5,658 acres), one crupina site (159 acres) and seven sites of rhizomatous noxious weeds (913 acres). The common crupina site is part of a larger site on adjacent private lands (an additional 586 acres). Limited treatment of these sites is expected to be 100 acres. Design Standards have been implemented in determining the treatment method that these acres will receive. These sites are comprised of rhizomatous species and are greater than 0.10 acre. Physical methods are not as effective in treating rhizomatous species as herbicides, thus treatment goals would only include containment of the current infestation.  An Early Detection - Rapid Response Strategy would be implemented in this Alternative. This strategy would provide the opportunity to treat new sites of the identified species that have developed, existing sites that have expanded, and new sites of new noxious weeds using the same treatments as outlined for the noxious weed species identified, provided that environmental effects are within the Design Standards, and effects analyses are reflected in this FEIS. Proposed treatment under Early Detection – Rapid Response would be capped at 200 acres over the life of the Alternative with no more than 100 acres being treated in any given year. The rationale for this cap is to provide limited flexibility to treat new and/or expanding weed sites while remaining within the range of effects as displayed in this analysis.

Alternative 6 Alternative 6 proposes use of additional herbicide formulations, while treating fewer acres with herbicides, and proposes additional manual treatment methods. Alternative 6 provides the opportunity to use an additional herbicide (chlorsulfuron) and two mixtures of herbicides not included in Alternatives 2 and 4. Alternative 6 also includes the additional manual treatment methods and the Early Detection - Rapid Response Strategy included in Alternative 5. Under Alternative 6, only the perimeter of a 5,658-acre site (DH013ISTI) of dyer’s woad, the 159-acre ( BV001CRVU2 ) Common Crupina and the 851 acre Dalmatian toadflax (WM003LIDA) sites would be treated with either herbicide or physical methods. Physical methods are physical treatments which include manual hand pulling, grubbing, hoeing, clipping (including use of hand-held string trimmers), and mulching/tarping. Under Alternative 6, the Modoc National Forest proposes to treat noxious weeds over a ten-year time frame. Listed below are features of Alternative 6:  Treating approximately 341 acres (541 inventoried sites).  Treatment using physical+ methods, including manual hand pulling, grubbing, hoeing, clipping (including hand-held string trimmers), and mulching/tarping would occur on 116 sites (19 acres).  Treatment using physical methods listed above and/or herbicides would occur on 371 sites (116 acres).

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 Treatment using herbicide methods would occur on 46 sites (65 acres).  There is potential to treat five sites (41 acres) using goat grazing. These sites may alternatively be treated with physical and/or herbicide methods.  Limited treatment methods along major travel ways to reduce potential for spread would occur on three sites (5,658-acre dyer’s woad site, 159 acre common crupina site, and 850 acre Dalmatian toadflax site). These sites would be treated around the borders to contain the infestations. The estimated number of acres treated would be 100 acres along the borders. These treatment acres are estimated proportionally to the size of the current inventoried acres for these three sites.  Herbicide treatments include: Chlorosulfuron, Clopyralid, Dicamba, Glyphosate, Triclopyr, 2-4-D, and two herbicide mixtures (Mix 1: Chlorosulfuron + 2, 4-D, and Mix 2: Dicamba + 2, 4-D).  No 2, 4-D treatments would be applied to noxious weed occurrences greater than 2 acres in size.  Herbicide treatments in this Alternative would include use of surfactants and dyes. Surfactants increase the absorption of herbicide by the target weeds, and dyes assist the applicator in efficiently treating target weeds.  Herbicide treatments would be the primary treatment for rhizomatous species.  An Early Detection - Rapid Response Strategy would be implemented in this Alternative. This strategy would provide the opportunity to treat new sites of the identified species that have developed, existing sites that have expanded, and new sites of new noxious weeds using the same treatments as outlined for the noxious weed species identified, provided that environmental effects are within the Design Standards, and effects analyses are reflected in this FEIS. Proposed treatment under Early Detection – Rapid Response would be capped at 200 acres over the life of the Alternative with no more than 100 acres being treated in any given year. The rationale for this cap is to provide limited flexibility to treat new and/or expanding weed sites while remaining within the range of effects as displayed in this analysis.  In the areas under the Lahontan Water Quality Control Board jurisdiction (see Figure 3- 2), with Alternative 6 no herbicide treatment will occur from the high-water mark for a distance of 10 feet. From a distance of 10 to 100 feet from the high-water mark, only aquatic glyphosate will be used. At a distance greater than 100 feet from the high-water mark, the other herbicides shown in the Alternative may be applied. Effects on Soil and Water Resources The following sections discuss the general effects of physical + and herbicide treatments on soil and water resources. Specific differences in Alternatives are detailed after the general discussion. Effects to Soils

General Effects of Physical Treatment Physical treatments are proposed under all Alternatives. Proposed physical treatments are hand pulling, grubbing, digging and hoeing. Physical methods are proposed under Alternatives 5 and 6, and include the clipping of the seed head or plant including using a hand-held string trimmer as well as mulching and tarping.

Chapter 3—Affected Environment & Environmental Consequences 129 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

The overall impacts of these activities are low. These methods would temporarily decrease ground cover, leading to incremental effects from erosion or slight decreases in soil moisture from ground cover reductions. These methods would not lead to adverse effects on soils since soil organic matter would be supplemented from cut vegetative material. These methods would also loosen small amounts of soil at the surface, potentially increasing the chance of localized erosion. This is a very minor and temporary effect and changes would be within the natural range of variability. The use of hand-held string trimmers would not contribute to soil disturbance. The proposed manual treatments result in an input of dead root material, in the form of dead roots into the soil. As the roots are broken down in the soil food web, nutrients are released. The use of hand clipping would also provide organic material, in those cases where the whole plant is cut and dropped to the ground. Rainfall may cause these nutrients to be lost to surface runoff or to groundwater. Where bare soils occur, if they are combined with high nutrient levels, these areas may provide ideal conditions for the establishment of many invasive species. However, in lower intensity infestations, non-target vegetation could provide erosion control as well as a seed source for establishing native vegetation. In areas with larger amounts of bare soil (0.25 acre), Alternatives 2 and 4 Design Standards would require restoration activities to be considered in order to reestablish native vegetation. The intent is to reestablish competitive local, native vegetation post-treatment in areas of bare ground, to control soil erosion and provide native competition to invasive plant seeds. Removal of plant roots would break mycorrhizal hyphae in the soil and probably cause a transient reduction of mycorrhizal function. Studies on crop plants have shown that leaving an undisturbed mycorrhizal network in the soil after harvest (e.g. zero-till agriculture) increases the nutrient uptake of the subsequent crop (Evans and Miller 1990). Establishment of native plants may be more successful on undisturbed soil. Indirect negative impacts from manual control could be attributed to soil disturbance and opening of the canopy (understory or depending on the species). This could cause minor and transient shifts in microsite conditions such as reduction in soil moisture, disruption of mychorrhizal associations, and cause an increase in surface temperatures. As the treatment areas associated with this project are generally in previously disturbed sites, treatment would improve the condition of the site by allowing reestablishment of native vegetation. Physical treatments may slightly increase the potential for delivery of fine sediment to streams the year after treatment. Removal of surface cover could cause minor localized erosion trapped by surrounding vegetation for approximately one season until vegetation becomes reestablished. Using hand-held string trimmers would not create any additional soil impacts. The use of truck- mounted pressurized sprayers (See Chapter 2, Figure 2-1 of this FEIS) off-road has the potential to compact soil. Soil compaction eliminates soil pores and so reduces water infiltration, aeration, and the ability of plants to root effectively. While the relative amounts of physical treatments vary between the Alternatives, the treatments are similar; therefore differences in terms of intensity or duration of effects from such treatments have no substantive differences.

General Effects of Cultural Treatments Cultural treatments can include grazing, mulching, tarping, fertilizing and reseeding. Grazing can be effective in reducing a large infestation or eliminating a smaller infestation (Tu et al. 2003). By treating the invasives with grazing first, the intent is to lower impacts on the site from subsequent treatments. Tarping would shade or heat the soil to kill undesirable plants. This would only be used in small treatment areas, as this method is most effective in damp soils (Tu et al. 2003). The dry conditions found on the Modoc are not conducive to widespread use of this method (Table 2-2,

130 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Modoc Noxious Weeds FEIS). Mulching would also be used only on small areas. It is not used on larger areas to avoid impacts to desirable vegetation. Fertilizing and reseeding would help encourage the growth of desirable vegetation.

General Effects of Herbicides on Soils Chemical treatments may affect soils directly by having short-term adverse impacts on certain soil microbes and indirect impacts from losses in vegetative cover. Most of the proposed chemicals are decayed primarily by soil microbes. Only Chlorsulfuron is mainly degraded through hydrolysis (Table 3-15a). Results from field and laboratory testing are mixed, since soil conditions are highly variable. In general, herbicides decay over time; therefore, effects are reduced when microbial metabolic rates are highest (such as during spring when adequate warmth, moisture, and microbial substrate are abundant). The effect of a chemical treatment on the soil depends on the particular characteristics of the chemical used, how it is applied, and the physical, chemical, and biological condition of the soil medium. In general, primary herbicide routes in soil are leaching, hydrolysis, and adsorption/desorption onto soil particles, and biological degradation. Appendix E of the Modoc Noxious Weed FEIS contains a summary of the factors limiting herbicide treatments, including soil-related factors such as drainage and permeability. Soil characteristics affect the herbicide residency time through drainage and adsorptive capacities. Highly drained soils have greater propensity to transfer herbicides to groundwater stores. Organic rich soils and finer texture soils have higher adsorption potential for holding herbicides. Herbicides will vary in the degradation potential based on their chemical structure and the biological potential of the soil. Overall, the proposed herbicide types and application rates are low enough to facilitate decay by soil microbes. The proposed herbicide use would have a low risk for soils since the bulk of treatments focus along roads, where soils are unproductive and soil communities are uniform. Soil attributes at greatest risk from chemicals include damage to soil organisms and erosion from removal of ground cover. The overall effect to soils from proposed treatments is low due to a very limited application of herbicides (see descriptions of the Alternatives in Chapter 2). A more extensive discussion of the individual herbicide properties can be found in Appendix E of the Noxious Weed FEIS. Below is a brief summary, for each chemical proposed for use detailing each chemical’s behavior in soils, including permeability and drainage: 2, 4-D: 2, 4-D is degraded in soils primarily by microbes. Studies indicate that the size of the microbial population, the concentration of 2, 4-D and the ratio of the two factors determine the 2, 4-D degradation rates (Hemmett and Faust 1969). Soil conditions that enhance microbial populations (i.e. warm and moist) facilitate 2, 4-D degradation rates (Foster & McKercher 1973). Wilson et al. (1997) found that adequate soil moisture was the most influential parameter affecting the degradation rates. Lag times of up to eight weeks during which 2, 4-D degradation is slow, have been reported following the first application of 2, 4-D to soil (Audus 1960). Most formulations of 2, 4-D do not bind tightly with soils and have the potential to move down into the soil column. 2, 4-D is considered to be highly mobile and is prone to move off site in surface runoff and subsurface flow (Tu et al. 2003). T he EPA reports that 2, 4-D is broken down into inert particles by soil microbial activity and that within 7 days following application, 2, 4-D has low soil persistence (Tu,M, Hurd, C & J.M. Randall 2001). The half-life in soil is less than 7 days. Soil microbes are primarily responsible for its disappearance. Despite its short half-life in soil and in aquatic environments, the compound has been detected in groundwater supplies in at least five states and

Chapter 3—Affected Environment & Environmental Consequences 131 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

in Canada. Very low concentrations have also been detected in surface waters throughout the U.S (Weed Control Methods, The Nature Conservancy, April 2001). Chlorsulfron: Chlorsulfron should not be applied to soils when they are saturated or when they are subject to periods of intense rainfall, as this chemical is degraded mainly through hydrolysis Drift potential is high during a surface inversion (Source- Specimen Label Telar DF (EPA Reg. No. 352-522). Tank mix of 2, 4-D and chlorsulfron should not be applied to saturated or coarse textured soils or when intense rainfall (summer thunderstorm) is likely to occur within 7 days of application. Both of these chemicals are highly mobile and can be transported by surface runoff into the streams and lakes. Clopyralid: Clopyralid is relatively persistent in soil and is degraded by soil microbes. It is not susceptible to photo or chemical degradation. Clopyralid does not bind strongly with soil particles. Once it has been applied, it rapidly disassociates, becoming extremely soluble in water and does not bind strongly with soil particles (Shang and Arshad 1998). This means that Clopyralid has the potential to be mobile, and could contaminate ground and surface waters via leaching. The average half-life of Clopyralid is one to two months but can range from one week to one year depending on the soil type, temperature, and rates of application. Clopyralid should not be applied to areas where soils are very permeable and the water table is shallow. Because Clopyralid is highly soluble in water, there is a potential for it to move off site during summer thunderstorm activity where there are high-intensity and short-duration precipitation events (Tu et al. 2003). From the specimen label for Transline, Clopyralid should not be applied where soils have a rapid to very rapid permeability or the depth to groundwater is shallow (EPA Reg. No. 62719-259 revised 07-26-99). Dicamba: Dicamba is not adsorbed by most soils. It is highly mobile and is moderately persistent in most soils. Dicamba has a half-life of 1 to 6 weeks in soil with degradation due to soil microbial activity. The rate of degradation of Dicamba is slower at low temperature and low soil moisture (Pesticide Fact Sheet prepared by Information Ventures, Inc.). Dicamba can be introduced to groundwater and surface water during application or in combination with 2, 4-D on sensitive or shallows soils, which can introduce the active ingredient into the groundwater table. Glyphosate: Glyphosate is highly water soluble but unlike most water-soluble herbicides has a very high adsorption capacity. Once Glyphosate contacts soil it is rapidly bound to soil particles rendering it essentially immobile (Roy et al. 1989a, Feng 1990). Unbound or free Glyphosate molecules are degraded at a steady and relatively rapid rate by soil microbes. Because glyphosate binds strongly to soils, it is unlikely to enter waters through surface or subsurface runoff except when the soil itself is washed away by runoff, and even then, it remains bound to soil particles and unavailable to plants (Rueppel et al. 1977, Malik et al. 1989). Triclopyr: Microbial metabolism accounts for a significant percentage of Triclopyr degradation in soils. In general, warm moist soils with a high percentage of soil organic matter will support the largest microbial populations and the highest rate of metabolism. The reported half-life of Triclopyr in soil varies from 3.7 to 314 days depending on specific soil and environmental conditions (Newton et al. 1990). Coarse textured soils that are highly permeable may therefore retain Triclopyr but most studies have found that Triclopyr does not tend to move in significant quantities below the top 15 cm (0.5 inches) of soil (Norris et al. 1987, Newton et al. 1990, Stephenson 1990, and Johnson et al. 1995a). From the specimen label for Garlon 3A (EPA Reg. No. 6271937) treatment of aquatic weeds can result in oxygen depletion or loss due to the decomposition of dead plants. To minimize this hazard, do not treat more then one-third to one-half of the water area in a single operation.

132 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Garlon 4 includes kerosene as an inert ingredient. Triclopyr is active in the soil and adsorbed by clay particles and organic matter in the soil. Microorganisms degrade Triclopyr and it has a relatively short half-life of 46 days under ideal conditions (warm moist soil conditions). It is highly mobile and is moderately persistent in most soils. The rate of degradation of Dicamba is slower at low temperature and low soil moisture ( Pesticide Fact Sheet prepared by Information Ventures, Inc.). Tank Mixes: 2, 4-D is proposed to be applied in combination with Chlorsulfron as Tank Mix #1 or in combination with Dicamba as Tank Mix #2. 2, 4-D is identified by the EPA as having characteristics that make it an herbicide with a high leaching potential and very water-soluble thereby making it subject to movement by runoff when applied adjacent to or near water. Chlorsulfron should not be applied to soils when they are saturated or when they are subject to periods of intense rainfall. Tank Mix #1 is highly mobile and is moderately persistent in most soils. Application of Banvel (dicamba) or in combination with 2, 4-D on sensitive or shallows soils can introduce the active ingredient into the groundwater table. Tank Mix #2 should not be applied to saturated or coarse textured soils or when intense rainfall (summer thunderstorm) is likely to occur within 7 days of application. Both of these chemicals are highly mobile and can be transported by surface runoff into the streams and lakes. 2, 4-D is proposed to be applied within the RCAs either alone or in combination with Dicamba as a Tank Mix#1 or in combination with chlorsulfuron as Tank Mix #2. Chlorsulfuron should not be applied to soils when they are saturated or when they are subject to periods of intense rainfall. Tank mix of 2, 4-D and chlorsulfuron should not be applied to saturated or coarse textured soils or when intense rainfall (summer thunderstorm) is likely to occur within 7 days of application. Both of these chemicals are highly mobile and can be transported by surface runoff into the streams and lakes (SERA. 2004 and 1999). Dicamba is not adsorbed by most soils. It is highly mobile and is moderately persistent in most soils. Application of Dicamba or in combination with 2, 4-D on sensitive or shallows soils can introduce the active ingredient into the groundwater table. Clopyralid has been identified as extremely water-soluble and has a high potential for mobility and leaching into the soil profile. It is not approved for application on or near water. Clopyralid should not be applied to areas where soils are very permeable and the water table is shallow. The usage of this herbicide in areas where soils are considered to be sensitive, shallow depth or where the water table is shallow may result in groundwater contamination. Because Clopyralid is highly soluble in water, there is a potential for surface waters to be contaminated if Clopyralid is applied directly to bodies of water or wetlands (Tu et al. 2003). Triclopyr (Garlon 3A) has been identified for treatment of aquatic weeds associated with impounded waters (i.e. lakes, ponds and reservoirs) but not free flowing streams. This herbicide has properties and characteristics associated with chemicals detected in groundwater. The usage of this herbicide in areas where soils are considered to be sensitive, shallow depth or where the water table is shallow may result in groundwater contamination. Triclopyr binds to clay (fine textured soils) and organic matter and is highly mobile (SERA 2003f).

Herbicide Effects to Soil Organisms The low application rates and type of herbicides proposed in general have a low impact on soil organisms. At high rates, Triclopyr (Garlon, Access) can affect soil microbes and may adversely affect some fungi and algae. Effects are short term and transitory since effects decrease with time as the herbicides degrade. Dicamba and 2, 4-D may also affect mycorrhizal fungi at high rates.

Chapter 3—Affected Environment & Environmental Consequences 133 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Functional groups of microbes that have similar metabolic pathways as the target weeds would be most sensitive to the herbicides. However, collective adverse effects of the proposed herbicides on soil microbes are hard to predict, given the diversity of the soil community and varying resistance to the particular herbicides. For example, some laboratory studies found glyphosate adversely impacted several types of microbes, although populations rebounded quickly (Tu et al. 2003). Similarly, Busse et al. (2001) found no long-term impact on microbial communities when using glyphosate on ponderosa pine plantations. Ultimately, soil microbes facilitate the degradation of the herbicides by using the herbicides as growth substrate, co-metabolizing, polymerizating, accumulating, or altering the chemical structure by influencing the pH of the soil environment (Bollag and Liu 1998). The residency times shown in Table 3-15a are a gross collective function of average soil types, application timing and frequency, and finally the unique chemical structure.

Soil Cover The treatment of sites with herbicides could also indirectly affect site productivity in the short term through changes in total organic production on site and annual input into the soil. Chemically treated plants would die and become incorporated into the soil as organic matter during the first years following treatment. Annual input in subsequent years would be limited by the number of non-target species interspersed between invasive plants or the rate at which vegetation returned to the site.

Physical Properties of Herbicides Factors that determine the fate of herbicides in soil include mobility and degradation. Herbicide degradation over time is a result of physical and chemical processes in soil and water. Herbicide fate in soil is determined by herbicide characteristics such as adsorption, solubility, degradation, and volatility. Soil characteristics such as organic matter, pH, temperature, moisture content, clay content, and microbial degradation can modify certain properties of herbicides such as mobility in soils and half-life (time it takes for half the amount of chemical present to breakdown). General characteristics for the proposed herbicides are displayed in Table 3-15a. Many of the proposed herbicides are highly soluble in water. In general, this is often taken as an indicator of the mobility of the chemical in soils. There are exceptions, however. Glyphosate, while having a high solubility, also binds tightly with soil particles, and because of this it has low mobility. Herbicides with high mobility potential and long half-lives have a greater potential for leaching into near-surface groundwater. Water Streams are complex and dynamic systems that reflect the balance between stream flow, sediment input and substrate/bank composition. As stated on page 12, riparian condition and water quality are the two elements potentially affected by invasive plant treatments.

General Effects of Non-herbicide Treatment Physical treatments generally consist of grubbing, digging or pulling weeds. If weed seeds are present, the weeds would be bagged and taken off site. Removal of soil cover would be very small under these circumstances. However, there could be small localized areas of erosion and subsequent sediment input to the stream. Such effects would be transitory and too small to measure.

134 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Pulling weeds along stream banks could also destabilize the banks in highly localized areas. In general, weeds provide very little stabilization for stream channels. Any localized effects would be expected to last only a season until vegetation becomes reestablished at these sites. Other physical treatments within riparian areas could accelerate sediment delivery to streams through ground disturbance. Most of the treatment areas are previously disturbed roadways and trails so additional ground disturbance would not be a significant change from the existing condition. Modification of surface ground cover can change the timing of runoff, but given the small areas of treatment, any changes would be transitory and too small to measure.

General Effects of Herbicide Treatments None of the Alternatives have the potential to influence stream flow and channel morphology due to the small portion of any watershed that would be treated. Treating invasive plants would improve riparian stability where invasive plants have colonized along stream channels and out- competed native species. All invasive plant treatments carry some risk that removing invasive plants could exacerbate stream instability; however, the restoration plan accounts for these areas and prescribes mulching, seeding and planting as needed to revegetated riparian and other treated areas.

Table 3 – 15a. Herbicide Properties Compiled from the Region 6 Invasive Plant FEIS (USDA Forest Service 2005b), SERA Risk Assessments and The Nature Conservancy Weed Manual (Tu et al. 2003)

Degradation Toxicity to Soil Potential Water Activation Herbicide path and half Microbes Mobility1 Solubility1 Mechanism2 life2 Effect to 3 species of ectomychorrhizal fungi in laboratory experiments (Estok Soil microbes et al., 1989) Inhibits 7 days growth of some soil High to low reported by Highly Plant growth 2, 4-D algae at 1 mg/L. depending EPA mobile regulator Mycorrhizal fungi on form 1-30 days in less sensitive; little SERA risk effect at 10 ppm, assessments substantial inhibition at 1000 ppm. (SERA, 1998, 2, 4-D) Acetolactate synthesis inhibitor High Hydrolysis (Selective: Chlorsulfuron Low Very high in Very High 37-168 days controls clay soils broadleaves and some grasses) Plant growth Very high regulator (Very Soil microbes Clopyralid Low especially in High selective to 14 to 29 days sandy soils broadleaves; post emergent) Transitory effects at Soil microbes Plant growth Dicamba High High high concentrations 1-30 days regulator

Soil microbes Inhibits 3 amino Glyphosate Low Low Very High acids and protein 30 to 60 days synthesis (Non-

Chapter 3—Affected Environment & Environmental Consequences 135 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

selective; quickly absorbed by leaves with rapid movement through plant; no root absorption) Plant growth Inhibits algae at low regulator Soil microbes Triclopyr rates Toxic to fungi Very High Medium (Absorbed thru 46 days at high rates. roots, foliage and green bark) 1 Mobility and water solubility categories from Shauwna Bautista, R6 invasive plant specialist, and are general breakdowns, not a definitive classification. 2 Deschutes-Ochoco Invasive Plant EIS Soils Report, 2006.

A primary issue for this analysis is the potential for herbicides to enter streams and impact aquatic organisms. This section describes how Design Standards minimize the possibility that herbicides would enter water and impact water quality. The overall effect to soils from proposed treatments is low due to a very limited application of herbicides (see descriptions of the Alternatives in Chapter 2).

Drift, Runoff and Leaching The routes for herbicide to contaminate water are direct application, drift into streams from spraying, runoff from a large rain storm soon after application, and leaching through soil into shallow groundwater or into a stream. This section addresses each of these delivery routes. No direct application of herbicide to water is intended in any Alternative. No emergent plants would be treated under any Alternative. Effects from drift, runoff, and leaching were considered in the herbicide risk assessments, assuming broadcast treatments occurring directly adjacent to streams. The Groundwater Loading Effects of Agricultural Management Systems (GLEAMS) model was used to estimate the amount of herbicide that may potentially reach a reference stream via runoff, drift and leaching in a 96- hour period, assuming broadcast treatments on a 50-foot strip along about 1.6 miles of perennial stream. SERA risk assessments evaluated the hazards associated with each herbicide based on the concentrations of herbicide predicted by the GLEAMS model using these parameters. The risk assessment worksheets used in this project (SERA worksheets) overestimate the herbicide concentrations that would plausibly enter most streams from this project for three reasons: 1) The worksheets do not take into account a “no herbicide use” area within an RCA; 2) The estimate for the rainfall is generic and is not adjusted to the dry conditions found on most of the Forest; 3) The model assumes broadcast treatments along the stream versus the wicking and targeted spray treatments proposed under this project. The results from the SERA worksheet are found below in Table 3-16. Wicking and targeted spray treatments allowed with this project are inherently far less likely to deliver herbicide to water than broadcast treatments because the herbicide is applied to individual plants, so drift, runoff, and leaching are greatly minimized. Small amounts of some herbicides can trans-locate from the plant to the soil or an adjacent plant, but the concentration of herbicides that may be delivered to streams from this mechanism is much less than GLEAMS predictions (P. Adams 2007), which models broadcast spraying of herbicide next to the stream without a no- spray area within the RCA.

136 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Monitoring Studies Berg’s (2004) compilation of monitoring studies on herbicide treatments with various distances from streams in which herbicide spraying is not allowed, showed that any distance helps lower the concentration of herbicide in streams adjacent to treatment areas. In California, distances between 25 and 200 feet generally had no detectable concentrations of herbicide in monitored streams with detection limits of 1-3 mg/m3 (ibid). The USGS, in partnership with the Oregon Department of Transportation, studied runoff of herbicides along roads (Wood 2001). The study was conducted on runoff associated with several herbicides (including glyphosate) along a road in western Oregon simulating rainfall at 1/3 inch an hour at 1, 7 and 14 days after treatment. Samples were collected at the shoulder of the road and found concentrations of nearly 1,000 parts per billion (ppb) of glyphosate on the road shoulder that could potentially leave the road shoulder. In the fall, the road was again sprayed and the ditch line of the road was checked during natural rainstorms for three months. Glyphosate was not found at the shoulder, ditch line, or stream. This study indicates that the greatest risk of herbicides moving off site is from large storms soon after herbicide application.

Table 3 - 16. Herbicide and Application Rates with Peak Water Concentrations Generated in SERA Worksheets (worksheets can be found in the project record)

Range of water Range of Range of Water Average water concentration rates Herbicide Application Rates concentrations concentration (per pound per (per acre) (mg/l) (mg/l) acre) Chlorsulfuron 0.56-1 ounce 0.01-0.2 0.007-0.0125 0.0047

Clopyralid 0.13-.25 pound 0.005-0.07 0.00065-0.0175 0.005

2, 4-D 0.5 to 2 pounds 0.13-0.42 0.065-0.84 0.22

Dicamba 0.25 to 2 pounds 0.00006-0.01 0.000015-0.02 0.003

Glyphosate 0.75 to 3.75 pounds 0.001-0.4 0.001-1.5 0.05

Triclopyr 0.5 to 1.5 pounds 0.001-0.4 0.0005-0.6 0.09

Berg (2004) reported that herbicide applied in or along dry, seasonally flowing stream channels may enter streams through runoff if a large rainstorm occurred soon after treatment. This risk is minimized if seasonally flowing channels have no spray areas within the RCAs, as would occur under the action Alternatives. If a large rainstorm occurs after herbicide application, sediment contaminated by herbicide could be carried into streams. As most herbicide application occurs in the late spring through the early fall, which is the driest time of the year, the probability of a large rainstorm soon after application of herbicides is low at any particular site.

Region 5 Monitoring Water quality monitoring in R5 from 1991 to 1999 occurred on multiple projects in the Regional Forests. Most projects were for control of non-conifers in conifer plantations. The Angeles monitoring included an invasive weed project within riparian areas (USDA Forest Service 2001).

Chapter 3—Affected Environment & Environmental Consequences 137 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Glyphosate was used in four Forests on eight projects. With no spray areas as narrow as 10 feet, Glyphosate was found to be non-detectable in collected samples with levels of detection between 9 and 24 parts per billion (ppb; some samples gave no level of detection). On the Angeles National Forest, Aquatic Glyphosate was used within the channel for control of aquatic plants. In this instance, one out of 12 samples had a concentration above the level of detection of 9 ppb. This sample had 15 ppb a quarter of a mile downstream of the treatment site (USDA Forest Service 2001). Triclopyr was used on five projects on three Forests. Where Triclopyr was used with no spray areas of 10-15 feet, there were 3 projects where detections occurred. The levels of detection ranged between 0.1 to 1 ppb where specified. One detection of 82 ppb was determined to be from not establishing a no spray area on a seasonally flowing channel. The other detection was on a project with no spray areas of 10 feet; it had detection during winter storms of 0.63 ppm (parts per million) and 0.6-0.7 ppm. Another project with no spray areas of 15 feet had a single detection of 1 ppb (USDA Forest Service 2001).

Accidental Spills Concentrations of herbicides in the water as a result of an accidental spill depend on the rate of application and the stream ratio of surface area to volume. The persistence of the herbicide in water depends on the length of stream where the accidental spill took place, velocity of stream flow, and hydrologic characteristics of the stream channel. The concentration of herbicides would decrease rapidly downstream because of dilution and interactions with physical and biological properties of the stream system (Norris et al.1991). Accidental spills are not considered within the scope of the project. Design Standards would reduce the potential for spills to occur, and if an accident were to occur, minimizes the magnitude and intensity of impacts. An herbicide transportation and handling plan is a project requirement. This plan would address spill prevention and containment.

Lakes, Wetlands and Floodplains Herbicides affect lakes and wetlands differently than streams. Dilution by flow or tributary inflow is generally less effective in lakes. Dilution is partially a function of lake size, but dilution could be rapid in small lakes with large water contributing areas. Decreases in herbicide concentration in lakes, ponds, and other lentic water bodies are a function of chemical and biological degradation processes or preferential adsorption of the herbicide into the lake sediments rather than from dilution. As no emergent treatments are proposed, the primary pathways for herbicide to enter lakes would be from drift or runoff. Some invasive plants may grow in wetlands or near lakes and reservoirs. A large rain event after treatment could carry herbicide into water resulting in minor amounts of herbicide contacting surface water.

Emergent Vegetation There is no treatment of emergent vegetation proposed under any Alternative.

Municipal Watersheds There are no municipal watersheds within 13 miles downstream of the project area. However, the Fort Bidwell Indian Community water source would be protected under an agreement between the Forest and the Tribe. Design Standard 19b requires that no herbicide be used for noxious

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weed treatments in the area above the water source. A map of this area of concern is found in Appendix N of the Modoc Noxious Weed FEIS. Comparison of Alternatives

Alternative 1 – No Action

Direct and Indirect Effects to Soils There could be a short-term (1 to 2 years) reduction in soil cover for the areas treated. This localized reduction in cover would increase treated areas vulnerability to soil erosion. The effects would be minimal given the poor quality of groundcover provided by the invasive species proposed for treatment, the scattered nature of the treatments and the small amount of land treated. Adverse impacts to soils may occur where some noxious weeds are left to populate. Alternative 1 would only treat 20 to 30 acres per year. Specific changes to soil nutrient regimes are associated with large spotted knapweed infestations (Lejeune and Seastedt 2001), allelopathic influences (Bais et al. 2003), in addition to changes in surface hydrology where the plant communities are moved from bunchgrass-dominated to taproot-forb-dominated (Lacey 1989). Similarly, the influx of cheatgrass (Bromus tectorum) can alter soil dynamics with changes in structure, nutrient pulses and soil moisture status (Norton et al. 2003). These changes may be coincident with the long-term shifts from perennial grasslands to annual grasslands as documented in California (D’Antonio and Vitousek 1992). Other noxious weed species may have similar impacts as demonstrated by Vinton and Burke (1994) where fertilization caused long time shifts to favor weedy forb species. Adverse tradeoffs with Alternative 1, in this case the risk of no treatment, would be highest for Centaurea spp. and others that can spread into relatively undisturbed grasslands (see Tyser and Key 1988). These tradeoffs are weighed by addressing spread rate versus the impact from treatment (D’Antonio et al. 2004), especially in regards to affecting non-target plant species (see Ortega 2005b).

Cumulative Effects This Alternative is covered under other NEPA projects. Treatments would occur on an extremely small percentage of any watersheds in the Project Area. Direct and indirect effects are so insignificant and temporary that treatment under No Action could not plausibly contribute to significant cumulative effects.

Alternative 2

Direct and Indirect Effects to Soils Thirty-one acres are proposed for physical treatment only. Effects of physical treatments on small scattered treatment sites would be similar to those discussed under general effects and are expected to be minor and transitory as the treatment sites are small and dispersed across the Forest. Herbicide treatments only are proposed for 907 of the total 6,908 acres inhabited by invasive plants (Table 3-16). Up to 5,961 acres would be treated with either physical or herbicide methods. Approximately 300 to1,500 acres of treatment are expected to occur in any one year do to budget constraints.

Chapter 3—Affected Environment & Environmental Consequences 139 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

One risk from herbicide use is from herbicide contact with soil affecting soil productivity by inhibiting the growth of soil organisms. Dicamba, Triclopyr and 2, 4-D all have potential to inhibit soil organisms at high rates, with less inhibition at normal application rates. These changes are temporary as the organisms rebound and the herbicides degrade. This risk would be minimized by Design Standard 29, which requires direct spray to the plant or patch of plants, or to wick the herbicide directly onto the plant. This would minimize drift off site as well as minimize the amount of herbicide in contact with soil. This target spray technique also avoids spraying desirable vegetation, leaving it as a seed source to reseed treated areas. Approximately 90 percent of the sites are within a quarter mile of roads. Soil communities along roads are largely uniform and disturbance oriented; therefore, impacts to soil organisms are not anticipated.

Cumulative Effects Most of the five herbicides used under this Alternative do not negatively affect soil organisms at typical application rates and would not affect soil productivity. Cumulative soil productivity is protected due to the fact that the application methods proposed under Design Standard 29 requires a targeted spray or wicking directly onto the plant to minimize herbicide contact with soil protecting soil organisms and therefore soil productivity. Soil cover is protected by Design Standard 20 rehabilitation activities. Design Standard 14 requires that physical disturbance or herbicide treatments be limited to no more than 15 percent of any 6th-field watershed to minimize cumulative effects from treatments. Alternative 2 is unlikely to have significant effects to soil and therefore is unlikely to approach a threshold of concern, so would not contribute to significant cumulative effects. No adverse cumulative effects are expected from implementation of this Alternative.

Alternative 3

Direct and Indirect Effects to Soils This Alternative includes only the physical methods of controlling invasive plants discussed above under general effects of physical treatment. As rhizomatous species are not effectively treated without herbicides, 47 sites occupying 916 acres would be dropped and not treated allowing for the further spread of these invasive plants. Up to 494 sites (5,993 acres) would be treated with physical methods over a 5-year time period. There would be more soil disturbance under this Alternative than under Alternative 2, as the primary methods are pulling, digging, grubbing and hoeing to remove invasive species. This is still a small amount of disturbance in any one area, as 94 percent of the sites are less than 1 acre in size (Table 3-4). The sites are generally not a solid infestation of invasive plants but are often a mixture of invasives and more desirable plants. Only the noxious weeds would be removed, leaving the desirable vegetation for soil cover to protect the site from erosion, as well as for a seed source. The effects of treatment at any site are expected to be short-term, lasting only a year or so until the site is revegetated.

Cumulative Effects Treatments are primarily pulling noxious weeds, which is a fairly low impact activity. Treatments would take place on between 300 and 1,500 acres a year. Given the cost of treating by pulling weeds, probably the number treated would be closer to 300 acres a year. These acres would be scattered across the Forest. Design Standard 14 requires that physical disturbance or herbicide

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treatments be limited to no more than 15 percent of any 6th field watershed to minimize cumulative effects from treatments.

Alternative 4

Direct and Indirect Effects to Soils The effect of this Alternative would be the same as for Alternative 2 except this Alternative would be implemented over a 10-year timeframe and would include Early Detection –Rapid Response. This would allow for a longer time period to control the weed infestations and would give the Forest the flexibility to treat 100 acres of new infestations a year with a cap of 200 acres of new infestations treated for the life of the project.

Cumulative Effects Cumulative effects would be similar to those discussed under Alternative 2.

Alternative 5

Direct and Indirect Effects to Soils Overall, there would be fewer disturbances with Alternative 5 than for Alternative 3 because fewer acres would be treated. A total of 480 acres would be treated out of the 6,908 acres of inventoried weeds. All the sites would receive some treatment. Nine sites would receive only limited treatment. These sites are the dyer’s woad site (5,658 acres) of the larger common crupina site (159 acres), the Dalmatian toadflax site (850 acres) and seven smaller sites of rhizomatous noxious weeds (913 acres). Most of the treatment effects are the same as discussed under general effects of physical treatments and those discussed under Alternative 3. However, this Alternative has more physical treatments available than Alternative 3. These treatments are generally not soil-disturbing activities and they include mulching/tarping and cutting the plant, including using a hand-held string trimmer. This Alternative includes potentially using goat grazing for five sites totaling 41 acres. The sites range in size from 4 to 25 acres and are occupied by musk thistle or scotch thistle. By itself, it will not eradicate weeds but when combined with other treatments can be effective at controlling invasive species. Grazing can be effective in reducing a large infestation or eliminating a smaller infestation (Tu 2003). Potentially, goats would be used on the site first and herbicide could be used for follow-up on the smaller number of remaining plants. Early Detection-Rapid Response (for 100 acres a year with a project cap of 200 acres total) is allowed for sites similar to those presently included for treatment under this Alternative. Design standard 22 requires that the Forest soil scientist or hydrologist annually verify treatment locations to ensure proper Design Standards are used for each site.

Cumulative Effects Cumulative effects are similar to those discussed under Alternative 3. As no significant direct or indirect effects are expected under this Alternative, no significant contribution to cumulative effects is expected.

Chapter 3—Affected Environment & Environmental Consequences 141 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Alternative 6

Direct and Indirect Effects to Soils Alternative 6 treats only 541 acres, far fewer acres than proposed for Alternatives 2 (6,899) and 4 (7,099). Therefore, there would be less overall disturbance under this Alternative. Up to 541 acres would be treated under this Alternative. As with the previous Alternative, the three largest sites would have only the perimeter of the sites treated. The physical treatments would be the same as discussed above under Alternative 5. One hundred and sixteen sites totaling 19 acres would be treated with physical+ methods with 371 sites totaling 116 acres treated with either physical methods or herbicide. This Alternative allows use of chlorsulfuron. This herbicide has low potential to affect soil organisms. This herbicide targets broadleaf vegetation leaving grasses unaffected. This Alternative also allows the use of two mixtures of herbicides. As noted under General Herbicide Effects dicamba, Triclopyr and 2, 4-D have temporary effects on soil organisms. Herbicide is proposed for only 46 sites on 65 acres. DS-24a restricts use of herbicides (except glyphosate) to 1 acre per 6th field a year on sensitive or shallow soils. This could allow minor amounts of herbicide to leach into shallow aquifers. This effect is likely to be small given the dry climate and the small acreage of this type of soils proposed for treatment. This Alternative treats fewer acres with both herbicides and with physical treatment than the other Alternatives that allow herbicide use. All treatment sites would be evaluated for rehabilitation on a site-by-site basis. Given the few acres treated, the scattered nature of the treatments, and the use of Design Standards, this Alternative is unlikely to have noticeable effects.

Cumulative Effects Cumulative effects are similar but much more limited than those discussed under Alternative 2.

Effects to Water Resources Alternative 1

Direct and Indirect Effects Under this Alternative, no Forest-wide management of invasive plants would occur. Under this Alternative, 20 to 30 acres would be treated by physical means each year. Invasive plants would continue to grow on sites where their treatment is currently not authorized by NEPA analysis. Invasive plants are often less effective for stream bank stabilization than deeper rooted native plant species. Most invasive plants also provide less stream shading than native hardwoods and conifers. Alternative 2

Direct and Indirect Effects Up to 150 acres of treatment, including chemical treatment, could take place in stream RCAs. In reality, most of these areas have only discontinuous infestations of invasive plants, but, as acres of infestations change year to year; analysis is done as if all the land within a treatment area were infested.

142 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

None of the treatments are extensive enough under any Alternative to affect peak flows, low flows, or water yield. Methods used for treatment would have negligible effect on water infiltration into soil and associated surface runoff as discussed in the general effects section and the soils section above. No 5th-field watershed has more than 2.5 percent proposed for treatment; most have well under 1 percent (Table 3-8). This amount is much too small an area to show effects to flows from treatment. The sites identified below in Table 3-17 are the larger invasive plant sites on the Forest. All the sites identified are listed in Appendix B of the Modoc Noxious Weed FEIS.

Chapter 3—Affected Environment & Environmental Consequences 143 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 3 - 17. Larger Invasive Sites on the Forest

Acres Town- Site Species ID Number Range Section Within Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 ship Acres RCAs

Canada WM009CIAR4 T47N R15E 27 9.99 9 PT-H NT PT-H LT H Thistle

Crupina BV001CRVU2 T40N R10E 36 158.65 35 P P P LT LT

Dalmatian WM003LIDA T46N R14E 13 44.57 27.2 PT-H NT PT-H LT H Toadflax

Dalmatian BV006LIDA T42N R6E 28 850.82 98.4 PT-H NT PT-H LT LT Toadflax

Dyer’s DH013ISTI T43N R7E 7 5657.75 1.4 P or H P P or H LT LT woad

Dyer’s 5.1 P+ or WM002ISTI T46N R15E 5 12.65 P P P P+ woad H

Dyer’s P+ or WM004ISTI T47N R15E 32 12.27 2.4 P P P P+ woad H

G or Scotch G or BV284ONAC T39N R10E 8 16.3 15.9 P P P P+ Thistle P+ or H

G or Scotch G or WM004ONAC T45N R15E 14 9.72 0 P or H P P or H P+ or Thistle P+ H

P - Physical: hand pulling, hoeing, grubbing P+ - Physical+: hand pulling, hoeing, grubbing, clipping seed head or plant, trimming with hand-held string trimmers, mulching/tarping H - Herbicide NT - No Treatment LT - Limited Treatment: perimeter treatment only to contain infestation G - Goat Grazing PT-H - Partial Treatment of site with herbicides Generally, small areas would be treated along streams. Thirty-one acres of physical treatment are proposed within 10 feet of streams in RCAs scattered across 161 sites. Treatment would be

144 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

discontinuous and limited at any one site. As most invasive plants provide little shade, removal of these plants is unlikely to have any measurable effect to stream temperature. Where manual methods remove invasive plants near streams, there could be minor loss of ground cover and soil disturbance leading to erosion and a minor localized increase in fine sediments particularly if vegetation is removed from stream banks. This increase is not considered significant as it would only last a season or two until vegetation became reestablished. Many treatment sites are small and would reseed naturally with existing native vegetation. Restoration would occur on sites greater than ¼ acre lacking native vegetation seed source to ensure revegetation occurs and erosion is controlled. No herbicide would be used within 10 feet of streams. Aquatic Glyphosate, licensed for use in water, would be used within RCAs of 150 feet for seasonally flowing streams, and 300 feet for perennial streams. Glyphosate tends to bind strongly to soils and would move only if the soil particle was carried into water. The spray methods used would be targeted spray or hand application of herbicides to the target plants. Drift would be minimal under these circumstances and risk to native riparian vegetation is small. Spot treatments would also remove less vegetation than broadcast treatments so there is less potential for erosion. There are approximately 40 acres of treatment within 10 feet of water scattered across the Forest. Under this Alternative, only the non-rhizomatous acres would be treated with manual methods. The other herbicides would not be used within RCAs. No spray areas of 150 feet on seasonally flowing streams and 300 feet on perennial streams would protect water quality. These no spray areas are considered adequate to minimize herbicide concentrations in water because, no spray area studies in forested areas (Berg 2005, USDA Forest Service 2001) show that no spray areas greater than 25 feet commonly lower herbicide concentrations below any threshold of concern and often below detectable limits. For 2, 4-D, a 1,000-foot no-spray distance from streams is required under Design Standard 17. Design Standards also minimize the chance of herbicides reaching streams or wetlands through drift, runoff, or leaching into soils. Design standard 23 prohibits use of the more mobile herbicides on shallow or sensitive soils. This would protect groundwater, particularly in areas of the Forest where shallow soils cover fractured bedrock. Where physical methods remove invasive plants near streams, there could be minor loss of ground cover and soil disturbance leading to localized erosion, and a minor localized increase in fine sediments, particularly if vegetation is removed from stream banks. This increase is not considered significant as it would only last a season until vegetation became reestablished. Many treatment sites are small and would reseed naturally with existing native vegetation. Where more than a ¼ acre site has bare soil from treating invasives, Design Standard 20 requires the site be assessed for rehabilitation. Rehabilitation would allow sites lacking a native vegetation seed source to be revegetate to control erosion.

Specific Sites Some of the larger sites were looked at more closely for effects. These sites are listed in Table 3- 17. Alternative 2 allows only aquatic glyphosate within RCAs and requires a 10-foot, no- herbicide-use area for both perennial and seasonally flowing streams. Under Alternative 2, three of the nine treatment areas shown in Table 3-17 would be treated with aquatic glyphosate outside the 10-foot no spray area. Glyphosate adheres well to soil and is the least mobile of the herbicides proposed under this project. The large Common Crupina site, the Scotch Thistle site with almost 16 acres in RCAs and two dyer’s woad sites of approximately 12 acres apiece would all be treated with physical treatments.

Chapter 3—Affected Environment & Environmental Consequences 145 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Site WM009Ciar4 is infested with Canada Thistle. This site is in section 27 just south of Mill Creek. The site is almost entirely within either a lake or spring RCA or a seasonally flowing stream RCA. The entire polygon is approximately 10 acres with 9 acres within the RCA of a lake, spring, or seasonally flowing stream RCA. This site is within the Lahonton Regional Water Board, which allows only aquatic glyphosate application by wicking directly to the plant at least 10 feet from the stream or water feature. Given these tight constraints, it is unlikely that adverse effects would occur from this treatment.

The large dyer’s woad site ( DH013ISTI) would be treated either physically or with chemicals. This site has a seasonally flowing drainage to the south side of the treatment area. This treatment is unlikely to affect water quality because only 1.4 acres of the site is within the seasonal stream RCA.

For the large Dalmatian toadflax site,(BV006LIDA) the 850 acre site has a series of small ponds, wetlands and meadows scattered around the site. The individual RCAs range in size from the approximately 35-acre meadow to a 1-acre lake. This area has 64 acres within RCAs with a set of small lakes and 34 acres within a meadow. Approximately 14 acres are in the inner 100 feet of the RCAs. This site receives an average of 20 inches of precipitation a year. Outside the RCA any of the other herbicides can be used, with 2, 4-D having an additional no spray area of 1,000 feet from the high-water mark. Given that only aquatic glyphosate would be used in RCAs and 2, 4-D has a 1,000-foot no spray area from use near water, it is impossible for the concentrations to approach those calculated in Table 3-16 for any herbicide except glyphosate. Glyphosate application was modeled with the GLEAMS-Driver model with site-specific parameters for a small lake and a small stream (Table 3-18). The parameter changes for this model included a yearly rainfall of 21 inches a year and a 16-acre treatment site. This is a conservative model because it models as if broadcast spray occurred up to the edge of the stream and the highest possible application rate was assumed. In reality, there is a 10-foot no spray area, and no broadcast spraying occurs. Instead, the herbicide is applied directly to the plant by wicking it onto the plant. This would keep herbicide from contacting either desirable plants or contacting soil. Modeling results in Table 3-18 show water concentrations below any level of concern. Given these results and the conservative use of herbicides with this Alternative, adverse effects from herbicide use are unlikely under this Alternative.

Table 3 - 18. GLEAMS-Driver Model Results with Site-Specific Climate and Acre Data

EPA Yearly Low Median High Acre Drinking Modele Averag Herbicide Herbicide Herbicide s Water d Herbicide e Concentrati Concentrati Concentrati treate Featur Rainfall on in Water on in Water on in Water Maximum d e (inches) (mg/l) (mg/l) (mg/l) Contaminan t level (mg/l) glyphosat 16 21 0.014 0.015 0.025 0.7 stream e glyphosat 16 21 0.0091 0.011 0.012 0.7 pond e

Roads There are 26.6 miles of road within treatment areas. Of these, only 3 miles (11 percent) are within RCAs. There is an additional 0.8 miles of road within RCAs associated with ponds, lakes and

146 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

wetlands within treatment areas. Roads and their associated ditch lines are often connected to streams and during storm events can carry herbicide to streams. However, as only targeted spray techniques would be used, very little herbicide applied to the soil would be available for transport to streams.

Lakes, Wetlands and Floodplains There are approximately 128 acres of treatment proposed within RCAs of wetlands, lakes, ponds, or reservoirs on the Forest. The main invasive plants found at these sites are Dalmatian toadflax (98.4 acres), Canada thistle (10 acres) and Scotch thistle (8.3 acres). Most of these treatment acres are near the High Reef area just south of Lava Lake in the largest treatment area for Dalmatian toadflax. There are 98 acres of noxious weeds in eight polygons ranging in size from 0.3 acres to 34 acres. These are all part of a large 851-acre treatment area of Dalmatian toadflax. Under this Alternative most of this site would be treated with herbicides except for the infestations within 10 feet of the High Water Mark. Because Dalmatian toadflax is a rhizomatous species, these acres would not be treated. This leaves plants for reinfestation of the site. The infested areas 10 feet away from water would be treated with aquatic glyphosate within the RCA and potentially other herbicides outside the RCA. Glyphosate is the herbicide that most strongly adheres to soil and is unlikely to move into water in any significant amounts. Even where soil particles move into water the glyphosate preferentially stays on the soil particle (SERA 2003b). As only aquatic glyphosate can be used with the RCAs, it is unlikely that the other herbicides would be of concern for water resources. While the Design Standards make it highly unlikely that herbicide concentration in water would reach a level of concern, high rainfall soon after application could deliver herbicide to a lake or pond. To model this scenario, the risk assessment worksheet (SERA worksheet) was run for specific rainfall for glyphosate (only herbicide that is allowed within RCAs). No concentrations of concern were reached for any herbicide (Table 3-18). Use of Design Standards discussed above further lowers potential for higher concentrations of herbicides near the lakes. Therefore, treatments are unlikely to affect functioning of wetlands or water bodies or to contribute to significant adverse effect on beneficial uses. To control the infestation, the treatments would continue over several years, with fewer acres needing treatment each year. Wetlands would be treated using non-herbicide methods where such treatments are likely to be effective. Alternative 3 Alternative 3 uses only physical treatments. Under this Alternative rhizomatous species would not be treated because physical methods are not effective on these species. There would be more ground disturbance under this Alternative than under Alternative 2.

Direct and Indirect Effects Under this Alternative, up to 494 sites totaling 5,993 acres could be treated over 5 years. The 47 sites (916 acres) of rhizomatous infestations would not be treated. The primary treatments would be pulling, hoeing, and grubbing weeds. Within 10 feet of water, there are 31 acres at 161 sites of potential physical treatment. Physical treatment close to water is more likely to lead to additional sediment input to streams than treatment farther from the streams. Alternative 3 increases the risk of trampling and instability of stream banks due to its reliance on non-herbicide treatments, particularly in areas where invasives grow directly along stream banks. This would be a short-term effect until revegetation occurred. The risk of long-term adverse

Chapter 3—Affected Environment & Environmental Consequences 147 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

effects from these treatments is low. Invasive plants provide little shade; therefore, removing them would not lead to a measurable change in temperature. In the long term, temperature would be improved on streams currently impacted by invasive plants. The treatments proposed are unlikely to result in significant amounts of decaying plants or nutrients entering a stream at one time, and therefore, no measurable effect to oxygen levels is anticipated. Alternative 4

Direct and Indirect Effects The effects from treatment under this Alternative are the same as for Alternative 2, except that EDRR could take place under this Alternative and treatments would occur over a 10-year time frame. Alternative 5 The effects of this Alternative are the same as for Alternative 3, except that this Alternative includes additional physical treatments, use of grazing and Early Detection-Rapid Response. The additional physical treatments include cutting weeds, mulching, and tarping. These are not considered ground disturbing and would have minimal effects to treated sites. Grazing is proposed for 5 sites, including two Scotch thistle sites shown in Table 3-17. These sites are approximately 10 and 16 acres in size. The 10-acre site is dry, but the 16-acre site is within the RCA of a seasonal stream. As long as the goats are moved in a timely manner, using goats for grazing noxious weeds can be an effective way to weaken or kill plants to make the site smaller for further treatment with other methods (Tu et al. 2003). Alternative 6 Alternative 6 allows the most flexible use of herbicides. It includes the use of chlorsulfuron and herbicide mixtures. Mix 1 is Dicamba and 2, 4-D, and Mix 2 is Chlorsulfuron and 2, 4-D. Alternative 6 proposes smaller stream no-spray areas than Alternatives 2 and 4 (Table 3-13). As under Alternative 2, herbicide exposure levels for both the public and for workers executing treatment activities would not exceed acceptable levels of risk to human health for all herbicides proposed for use (Bakke 2005). The use of proper personal safety equipment, training, and supervision for all weed-treatment crews would be required to reduce the potential for injuries to workers. Glyphosate is the only herbicide proposed for use when spraying within 10 feet of bankfull along stream channels. Glyphosate is highly water-soluble but because it adheres tightly to soils is unlikely to be carried into a stream unless the soil particle is carried into the stream. This is unlikely to happen during the late spring or summer, when herbicides would be applied, because there is less rain in the summer and more vegetation growth to hold soil particles in place. However, large thunderstorms capable of moving sediment occasionally occur in the summer. It is impossible to predict where these would occur. If glyphosate is carried into a stream by runoff, it would preferentially bound with the soil particle over partitioning into water (SERA 2003b). Herbicides entering surface water through surface runoff are also expected to be minimal, since targeted spraying techniques would be used to apply herbicide. This would minimize the amount of herbicide reaching the ground surface as well as minimize the potential for herbicide drift.

148 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Site-specific Analysis The three largest sites listed in Table 3-17 would get limited treatment under this Alternative. The crupina site, a Dalmatian toadflax site, the large dyer’s woad site, and six smaller sites (not listed in Table 3-17) would get limited treatment around the edges of the sites and along major roads, to keep the noxious weeds from spreading. The total estimated treatment for these sites is 100 acres. The Dalmatian toadflax site has an additional mitigation allowing treatment of only 10 percent of the acreage within the inner 100 feet of RCAs to occur annually, to protect water quality. Where treatment may occur, wicking the herbicide directly onto the plant is the required application type. The two smaller dyer’s woad sites, as well as the 44-acre Dalmatian toadflax site shown in Table 3-17, are within the Goose Lake CAR. To protect TES aquatic species, only aquatic glyphosate is allowed within 100 feet the High Water Mark of streams (Design Standard 11). Given these requirements, adverse effects from treatments are unlikely. The 10-acre Canada thistle site is within the Lahontan Regional Water Board (LRWB) plan area. Within the LRWB area, no treatments would occur from the high-water mark for a distance of 10 feet; only aquatic glyphosate would be used from 10 to 100 feet of the high-water mark; further than 100 feet from the high-water mark, the other herbicides displayed in the Alternative may be applied. Aquatic glyphosate is used by wicking it directly onto plants. This would allow the project to meet the LRWB Basin Water Quality Standard for zero detection of herbicide in streams. The 9.7-acre Scotch thistle site is not near water; therefore, treatment of this site would have no impact on water quality. In the areas under the Lahontan Water Quality Control Board jurisdiction (see Figure 3-2), with Alternative 6 no herbicide treatment will occur from the high-water mark for a distance of 10 feet. From a distance of 10 to 100 feet from the high-water mark, only aquatic glyphosate will be used. At a distance greater than 100 feet from the high-water mark, the other herbicides shown in the Alternative may be applied. One reason why the restrictions on herbicidal treatments in the area under the jurisdiction of the Lahontan Water Board are different, is that the eastern slope of the Warner Mountains is the most highly erosive and steep area on the Modoc National Forest. Two of the sites with larger treatment acres in RCAs were modeled using the GLEAMS-Driver model. The 16.3-acre Scotch thistle site is located along Messenger Creek, which is a seasonal stream. The site was modeled with the GLEAMS-Driver with a rainfall of approximately 21 inches a year and 16 acres of treatment. The other site modeled was the Canada thistle site with 33 inches of rain and 10 acres of treatment to match the treatment site. The herbicides that could potentially be used at these sites were modeled. Even when modeled at the highest allowed application rate, using broadcast application up to the edge of a stream, no concentrations were over a level of concern. In reality, 2, 4-D is not allowed on sites over 2 acres in size and would not be used at either of these sites.

Chapter 3—Affected Environment & Environmental Consequences 149 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 3 - 19. GLEAMS-Driver Model Parameters and Results

EPA Drinking Lower Median Upper Water Soil Soil Herbicide Acres Rainfall concentration Concentratio Concentration Type Depth Maximum (mg/l) n (mg/l) (mg/l) Contaminant level (mg/l) glyphosate 16 21 loam 24 0.014 0.015 0.025 0.7 dicamba 16 21 loam 24 0.0074 0.0083 0.009 - 2, 4-D 16 21 loam 24 0.0075 0.008 0.013 0.07 glyphosate 10 33 loam 24 0.023 0.024 0.058 0.7 dicamba 10 33 loam 24 0.012 0.013 0.060 - clopyralid 10 33 loam 24 0.0016 0.003 0.026 - chlorsulfuron 10 33 loam 24 0.00038 0.00041 0.00057 - Triclopyr 10 33 loam 24 0.0094 0.011 0.031 -

When all the acres of infestations within the inner 100 feet of RCAs were totaled by watershed, there were less than 15 acres infested within 10 feet of any RCA, and only 116 acres total within the inner 100 feet of the RCA . This is a small amount of disturbance, given the scattered nature of the treatments.

Table 3 – 20. Acres of Infestations Within 100 Feet of Streams, Lakes, Springs or Meadows, by 6th- Field Watershed

Infested Infested Infested Infested Acres within Acres within Acres within Acres with Watershed 10 feet of 25 feet of 50 feet of 100 feet of Watershed Hydrologic streams, streams streams streams Name Unit Code lakes, lakes, lakes, lakes, springs and springs and springs and springs and meadows meadows meadows meadows 180102040103 Mosquito Creek 0.29 0.49 0.81 1.38 180102040106 Fairchild Swamp 0.11 0.23 0.34 0.47 Lower North Fork 180102040204 0 0 0.03 0.19 Willow Creek 180102041102 Spaulding Butte 0 0 0 0.25 180102041105 Knobcone Butte 0.01 0.03 0.07 0.10 Double Head 180102041106 0.03 0.06 0.08 0.08 Mountain North Coast Subtotal 0.44 0.81 1.33 2.47 RWB North Fork 180200010303 Cottonwood 0.65 1.64 3.26 6.55 Creek 180200010304 Willow Creek 0.27 1.31 2.70 5.78 180200010305 Lassen Creek 1.87 4.63 9.23 18.83 180200010306 Ross Creek 0.06 0.16 0.24 0.30 180200010307 Davis Creek 0.02 0.05 0.14 0.28 180200010403 Corral Creek 0.01 0.03 0.07 0.10 Southern Jess 180200020103 0.09 0.23 0.44 0.76 Valley

150 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Infested Infested Infested Infested Acres within Acres within Acres within Acres with Watershed 10 feet of 25 feet of 50 feet of 100 feet of Watershed Hydrologic streams, streams streams streams Name Unit Code lakes, lakes, lakes, lakes, springs and springs and springs and springs and meadows meadows meadows meadows 180200020202 Parsnip Creek 0.06 0.16 0.18 0.18 180200020203 Warm Creek 0.11 0.25 0.46 0.87 180200020207 Crooks Canyon 0.03 0.08 0.10 0.10 180200020303 Fitzhugh Creek 0 0 0.10 0.08 Headwaters 180200020401 North Fork of Pit 0 0 0.02 0.09 River 180200020402 Joseph Creek 0.09 0.22 0.42 0.64 180200020403 Thoms Creek 0 0 0.01 0.19 Baker and 180200020504 Thomas 0 0 0.02 0.11 Reservoir 180200020903 Canby-Pit River 0.48 1.03 1.98 4.66 Stone Coal 180200020904 0.47 1.03 1.90 4.08 Creek Roberts 180200020906 Reservoir-Pit 0.02 0.04 0.09 0.10 River Washington 180200021001 0.03 0.06 0.10 0.10 Creek Upper Turner 180200021002 0.05 0.06 0.12 0.19 Creek Hulbert-Turner 180200021003 0 0 0.03 0.10 Creek 180200021101 Kephart Creek 0 0 0 0.01 180200021103 Frog Waterhole 2.80 4.55 7.53 13.69 180200021203 Upper Ash Valley 0 0.05 0.14 0.29 Cottonwood 180200021204 0.36 0.63 1.07 1.37 Creek 180200021205 Lower Ash Valley 0.10 0.21 0.41 0.53 180200021301 Rush Creek 2.35 5.94 11.96 23.85 Messenger 180200021302 1.72 4.01 7.39 13.35 Gulch Upper Dutch Flat 180200021303 0 0 0.28 0.30 Creek Lower Dutch Flat 180200021304 0 0 0.05 0.10 Creek Upper Willow 180200021401 0 0 0 0.04 Creek Lower Willow 180200021401 0.10 0.10 0.10 0.10 Creek 180200021501 Butte Creek 0.07 0.09 0.10 0.17 South Big 180200021503 0 0 0 0.01 Swamp East Fork 180200021601 0.05 0.13 0.25 0.35 Juniper Creek South Fork 180200021602 0.38 0.87 1.56 2.69 Juniper Creek

Chapter 3—Affected Environment & Environmental Consequences 151 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Infested Infested Infested Infested Acres within Acres within Acres within Acres with Watershed 10 feet of 25 feet of 50 feet of 100 feet of Watershed Hydrologic streams, streams streams streams Name Unit Code lakes, lakes, lakes, lakes, springs and springs and springs and springs and meadows meadows meadows meadows Lower Juniper 180200021603 0 0 0 0.03 Creek 180200021704 Lower Big Valley 0.03 0.08 0.10 0.10 180200030101 Van Sickle Lake 0.01 0.04 0.08 0.10 180200030105 Wagontire Creek 1.00 1.16 1.34 1.92 180200030106 Clarkes Valley 0.04 0.10 0.16 0.20 Central Valley Subtotal 13.32 25.94 54.13 103.29 RWB 180800010102 Bidwell Creek 1.00 2.51 5.08 10.36 Northwest Shore 180800010201 Middle Alkali 0.01 0.03 0.14 0.43 Lake West Shore 180800010202 Middle Alkali 0 0.01 0.05 0.11 Lake Subtotal Lahontan RWB 1.01 2.55 5.27 10.90 Totals 14.77 29.3 60.73 116.66

Critical Aquatic Refuges (CARs) Where aquatic TES species are present, larger no-spray areas would be used as shown in Table 3- 7. No herbicides would be used within 10 feet of a stream’s High Water Mark, and only aquatic glyphosate would be used within 100 feet of the stream. This additional protection makes it exceedingly unlikely that herbicides would reach any threshold of concern in these areas. For the treatments within the Lahonton Water Board area, no herbicide treatment would take place within 10 feet of a stream. Only aquatic glyphosate could be used within the RCA using wicking to apply the herbicide directly to the plant.

Table 3 – 21. Noxious Weed Sites and Infested Acres Within RCAs of the Lahonton Water Board

Weed ID Weed Name Acres SMZ Type WM001CIAR4 Canada Thistle 0.10 Seasonal Stream WM002ONAC Scotch Thistle 0.10 Seasonal Stream WM003CIAR4 Canada Thistle 0.06 Seasonal Stream WM003CIAR4 Canada Thistle 0.10 Perennial Stream WM003CIAR4 Canada Thistle 0.09 Meadow WM006CIAR4 Canada Thistle 0.10 Seasonal Stream WM007ISTI Dyer’s woad 0.45 Seasonal Stream WM009CIAR4 Canada Thistle 8.04 Lake WM009CIAR4 Canada Thistle 6.16 Spring WM009CIAR4 Canada Thistle 8.42 Seasonal Stream WM009ISTI Dyer’s woad 1.21 Perennial Stream WM010ISTI Dyer’s woad 0.83 Perennial Stream WM014ISTI Dyer’s woad 0.75 Seasonal Stream

152 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Weed ID Weed Name Acres SMZ Type WM017ONAC Scotch Thistle 0.10 Seasonal Stream WM017ISTI Dyer’s woad 0.10 Seasonal Stream WM018ISTI Dyer’s woad 1.13 Perennial Stream WM018ISTI Dyer’s woad 1.12 Seasonal Stream WM019ISTI Dyer’s woad 0.10 Perennial Stream WM022ONAC Scotch Thistle 0.15 Perennial Stream WM025ONAC Scotch Thistle 0.10 Perennial Stream WM025ONAC Scotch Thistle 0.10 Seasonal Stream WM027ONAC Scotch Thistle 0.10 Perennial Stream WM027ONAC Scotch Thistle 0.08 Seasonal Stream WM036ONAC Scotch Thistle 0.10 Perennial Stream WM037ONAC Scotch Thistle 0.14 Perennial Stream TOTALS 29.73

Note: For the Noxious Weed FEIS, the designated zone for all SMZs is the Riparian Conservation Areas (RCAs) on the Modoc National Forest. See the definition for Riparian Conservation Area in the glossary. Therefore, for the Noxious Weeds FEIS, the terms SMZ and RCA are interchangeable.

Early Detection-Rapid Response Early Detection-Rapid Response is part of this Alternative. Under this approach, new or currently unknown infestations may be treated using the range of methods analyzed in the Modoc Noxious Weed FEIS 2008, on sites similar to those presently proposed for treatment. Design Standards limit types of treatments and types of herbicides by aquatic risk within RCAs and would minimize the risk of treating these new or undiscovered infestations. Cumulative Watershed Effects A watershed cumulative impact can be defined as the total impact, positive or negative, on runoff, erosion, water yield, floods, and/or water quality that result from the incremental impact of a Proposed Action, when added to other past, present and reasonably foreseeable future actions occurring within the same natural drainage basin, or watershed (CEQ 1997). The cumulative effects analysis area for this project is comprised of the 29 5th-field watersheds that are either totally or partially found within the Forest’s administrative boundary. Cumulative effects information for this report is primarily derived from Chapter 3 of the FEIS. Additional sources of information are referenced accordingly.

Past, Present and Foreseeable Actions For a complete list of all past, present, and reasonably foreseeable actions, please refer to the beginning of Chapter 3.

Past Noxious Weed Treatments and Adjacent Treatments Prior to 2002, Modoc County Department of Agriculture treated weeds on the Forest through a Memorandum of Understanding. Billing records and correspondence between the Forest and Modoc County indicate treatments were done for about 30 years. The Modoc National Forest contains Modoc, Lassen and Siskiyou counties. Pesticide application data is summarized annually by the California Department of Pesticide. The Department produces a report each year summarizing pesticide use by category, total pounds of pesticide applied,

Chapter 3—Affected Environment & Environmental Consequences 153 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

number of treatments, acres and treatment type. The annual reports put out by the California Department of Pesticide do not contain information as to where the pesticides are applied geographically. Herbicide application data for the categories of forestry, rangeland and right-of- way (ROW) are summarized in Appendix B in Table 24 for the years 2002 to 2006.6 (Appendix B is part of the Watershed and Soils specialist report, found in Appendix T, Watershed and Soils, of this final EIS.) The table summarizes the amount of chlorsulfuron, clopyralid, 2, 4-D, dicamba, glyphosate and triclopyr applied, for the years 2002-2006. These are the herbicides proposed for use under the Proposed Action. The table also determines what percentage these herbicides comprised in terms of the total amount applied in each county for 2002-2006, as well as pounds per acre. The use of herbicides on road rights-of-way is assumed to be primarily for noxious weed treatments. However, the acreage associated with right-of-way treatments is inconsistently reported. As a result, the average rates of application have been calculated only for forestry and rangelands. The Forest has not been extensively involved in herbicide application in the last 5 years. However, in 2002 there was minor use of clopyralid, 2, 4-D, dicamba, glyphosate, and hexazinone, all of which were used for noxious weed control. From 2003 through 2007, no herbicides were applied on the Forest outside of existing permits. As a result, it is assumed that the majority of the herbicide applications summarized in Apendix B, Table 24 have been applied to lands other than national forest. In 2006, no herbicides were applied in Modoc County for forestry. In the same year, no herbicides were applied for rangelands in both Lassen and Modoc counties. This is also the case for both Lassen and Modoc counties in 2004. However, in 2003 rangelands in Modoc County received herbicide application while Lassen County did not. In 2002, herbicide applications were not reported for rangelands in both counties. It is assumed that from 2003 to 2006 that the herbicide use in the forestry category was on lands owned or administered by other entities than the Forest Service. Herbicide use for each of these categories appears to have widely varied from 2002 to 2006. The total amount of chlorsulfuron, clopyralid, 2, 4-D, dicamba, glyphosate and tricoplyr, for the forestry category, ranged from a low of 1,569.4 lbs. in 2002 to a high of 11,108.6 lbs. in 2006 for Siskiyou County. For rangelands, the maximum reported amount of herbicides applied from 2002 to 2006 occurred in 2003 in Siskiyou County, where 928.4 lbs. were applied. Right-of-way applications have ranged from a low of 139.9 lbs. in Lassen County in 2004 to a high of 6, 463.6 lbs in Siskiyou County during 2004. At no time during the period of 2002-2006 did the total amount of chlorsulfuron, clopyralid, 2, 4- D, dicamba, glyphosate and triclopyr exceed 0.1 percent of the total amount of herbicides applied in Lassen, Modoc and Siskiyou counties.

Table 3 - 22. Previous Treatments of Noxious Weeds Using Herbicides, Modoc National Forest

Weed Control agent Scope of program Scotch thistle Herbicide & Physical Over 500 Locations Knapweeds Herbicide 25 Locations Leafy spurge Herbicide 2 Locations Yellow starthistle Herbicide 25 Locations Yellows pine thistle Herbicide 3 Locations Dalmatian toadflax Herbicide 15 Locations

6 http://www.cdpr.ca.gov/docs/pur/purmain.htm

154 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Weed Control agent Scope of program Musk thistle Herbicide 2 Locations Crupina Herbicide 1 Location Russian knapweed Herbicide 4 Locations Perennial pepperweed Herbicide 12 Locations

Past activities also include the following:  Mechanical treatment of less than 1 acre on the Goosenest District of the Klamath National Forest.  Control of noxious weeds in areas adjacent to the Modoc by the Hat Creek District of the Lassen National Forest. Targeted species include dyer’s woad, Scotch thistle, and squarrose knapweed. Ten acres of noxious weeds located on the Shasta Trinity National Forest have been treated by the Lassen N.F. as these acres are administered by the Lassen.  Various noxious weeds (425 acres) have occurred on BLM land in Modoc and Lassen Counties that have been treated with physical methods, including prescribed fire, or with chemicals between 1997 and 2002. Of these acres, 410 were populated by Medusahead.  Noxious weed eradication was performed by the Pit River Indian tribe, using a combination of herbicide and mechanical methods, on Tribal lands. Details on which herbicides have been used were not available. Eleven acres were treated on the Fort Bidwell Reservation for Mediterranean sage, Scotch thistle and dyer’s woad using mechanical methods.  Approximately 10,000 acres a year have been treated with herbicides on private, commercial farm ground and private forests within Modoc County. Approximately 1,000 acres per year of regulatory noxious weed control occurs. Additional detail on these activities was unavailable when this report was written.

Relevant Present Activities Fuel treatments, fire, range management, dam construction and maintenance, recreation, timber harvest, and vegetation treatments, reforestation projects, road and right-of-way management (including state and county easements and railroads), and special uses are all ongoing activities on the Forest. Each of these management activities in some way tie in to the dispersal and propagation of weeds, typically through transporting seeds or providing seed bed opportunities. For a complete discussion of all these present activities, and how they relate to the spread and propagation of noxious weeds, Chapter 3 of the FEIS. Present activities related specifically to the inventory and treatments of noxious weeds are listed below. These activities may belong to other agencies and the lands they administer, but occur within the boundaries of the 29 5th-field watersheds that are either wholly or partially located within the boundary of the Modoc National Forest.  Klamath National Forest, Goosenest District: noxious weed inventory  Ongoing noxious weed control on the Klamath and Lassen National Forest’s mentioned above under relevant past activities  Modoc National Wildlife Refuge that treats 200 acres annually to control Scotch thistle. Rodeo, Roundup, 2, 4-D, and other chemicals are applied by hand, ATV and truck. In addition, a limited amount of hand grubbing occurs.

Chapter 3—Affected Environment & Environmental Consequences 155 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

 BLM-Alturas and Surprise Valley Offices: Approximately 50 acres in Modoc County are treated annually primarily for the control of Scotch thistle and Mediterranean sage. Both Telar and 2, 4-D are applied using trucks and helicopters. The treatment of 3,500 acres of exotic invasive plant species are treated annually by a combination of manual, mechanical, chemical (both aerial and ground applications, grazing, biological and prescribed fire methods.  Ongoing weed eradication on Pit River tribal lands (see past activities for more detail)  10,000 acres a year on private, commercial farm ground and private forests are treated. 1,000 acres a year of regulator weed control occurs each year. Details regarding these treatments were not available at the time this report was written.

Relevant Foreseeable Activities  Ongoing noxious weed control on the Klamath and Lassen National Forest’s mentioned above under relevant past activities  Modoc National Wildlife Refuge that treats 200 acres annually to control Scotch thistle. Rodeo, Roundup, 2, 4-D, and other chemicals are applied by hand, ATV and truck. In addition, a limited amount of hand grubbing occurs.  Ongoing weed eradication on Pit River tribal lands (see past activities) for more detail  10,000 acres a year on private, commercial farm ground and private forests are treated. 1,000 acres a year of regulator weed control occurs each year. Details regarding these treatments were not available at the time this report was written.  The Western Area Power Administration is proposing to vegetation and other types of maintenance along 1,400 miles of 69-500 kV transmission lines, of which approximately 456.2 of these miles are located within the Forest’s boundary. The purpose of the right- of-way project is to maintain existing transmission lines and legal access road rights-of- way in order to ensure maintenance crews have safe and all-weather access to transmission line structures (Western Area Power Administration 2007). By implementing the project, the threat of vegetation to interfere with power lines and towers would be eliminated, vegetation would be controlled in a cost effective and environmentally sensitive manner, and year-round access would be facilitated. Alternative 6 proposes using a combination of manual, mechanical, and herbicide methods to create favorable conditions for the establishment of low-growing plant communities. Seeding or planting may occur. Spot and broadcast herbicide applications would be used. Aerial applications would not occur. These methods would be applied to areas underneath and adjacent to the power lines and substations. Under their Proposed Action, Western Area Power Administration may expand their use of herbicides for vegetation management. In Appendix G of their environmental assessment, Western proposes to use up to 25 herbicides, all of which have been approved and had human health and ecological risk assessments prepared (Western Area Power Administration 2007). At the time this report was written, information as to how much of each herbicide would be used, and when, and associated application method was not available. In addition, information as to how much herbicide would be applied on a watershed basis was also not available. The herbicides proposed for use by Western are listed below in Table 3-23.

156 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Discussion of Cumulative Effects Only the land and roads within the National Forest System would be treated in the action Alternatives proposed by this FEIS. The Forest, however, is intermingled with other federal, state, county, and private ownerships. Management activities and actions on neighboring lands may contribute to spread or containment of invasive plants on National Forest system lands, and vice versa.

Alternative 1 – Cumulative Effects This Alternative is covered under other NEPA projects. Existing levels of pesticide treatments would continue, by Tribes, the County, and on other private and public lands. No new treatments would be associated with this project. Treatments on the Forest would occur on an extremely small percentage (<0.1%) of any watersheds in the project area. Direct and indirect effects from treatment are so insignificant and temporary that treatment under the no action Alternative does not contribute to significant cumulative effects. Lack of treatment would allow the continued spread of invasive plants and the associated changes in ecosystems.

Alternative 2 - Cumulative Effects Only the land and roads within the National Forest System would be treated in the action Alternatives proposed by this FEIS. The Forest, however, is intermingled with other federal, state, county, and private ownerships. Management activities and actions on neighboring lands may contribute to spread or containment of invasive plants on National Forest System lands, and vice versa. The treatments described above by county would probably continue at similar levels in the future. Very little vegetation would be removed in any watershed therefore none of the treatments are extensive enough under any Alternative to effect peak flows, low flows or water yield in any watershed. No tractor or dozer ground-disturbing activity is proposed for this project; therefore, methods used for treatment would have negligible effects on water infiltration into soil and associated surface runoff. No 5th-field watershed has more than 2.5 percent proposed for treatment, and most have less than 1 percent (Table 3-8). This amount is much too small an area to show effects to flows from treatment. The three 5th-field watersheds with the largest treatment acres were looked at closely. These all have one large treatment site for each watershed.

Table 3 - 23. Herbicides Proposed for Use in the Western Area Power Administration Project

Herbicide Use Bromacil and Diuron Substations and non sensitive areas only Chlorsulfuron Right of Way Clopyralid Noxious Weed Control 2, 4-D Substations, Right of Way Clopyralid and 2, 4-D Substations, ROW and Noxious Weed Control Dicamba Right of Way (stump treatment) and Substations Dithiopur Landscaped Areas Diuron Substations Flumioxazin Bare-ground – Substations and Kochia (Mexican burning bush) control Fosamine Ammonium Right of Way

Chapter 3—Affected Environment & Environmental Consequences 157 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Herbicide Use

Glyphosate Substations and areas near water and wetlands Imazapyr Substations, Right of Way and Stump Treatment Oxyfluorfen Landscaped Sites and Bare-ground control Sulfometuron Methyl Storage yards and Substations Sulfometuron Methyl Bare-ground and substations and Chlorsulfuron Tebuthiuron and Diuron Substations Mefluidide Around Substations (on grass) Imazapyr and Diuron Substations and Right of Way Tebuthiuron Substations Triclopyr Right of Way and Stump Treatments Pendamethalin Substations Oryzalin Substations Right of Way, Substations especially for Kochia (Mexican burning Fluroxypyr bush) Paclobutrazol Right of Way (sensitive areas) Trifluralin Substations and yards

Coptic Bay has the largest number of acres of invasive plants identified; 5,676 with 2.3 percent of the watershed proposed for treatment. This is due to the single large treatment area for dyer’s woad (5,658 acres) which has only 1.4 acres of treatment in a seasonal RCA. As there is little water present, treating this site is unlikely to effects water resources. All other sites within the watershed are less than 1 acre in size. There are 5 acres proposed for physical treatments. Only 12 percent of the treatments are proposed are within riparian areas. Round Valley has one large site of common crupina that is on both national forest and private land. This infestation is about 159 acres on national forest land and 586 acres on adjacent private land. On Forest land this site would be treated with physical means under Alternative 2. There is a 16-acre treatment site for scotch thistle which would also be treated with physical means. All the other sites within the watershed are less than 1 acre in size. Taylor Lake has an 851-acre treatment site for Dalmatian toadflax, which includes treatment within RCAs of ponds, springs and wetlands. This site was modeled in Table 3-9, and was below any threshold of concern. Alternative 2 allows the use of aquatic glyphosate in RCAs at a distance of at least 10 feet from the High Water Mark for perennial and seasonally flowing streams. Other herbicides are allowed at a distance of at least 150 feet from seasonally flowing streams, and 300 feet from perennial streams (see Figure 2-2). This protects water resources from direct and indirect effects of herbicide use at each site. Chemical treatments are scattered in small patches across the watersheds, making it unlikely that herbicide concentrations would be additive with similar treatments at the watershed scale. The potential for cumulative effects is negligible due to the implementation of Design Standards that limit direct and indirect effects, the scattered nature of the treatments, and the dilution over time and space by mixing and addition of inflow downstream. Alternative 2 is unlikely to have significant effects on water resources and therefore is unlikely to approach a threshold of concern or contribute to significant cumulative effects. No adverse cumulative effects are expected from implementation of this Alternative.

158 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Alternative 3 - Cumulative Effects Alternative 3 allows only physical treatments. Small acreages are being treated within each 6th- field watershed. As these treatments are primarily pulling weeds in sites scattered across the Forest, it is unlikely that these treatments would have significant direct and indirect effects, and are therefore unlikely to add significantly to cumulative effects. Design Standards 14, 16 and 25 protect the watersheds from cumulative effects.

Alternative 4 - Cumulative Effects The cumulative effects are the same as those discussed under Alternative 2.

Alternative 5 - Cumulative Effects This Alternative treats only 480 acres scattered across the Forest primarily with physical means. Given the minor effects at any site, and the scattered nature of the proposed treatments, cumulative effects from this Alternative are unlikely.

Alternative 6 - Cumulative Effects This Alternative treats only 541 acres scattered across 541 sites. Design Standard 14 requires that no more than 15 percent of any 6th field watershed be treated in one year under this project. Design Standard 18b protects specific watersheds with high amounts of treatment in RCAs by limiting acres treated within RCAs. Given these and other Design Standards, it is unlikely that this Alternative would contribute significantly to cumulative effects. Heritage Resources This section dealing with heritage resources and effects of the Alternatives is limited to the physical presence of prehistoric and historic archeological resources. The traditional cultural properties/practices and locations of current use are discussed in the Tribal Section of this Chapter. No public comments were received concerning the effects of the Proposed Actions on the physical prehistoric or historic archeological resources. The Forest has a vast array of prehistoric and historic archaeological resources, traditional cultural properties, and locations still used by local Native American populations. The prehistoric resources of the Forest span the last 10,000 years and the historic period sites date between roughly 1826 to the mid-20th Century. Contemporary Native American groups include the Pit River Tribe (Achomawi/Atsugewi), the Klamath Tribes (specifically, the Modoc), and the Northern Paiute of the Surprise Valley area. Many locations throughout the Forest continue to be utilized by these contemporary Native American peoples for plant gathering (such as epos and medicinal plants), hunting, and other traditional cultural uses (including religious activities). Prehistoric archaeological resources include numerous "lithic scatters", places where peoples in the past made stone tools, butchered animals, or camped briefly, to more prominent encampments and village sites with visible rock rings, pit house depressions, and an array of stone tools. They also include rock stacks or cairns, rock alignments, and rock art (petroglyph and pictograph sites). Over 7,000 such prehistoric sites have been recorded on the Forest to date. The overall average site density for the Forest is one site per 54 acres. Cultural, or heritage, resource sites are managed in several ways to comply with the provisions of the National Historic Preservation Act. The level or intensity of management, according to the Forest Plan, has the following range:  Preservation - excluding incompatible land activities protects sites.

Chapter 3—Affected Environment & Environmental Consequences 159 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

 Conservation - when preservation is not feasible, scientific information is recovered from sites so that other land-use activities can occur.  Interpretation - sites are developed for public enjoyment and education through signs, trails, and public information kiosks.  No Management - sites are not preserved in any way. (These sites are not of the quality suitable for nomination to the National Register of Historic Places. They contain little scientific information or Native American cultural heritage value.) Cultural, or heritage, resource sites are managed in several ways to comply with the provisions of the National Historic Preservation Act.

Direct and Indirect Effects Physical Manipulation (All Action Alternatives) The use of physical treatment methods for the control of noxious weeds has the greatest potential for affecting heritage resources such as prehistoric and historic archaeological sites, in a direct manner. These methods may also affect potential traditional cultural properties and contemporary Native American uses. The affect may be relatively minor, that is, unlikely to affect those qualities that may make an heritage property eligible for the NRHP, then the action may be treated as an "Exempt Undertaking" under the Pacific Southwest Regions "Programmatic Agreement" (PA) with the California State Historic Preservation Office (SHPO). Herbicides (Alternatives 2, 4, and 6) The use of herbicides generally will have little potential effect on most archaeological properties (prehistoric or historic) and should be considered to have "no effect" on those qualities that may make a property eligible for the NRHP. Therefore, treatment of noxious weeds by the use of herbicides should be classed as an "Exempted Undertaking" in regards to compliance with the NHPA. The current PA allows for programmatic compliance for this class of undertaking. However, this type of treatment may have an effect on existing or potential Native American Tribal cultural properties, especially if the potential area is used for gathering food or medicinal plants. Any proposed use of herbicide treatment should include advanced notification of the appropriate tribal organization and individuals who may use the area. Existing ethnographic information may help identify areas subject to potential conflicts. Cultural (Alternatives 2 through 6) Seeding to control noxious weeds should have no effect on most heritage resources, provided the seeds are broadcast, or less than a cubic meter of soil is disturbed per acre planted. This action could also be dealt with under the PA. Goat Grazing (Alternatives 5 and 6) The use of goat grazing to control noxious weeds should not represent a significant effect to most archaeological resources. Some very minor ground disturbance may be present as a result of the short-term trampling affect of a goatherd milling about in a single location. This action, however, should result in relatively little lateral displacement of surface artifactual materials (e.g., obsidian waste flakes, surface artifacts such as projectile points) and should have no impact on subsurface archaeological materials. Implementation of Alternative 3 or 5 poses the greatest risk to heritage resources due to their reliance on physical + (digging) of noxious weeds.

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Alternative 1 (No Action) There would be no direct effect on heritage resources as a result of the Alternative. However, the proliferation of noxious weeds could displace native plants traditionally used by native people, and could also result in increased erosion of archeological sites as native vegetation is displaced. The displacement of native plants could also have an impact on visually aesthetic elements of historic sites.

Cumulative Effects There are no direct or indirect effects from herbicide application control methods in any Alternative; therefore, there would be no cumulative effects on heritage resources from those activities. Physical and cultural methods may have direct and indirect effects, although environmental protection measures are in place to avoid these effects. Other activities already planned or ongoing on the Forest (with the exception of illegal activities) also have measures to protect cultural resources, as required by the Forest Plan and other regulations. Cumulative effects from any action Alternative are expected to be minimal, and cultural resources, known or discovered during activities, would be protected.

Consistency with Forest Plans and Other Laws and Policies Any such actions would be implemented in accordance with applicable federal law and the Site Identification Strategy for the Modoc National Forest. Human Health and Safety This section describes the risk of negative impacts to human health and safety associated with noxious weed treatments including hand methods and herbicides. It is broken into two sections, a) those risks associated with hand methods and b) those risks associated with herbicide treatments. This effects section responds to the DEIS public concerns that the FEIS should more clearly disclose the human health and safety issues of herbicides proposed for use, and more information on the effects of specified herbicides on humans. Volume 2 Appendix items (Appendix C, Spill and Safety Management; Appendix E, Herbicide Information; Appendix F, Human Health Risk Assessment; Appendix P, Social and Economic Specialist Report; and Volume 3, Response to Comments sections on Herbicides and Human Health) were utilized in this Human Health and Safety analysis.

Hand Methods Hazards associated with using hand tools or workings on steep slopes under unfavorable site conditions are apparent. Conditions can be highly variable, ranging from gentle slopes with low vegetation densities and moderate ambient temperatures, to steep slopes with dense tall shrubs or trees and extremely hot or cold ambient temperatures. Workers could be cut by tools, hit by falling trees, or injured by falling onto sharp stumps or shrub stems. Risks of injuries increase with the amount of work, and are exacerbated when working in concentrated areas or when workers are fatigued. Injuries can vary from minor cuts, sprains, bruises, and abrasions to severe injuries causing major bleeding, compound bone fractures, serious brain concussions, or mortality. Hand clearing of vegetation is relatively slow work, with rates of production of 2 to 4 workdays per acre. This exposes workers to the hazards of this work for longer periods in relation to other, more efficient methods of clearing vegetation. Risks of injury increase as the slope, vegetation

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density, and vegetation height increases. Some invasive weed species can cause allergies and minor skin irritations in a few individuals. For example, leafy spurge contains a latex-bearing sap that irritates human skin and can (rarely) cause blindness in humans upon contact with the eye (Callihan et al. 1991). Some species of noxious weeds, such as thistles, cause minor scrapes and irritations. Approximately 10 to 15 % of the U.S. population suffers from allergy symptoms from invasive weed species such as knapweed. Knapweed is a common and powerful allergen that peaks in August (Gillespie and Hedstrom 1979). Allergies to weeds such as knapweed may complicate or trigger asthma. Other adverse health effects associated with outdoor work in rugged terrain are possible. Examples are extreme fatigue, heat exhaustion or heat stroke, and exacerbation of chronic health conditions, such as tendon or ligament damage or arthritis. In extreme situations, exertion from applying hand methods in rugged terrain could trigger a heart attack or stroke in predisposed workers. Workman’s compensation insurance data can suggest the magnitude of human health risks associated with hand methods, relative to some other methods. The Oregon State Accident Insurance Fund listed 2002 rates for reforestation activities (including brush cutting, slash piling and burning, construction of fire lines) not associated with logging operations as $7.89 per $100 of payroll (Heaser 2002, personal communication with D.Bakke). These rates are slightly higher than the rate for spraying herbicides ($7.10 per $100 of payroll) and for recreational forest trail construction ($6.32 per $100 payroll), but all of these rates indicate roughly comparable risk levels. The Workers Compensation Insurance Rating Bureau of California listed 2002 rates for forest workers (non-loggers) who handled chainsaws and handtools as $11.31 per $100 of payroll. This rate is comparable to workers who use herbicides (Egly 2002, personal communication with D. Bakke), indicating a similar level of work-related injuries (data for workers involved with mechanical treatments were unavailable). Proper supervision and effective training for safe use of hand equipment can reduce risks of worker injury. Wearing boots with non-skid soles and snag-resistant long-sleeve shirts and trousers also reduces risks. Forest Service procedures and normal forestry worker practices would encompass the use of these common safety items. Members of the public should not be at risk from hand methods, because they are not likely to be sufficiently close to specific areas when tools are used.

Effects Alternative 1, the No Action Alternative, would have no direct effects on human health associated with noxious weed treatments. The No Action Alternative would pose a continued direct effect on individuals visiting the National Forest when encounters with thistles or noxious weeds cause rashes or other health problems. There is no definitive way to distinguish between the action Alternatives, Alternatives 2 through 6, in terms of effects on human health and safety associated with hand methods. There is some level of potential risk, and significant adverse effects on human health could occur under any action Alternative, as explained in the above sections on the general consequences of using hand methods. Significant adverse risks are not expected if the treatments are conducted according to treatment prescriptions, but the potential for accidents, unexpected weather, and other factors that could cause unexpectedly high risks, is acknowledged.

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Human Health and Safety of Herbicide Use As Alternatives 1, 3, and 5 do not propose to use herbicides, there would be no direct, indirect, or cumulative risks of herbicide-related health effects from noxious weed treatments. The risks of adverse health effects in Alternatives 2, 4, and 6 from the use of any of the six herbicides addressed in this FEIS depend on the level of exposure at any given time, the duration of that exposure, and the inherent toxicity of the herbicide. Possible short-term adverse health effects include nausea, headache, dizziness, eye irritation, and coughing. The effects of Alternative 6 relative to Issue 1 (human health and safety) are similar to those described under Alternatives 2 and 4. However, risks to worker health and safety for Alternative 6, and the potential for public exposure to herbicides, would be reduced due to treatment of fewer acres. Long-term effects such as cancer, reproductive effects, and heritable mutations, were also considered. Applications of chlorsulfuron, Clopyralid, Glyphosate, and Triclopyr herbicides and the nonylphenol polyethoxylate surfactants are expected to pose a low risk to human health and safety. The use of 2, 4-D and Dicamba represent a higher risk to human health and safety. These conclusions are based on a comprehensive analysis of human health risks which was conducted to analyze the potential for adverse health effects to workers and members of the public from the use of these herbicides and surfactants. The analysis examines a range of potential exposures to herbicides, from routine operations involving workers, to accidents involving workers and the public. Assumptions range from typical rates of use to very high rates, representing what could be considered worst-case exposures. Appendix F of this FEIS presents the complete human health risk assessment. The following discussion on herbicide effects is taken from that risk assessment. The risk assessment examines the potential health effects on all groups of people who might be exposed to any of the six herbicides that might potentially be used in treating noxious weeds. Those potentially at risk fall into two groups: workers and members of the public. Workers include applicators, supervisors, and other personnel directly involved in the application of herbicides. The public includes non-project forest workers, forest visitors or nearby residents who could be exposed through the drift of herbicide spray droplets, through contact with sprayed vegetation, or by eating, or placing in the mouth, food items or other plant materials, such as berries or shoots growing in or near forests, by eating game or fish containing herbicide residues, or by drinking water that contains such residues. The analysis of the potential human health effects associated with the use of chemical herbicides uses the methodology of risk assessment generally accepted by the scientific community (National Research Council 1983; EPA 1986, both as referenced in Appendix F). In essence, this herbicide risk assessment consists of comparing doses that people may get from applying the herbicide (worker doses) or from being on or near an application site (public doses) with the U.S. Environmental Protection Agency’s (EPA) established Reference Doses (RfD), a level of exposure considered protective of lifetime or chronic exposures. RfD’s are based upon doses shown to cause no observed ill effects to test animals in either short-term (acute) or long-term (sub chronic or chronic) studies. Much of the information used in this risk assessment was gathered from herbicide-specific risk assessments completed by Syracuse Environmental Research Associates, Inc. (SERA), under contract to the Forest Service (principal author of these SERA risk assessments is Dr. Patrick Durkin). Details regarding the specific methods used to prepare the SERA human health risk assessments referenced in the Risk Assessment (Appendix F of this document) are provided in SERA (2000b, as referenced in Appendix F). Different types of possible effects were considered, including acute and chronic systemic effects, cancer and mutations, and reproductive effects. These were evaluated using appropriate animal test data. The risk assessment evaluated the chances of herbicide exposure causing general

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systemic effects that could range from nausea and headaches at low doses to organ damage, effects on reproduction, the possibility of birth defects, or even mortality at extreme doses. The risk assessment also examined the possibility of acute toxic effects from exposure in accidental scenarios. A Hazard Quotient (HQ) was computed, for each type of dose estimated for workers and members of the public, by dividing the dose by the RfD. In general, if the HQ was less than or equal to 1, the risk of effects was considered negligible. HQ values, because they are based on the RfD, a long-term measure of protection, can be considered over-protective when applied to acute exposures. This aspect is discussed in evaluating possible effects. Because the risk assessment is based on a number of assumptions, readers and decision-makers should not make the conclusion that the risk values are absolute. If the assumptions are changed, the risk values change. However, the relative risk among herbicides or methods should remain the same unless new toxicity data becomes available. One of the primary uses of a risk assessment is for risk management. Decision-makers can use the risk assessment to identify those herbicides, application methods, or exposure rates that pose the greatest risks to workers and the public. Specific Design Standards or other prevention measures can then be employed where the decision-maker feels the risks are unacceptably high. Reducing exposure can reduce risk. The use of Design Standards, personal protective equipment for applicators, and posting of treated areas are all examples of ways to reduce exposure to applicators and the public and are part of the action Alternatives (refer to the Design Standards in Chapter 2). Acceptable risk levels have been established and are used in the risk assessment and in this effects discussion. U.S. EPA has established a significant cancer risk level as being 1 chance in 1 million; the state of California, through Proposition 65, uses a standard of 1 chance in 1 hundred thousand. The RfD is also an EPA-established measure of acceptable risk for non- carcinogen exposures. This FEIS uses the standard of 1 chance in 1 million as a cancer risk level and the RfD as the standard for non-carcinogen exposures. In all herbicide Alternatives, herbicide exposure levels for both the public and for workers executing treatment activities would not exceed acceptable levels of risk to human health for all herbicides proposed for use (Bakke 2005). The use of proper personal safety equipment, training, and supervision for all weed-treatment crews would be required to reduce the potential for injuries to workers. The Risk Assessment in Appendix F has five major sections: 1) an introduction; 2) an identification of the hazards associated with each herbicide and its commercial formulations; 3) an assessment of potential exposure to the product; 4) an assessment of the dose-response relationships; and 5) a characterization of the risks associated with plausible levels of exposure. The following is a summary of Sections 2 – 5 including discussions about synergistic effects, sensitive individuals, and cumulative effects.

Hazard Analysis The hazards associated with using each of the herbicides were determined by a thorough review of available toxicological studies. For the most part, these reviews are contained in other documents and are referenced in the Risk Assessment (refer to Appendix F, pages 2 to 30). A considerable body of information has been compiled in a group of risk assessments completed by SERA, as well as in a risk assessment contained in the programmatic Region 5 FEIS Vegetation Management for Reforestation (USDA 1989 as referenced in Appendix F) and in the programmatic Herger Feinstein Quincy Library Group Forest Recovery Act Final SEIS (USDA 2003). Another source of information on toxicity is the background statements contained in Forest Service Agricultural Handbook No. 633 (USDA 1984, as referenced in Appendix F).

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Current peer-reviewed articles from the open scientific literature, as well as recent U.S. EPA documents are also used to update information contained in these reference documents. The toxicological database for each herbicide was reviewed for acute, sub-chronic, and chronic effects to test animals. Because of the obvious limitations on the testing of chemicals on humans, judgments about the potential hazards of pesticides to humans are necessarily based in large part on the results of toxicity tests on laboratory animals. Information on actual human poisoning incidents and effects on human populations supplemented these toxicity test results, where such information is available. For a background discussion of the various toxicological tests and endpoints, refer to USDA, 1989 (pages F-7 to F-18). For the herbicide Triclopyr, there are two formulations that are commonly used in treating noxious weeds: the triethylamine (TEA) salt and the butoxyethyl ester (BEE). These have somewhat different toxic properties so are considered separately in the risk assessment. They are referred to as Triclopyr TEA and Triclopyr BEE respectively.

Impurities and Metabolites Virtually no chemical synthesis yields a totally pure product. Technical grade herbicides, as with other technical grade products, may contain some impurities. The U.S. EPA defines the term impurity as “…any substance…in a pesticide product other than an active ingredient or an inert ingredient, including un-reacted starting materials, side reaction products, contaminants, and degradation products” (40 CFR 158.153(d)). To some extent, concern for impurities in technical grade herbicides is reduced by the fact that the existing toxicity studies on these herbicides were conducted with the technical grade product. Thus, if toxic impurities are present in the technical grade product, they are likely to be encompassed by the available toxicity studies on the technical grade product. An exception to this general rule involves carcinogens, most of which are presumed to act by non-threshold mechanisms. Because of the non-threshold assumption, any amount of a carcinogen in an otherwise non-carcinogenic mixture is assumed to pose some carcinogenic risk. This is the case with the following impurities:  Hexachlorobenzene in Clopyralid.  Ethylene oxide in some formulations of Glyphosate and in nonylphenol polyethoxylate (NPE)-based surfactants.  1,4-dioxane in some formulations of Glyphosate For these three impurities, separate analyses of their carcinogenic risk were completed. The Risk Assessment contains the analyses for hexachlorobenzene. An analysis of the cancer risks from exposure to ethylene oxide and 1, 4-dioxane is included in separate references (USDA 2003, and Borrecco and Neisess 1991 both as referenced in the Risk Assessment). In addition to the carcinogenic risks, acute and chronic risks from exposure to hexachlorobenzene are specifically included in the Risk Assessment. From USDA (2003), the risks of cancer from the exposure to ethylene oxide were considered negligible for occupationally exposed individuals, based on a standard of acceptable risk of 1 in 1 million. As the risks from ethylene oxide are considered in USDA (2003) and risks are considered acceptable, given the conservative assumptions of exposure, it will not be further analyzed or discussed in the Risk Assessment. From Borrecco and Neisess (1991), the risks of cancer from the exposure to 1, 4-dioxane was considered negligible for occupationally exposed individuals, based on a standard of acceptable risk of 1 in 1 million. Since the Borrecco and Neisess paper was written, the amount of 1,4- dioxane that was assumed present in the Glyphosate formulation by the authors, has been determined to be much lower (correspondence between Borrecco and M. Lemon, Monsanto

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Company 1995). Hence, the margins of safety in Borrecco and Neisess can be considered conservative. In addition, an evaluation of non-cancer toxicity indicated that exposures to 1, 4- dioxane would result in acceptable levels of risk (Borrecco and Neisess 1991). Another impurity that has been considered separately is 2-butoxyethanol (also known as ethylene glycol monobutyl ether or EGBE). 2-butoxyethanol is an impurity in the Triclopyr BEE formulation. It is on the EPA Inerts List 2 (see discussion of inerts below), because of its toxicity. This impurity was also assessed in Borrecco and Neisess, 1991. The analysis of 2-butoxyethanol indicated that exposures would result in acceptable levels of risk to both workers and the public. Similar to impurities, the potential effect of metabolites in a risk assessment is often encompassed by the available in vivo toxicity studies under the assumption that the toxicological consequences of metabolism in the species on which toxicity studies are available would be similar to those in the species of concern; human in this case. Uncertainties in this assumption are encompassed by using an uncertainty factor in deriving the RfD and may sometimes influence the selection of the study used to derive the RfD. There is an exception when environmental metabolites may be available for exposure, as is the case with 2, 4-D, Glyphosate, and Triclopyr. The environmental metabolites of 2, 4-D and Glyphosate are discussed below, while the environmental metabolite of Triclopyr is discussed under cumulative effects. Although 2, 4-D does not appear to be metabolized extensively in mammals; the compound degrades in the environment to form the metabolite, 2, 4-dichlorophenol. Although 2, 4- dichlorophenol was not detected in vegetation or water samples after the application of 2, 4-D, it has been detected in aqueous sediments at approximately the same concentrations as 2, 4-D. 2; 4- Dichlorophenol is a toxic metabolite. The RfD for 2, 4-dichlorophenol is 0.003 mg/kg/day based on impaired immunological function. The RfD for 2, 4-dichlorophenol is approximately the same as the chronic RfD for 2, 4-D that is used in the risk assessment. Because there is no indication that workers or the general public will be exposed to substantial amounts of 2, 4-Dichlorophenol, the formation of this compound in sediment as part of the environmental degradation process does not contribute substantially to the risks associated with the use of 2, 4-D. Glyphosate is partially metabolized in the environment to aminomethylphosphonate (AMPA). The U.S. EPA has assessed the potential consequences of exposures to AMPA as an environmental metabolite. Based on this review, the U.S. EPA concluded that only the Glyphosate parent is to be regulated and that AMPA is not of toxicological concern regardless of its levels in food. The position taken by the U.S. EPA is supported by more extensive reviews. The position taken by U.S. EPA appears to be reasonable and is well supported. Consequently, in the risk assessment, AMPA is not quantitatively considered in the dose-response and exposure assessments.

Inert Ingredients The issue concerning inert ingredients and the toxicity of formulations is discussed in USDA (1989) (pages 4-116 to 4-119). The approach used in USDA (1989), the SERA Risk Assessments (as referenced in Appendix F), and this analysis to assess the human health effects of inert ingredients and full formulations has been to:  Compare acute toxicity data between the formulated products (including inert ingredients) and their active ingredients alone;  Disclose whether or not the formulated products have undergone chronic toxicity testing; and  Identify, with the help of EPA and the chemical companies, ingredients of known toxicological concern in the formulated products and assess the risks of those ingredients.

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Researchers have studied the relationships between acute and chronic toxicity and while the biological end-points are different, relationships do exist and acute toxicity data can be used to give an indication of overall toxicity (Zeise et al. 1984, as referenced in Appendix F). The court in NCAP v. Lyng, 844 F.2d 598 (9th Cir 1988) decided that this method of analysis provided sufficient information for a decision maker to make a reasoned decision. In SRCC v. Robertson, Civ.No. S-91-217 (E.D. Cal., June 12, 1992) and again in CATs v. Dombeck, Civ. S-00-2016 (E.D. Cal., Aug 31, 2001) the district court upheld the adequacy of the methodology used in USDA, 1989 for disclosure of inert ingredients and additives. The U.S. EPA has categorized approximately 1,200 inert ingredients into four lists. Lists 1 and 2 contain inert ingredients of toxicological concern. List 3 includes substances for which EPA has insufficient information to classify as either hazardous (List 1 or 2) or non-toxic (List 4). List 4 contains non-toxic substances such as corn oil, honey and water. Use of formulations containing inert ingredients on List 3 and 4 is preferred on vegetation management projects under current Forest Service policy. Since most information about inert ingredients is classified as “Confidential Business Information” (CBI) the Forest Service asked U.S. EPA to review herbicide formulations and advise if they contain inert ingredients of toxicological concern. In addition, the CBI files were reviewed in the development of the various SERA risk assessments. Information has also been received from the companies who produce the herbicides and spray additives. Appendix F contains information on inert ingredients in Section 2, Hazard Analysis. Comparison of acute toxicity (LD50 values) data between the formulated products (including inert ingredients) and their active ingredients alone shows that the formulated products are generally less toxic than their active ingredients (USDA, 1989; USDA, 1984, SERA risk assessments). The analysis in Appendix F reviewed the acute toxicity comparisons, the U.S. EPA review, and the examination of toxicity information on inert ingredients in each product. While these formulated products have not undergone chronic toxicity testing like their active ingredients, this review leads to the conclusion that the inert ingredients in these formulations do not significantly increase the risk to human health and safety over the risks identified for the active ingredients.

Additives Additives, or adjuvants, to the formulations that might be used when herbicides are applied are not considered in detail in the risk assessment, with the exception of surfactants containing nonylphenol polyethoxylate (NPE) as an active ingredient. This active ingredient is specifically included because of the potential presence of nonylphenol in this compound (a U.S. EPA inerts list 2 material) and the potential for toxic effects, including endocrine disruption. Additives might involve surfactants, drift reduction agents, and dyes or colorants. Many of the formulated herbicides require the use of added surfactants; such information is on the herbicide label. Surfactants increase the ability of the herbicide to be absorbed into plant tissues. Dyes and colorants are used to indicate that a plant or area has been treated, for several reasons, including avoiding waste of materials by retreating, to allow people to avoid treated areas in short term, and to be more effective by treating all target vegetation. There is a colorant often used in foliar applications of these herbicides (Colorfast™ Purple) that contains a dye, Basic Violet 3 or Gentian Violet, considered a potential carcinogen. A risk assessment for the carcinogenic properties of this dye was completed (SERA, 1997b, as referenced in the Risk Assessment, Appendix F). In SERA (1997b) the cancer risk to workers and the public is at acceptable levels of risk. For public exposures, it is expected that the dye would

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reduce exposures both to itself and to the other chemicals it might be mixed with (herbicide and other adjuvants) as the public would be alerted to the presence of treated vegetation. As for other additives that potentially could be used, as previously stated and in USDA (2002, 2007 as referenced in Appendix F), there is a considerable range of such products that could be considered. USDA (2002, 2007) provides an overview of the various types of additives (or adjuvants) likely to be used in forest herbicide applications and provides acute toxicity data for many of the formulations used by the Forest Service. An analysis of the ingredients in these adjuvants did not identify any specific toxic concern with the exception of the ingredients discussed in the risk assessment (ibid). None were on EPA Inerts Lists 1 or 2. The primary summary statement that can be made is that the more common risk factors for the use of these adjuvants are through skin or eye exposure. These adjuvants all have various levels of irritancy associated with skin or eye exposure. This reinforces the need for good industrial hygiene practices while utilizing these products, especially when handling the concentrate, such as during mixing. The use of chemical resistant gloves and goggles, especially while mixing, should be observed. Since state law requires the use of goggles and gloves when mixing or applying any of the herbicides, including any of the adjuvants, eye and skin protection should be adequate.

Herbicide Use - Direct and Indirect Effects

Worker Exposure Analysis Pesticide applicators are the individuals most likely to be exposed to a pesticide during the application process. Two types of worker exposure assessments are considered: general and accidental/incidental. The term general exposure assessment is used to designate those exposures that involve estimates of absorbed dose based on the handling of a specified amount of a chemical during specific types of applications. The accidental/incidental exposure scenarios involve specific types of events that could occur during any type of application. Initially, risk assessments for the Forest Service adjusted the exposure rate by the estimated dermal absorption rate, typically using 2, 4-D as a surrogate chemical when compound-specific data were not available (USDA 1989). SERA conducted a detailed review and re-evaluation of the available worker exposure studies that can be used to relate absorbed dose to the amount of chemical handled per day (SERA 1998b, 2006, as referenced in Appendix F). This review noted that there was no empirical support for a dermal absorption rate correction. Two factors appear to be involved in this unexpected lack of association: 1) algorithms for estimating dermal absorption rates have large margins of error; and, 2) actual levels of worker exposure are likely to be far more dependent on individual work practices or other unidentified factors than on differences in dermal absorption rates. Thus, in the absence of data to suggest an Alternative approach, no corrections for differences in dermal absorption rate coefficients or other indices of dermal absorption seem to be appropriate for adjusting occupational exposure rates. In general, occupational exposures may involve multiple routes of exposure (oral, dermal, and inhalation); nonetheless, dermal exposure is generally the predominant route for herbicide applicators. Typical multi-route exposures are encompassed by the methods used for general exposures. Accidental exposures, on the other hand, are most likely to involve splashing a solution of herbicides into the eyes or to involve various dermal exposure scenarios. There are various methods for estimating absorbed doses associated with accidental dermal exposure. Two general types of exposure are modeled: those involving direct contact with a

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solution of the herbicide and those associated with accidental spills of the herbicide onto the surface of the skin. Any number of specific exposure scenarios could be developed for direct contact or accidental spills by varying the amount or concentration of the chemical on or in contact with the surface of the skin and by varying the surface area of the skin that is contaminated. For this risk assessment, two exposure scenarios are developed for each of the two types of dermal exposure, and the estimated absorbed dose for each scenario is expressed in units of mg chemical/kg body weight.

Table 3 - 25. Herbicide and Nonylphenol Polyethoxylate Application Rates to be Used to Treat Noxious Weeds, Including the Incidental Rate of Application of the Impurity Hexachlorobenzene

Herbicide App Rate-Typical App Rate-Lowest App Rate-Highest Lb/ac Lb/ac Lb/ac Chlorsulfuron 0.047 ai 0.035 ai 0.062 ai Clopyralid 0.25 ae 0.13 ae 0.25 ae 2, 4-D 1.5 ae 0.5 ae 2.0 ae Dicamba 1.0 ae 0.25 ae 2.0 ae Glyphosate 2.5 ae 0.75 ae 3.75 ae Triclopyr TEA 1.0 ae 0.5 ae 1.5 ae Triclopyr BEE 1.0 ae 0.5 ae 1.5 ae Nonylphenol Polyethoxylate 1.7 ai 1.3 ai 2.3 ai Hexachlorobenzene 0.000000625 ai 0.000000325 ai 0.000000625 ai Note: These application rates include the incidental rates of application of the impurity hexachlorobenzene. ai = active ingredient; ae = acid equivalent. If the active ingredient is commercially formulated as a salt, ester, or amine, it is converted to its acid equivalent for purposes of comparison. Exposure scenarios involving direct contact with solutions of the chemical are characterized by immersion of the hands for 1 minute or wearing contaminated gloves for 1 hour. Generally, it is not reasonable to assume or postulate that the hands or any other part of a worker would be immersed in a solution of an herbicide for any period. On the other hand, contamination of gloves or other clothing is quite plausible. For these exposure scenarios, the key element is the assumption that wearing gloves grossly contaminated with a chemical solution is equivalent to immersing the hands in a solution. In either case, the concentration of the chemical in solution that is in contact with the surface of the skin and the resulting dermal absorption rate are essentially constant. Exposure scenarios involving chemical spills onto the skin are characterized by a spill onto the lower legs as well as a spill on to the hands. In these scenarios, it is assumed that a solution of the chemical is spilled onto a given surface area of skin and that a certain amount of the chemical adheres to the skin. Quantitative summaries of the exposures to workers from these exposure scenarios for both general and accidental exposures, by herbicide (including nonylphenol polyethoxylate and hexachlorobenzene), are shown in Appendix F. The implications of these exposure scenarios are discussed in the Risk Characterization section below.

Public Exposure Analysis Under normal conditions, members of the general public should not be exposed to substantial levels of any of these herbicides. Members of the public would generally not be in the areas of maintenance work during herbicide application. In addition, posting of treatment areas should provide adequate warning to the public that an area has been treated. Despite the likelihood that the public would not be exposed to these herbicides, exposure scenarios were developed and evaluated for members of the public. These scenarios are described below. Quantitative summaries of the exposures to the public from these exposure scenarios, by herbicide (including nonylphenol polyethoxylate and hexachlorobenzene), are shown in

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Appendix F. The implications of these exposure scenarios are discussed in the Risk Characterization section below.

Direct Spray The majority of the acres to be treated would not be expected to act as a specific draw to large numbers of non-project personnel. Nonetheless, any number of exposure scenarios can be constructed for the general public, depending on various assumptions regarding application rates, dispersion, canopy interception, and human activity. Several highly conservative scenarios are developed for this risk assessment. The two types of exposure scenarios developed for the general public includes acute exposure and longer-term or chronic exposure. All of the acute exposure scenarios are primarily accidental. They assume that an individual is exposed to the compound either during or shortly after its application. Specific scenarios are developed for direct spray, dermal contact with contaminated vegetation, as well as the consumption of contaminated fruit, water, and fish. Most of these scenarios should be regarded as extreme, some to the point of limited plausibility. The longer-term or chronic exposure scenarios parallel the acute exposure scenarios for the consumption of contaminated fruit, water, and fish but are based on estimated levels of exposure for longer periods after application. For direct spray scenarios, it is assumed that during a ground application, a naked child is sprayed directly with the herbicide. The scenario also assumes that the child is completely covered (that is, 100 % of the surface area of the body is exposed), which makes this an extremely conservative exposure scenario that is likely to represent the upper limits of plausible exposure. An additional set of scenarios are included involving a young woman who is accidentally sprayed over the feet and legs. For each of these scenarios, some standard assumptions are made regarding the surface area of the skin and body weight. In the dermal exposure from contaminated vegetation exposure scenario, it is assumed that the herbicide is sprayed at a given application rate and that an individual comes in contact with sprayed vegetation or other contaminated surfaces at some period after the spray operation. For these exposure scenarios, some estimates of dislodgeable residue and the rate of transfer from the contaminated vegetation to the surface of the skin must be available. No such data are directly available for these herbicides, and so estimation methods are used.

Water Contamination Water can be contaminated from runoff, as a result of leaching from contaminated soil, from a direct spill, or from unintentional contamination from aerial applications. For this risk assessment, the three types of estimates made for the concentration of these herbicides in ambient water are acute/accidental exposure from an accidental spill and short and longer-term/chronic exposure to the herbicides in ambient water that could be associated with the typical application of this compound to a 100-acre treatment area. There are two acute exposure scenarios. The first assumes that a young child (2- to 3-years old) consumes contaminated water shortly after an accidental spill of a field solution into a small pond. The second assumes that a small child consumes contaminated water shortly after an overland flow or drift event to a stream. Because these scenarios are based on the assumption that exposure occurs shortly after the water is contaminated, no dissipation or degradation of the herbicide is considered. The scenario for chronic exposure to these herbicides from contaminated water assumes that an adult consumes contaminated ambient water for a lifetime. Estimates of levels in ambient water were made based on the GLEAMS (Groundwater Loading Effects of Agricultural Management Systems) model. GLEAMS is a root zone model that can be used to examine the fate of chemicals in various types of soils under different meteorological and

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hydrogeological conditions. Tables below describe the acute and chronic water contamination rates utilized in the risk assessment and are based on GLEAMS modeling.

Table 3 - 26. Short-Term Water Contamination Rates (WCR) of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity (In Mg/L Per Lb Applied)

Herbicide Typical WCR Low WCR High WCR Chlorsulfuron 0.1 0.01 0.2 Clopyralid 0.02 0.005 0.07 2, 4-D 0.15 0.13 0.42 Dicamba 0.003 0.00006 0.01 Glyphosate 0.02 0.001 0.4 Triclopyr 0.09 0.001 0.4 Nonylphenol polyethoxylate 0.012 0.0031 0.031 Hexachlorobenzene 0.09 0.001 0.3

Table 3 - 27. Longer-Term Water Contamination Rates (WCR) of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity (In Mg/L Per Lb Applied)

Herbicide Typical WCR Low WCR High WCR Chlorsulfuron 0.0006 0.0001 0.0009 Clopyralid 0.007 0.001 0.013 2, 4-D 0.002 0.001 0.004 Dicamba 0.00001 0.000005 0.00003 Glyphosate 0.001 0.0001 0.008 Triclopyr 0.03 0.008 0.05 Nonylphenol polyethoxylate 0.007 0.00001 0.014 Hexachlorobenzene 0.0005 0.00003 0.001

Many chemicals may be concentrated or partitioned from water into the tissues of animals or plants in the water. This process is referred to as bioconcentration. As with most absorption processes, bioconcentration depends initially on the duration of exposure but eventually reaches steady state. Generally, bioconcentration is measured as the ratio of the concentration in the organism to the concentration in the water, referred to as a bioconcentration factor (BCF). There are three with BCF value greater than 1: chlorsulfuron (1 to 12), 2, 4-D (40), and hexachlorobenzene (10,000). For both the acute and longer-term exposure scenarios involving the consumption of contaminated fish, the water concentrations of the herbicides used are identical to the concentrations used in the contaminated water scenarios. The acute exposure scenario is based on the assumption that an adult angler consumes fish taken from contaminated water shortly after an accidental spill into a pond. No dissipation or degradation is considered. Because of the available and well-documented information and substantial differences in the amount of caught fish consumed by the general public and Native American subsistence populations, separate exposure estimates are made for these two groups. The chronic exposure scenario is constructed in a similar way.

Vegetation Contamination Under normal circumstances and in most types of applications, it is extremely unlikely that humans would consume, or otherwise place in their mouths, vegetation contaminated with these herbicides. Nonetheless, any number of scenarios could be developed involving either accidental spraying of crops, the spraying of edible wild vegetation, like berries, or the spraying of plants collected by Native Americans for basket weaving or medicinal use. Again, in most instances and particularly for longer-term scenarios, treated vegetation would probably show signs of damage from herbicide exposure, thereby reducing the likelihood of consumption that would lead to

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significant levels of human exposure. Notwithstanding that assertion, it is conceivable that individuals could consume contaminated vegetation. One of the more plausible scenarios involves the consumption of contaminated berries after treatment along a road or some other area in which wild berries grow. The two accidental exposure scenarios developed for this exposure assessment include one scenario for acute exposure and one scenario for longer-term exposure (90 days). In both scenarios, the concentration of herbicide on contaminated vegetation is estimated using a derived empirical relationship between application rate and concentration on vegetation. For hexachlorobenzene the assumption used is that there is no dissipation of the impurity in plants over the course of the chronic contaminated vegetation scenario. This is due to its long half time in the soil (SERA, 1999c). An additional consideration with hexachlorobenzene is that the BCF in vegetation is established as 19.

Dose-Response Assessment In evaluating the doses received under each scenario, the doses are evaluated against RfD’s as previously stated. If all the exposures are below the RfD (an HQ less than or equal to 1) the assumption is that the proposed use of the herbicide presents little risk to either the public or workers. If any exposure exceeds the RfD, a closer look at the various studies and exposure scenarios must be made to determine whether a toxic response is expected from the exposure. This section of the risk assessment describes the RfD, its basis, and for those herbicides that show doses exceeding the RfD, it provides an analysis of the various studies and further refines the risk thresholds. Table below displays the acute and chronic RfDs used in the risk assessment.

Table 3 - 28. Reference Doses (Rfd) in Mg/Kg/Day Of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity

Herbicide Acute RfD Chronic RfD Chlorsulfuron 0.25 0.02 Clopyralid 0.75 0.15 2, 4-D 0.067 (general population) 0.005 0.025 (women) Dicamba 0.1 0.045 Glyphosate 2.0 2.0 Triclopyr 1.0 (general population) 0.05 0.05 (women) Nonylphenol Polyethoxylate 1 0.1 0.1 Hexachlorobenzene 2 0.008 0.0008 1 This is not a U.S. EPA-derived RfD; it is developed in the USDA, 2003 risk assessment on nonylphenol polyethoxylate and is described as a ‘provisional reference dose’. 2 The acute value for hexachlorobenzene is an ASTDR acute MRL (minimal risk level). It is similar to an U.S. EPA RfD.

Risk Characterization A quantitative summary of the risk characterization for workers and the public associated with exposure to these herbicides is presented in this section, along with a narrative description. The quantitative risk characterization is expressed as the hazard quotient, which is the ratio of the estimated exposure doses to the RfD. A reservation attached to this assessment is that associated with any risk assessment: Absolute safety cannot be proven, and the absence of risk can never be demonstrated. No chemical has been studied for all possible effects, and the use of data from laboratory animals to estimate hazard or the lack of hazard to humans is a process that has uncertainty. Prudence dictates that

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normal and reasonable care would be taken in the handling of these herbicides. The introduction in Appendix F of this document discusses the concept of uncertainty in risk assessments, as do the lead-in paragraphs in Appendix F, Section 5 (Risk Characterization). To summarize worker exposures, with the exception of 2, 4-D, typical application rates and non- accidental work scenarios indicates that risks to workers are considered acceptable. At typical application rates, the use of 2, 4-D represents a slight risk to workers, but it is unlikely that toxic effects would be seen. At the upper application rates, chronic exposures of workers to both Dicamba and 2, 4-D represent a risk of health effects, although the extent of those effects is not clear. For the accidental exposure scenarios that are analyzed, only one scenario, the wearing of contaminated gloves for one hour after being exposed to the highest rates of Triclopyr BEE represents a risk of health effects. All other accidental scenarios for all other herbicides have hazard quotients below 1. All of these herbicides can cause irritation and damage to the skin and eyes. Eye or skin irritation is likely to be the only overt effect due to mishandling of these herbicides. As stated above, it is important to remember that under normal conditions, members of the general public should not be exposed to substantial levels of any of these herbicides. To summarize public exposures, exposure to chlorsulfuron, Clopyralid, Glyphosate, and the impurity hexachlorobenzene under the accidental scenarios analyzed here would represent acceptable levels of risk at all application rates and both acute and chronic exposures. Public exposures to 2, 4-D, Dicamba, Triclopyr and nonylphenol polyethoxylate result in hazard quotients exceeding one in several scenarios; some that greatly exceed one. The implications of hazard quotients that exceed one vary by herbicide; it is an incorrect assumption that the same HQ means the same degree of effects with different herbicides.

Worker Risks Related to Occupational Exposures For typical concentrations, backpack sprayers can apply five of the six herbicides without exposures exceeding a hazard quotient (HQ) of 1 (refer to Tables 3-29 and 3-30). The exception is 2, 4-D, which slightly exceeds a HQ of 1. This implies that long-term employment applying these five herbicides, absent accidental scenarios, can be accomplished without any expected toxic effects. All worker occupational exposures at typical, lower, and upper application rate scenarios result in a hazard quotient less than or equal to 1 for chlorsulfuron, Clopyralid, Glyphosate, nonylphenol polyethoxylate, and the impurity hexachlorobenzene. In addition, the cancer risks from all the worker occupational exposures to hexachlorobenzene in Clopyralid are at least 2 orders of magnitude below the risk standard of 1 chance in 1 million.

Table 3 - 29. Hazard Quotients (Non-Cancer) for Backpack Applicators – General (Non-Accidental) Exposures of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity

Herbicide Typical Rate of Lower Rate of Upper Rate of Application Application Application Chlorsulfuron 0.01 0.0006 0.1 Clopyralid 0.01 0.0003 0.07 2, 4-D 2 0.04 16 Dicamba 0.1 0.002 2 Glyphosate 0.008 0.0001 0.08 Triclopyr TEA 0.1 0.004 1.2 Triclopyr BEE 0.1 0.004 1.2 Nonylphenol Polyethoxylate 0.1 0.005 0.9 Hexachlorobenzene 0.000005 0.0000001 0.00003

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Table 3 - 30. Hazard Quotients (Non-Cancer) for Boom Spray Applicators – General (Non-Accidental) Exposures of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity

Herbicide Typical Rate of Lower Rate Upper Rate Application of of Application Application Chlorsulfuron 0.01 0.0002 0.1 Clopyralid 0.009 0.0001 0.07 2, 4-D 2 0.01 17 Dicamba 0.1 0.0007 2 Glyphosate 0.007 0.00005 0.08 Triclopyr TEA 0.1 0.001 1.3 Triclopyr BEE 0.1 0.001 1.3 Nonylphenol Polyethoxylate 0.09 0.002 1.0 Hexachlorobenzene 0.000004 0.00000005 0.00003 Note: Data for boom-sprayer application is for comparison purposes only. The Forest does not propose using boom sprayers. For 2, 4-D, at the typical application rates, the hazard quotient slightly exceeds one with a value of 2 for both backpack and boom spray applications. At the upper rates of application, worker exposures greatly exceed a value of one, with hazard quotients of 16 and 17. One reason for these high hazard quotients is the additional 10X safety factor due to toxicity database gaps that is used to derive the RfD. As discussed in Appendix F (Section 4), and assuming that the missing studies don’t change the conclusions, chronic human doses in the range of 0.08 to 0.09 mg/kg/day (upper range for workers) can result in some sub-clinical effects (effects to kidney, liver, testes, thyroid, body weight). At the typical exposures, effects to workers are unlikely, even with hazard quotients slightly exceeding unity. For Dicamba, at the typical and lower application rates, the hazard quotients are below unity for backpack and boom spray applications. At the upper application rate, the hazard quotient slightly exceeds one with a value of 2. The simple verbal interpretation of this quantitative characterization of risk is that under a protective set of exposure assumptions, backpack and boom spray workers would not be exposed to levels of Dicamba that are regarded as unacceptable at the typical application rate. At the maximum application rate, some workers could be exposed to levels of Dicamba that would not be regarded as acceptable. It is unclear from the toxicity tests that form the basis for the RfD, if overt effects would be likely from this slight exceeding of the RfD. This dose is below the 45 mg/kg/day rat NOAEL by a factor of ~560. For Triclopyr, both TEA and BEE formulations, typical and lower estimates of exposure for workers approach, but don’t exceed, a level of concern. At the upper application range, exposure levels slightly exceed the level of concern, with hazard quotients of 1.2 and 1.3. The health consequences of these exposure levels are uncertain but would be expected to be minimal.

Worker Risks from Accidents and Incidents Tables below display the hazard quotients for worker risks from accidents and incidents. As stated, the hazard quotient is based on the RfD, which for many of the herbicides is itself a measure of acceptable chronic exposure. Since the accident scenarios are infrequent events, the use of the hazard quotient is inherently conservative. With that said, all worker accidental exposures at typical, lower, and upper application rate scenarios result in a hazard quotient less than or equal to 1 for chlorsulfuron, Clopyralid, Glyphosate, Triclopyr TEA, nonylphenol polyethoxylate, and the impurity hexachlorobenzene.

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Table 3-31 shows hazard quotients (non-cancer) for workers from accidental/incidental exposures at the typical application rate, and Table 3-32 shows hazard quotients (non-cancer) for workers from accidental/incidental exposures at the upper application rate.

Table 3 - 31. Hazard Quotients (Non-Cancer) for Backpack Applicators – Accidental/Incidental Exposures with Typical Application Rate of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity

Spill on Immersion of Contaminated Spill on lower Herbicide hands, hands, 1 min. gloves, 1 hour legs, 1 hour 1 hour Chlorsulfuron 0.0000004 0.00003 0.00002 0.00004 Clopyralid 0.0000005 0.00003 0.0001 0.0002 2, 4-D 0.0005 0.03 0.01 0.03 Dicamba 0.0003 0.02 0.006 0.01 Glyphosate 0.000002 0.0001 0.0002 0.0006 Triclopyr TEA 0.00002 0.001 0.006 0.02 Triclopyr BEE 0.008 0.5 0.02 0.05 Nonylphenol Polyethoxylate 0.002 0.1 0.0005 0.001 Hexachlorobenzene 0.00006 0.004 0.0000008 0.000002

Table 3 - 32. Hazard Quotients (Non-Cancer) for Backpack Applicators – Accidental/Incidental Exposures with Upper Application Rate of Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity

Herbicide Immersion of Contaminated Spill on Spill on lower hands, 1 min. gloves, 1 hour hands, legs, 1 hour 1 hour Chlorsulfuron 0.000002 0.0001 0.0001 0.0003 Clopyralid 0.000003 0.0002 0.0006 0.001 2, 4-D 0.002 0.1 0.06 0.2 Dicamba 0.002 0.1 0.04 0.1 Glyphosate 0.00001 0.0008 0.001 0.003 Triclopyr TEA 0.0001 0.006 0.03 0.09 Triclopyr BEE 0.03 1.6 0.06 0.1 Nonylphenol Polyethoxylate 0.004 0.3 0.007 0.02 Hexachlorobenzene 0.0004 0.01 0.000004 0.00006

The accidental exposure scenario of wearing gloves contaminated with Triclopyr BEE for 1 hour exceeds the RfD for upper exposure levels (HQ = 1.6). Although it is unlikely that a one-time exposure to Triclopyr BEE at this level would result in toxic effects, this scenario indicates that adequate worker hygiene practices are important. As stated above, workers applying Triclopyr only occasionally would be at much lower risk of such an accident. If a worker applies Triclopyr often, and is sloppy with industrial hygiene, some effects to the kidney are plausible. The simple verbal interpretation of this quantitative characterization of risk is that under the most conservative set of accidental exposure assumptions, workers could be exposed to levels of Triclopyr BEE that are regarded as unacceptable. If Triclopyr is not applied at the highest application and concentration rate or if appropriate steps are taken to ensure that workers are not exposed to the maximum plausible rates (i.e., worker hygiene practices) the risk to workers would be substantially reduced. All of these herbicides can cause irritation and damage to the skin and eyes. Eye or skin irritation is likely to be the only overt effect due to mishandling of these herbicides. These effects can be minimized or avoided by prudent industrial hygiene practices during handling. The amine formulations of 2, 4-D and Triclopyr can have impacts that are more serious to the eyes; eye

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protection is critical when using these two active ingredients. Since state law requires the use of goggles when mixing or applying any of these herbicides, eye protection should be adequate.

Public Exposures from Direct Spray Table 3-33 displays the hazard quotient values for the public, direct-spray scenarios. The two direct spray scenarios (child sprayed and woman sprayed on feet and legs) at all application rate scenarios results in a hazard quotient less than or equal to 1 for chlorsulfuron, Clopyralid, nonylphenol ethoxylate, and the impurity hexachlorobenzene.

Table 3 - 33. Hazard Quotient (Non-Cancer) for the Public – Direct-Spray Scenarios of Using Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity

Child, Child, Woman, Woman, Herbicide typical rate upper rate typical rate upper rate Chlorsulfuron 0.0006 0.005 0.00006 0.005 Clopyralid 0.004 0.02 0.0004 0.002 2, 4-D 0.5 2 0.1 1 Dicamba 0.2 1.7 0.02 0.2 Glyphosate 0.009 0.04 0.0009 0.004 Triclopyr TEA 0.2 1.3 0. 5 3 Triclopyr BEE 0.7 2 1.4 4 Nonylphenol Polyethoxylate 0.02 0.3 0.002 0.03 Hexachlorobenzene 0.00003 0.0002 0.000003 0.00002

The direct spray of the naked child with 2, 4-D at the upper exposure level slightly exceeds the level of concern, with a hazard quotient of 2. As with the worker exposures, one reason for these high hazard quotients is the additional 10X safety factor due to toxicity database gaps that is used to derive the RfD. Where the acute human exposures are less than about 1 mg/kg/day, no effects would be anticipated. At the upper exposure level, the spraying of a child slightly exceeds the level of concern (HQ = 1.7). This level of exposure is unlikely to result in sub-clinical effects to a child. As stated in Appendix F, the acute RfD is based on a single-dose neurotoxicity study in rabbits with an implied NOAEL of 30 mg/kg/day. Based on this study, there is little chance of neurological effects to a child exposed at the upper application rates. At the upper application rate of 1.5 lbs/acre, both Triclopyr BEE and Triclopyr TEA formulations would exceed the level of concern for all dermal exposure scenarios. At the typical rate, the Triclopyr BEE scenario for a woman sprayed also exceeds the level of concern. Based on the dose-severity relationship for Triclopyr, at these levels of acute exposure, it is unlikely that there would be any adverse health effects associated with a one-time exposure.

Public Exposures from Exposure to Treated Vegetation Table 3-34 displays the hazard quotient values for members of the public who might contact sprayed vegetation. The scenario involving a woman contacting treated vegetation at all application rate scenarios results in a hazard quotient less than or equal to 1 for all herbicides but Triclopyr TEA and BEE. For Triclopyr BEE, at the typical rate of application, the HQ slightly exceeds 1, while at the upper application rates, the HQ for both TEA and BEE exceed the RfD (HQ = 2 – 3). Based on the dose-severity relationship for Triclopyr, at these levels of acute exposure, it is unlikely that there would be any adverse health effects associated with a one-time exposure. This scenario again highlights the need for prevention of public exposures during and immediately after spraying.

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Table 3 - 34. Hazard Quotient (Non-Cancer) for the Public – Direct Spray Scenarios of Using Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity

Herbicide Typical rate Upper rate Chlorsulfuron 0.00006 0.0004 Clopyralid 0.0005 0.002 2, 4-D 0.2 1 Dicamba 0.03 0.2 Glyphosate 0.001 0.005 Triclopyr TEA 0.6 2 Triclopyr BEE 1.3 3 Nonylphenol Polyethoxylate 0.003 0.06 Hexachlorobenzene 0.0000009 0.000002

Public Exposure from Eating Sprayed Fruit (Acute and Chronic) Table 3-35 displays the hazard quotient for members of the public shortly after ingesting contaminated fruit. The scenario involves eating berries daily for 90 days after they were sprayed with herbicides. Both the acute and chronic scenarios show similar results. For all six herbicides, nonylphenol polyethoxylate, and the impurity hexachlorobenzene, HQs are less than or equal to 1 for both the acute and chronic scenario for the typical rates of application. For all the herbicides but 2, 4-D, and Dicamba, and nonylphenol polyethoxylate, the HQs are less than 1 for the upper application rates. In addition, the cancer risk in the chronic scenario from hexachlorobenzene in Clopyralid is at least 3 orders of magnitude below the risk standard of 1 chance in 1 million for all exposure levels.

Table 3 - 35. Hazard Quotient (Non-Cancer) for the Public – Contaminated Fruit While Using Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity

Acute Chronic Herbicide Typical rate Upper rate Typical rate Upper rate Chlorsulfuron 0.002 0.05 0.01 0.2 Clopyralid 0.004 0.06 0.008 0.2 2, 4-D 0.7 15 1 17 Dicamba 0.1 4 0.04 1.2 Glyphosate 0.01 0.3 0.008 0.2 Triclopyr TEA 0.06 1 0.03 0.7 Triclopyr BEE 0.06 1 0.03 0.7 Nonylphenol polyethoxylate 0.2 4 0.003 0.07 Hexachlorobenzene 0.000002 0.00001 0.0000006 0.000006

For 2, 4-D, at the upper exposure level, the acute exposure exceeds the level of concern, with a hazard quotient of 15. As with the worker exposures, one reason for this high hazard quotient is the additional 10X safety factor due to toxicity database gaps that is used to derive the RfD. As stated, where the acute human exposures exceed about 1 mg/kg/day, potential sub-clinical effects could be seen. Based on the exposure value in Appendix F (Table F3-5c), the upper range acute exposure does not exceed this level. The chronic consumption of unwashed berries after application of the highest dose yields a hazard quotient that is substantially greater than unity. At the highest application rate of 2.0 lbs/acre, the estimated dose would be about 0.08 mg/kg/day. This value is in the range of which no chronic effects should be seen. This scenario may be considered conservative in that it does not consider the effects of washing contaminated vegetation, but again, it points out that oral exposures are of greater concern than dermal exposures. It also points out the importance of notifying the public of areas to be treated so that the collection of food products or basketry materials can be avoided

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For Dicamba, at the upper exposure levels, both the acute and chronic exposures slightly exceed the level of concern, with hazard quotients ranging from 1.2 to 4. Again, it is uncertain from the toxicology studies whether such acute exposures would result in any overt effects to adults. For the chronic exposure, the estimated dose would be about 0.05 mg/kg/day. Similar to the worker exposures, it is unclear from the toxicity tests that form the basis of the RfD, if overt effects would be likely. This dose is 833 times lower than the 45 mg/kg/day rat NOAEL on which the current RfD is based. For nonylphenol polyethoxylate, the consumption of contaminated vegetation represents a risk of clinical effects at the high application rates only (HQ = 4). This exposure could present risks of nausea and vomiting from the ingestion of sprayed fruit.

Public Exposure from Drinking Contaminated Water (Acute and Chronic) Table 3-36 displays the hazard quotient values from the contaminated water scenarios involving public consumption. These scenarios involving a child drinking from a pond immediately after a spill or from a stream after a drift event, and an adult drinking water from the same contaminated pond over a lifetime are arbitrary scenarios. Scenarios that are more or less severe, all of which may be equally probable or improbable, easily could be constructed. However, these scenarios indicate that a spill of herbicide into a water body is something to be strongly avoided. Prevention strategies are displayed in Appendix A. Another aspect to the pond water contamination scenario is that it represents standing water, with no dilution or decomposition of the herbicide. This is unlikely in a forested situation where flowing streams are more likely to be contaminated in a spill, rather than a standing pond of water. For the acute stream contamination scenario where a child drinks from a contaminated stream, 2, 4-D just reaches a hazard quotient of 1 for the upper application rate; none of the other herbicides or nonylphenol polyethoxylates or the impurity hexachlorobenzene exceeds a value of one. For the scenario in which the adult drinks contaminated water over a lifetime, none of the hazard quotient values, for any of the herbicides, nonylphenol polyethoxylates, or the impurity hexachloro-benzene, at any application rate, exceeds a value of one. In addition, the cancer risk in the chronic scenario from hexachlorobenzene in Clopyralid is at least 5 orders of magnitude below the risk standard of 1 chance in 1 million for all exposure scenarios.

Table 3 - 36. Hazard Quotient (Non-Cancer) for the Public – Drinking Contaminated Water from Herbicides, Nonylphenol Polyethoxylate, and the Hexachlorobenzene Impurity

Acute-spill Acute-stream Chronic-spill Herbicide Typical Upper Typical Upper Typical Upper rate rate rate rate rate rate Chlorsulfuron 0.05 0.1 0.001 0.006 0.00004 0.0001 Clopyralid 0.09 0.2 0.0005 0.003 0.0003 0.0007 2, 4-D 6 15 0.3 1 0.02 0.05 Dicamba 3 10 0.002 0.02 0.000006 0.00005 Glyphosate 0.3 0.9 0.002 0.08 0.00004 0.0005 Triclopyr TEA 0.3 0.8 0.007 0.07 0.02 0.05 Triclopyr BEE 0.3 0.8 0.007 0.07 0.02 0.05 Nonylphenol Polyethoxylate 5 7 0.009 0.04 0.002 0.005 Hexachlorobenzene 0.00002 0.00004 5 E-7 0.000003 1 E-8 3 E-8

The acute exposure scenario with the child drinking water from a pond shows that chlorsulfuron, Clopyralid, Glyphosate, Triclopyr, and the impurity hexachlorobenzene have hazard quotient

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values at or below 1 for all application rates. 2, 4-D, Dicamba, and nonylphenol ethoxylate show hazard quotient values greater than 1 for typical and high application levels. For 2, 4-D, where the hazard quotient ranges from 6 to 15, the doses associated with these typical application rates ranges from 0.41 to 1.0 mg/kg per incident. Assuming that new studies don’t change the current hazard discussions, levels of acute exposures from 0.1 to 1 mg/kg/day should not result in any adverse health effects. With Dicamba, the hazard quotient slightly exceeds the level of concern (HQ = 3) at the typical exposure rate. As stated above for workers, it is uncertain from the toxicology studies whether such an acute exposure would result in any overt effects. At the upper exposure level, the consumption of contaminated water by a child exceeds the level of concern by an order of magnitude (HQ = 10). This level of exposure (approximately 1 mg/kg/day) may result in sub- clinical effects to a child, although the toxicity data do not clearly point to this conclusion. The acute RfD is based on a single-dose neurotoxicity study in rabbits with an implied NOAEL of 30 mg/kg/day. Based on this study, there is a chance for some neurological effects to a child exposed at the upper application rates from drinking water after a spill. For NPE, the spill scenario represents the greatest risk, with a hazard quotient of 5 for the typical application rate, and a hazard quotient exceeding unity even with the lowest application rates. An HQ of 5 represents a risk of sub-clinical effects to the liver and kidney. The upper hazard quotient of 7 represents an increasing risk of clinical effects to the kidney, liver, and other organ systems.

Public Exposures from Consumption of Fish (Acute and Chronic) Like the drinking water scenarios, the scenarios involving consumption of fish taken from contaminated waters are arbitrary scenarios. Scenarios that are more or less severe, all of which may be equally probable or improbable, easily could be constructed. Tables 3-37 and 3-38 display the hazard quotient values for these scenarios. For the chronic exposure scenarios, where recreational or subsistence adults consume fish for a lifetime, none of the hazard quotient values exceeds 1. In addition, the cancer risk in these chronic scenarios from hexachlorobenzene in Clopyralid is at least 2 orders of magnitude below the risk standard of 1 chance in 1 million for all exposure scenarios.

Table 3 - 37. Hazard Quotient (Non-Cancer) for the Public – Consumption of Contaminated Fish, Acute Exposure, as a Result of Using Herbicides, Nonylphenol Polyethoxylate, and Products Containing the Hexachlorobenzene Impurity

Recreational Subsistence Herbicide Typical rate Upper rate Typical rate Upper rate Chlorsulfuron 0.002 0.003 0.008 0.01 Clopyralid 0.003 0.003 0.01 0.02 2, 4-D 7 12 36 60 Dicamba 0.05 0.1 0.3 0.7 Glyphosate 0.004 0.007 0.02 0.04 Triclopyr TEA 0.0005 0.0009 0.002 0.004 Triclopyr BEE 0.0005 0.0009 0.002 0.004 Nonylphenol Polyethoxylate 0.1 0.1 0.7 0.7 Hexachlorobenzene 0.001 0.002 0.006 0.008

The acute scenarios show that all but 2, 4-D have hazard quotient values below 1 for all application rates and for recreational and subsistence populations. For 2, 4-D, where the hazard quotient ranges from 7 to 60, the acute doses associated with these application rates ranges from

Chapter 3—Affected Environment & Environmental Consequences 179 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

0.49 to 4.0 mg/kg per incident. Assuming that new studies don’t change the current hazard discussions, levels of acute exposures from 1 to 10 mg/kg/day could result in prenatal effects, possible neurological effects, and body weight loss. These scenarios point out that spill prevention and the prevention of water contamination is a critical aspect of 2, 4-D use (refer to Best Management Practices descriptions in Appendix D).

Table 3 - 38. Hazard Quotient (Non-Cancer) for the Public – Consumption of Contaminated Fish, Chronic Exposure, as a Result of Using Herbicides, Nonylphenol Polyethoxylate, and Products Containing the Hexachlorobenzene Impurity

Recreational Subsistence Herbicide Typical rate Upper rate Typical rate Upper rate Chlorsulfuron 3 E-7 6 E-7 0.000002 0.000005 Clopyralid 0.000002 0.000003 0.00001 0.00003 2, 4-D 0.003 0.009 0.03 0.07 Dicamba 2 E-8 1 E-7 2 E-7 0.000001 Glyphosate 7 E-8 8 E-7 5 E-7 0.000007 Triclopyr TEA 0.000005 0.00001 0.00004 0.0001 Triclopyr BEE 0.000005 0.00001 0.00004 0.0001 Nonylphenol Polyethoxylate 0.00001 0.00002 0.00008 0.0002 Hexachlorobenzene 0.000001 0.000002 0.000009 0.00002

Synergistic Effects Synergistic effects are those effects resulting from exposure to a combination of two or more chemicals that are greater than the sum of the effects of each chemical alone (additive). Refer to USDA, 1989 (pages 4-111 to 4-114) for a detailed discussion on synergistic effects. Instances of chemical combinations that cause synergistic effects are relatively rare at environmental exposure levels. Review of the scientific literature on toxicological effects and toxicological interactions of agricultural chemicals indicate that exposure to a mixture of pesticides is more likely to lead to additive rather than synergistic effects (Kociba and Mullison 1985; Crouch et al. 1983; U.S. EPA 1986, all as referenced in Appendix F). In U.S. EPA (1986), the assumption of dose or response addition of the individual components is recommended in the absence of toxicity data on the mixture of the components, if the toxic response of the components is the same. Synergism has rarely been observed in toxicological tests involving combinations of these herbicides with other commercial pesticides. The herbicide mixtures that could possibly occur on this project have not shown synergistic effects in humans who have used them extensively in forestry and other agricultural applications. However, synergistic toxic effects of herbicide combinations, combinations of the herbicides with other pesticides such as insecticides or fertilizers, or combinations with naturally occurring chemicals in the environment are not normally studied. Based on the limited data available on pesticide combinations involving these herbicides, it is possible, but unlikely, that synergistic effects could occur as a result of exposure to the herbicides considered in this analysis. However, even if synergistic or additive effects were to occur as a result of a proposed treatment, these effects are dose dependent (Dost 1991, as referenced in Appendix F). This means that exposures to the herbicide plus any other chemical must be significant for these types of effects to be of a biological consequence. Based on the very low exposure rates estimated for the Alternatives analyzed in this FEIS, any synergistic or additive effects, if any, are expected to be insignificant. The combination of surfactant and herbicide might indicate an increased rate of absorption through the skin; however, a review of recent studies indicates this is not often true (USDA,

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2002, as referenced in Appendix F). For a surfactant to increase the absorption of another compound, the surfactant must affect the upper layer of the skin. Without some physical effect to the skin, there would be no change in absorption as compared to the other compound alone. The studies (USDA 2002, as referenced in Appendix F) indicate that in general non-ionic surfactants have less of an effect on the skin, and hence absorption, then anionic or cationic surfactants. Compound specific studies indicate that the alkylphenol ethoxylates generally have little or no effect on absorption of other compounds. In several studies, the addition of a surfactant actually decreased the absorption through the skin. It would appear that there is little support for the contention that the addition of surfactants to herbicide mixtures would increase the absorption through the skin of these herbicides. Several of the six herbicides considered in this risk assessment can be combined with other herbicides to increase the range of effective control. Although combining any of these six herbicides with any other herbicide is not anticipated nor proposed under Alternatives 2 or 4, it is important to consider whether any of the six have shown synergistic effects when combined with other compounds. Studies of these six herbicides in combination with other compounds are not common, as toxicology studies generally involve the active ingredient. So to the extent that any studies exist, they are important to consider for their insight into potential impacts of combinations. In addition, in Alternative 6, there are two mixtures proposed to be used (Dicamba plus 2, 4-D and chlorsulfuron plus 2, 4-D. Using current guidance on analyzing mixtures (refer to Appendix F), it is apparent that mixtures containing 2, 4-D will represent some degree of risk represented by 2, 4-D itself (several scenarios with HQ values > 1). None of the acute scenarios involving workers should represent a risk of additive effects when these two mixtures (2, 4-D plus chlorsulfuron and 2, 4-D plus Dicamba) are considered. Central estimates for chlorsulfuron result in HQ values less than 0.1, even at the highest application rate of 0.0625 pounds/acre, which would indicate that a mixture of 2, 4-D and chlorsulfuron should represent health risks that should focus on 2, 4-D itself, and not on the mixture. However, since several of the Dicamba HQ values also exceed 0.1 at the upper mixture rate of 1 lb ae/acre, there could be additive effects associated with this mixture (although, as stated below, there is some evidence that such interactions may not occur, as the mode of toxic action may be dissimilar between Dicamba and 2, 4-D). These additive effects of Dicamba and 2, 4-D would be more likely in public acute exposures and chronic worker exposures and would be unlikely in chronic public exposures or acute worker exposures. The manufacturers recommend that chlorsulfuron formulations be mixed with a non-ionic surfactant. There is no published literature or information in the US EPA files that would permit an assessment of toxicological effects or risk assessment of chlorsulfuron mixed with a surfactant. According to the product label, the Telar formulation of chlorsulfuron may be applied in combination with other herbicides, such as 2, 4-D, Dicamba, or Glyphosate. However, there are no animal data to assess whether chlorsulfuron will interact, either synergistically or antagonistically with 2, 4-D or any other herbicide. Clopyralid may be applied in combination with other herbicides. There are no data in the literature suggesting that Clopyralid will interact, either synergistically or antagonistically with this or other compounds. A commercial formulation of picloram and 2, 4-D, Tordon 202C, has been shown to inhibit immune response in mice (SERA 1999c, as referenced in Appendix F). While the design of this study does not permit the determination of which agent caused the immune response, this observation is relevant to some Forest Service activities because, picloram is often applied with 2, 4-D (although the use of picloram is not proposed under this FEIS, as it is not registered in California).

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There is no substantial evidence that Dicamba will interact with other compounds. A study by Moody et al. (1991, as referenced in Appendix F) indicates that Dicamba does not induce cytochrome P-450 activity and does not substantially affect a variety of other xenobiotic metabolizing enzymes. Although this finding does not rule out the possibility that Dicamba may be involved in toxicologically significant interactions, the induction of cytochrome P-450 is a major mechanism by which such interactions are known to occur. There is very little information available on the interaction of Glyphosate with other compounds. The available data do not suggest a synergistic interaction between Glyphosate and the ethoxylated tallow amine (POEA) surfactant used in several formulations of Glyphosate from plausible routes of exposure (SERA 1996a, as referenced in Appendix G). There is very little information available on the interaction of Triclopyr with other compounds. The available data do not suggest a synergistic interaction between the Triclopyr active ingredient and the other components in the commercial Triclopyr formulations of Garlon 3A or Garlon 4 (SERA 1996b, as referenced in Appendix F).

Sensitive Individuals The uncertainty factors used in the development of the RfD takes into account much of the variation in human response. The uncertainty factor of 10 for sensitive subgroups is sufficient to ensure that most people would experience no toxic effects. “Sensitive” individuals are those that might respond to a lower dose than average, which includes women and children. As stated in National Academy of Sciences (NAS), 1993 (as referenced in Appendix F), the quantitative differences in toxicity between children and adults are usually less than a factor of approximately 10-fold. An uncertainty factor of 10 for sensitive subgroups may not cover all individuals that may be sensitive to herbicides because human susceptibility to toxic substances can vary by two to three orders of magnitude. Factors affecting individual susceptibility include diet, age, heredity, pre-existing diseases, and life style. Individual susceptibility to the herbicides proposed in this project cannot be specifically predicted. Unusually sensitive individuals may experience effects even when the HQ is equal to or less than 1. There is no information to suggest that specific groups or individuals may be especially sensitive to the systemic effects of chlorsulfuron. Due to the lack of data in humans, the likely critical effect of chlorsulfuron in humans cannot be identified clearly. In animals the most sensitive effect of chlorsulfuron appears to be weight loss. There is also some evidence that chlorsulfuron may affect the circulatory system. However, it is unclear if individuals with pre-existing diseases of the circulatory system or metabolic disorders would be particularly sensitive to chlorsulfuron exposure. Individuals with any severe disease condition could be considered more sensitive to many toxic agents. The 1996 Food Quality Protection Act requires that U.S. EPA evaluate an additional 10X safety factor, based on data uncertainty or risks to certain age/sex groupings. U.S. EPA has evaluated chlorsulfuron against this standard and has recommended a 3X additional safety factor be used for the protection of infants and children. This additional 3X safety factor is factored into the acute and chronic RfD’s of this risk assessment as it applies to chlorsulfuron. There is no information to suggest that specific groups or individuals may be especially sensitive to the systemic effects of Clopyralid (SERA, 1999a, as referenced in Appendix F). The likely critical effect of Clopyralid in humans cannot be identified clearly. Clopyralid can cause changes in organ and body weight, deceased red blood cell counts, as well as changes to the intestinal walls. These effects, however, are not consistent among species or even between different studies in the same species. Thus, it is unclear if individuals with pre-existing diseases of the kidney, liver, or blood would be particularly sensitive to Clopyralid exposures, although individuals with any severe disease condition could be considered more sensitive to many toxic agents.

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There is anecdotal information (case histories) suggesting that some individuals may be sensitive to 2, 4-D. These individuals may develop impaired nerve function after exposure to 2, 4-D at levels that are not expected to cause adverse health effects in the general population. The effects reported in the case studies are debilitating, and recovery may be prolonged and incomplete. On the other hand, the case studies do not rule out the possibility that the neuropathy was caused by other unidentified agents. The medicine probenecid enhances the acute toxicity of 2, 4-D and 2,4,5-T to rats. Thus, individuals taking probenecid may be more sensitive than others to the acute toxicity of 2, 4-D. Laboratory studies demonstrate that there is substantial variation among individual animals within a species in their response to 2, 4-D. Also, there is evidence of human variability regarding dermal absorption rates. Individuals who absorb 2, 4-D more rapidly or eliminate the compound more slowly are likely to be more sensitive than others to 2, 4-D exposure. The only identified sensitive subgroup for Dicamba appears to be children. Since the RfD for Dicamba explicitly considers the increased sensitivity of children with an additional safety factor and since exposure assessments for children are conducted in the risk assessment, this sensitive subgroup is addressed in the current risk assessment. No reports were encountered in the Glyphosate literature leading to the identification of sensitive subgroups. There is no indication that Glyphosate causes sensitization or allergic responses, which does not eliminate the possibility that some individuals might be sensitive to Glyphosate as well as many other chemicals (SERA 2003a, as referenced in Appendix G). Because Triclopyr may impair blood filtration, individuals with pre-existing kidney diseases are likely to be at increased risk (SERA, 1996b, as referenced in Appendix F). Because the chronic RfD for Triclopyr is based on reproductive effects, women of child-bearing age are an obvious group at increased risk (SERA 2003b as referenced in Appendix F). This group is given explicit consideration and is central to the risk characterization. NP9E can cause increases in kidney and liver weight, and effects to kidney function and structure. Thus, individuals with pre-existing conditions that involve impairments of the kidney or liver may be more sensitive to this compound. There is some indication that sensitive individuals may develop contact allergies. People with a history of skin allergic reactions to soaps and detergents may be especially sensitive to dermal exposures of NP9E-based surfactants. The potential of NP9E to induce reproductive effects should be considered low. Based on the available dose/duration/severity data, it appears that exposure levels below those associated with the most sensitive effect (i.e., kidney effects) are not likely to be associated with reproductive toxicity. However, as shown in the exposure scenarios, there is the potential for acute exposures to be in the range (considering a 100X safety factor) where effects to the developing fetus may occur, therefore women of child-bearing age could be considered a sensitive population.

Cumulative Effects of Human Health and Safety and the Risks Associated with Herbicide Use for Noxious Weed Treatments The proposed use of herbicides could result in cumulative doses of herbicides to workers or the general public. Cumulative doses to the same herbicide result from (1) additive doses via various routes of exposure resulting from the management scenarios presented in Alternatives 2, 4, and 6, and (2) additive doses if an individual is exposed to other herbicide treatments. Additional sources of exposure include: use of herbicides on adjacent private timberlands or home use by a worker or member of the general public. Using Forest Service and State of California pesticide-use records (from 2002 and 2003); Table F5-11 in Appendix F displays the use of herbicides on public and private timberlands, rangelands, and road rights-of-ways (the

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latter assumed to be primarily for noxious weed work) within the four-counties that make up the Modoc National Forest area (Lassen, Modoc, Shasta, and Siskiyou Counties). This four county area would likely encompass the area where workers would be living while participating in this project. It is conceivable that workers or members of the public could be exposed to herbicides as a result of treatments on surrounding public or private forestlands or from fire restoration efforts on National Forest System lands. Where individuals could be exposed by more than one route, the risk of such cases can be quantitatively characterized by simply adding the hazard quotients for each exposure scenario. For example, using Glyphosate as an example, the typical levels of exposure for a woman being directly sprayed on the lower legs, staying in contact with contaminated vegetation, eating contaminated fruit, and consuming contaminated fish leads to a combined hazard quotient of 0.03. Similarly, for all of the chronic Glyphosate exposure scenarios, the addition of all possible pathways lead to hazard quotients that are substantially less than one. Similar scenarios can be developed with the other herbicides. This risk assessment specifically considers the effect of repeated exposure in that the chronic RfD is used as an index of acceptable exposure. Consequently, repeated exposure to levels below the toxic threshold should not be associated with cumulative toxic effects. Since these herbicides persist in the environment for a relatively short time (generally less than 1 year), do not bio-accumulate, and are rapidly eliminated from the body, additive doses from re- treatments in subsequent years are not anticipated. According to recent work completed by the California Department of Pesticide Regulation, some plant material contained Triclopyr residues up to 1.5 years after treatment (Glyphosate, up to 66 weeks), however, these levels were less than 1 part per million (Segawa et al. 2001 as referenced in Appendix F). Based on the re-treatment schedule in Alternatives 2, 4, and 6, it is possible that residues from the initial herbicide application could still be detectable during subsequent re-treatments, but these plants would represent a low risk to humans as they would show obvious signs of herbicide effects as so would be undesirable for collection. Table F5-11 in Appendix F indicates that several of these herbicides are used primarily outside of forestlands in the four county area. In order to consider the cumulative effects of these other uses, U.S. EPA has developed the theoretical maximum residue contribution (TMRC). The TMRC is an estimate of maximum daily exposure to chemical residues that a member of the general public could be exposed to from all published and pending uses of a pesticide on a food crop (Table F5- 13 in Appendix F). Adding the TMRC to this project’s chronic dose estimates can be used as an estimate of the cumulative effects of this project with theoretical background exposure levels of these herbicides. The result of doing this doesn’t change the risk conclusions based on the project-related HQ values. Cumulative effects can be caused by different chemicals with a common metabolite or a common toxic action. With the exception of Triclopyr and chlorpyrifos discussed below, none of the other herbicides have been demonstrated to share a common metabolite with other pesticides. As shown in the analysis below, the use of Triclopyr in this project does not represent an unacceptable risk to human health due to its environmental metabolite. The primary metabolite of Triclopyr is 3,5,6-trichloro-2-pyridinol, referred to as TCP. TCP is also the primary metabolite of an insecticide called chlorpyrifos. U.S. EPA (1998, 2002a both as referenced in Appendix F) considered exposures to TCP from both Triclopyr and chlorpyrifos in their general dietary and drinking water exposure assessments. The toxicity of TCP is similar to Triclopyr. In the RfD on Triclopyr, the provisional chronic RfD for TCP is 0.03 mg/kg/day, about the same as the 0.05 mg/kg/day for Triclopyr. For acute exposures in this risk assessment, the corresponding values are 1 mg/kg/day for Triclopyr and 0.25 mg/kg/day for TCP. The U.S. EPA

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estimated dietary exposures at the upper 99.5% level for a young woman – i.e., the most sensitive population in terms of potential reproductive effects, the endpoint of greatest concern for Triclopyr. The upper range of acute exposure to Triclopyr was estimated at 0.012 mg/kg/day and the upper range of exposure to chlorpyrifos was estimated at 0.016 mg/kg/day. Thus, making the assumption that both Triclopyr and chlorpyrifos are totally converted to TCP, the total exposure is about 0.028 mg/kg/day, a factor of 8.9 below the level of concern. For chronic exposures, the U.S. EPA based the risk assessment on infants – i.e., individuals at the start of a lifetime exposure. The dietary analysis indicated that the total exposure expressed as a fraction of the RfD was 0.044 for TCP from Triclopyr and 0.091 for TCP from chlorpyrifos for a total of 0.135 or a factor of about 7.4 below the level of concern [1÷0.135 = 7.4]. Based on this assessment, the U.S. EPA (1998) concluded that ...the existing uses of Triclopyr and chlorpyrifos are unlikely to result in acute or chronic dietary risks from TCP. Based on limited available data and modeling estimates, with less certainty, the Agency concludes that existing uses of Triclopyr and chlorpyrifos are unlikely to result in acute or chronic drinking water risks from TCP. Acute and chronic aggregate risks of concern are also unlikely to result from existing uses of Triclopyr and chlorpyrifos. This conclusion, however, is based primarily on the agricultural uses of Triclopyr – i.e., estimated dietary residues – and does not specifically address potential exposures from forestry applications. In forestry applications, the primary concern would be the formation of TCP as a soil metabolite. TCP is more persistent than Triclopyr in soil and TCP is relatively mobile in soil (U.S. EPA 1998) and could contaminate bodies of water near the site of application. In order to assess the potential risks of TCP formed from the use of Triclopyr, the TCP metabolite was modeled in the SERA risk assessment (SERA 2003b) along with Triclopyr. The results for TCP are summarized in SERA (2003b). While Triclopyr and chlorpyrifos would not be commonly applied together in forestry applications, at least one formulation of chlorpyrifos, Nufos 4E, is labeled for forestry applications and may be applied at a rate of 1 lb/acre for the control of insect pests in tree nurseries and plantations. In order to assess potential exposures to TCP from the application of both Triclopyr and chlorpyrifos at the same site, GLEAMS was used to model the application of chlorpyrifos at 1 lb per acre under the same conditions used for Triclopyr (SERA 2003b). As modeled, concentrations of TCP in a small stream could reach up to 11 ppb from the use of Triclopyr at a rate of 1 lb/acre and up to 68 ppb in a small stream from the use of Triclopyr at a rate of 1 lb/acre and chlorpyrifos at a rate of 1 lb/acre. The current RfD for TCP used by U.S. EPA (2002a) is 0.012 mg/kg/day for chronic exposure and 0.025 mg/kg/day for acute exposure. The child is the most exposed individual, consuming 1L of water per day at a body weight of 10 kg. Thus, based on the chronic RfD of 0.012 mg/kg/day, the associated concentration in water would be equivalent to 120 ppb. Since the peak exposure to TCP in water (68 ppb) is below the concentration associated with the chronic RfD, there is no basis for asserting that the use of Triclopyr with or without the use of chlorpyrifos will result in hazardous exposures of humans to TCP. Recent studies have shown drift of chlorpyrifos, and other insecticides, from agricultural lands in the Sacramento/San Joaquin Valley to the Sierra Nevada range (McConnell et al. 1998). In the four-county Modoc National Forest area, chlorpyrifos use in 2002 totaled 5,800 pounds, primarily used in alfalfa, onion, mint, and walnut orchards in the agricultural valleys. Levels of chlorpyrifos have been measured in watercourses in the Sierra Nevada as high as 13 ng/L (equivalent to 0.013 ppb). These upper levels have been measured in the southern Sierra. As a comparison, the use of chlorpyrifos in Fresno County was over 40 times higher in 2002 then the four Modoc National

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Forest counties combined. This would indicate that it is unlikely that such high aquatic levels of chlorpyrifos would be found in the Modoc National Forest area as a result of atmospheric movement. Assuming that 100% of measured chlorpyrifos would degrade to TCP (an over- exaggeration of the rate of degradation), this would add 0.013 ppb of TCP. If this amount is added to the modeled peak exposure of 68 ppb, it would not result in any appreciable increase in risk. Estrogenic effects (a common toxic action and a form of endocrine disruption) can be caused by additive amounts of nonylphenol (NP), nonylphenol polyethoxylate (NPE), and their breakdown products. In other words, an effect could arise from the additive dose of a number of different xenoestrogens (estrogens from outside the body), none of which individually have high enough concentrations to cause effects. This can also extend out to other xenoestrogens that biologically react the same. Additive effects, rather than synergistic effects, are expected from combinations of these various estrogenic substances. When assessing cumulative effects of exposure to NP and NPE, there must be some consideration of the contribution from other sources, such as personal care products (skin moisturizers, makeup, deodorants, perfumes, spermicides), detergents and soaps, foods, and from the environment away from the forest herbicide application site. In addition to xenoestrogens, humans are exposed to various phytoestrogens, which are hormone-mimicking substances naturally present in plants. In all, more than 300 species of plants in more than 16 families are known to contain estrogenic substances, including beets, soybeans, rye grass, wheat, alfalfa, clover, apples, and cherries. Adding together the contributions from the worst-case background environment and consumer products, as described in the Risk Assessment, there would be a background dose to a female worker of 27.034 mg/kg/day (assuming 100% dermal absorption) or 0.304 mg/kg/day (assuming 1% dermal absorption. Using the derived NP human NOEL of 0.10 mg/kg/day, these exposure estimates result in hazard quotients of 270 and 3. In terms of the risk assessment, the non-acute contribution of NPE (backpack workers exposure ranged from 0.000075 to 1.01 mg/kg/day) would contribute up to 10 to any hazard quotient; at typical application rates, the worker exposure would add 0.1 to the HQ. For the public chronic exposures at the upper range of application, the doses of NPE would add 0.00002 to 0.2 to any HQ. These may be negligible depending upon the background exposures, lifestyles, absorption rates, and other potential chemical exposures that are used to determine overall risk to environmental xenoestrogens.

Opposing Viewpoints Concerning the Use of Herbicides Some people have expressed concern regarding the use of herbicides in an integrated pest management program even though available studies and evidence suggests minimal or no potential negative impacts on wildlife, the environment or on humans. Chief concerns include: synergistic reactions, bio-accumulation, persistence in environment, low dose impact, migration through the environment, and lack of data and transferability of knowledge. These concerns generally arise out of the uncertainty and lack of trust in the studies and state and federal certification processes. The Human Health Risks section of this chapter presents information and discussion on these subjects as they relate to human health. However, that discussion applies generally to wildlife, particularly since toxicity testing is carried out on laboratory animals and not on human subjects. The problem of utilizing herbicides in an integrated weed management system was described by a research student as the “impossibility of determining a concise answer between those who see herbicides as a necessary tool and those who see it as a poison with no middle ground or room for compromise.”

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Noxious Weeds Thirty-two different noxious weeds are believed to be present in Modoc County, and are possibly occurring on the Modoc National Forest. Below are 14 noxious weed species listed with “proposed to be treated” in the right column. These species could be eradicated and/or controlled within the boundaries of the Modoc National Forest. The other species not identified for treatment are not known to occur on the Forest, or occur at rates that are currently beyond control within the Modoc National Forest.

Table 3 - 39. Weeds of Modoc County7

“A” Rated Common Crupina Crupina vulgaris Proposed to be treated Dalmatian toadflax Linaria dalmatica Proposed to be treated Diffuse knapweed Centaurea diffusa Proposed to be treated Halogeton Halogeton glomeratus Not known to occur on the Modoc NF Leafy spurge Euphorbia esula Not known to occur on the Modoc NF Longleaf ground cherry Physalis longifolia Not known to occur on the Modoc NF Musk thistle Carduus nutans Proposed to be treated Perennial sowthistle Sonchus arvensis Not known to occur on the Modoc NF Plumeless thistle Carduus acanthoides Proposed to be treated Scotch thistle Onopordum acanthium Proposed to be treated Skeletonweed Chondrilla juncea Not known to occur on the Modoc NF Spotted knapweed Centaurea stoebe ssp. micranthos Proposed to be treated Squarrose knapweed Centaurea squarrosa Proposed to be treated Yellowspine thistle Cirsium ochrocentrum Not known to occur on the Modoc NF “B” Rated Austrian fieldcress Rorippa austriaca Not known to occur on the Modoc NF Canada thistle Cirsium arvense Proposed to be treated Dyer's woad Isatis tinctoria Proposed to be treated Globepodded hoarycress Cardaria pubescens Recently detected on the Modoc NF Heart-podded hoarycress Cardaria draba Not known to occur on the Modoc NF Japanese knotweed Polygonum cuspidatum Not known to occur on the Modoc NF Mediterranean sage Salvia aethiopis Proposed to be treated Purple loosestrife Lythrum salicaria Not known to occur on the Modoc NF Quackgrass Agropyron repens Not known to occur on the Modoc NF Russian knapweed Acroptilon repens Recently detected on the Modoc NF Tall whitetop Lepidium latifolium Proposed to be treated “C”Rated Common Russian thistle Salsola tragus Occur at rates beyond control Field bindweed Convolvulus arvensis Occur at rates beyond control Klamathweed Hypericum perforatum Proposed to be treated Medusahead Taeniatherum caput-medusae Occur at rates beyond control Povertyweed Iva axillaris Occur at rates beyond control Puncturevine Tribulus terrestris Not known to occur on the Modoc NF Yellow starthistle Centaurea solstitialis Proposed to be treated See Page for definition of State of California Weed Rating System Past Noxious Weed Treatments Hand-pulling and grubbing efforts on the Forest and County over the past several years have proven ineffective in reducing populations or providing lasting control of target weed

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infestations. Efforts have resulted in some success preventing individual Spotted knapweed from producing seeds during the treatment year (Modoc County 2000-2002).

Table 3 - 40. Previous Treatment of Invasive Species Through Use of Physical + Methods

Pest Mechanism Scope of program gypsy moth 75 traps placed throughout None Detected county Scotch thistle Herbicide & Physical + Over 500 Locations Use of herbicides to control weeds during the last 11 years on the Forest and adjacent lands has shown to be the most effective method at suppressing infestations and eradicating new populations. Although eradication of all weeds is not feasible Plateau-wide, isolated infestations have been treated with consistently moderate to high success.

Table 3 - 41. Previous Treatment of Noxious Weeds on the Modoc NF Through Use of Herbicides

Pest Control agent Scope of program Scotch thistle Herbicide & Physical + Over 500 Locations Knapweeds Herbicide 25 Locations Leafy spurge Herbicide 2 Locations Yellow starthistle Herbicide 25 Locations Yellowspine thistle Herbicide 3 Locations Dalmatian toadflax Herbicide 15 Locations Musk thistle Herbicide 2 Locations Crupina Herbicide 1 Location Russian knapweed Herbicide 4 Locations Perennial pepperweed Herbicide 12 Locations In addition to treatment of noxious weeds, pesticides are used on private lands, including privately owned commercial timberlands, ranch and farmlands, home sites, utility corridors, county and state roadways, and businesses. Much of the use of herbicides such as Glyphosate (Roundup) is sold over the counter for home and private use, and cumulative totals for the area are not available. According to reports filed by the Modoc County Agricultural Commissioner, an average of approximately 200,000 pounds of herbicides (approximately 140 different herbicides) have been utilized in Modoc County, primarily on agriculture crops on private land adjacent to Federal Lands) on an annual basis for over ten years (Department of Pesticide Regulation, 1991- 2002 Annual Pesticide Use Reports, Indexed by Herbicide – Modoc County). Public comments on the DEIS requested additional analysis of noxious weed treatment methods and less or no reliance on herbicides to control noxious weeds, clarify priority for treatment, and/or extensive analysis of each specific noxious weed and treatment methods. Some wanted less aggressive approaches to noxious weed treatment and others wanted more aggressive treatments. Some wanted more site specific information about each noxious weed-infested site. Throughout the effects analysis, when specific sites where treatment may have an effect on a resource are discussed by site number, Volume 4, Map Book displays the location and approximate size of each inventoried noxious weed site and specific treatments of those sites is found in Appendix B. Chapter 2 of this FEIS displays the decision tree and criteria that are to be utilized in determining site specific treatment methods, as well as resource protection measures. The effects discussion below is summarized from the Noxious Weed Risk Assessment and NWRA Addendum for the Modoc National Forest Noxious Weed Treatment Project, and from the Design standard, Description of Alternatives, Appendix G: Weed Species Information and

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Specialist Reports located in the project record. The Response to Comments Volume contains detailed responses to the above concerns. The Appendix Volume and Response to Comments Volume are incorporated into this section of the analysis.

Direct and Indirect Effects Alternative 1 (no action): Under the No Action Alternative, it is expected that all noxious weeds would continue to regenerate and spread within the Modoc National Forest. New noxious weeds could invade the Forest. As weeds increase, there would be a corresponding increase in weed propagules, such as seeds and rhizomes, that could continue to spread the infestations. Alternative 2 would allow for an aggressive noxious weed control program. Reductions in occurrences of the treated weeds and in size of the occurrences would be expected. Since new weeds and new or expanding occurrences would not be treated, the overall area occupied by noxious weeds on the Forest may actually be able to increase. Production of weed propagules would be reduced on the sites treated, although there still would be viable noxious weed seed in the seed bank on termination of this 5-year program, as many weed seeds remain viable for many years – up to 30 years for Scotch thistle. Removal of noxious weeds at treated sites could enhance the native communities, making them more resistant to weed invasion, which in turn would reduce the potential available habitat for weed invasion. Alternative 3 would result in the reduction of some noxious weeds. However, only non- rhizomatous weeds would be treated, and, therefore, the rhizomatous species would continue to grow - possibly expanding in occurrence size - and produce propagules that could spread those weeds. Non-rhizomatous weeds would not be adding new propagules to the soil. However, the seed bank would not be treated, and the potential for this seed bank to regenerate weeds would be high, as ground generally would be disturbed during physical treatments, providing habitat for invasive plants. No Early Detection - Rapid Response would be included in this Alternative, and therefore new sites, expanded sites, or new noxious weeds would not be treated, allowing for untreated expanding noxious weed infestation. Alternative 4 provides for aggressive treatment of noxious weeds, utilizing a wide range of treatment methods. All known noxious weed infestations, including rhizomatous species, would be treated by herbicide or physical methods. This Alternative would be in effect for 10 years, instead of the 5 years of Alternatives 2 and 3, and, therefore, the chances for complete removal of occurrences of noxious weeds would be greater, especially for smaller infestations. Early Detection - Rapid Response would allow treatment of the same weeds with the same treatments on new sites or sites that have expanded, which would provide more effective treatment and could result in the complete removal of many sites of the 14 known noxious weeds. However, Early Detection - Rapid Response would not address new noxious weeds, and therefore, these new species would be able to expand in size or occurrence number without treatment. Alternative 5 would result in the reduction of some noxious weeds. However, two large infestations – one of dyer’s woad and one of common crupina – would not be treated. Even with treatment on the periphery to keep it from expanding, the main infested acres of these two large sites would most likely increase in weed density, continuing to weaken native communities within the infestation, which would most likely allow further degradation by weeds due to the reduced competition. Only small infestations of non-rhizomatous weeds would be treated, and, therefore, the larger occurrences of rhizomatous species would continue to grow - possibly expanding in occurrence size - and produce propagules that could spread those weeds. Rhizomatous noxious weeds that have not been eliminated completely would be expected to re- infest areas, and possibly come back in denser stands. Physical+ treatments have been found to stimulate the roots of rhizomatous species, and even the small occurrences treated in this

Chapter 3—Affected Environment & Environmental Consequences 189 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Alternative, unless treated persistently over a long time, may not effectively control or eliminate these species. Clipping of seed heads would remove current year’s seed, but not remove plants, nor address the seedbed already created. Persistent use of weed-eaters may reduce populations of noxious weeds. However, some plants, such as yellow starthistle, adapt to the removal of tops, and begin to flower and fruit extremely close to the ground. Mulching and tarping may reduce or eliminate a few small occurrences of weeds, but this method would be very limited, and use on rhizomatous species may not be effective, as extensive rhizomes with their stored carbohydrates may grow toward the light and the untarped/unmulched edge. New sites and expanded sites and new noxious weeds can be treated in this Alternative through Early Detection - Rapid Response. This would eliminate any increase in infested acres from new information. Because new infestations are usually small, Physical+ treatment should be effective. The success of treatment of noxious weeds by goat grazing would be limited due to the size of areas to be treated (>4 acres and <25 acres). This method would need to be followed up with continued treatment to address plants that come up from the seed bank. Alternative 6: Due to the number of weed control techniques available under Alternative 6, it is expected to provide for the most variable and aggressive treatment and control of noxious weeds on those acres treated. However, the treated acres would be much less than in Alternatives 2 and 4. The ~ 6000-acre dyer’s woad site and the large common crupina site would only be treated on the parameter to reduce expansion of the site. The noxious weeds at these sites would continue to compete with natives, reducing native plant vitality. This, in turn, could allow the noxious weeds to aggressively increase the density of noxious weeds. These acreages would remain a large source for noxious weed seed. On the sites where treatment would take place, however, it is expected that noxious weed populations would be greatly reduced; some species could be contained, controlled, or eradicated over the life of the project. Physical + treatment of weeds would remove noxious weeds where treatment can occur, but has the potential to increase noxious weed infestation by disturbing the soil and providing ideal conditions for the germination of the weed seed in the soil. New sites, expanded sites and new noxious weeds can be treated in this Alternative, and therefore these new occurrences most likely would be controlled or eliminated. However, new satellite sites around the occurrences not to be treated could become a constant battle, and some new sites could escape detection and spread weed seed over a wide area before inventory reveals them. Unless good annual inventories are performed, satellite occurrences could get out of hand. Please see the discussion under Alternative 5 for effects from physical + treatments. As under Alternative 2, herbicide exposure levels for both the public and for workers executing treatment activities would not exceed acceptable levels of risk to human health for all herbicides proposed for use (Bakke 2005). The use of proper personal safety equipment, training, and supervision for all weed-treatment crews would be required to reduce the potential for injuries to workers.

Cumulative Effects Past, present, and reasonably foreseeable future actions that disturbed, are disturbing, or would disturb ground or weaken native plant communities provide potential habitat for noxious weeds. Previously approved physical + weed treatment programs, grazing activities on Forest allotments, timber management and fuel reduction, pile burning, railroad construction, road construction and maintenance, recreation such as OHV (off-highway vehicles) and foot or horse traffic, firewood gathering, dam construction and repair, goose nesting island construction, excavation of burrow

190 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

material, and stock pond construction all create disturbed ground, providing additional disturbed areas where noxious weeds can gain a foothold. In the long-term, this would lead to increased area and increased infestations occupied by known and new noxious weeds on the Forest, and possibly on other lands in Modoc County. Gains of past weed treatments may be lost in a few years of unchecked weed seed production. Alternative 1 – No Action: This Alternative would result in no control, containment, or eradication of known noxious weeds. Prevention and education should help prevent new weeds from invading, but would not treat them if they are found. Alternative 2 – Proposed Action: Herbicide treatment of noxious weeds would kill weeds without disturbing the soil. Weeds treated effectively in this manner for 5 years would remove that infestation from the Forest as long as viable propagules do not remain. Physical treatment of noxious weeds could create more disturbed ground, which is prime habitat for aggressive noxious weeds. Unless this treatment is continued to outlast the seed bank and desirable species seed in naturally or from cultural treatments, these areas could become dense weed patches upon termination of the project. Weed seed banks would not be treated, and these may be a continuing source of noxious weeds. Based on longevity of project, number of sites to be treated, treatments proposed, seed or rhizome longevity, size and number of occurrences, and Design Standard, known weeds and sites that might be eradicated include diffuse knapweed, plumeless thistle, and squarrose knapweed. Weeds that might be controlled or contained are yellow starthistle and tall whitetop. New weeds or sites would not be controlled. Alternative 3: Physical treatment of noxious weeds could create more disturbed ground that is prime habitat for aggressive noxious weeds. Unless this treatment is continued to outlast the seed bank and desirable species seed in naturally or from cultural treatments, these areas could become dense weed patches upon termination of the project. Rhizomatous noxious weeds would continue to grow and occurrences may increase in size. New sites and expanded sites may continue to grow unimpeded, and new noxious weeds that invade would be allowed to grow and infest the Forest. Weed seed banks would not be treated, and these may be a continuing source of noxious weeds. Based on longevity and of project, number of sites to be treated, and treatments proposed, seed or rhizome longevity, size and number of occurrences, and Design Standard, known weeds and sites that might be eradicated include diffuse knapweed, plumeless thistle, and squarrose knapweed. Weeds that might be controlled or contained are yellow starthistle and possibly tall whitetop. New weeds or sites would not be controlled. Alternative 4: Rhizomatous noxious weed infestations would diminish across the Forest unless the infestation is near a sensitive area where herbicides (or herbicides that are effective for the particular noxious weed) cannot be used (see Design Standards). Glyphosate is not the most effective and efficient chemical for some rhizomatous weeds. Only the largest occurrences of rhizomatous species may still have plants at the end of 10 years. Due to the aggressive noxious weed treatment, overall noxious weed infestations would diminish across the Forest. Physical treatment of noxious weeds could create more disturbed ground -- prime habitat for aggressive noxious weeds. Unless this treatment is continued to outlast the seed bank and desirable species seed in naturally or from cultural treatments, these areas could become dense weed patches upon termination of the project in 10 years. Weed seed banks would not be treated, and these may be a continuing source of noxious weeds. Also, please see Cumulative Effects under Alternative 1. Based on longevity of project, number of sites to be treated, and treatments proposed, seed or rhizome longevity, size and number of occurrences, and Design Standard, weeds that might be eradicated include diffuse knapweed,

Chapter 3—Affected Environment & Environmental Consequences 191 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

plumeless thistle, spotted knapweed, and squarrose knapweed. Weeds that might be controlled or contained are yellow starthistle, Canada thistle, common crupina, Dalmatian toadflax, Klamathweed, and tall whitetop. New weeds would not be controlled. Alternative 5: The large untreated sites could become a source of many new satellite sites if careful, annual inventory is not performed. Physical + treatment of noxious weeds could create more disturbed ground that is prime habitat for aggressive noxious weeds. Unless this treatment is continued to outlast the seed bank and desirable species seed in naturally or from cultural treatments, these areas could become dense weed patches upon termination of the project. Untreated rhizomatous noxious weeds would continue to grow and occurrences may increase in size. New sites and expanded sites and new noxious weeds can be treated in this Alternative, and therefore these new occurrences most likely would be controlled or eliminated since they most likely would be small. Weed seed banks would not be treated, and these may be a continuing source of noxious weeds. Also, please see Cumulative Effects under Alternative 1. Based on longevity of project and number of sites treated, and treatments proposed, seed or rhizome longevity, size and number of occurrences, and Design Standard, weeds that might be eradicated include diffuse knapweed, plumeless thistle, squarrose knapweed, spotted knapweed, tall whitetop and yellow starthistle. Weeds that might be controlled or contained are Klamathweed, musk thistle, Canada thistle, Dalmatian toadflax, Mediterranean sage, and common crupina. New species and new sites could be controlled. Alternative 6: The large untreated sites could become a source of many, new satellite sites if careful, annual inventory is not performed. Weed seed banks would not be treated, and these may be a continuing source of noxious weeds, especially where Physical + treatments create disturbance. Scotch thistle seeds can live in the soil for up to 30 years. Also, please see Cumulative Effects under Alternative 1. Based on longevity of project and number of sites treated, and treatments proposed, seed or rhizome longevity, size and number of occurrences, Design Standard, and priority of treatment by Modoc County, weeds that might be eradicated include diffuse knapweed, plumeless thistle, squarrose knapweed, spotted knapweed, tall whitetop, yellow starthistle, Canada thistle, and Dalmatian toadflax. Weeds that might be controlled or contained are Klamathweed, musk thistle, Mediterranean sage, and common crupina. New species and new sites would be controlled.

Consistency with Forest Plans and Other Laws and Policies The Proposed Action and Alternatives (except for Alternative 1, the no-action Alternative) are consistent with these directions and goals. Similarly, the Proposed Action and Alternatives are consistent with Executive Order 13112, section 2, (a), (2), (ii), which states, "Each Federal agency whose actions may affect the status of invasive species shall, to the extent practicable and permitted by law, detect and respond rapidly to and control populations of [invasive] species in a cost-effective and environmentally sound manner." The Federal Noxious Weed Act of 1974 directs us to "complete and implement cooperative agreements with State agencies regarding the management of undesirable plant species on Federal lands under the agency's jurisdiction; and establish integrated management systems to control or contain undesirable plant species targeted under cooperative agreements (7 U.S.C. 2814 (a (3, 4)))," with which law the Proposed Action and Alternatives are also consistent. Noxious weeds also imperil Threatened and Sensitive species plants and habitats with encroachment, competition, changes in fire regimes, and other threats; therefore, the Proposed Action and Alternatives are also consistent with Forest direction in conservation of Threatened and Sensitive plant species (q.v. Modoc NF Forest Plan, 4-21).

192 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Because noxious weeds threaten native plant and plant community diversity, the Proposed Action and Alternatives are consistent with the Forest goals to provide plant diversity for scenic quality, wildlife use, and other resource objectives (Modoc NF Forest Plan, 4-2). Executive Order 13112, section 2, (a), (2), (iv), directs us also to "provide for restoration of native species and habitat conditions in ecosystems that have been invaded." Rangelands The rangeland management program on the Modoc National Forest provides up to 122,500 animal unit months of forage annually for livestock grazing. The Forest is divided into 84 grazing allotments. About 110 term permittees depend on using the allotments to graze their livestock, primarily from late spring to early fall (May-Sept.). To achieve vegetation management objectives through livestock grazing the Forest Service develops and implements allotment management plans (AMPs). The Modoc National Forest also supplies forage for wild horses on the Devils Garden Wild Horse Territory of the Devils Garden Ranger District. The planned management level is 285 to 325 animals. Current populations are estimated at approximately 550 head. Approximately 910,000 acres (56 %) of the Forest is managed under rangeland prescriptions (Rangeland Management Prescription – 10 and Rangeland Management with Forage Improvement (Range-Forage) Management Prescription -11 of the Modoc NF Forest Plan), of which 90 % is suitable for grazing. The 10 % deemed unsuitable for grazing is due to steep slopes, inaccessible dense timber, and/or lack of forage. An additional 200,000 acres of timberland provide long-term forage production due to open canopies. Noxious weed populations have been identified on 51 of the 84 grazing allotments on the Modoc National Forest. Program Objectives and Program Standards and Guidelines for rangeland management can be found in the Forest Plan. Public comments on the DEIS requested the end of grazing, as many believe this is the primary vector for noxious weed spread, or they say the Proposed Action is a means to increasing grazing rather than improving natural plant health and diversity. Others wanted to see increased grazing to control noxious weeds. The effects of noxious weed treatment on the grazing program are summarized below. The elimination of grazing, because some see it as a major vector of noxious weed spread, is outside the scope of this analysis. This analysis does display that the major vector for noxious weed spread is roads, not domestic grazing. The Alternatives display the effects of limited grazing to control noxious weeds. The Purpose and Need for the FEIS is to implement a program to control, contain, and/or eradicate species weed sites. (Chapter 1 of the FEIS). The treatment of noxious weeds would meet the need and requirement of the Forest to promote ecosystem health of forested and rangeland habitats by maintaining or improving native forbs and grass species, ultimately preventing the loss of wildlife habitat. Other resources, such as recreation and range, may also benefit from controlling weeds, insofar as all of the weeds the Forest is planning to treat are generally unpalatable to livestock. The effects section below indicates that grazing may be reduced in the short term to enhance the effects of noxious weed treatments proposed. Commodity use of rangelands could not be increased above current permitted levels without additional environmental analysis and public participation.

Chapter 3—Affected Environment & Environmental Consequences 193 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Direct and Indirect Effects Under the No Action Alternative, it is anticipated weeds would continue to spread within NFS lands. As noxious weeds increase, they impact the livestock industry by lowering yield and quality of forage, interfering with grazing, and increasing costs of managing and producing livestock (DiTomaso, 1999). In the long-term, a reduction in forage quality and quantity could lead to downward adjustments in the allowable use made by livestock and to wild horses inhabiting the Devils Garden Herd Territory. Alternative 2 would allow for a large scale program of noxious weed control (99 % of infested acreage), utilizing a combination of physical and herbicide treatments. Under this Alternative, nine acres of rhizomatous species, within ten feet of water would not be treated. This Alternative would result in positive impacts to the upland native plant communities, including desirable forage species available to livestock and wild horses. Carrying capacities would be maintained in these upland habitats. Noxious weeds would continue spreading in riparian habitats, and in the long term available forage in these habitats would decrease. The positive benefits of Alternative 2 would be experienced somewhat slower than for Alternative 4, due to the reduced acres receiving treatment each year. All herbicide treatments would consist of directed spray to noxious weeds which are generally unpalatable to livestock, thereby limiting their consumption of treated forage. Also, because a maximum of four tenths of one % of the NFS lands in the project area would receive herbicide treatments during the five year implementation period, the chances of livestock consuming the quantity of treated forage necessary to cause adverse animal health effects would be very remote. Depending on the type of herbicide used, there may be some deferment of grazing required, as specified by label directions. This is normally a short period (days) and generally livestock operations can be easily adjusted to accommodate such restrictions. Alternative 3 would have beneficial impacts to the rangeland resource, as there would also be large- scale noxious weed control implemented (87 % of the infested acreage), through physical methods. However, there are 47 sites (916 acres) of rhizomatous weed species that would not receive treatment, due to the ineffectiveness of physical methods for control of these species. These species would continue expanding, and, in the long term, the quantity of forage for livestock and wild horses would likely be reduced. Alternative 4 allows for the large-scale treatment of noxious weed infestations (99 % of the infested acres), utilizing physical , cultural and herbicide treatments. There would be no treatment of 5 sites (9 acres) that consist of rhizomatous species, within 10 feet of water. This Alternative also includes an Early Detection- Rapid Response strategy to allow treatment of up to 200 acres of new infestations during the ten year implementation period. Due to the large-scale treatment of noxious weeds, and the variety of treatment methods that could be implemented, Alternative 4 would provide the most beneficial impact to the upland rangeland resource, including improved forage quality and quantity for livestock and wild horses. Rhizomatous species would continue to expand in riparian habitats resulting in the decreased condition and forage quantity in these habitats. As with Alternative 2, the probability of livestock consuming vegetation treated with an herbicide in amounts that would have animal health effects is extremely low, because noxious weeds are generally unpalatable and a maximum of less than five tenths of one % of the NFS lands in the project area would be treated with herbicides over the 10-year implementation period. Again, there may be short-term deferment in livestock use, depending on which herbicide is used. This would be based on label instructions for the specific herbicide and is normally a short time

194 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

(days). This would be handled on a case-by-case basis, either through modification in pasture rotation, or deferment in treated pastures or allotments. Alternative 5 allows for active treatment of only 7 % of the known acres of noxious weed infestations, including up to 200 acres (100 acres annually) treated under the Early Detection – Rapid Response strategy over the 10-year implementation period. Additionally, nine sites would receive limited treatments along the borders to contain infestations. This Alternative would implement non-herbicide treatments, including cultural, goat grazing, physical and physical + methods. As with Alternative 3, implementation of this Alternative would have beneficial impacts to the rangeland resource, as there would be some noxious weed control implemented. However, rhizomatous species would continue to expand, which would have negative impacts on upland and riparian habitats. In the long term, livestock carrying capacities would likely decline, leading to possible reductions in allowable use by livestock and wild horses. The treatment of noxious weeds by goat grazing would have negligible impacts to livestock operations due to the limited size of areas to be treated (5 sites/41 acres), and the short period of time such treatments would occur. All goat grazing treatments would be carefully monitored to ensure that weed treatment objectives are met without damaging the range resource through overgrazing. Alternative 6 would provide for the active treatment of 541 acres, 7 % of the known infestation acres, using the widest range of treatment techniques, consisting of physical, physical +, goat grazing, cultural methods, and herbicides including two tank mixes. Under this Alternative, the Early Detection/Rapid Response strategy would allow the treatment of 200 acres (100 acres annually) over the 10-year implementation period. Due to the number of weed control techniques available under Alternative 6, this Alternative would be expected to provide the most control of invasive species on those acres treated. In the long term, outside those areas having a containment objective, it is expected that noxious weed populations would be greatly reduced, and in many cases, eradicated. It is expected that forage species would have less competition for available water and nutrients, leading to a stabilized grazing capacity for livestock and wild horses. The positive effects of this Alternative would be less than Alternative 2 and 4, based on the limited treatment acreage. If herbicides are used, there would be a very remote chance that livestock would consume enough treated forage to cause effects to animal health, as noxious weeds are generally unpalatable and only a maximum of less than one tenth of one % of NFS lands in the project area would be treated with herbicides during the 10-year implementation period. Again, there may be short- term deferment in livestock use, depending on which herbicide is used. This would be based on label instructions for the specific herbicide and is normally a short time (days). This would be handled on a case-by-case basis, either through modification in pasture rotation, or deferment in treated pastures or allotments. As with the other Alternatives calling for cultural treatments (seeding), areas that are re-seeded would require rest for two to four years to allow new plants to become established. This might require a change in pasture rotation, complete rest of the allotment(s) or structural improvements such as fencing to facilitate the necessary rest. If livestock must be removed completely from an allotment, there would be negative economic impacts to the grazing permittee(s) if they must purchase Alternative forage sources for their livestock. The treatment of noxious weeds by goat grazing would have the same negligible impacts to livestock operations as described in Alternative 5. Cumulative Effects

Chapter 3—Affected Environment & Environmental Consequences 195 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Due to the small proportion of the NFS lands that are treated under any of the Alternatives, and through implementation of the Design Standards, there would be no cumulative impacts to the rangeland resource. There may have to be adjustments in the livestock season of use, use areas and, perhaps in some cases, temporary closure of pastures or allotments to facilitate the effectiveness of weed treatments and/or cultural treatments. This would be coordinated with the affected grazing permittees on a site specific basis and incorporated into Annual Operating Instructions as necessary. Consistency with Forest Plans and Other Laws and Policies The Forest Plan calls for the rangelands and riparian areas to be managed in satisfactory ecological condition and maintain range resource productivity. Allotments are to be managed to protect soil, water, and streamside-dependent resources. The Modoc NF Forest Plan contains the following Standards and Guidelines:  "Mange allotments to protect soil, water, and streamside-dependent resources" (p. 4-19)  "Manage livestock and wild horses to maintain range resource productivity" (p. 4-19)  "Manage grazing to maintain desired vegetation expressions and satisfactory ecological condition” (pp. 4-94, 4-100)  " Manage riparian areas to achieve satisfactory ecological condition and desired vegetation expressions...... " (pp. 4-95, 4-101) The No Action Alternative would be the least consistent with Forest Plan Standards. With little or no treatment of noxious weeds, infestations would continue to expand, displacing native vegetation and contributing to unsatisfactory ecological conditions, and decreased productivity of the range resource. Based on the treatment of noxious weeds in Alternatives 2, 4, and 6, it is expected that ecological conditions would be maintained or improved, with a corresponding maintenance or improvement in range resource productivity. These Alternatives would be consistent with Forest Plan Standards. Alternatives 3 and 5 would also allow for improvement of rangeland conditions, except for those areas with noxious weeds that do not respond to non-herbicide treatments. Therefore, these Alternatives would also be consistent with Forest Plan Standards, but to a lesser degree. Other Actions The 1995 Rescission Act (PL 104, Section 504a) requires that the Forest Service schedule and complete environmental analyses for the renewal of term grazing permits. As part of the analyses, the Forest Service is completing Noxious Weed Assessments. The Noxious Weed Assessments describe the risks associated with implementing the various Alternatives, and provides recommendations on how those risks can be minimized. These recommendations may include adjusting the season of use, excluding grazing from certain areas, prohibitions of off road use by vehicles, or the washing of vehicles used in the management of livestock. Measures to minimize the spread of noxious weeds and to maximize control measures would be considered during the development of site-specific environmental analysis for the renewal of grazing permits. Recreation The Modoc National Forest is best known for its remote location and secluded recreation opportunities. Most visitors enjoy sightseeing, picnicking, camping, fishing, hiking, horseback

196 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

riding, and hunting. Some of these activities may occur on sites where noxious weed control activities are planned. Under all Alternatives, previous biocontrol releases outside the Forest may eventually make their way into the recreation, wilderness, or inventoried roadless areas of the forest as long as their habitat (noxious weeds) exists. Recreation occurs on nearly all areas of the Forest. The patterns of recreation use are relatively stable, with summer as the busiest season. Recreational uses support a tourist-based economic segment. Typical summer activities include biking, camping, fishing in the mountain lakes and streams, horse packing and horseback riding, rock climbing, berry picking, sightseeing, and scouting for fall hunting trips. During the fall, fishing and hunting activities increase substantially. In the spring, use increases with antler hunting, camping, photography, hiking in the lower elevations, and mushroom picking. Winter use is lower, with a small number visiting for backcountry skiing, snowshoeing, and snowmobiling. At this time of year, opportunities for solitude and outdoor recreational challenges are the greatest. Winter recreation activities would not be affected by noxious weed treatments nor would noxious weed treatments affect winter use of the Forest. Recreational users, private landowners, and others use the Forest road and trail system for access to backcountry areas and the South Warner Wilderness. Forest personnel use roads and trails for fire control, special-use administration, facility access, resource monitoring, and general patrolling of the area. Most trail users travel by foot or pack and saddle stock. Total recreation use on the Modoc National Forest as measured and reported in the National Recreation Visitors Survey was rated nearly the lowest of all Forest Service units, with a yearly recreation of 500,000 (plus or minus 25 %) visitor days. Use is generally confined to developed recreation sites, lakes, in areas where roads are adjacent to or near streams or lakes, and the South Warner Wilderness. Hunting is the major dispersed recreation use. There are no noxious weeds within a developed recreation facility. The five weed occurrences below occur within 1/8th of a mile of the identified campground.

Table 3 - 42. Noxious Weed Infestations within 1/8 Mile of a Campground

Population Campground Weed ID Number Ranger District Acres Size Ash Creek Scotch Thistle BV219ONAC 3 Big Valley 0.1 Reservoir F Canada Thistle DG004CIAR4 20 Devil’s Garden 0.1 Pepperdine Canada Thistle WM001CIAR4 >1000 Warner Mountain 0.1 Stough Scotch Thistle WM002ONAC unknown Warner Mountain 0.1 Stough Canada Thistle WM006CIAR4 10 Warner Mountain 0.1 Public comments received on the DEIS showed concern for herbicide treatments within heavily utilized recreation activities, and requested that Best Management Practices (BMPs) for recreation areas should be included in the FEIS. The effects analysis below, in conjunction with the effects analysis section on human health, explains the potential effects of the Alternatives on recreation users. Best management Practices are specifically designed for forest management activities to meet the intent of the Clean Water Act. The established regional BMPs related to recreation are specifically designed to mitigate the effects recreational sites and activities have on water quality.

Chapter 3—Affected Environment & Environmental Consequences 197 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Direct and Indirect Effects Noxious weeds can affect the recreation experience. Invading weeds such as spotted knapweed, Scotch thistle, and yellow starthistle can detract from the desirability of using recreation sites and enjoyment of the wilderness. These species can diminish the usefulness of sites because the stiff plant stalks, thorns, or sharp bristles can discourage or prevent walking, sitting, or setting up a camp. Noxious weeds can also detract from the recreation experiences by reducing the variety and amount of native flora to observe or study, and reducing forage available for wildlife and recreational livestock. Noxious weed infestations do not directly impact recreation sites on the Modoc National Forest, and the degree of indirect impacts is minimal since only five weed infestations are located within one-eighth of a mile of a developed recreation facility. Direct and indirect effects of all action Alternatives include the cost of removal and disposal of dug, pulled, or clipped plants to insure they do not re-sprout or detract from the visual or recreational activities. The use of wheeled vehicles to transport hand-treatment crews and equipment, remove dug or clipped plants, or to apply herbicide would result in short-term visual impacts in the form of tracks created by laying down grasses. In dry years, these tracks could remain visible throughout the season, while in wetter years they could be erased by rains and re- growth before fall. Long-term improvements as a result of all action Alternatives include an overall reduction of stiff plant stalks and sharp bristles, and increase in the variety and amount of native flora. Treating noxious weeds would be an improvement in the overall recreational environment, including the desirability and enjoyment of recreational sites, although in Alternatives 5 and 6 not all areas would benefit. Alternative 1 (No Action) – Under the No Action Alternative, spread of noxious weeds could result in the unavoidable deterioration of the natural condition of adjoining land, diminishing the recreational experience for some people. The negative effects noxious weeds would have on use of dispersed recreation sites would be greatest under the no action Alternative. Alternatives 3 and 5 – Direct and indirect effects on recreation resulting from implementation would include short-term (one to several days) encounters with treatment crews and visual impacts from pulled plants or digging. Additional effects resulting from Alternatives involving digging or pulling include disturbed soil that could increase sediment for brief periods, discoloring surface water and detracting from the recreation experience. Disturbed soil could also increase the noxious weed cover by providing better growing conditions for the prodigious seed- producing weed species, further reducing recreation opportunities listed above. Alternatives 2, 4 and 6 – Direct and indirect effects on recreation resulting from implementation would include short-term (one to several days) encounters with herbicide treatment crews and visual impacts from wilting plants. The visual impacts of spraying would be temporary, and on most sites only last a few hours or less. Dying and wilting plants following herbicide treatment could be apparent. However, this appearance would be short-lived as surrounding vegetation would screen dead plants or blend with native vegetation, as it grew dormant. Additional effects resulting from Alternatives would be the protection of adjacent non-infested areas and preservation of intact plant communities, which would enhance the recreation experience. Concern over the herbicides may cause some Forest users to choose to recreate in areas that have not been recently treated with herbicides. All weed-treatment activities would be conducted in compliance with Modoc National Forest Travel Plan, which allows for administrative use. Visual impacts of spraying would be temporary, and on most sites only last a few days or less. Odors emitted by herbicides may cause anxiety in persons unaware of their presence. Herbicides

198 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

proposed for use on this Project would not affect grasses or sedges at recommended application rates. Early Detection - Rapid Response treatments under Alternatives 4, 5 and 6 would have the same direct and indirect effects as mentioned above.

Cumulative Effects When any of the Proposed Actions is added to all the other forest management activities (grazing, vegetation management, timber operations, fuels reduction, prescribed fire, wildlife habitat improvement) recreation visitors would not experience a noticeable or measurable change in their experience, because the areas to be treated are so small and dispersed most visitors would be oblivious to the Proposed Actions and treatments. Without treatment, thistle sites could become large and extensive near recreation trails or campgrounds, or wildfire may introduce large infestations of thistles near popular areas, impairing visitor enjoyment as they and their pets and livestock experience painful encounters with the thistles. All management activities adjacent to recreation areas and recreation-area improvement projects include noxious weed inventory and treatment of sites found during implementation of the project, which would require noxious weed treatment and prevention measures that would not be noticeable to visitors since they would be part of each individual action.

Consistency with Forest Plans and Other Laws and Policies Alternative 1 is not consistent with Modoc NF Forest Plan direction, as the spread of noxious weeds has the potential to limit recreational opportunities on the Forest as visitors to the Forest may choose to avoid areas infested with noxious weeds. All action Alternatives are consistent with the Modoc NF Forest Plan, and would not result in a decrease in recreational opportunities on the Forest. Special Designated Areas Special designated areas on the Modoc National Forest include Inventoried Roadless Areas (IRAs), Research Natural Areas (RNA’s), Special Interest Areas (SIAs), the South Warner Wilderness Area (SWW), and a Wild and Scenic River Study Area (WSR). Under the Forest Plan, these areas are to be managed for the natural and scenic values. One commenter on the DEIS suggested there was no Wild and Scenic River Assessment. The Modoc NF does not contain a designated Wild and Scenic River, nor have noxious weeds been identified in potential Wild and Scenic Rivers. The analysis below shows possible effects on proposed Wild and Scenic Rivers would be the same as the effects disclosed for Wilderness Areas. One commenter on the DEIS suggested the need for additional Wilderness Areas. This is outside the scope of this analysis. No comments were received concerning Research Natural Areas. Inventoried Roadless Areas In 2001, The Forest Service established a rule to protect the social and ecological values and characteristics of inventoried roadless areas from road construction and reconstruction, and certain timber harvesting activities to protect the following values or features at a national level:

Chapter 3—Affected Environment & Environmental Consequences 199 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

 High quality or undisturbed soil, water, and air.  Sources of public drinking water.  Diversity of plant and animal communities.  Habitat for threatened, endangered, proposed, candidate, and sensitive species; and for those species dependent on large, undisturbed areas of land.  Primitive, semi-primitive non-motorized, and semi-primitive motorized classes of dispersed recreation.  Reference landscapes.  Natural appearing landscapes with high scenic quality.  Traditional cultural properties and sacred sites.  Other locally identified unique characteristics. The Modoc National Forest has 19 inventoried roadless areas, covering approximately 201,600 acres. Seven of these are infested with noxious weeds which occur on 20 individual sites totaling 3,564.2 acres. The largest is the 5,657.8-acre dyer’s woad site, with 3,554.1 acres within the Damon Butte Inventoried Roadless Area, which has over 50 miles of identified roads. The remaining sites all occur along roads that either surround or traverse the inventoried roadless areas.

Table 3 - 43. Inventoried Roadless Areas Containing Noxious Weed Infestation Sites

ALT ALT ALT ALT ALT Roadless Name Site ID No. 2 3 4 5 6 Acres Area Scotch Thistle DG044ONAC P P P P+ P+ 0.1 Big Canyon Scotch Thistle DG045ONAC P P P P+ P+ 0.1 Big Canyon Scotch Thistle DG062ONAC P P P P+ P+ 0.1 Big Canyon Scotch Thistle DG061ONAC P P P P+ P+ 0.1 Big Canyon Scotch Thistle WM016ONAC P P P P+ P+ 0.1 Crane Mtn. Scotch Thistle WM045ONAC P P P P+ P+ 0.1 Crane Mtn. Dalmatian Toadflax DH005LIDA H NT H LT H 0.1 Damon Butte Dyer’s Woad DH016ISTI P P P P+ P+ 0.1 Damon Butte Dyer’s Woad DH013ISTI P/H P P/H LT LT 3,554.1 Damon Butte Scotch Thistle DH039ONAC P P P P+ P+ 0.1 Damon Butte Scotch Thistle BV156ONAC P P P P+ P+ 0.1 Knox Mtn. Dyer’s Woad WM011ISTI P/H P P/H P+ H 0.7 Mt. Vida Dyer’s Woad WM009ISTI P/H P P/H P+ H 1.2 Mt. Vida Dyer’s Woad WM018ISTI P/H P P/H P+ H 1.1 Mt. Vida Dyer’s Woad WM015ISTI P/H P P/H P+ H 1.0 Mt. Vida Dalmatian Toadflax WM010LIDA P/H NT P/H NT H 3.0 Mt. Vida Dalmatian Toadflax WM008LIDA P/H NT P/H NT H 3.4 Mt. Vida Scotch Thistle BV285ONAC P P P P+ P+ 0.1 Sears Flat Scotch Thistle BV157ONAC P P P P+ P+ 0.1 Sears Flat Scotch Thistle WM022ONAC P P P P+ P+ 0.1 Soldier Treatment codes: P = Physical, P+ = Physical+, H = Herbicide, P/H = Physical and/or Herbicide, LT = Limited Treatment, and NT = No Treatment. The treatment methods are as proposed in chapter 2 for each type of treatment.

200 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

No comments were received concerning treatment of noxious weeds within inventoried roadless areas.

Direct and Indirect Effects The direct and indirect effects on the characteristics of solitude, primitive recreation, and natural integrity that lead to designation as an IRA are described in the recreation section, and are not repeated here. Treatment of noxious weeds within inventoried roadless areas would decrease the feeling of solitude during periods of treatment as crews treat the infestations. The sights and sounds of vehicles and the noise of crews would be short lived. Alternative 1 (No Action) – Not treating noxious weeds would increase the loss of the following values and characteristics outlined in the Roadless Rule of 2001: diversity of plant and animal communities; habitat for threatened, endangered, proposed, candidate, and sensitive species and for those species dependent on large, reference landscapes; and natural-appearing landscapes. Alternatives 2 and 4 – In addition to the effects outlined above in the recreation section, Alternatives 2 and 4 are the only Alternatives that would treat all existing sites within Inventoried Roadless Areas, thus restoring the values and characteristics for which the areas were established, by eradicating or controlling all infestations within inventoried roadless areas. However, since Alternative 2 does not have an Early Detection - Rapid Response component progress in eradication and control of noxious weeds would not be permanent. Alternatives 2 and 4 treat the total 3,564.2 acres of noxious weeds within inventoried roadless areas. Alternative 3 – Has similar effects as Alternative 2 except that infestations of dalmatian toadflax, a rhizomatous species, would not be treated, resulting in further decline in the Mt. Vida and Damon Butte Inventoried Roadless Areas. Alternative 3 treats less than 3.7 acres of inventoried roadless areas. Alternative 5 – Would not treat the Dalmatian toadflax sites in the Damon Butte and Mt. Vida areas, and would only treat the perimeter of the dyer’s woad site, thus allowing the infestations to continue to degrade the roadless area characteristics and values. Alternative 3 treats less than 3.7 acres of inventoried roadless areas. Alternative 6 – Alternative 6 would eradicate all the small infestations currently within inventoried roadless areas, thus protecting the values and characteristics of the sites. The Early Detection - Rapid Response component would provide for additional protection of the areas, but would be limited to by the cap on acres that could be treated. The dyer’s woad infestation in the Damon Butte area would be part of a containment option, which would continue the degradation of the values and characteristics noted under Alternative 1. Alternative 6 would treat approximately 10 acres of inventoried roadless area.

Cumulative Effects The sights and sounds of dead or dying noxious weeds would not significantly have cumulative effects when added to those of the ongoing permitted management activities of grazing, infrequent road use, and dispersed recreation.

Irreversible and Irretrievable Commitment of Resources Under the No Action Alternative, an irreversible loss of natural integrity and apparent naturalness would occur once weeds become well established in an IRA, since eradication would probably never occur.

Chapter 3—Affected Environment & Environmental Consequences 201 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Consistency with Forest Plans and Other Laws and Policies All action Alternatives are consist with Forest Plan direction and current policy and direction provided by Interim Directive #1920-2006-1 concerning management of inventoried roadless areas. Wilderness The South Warner Wilderness encompasses approximately 70,385 acres of undeveloped land found within the Warner Mountain Ranger District. It contains rugged topography, expansive vistas, rolling hills, mountain meadows, clear streams, and the highest peaks in northeastern California. Historic noxious weed locations inside the South Warner Wilderness include Emerson Lake and Kaiser Canyon, and adjacent to the Wilderness at Pepperdine and Granger Canyon. Few surveys for noxious weeds have occurred in the Wilderness; actual sites are probably higher than what this document reflects. Public comments on the DEIS concerning Wilderness included a request to expand wilderness designations on the Forest. These comments are outside the scope of this analysis because this document analyzes noxious weeds, not wilderness suitability. Treatment of noxious weeds sites found within the designated South Warner Wilderness will be accomplished using only hand treatment. Herbicides and mechanical means will not be utilized under decisions made as a result of this analysis. If herbicides or mechanical treatments are required in the future, new analysis and decision will be necessary. This meets key criteria for defining Wilderness.

Direct and Indirect Effects Under all Alternatives, the South Warner Wilderness (SWW) will continue to remain an area of undeveloped land, sufficient in size to preserve it in an unimpaired condition. Wilderness management will continue to emphasize natural conditions, and the landscape will remain primarily affected by the forces of nature. There are no hand treatment actions within any of the Alternatives that would affect the overall scenic attributes of the SWW. However, allowing infestations to grow unchecked could alter the natural landscape and degrade wilderness values. Some visitors may find the flowers of noxious weeds attractive. Education, scientific and conservation purposes for Wilderness will not be affected by any of the Alternatives. Opportunities to study and learn about wilderness systems that are ecosystem in size will continue to be a unique opportunity within the SWW. Recreation experiences on the SWW will be the same as those described above under the recreation discussion. Alternatives 1, 2 and 3 would not treat new infestations of noxious weeds under an Early Detection - Rapid Response method, thus providing for the loss of wilderness characteristics as noxious weeds replace native species. Wilderness users would avoid areas of thistle infestations and may lead to creation of unwanted trails or campsites that cause erosion. Only Alternatives 4, 5, and 6 provide for an early detection rapid response that would allow for eradication of new infestations and protection of wilderness characteristics.

202 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Cumulative Effects The impact of crews treating noxious weeds by hand would be similar to those of hikers or trail maintenance crews. The added noise and sight of treatment crews, when added to the permitted recreation and grazing use, would be of short duration and would not permanently alter wilderness characteristics. Those individuals seeking solitude would be impacted only during the treatment period.

Irreversible and Irretrievable Commitment of Resources Only the No Action Alternative has an irreversible loss of natural integrity, and loss of apparent naturalness would occur once weeds become well established in the wilderness area since eradication would probably never occur.

Consistency with Forest Plans and Other Laws and Policies All action Alternatives are consistent with management direction found in the Forest Plan and the Wilderness Act. All action Alternatives are consistent with Forest Service Manual (FSM) 2323.26b, which allows plant control for “noxious farm weeds by grubbing or with herbicides when they threaten lands outside wilderness or when they are spreading within the wilderness, provided that it is possible to effect control without causing serious adverse impacts on wilderness values.” All action Alternatives are consistent with the 1964 Wilderness Act, which requires managers of wilderness with the responsibility of maintaining the enduring resource of wilderness. The Act specifically requires that a Wilderness Area be managed to "preserve its natural conditions" and "to assure that an increasing population, accompanied by expanded settlement and growing modernization does not occupy and modify all areas within the United States." Research Natural Areas (RNA) and Special-Interest Areas (SIA) These areas were established for the purpose of maintaining biological diversity, conducting non- manipulative research and monitoring, and fostering education. Research Natural Areas are typical and distinctive natural ecosystems and habitats that are generally retained in an unmodified condition. Noxious weeds need to be eliminated if they were to become established in these areas, since they are not natural to the ecosystem. The Modoc National Forest has two Research Natural Areas. The 800-acre Research Natural Area known as Devil's Garden RNA, located on the Devil's Garden Ranger District, was chosen as a representation of western juniper stand in the Modoc Plateau Physiographic Province. The 6,287-acre Raider Creek RNA in the South Warner Wilderness was designated as a representation of the white fir type. At this time, there are no known noxious weed locations within the Research Natural Areas, but an intensive search has not been conducted because of limited accessibility. Special Interest Areas were developed because of their unusual scenic, historic, cultural, and geological values. The three Special Interest Areas (Burnt Lava Flow, Glass Mountain Lava Flow, and Medicine Lake Lava Flow Geologic Areas) are unlikely to be adversely affected by noxious weeds due to their geologic makeup and lack of soil.

Direct and Indirect Effects In the event a new infestation of the existing species or a new species infestation occurred in one of these areas, it could be treated using the Early Detection - Rapid Response Strategy found in

Chapter 3—Affected Environment & Environmental Consequences 203 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Alternatives 4, 5, and 6. Infestations are expected to occur along transportation corridors. The SIAs are lava flows that contain very little soil area, except along Forest Roads. New infestations would probably be treated through the use of herbicides due to the lack of soil and water, since removal of root systems in the coarse lava flows would be difficult, if not impossible. There are no water courses, and no TES plant or animal habitats in the designated SIAs. The rugged terrain prevents human and animal access except along roads. Due to these factors, treatment of noxious weeds in existing or new sites is not anticipated to have direct, indirect or cumulative impacts within the designated Special Interest Areas. The impacts to the RNA’s would be similar to those described for inventoried roadless areas. (see above). Early Detection - Rapid Response activities proposed include the identification and treatment of weeds that may enter the RNAs and SIAs through natural sources (e.g., wind, wildlife, fire). Effects from treatment of new locations would be the same as what is disclosed in this FEIS. Under the no action Alternative, the lack of treatment of potential new infestations along with the likelihood that weeds would eventually spread from outside these areas into them, poses a risk that the RNA’s would lose their research value.

Cumulative Effects Under all Alternatives, there were no identified activities within the RNAs or SIAs, nor are there any Proposed Actions within them, that would increase the risk of noxious weed spread, with the exception of wildfire. Therefore, there are no cumulative impacts to be analyzed in conjunction with noxious weed treatments within RNA’s or SIAs.

Consistency with Laws and Policies All of the action Alternatives are consistent with the Forest Plan, and are consistent with direction in the Establishment Records by proposing specific control against target organisms and taking measures to control or eradicate these populations. All the action Alternatives would be consistent with Forest Service Manual 4603 by removing exotic plant or animal life. The no action alterative would be consistent until a new weed infestation is discovered in the RNA, at which time a separate NEPA process would have to be completed to comply with this Manual direction. Wild and Scenic Rivers The Modoc National Forest does not have any designated Wild and Scenic Rivers. Social and Economic Effects Analysis The Modoc National Forest encompasses lands in Modoc, Lassen, and Siskiyou Counties of California. The area considered for the analysis of direct, indirect, and cumulative social and economic effects is all of Modoc County, as well as the surrounding unincorporated areas of Lassen and Siskiyou Counties. The Modoc National Forest encompasses approximately 2 million acres. Of that total, National Forest System lands make up 1.6 million acres, while private landowners and other government agencies own the remaining land. Modoc County comprises approximately 2,689,246 acres. Approximately 64 % of lands within the county are administered by an agency of the Federal Government. Most of that (1,374,238

204 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

acres) is administered by the Modoc National Forest. Less than 1 % is tribal trust land. The remainder is in private ownership. Because of the high percentage of federal land ownership in the county, people living within the analysis area experience the effects of Forest Service policy and programs directly.

Population Modoc County had an estimated population of 9,640 residents in 2004, reflecting growth of about 2 % since 2000 according to the California Department of Finance. By way of contrast, California’s population grew by approximately 7 % during the same period. Although Modoc County experienced modest population growth, the population of the city of Alturas declined by 1.7 %. The overall analysis area population grew by 2.8 % with the majority of growth occurring in rural areas. The population density within Modoc County in 2000 was estimated at only 2.4 persons per square mile. The racial diversity of the counties in the analysis area is displayed in the following table:

Table 3 - 44. Racial and Ethnic Diversity (2000 Census)

Racial/Ethnic Origin percentage of Population Modoc Lassen Siskiyou County County* County White 85.9 80.8 87.1 Black or African American 0.7 8.8 1.3 American Indian & Alaska Native 4.2 3.3 3.9 Asian` 0.6 0.7 1.2 Native Hawaiian & Other Pacific Islander 0.1 0.4 0.1 Persons Reporting Some Other Race 5.7 3.2 2.8 Persons Reporting Two or More Races 2.8 2.7 3.6 White, Not of Hispanic/Latino Origin 81.1 70.6 83.3 Hispanic or Latino Origin 11.5 13.8 7.6 (U.S. Census Bureau 2000a) Note: Totals do not sum to 100 % due to overlap of some categories (e.g., Someone of Hispanic origin may be of any race: therefore, they would be counted in two categories).

National Visitor Use Monitoring Survey Results The National Visitor Use Monitoring Survey (NVUM) was implemented as a response to the need to better understand the use of and satisfaction with national forest system recreation opportunities. NVUM is a recreation sampling system designed to provide statistical recreation use information at the forest, regional, and national levels. In any given year, 25 % of the national forests conduct on-site interviews and sampling of recreation visitors. The Modoc National Forest participated in the NVUM project from January 1 through December 31, 2000. Weather during the sample year was unusual in that there was not much snow. The second winter of sampling was an average year. Another factor that may have affected results is that most visitors to the Modoc National Forest are locals, who tended not to stop for the interviews. Estimates of recreation use for calendar year 2000 at the 80 % confidence level were 146,155 forest visits +/- 32.1 %. Of visitors interviewed, 98 % categorized themselves as White; 0.4 % as American Indian/Alaska Native; 0.3 % as Spanish, Hispanic, or Latino; 1.1 % as Native Hawaiian or Other Pacific Islander; and 0.2 % as Asian. Approximately 2 % of those surveyed indicated that they participate in gathering mushrooms, berries, firewood, or other natural products (USDA Forest Service 2001).

Chapter 3—Affected Environment & Environmental Consequences 205 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Income and Employment The 1999 median household income in Modoc County was $27,522, compared to $47,493 for the State and $41,994 for the United States as a whole. Median household incomes in Lassen and Siskiyou Counties were somewhat higher at $36,310 and $29,530 respectively (U.S. Census Bureau 2000a). The table below displays the percentage of the analysis area populations that are below the poverty level. Data is provided for each county as a whole and by racial/ethnic group. Twenty-one % of Modoc County residents are below the poverty level, significantly higher than the State. Higher poverty rates were found in all racial/ethnic groups.

Table 3 - 45. Poverty Status (2000 Census)

State of Modoc Lassen Siskiyou Poverty Status California County County County All individuals for whom poverty 33,100,044 9,142 24,853 43,699 is determined Individuals below poverty level 4,706,130 1,962 3,484 8,109 % Below Poverty Level 14.2 % 21.5 % 14.0 % 18.6 % % Below Poverty Level by Racial/Ethnic Group White 10.5 % 18.6 % 12.9 % 16.6 % Black or African American 22.4 % 41.7 % 10.9 % 25.7 % Am. Indian and Alaska Native 21.9 % 41.8 % 36.2 % 31.7 % Asian 12.8 % 21.2 % 10.3 % 58.1 % Native Hawaiian and Other Pacific Islander 15.7 % --- 15.4 % 32.3 % Some Other Race 24.0 % 48.8 % 18.6 % 25.1 % Two or More Races 16.8 % 17.8 % 13.1 % 28.3 % Hispanic or Latino 22.1 % 46.1 % 22.1 % 27.8 % White Alone, Not Hispanic or Latino 7.8 % % 17.312.1 % 16.3 % (U.S. Census Bureau 2000c) Note: Totals do not sum to 100 % due to overlap of some categories (e.g., Someone of Hispanic origin may be of any race; therefore, they would be counted in two categories). The number of employed persons in the counties of the analysis area in 2004 is displayed in table 3-46. Unemployment in Modoc County in 2004 was estimated at 8.6 %, compared to 6.2 % for the state. Unemployment rates were at 9.3 % in Siskiyou County and 7.7 % in Lassen County.

Table 3 - 46. Employment (2004)

Modoc County Lassen County Siskiyou County Civilian Labor Force 4,150 12,220 19,210 Civilian Employment 3,790 11,280 17,420 Civilian 360 940 1,790 Unemployment Civilian 8.6 % 7.7 % 9.3 % Unemployment Rate (California Employment Development Department 2005)

Stakeholder Groups Various groups, expressing a diversity of social values, participated in this planning process. These groups often may have both local voices and affiliation with other like-minded organizations at the county, river basin, state, university, tribal, or national level. Ongoing and continuous public scoping activities over the last ten years, primarily at the local level, identified

206 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

interested and affected publics (“stakeholders”) in noxious weeds control. These groups are extremely interested in the noxious weed treatment program chosen for the Modoc National Forest. These scoping activities revealed stakeholders’ concerns about potential social effects resulting from the adoption of a decision on how noxious weeds are treated. The major stakeholders were grouped into the following categories for analysis. There is considerable overlap among the delineated social organization groups. However, these distinctions are useful in setting the social context for the decision and describing the effects of these Alternatives to interested and potentially affected groups.  Local Residents: City and Rural (non-Farm Landowners or Renters)  Forest Recreation users  Ranching and all Agricultural Forest Practices Industries  The Hispanic Minority Community and Farm Laborers  The Native American Tribes  Environmental Organizations  Other Federal & State Land Management Agencies  State of California, County, City Government, River Basins Most, if not all, groups are interested in promoting greater ecosystem health and insuring the long-term productivity of the land. While all groups recognize the threat posed by noxious weed infestations, some individuals and groups have strong feelings about the desirability of particular treatment methods. The actions of the Modoc National Forest to manage noxious weeds affect these stakeholders. By the same token, the actions of these stakeholders affect the Modoc National Forest and each other. For example, the activities of all adjacent landowners affect populations of noxious weeds. This includes ranchers, other farm operations, other rural property owners, other Federal, State, County, and City government, and private homeowners within cities. It will take considerable collaboration and informed consent to stop the spread of noxious weeds in Modoc County due to the nature of the problem.

Stakeholder Attitudes, Beliefs, and Values Public comments on the DEIS concerning Social Values and Economics are addressed in the analysis, and also in the Human Health and Safety Section and the Tribal Sections of this Chapter. The reader is also directed to the Response to Comment Sections on Economics and Values, Trust and Credibility, Tribal and Public Involvement, and Tribal/Native Americans, which are summarized in this and other sections of this Chapter. Comments on the DEIS also reflected a lack of trust in the analysis, and that the analysis was prepared in a biased manner. The FEIS acknowledges that no amount of analysis will change the attitudes and beliefs of those who do not trust the analysis sections or statements contained in this FEIS.

Local Residents: City and Rural Local residents work in the private sector, are government employees, or are retirees. Important formal and informal associations bring people of diverse backgrounds, occupations and cultures together. Local residents sell goods and services, provide lodging, amusement and professional

Chapter 3—Affected Environment & Environmental Consequences 207 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

services, and work in finance, insurance, and real estate. Alturas, the only incorporated city in the analysis area, is governed by a mayor and four city council members. In addition, the city has an active Chamber of Commerce. Strong community spirit and shared values often found in rural areas are evident. Although the employment opportunities are not primarily dependent on forest products, residents are concerned with the economic stability and growth of the area. While recognizing that commodity outputs (range and timber) contribute to the economic stability, non-commodity outputs provide residents with recreational opportunities as well as economic benefits from tourists attracted to the area for hunting, fishing, and other recreational pursuits. Rural landowners, such as retirees, a small but growing number, have come to the area to escape large population centers or to purchase second homes or parcels of land for vacations or investment. These rural, non-farming residents, may live here year long or only seasonally. Environmental amenities provided by the rural character of the area attract new residents and their use of the Forest is generally recreational. Income sources may be primarily from retirement funds or from employment outside the area. Among the primary concerns of retirees on fixed income are taxes and the ability of the local communities to provide adequate health and social services. A growing concern that cuts across many social groups is the loss of open space and the natural setting. The arrival of increasing numbers of retirees has generally resulted in subdivisions of open spaces and new development. However, the phenomenon of ever growing numbers of rural small property owners circling National Forests is not as pronounced in Modoc, Lassen, and Siskiyou counties as in other counties of California west of the Sierra Nevada Mountains or in other regions of the United States. The Modoc National Forest uses a local Resource Advisory Committee (RAC) under the “The Secure Rural Schools and Community Self-Determination Act of 2000” (Public. Law No. 106- 393) to propose projects and funding to the Secretary of Agriculture under section 203 of the Act. The membership requirements of the law require a balanced view of natural resource management among the participants. As required by law, the current members of the Forest’s RAC consist of individuals from a broad spectrum of social, economic, and environmental views.

Forest Recreation Users People use the Modoc National Forest’s resources for a wide variety of recreational pursuits. This group primarily includes local residents and individuals from California to the south and west of the analysis area, and from southern Oregon. They use the Forest seasonally for recreation activities such as mule deer and pronghorn hunting, fishing, camping and rock hounding. The primary users of the Modoc National Forest are local residents from the surrounding communities. Visitors from outside the area also enjoy destinations of interest on the Forest. The local economy benefits from dollars spent by tourists attracted to the Forest. With more interest in amenity values than in resource developments, recreationists benefit from Alternatives which enhance the natural environment and recreation opportunities. They benefit from healthy wildlife habitat and populations, maintenance of access roads and trails, preservation of traditional hunting camps, and maintenance of developed recreation sites. Their major concern with invasive plants control is both forest degradation and their safety in pursuit of recreational interests. Like most American citizens, they look to the scientific community and government for the best methods to control invasive plants.

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Ranching and all Agricultural Forest Practices Industries Agriculture, including ranching, is the largest economic sector in the analysis area in terms of total industrial output. This group is comprised of individuals involved in livestock production and the growing of grain crops, hay and pasture, and vegetable crops. Many members of this group are long-time residents who own ranches and farms that have been passed to successive generations. Agricultural organizations, like the Modoc County Farm Bureau, Cattlemen's Association, 4-H clubs, rodeos, etc., are still part of the cultural life of the area. The Modoc County Farm Bureau reports that the value of agricultural production produced in Modoc County in 2004 was $77.1 million. The Bureau reports that the top five crops, by value in 2004 were: Alfalfa Hay, $17.2 million; Cattle and Calves, $17.1 million; Potatoes, $11.7 million; Timber, $6.0 million; and Vegetables, $4.7 million. Grazing on public lands is an integral part of many local ranch operations. While livestock graze on public lands during the summer months, those private lands not used for summer grazing are devoted to alfalfa and grass hay production for winter feeding. The table below shows the number of farms with Grazing Permits in Modoc County for 1987, 1992, and 1997 from the USDA National Agricultural Statistical Service. This series of information was discontinued in 2002. In 2005, the Modoc National Forest had 75 permittees.

Table 3 - 47. Farms with Grazing Permits, Modoc County

Description 1987 1992 1997 Farms with grazing permits, land in farms (farms) 128 128 121 Farms with grazing permits, land in farms (acres) 501,962 436,704 478,932 Farms with grazing permits, farms by land in farms (less than 100 acres) 3 10 11 Farms with grazing permits, farms by land in farms (100 to 259 acres) 11 3 7 Farms with grazing permits, farms by land in farms (260 to 499 acres) 9 17 7 Farms with grazing permits, farms by land in farms (500 to 999 acres) 19 21 13 Farms with grazing permits, farms by land in farms (1,000 to 1,999 acres) 29 27 27 Farms with grazing permits, farms by land in farms (2,000 acres or more) 57 50 56 Farms with grazing permits, source of permits (Forest service) 78 75 59 Farms with grazing permits, source of permits (Taylor grazing) 81 89 86 Farms with grazing permits, source of permits (Indian land) 5 4 5 Farms with grazing permits, source of permits (Other) 9 16 17 Source: USDA National Agricultural Statistical Service (http://usda.mannlib.cornell.edu/). The Ranch Farming group benefits from Forest commodities, especially forage and water for domestic livestock. They have a strong interest in public land management. In fact, the Modoc National Forest was established in 1906 largely because of the work and recommendations of local ranchers. The ranching and agricultural community would be the principal stakeholder group financially affected by the spread of noxious weeds. Noxious weed proliferation results in a loss of productive agricultural land. This group has long used chemical methods to control noxious weeds on their private property.

Hispanic Minority Community and Farm Laborers This group is made up of ethnic minorities, primarily Hispanic, many of whom work for ranchers and farmers and other forest and agricultural industries. The minority population of the analysis area is growing both in number and as a proportion of the total population. The largest and fastest-growing segment of the minority population in the analysis area is Hispanics. The

Chapter 3—Affected Environment & Environmental Consequences 209 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Hispanic population of Modoc County was approximately 12 % in 2000 compared to only 4 % in 1980. As noted above, poverty rates in Modoc County are well above the average for the state as a whole at 21.5 %. Poverty rates among many minorities are more than double that of white residents, and range from 41.7 to 48.8 % for Hispanics, American Indians, Blacks or African Americans, and those who indicated “some other race.” Asian residents had a poverty rate of 21.2 %, which was also higher than whites, with a poverty rate of 18.6 %. Minorities, particularly Hispanics, hold the majority of farm labor jobs in the analysis area. As such, Hispanics or other minorities could be employeed to treat noxious weeds. Concern has been expressed regarding potential impacts to these populations as a result of exposure to herbicide chemicals through their employment.

The Native American Tribal Communities The Modoc National Forest consults with five federally recognized tribes: the Pit River Tribe, the Klamath Tribes, Ft. Bidwell Paiutes, Alturas Rancheria, and the Cedarville Rancheria. Additionally, consultation occurs with the unrecognized Shasta Tribe, Inc. and the Shasta Nation, Inc. Members of many tribes gather Forest products for consumption, medicinal, and spiritual use. The population of Native American Indians has remained relatively constant over time at about 4 % of the population of Modoc County, and the analysis area as a whole. Through government to government consultation and discussions with traditional practitioners, Native Americans have expressed concern relative to the effects of noxious weeds and of herbicide use on culturally significant plants and impacts to human health as a result of exposure to, use of, and/or consumption of exposed plant materials. Tribal communities in Modoc County experience high unemployment, and those who are employed often work seasonally in ranching and construction both on and off reservations and rancherias. Native Americans have traditional and non-traditional economic ties to the land. That is, religious/heritage sites are located on the Forest, and many individuals work on the land (logging, thinning, planting, etc.). Through government-to-government consultation and individual discussions, Native Americans in Modoc County generally believe in retaining a natural landscape and using resources necessary to sustain their lifestyle. Thus, part of their concerns about how the Forest is managed stems from the desire to protect and preserve hunting, gathering, and spiritual places. Many believe that sites such as seasonal base camps, burial grounds, rock art, and prayer seats should be preserved out of respect for ancestors and to preserve examples of past lifestyles. Consequently, Native Americans prefer land management practices which maintain the Forest in a natural setting. Traditionalists may also include younger individuals interested in reviving and maintaining aspects of past lifestyles, beliefs, and traditions. Most Native Americans in Modoc County are concerned with the economic necessity of employment. Generally, increased opportunities for local employment, especially available work on the land, is a benefit to these communities. The attitude of Native Americans towards noxious weed treatment methods varies from accepting only physical + treatment methods to some use of a variant of treatment methods, including chemicals. Three traditional cultural properties and four plant-gathering areas have been identified on the Forest. Table 3-29 displays these areas and the known weed sites located within each. Only two gathering areas have weed sites identified within them. These weed sites represent approximately 0.01 % of the tribal areas identified.

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Table 3 - 48. Traditional Cultural Properties and Gathering Areas and Associated Weed Sites

Identified Acreage of Area Size Area Weed Identified (Acres) Sites Weed Sites Medicine Lakes Highlands Traditional Cultural Property 42,350 0 0.0 Timber Mountain Traditional Cultural Property 4,074 0 0.0 Sugar Hill Traditional Cultural Property 2,429 0 0.0 Alturas Rancheria Gathering Area 1 184 2 44.4 Alturas Rancheria Gathering Area 2 103 0 0.0 Alturas Rancheria Gathering Area 3 80 0 0.0 Pit River Tribe Gathering Area 292,769 27 2.6 Total 341,989 29 47.0 (USDA Forest Service 2006) The Forest Service and the Pit River Tribe are currently in negotiations to establish a participating agreement. This agreement would further facilitate the Forest Service and the Tribe working together cooperatively in the treatment of noxious weeds located in ancestral territories within the boundaries of the Modoc National Forest and on adjacent tribal lands.

Environmental Organizations The group entitled “Environmental Organizations” covers a wide variety of individuals and organizations concerned about the environment and natural resource issues. This group has members in the analysis area and links to other stakeholder groups such as the scientific community and Native American Tribes. The views of this group are diverse, some support collaborative approaches and accept limited use of herbicides with strong oversight to eliminate or control noxious weeds, while others take the approach of no herbicides regardless of the cost or treatment effectiveness. Organizations that seek to keep federal lands free of pesticide use in the treatment of noxious weeds refer to similar concerns including: human health and ecosystem reasons. They fear that over-reliance on pesticides may create “super-weeds” resistant to chemical control, thus exacerbating an already difficult infestation problem’ many in this group view the introduction of herbicides to eradicate or control noxious weeds as both unsound science and ill-considered public policy, they have contributed public comments criticizing the scientific rationale for use of chemicals and the potential deleterious effects of chemicals to Forest flora, fauna, soils, and water.

Other Federal Land-Management Agencies This group is composed of other Federal agencies, most of whom have land adjacent to the Modoc National Forest. These agencies are charged with promoting both economic opportunity and environmental protection. The USDI Bureau of Land Management and USDI National Park Service have lands adjacent to the Modoc National Forest. Other USDA Forest Service units that lie adjacent to or near the Modoc National Forest include the Shasta-Trinity, Lassen, Fremont- Winema, and Klamath National Forests. Other agencies with interests in the area include the USDA Natural Resources Conservation Service, Farm Service Agency, North Cal-Neva RC & D Office, and Rural Development Agency.

State and Local Governments The State manages lands adjacent to and in the vicinity of the Modoc National Forest through the State of California Land Commission, the State of California Department of Fish and Game, and

Chapter 3—Affected Environment & Environmental Consequences 211 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

the California Department of Parks and Recreation. Other state and local agencies with interests in the Proposed Action include the California Department of Pesticide Regulation, Regional State Water Quality Control Boards, the California State Transportation Agency, the Modoc, Lassen, and Siskiyou Boards of Agriculture and County Supervisors, and the City of Alturas. This group also includes quasi-government institutions such as the Modoc Noxious Weed Working Group. The Modoc County Noxious Weed Working Group is a standing committee comprised of representatives of many public entities. Working closely with the county agricultural commissioner and the State Department of Food & Agriculture, the work group strives to coordinate weed management efforts and educate everyone on the need for weed awareness (http://www.pitriveralliance.net/resource/noxweeds.html). All these groups use herbicides as one of the primary methods for controlling or eliminating noxious weeds once they have been established.

Environmental Consequences

Alternative 1 - No Action Under the No Action Alternative, current management plans would continue to guide management of the project area. No aggressive treatment activities would be implemented to accomplish the Purpose and Need. This Alternative is required by regulation (CEQ Regulations for Implementing NEPA 1502.14(d)) and would call for no weed management treatments applied to any National Forest System lands, except for those Forest Service parcels under authority of the Federal Highway Administration, the State of California, or areas covered by site specific NEPA analysis. There would be no program for the management of seed banks, for the treatment of new infestations of existing species, or the occurrence of new species of weeds. This Alternative provides a baseline for comparison and analysis of effects. Direct and Indirect Effects Under this Alternative, no aggressive weed management activities would be conducted on the Modoc National Forest by the Forest Service. The spread of noxious weeds would continue, unchecked, except for localized activities totaling 20 to 30 acres of treatment annually, as authorized by site specific NEPA analysis or as treated under the authority of the Federal Highway Administration or the State of California. Existing noxious weed infestations, even if treated, can leave behind seed banks, which can remain viable for many years after treatment activities have been completed. Alternative 1 does not provide for ongoing re-treatment or management of these seed banks. Without re-treatment, these sites continue sprouting from the seed bank, ensuring a reoccurrence of the infestation. Additionally, new infestations or the occurrence of new weed species would remain untreated. All stakeholders would be adversely impacted under the implementation of Alternative 1, as the biological diversity of vegetative communities within the Forest would continue to be reduced. Native species and desirable non-native species would be threatened, as the occurrence of noxious weed infestations continues to increase. Forage production on Forest rangelands would be reduced, adversely impacting habitat capability to support wildlife populations. Permitted grazing activities would be adversely impacted as less forage would be available for grazing by domestic livestock. Recreational users would be adversely impacted in that the enjoyment of the forest for some users may be reduced by the loss of biological diversity. In severe cases, some users may relocate their recreational activities to other areas of the forest or to other public lands as a result of noxious weed infestations.

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Neighboring private and public lands would be adversely impacted as noxious weed populations spread from the Modoc National Forest. Land values may be reduced and costs to control noxious weed infestations for neighboring land owners or administrative agencies (federal, state, and local governments) would be increased. Some stakeholders expressed concern regarding the potential impacts of herbicides to the environment and to human health. Although no herbicide treatments would be implemented under the No Action Alternative, many of those opposing the use of herbicide treatments would remain unsatisfied because the Forest is not treating more aggressively with physical + treatment methods. The no action alternative also would not use methods promoted by these stakeholders, continued and increasing negative effects to the health and diversity of the biological resources of the forest would occur as noxious weed infestations spread. Concern was expressed that the application of herbicides for weed control may affect the ability of Native Americans and others to collect plants for traditional uses or medicinal reasons in specific areas. No herbicides would be applied under this Alternative; therefore, there would be no herbicide impacts to the collection of plants or other forest products. However, the spread of noxious weeds from the Forest to Tribal trust lands would adversely impact American Indian Tribal interests. In the long term, noxious weed populations may threaten traditional gathering areas used by Tribal members. Cost estimates associated with the implementation of Alternative 1 are displayed in Table 3-49. Assuming 30 acres of treatment annually, the estimated five-year discounted cost of this Alternative is $135,670. There is no time limit on implementation under this Alternative; therefore in order to facilitate comparison with the longest term considered under the other Alternatives, ten years was used as to estimate the discounted cost of “full implementation.” The ten-year discounted cost is estimated to be $247,920. Although data about the historical rate of effectiveness was not available, it was assumed that physical + treatments would be applied to non-rhizomatous species, with an 80 % estimated rate of effectiveness. Using this assumption, the average cost per effectively treated acre is approximately.

Table 3 - 49. Alternative 1 Estimated Costs (2006 dollars)

Economic Measure Dollars Five-Year Discounted Cost $135,670 Ten-Year Discounted Cost $247,920 Cost per Effectively Treated Acre > $413 Because the majority of inventoried infestations would remain untreated under this Alternative, they would continue to spread. New infestations of existing species and new species would remain untreated. Therefore, the future cost to control noxious weeds would continue to escalate. The table below displays the potential employment and income that may be supported within the local economy as a result of implementing Alternative 1. The employment figures presented represent potential full-time, part-time, and/or seasonal positions.

Table 3 - 50. Alternative 1 Estimated Job and Income Impacts

Impact Amount Jobs 2 Labor Income ($1,000) $39 (USDA Forest Service 2005)

Chapter 3—Affected Environment & Environmental Consequences 213 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Cumulative Effects Although private land owners and federal, state, and local governments administering lands adjacent to the Forest would continue noxious weed treatment activities, it is likely that they would be unable to treat all occurrences. To the extent that some noxious weed infestations on lands adjoining the Forest may remain untreated, implementation of Alternative 1 would contribute to or accelerate the long-term decline in the health and sustainability of native plant communities within the Forest and adjoining land ownerships. The resulting decrease in biological diversity and reduction in the economic and social returns natural plant communities provide, would adversely impact all stakeholders. Costs incurred by adjoining land ownerships to treat noxious weed infestations would likely continue to escalate as a result of the increasing likelihood and scale of the spread of weeds from untreated National Forest System lands. Deferring the treatment of current noxious weed populations on the Modoc National Forest would result in continued growth and expansion of these sites. Because no action would be taken to address seed bank management, these viable reserves of weed seed would continue to germinate ensuring that even if treated, existing infestations would recur, spread, and create ever larger seed bank reserves. Future management of these expanding sites would require increasingly larger expenditures to implement effective treatments.

Alternative 2 - Proposed Action The Modoc National Forest proposes to treat 14 species of noxious weeds on 536 sites comprising approximately 6,899 acres to eradicate, control, or contain the occurrences. Between 300 to 1,500 acres would be treated annually for the next five years. Herbicides would be applied by directed spray and wicking treatments. Herbicides would include Clopyralid, Dicamba, Glyphosate, Triclopyr, and 2-4-D. Treatments would include use of surfactants and dyes. Surfactants increase the absorption of herbicide by the weeds, and dyes assist the applicator in efficiently treating target weeds. However, this Alternative would not incorporate a program to treat new infestations of existing species or new species of weeds occurring on the Forest. Herbicide treatments would occur only once each year. Some noxious weed sites may require re- treatment during the same year to fully control or eradicate the site. Re-treatment of noxious weed sites after annual herbicide treatment activities within the same season will normally be done by hand or physical + treatments. Noxious weed seed banks can remain viable for many years after treatment activities have been completed on currently inventoried sites. Re-treatment of these sites is needed to control sprouting from the seed bank and prevent a reoccurrence of the infestation. This re-treatment activity is identified as seed bank management. Seed bank management includes visiting previously treated sites on an annual basis to treat newly germinated weeds. The annual combination of methods used would vary depending on noxious weed species, distance from water or other sensitive areas, effectiveness of treatments, and most economical and efficient treatment methods available. There would be no aerial spraying or herbicide use within ten feet of water. The table below summaries the size of areas by treatment method relative to the size of all areas proposed for treatment, and of the Forest as a whole.

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Table 3 - 51. Alternative 2 Treatment Methods

percentage percentage of National Treatment Method Acres Treatment Forest Acres System Acres Physical – hand pulling, hoeing, grubbing 31 0.4 % 0.002 % Physical and/or Herbicide Treatments 5,961 86.4 % 0.358 % Herbicide 907 13.2 % 0.055 % Total 6,899 100 % 0.415 %

Direct and Indirect Effects Herbicide treatments employed under this Alternative are expected to more effectively control weed populations than Alternatives that do not utilize herbicides. However, since all sites would not be treated each year, seed production would continue at untreated sites. New infestations of existing species or infestations of new species would not be treated under this Alternative. Implementation of Alternative 2 would slow the spread of noxious weed species (Noxious Weed Risk Assessment 2006). Biological diversity would be maintained by controlling, reducing, and in some limited cases, eliminating occurrences of 14 species of noxious weeds within the Modoc National Forest. After five years, an environmental analysis would be required to authorize continued noxious weed treatment activities. To the extent that all stakeholders have an interest in promoting greater ecosystem health and ensuring the long-term productivity of the land, all stakeholders would benefit from implementation of this Alternative. Sensitive plant populations would be benefited as competition for light, water, and nutrients would be reduced (Beyer 2006). Forage production on Forest rangelands would be maintained or enhanced, supporting habitat capability to sustain wildlife populations. Forage for domestic livestock grazing would be maintained or improved, supporting permitted grazing activities. Recreational opportunities and environments would be enhanced by the reduction of noxious weed infestations, contributing to biologically diverse populations of native and desirable non-native plant populations. Potential for the spread of noxious weeds from the Modoc National Forest to adjoining land ownerships would be reduced through implementation of Alternative 2. Control efforts on the Forest would therefore contribute to containment of the costs incurred by private land owners and other agencies for the control of noxious weeds. Although public concern was expressed relative to the health risk of herbicide use, physical control methods also represent human health risks for crews implementing control activities. Crews would be exposed to the potential for injuries as a result of tripping, falls, motor vehicle accidents, tool use, etc. Physical control methods are more time consuming to implement and therefore require increased time in the field, increasing exposure to the risk of physical injury. Contra Costa County experienced increased worker compensation claims as a result of implementing physical control methods. There was a significant rise in the incidence of back injuries above that experienced when herbicide treatments were implemented. A contributing factor may have been that all members of the crew were over the age of 40. The experience of Contra Costa County was that physical control methods were less effective and required more repeat treatments and thus increased worker exposure. Additionally, crews found physical treatment methods to be physically demanding and tiring (Jefferies 2006). However, 2002 Worker Compensation Insurance data cited in the Human Health and Safety specialist’s report (Bakke 2005) indicated that compensation rates for physical treatment methods were only slightly higher than for herbicide treatment methods.

Chapter 3—Affected Environment & Environmental Consequences 215 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Combinations of physical, physical +, and herbicidal treatments are proposed under this Alternative. Physical control methods will be used exclusively to treat 31 acres and, as an option, for treating an additional 5,961 acres. The design of Alternative 2 requires the use of proper personal safety equipment, training, and supervision for all weed treatment crews to reduce the potential for injuries to workers. However, crew members tasked with implementation of physical treatment methods would be exposed to greater risk of injury under this Alternative than under Alternatives 5 and 6 due to the potential number of acres to be treated. Crews made up of temporary employees may be less likely to experience repetitive motion injuries due to the potential for a shorter length of exposure. Crews made up of permanent personnel may be at greater risk, as the length of exposure has the potential to be more long term. Some stakeholders are concerned about the potential impacts of herbicides to the environment and to human health. Exposure of the general public to herbicides may occur through members of the public visiting recently treated areas; permittees conducting activities within treatment areas; or through the consumption of plant materials, water, or fish contaminated by herbicide chemicals. Areas to be treated at one time would generally be small and scattered. Total annual treatment acres (300-1,500 acres) represent between 0.02 to 0.09 % of the lands administered by the Modoc National Forest; in total, less than 0.41 % (6,868 acres) of the Forest could be subject to herbicide treatment. Additionally, herbicides would be applied through the use of directed spray or by application to individual plants by wick, minimizing the potential for drift beyond the targeted plants. Public exposure would therefore be minimal. Design Standards for all Alternatives utilizing herbicides require that treatment areas be posted with notification signs at access points prior to initiating treatment activities. These signs will list the herbicides to be used, the effective dates for treatment, and the name and number of a Forest Service contact. Dyes would be used to facilitate the identification of recently treated plants. Human health and safety impacts to workers and the public under a variety of exposure scenarios including exposure from direct spray, treated vegetation, consumption of sprayed fruit, drinking contaminated water, or consuming fish by recreational and subsistence users were analyzed in the Human Health and Safety specialist’s report (Bakke 2005). Both acute (one-time) and chronic (long-term) circumstances were considered. Details of the analysis are located in the project record worksheet analysis for each herbicide, which is located in the Forest Supervisor’s Office in Alturas, CA. The worksheets contain over 500 pages and will not be repeated in detail here. However, using compliance with recommended safety practices and procedures, results indicate that exposure levels would not be expected to exceed acceptable levels of risk, particularly given the relatively small area to be treated. Some expressed concern relative to herbicide impacts in areas utilized for mushroom-gathering activities. The Modoc, Klamath, and Shasta-Trinity National Forests jointly administer commercial mushroom gathering permits in the Medicine Lakes Highlands Traditional Cultural Property. Mushrooms are also an important cultural resource to Native American tribes in the area. No weed sites are currently identified in the Medicine Lakes Highlands area, and no weed treatment activities impacting this important resource are anticipated. A small percentage of the population may have a hypersensitivity to a wide variety of pesticides, perfumes, household cleaners, construction products or industrial herbicides, including the herbicides proposed for use by the Forest. Risk of exposure for these individuals would be minimal (see Human Health and Safety Report, Bakke, 2005). For some forest users, any exposure to herbicides, direct or indirect, reduces the quality of their experience in the forest. Some individuals may regard the presence of herbicide residues and odors as a threat to good health and an adverse impact to their quality of life. These individuals

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may chose to relocate to other areas of the forest or other public lands to avoid recently treated areas. Those with the greatest risk of exposure would be the workers applying the herbicides. In accordance with the letter of direction dated November 18, 2005 from the Chief of the Forest Service in response to public concern about migrant and guest worker health and safety (Bosworth 2005) all Alternatives would require strict adherence to health and safety requirements for all workers. Exposure levels would not be expected to exceed acceptable levels of risk to human health for all herbicides proposed for use by the Forest (Bakke 2005). Herbicides would only be applied by personnel who have been certified as applicators in accordance with label instructions and federal and state pesticide regulations. All crews assigned to conduct weed treatment activities would be required to have received training, conducted in the language of the crew, addressing health and safety precautions, Herbicide Fact Sheets, spill plans, and requirements for personal protective equipment. Additionally, supervision and inspections would be provided to ensure compliance with all safety requirements including the use of required personal protective equipment. To address herbicide impacts to gathers and weavers, the California Environmental Protection Agency, Department of Pesticide Regulation completed a study entitled “Residues of Forestry Herbicides in Plants of Interest to Native Americans in California Forests.” This report is discussed in the Tribal/Native American specialist report (Meza 2006). The conclusions are quoted below. “In general, low residue levels were detected in the roots, shoots, foliage, and berries of plants treated with granular hexazinone and also in roots of bracken fern treated with Glyphosate, Triclopyr, or liquid hexazinone. Although levels were low, residues persisted in many of the sampled media, with Glyphosate remaining detectable in bracken fern roots at 67 weeks post- application, the last sampling period for the plant-herbicide combination. Also gatherers sampling shoots, foliage, and berries in Glyphosate or Triclopyr treatment areas may be exposed to herbicide. The highest residue levels were generally observed on application day or 4 weeks following application (second sampling interval) with residues remaining detectable in plant materials for several weeks thereafter. Consequently, herbicide residue data should be used for exposure assessment to determine if gatherers and basket weavers are exposed to hazardous levels of the four forestry herbicides. As herbicide residues were found to move off-site to non-treatment areas, plant gatherers and basketweavers may want to select plants beyond 100 ft. down slope from treated areas for up to 12 weeks following treatment. (Ando 2002) ” Effects to human health relative to Native American traditional uses including the consumption of plant materials, water, or fish are addressed in detail in the specialist’s reports for Human Health and Safety (Bakke 2005), and for Tribal/Native American Uses (Meza 2006). Exposure levels would not be expected to exceed acceptable levels of risk to human health for all herbicides proposed for use (Bakke 2005). Positive impacts to Native American tribal interests would be a reduced risk of weed infestations encroaching on gathering areas, and adversely impacting populations of traditional plant resources. Additionally, the risk of invasive species encroachment on Tribal lands would be reduced. Negative impacts are an increased chance that traditional plant resources in close proximity to treatment areas may be damaged or lost. Approximately 341,989 acres of traditional cultural properties and tribal gathering areas have been identified on the Forest. Approximately 47 acres of weed infestations have been identified within these areas. Under Alternative 2, approximately 45.2 acres would not be treated, 0.5 acres

Chapter 3—Affected Environment & Environmental Consequences 217 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

would be treated through the use of physical treatment methods only, 0.5 acres would be treated through the use of herbicides only, and 0.8 acres would be treated with a combination of physical and herbicide treatments. The acres of gathering areas proposed for herbicide treatment represents 0.0004 % of the total identified tribal areas. Additionally, herbicides would be applied through the use of directed spray or by application to individual plants by wick, minimizing the potential for drift beyond the targeted plants. Design Standards for this Alternative require that Forest personnel work closely with Native American tribal leadership regarding annual operating plans to prevent the spread of weed populations onto tribal lands and also to protect heritage resources such as traditional plant gathering areas. If tribal crews are utilized to implement treatment activities through the proposed participating agreement with the Pit River Tribe, cultural familiarity with traditional plant materials by crew members may afford additional protection to these resources. The timing of treatment activities may correspond with the timing of traditional gathering activities. Advance coordination with tribal leadership would allow for adjustments to annual treatment plans based on new information and make it possible for tribal leaders to provide notification to tribal membership regarding planned treatment activities. Such advance notice would allow those conducting traditional gathering activities to avoid exposure to recently treated areas. Notification signs would be posted at access points to treatment areas prior to initiating treatment activities. These signs will list the herbicides to be used, the effective dates for treatment, and the name and number of a Forest Service contact. Additionally, dyes used in herbicide treatments would facilitate the identification of recently treated plants. National Visitor Use Monitoring (NVUM) survey results indicate that Native Americans represented only 0.4 % of Forest recreation visitors surveyed. Of all visitors surveyed, those who participate in gathering natural products represented only 2 %. Although survey results are the only source of information regarding National Forest use levels, many local residents did not stop and participate in the survey. Those who did not participate in the survey likely included American Indian users who may not have considered their activities as “recreational.” Therefore, survey results are likely to have underestimated the number of these users. Nonetheless, even if undercounting is assumed, the very small area to be treated indicates a minimal risk of exposure to Native American forest visitors. Adverse impacts to gathering activities for subsistence or income producing purposes are not expected. Despite the low risk of exposure, some users would likely consider any herbicide treatments as an intrusion, endangering traditional cultural practices important to tribal lifestyles and quality of life. Therefore, herbicide use at any level may contribute to a perceived reduction in quality of life for some American Indian users. Native American workers implementing weed treatment activities under the proposed participating agreement with the Pit River Tribe would be at increased risk of exposure to herbicides or to injuries as a result of weed treatment activities. Exposure levels would not be expected to exceed acceptable levels of risk to human health for all herbicides proposed for use by the Forest (Bakke 2005). In accordance with the letter of direction dated November 18, 2005 from the Chief of the Forest Service in response to public concern about migrant and guest worker health and safety (Bosworth 2005), all Alternatives would require strict adherence to health and safety requirements for all workers. Herbicides would only be applied by personnel who have been certified as applicators in accordance with label instructions and federal and state pesticide regulations. All crews assigned to conduct weed treatment activities would be required to have received training, conducted in the language of the crew, addressing health and safety precautions, Herbicide Fact Sheets, spill plans, and requirements for personal protective

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equipment. Additionally, supervision and inspections would be provided to ensure compliance with all safety requirements including the use of required personal protective equipment. Estimated costs include the cost of treatment activities, seed bank management, monitoring and inventory activities, water quality monitoring, and soil unit validation. Water quality monitoring and map unit validation will be completed under this Alternative due to the potential for herbicide use. The highest level of annual treatments (1,500 acres) was assumed. The estimated five-year discounted cost for the implementation of Alternative 2 in 2006 dollars is $1,393,760. The total discounted cost for the life of the Alternative is the same, as Alternative 2 is proposed with a five- year life span. These figures are an approximation, and are intended to allow for comparison of the Alternatives. No adjustment was made to allow for the effects of inflation on the cost of implementation as it occurs in future years. The estimated cost per effectively treated acre is $243.

Table 3 - 52. Alternative 2 Estimated Treatment Costs (2006 dollars)

Economic Measure Dollars Five-Year Discounted Cost $1,393,760 Total Discounted Cost (Life of Alternative = Five Years) $1,393,760 Cost per Effectively Treated Acre $243 The estimate of total cost for five years of implementation calculated above assumed that the maximum level of annual treatment (1,500 acres) would be implemented each year. Needless to say, costs would be reduced at lower annual treatment levels. An analysis was conducted to determine how long it would take to treat all areas proposed for treatment under this Alternative. It was assumed that treatments would be implemented at the maximum annual level proposed, 1,500 acres. Treatments were assumed to be 80 % effective, and that the remaining 20 % of acres would likely require some form of re-treatment in succeeding years, thereby reducing the number of “new” acres that could be treated in each year following the first year of implementation (e.g., 20 % of acres treated (300 acres) in year one would be treated again in year two, therefore only 1,200 “new” acres would be treated in years two through five). Under these assumptions, approximately nine % of acres proposed for treatment would not be treated within the five-year life of this Alternative. At the lowest level of annual treatment proposed (300 acres), as much as 82 % of proposed areas would remain untreated. If priority is placed on applying an initial treatment to as many acres as possible before re-treatment activities are initiated, rates of spread could be slowed considerably. However, depending on the actual annual weed treatment program level, some areas requiring re-treatment may not receive that follow-up treatment during the proposed implementation period. Table 3-53 below displays the potential employment and income that may be supported within the local economy as a result of implementing Alternative 2. The employment figures presented represent potential full-time, part-time, and/or seasonal positions.

Table 3 - 53. Alternative 2 Estimated Job and Income Impacts

Impact Amount Jobs 72 Labor Income ($1,000) $922 (UDSA Forest Service 2005) Many other anticipated economic benefits are not easily converted to dollar amounts. In addition to job and income benefits, there would be additional intangible and difficult to quantify economic benefits. Some of those benefits, such as improved biodiversity, improved forage for

Chapter 3—Affected Environment & Environmental Consequences 219 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

wildlife and domestic cattle grazing, and protection of adjacent lands, are discussed above. Other benefits include those listed below:  Reduced potential for increased erosion and soil loss associated with weed-dominated plant communities  Protection of aquatic species resulting from reduced runoff and sedimentation  Improved esthetic value of the landscape  Potential increases in the amount of recreation use that would occur in relatively weed- free areas Refer to the other specialists’ reports for further discussion of the effects of the Alternatives on the above resources. Cumulative Effects In combination with noxious weed treatment activities implemented on adjoining land ownerships, implementation of Alternative 2 would contribute to the long term improvement and maintenance of area biodiversity and ecosystem health, positively impacting all stakeholders. Costs to adjoining land ownerships to control and contain noxious weed infestations would be reduced in the long term, as seed sources on National Forest system lands are reduced or eliminated. Herbicide treatments on National Forest System lands, when combined with herbicide treatment activities on adjoining land ownerships, represent a potential for increased risk of exposure to some members of the public. These risks are discussed in the Human Health Specialist’s report. Bioaccumulations within the environment of the chemicals proposed for use are not anticipated. The anticipated risk to human health is considered low.

Alternative 3 Alternative 3 was developed in response to scoping comments to provide an Alternative that did not include herbicides. Alternative 3 treats a total of 5,993 acres through physical methods. Between 300 to 1,500 acres would be treated annually for the next five years. However, this Alternative would provide no program for the treatment of new infestations of existing weeds or occurrences of new weed species. Noxious weed seed banks can remain viable for many years after treatment activities have been completed on existing plants. Re-treatment of these sites is needed to control sprouting from the seed bank and prevent a reoccurrence of the infestation. This re-treatment activity is identified as Seed Bank Management. Seed Bank Management includes visiting previously treated sites on an annual basis to treat newly germinated weeds. The size of the area to be treated relative to the Forest as a whole is displayed in the table below.

Table 3 - 54. Alternative 3 Treatment Methods

percentage of percentage of Treatment Method Acres National Forest Treatment Acres System Acres Physical – hand pulling, hoeing, grubbing 5,993 100 % 0.362 %

220 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Direct and Indirect Effects The direct and indirect effects resulting from the implementation of Alternative 3 would be similar to those described under Alternative 2 with the following exceptions. No herbicides would be used, therefore impacts related to the application of herbicides would not occur under this Alternative; however, overall effectiveness of treatment activities is expected to be lower. Only a portion of existing sites would be treated each year, so seed production at untreated sites would continue. The occurrence of treated species of noxious weeds would decline during the five years of implementation. New infestations of existing species or occurrences of new species would not be treated. After five years, additional analysis would be required to continue treatment activities. Control and eradication of larger sites would not occur. Soil disturbance resulting from physical + and physical treatment methods also provides conditions conducive to new seed invasion (Beyer 2006). Implementation of Alternative 3 would maintain biodiversity to a lesser extent than would occur under Alternative 2. As a result of soil disturbance resulting from the use of physical + methods, this Alternative could potentially increase or exacerbate some noxious weed infestations and result in loss of diversity (Beyer 2006). Although the potential for the spread of noxious weed infestations to other land ownerships would be reduced as compared to Alternative 1, there may be greater potential for spread than would occur under Alternatives 2, 4, and 6,. No risks to workers as a result of herbicide use would occur under this Alternative. Because all acres would be treated using physical treatment methods, the potential for physical injuries to workers is greater under this Alternative, due to increased exposure to the risks involved. As described under Alternative 2, Alternative 3 would require strict adherence to health and safety requirements for all workers implementing treatment activities. No herbicides would be utilized under this Alternative. Therefore, adverse impacts to human health and the environment as a result of herbicide use would not occur. No adverse impacts to traditional Native American gathering areas would occur as a result of herbicides. Of the 47 acres of weed infestation identified within identified gathering areas, 45.7 acres would not be treated. Approximately 1.3 acres would be treated with physical treatment methods. The spread of noxious weed populations may be slowed, but ground disturbance as a result of physical treatment methods could provide habitat for the spread of some weed species. Risk of spread to tribal lands is less than under Alternative 1, but greater than under Alternatives 2, 4, and 6. Native American workers implementing weed-treatment activities under the proposed participating agreement with the Pit River Tribe would be at greater risk of physical injuries as a result of weed treatment activities under this Alternative relative to Alternative 2, due to the increased number of acres to be treated using physical methods. In accordance with the letter of direction dated November 18, 2005 from the Chief of the Forest Service in response to public concern about migrant and guest worker health and safety (Bosworth 2005) all Alternatives would require strict adherence to health and safety requirements for all workers. All crews assigned to conduct weed treatment activities would be required to have received training, conducted in the language of the crew, addressing health and safety precautions and requirements for personal protective equipment. Supervision and inspections would be required to ensure compliance with all safety requirements including the use of required personal protective equipment. Design Standards for this Alternative require that Forest personnel work closely with Native American tribal leadership regarding annual operating plans to prevent the spread of weed

Chapter 3—Affected Environment & Environmental Consequences 221 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

populations on to tribal lands and also to protect heritage resources such as traditional plant gathering areas. This coordination would allow for adjustments to annual treatment plans to improve potential effectiveness and address tribal concerns. Estimated costs include the cost of treatment activities, monitoring and inventory activities, and seed bank management. Water quality monitoring and soil profile examinations would not be required, since no herbicide treatments would be utilized. The estimated five-year discounted cost for the implementation of Alternative 3 in 2006 dollars is $2,225,190, and is displayed in Table 3- 55. Because Alternative 3 specified a life of five years, this is also the total discounted cost. No adjustment was made to allow for the effects of inflation on the cost of implementation as it occurs in future years. Projected costs are highest under this Alternative due to the labor intensity of physical treatments. The estimated cost per effectively treated acre is $418 per acre.

Table 3 - 55. Alternative 3 Estimated Treatment Costs

Economic Measure Dollars Five-Year Discounted Cost $2,225,190 Total Discounted Cost (Life of Alternative = Five Years) $2,225,190 Cost per Effectively Treated Acre $418 An analysis was conducted to determine how long it would take to treat all areas proposed for treatment under this Alternative. It was assumed that treatments would be implemented at the maximum annual level proposed, 1,500 acres. Treatments were assumed to be 80 % effective, and that the remaining 20 % of acres would likely require some form of re-treatment in succeeding years, thereby reducing the number of “new” acres that could be treated in each year following the first year of implementation (e.g., 20 % of acres treated (300 acres) in year one would be treated again in year two, therefore only 1,200 “new” acres would be treated in years two through five). Under these assumptions, all acres proposed for treatment would be treated within the five year life of this Alternative. At the lowest level of annual treatment proposed (300 acres), as much as 79 % of proposed areas would remain untreated. If priority is placed on applying an initial treatment to as many acres as possible before re-treatment activities are initiated, rates of spread could be slowed considerably. However, depending on the actual annual weed treatment program level, some areas requiring re-treatment may not receive that follow-up treatment during the proposed implementation period. The estimated number of jobs and income potentially supported over five years as a result of implementing Alternative 3 are detailed in the following table.

Table 3 - 56. Alternative 3 Estimated Job and Income Impacts

Impact Amount Jobs 17 Labor Income ($1,000) $437,654 (USDA Forest Service 2005) As described in under Alternative 2, there would be other benefits that are difficult to convert to dollar values. Refer to the specialists’ reports for other resource areas for a discussion of the effects of the Alternatives on these resources. Cumulative Effects Cumulative effects under Alternative 3 would be similar to those described under Alternative 2; however, the cumulative use of herbicides within the area would be lower than under Alternatives 2, 4, and 6. Thus, potential for impacts to human health from these chemicals would also be lower. Herbicide use will continue on private and other federal lands.

222 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Alternative 4 Alternative 4 expands on Alternative 2 to reflect scoping comments on the need to provide flexibility in treatment methods to eradicate, control, or contain the current occurrences and expanding or new infestations of the selected noxious weeds over a ten-year time period by adding an Early Detection – Rapid Response component. The annual weed treatment program would treat an estimated of 500-1,500 acres per year for ten years. Herbicides would be applied by directed spray and wicking treatments. The herbicides utilized would include Clopyralid, Dicamba, Glyphosate, Triclopyr, and 2-4-D. Treatments in Alternative 4 would also include use of surfactants and dyes. Surfactants increase the absorption of herbicide by the target weeds, and dyes assist the applicator in efficiently treating target weeds. An Early Detection – Rapid Response Strategy would be implemented in this Alternative. Early Detection – Rapid Response would provide the opportunity to treat new sites of the identified species that have developed, new sites of new noxious weed species, and existing sites that have expanded using the same treatments as outlined provided the effects are within the design Standards, and effects analyses are reflected in this FEIS. Proposed treatment under Early Detection – Rapid Response would be capped at 200 acres over the life of the Alternative with no more than 100 acres treated in any single year. The rationale for this cap is to provide limited flexibility to treat new and/or expanding weed sites while remaining within the range of effects as displayed in this analysis. Herbicide treatments will occur only once each year. Some noxious weed sites may require re- treatment during the same year to fully control or eradicate the site. Re-treatment of noxious weed sites after annual herbicide treatment activities within the same season will normally be done by physical + treatments. Noxious weed seed banks can remain viable for many years after treatment activities have been completed on existing plants. Re-treatment of these sites is needed to control sprouting from the seed bank and prevent a reoccurrence of the infestation. This re-treatment activity is identified as Seed Bank Management. Seed Bank Management includes visiting previously treated sites on an annual basis to treat newly germinated weeds. Table 3-57 summarizes the size of the areas proposed for each treatment method relative to all areas proposed for treatment, and to the National Forest System lands administered by the Modoc National Forest.

Table 3 - 57. Alternative 4 Treatment Methods

percentage of percentage of Treatment Method Acres Treatment National Forest Acres* System Lands Physical – hand pulling, hoeing, grubbing 31 0.45 % 0.002 % Physical and / or Herbicide Treatments 5,961 86.40% 0.358 % Herbicide 907 13.15% 0.055 % Total Treatment Acres – Existing Infestations 6,899 100 % 0.415 % Early Detection – Rapid Response Strategy – same species at new or expanded sites and 200 --- 0.012 % new species and new sites (Max. of 100 acres in any one year) * percentages are based on the estimated total of existing infestations and do not include estimated acres to be treated through Early Detection – Rapid Response.

Chapter 3—Affected Environment & Environmental Consequences 223 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Direct and Indirect Effects Up to 6,868 acres could potentially be treated with herbicides under this Alternative. Up to 200 additional acres could also be treated with herbicides under the Early Detection – Rapid Response strategy. The effects of Alternative 4 would be similar to those described under Alternative 2, but would occur over a longer period of time (ten years verses five). This Alternative is expected to be more effective at controlling the spread of weeds due to the ability to treat new or expanded occurrences of the 14 identified noxious weed species, as well as newly occurring species. The result would be more effective maintenance of native plant communities and plant diversity. The ability to treat new infestations increases the potential for the maintenance or improvement of native plant communities above that provided by Alternative 2. Overall, the potential for spread to other land ownerships would be less than is anticipated under Alternative 2. Physical treatment methods could be implemented on up to 31 acres under this Alternative. This includes acres that could be treated with physical and/or herbicide treatments. It also includes the maximum number of acres potentially treated through Early Detection – Rapid Response. The risk of physical injuries to workers implementing this Alternative and the resultant costs are similar to Alternative 2. Risk of injury and associated costs would be higher than under Alternatives 5 and 6. Approximately 5,961 acres could be treated with herbicides and/or physical treatments. If all of these acres are treated physically, risk of worker injury and associated costs could potentially be similar to Alternative 3. However these impacts would likely be lower since a significant number of acres may be treated with herbicides rather than with physical treatments. As described under the Alternatives above, Alternative 4 would require strict adherence to health and safety requirements for all workers implementing treatment activities. Impacts relative to Issue 1 would be the same as described under Alternative 2, but would occur over a longer period of time. Herbicide treatments would be applied to as much as 200 additional acres over that treated under Alternative 2 due to Early Detection – Rapid Response for a total of approximately 7,068 acres. However, effects are not expected to differ measurably from those anticipated under Alternative 2. Impacts related to Issue 2 would be the same as described under Alternative 2, but would occur over a longer period of time. The risk of the spread of noxious weed species to tribal lands would be lower under this Alternative due to the use of Early Detection – Rapid Response. Herbicides would be used to treat 0.5 acres and physical or herbicide treatments would be applied to 0.8 acres within identified gathering areas. The acres proposed for herbicide treatment represents 0.0004 % of the total identified tribal gathering areas. A small amount of additional acreage could be treated to address new infestations of the 14 identified noxious weed species, occurrences of new species, or expansions of existing sites. Herbicides would be applied through the use of directed spray or by application to individual plants by wick, minimizing the potential for drift beyond the targeted plants. As with the other action Alternatives, Design Standards for this Alternative require that Forest personnel work closely with Native American Tribal leadership regarding annual operating plans to prevent the spread of weed populations onto Tribal lands and also to protect heritage resources such as traditional plant gathering areas. This coordination would allow for adjustments to annual treatment plans to increase likely effectiveness and address Tribal concerns. Notification signs would be posted at access points to treatment areas prior to initiating treatment activities. These signs will list the herbicides to be used, the effective dates for treatment, and the name and number of a Forest Service contact. Additionally, dyes used in herbicide treatments would facilitate the identification of recently treated plants.

224 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Estimated costs include the cost of treatment activities, seed bank management, monitoring and inventory activities, water quality monitoring, and soil profile examination. Water quality monitoring and soil profile examination are required under this Alternative as a result of the use of herbicide treatments. The costs of Early Detection – Rapid Response are not included. The estimated five-year discounted cost of Alternative 4 in 2006 dollars is $1,383,010. This figure is an approximation and is intended to allow comparison of the Alternatives. No adjustment was made to allow for the effects of inflation on the cost of implementation as it occurs in future years. No estimate for rate of spread was incorporated in cost estimates. The total discounted cost of implementing Alternative 4 is $1,987,840. Unlike Alternatives 2 and 3, these costs would be incurred over a period of ten years rather than five. The cost per effectively treated acre is estimated at $241 per acre.

Table 3 - 58. Alternative 4 Estimated Treatment Costs (2006 dollars)

Economic Measure Dollars Five-Year Discounted Cost $1,383,010 Total Discounted Cost (Life of Alternative = Ten Years) $1,987,840 Cost per Effectively Treated Acre (inventoried acres) $241 Cost per Effectively Treated Acre (ED-RR) $226 It is unknown what treatment methods would be required for infestations to be treated through Early Detection – Rapid Response. To estimate the average costs, the estimated acres of Early Detection – Rapid Response were distributed among the treatment methods based on the proportions estimated for existing infestations as displayed in the preceding table. Because the cost of monitoring is covered in the cost of treated existing inventoried acres, the expected cost per effectively treated acre under Early Detection – Rapid Response is estimated to be approximately $226 per acre. An analysis was conducted to determine how long it would take to treat all areas proposed for treatment under this Alternative. It was assumed that treatments would be implemented at the maximum annual level proposed, 1,500 acres. Treatments were assumed to be 80 % effective, and that the remaining 20 % of acres would likely require some form of re-treatment in succeeding years, thereby reducing the number of “new” acres that could be treated in each year following the first year of implementation (e.g., 20 % of acres treated (300 acres) in year one would be treated again in year two, therefore only 1,200 “new” acres would be treated in years two through ten). Under these assumptions, all acres proposed for treatment would be treated within the ten- year life of this Alternative. At the lowest level of annual treatment proposed (500 acres), as much as 46 % of proposed areas would remain untreated. If priority is placed on applying an initial treatment to as many acres as possible before re-treatment activities are initiated, rates of spread could be slowed considerably. However, depending on the actual annual weed treatment program level, some areas requiring re-treatment may not receive that follow-up treatment during the proposed implementation period. The estimated number of jobs and income potentially supported as a result of the implementation of Alternative 4 are detailed in the table below.

Table 3 - 59. Alternative 4 Estimated Job and Income Impacts

Impact Amount Jobs 97 Labor Income ($1,000) $1,262 (USDA Forest Service 2005)

Chapter 3—Affected Environment & Environmental Consequences 225 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Cumulative Effects The cumulative effects of Alternative 4 would be the same as described under Alternative 2 above.

Alternative 5 Alternative 5 was developed in response to comments on the DEIS to provide a non-herbicide Alternative that contained additional non-herbicide treatments. This Alternative would be implemented over a ten-year treatment period. An Early Detection – Rapid Response Strategy would be implemented in this Alternative. Early Detection – Rapid Response would provide the opportunity to treat new sites of the identified species that have developed, new sites of new noxious weed species, and existing sites that have expanded using the same treatments as outlined, provided the effects are within the Design standards, and effects analyses are reflected in this FEIS. Proposed treatment under Early Detection – Rapid Response would be capped at 200 acres over the life of the Alternative, with no more than 100 acres treated in any single year. The rationale for this cap is to provide limited flexibility to treat new and/or expanding weed sites, while remaining within the range of effects as displayed in this analysis. Noxious weed seed banks can remain viable for many years after treatment activities have been completed on existing plants. Re-treatment of these sites is needed to control sprouting from the seed bank and prevent a reoccurrence of the infestation. This re-treatment activity is identified as Seed Bank Management. Seed Bank Management includes visiting previously treated sites on an annual basis to treat newly germinated weeds. The table below summaries the size of areas by treatment method relative to the total area proposed for treatment and to the Forest as a whole.

Table 3 - 60. Alternative 5 Treatment Methods

percentage percentage of Treatment Method Acres of Treatment National Forest Acres1 System Lands Physical + – hand pulling hoeing, grubbing, clipping, seed 139 50 % 0.008 % head or plant, hand-held string trimmer, mulching/tarping Goat Grazing or Physical+ 41 15 % 0.003 % Limited Treatment (treatments along border of current infestation to prevent spread using physical+ methods or 100 35 % 0.006 % goat grazing) Total Treatment Acres – Existing Infestations 280 100 % 0.017 % Early Detection – Rapid Response Strategy – hand and Physical+ treatment of same species at new or expanded 200 --- 0.012 % sites and new species and new sites (Avg. of 20 acres per year for ten years, Max. of 100 acres in any one year) 1 percentages are based on the estimated total of existing infestations to be treated, and do not include estimated acres to be treated through Early Detection – Rapid Response. Direct and Indirect Effects The effects of Alternative 5 would be similar to those described under Alternative 3, but would occur on a smaller number of acres over a longer period of time. Total acres treated under this Alternative would be 0.029 % of National Forest System acres. Two large sites, a 5,657.76 acre site of dyer’s woad and one 158.27 acre site of common crupina, would only be treated to reduce, but not eliminate, the potential for spread. Because the smaller number of acres to be treated may allow for increased re-treatment of some sites, there may be an increased chance of control and elimination of smaller infestations, but large sites and rhizomatous species would be more

226 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

difficult to control using the treatment methods specified. Soil disturbance as a result of treatment activities may increase the susceptibility of a site to re-invasion by noxious weed species. This Alternative may present an increased risk of spread to adjoining land ownerships as compared to Alternatives 2, 4, and 6. However, Early Detection – Rapid Response would allow the treatment of new infestations of the 14 identified weed species and infestations by new species. Overall effectiveness would be less than that expected under Alternatives 2, 4, and 6. This Alternative proposes a ten-year period of implementation. The potential for Physical+ injuries to workers implementing treatment activities would be less than described under Alternative 3 because this Alternative would utilize Physical+ treatment methods on up to 139 acres. As described under the Alternatives above, Alternative 5 would require strict adherence to health and safety requirements for all workers implementing treatment activities. No herbicides would be utilized under this Alternative. The effects relative to Issue 1 would be the same as described under Alternative 3; however, fewer acres would be treated. The effects relative to Issue 2 would be the same as described under Alternative 3, except that all 47 acres of noxious weed infestations within identified gathering areas would be treated through Physical+ treatment methods. There may be an increased chance of control and elimination of smaller infestations within gathering areas, but large sites may be more difficult to control. Soil disturbance as a result of treatment activities may increase the susceptibility of a site to re- invasion by noxious weed species and renewed risks to desirable native plants within these gathering areas. Should Native American crews be utilized to implement treatment activities across the forest under the proposed participating agreement, they would be at risk of Physical+ injuries as described under Alternative 3. However the potential risk would be reduced due to the smaller number of acres to be treated. Alternative 5 would require strict adherence to health and safety requirements for all workers implementing treatment activities. Estimated costs include the cost of treatment activities, seed bank management, and monitoring and inventory activities. Water quality monitoring and soil profile examinations would not be required since no herbicide treatments would be utilized. The estimated five-year discounted cost for the implementation of Alternative 5 in 2006 dollars is $533,420. The total discounted cost of implementing this Alternative is $900,230. No adjustment was made to allow for the effects of inflation on the cost of implementation as it occurs in future years. These costs would occur over a period of ten years. The average cost per effectively treated acre is $1,159. This cost is higher than the average for Alternative 3, due to the higher estimated unit cost of Physical+ treatments plus mulching/tarping. Additionally the annual costs of seed bank management and inventory and monitoring activities would be spread across fewer acres. This Alternative would leave the largest percentage (96 %) of inventoried infestations untreated.

Table 3 - 61. Alternative 5 Estimated Treatment Costs (2006 dollars)

Economic Measure Dollars Five-Year Discounted Cost $533,420 Total Discounted Cost (Life of Alternative = Ten Years) $900,230 Cost per Effectively Treated Acre (inventoried acres) $1,159 Cost per Effectively Treated Acre (ED-RR) $507 Treatments under Alternative 5 would be focused more on the eradication of small infestations and containment and control of large infestations, rather than on their elimination. Early Detection – Rapid Response would be implemented, using Physical+ plus tarping/mulching treatment methods. Because the costs of inventory and monitoring activities and seed

Chapter 3—Affected Environment & Environmental Consequences 227 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

management are included in the cost of treating existing inventoried acres, the expected cost per effectively treated acre to treat new infestations as they occur under Early Detection – Rapid Response is estimated to be approximately $507. The estimated number of jobs and income potentially supported as a result of the implementation of Alternative 5 are detailed in the table below.

Table 3 - 62. Alternative 5 Estimated Job and Income Impacts

Impact Amount Jobs 8 Labor Income ($1,000) $192 (USDA Forest Service 2005) Cumulative Effects Cumulative effects under Alternative 5 would be similar to those described under Alternative 3 above.

Alternative 6 Alternative 6 was developed to respond to comments that requested a more flexible approach utilizing herbicide treatment methods, a larger range of Early Detection – Rapid Response techniques, and additional herbicides. This Alternative will be implemented over a ten-year treatment period. Herbicide treatments would include Chlorsulfuron, Clopyralid, Dicamba, Glyphosate, Triclopyr, 2-4-D, and two herbicide mixtures (Mix 1: Chlorsulfuron + 2, 4-D, and Mix 2: Dicamba + 2, 4- D). Herbicide treatments would also include use of surfactants and dyes. Surfactants increase the absorption of herbicide by the target weeds, and dyes assist the applicator in efficiently treating target weeds. Herbicide treatments would be the primary treatment for rhizomatous species. An Early Detection – Rapid Response Strategy would be implemented in this Alternative. Early Detection – Rapid Response would provide the opportunity to treat new sites of the identified species that have developed, new sites of new noxious weed species, and existing sites that have expanded using the same treatments as outlined, provided the effects are within the Design Standards, and effects analyses are reflected in this FEIS. Proposed treatment under Early Detection – Rapid Response would be capped at 200 acres over the life of the Alternative with no more than 100 acres treated in any single year. The rationale for this cap is to provide limited flexibility to treat new and/or expanding weed sites while remaining within the range of effects as displayed in this analysis. Herbicide treatments would occur once each year. Some sites may require re-treatment during the same year to fully control or eradicate the site. Re-treatment of noxious weed sites after annual herbicide treatment activities within the same season will normally be done by physical + methods. Noxious weed seed banks can remain viable for many years after treatment activities have been completed on existing plants. Re-treatment of these sites is needed to control sprouting from the seed bank and prevent a reoccurrence of the infestation. This re-treatment activity is identified as Seed Bank Management. Seed Bank Management includes visiting previously treated sites on an annual basis to treat newly germinated weeds. A summary for Alternative 6 of the size of areas by treatment methods compared to all areas proposed for treatment and to the Forest as a whole are displayed in the following table.

228 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 3 - 63. Alternative 6 Treatment Methods

percentage of percentage of Treatment Method Acres Treatment National Forest Acres1 System Lands Physical+ - Hand pulling, hoeing, grubbing, clipping seed head or plant, hand-held 19 6 % 0.001 % string trimmer, mulching / tarping Physical+ and / or Herbicide Treatments 116 34 % 0.007 % Herbicide Treatment 65 19 % 0.004 % Cultural – Limited Goat Grazing or Herbicide Treatment (>4 acres and < 25 41 12 % 0.003 % acres for thistle flowers). Limited Treatment (treatments along border of current infestation to prevent spread 100 29 % 0.006 % using physical+ methods, herbicide, or goat grazing) Total Treatment Acres – Existing 341 100 % 0.021 % Infestation Early Detection – Rapid Response Strategy – same species at new or expanded sites and new species and new sites (Avg. of 20 200 --- 0.012 % acres per year for ten years, Max. of 100 in any one year) 1 percentages are based on the estimated total of existing infestations to be treated and do not include estimated acres to be treated through Early Detection – Rapid Response. Direct and Indirect Effects The effects of Alternative 6 would be similar to those described under Alternatives 2 and 4, but would occur on fewer acres over a longer period of time. A large site of dyer’s woad, a large site of Dalmatian toadflax, and a large site of common crupina would not be treated, except around the borders to prevent spread or the establishment of satellite infestations. Treatments applied to these sites would utilize herbicides. Efforts under this Alternative would be focused more on eradication of small infestations and containment and control of large infestation rather than their elimination. This Alternative allows for the use of Early Detection – Rapid Response procedures to treat not only new occurrences of the 14 identified weed species, but also occurrences of new weed species when they are first discovered, and are small and manageable. The use of Early Detection – Rapid Response would reduce the potential for spread on the forest and to other land ownerships. A total of approximately 522 acres could potentially be treated annually with herbicides under Alternative 6. This represents 0.03 % of all National Forest System lands. Approximately 200 acres of these could be treated through Early Detection – Rapid Response. This represents a risk of exposure to members of the public that would be less than under Alternatives 2 and 4. As under Alternative 2, herbicide exposure levels for both the public and for workers executing treatment activities would not exceed acceptable levels of risk to human health for all herbicides proposed for use (Bakke 2005). The use of proper personal safety equipment, training, and supervision for all weed treatment crews would be required to reduce the potential for injuries to workers. Physical+ treatment methods could be implemented on up to 19 acres (including potential treatments under Early Detection – Rapid Response), much lower than under Alternatives 2, 3, 4, or 5. The effects relative to Issue 1 are similar to those described under Alternatives 2 and 4. However, risks to worker health and safety and the potential for public exposure to herbicides would be reduced due to treatment of fewer acres.

Chapter 3—Affected Environment & Environmental Consequences 229 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Impacts related to Issue 2 would be the same as described under Alternative 4, but would occur over a longer period of time. However, a total of approximately 45.5 acres of noxious weeds would be treated with herbicides, and another acre would be managed with either Physical+ or herbicide treatments within identified gathering areas. While this represents a greater use of herbicides within traditional tribal gathering areas than under Alternatives 2 and 4, it represents only 0.01 % of the total gathering area acreage. Use of herbicides increases the likelihood that the existing infestations can be eliminated. The risk of the spread of noxious weed species to tribal lands would be lower under this Alternative, due to the use of Early Detection – Rapid Response to treat new and spreading infestations of not only the 14 identified species, but also new species. As with the other action Alternatives, Design Standards for this Alternative require that Forest personnel work closely with Native American tribal leadership regarding annual operating plans, to prevent the spread of weed populations on to tribal lands and also to protect heritage resources such as traditional plant gathering areas. This coordination would allow for adjustments to annual treatment plans to improve potential effectiveness and address Tribal concerns. Notification signs would be posted at access points to all treatment areas prior to initiating treatment activities. These signs would list the herbicides to be used, the effective dates for treatment, and the name and number of a Forest Service contact. Additionally, dyes used in herbicide treatments would facilitate the identification of recently treated plants. As under Alternative 2, herbicide exposure levels for tribal members and for workers executing treatment activities would not exceed acceptable levels of risk to human health for all herbicides proposed for use (Bakke 2005). The use of proper personal safety equipment, training, and supervision for all weed treatment crews would be required to reduce the potential for injuries to workers. Estimated costs include the cost of treatment activities, seed bank management, monitoring and inventory activities, water quality monitoring, and soil profile examination. Water quality monitoring and soil profile examination are required under this Alternative as a result of the use herbicide treatments. The costs of fully implementing this Alternative are detailed in the table below. Estimated five-year discounted cost for the implementation of Alternative 6 in 2006 dollars is $455,200. No adjustment was made to allow for the effects of inflation on the cost of implementation, as it occurs in future years. The total discounted cost of implementing this Alternative is $734,630. The average cost per effectively treated acre is estimated to be $660. This cost is higher than estimated under Alternatives 2 and 4, due to the higher estimated cost of soil and water monitoring, and because the costs of seed bank management, inventory and monitoring are spread over a fewer number of treated acres. The total cost of implementation over the life of the Alternative is much lower than under Alternatives 2 and 4; however, approximately only 4 % of the total inventoried noxious weed sites would be treated under Alternative 6.

Table 3 - 64. Alternative 6 Estimated Treatment Costs (2006 dollars)

Economic Measure Dollars Five-Year Discounted Cost $455,200 Total Discounted Cost (Life of Alternative = Ten Years) $734,630 Cost per Effectively Treated Acre - Inventoried Acres) $660 Cost per Effectively Treated Acre for ED-RR $261 It is unknown what treatment methods would be required for infestations to be treated through Early Detection – Rapid Response. To estimate costs, the estimated acres of Early Detection – Rapid Response were distributed among the treatment methods based on the proportions estimated for existing infestations as displayed in the preceding table. Because the costs of monitoring and seed bank management are covered in the average cost of treating existing inventoried acres, the expected average cost per effectively treated acre for the treatment of new

230 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

infestations under Early Detection – Rapid Response is estimated to be approximately $261 per acre. The estimated number of jobs and income potentially supported as a result of the implementation of Alternative 6 are detailed in the table below.

Table 3 - 65. Alternative 6 Estimated Job and Income Impacts

Impact Amount Jobs 22 Labor Income ($1,000) $364 (USDA Forest Service 2005) Cumulative Effects The cumulative effects of Alternative 6 would be the same as described under Alternative 4. Summary of Effects Alternatives 4 and 2 would have the greatest potential for public and worker exposure over the life of the Alternative, due to the total number of acres that could potentially be treated with herbicides. Annual treatments under both Alternatives would be applied to a maximum of 1,500 acres, which represents approximately 0.09 % of the forest. Of the Alternatives that propose the use of herbicides, Alternative 6 would propose herbicide applications to the fewest number of acres, with a total of 522. This represents 0.03 % of the national forest system lands administered by the Modoc National Forest. Alternative 6 would treat the highest number of acres within identified traditional gathering areas, and may pose the greatest risk of exposure to Native Americans gathering traditional plant materials. However, consultation at the gathering area with representatives from the Alturas Rancheria showed this risk was acceptable to the Tribe, because treating the area effectively with herbicides would prevent the loss of the area to Dalmatian toadflax. The Alturas Rancheria responded in writing that it wants the Forest to treat the Dalmatian toadflax in the gathering area. They understand it would require herbicides to treat the infestation. In their letter, the Tribe wrote that they have Alternative places for gathering the resource provided by the gathering area. Approximately 45.5 acres could potentially be treated with herbicides under Alternative 6 which represents about 0.01 % of all identified gathering area and 0.003 % of the national forest system lands administered by the Modoc National Forest. Alternative 1 would cost the least to implement, would treat the fewest acres, and would not contain or control most of the inventoried noxious weed sites on the forest. Alternatives 2, 3 and 4 would treat the most acres of the six Alternatives considered. Alternatives 4, 5, and 6 would provide for treatment activities for a period of ten years versus five years under Alternatives 1, 2, and 3. The most costly Alternative overall is 3, followed by 2, and 4. Not surprisingly, these Alternatives also propose to treat the largest number of acres. Average cost per effectively treated acre is lowest under Alternative 4. This low cost can be attributed to treatment methods with a lower per-acre cost, and the lowest level of required water quality and soil monitoring of all the Alternatives proposing herbicide treatments. Additionally, recurring annual costs such as seed bank management and inventory and monitoring activities are distributed across a larger number of acres effectively treated each year. The highest average cost per effectively treated acre occurs in Alternatives 1 and 5, which treat the fewest acres using the most expensive treatment method. Because Alternatives 1 and 5 treat the fewest acres, annual costs such as inventory and monitoring and seed bank management are distributed across fewer acres, increasing the per-acre cost to a greater extent.

Chapter 3—Affected Environment & Environmental Consequences 231 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Early Detection – Rapid Response treatment activities are proposed under Alternatives 4, 5, and 6. The lowest average cost per effectively treated acre for these treatments is Alternative 4, followed by 6, and the highest cost occurs under Alternative 5. Alternatives 1, 2, and 3 do not provide for Early Detection – Rapid Response.

Table 3 - 66. Summary of Effects by Alternative

Measure Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6 Acres of Potential Herbicide Treatment (Public and worker 0 6,868 0 7,068 0 522 exposure)1 Acres of Potential Herbicide Treatment within Identified 0 1.3 0 1.3 0 45.5 Gathering Areas (exposure of Native American Gatherers) Five-Year Discounted Cost $136 $1,394 $2,225 $1,383 $533 $455 Estimate ($1000) Estimated Total Discounted $248 $1,394 $2,225 $1,988 $900 $735 Cost ($1000) Avg. Cost per Effectively $1,183 $243 $418 $241 $1,159 $660 Treated Acre – Inventoried Sites Avg. Cost per Effectively NA NA NA $226 $507 $261 Treated Acre – ED-RR Jobs 2 72 17 97 8 22 Labor Income ($1000) $39 $922 $438 $1,262 $192 $364 Alternative 4 would potentially support the largest number of jobs and income in the community, due to the large number of acres potentially treated with herbicides. It was assumed that all herbicide treatments would be achieved through contracting. IMPLAN modeling indicates that weed treatment services would stimulate a larger number of jobs and income per million dollars of output than would occur through the use of Forest Service crews. Therefore, Alternatives which propose higher levels of herbicide weed treatment services, tend to have an increased potential to stimulate jobs and income.

Environmental Justice Executive Order 12898 requires the evaluation of Alternatives to determine whether they would disproportionately impact minority or low-income populations. Hispanic, American Indian, Black or African American, and Asian populations have a larger proportion of individuals with incomes below the poverty level. Crews hired to conduct weed treatment activities in the area are frequently made up of minority workers. Alternative 1, No Action: Under the No-Action Alternative, no jobs or income would be supported; however, existing jobs and income would not be lost. Existing weed treatment activities as authorized by the Federal Highway Administration or the State of California would continue. Additionally, some weed-treatment activities authorized under site-specific NEPA analysis would continue. Based on the above analysis, there would be no disproportionate impact to minority or low income groups as a result of implementation of Alternative 1. Alternative 2: Native American stakeholders have expressed concern that residues from herbicides may contaminate food sources and cause harm over time. Because traditional basket weavers often use their teeth to hold fiber plants in preparing them for weaving, fiber plants with herbicide residues are also of concern.

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To address herbicide impacts to gatherers and weavers, the California Environmental Protection Agency, Department of Pesticide Regulation completed a study entitled “Residues of Forestry Herbicides in Plants of Interest to Native Americans in California Forests”. This report is discussed in the Tribal/Native American specialist report. Tribal/Native American gatherers collecting shoots, foliage, and berries in treatment areas may be exposed to herbicides. The highest residue levels were generally observed on application day and for four weeks following application with residues remaining detectable in plant material of treatment activities. Design Standards of this Alternative require that Forest personnel work closely with Native American Tribal leadership regarding annual operating plans to protect heritage resources such as traditional plant gathering areas, rock art, and historic structures. The potential for impacts to traditional plant gathering areas from weed infestation would be reduced. At the same time, coordination with Tribal leadership would help to minimize adverse impacts resulting from the application of herbicides. Additionally, coordination with Tribal leadership would allow notification to those conducting traditional gathering activities so that exposure to recently treated areas could be avoided. As stated above, areas subject to treatment annually represent only 0.09 % of the Forest and National Visitor Use Monitoring results indicate Native American visitors represent a very small portion of Forest use. Risk to Native Americans seeking to collect traditional plant materials would be minimal. Crews employed for weed treatment activities may be composed of minority workers. As stated above, appropriate training, supervision, and inspection would be implemented to ensure that worker exposure does not exceed recommended safety levels. Impacts to recreation users are expected to be minor, and would not differ with regard to ethnicity or income status. Based on the above analysis, this Alternative would not have disproportionate adverse impacts on minority or low-income populations. Alternative 3: The effects of Alternative 3 would be similar to Alternative 2, except that no herbicides would be utilized. However, because some large sites of rhizomatous species would not be treated, there may be an increased risk of spread to adjoining land ownerships than under the other action Alternatives. Through consultation, the Alturas Rancheria identified three plant-gathering areas that are important to them on FS lands. One gathering area is 184 acres, another is 103 acres, and the last is 80 acres. The combined total of acres is 367. The 184-acre gathering area has two Dalmatian toadflax infestations on the site. One infestation is 44.33 acres and the second is 0.09 acres. Table 2-5, Alternative 2 Site-Specific Treatment Information in the FEIS, indicates that physical methods are not effective in treating this rhizomatous weed. Therefore, this gathering area could be lost due to encroaching Dalmatian toadflax under Alternative 3. Consultation regarding the infestation was done in the field, at the gathering area with the Tribe. The Tribe responded in writing after the field trip. The Tribe wants the Forest to treat the Dalmatian toadflax in the gathering area. They understand it would require herbicides to treat the infestation as indicated in Table 2-3, Weed Treatment Methods by Noxious Weed Species, of this FEIS. Under this Alternative, this site would not be treated. In their letter, the Tribe wrote that they have alternate places for gathering the resource provided by the gathering area. They requested a timeline for treatment and subsequent monitoring. Based on the above analysis, this Alternative could have a disproportionate adverse impacts to the Alturas Rancheria by the loss of their traditional gathering area due to spread of Dalmatian toadflax (that would not be treated under this Alternative). Other than this potential effect, this

Chapter 3—Affected Environment & Environmental Consequences 233 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Alternative would not have any disproportionate adverse impacts on any other minority or low- income populations. Alternative 4: The environmental justice concerns under Alternative 4 are similar to those described under Alternative 2. Because a relatively small portion of the Forest would undergo treatment each year, this Alternative would not have disproportionate adverse impacts on any minority or low-income populations. Alternative 5: Effects relative to environmental justice are the same as described under Alternative 3. However, because some large sites would only be treated around the perimeter of the infestation, and the treatment methods employed under this Alternative are not as effective in controlling large sites or rhizomatous species, there may be an increased risk of spread to adjoining land ownerships, than under the other action Alternatives. Alternative 6: The effects relative to environmental justice under Alternative 6 would be the same as described under Alternatives 2 and 4. However, herbicide treatments would be applied to a smaller portion of the Forest. Based on the above analysis and the relatively small portion of the Forest that would undergo treatment each year, this Alternative would not have disproportionately adverse impacts on minority or low-income populations. Tribal and American Indian Uses

Introduction The Modoc National Forest, located in northeastern California, is one of 155 national forests administered by the Forest Service, U.S. Department of Agriculture. Native American land, which lies within, adjacent and outside the Modoc National Forest, and Forest Service land, are affected by legislation such as the National Environmental Policy Act (NEPA) of 1970. California, according to the U.S. Census Bureau, maintains the highest American Indian population of any state in the United States. The California and Oregon Native American Tribes residing on or near the Modoc National Forest are divided between the six federally recognized tribes, and the two federally unrecognized. The six federally recognized tribes are listed below (Federal Register Vol.73, No. 66, Friday, April 4, 2008): Alturas Indian Rancheria, California Cedarville Rancheria, California Fort Bidwell Indian Community of the Fort Bidwell Reservation of California Susanville Indian Rancheria, California Pit River Tribe, California (includes XL Ranch, Big Bend, Likely, Lookout, Montgomery Creek and Roaring Creek Rancherias) Klamath Tribes, Oregon The two unrecognized tribes are listed below: The Shasta Tribe, Inc. The Confederated Bands of the Shasta and Upper Klamath River Indians The Modoc National Forest proposes to treat noxious weeds on Forest Service lands to meet the requirements of the National Environmental Policy Act. We have prepared this Forest Service Environmental Impact Statement (FEIS). The American Indian component includes a statement on the existing conditions, direct and indirect effects, and cumulative effects.

234 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Existing Conditions American Indian tribes gather forest products for consumption, medicinal and spiritual uses, where consultation has indicated a wide range of plants important to tribes. Plant species include sagebrush (Artemisia tridentate), epos (Perideridia spp.), elderberries (Sambucus ssp.) wild onions (Alliums spp.), mules ears (Wyethia mollis), wild plums (Prunus spp.), Oregon grape (Berberis aquifolium), and others. Also, several American Indian cultural properties or sacred sites, which total 48,853 acres in the Modoc National Forest, are eligible for nomination to the National Register of Historic Places. Government-to-Government Consultation with Tribes In an effort to control noxious weeds on the 1.6 million acres of the Modoc National Forest, Native American Tribes were engaged in a consultation process with the Forest Service as required by executive orders, agency memorandums and statutes, including the National Environmental Policy Act. The tribes, tribal organizations, and interested individuals expressed concerns in four areas. Tribal Concerns on Noxious Weed Control 1. The use of herbicides for invasive weed control may cause health problems to the public and Native American people. 2. The use of herbicides for invasive weed control may affect the traditional or medicinal uses of plants by Native Americans. 3. The use of herbicides for invasive weed control may provide only a short-term solution, when alternate, long-term remedies are available. 4. The use of herbicides for invasive weed control has the potential to adversely affect all natural resources in the forest. Alturas Indian Rancheria Gathering Site The Alturas Indian Rancheria identified three plant gathering areas on the Modoc Nation-al Forest, totaling 367 acres. One of the two sites is infested with Dalmatian toadflax (Linaria dalmatica L.), which is a non-native plant under consideration for treatment. Fort Bidwell Indian Community of the Fort Bidwell Reservation Forest Certification The Fort Bidwell Indian Community was certified by the Scientific Certification System under the Forest Conservation Program, and in accordance with the Forest Stewardship Council’s Principles and Criteria as a well-managed forest in February 2004. The tribal willingness to address noxious weeds was a contributing factor toward their certification, which was in partnership with the Modoc National Forest, Bureau of Land Management, and the Bureau of Indian Affairs. Pit River Tribal Noxious Weed Eradication Program In cooperation with the U.S. Bureau of Indian Affairs (BIA), Pit River employs a noxious weed eradication program of physical, mechanical, biological and herbicidal treatments. Klamathweed (Hypericum perforatum L.) St. Johnswort or Klamathweed is a non-native plant species of medicinal value and is one of 14 weeds identified for noxious weed treatment; however, treatment is by physical + methods and not by herbicides. Enthnobotany

Chapter 3—Affected Environment & Environmental Consequences 235 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

The Forest Service Washington Office provided an intensive three-week training course in ethnobotany to the botanist of the Modoc National Forest. Ethnobotany is the study of how people in a particular cultural or region use indigenous plants. The purpose of the training is to increase the cultural sensitivity of the Modoc National Forest during any government-to- government consultation with tribes. Public Law 108-278 The Tribal Forest Protection Act of 2004 (P.L. 108-278) authorizes the Secretary of Agriculture and the Secretary of the Interior to contract with Indian tribes in order to protect Indian forest land or rangeland. The Pit River Tribe and the Fort Bidwell Indian Community have trust land adjacent to the Modoc National Forest. Despite an apparent opportunity to implementing Public Law 108-278 in treating noxious weeds, American Indian tribes have made no requests under the Act.

Direct and Indirect Effects Under the No-Action Alternative Noxious weeds would spread unabated toward tribal trust lands under this alternative. The costs incurred by tribes to treat noxious weeds would increase as non-native plants spread across trust lands. Pit River Tribe, California, Trust Lands Non-native plant populations of Scotch thistle (Onopordum acanthium L.) may threaten trust land of the Pit River Tribe on the XL Ranch and near McGinty Point. Fort Bidwell Indian Community, California, Trust Lands Non-native plant populations such as dyer’s woad (Isatis tinctoria L.) may pose a future threat to lands on the Fort Bidwell Indian Community by encroaching on tribal trust land. American Indian Cultural Properties as Gathering Areas, Non-Trust Lands Non-native plant populations or noxious weeds threaten a 285,351-acre plant-gathering area important to the Pit River Tribe. Twenty-seven weed sites have been identified of less than 0.10 acres each, except for one site of 0.16 acres. Alternatives 2, 4, and 6 (Herbicide Use) The large-scale program of noxious weed control would use a combination of physical and herbicidal treatments. Treatment methods may direct foliar spray or by wicking individual plants. Non-native plant populations or noxious weeds within 10 feet of water would be treated with hand treatments or aquatic glyphosate. Cost to the tribes would be reduced in the long-term, since seed sources would be reduced or eliminated. Pit River Tribe, California, Trust Lands Non-native plant populations of Scotch thistle (Onopordum acanthium L.) may be treated by physical, mechanical and herbicidal methods, depending on consultation outcomes. Fort Bidwell Indian Community, California, Trust Lands Non-native plant populations such as dyer’s woad (Isatis tinctoria L.) may be treated by physical, mechanical and herbicidal methods, depending on consultation outcomes. Presently, the tribe is neither utilizing herbicides nor supporting the use of herbicides as a treatment method. The tribe is especially concerned about the sub-watershed, which is a community based water system

236 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

providing drinking water to the reservation. The sub-watershed is not identified as a municipal watershed within the State of California. American Indian Cultural Properties as Gathering Areas, Non-Trust Lands Non-native plant populations or noxious weeds threaten a 285,351-acre plant-gathering area important to the Pit River Tribe, which may be treated by physical, mechanical and herbicidal methods, depending on consultation outcomes. Also, herbicides are considered to have “no effect” on archaeological properties. Non-Cultural Properties as Gathering Areas, Non-Trust Lands Over 90 percent of noxious weed occurrences are along public roads. Health risks to Native American elderly gatherers and weavers increase, according to a December 2002 California Environmental Project Agency study entitled, “Residues of Forestry Herbicides in Plants of Interest to Native Americans in California Forests.” Alternative 3 (Non-Herbicide Use) The large scale program of noxious weed control would implement physical treatments to rangeland resources (87 percent of infested acreage). The Forest Service may be unable to halt noxious weeds, particularly dyer’s woad on the Fort Bidwell Indian Community where physical treatment methods are less effective. Also, the tribal sub-watershed would remain unaffected with herbicides under this alternative. Alternative 5 (Non-Herbicide Use) Active treatments of only four percent of noxious weed infestations would occur. The Forest Service may be unable to halt noxious weeds under this alternative.

Cumulative Effects Fuels and Prescribed Fire Herbicides are not employed in the Forest Service Fuels Programs; consequently, no increased human health risks due to chemical exposure would occur. A temporary seasonal loss of plants occurs under the prescribed fires, which enhance culturally important plant and wildlife habitat over the long term. Range Management Herbicides are not used by the Forest Service Range Program; consequently, no increased human health risks due to chemical exposure would occur. Access to cultural important areas is not limited under the range management program. A Geographical Information System (GIS) analysis of noxious weed occurrences shows that grazing areas are not infested with non-native plant populations. Recreation Herbicides are not utilized by the Forest Service Recreation Program; consequently, no increased human health risks due to chemical exposure would occur. Access to culturally important areas is not limited under the recreation program. The recreational users of Forest Service roads do contribute to the spread noxious weeds. The cumulative effect to tribal communities is the loss of easily accessible gathering areas. Presently, tribes are consulted on campground development

Chapter 3—Affected Environment & Environmental Consequences 237 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

and improvement projects as a mitigation effort against the loss of more plant gathering areas and to improve other areas. Reforestation Activities associated with replanting trees may have included the use of herbicides prior to 1984. Presently, no herbicides are used since 1984 in reforestation activities; however, 800 acres of Forest Service land are planned for gopher control, using strychnine-laced oats. The human health risk to tribal gatherers and weavers due to chemical exposure is negligible, since the strychnine-laced oats are placed underground in burrows. Roads Administration GIS analyses of noxious weed occurrences indicate that Forest Service road systems contribute to the spread of non-native plant populations. Herbicides are neither used by the roads program nor are limits imposed on access points to culturally sensitive areas. Sixty miles of California State Highways cross the Modoc National Forest. Also, Modoc County maintains 1,040 miles of roads through the national forest. Specific terms of easement for vehicle transportation include provisions for herbicide use. Timber Administration and Vegetation Treatments The Forest Service road system was designed to support timber harvests after World War II. Access was limited to certain areas for short durations. The implementation of contract “C” provisions has helped reduce the spread of noxious weeds prior to logging. Special Uses The Forest Service processes a mean caseload of 160 special use permits annually. The provisions of these permits require users to aid the Forest Service in controlling noxious weeds. Utilities require prior authorization for the power transmission and distribution of electricity and natural gas on over 3,000 acres of power and pipeline corridors. Also, the Forest Service leases over 1,460 acres to public and private agencies for communication purposes, including 900 acres leased to the Department of Defense. In the last five years, herbicides have not been used to maintain these corridors. Two railroads cross portions of the national forest where herbicides are known to be used to control vegetation. The rights-of-way are owned by the railroad. Previous Noxious Weed and Adjacent Treatments The Modoc County Department of Agriculture treated noxious weeds on national forest land with a memorandum of understanding prior to 2002. Records indicate a period of 30 years where herbicides were used primarily on private lands. The herbicides persist in the environment for less than one year and are not bio-accumulative. Herbicidal treatments on Forest Service land, combined with adjacent lands, may increase potential exposure to tribal communities. The risk to human health is expected to be low.

Sagebrush Steppe Ecosystem Restoration Project (SSERP) The SSERP project is the restoration of sagebrush communities that are invaded by juniper over the past 100 to 150 years. The project area consists of 6.5 million acres, where restoration treatments would employ mechanical and hand and fire methods. American Indian tribes indicated vegetative changes created by sagebrush restoration may adversely affect the integrity of tribal cultural resources. Also, tribes state that large-scale fire usage may adversely impact air

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quality. The use of herbicides for the SSERP project is not expected; therefore, the risk to human health is anticipated to be minimal. Vegetated Communities The effects of weed-treatment options on vegetation resources are important. Vegetation resources considered under the Proposed Action and each Alternative are plant communities and Management Indicator Species (MIS). MIS include Federally Listed Species (Threatened, Endangered, and Sensitive Species-TES) and Watch List Species. The concerns for vegetation resources are intense because the results of doing nothing to stem the invasion of weeds are likely to be worse in the long term than the most aggressive treatment strategy. Biodiversity and plant species richness for native vegetation and plant communities, wildlife habitat values, and sensitive species populations are likely to be severely compromised by the unchecked invasion of weeds. Similarly, these same vegetation resources could be compromised by unconstrained weed treatment efforts as well. Commenters on the DEIS were concerned about re-vegetating treated areas to native plant species, which is part of the Proposed Action. Comments on the DEIS focused on herbicide effects to non-target plants, plant communities, federally listed species, and the effects of specific herbicides on vascular plants. The following discussion focuses on how these effects may differ among Alternatives. The Botany Specialist Reports in the Appendix K of Volume 2, and the Native Plants discussion in the Response to Comments section in Volume 3, are expanded information of the summarized analysis below.

Plant Communities The Forest encompasses numerous plant communities, many of which contain or have the potential to contain the noxious weeds listed in this document. There are 17 major vegetation types found on the Forest, based on the classification of California Vegetation, CALVEG (Parker and Mayas 1981), and on the Wildlife Habitat Relationship Program. The Forest is dominated by juniper and eastside pine. Western juniper covers approximately 28% of the Forest. Juniper has increased substantially as a result of fire- suppression efforts and past grazing practices. Low sagebrush is the third-most dominant vegetation type. It is indicative of vast acreages of shallow soil, generally low-productivity land. With the addition of big and silver sagebrush to the low sagebrush habitat types, together these communities cover 20 % of the land. Conifer vegetation types found on the Forest are eastside pine, mixed conifer, white fir, red fir, and lodgepole forest. In total, commercial conifer vegetation types are found in nearly 640,000 acres, or 40 % of the Forest. Aspen groves are found on the more mesic high-elevation sites, primarily in the Warner Mountains. Rocky ridgelines support curlleaf mountain mahogany and cheatgrass. Noxious weed species have been observed on the Forest in many plant communities. Dry communities are inherently vulnerable to invasion by many species of weeds, including knapweeds and yellow starthistle (Callihan et al. 1989 and Lacey et al. 1997). Species such as knapweeds, Scotch thistle, dyer's woad, and Mediterranean sage can primarily be found in habitat types such as sagebrush, juniper and eastside pine communities. Disturbance factors such as road and utility corridors, timber sales, and OHV use increase vulnerability to noxious weed invasion. Riparian areas are associated with many communities on the Forest. Riparian areas in satisfactory ecological condition are vital for maintaining certain vegetation communities, water quality, fish

Chapter 3—Affected Environment & Environmental Consequences 239 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

and wildlife habitats. Wetlands and riparian areas occur along ponds, marshes, rivers, and streams. They are often inundated by water and normally have saturated or seasonally saturated soil conditions within 10 feet of surface water. The width of the areas may vary from a few feet along small streams, ponds and within spring meadows, to several hundred feet along major rivers, lakeshores, and within large meadow basins. Because of the presence of moisture and abundant nutrients, wetlands and riparian areas are often the most productive areas of vegetative growth. They are valuable in providing forage for both wildlife and livestock. Occasionally, noxious weed infestations occur in these areas. Some weeds, such as Canada thistle, spotted knapweed, and perennial pepperweed, have the potential to dominate riparian areas if not controlled. Wetland riparian areas, at this time, are relatively free of noxious weeds species with the exception of Canada thistle, which tends to be found in wetter areas on Forest lands. Spotted knapweed can reduce frequency and composition of native species and is considered a threat to conservation of native plant communities (Lajeunesse et al. 1995; Tyser and Key 1988; Belcher and Wilson 1989; Lym and Messersmith 1985). Other noxious weeds such as yellow starthistle and dyer’s woad have been found to reduce establishment and growth of more desirable species (Evans and Chase 1981; Rice et al. 1994; Callihan et al. 1989). Ecosystem processes that involve water retention and noxious weeds can impact nutrient cycling. Cryptogamic ground crust, which is composed of small lichens and mosses and commonly covers undisturbed soil surfaces, is reduced by spotted knapweed (Tyser 1992). This ground crust is important for soil stabilization, moisture retention, and nitrogen fixation (Anderson et al. 1982). Spotted knapweed also increases erosion rates because of its tap-rooted growth characteristic. Runoff was 56 % higher and sediment yield was 192 % higher on spotted knapweed plots compared to bunchgrass plots during a simulated rainfall period (Lacey et al. 1989). Knapweed infestations would have long-term detrimental effects on soil and water resources. Introduction and spread of noxious weeds threaten biological diversity of native plant communities, and can alter ecosystem processes such as intensity and frequency of fire, hydrologic cycles, and soil erosion rates. Weeds impact wildlife by reducing forage, modifying habitat, or changing how species interact within the environment. The effects on plant communities are summarized from the Botany Report Addendum for the Modoc National Forest Noxious Weed Treatment Project, and from the Design Standard, Description of Alternatives, and Specialist Reports in the Project Record. Direct and Indirect Effects Alternative 1 – No Action: Under the No Action Alternative, it is anticipated that weeds would continue to spread within the Modoc National Forest. As weeds increase, there would be a corresponding decrease in native plant cover and, subsequently, a decrease in intact native plant communities, and in plant diversity, especially where weeds spread to the point of becoming monocultures. Plant communities are aggregations of individual plants, and are somewhat stable, but do evolve over time. What affects the species, and species diversity, would also affect the communities in which they are included, and subsequently, diversity of plant communities. Soil erosion may increase because the root systems of weeds are generally less binding of soil particles, and those eroding and disturbed landscapes would be more susceptible to continued invasion by weeds. Alternative 2 would allow for an aggressive treatment program for noxious weed control, resulting in positive impacts to native plant communities and native plant diversity. Inadvertent trampling and injury of native plants and thus plant communities by the treatment crews could

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result, but the benefits from reduced competition for sunlight, water, space, and nutrients should outweigh these inadvertent side-effects of treatment. Depending on the herbicide used, there may be some loss of vitality or even death of some native plants if drift, runoff or subsurface movement moves herbicides to non-target areas and native plants take it up. Some herbicides are specific to certain groups (dicots vs. monocots) or families (grass or mustard family for example), and widespread spraying could selectively remove some of these. However, widespread spraying is not proposed. Herbicide treatments in this project would be by directed spray or wick. Therefore, although some individual plants may be affected, widespread removal of certain groups or families from plant communities would not result, nor would changes in direction of communities, from, say, mixed forb/grass to an all-grass community. Although physical treatment of weeds would remove individual plants, this treatment has the potential to increase noxious weed infestation by disturbing the soil and providing ideal conditions for the germination of the weed seed or overlooked rhizomes in the soil. New noxious weeds and new sites would not be treated, and in these places, native plant communities may become degraded during the project and plant diversity reduced. Alternative 3 could have beneficial impacts to native communities and native plant diversity as there would be some weed control implemented, and therefore native plant and weed competition would be reduced, and communities would remain intact. However, because some weed species may be spread as a result of ground disturbance or incomplete removal, there are caveats with this physical treatment only Alternative, especially since the life of the project is only five years, much less than the length of time that many noxious weeds seeds and propagules can still remain viable and re-infest the site. Physical treatment of weeds has the potential to increase weed infestation by disturbing the soil and thereby providing ideal conditions for the germination of the weed seed in the soil. New noxious weeds and new sites would not be treated, and in these places, native plant communities may become degraded even during the project, and native plant diversity reduced. As an example, cheatgrass and medusahead have invaded sagebrush communities within the Forest. These communities have been changed by the replacement of native grasses and many forbs with these non-native, invasive grasses, even though sagebrush is still there. The communities have changed in many places from sagebrush/native grass and forb to sagebrush/cheatgrass or sagebrush/medusahead. Some negative effects, such as inadvertent trampling by the treatment crews, could also result. Noxious weeds with rhizomes would not be treated in this Alternative. Consequently, native communities and diversity in those areas could continue to be negatively impacted from competition with these aggressive weeds. Areas with bare soil resulting from weed treatments that are greater than ¼ acre in size would be evaluated to assess a need for rehabilitation. Re-vegetation seed mixes have the potential to unbalance native communities nearby if not carefully chosen. However, these mixes would be designed on a site-specific basis to consider objectives and conditions at each site. Negative effects are not expected. Alternative 4 allows for the aggressive treatment of noxious weeds, utilizing a wide range of treatment methods. Due to the aggressive noxious weed treatment, Alternative 4 would, overall, be beneficial to native plant communities and diversity. Although some negative effects, such as inadvertent trampling by the treatment crews, could result, the benefits from reduced competition for sunlight, water, space, and nutrients should outweigh these inadvertent side effects of treatment.

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Depending on the herbicide used, there may be some loss of vitality or even death of some native plants if drift, runoff or subsurface movement moves herbicide to non-target areas. Physical treatment of weeds has the potential to increase noxious weed infestation by disturbing the soil and providing ideal conditions for the germination of the weed seed in the soil. Some herbicides are specific to certain groups (dicots vs. monocots) or families (grass or mustard family for example), and widespread spraying could selectively remove some of these. However, widespread spraying is not proposed. Herbicide treatments in this project would be by directed spray or wick. Therefore, although some individual plants may be affected, widespread removal of certain groups or families from plant communities would not result, nor would changes in direction of communities, from, say, mixed forb/grass to an all-grass community. All inventoried sites and new sites of the known 14 weeds would be treated over a period of 10 years, which is long enough to exhaust the seed bank of many of the 14 noxious weeds. This Alternative would be beneficial to native plant communities and plant diversity across the Forest. However, new weeds would not be treated, and native communities and plant diversity may therefore become degraded over time if new noxious weeds invade. Also see Direct and Indirect Effects under Alternative 2. Alternative 5, as with Alternative 3, a manual-treatment-only Alternative would have benefits to native plant communities and diversity. Occurrences of non-rhizomatous species other than the infestations over 500 acres would be treated and over time, some of these treated occurrences would be contained, controlled, or eradicated. The 913 acres (consisting of 7 sites) of rhizomatous weeds would receive limited treatment, and competition could be intense between native communities and weeds, with invasives taking over in many cases. Although new weeds and new sites could be treated for non-rhizomatous species, those that reproduce vegetatively would continue to grow, spread, and compete. Bare areas created by the treatment of noxious weeds would be evaluated for rehabilitation. Appropriate seed mixes and certified weed free mulch would be applied as needed so as not to compete or unbalance local native communities. Effects from the treatment of noxious weeds by goat grazing may include some removal or injury to native plants, but should not injure communities or native plant diversity. All goat grazing treatments would be carefully monitored to ensure that weed treatment objectives are met without damaging nearby native plant communities through trampling or overgrazing. Removal of noxious weeds by goats would eventually have a beneficial effect as native plant communities are restored to the site. See also Direct and Indirect Effects under Alternative 3. Alternative 6 would provide for the most variable and aggressive treatment of noxious weeds. Due to the number of weed control techniques available under Alternative 6, it would be expected to provide the most control of invasive species for treated sites. In the long term, outside of the 6,000-acre dyer’s woad site and the large common crupina site, it is expected that noxious weed populations would be greatly reduced, and in many cases, eradicated. In the long term, it is expected that native plant communities would have less competition for available water and nutrients, resulting in stable, healthy native plant communities. However, in the two large untreated infestations, native plant communities could become severely degraded. Cumulative Effects Alternative 1 – No Action: Natural events (fire, flood, drought, disease, insects, landslides, climate change) have affected plant communities in the past, and continue to do so. However, where native ruderal plants would reinvade after a natural disturbance, and, gradually, later-stage seral natives would move in, now noxious weeds, highly adapted to infesting disturbed sites, are just as likely to invade and take over these places, and change the conditions on those sites so that

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they remain in an early seral stage, inhabited primarily by the weeds themselves. (A ruderal plant is one that grows where natural vegetational cover has been disturbed by humans.) The effects of many past actions continue to affect native plant communities and plant diversity. Roads, railroads and power line construction and maintenance have created vectors or pathways for continuing weed infestation, and have essentially isolated some native communities from one another by creating barriers (isolating sections of a vernal pool, for example, by the raised bed of the track) or by changing intervening habitat -- open, dry and hot vs. shaded, moist, cool (such as a wide open swath for a power line) -- across which plants not adapted to those conditions cannot easily pass. Some past road maintenance has spread noxious weeds that were in the cinders and gravel of the borrow material, creating, in some cases, monocultures of weeds in place of native communities. Fire suppression has changed some plant communities by not selecting against non-fire adapted species, such as juniper. Canopy-cover removal during timber management and fuels reduction has changed understory soil moisture and light conditions – conditions necessary for some cool- forest communities. Plant communities that require low light and moist soil have subsequently been selected against in these places. Plantation-like conditions have replaced native communities in some cases. Road construction has changed hydrologic function and connectivity of springs and seeps, drying habitat and causing enough change in special aquatic features (such as fens) so that many no longer support communities they once had, such as sphagnum or three-ranked hump moss. Dam building, goose-nest island construction, and dug-outs for watering holes have changed the hydrology in the Devils Garden area, and subsequently, some vernal pool plant communities had been inundated, and others dried up, while vernal pool habitat may have been inadvertently created by other actions. Projects on the Forest continue to affect native plant communities and plant diversity. Pile burning can sterilize the soil and kill the native seedbed, creating disturbed openings where invasives can invade intact native communities and begin to disperse their propagules. Fire suppression continues to allow non-fire-adapted species to thrive, squeezing out fire-adapted species. Juniper has invaded native grasslands and sagebrush steppe, and changed these areas to juniper woodlands with little understory. Effects of reasonably foreseeable future actions include effects from projects that are on the schedule of Proposed Actions (SOPA). The proposed sagebrush steppe ecosystem restoration project could change the native plant communities over a large area of the Forest back to one that is less dominated by juniper. Recreation (OHV, horse riding, hiking, camping), firewood gathering, and many other activities have the potential to affect native communities and plant diversity. In the long-term, this gradual degradation of native communities could lead to a downward trend in extent and diversity of native plants and communities. Alternative 2: The five-year life span of this project would most likely not be sufficient to outlast the viability of most of the seeds of noxious weeds. Most likely weeds would begin to germinate from the seed bank after termination of the project, and over time, they could again become a source of competition with native plants and subsequently, communities. Also see Cumulative Effects under Alternative 1. Alternative 3: The 5-year life span of this project would most likely not be sufficient to outlast the viability of most of the seeds of noxious weeds. Most likely weeds would begin to germinate from the seed bank after termination of the project, and over time, again become a source of competition with native plants and subsequently, communities. Disturbance of the soil during implementation of this Alternative could provide a ready site for reinvasion of noxious weeds, or

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stimulate the weed seed bank. It is possible that on some sites the density of noxious weeds, over time, could become greater than at the beginning of the project. Also see Cumulative Effects under Alternative 1. Alternative 4: The 10-year life span of this project would most likely be sufficient to outlast the viability of many, but not all, of the seeds and propagules of noxious weeds. Most likely, weeds would begin to germinate after termination of the project, and over time, again become a source of competition with native plants and, subsequently, communities, unless a continuation of weed treatments is approved. Early Detection - Rapid Response would allow treatment of the same weeds with the same treatments on new sites or sites that have expanded, which would provide more effective treatment, and could result in the complete removal of many sites of the 14 known noxious weeds. However, Early Detection - Rapid Response would not address new noxious weeds, and therefore, these new species would be able to expand in size or occurrence number without treatment. Also see Cumulative Effects under Alternative 1. Alternative 5: The project would benefit native plant communities and plant diversity for the life of the project. However, seeds would remain viable on untreated sites, and the noxious weed seed bank would continue to accumulate there. Disturbance of the soil during implementation of this Alternative could provide a ready site for reinvasion of noxious weeds, or stimulate the weed seed bank if treatments are not done in a timely fashion. It is possible that on untreated sites the density of noxious weeds, over time, could become greater than at the beginning of the project, unless a continuation of weed treatments is approved. New sites and expanded sites and new noxious weeds can be treated in this Alternative through Early Detection - Rapid Response. This would eliminate any increase in competition to native plants and communities from new information. Also see Cumulative Effects under Alternative 1. Alternative 6: The project would benefit native plant communities and plant diversity for the life of the project. However, seeds would remain viable on untreated sites, and the noxious weed seed bank would continue to accumulate there. Disturbance of the soil during implementation of Physical+ treatments in this Alternative could provide a ready site for reinvasion of noxious weeds by stimulating the weed seed bank or weed rhizomes still in the soil. It is possible that on untreated sites the density of noxious weeds, over time, could become greater than at the beginning of the project unless a continuation of weed treatments is approved. Also see Cumulative Effects under Alternative 1.

Irreversible and Irretrievable Commitment of Resources Implementation of the action Alternatives with appropriate Design Standard would result in no ir- reversible or irretrievable loss of native plant communities and native plant diversity. Currently, these resources are at more risk from invasion and displacement by noxious weed populations.

Consistency with Forest Plans and Other Laws and Policies The Proposed Action and Alternatives are consistent with the Modoc NF Land and Resource Management Plan's goals for native plant and plant community diversity as outlined on page 4-2: to "provide vegetative diversity to maintain viable populations and other resource objectives, including scenic quality, wildlife, and reduced wildfire loss." These goals themselves as well as the Proposed Action and Alternatives are consistent with Federal NFMA regulations. 36 CFR 219.27 states that "All management prescriptions shall... provide for and maintain diversity of plant and animal communities," for multiple use objectives, and "preserve and enhance the diversity of plant and animal communities." See also FSM 2620.1 and 2622.01.

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Federally Listed and Watch List, and Plant Species Federally Listed Plant Species One threatened species occurs on the Modoc National Forest. Slender Orcutt grass, Orcuttia tenuis, is limited to relatively deep vernal pools or vernal pool-type habitat with clay soil. On the Modoc National Forest, most occurrences are in seasonally wet areas within sagebrush flats or ponderosa pine/juniper woodlands. The main habitat requirement for slender Orcutt grass is standing water of sufficient quantity and duration to drown out most competition from other plants and meet the physiological requirements for prolonged inundation, followed by a period of gradual (becoming total) desiccation (Corbin and Schoolcraft 1990). Slender Orcutt grass seeds germinate in the spring while under water, and plants send up long, floating leaves. As the pool dries, plants put out shorter terrestrial leaves, and then flowering stalks. Plants generally mature later than other vernal pool annuals, so often they are the only vegetation still green by mid-summer on the vernal pool bed. As an annual, it depends on seed set to replenish the seed bank for continued survival.

Direct and Indirect Effects Alternative 1: No Action: Noxious-weed infestatations spreading and out of control due to lack of treatment may reduce habitat areas of slender Orcutt grass. Alternatives 2, 4 and 6: No direct or indirect effects are expected to slender Orcutt grass from weed treatments in Alternatives 2, 4, or 6. Habitat requirements for slender Orcutt grass restrict other species un-adapted to the severe conditions of prolonged inundation, followed by a period of desiccation. Additionally, Design Standards would further protect rare plant species, including DS-33, no herbicide use within 100 feet of threatened or endangered plants. Herbicide use would not indirectly affect threatened and endangered plant species by impacts to invertebrate pollinator species such as bees and butterflies, as slender Orcutt grass is wind pollinated. It is unlikely that plants would be injured during physical + weed removal by digging or injury to the roots or stem, since the weed occurrences are in different habitat, such as on the raised bed of railroad right-of-way, whereas slender Orcutt grass occurs on the flat, vernal-pool areas. Alternatives 3 and 5: Direct and Indirect Effects: The habitat that slender Orcutt grass occupies is not susceptible to invasion, as discussed at length in the Biological Assessment (BA). Therefore, physical + treatments would not be so close to slender Orcutt grass that there would be direct or indirect effects. Noxious weeds anywhere near slender Orcutt grass are found on higher ground, such as railroad right-of-ways and dikes.

Cumulative Effects The effects from many past actions continue to impact native plants. Roads, railroads and powerline construction and maintenance have created vectors or pathways along which weeds can move from one location to another distant one. Vectors also provide habitat for continued weed infestation. Not only do these areas provide habitat for noxious weeds in places that normally would not support them (raised beds of railroads going across vernally wet meadows), the corridors give noxious weeds a foothold from which they can spread. These areas (such as a right-of-way for a powerline) isolate some native communities from one another by creating barriers or a drastically different intervening habitat—open, dry, and hot vs. shaded, moist,

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cool—across which un-adapted native plants cannot easily pass, nor cross-pollinate, leading to possible genetic problems in small populations. Some past road maintenance has spread noxious weeds that were in the cinders and gravel of the borrow material, creating, in some cases, monocultures of weeds in place of native communities that may have included native plants. This is especially true of medusahead, a C-rated noxious weed in Modoc County, which would not be treated in the project. Fire suppression continues to allow non-fire-adapted species to thrive, squeezing out fire-adapted species. Canopy-cover removal during timber management and fuels reduction has changed understory soil moisture and light conditions – conditions necessary for some cool-forest native plants. Plant communities that require low light and moist soil have subsequently been selected against in these places. Plantation-like conditions, where the diversity of understory plants is minimal, have replaced more diversified native communities, in some cases. Other forest activities, such as logging, thinning, prescribed fire, road building and road maintenance may result in habitat alteration and physical + injury to native plants, which may open up the habitat for invasive and noxious weed infestation. Dam building, goose nest island construction, and dug- outs for watering holes have changed the hydrology in the Devils Garden area. Subsequently, some vernal-pool plant communities have been inundated, and others dried up, while vernal-pool habitat may have been inadvertently created by other actions. Projects on the Forest continue into the present to have both positive and negative effects to native plants and habitat. Pile burning can sterilize the soil and kill the native seedbed, creating disturbed openings where weeds can invade and begin to disperse their propagules. Pile burning can also eliminate the native plant seed bank. Fire suppression and past overgrazing have allowed juniper to invade native grasslands and sagebrush steppe, and changed these areas to juniper woodlands with little understory.

`Irreversible and irretrievable commitment of resources Implementation of the action Alternatives with appropriate Design Standards will result in no irreversible or irretrievable loss of slender Orcutt grass.

Consistency with Forest Plan and Other Laws and Policies During review, it was determined that no habitat for slender Orcutt grass occurs within the proposed treatment areas. Alternative 6, will have “No Effect” on individuals or populations of slender Orcutt grass. No endangered plant species are known to occur on lands administered by the Modoc National Forest. The Modoc NF Land and Resource Management Plan was completed before the discovery of our only threatened plant, slender Orcutt grass (Orcuttia tenuis). However, management of noxious weeds as it relates to Threatened species is consistent with FSM 2670.2, which seeks to promote recovery efforts for Threatened species, and 2670.3, which places top priority on Threatened species recovery and directs us to "avoid all adverse impacts on threatened... species," and to "identify and prescribe measures to prevent adverse modification or destruction of critical habitat and other habitats essential for the conservation of... threatened... species." In this way, the Proposed Action and Alternatives are consistent with Forest Service objectives and policy, and with the Endangered Species Act. Sensitive Plant Species Forest Service Manual (FSM) 2670.5 defines sensitive species as “those plants and animal species identified by a Regional Forester for which population viability is a concern, as evidenced

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by significant current or predicted downward trends in population numbers, density, or habitat capability that reduce a species existing distribution.” In FSM 2670.22, management direction for sensitive species is, in part, to ensure that species do not become threatened or endangered because of Forest Service actions, and to maintain viable populations of all native species (U.S. Forest Service 1990a). In addition to Forest Service Region 5 sensitive species, the State of California keeps current listings for all state-sensitive species. The thirty sensitive species listed for the Modoc National Forest may have the potential to occur in treatment areas. Table K1-1 in Appendix K summarizes these species and the habitats in which they would most likely occur. Surveys for TES plants have been conducted in many areas across the Forest. Although surveys are not complete in all proposed treatment areas, sufficient analysis of the risks to TES plants can be accomplished with current information; prior to treatment, a survey may be conducted as part of development of the annual work plan. There are no known instances where sensitive plants and noxious weeds occur in such close proximity that the proposed control measures will impact the sensitive plants to such a degree that it will contribute to a trend towards federal listing or loss of viability to the population or species. The effects are summarized from the Biological Evaluation, Addendum, and Supplement for the Modoc National Forest Noxious Weed Treatment Project and from the Design Standard, Description of Alternatives, and Specialist Reports in the Project Record.

Direct and Indirect Effects All Alternatives: “Effects to all Sensitive Species From all Alternatives” has been prepared as part of the Addendum to the Biological Evaluation; none of the Alternatives in this project would cause a listing of any of the sensitive species. This determination was made through an assessment of risk for each species, using the factors of endemism, number of occurrences and number of plants per occurrence on the Forest, portion of known occurrences that are on the Forest, habitat vulnerability, whether a noxious weed currently exists within 50 feet, other threats, habitat alteration expected from the project, herbicide treatment expected within 50 feet, increased weed vectors as a result of the project, and the Design Standard under which that plant falls. Alternative 1 No Action: Identified noxious weeds can continue to grow and compete with sensitive plants for space and resources. New noxious weed species may become established and compete with sensitive plants. Noxious weeds that produce allelopathic substances (toxic chemicals produced that have a negative impact on other organisms) can prevent other plants, including sensitive plants, from growing in those locations. As weeds increase, there would be a corresponding increase in weed propagules, such as seeds and rhizomes, that could continue to spread the infestations, further reducing plants, populations, and/or habitat of sensitive species. Alternative 2 would allow for an aggressive treatment program for noxious weed control. Reductions in occurrences of the treated weeds, and in size of the occurrences, would be expected. Since new weeds and new or expanding occurrences would not be treated, the overall area occupied by noxious weeds on the Forest may actually be able to increase. If this happens, noxious weeds would most likely compete aggressively for resources with some sensitive plant species. Production of weed propagules would be reduced on the sites treated, although there still would be viable noxious weed seed in the seed bank on termination of this five-year program, as many weed seeds remain viable for years – up to 30 years for Scotch thistle. With the removal of

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competitive noxious weeds at the treated sites, sensitive plants and habitat could be enhanced in those areas. Since herbicides are designed to kill plants, and, therefore, some damage to sensitive plant species is possible despite cautious planning and implementation. Some native plants, including sensitive species, may be injured or killed. Sensitive plants could also be damaged or removed during physical or herbicide treatment, either directly or indirectly, such as by trampling or exposing roots. Herbicide spray, drift, runoff, leaching, or groundwater movement may result in mortality to individuals, reduce their productivity, or lead to abnormal growth patterns. For ground applications of herbicides, the closer the sensitive species is to the application site, the greater is the likelihood of damage. Specific Design Standard for the different Alternatives address how close herbicide treatments can come to sensitive plants. Even if plants were injured or killed, in no case is this determined to lead to a listing of any sensitive plant species on the Forest. During herbicide application, the level and extent of damage to sensitive plants depends, in part, on site-specific conditions, such as wind speed. Application instructions for each herbicide must be followed by the applicator, and can be found in the label directions. Herbicides can move off- site in water, soil and wind. Site-specific soil and water characteristics, as well as herbicide formulation characteristics, affect this movement. Effects from herbicide movement are reduced by Design Standards (please see FEIS for a listing by Alternative). The potential to harm sensitive species is also dependent on herbicide characteristics. Herbicides vary as to their potency, selectivity, and persistence. These factors all play a role in how much harm can occur. Measures taken to limit exposure, such as application methods, may reduce herbicide movement off-site. Some bare ground may be exposed during physical treatments as the weeds are removed, and noxious weeds, since they are aggressive invaders, may again take over these bare places. Herbicide treatment is less likely to be ground disturbing, and thereby, less likely to expose fresh soil for invasion. New noxious weed species, and new and expanded sites, would not be treated in this Alternative. This potentially leaves these weeds and locations as sources of weed plants and propagules that may compete with sensitive plants. As noxious weeds are removed, natives, including sensitive plants, have the chance of replacing them, or natives may be reseeded at sites that are too large to reseed naturally in a timely fashion, before weeds again take over. Seeded species could potentially compete with sensitive species. Alternative 3 would result in the reduction of some noxious weeds, and consequently, reduction in competition with sensitive plants, for a period of five years. However, only non-rhizomatous weeds would be treated, and, therefore, the rhizomatous species would continue to grow— possibly expanding in occurrence size—and produce propagules that could spread those weeds. Several occurrences of sensitive plants are within 50 feet of rhizomatous noxious weeds. These occurrences could be extirpated if weeds are not controlled. No Early Detection - Rapid Response would be included in this Alternative, and therefore new sites, expanded sites, or new noxious weeds would not be treated, allowing for untreated, expanding noxious weed infestation, and most likely, additional competition to sensitive plants. Some bare ground may be exposed during physical treatments as the weeds are removed, and noxious weeds may again invade these bare, disturbed places. Or, as noxious weeds are removed, natives have the chance to replace them, or may be reseeded at some sites.

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Some native plants, including sensitive species, may be injured or killed by the treatment methods either directly or indirectly, as by trampling or inadvertent mechanical injury. Alternative 4 provides for aggressive treatment of noxious weeds, utilizing a wide range of treatment methods. All known noxious weed infestations, including rhizomatous species, would be treated by herbicide or physical methods. This Alternative would be in effect for 10 years, instead of the five years of Alternatives 2 and 3, and therefore, the chances for complete removal of occurrences of noxious weeds would be more likely, especially for smaller infestations. Early Detection - Rapid Response would allow treatment of the same weeds with the same treatments on new sites or sites that have expanded, which would provide more effective treatment, and could result in the complete removal of many sites of the 14 known noxious weeds. However, Early Detection - Rapid Response would not address new noxious weeds, and therefore, these new species would be able to expand in size or occurrence number without treatment. As noxious weeds are removed, sensitive plants have the chance to replace them, if the habitat is appropriate. Sensitive plants and habitat would be enhanced by this Alternative, except in the case of new noxious weeds, which would be allowed to compete and degrade sensitive plants and habitat. Some sensitive plants may be injured or killed by the treatment methods, both physical and herbicide, either directly or indirectly. Please see Direct Effects under Alternative 2. Alternative 5 would result in the reduction of some noxious weeds, with the accompanying reduction in competition to sensitive plants and degradation of their habitat. However, two large infestations – one of dyer’s woad and one of common crupina – would not be treated. Sensitive plants that might be within those two infestations may experience reduced vigor, and their habitat may become degraded. Only small infestations of non-rhizomatous weeds would be treated, and, therefore, the larger occurrences of rhizomatous species would continue to grow—possibly expanding in occurrence size—and produce propagules that could spread those weeds. Expanding populations of these species could impact Columbia yellow cress and scalloped moonwort, two sensitive species within 50 feet of larger infestations of Canada thistle. Rhizomatous noxious weeds that have not been eliminated completely would be expected to re-infest areas, and possibly come back in denser stands, competing aggressively with any sensitive plants. Physical+ treatments have been found to stimulate the roots of rhizomatous species, and even the small occurrences treated in this Alternative, unless treated persistently over a long time, may not effectively control or eliminate these species, providing no relief if sensitive plants are nearby. New sites and expanded sites and new noxious weeds can be treated in this Alternative through Early Detection - Rapid Response. This would eliminate any increase in competition to sensitive plants from new information. It is unknown what new sites might be discovered under Early Detection - Rapid Response. No effect to sensitive plants is expected from treatment of noxious weeds by goat grazing. It would be limited and fences and herders would control the goats. Also, refer to the direct and indirect effects for Alternative 3. Alternative 6: Due to the number of weed-control techniques available under Alternative 6, it would be expected to provide for the most variable and aggressive treatment and control of noxious weeds, on those acres treated, and enhancement for those sensitive species that occur near those treated sites. However, the treated acres would be much less than in Alternatives 2 and 4. The 6,000-acre dyer’s woad site and the large common crupina site would receive limited perimeter treatments, and, therefore, large acreages would be left untreated, and sensitive plant habitat that might occur in those areas could continue to become more degraded as noxious species increased in density. On the sites where treatment would take place, it is expected that noxious weed populations would be greatly reduced, and sensitive plants and habitat would be enhanced.

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Physical+ treatment of weeds would remove noxious weeds where treatment can occur, but has the potential to increase noxious weed infestation by disturbing the soil and providing ideal conditions for the germination of the weed seed in the soil. Although sensitive plants would benefit from weed removal, if weeds competitively germinate on the disturbed soil, the benefit may be lost. New sites and expanded sites and new noxious weeds can be treated in this Alternative, and therefore these new occurrences most likely would be controlled or eliminated. Please see discussion under Direct Effects for Alternative 2, 4, and 5.

Cumulative Effects Alternative 1 – No Action: Natural events (fire, flood, drought, disease, insects, landslides, climate change) have affected sensitive plants in the past, and continue to do so. Where, normally, native ruderal plants would reinvade after a natural disturbance, and, gradually, later- stage seral natives, including sensitive plants, would move in, now noxious weeds, highly adapted to infesting disturbed sites, are just as likely to invade and take over these places, and change the conditions on those sites so that they remain inhabited primarily by the weeds themselves, not giving natives and sensitive plants a chance to grow on the site. Discussing the potential cumulative effects of natural disturbance is beyond the scope of this analysis. The effects from many past actions continue to impact sensitive plants. Roads, railroads and powerline construction and maintenance have created vectors or pathways for continuing weed infestation, in addition to removal or injury. Not only do these vectors encourage noxious weeds to compete with natives along these corridors, but also these swaths isolate some native communities from one another by creating barriers or changing intervening habitat—open, dry and hot vs. shaded, moist, cool (such as a wide open swath for a powerline)—across which un- adapted sensitive plants cannot easily pass, and cross-pollinate, leading to possible genetic problems in small populations. Some past road maintenance has spread noxious weeds that were in the cinders and gravel of the borrow material, creating, in some cases, monocultures of weeds in place of native communities that may have included sensitive plants. This is especially true of medusahead, a C-rated noxious weed in Modoc County, which would not be treated in the project. Fire suppression continues to allow non-fire-adapted species to thrive, squeezing out fire-adapted species, such as the sensitive plant Bakers globemallow. Canopy cover removal during timber management and fuels reduction has changed understory soil moisture and light conditions – conditions necessary for some cool-forest communities and sensitive plants such as mountain lady slipper. Plant communities that require low light and moist soil have subsequently been selected against in these places. Plantation-like conditions, where the diversity of understory plants is minimal, have replaced more diversified native communities, in some cases. Road construction and trampling by cows have changed hydrologic function and connectivity of springs and seeps, drying habitat and causing enough change in special aquatic features (such as peatlands) so that, where once these plants had habitat, habitat no longer exists for sensitive plants such as moonworts, two species of hump moss, and bug-on-a-stick moss. Cow trails continue to cut across sensitive plant habitat for Ash Creek ivesia, trampling individuals and degrading habitat. Dam building, goose nest island construction, and dug-outs for watering holes have changed the hydrology in the Devils Garden area, and subsequently, some vernal pool plant communities had been inundated, and others dried up, while vernal pool habitat may have been inadvertently created by other actions. Projects on the Forest continue into the present to affect sensitive plants and habitat. Pile burning can sterilize the soil and kill the native seedbed, creating disturbed openings where weeds can invade and begin to disperse their propagules. Pile burning

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can also eliminate the sensitive-plant seed bank. Fire suppression and past overgrazing have allowed juniper to invade native grasslands and sagebrush steppe, and changed these areas to juniper woodlands with little understory. Ash Valley milkvetch and crown milkvetch, both sensitive species, have habitat in the sagebrush steppe. Effects of reasonably foreseeable future actions from projects that are on the schedule of Proposed Actions (SOPA) include plant community changes from the proposed Sagebrush Steppe Ecosystem Restoration Project. This project covers a large area of the Forest, and plans are to revert back to a landscape less dominated by juniper. The effect to sensitive milkvetches is predicted to be enhancement of habitat. Recreation (OHV use, horse riding, hiking, camping), firewood gathering, and many other activities have the potential to affect sensitive plants and habitat by trampling, spreading weed seeds, and picking. Lady slipper orchids are especially prone to collection by rare plant enthusiasts and casual pickers. In the long term, this gradual degradation of native and sensitive plant communities and habitats could lead to loss of some of these species from the Forest. In the foreseeable future, however, it is unlikely that Alternative 1 would lead to a listing of any sensitive plant species on the Forest. Alternative 2: There could be an additive cumulative effect to susceptible non-target species if herbicide use is repeated over time on the same site. This cumulative effect would be most likely where the treatment toolbox is most limited (as in Alternatives 2 and 4). However, this effect is generally only found where spray is broadcast, a method that would not be used in this project. Over a five-year period, sensitive plants would have to compete less with noxious weeds, and noxious weeds would be less of a threat to sensitive plant habitat. After five years, if a new decision document to control noxious weeds is not approved; noxious weeds may again start to encroach on sensitive-plant habitat. Also, see Cumulative Effects under Alternative 1. Alternative 3: Physical treatment of noxious weeds could create more disturbed ground that is prime habitat for aggressive noxious weeds. Unless this project is continued to outlast the seed bank, and desirable species seed in naturally or from cultural treatments, these areas could become dense weed patches upon termination of the project, effectively keeping out sensitive species. Rhizomatous noxious weeds would continue to grow and occurrences may increase in size. New sites and expanded sites may continue to grow unimpeded and new noxious weeds that invade would be allowed to grow and infest the Forest. Weed seed banks would not be treated, and these may be a continuing source of noxious weeds. Noxious weeds would most likely continue to compete with sensitive plants. Also, please see Cumulative Effects under Alternative 1. Alternative 4: Due to the aggressive noxious weed treatment, overall noxious weed infestations would diminish across the Forest, which would improve the situation for sensitive plants that are competing with those species. Only the largest occurrences of rhizomatous species may still have plants at the end of 10 years, with possible effects to Columbia yellow cress and scalloped moonwort, two sensitive plants within 50 feet of infestations of Canada thistle. Physical treatment of noxious weeds could potentially create more disturbed ground, prime habitat for aggressive noxious weeds. Unless this treatment is continued to outlast the seed bank, these areas could become dense weed patches upon termination of the project in 10 years, and provide a new flush of competition with sensitive plants several years later. An Early Detection Rapid Response Strategy (EDDR) would be implemented to treat new sites of the identified species; however, new weed species would not be treated. Therefore, new weed species may invade and compete with sensitive plants.

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Weed seed banks would not be treated, and these may be a continuing source of noxious weeds. Also, please see Cumulative Effects under Alternative 2. Alternative 5: The large, untreated sites could become a source for many, new satellite sites if careful, annual inventory is not performed. Physical+ treatment of noxious weeds could create more disturbed ground that is prime habitat for aggressive noxious weeds to reinfest and compete with sensitive plants. Unless this treatment is continued to outlast the seed bank, and desirable species seed in naturally or from cultural treatments, these areas could become dense weed patches upon termination of the project. Untreated rhizomatous noxious weeds would continue to grow and occurrences may increase in size. Under EDRR, new sites and expanded sites and new noxious weeds can be treated in this Alternative, and therefore these new occurrences most likely would be controlled or eliminated since they most likely would be small. Weed seed banks would not be treated, and these may be a continuing source of noxious weeds. Due to the number of weed control techniques available under Alternative 6, it would be expected to provide for the most variable and aggressive treatment and control of noxious weeds on those acres treated, and enhancement for those sensitive species that occur near those treated sites. Also, please see Cumulative Effects under Alternative 3. Alternative 6: Due to the number of weed-control techniques available under Alternative 6, it would be expected to provide for the most variable and aggressive treatment and control of noxious weeds on those acres treated, and enhancement for those sensitive species that occur near those treated sites. Noxious weeds on the large, untreated sites would probably increase in density, further degrading habitat for native species and sensitive plants. These sites could also become a source for many, new satellite sites if careful, annual inventory is not performed, and subsequently provide aggressive competition to sensitive plants. Untreated rhizomatous noxious weeds would continue to grow and occurrences may increase in size. Sensitive plants nearby could be negatively affected by increased competition for resources. Under EDDR, new sites and expanded sites and new noxious weeds could be treated in this Alternative, and therefore these new occurrences most likely would be controlled or eliminated since they most likely would be small. Alternative 5 discusses the impact of Early Detection - Rapid Response on sensitive species. Weed seed banks would not be treated, and these may be a continuing source of noxious weeds. Also, please see the Cumulative Effects discussion under Alternatives 2, 4, and 5.

Irreversible and irretrievable commitment of resources Implementation of the action Alternatives with appropriate Design Standards will result in no irreversible or irretrievable loss of sensitive plants. Currently, sensitive plants are more at risk from invasion and displacement by noxious weed populations.

Consistency with Forest Plans and Other Laws and Policies The Proposed Action and Alternatives are consistent with the following management objectives in the Modoc N.F. Forest Plan, as amended: The Modoc N. F. Forest Plan directs us to "manage and conserve sensitive plant species and their habitats to insure that viable populations are maintained," in order to insure that "federal listing as threatened or endangered species is unnecessary (Modoc NF Forest Plan 1991, 4-21)." To these ends, the Modoc National Forest is directed to "develop and implement a consistent, systematic, biologically sound program for sensitive plant species (ibid, 4-21)." Combating noxious weeds is an important part of conserving sensitive plant species and their habitats; the Proposed Action and

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its Alternatives are part of a consistent, systematic, and biologically sound program for the implementation of sensitive-plant conservation. Watch List Plant Species A number of plant species reviewed for Regional Sensitive Species list revision did not meet the criteria to be included on the Forest Service Region Five List, but are of more localized concern and need to be considered in the planning process. These include species that are locally rare (as opposed to declining throughout their range), are of public concern, occur as disjoint populations, are newly described taxa, lack sufficient information on population size, threats, trend, or distribution, etc. These watch lists are dynamic and updated as the need arises to reflect changing conditions and new information. The creation of the sensitive species and watch lists are key steps in meeting our commitment as an agency to maintain biologically diverse and healthy ecosystems (CNPS Inventory, 2001). The 69 watch list plant species listed for the Modoc National Forest may have the potential to occur in treatment areas. Table K1-2 in Appendix K summarizes these species and the habitats in which they would most likely occur. Surveys for watch list plants have been conducted in many areas across the Forest. Although surveys are not complete in all proposed treatment areas, sufficient analysis of the risks to watch list plants can be accomplished with current information; before any treatment is accomplished a survey would be done. There are no known instances where watch list plants and noxious weeds occur in such close proximity that the proposed control measures would impact the watch list plants to such a degree that it would contribute to a trend towards federal listing or loss of viability to the population or species. This effects section below is summarized from the Botanical Report and Addendum for the Modoc National Forest Noxious Weed Treatment Project and from the Design Standard, Description of Alternatives, and Specialist Reports in the FEIS. Watch list plants make an important contribution to forest biodiversity, and analysis can be summarized from plant community, plant diversity, and sensitive plant species information. Two watch list species are known to exist within 50 feet of proposed weed treatment sites. Bogg’s Lake hedge-hyssop (Gratiola heterosepala) exists near two proposed treatment sites for Scotch thistle at Emigrant Springs, DG036ONAC and DG037ONAC. Habitat for this watch list species is marshes and swamps (lake margins), vernal pools/clay. The Forest has 18 occurrences of this species, ranging in size from two to more than 10,000 individuals. One occurrence of Baker’s globemallow exists near a dyer’s woad within the Long Damen burn. There are at least 47 known occurrences of Baker’s globemallow, with many more most likely within the boundaries of the Blue Fire that burned in the Warner Mountains in 2000. This species is a fire- follower, and impacts to its existence would most likely come from fire suppression rather than noxious weed treatments.

Direct and Indirect Effects The direct and indirect effects for watch list plant species would be the same as for sensitive plant species. Please see the discussion under sensitive plants (above).

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Cumulative Effects Cumulative effects for watch list plant species would be the same as for sensitive plant species, for Alternatives 1 through 5. Please see the discussion under sensitive plants (above). Alternative 6: Noxious weeds on the large, untreated sites would probably increase in density, further degrading habitat for native species and watch list plants. These sites could also become a source for many, new satellite sites if careful, annual inventory is not performed. These weeds could subsequently provide aggressive competition to watch list plants. Untreated rhizomatous noxious weeds would continue to grow and occurrences may increase in size. Watch list plants nearby could be negatively affected by increased competition for resources. New sites and expanded sites and new noxious weeds could be treated in this Alternative, and therefore these new occurrences most likely would be controlled or eliminated since they most likely would be small. Weed seed banks would not be treated, and these may be a continuing source of noxious weeds. Also, please see the Cumulative Effects discussion under Alternatives 2, 4, and 5.

Consistency with Forest Plans and Other Laws and Policies The Proposed Action and Alternatives are consistent with the Modoc NF Land and Resource Management Plan's goals for native plant and plant community diversity as outlined on page 4-2: to "provide vegetative diversity to maintain viable populations and other resource objectives, including scenic quality, wildlife, and reduced wildfire loss." These goals themselves as well as the Proposed Action and Alternatives are consistent with Federal NFMA (National Forest Management Act) regulations. 36 CFR 219.27 states that "All management prescriptions shall... provide for and maintain diversity of plant and animal communities," for multiple use objectives, and "preserve and enhance the diversity of plant and animal communities." See also FSM 2620.1 and 2622.01. Wildlife and Fish The Modoc National Forest is home to more than 350 species of wildlife and fish that utilize a wide variety of different or combinations of various habitats. The Modoc National Forest established its wildlife and fish program objectives in its Land and Resource Management Plan (Forest Plan), as amended by the Sierra Nevada Forest Plan and the Northwest Forest Plan. To implement wildlife and fish objectives, the Forest uses a subset of species called “Management Indicator Species.” The Forest Plan sets forth standards and guidelines for these Management Indicator Species. “They [Management Indicator Species] are designed to maintain viable populations of all existing native and desired non-native vertebrate species within the planning area” (Forest Plan, p. 4-25). These Management Indicator Species include federally listed threatened and endangered species [Endangered Species Act (ESA)], Forest Service Sensitive species (FSM 2670), and other Management Indicator Species (harvest species, ecological indicator species, and special-interest species). Management requirements for these species are listed in the Forest Plan Standards And Guidelines, as well as the various land allocations and prescriptions that provide habitat. However, management direction (both within and supplemental to the Forest Plan) for federally listed species provides enhancement of present population levels, as required by ESA. Federally listed species are designated because low population levels and loss of habitat may eventually render them extinct. The Forest Service management centers on achievement of recovery plan goals. The Forest is required to consult with the U.S. Fish and Wildlife Service (USFWS) whenever the Forest initiates any activity which may affect a federally listed T&E

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species. The Biological Assessments (BAs) prepared for wildlife and fish species documents the potential effects of the Proposed Action on federally listed species. The Biological Assessments are summarized below and may be found in their entirety in the Appendix Volume. Forest Service sensitive species are those species needing special management emphasis to ensure their viability, and to preclude trends toward endangerment that would result in their federal listing. The sensitive species are taken from the most current Pacific Southwest Region (R-5) Regional Forester’s Sensitive Species list dated 8 June 1998. The Biological Evaluations (BEs) for wildlife and fish prepared for this project documents the effects of the Proposed Action on sensitive species. For the Modoc NF, 32 species of wildlife and fish (FLRPM, Page 3-37) are defined as Management Indicator Species. The categories are Threatened and endangered (T&E), Sensitive species, and Other MIS. Other MIS include harvest species, ecological indicator species, and special interest species. The MIS, along with their monitoring requirements, are listed in Table 3- 69 below, as well as on page 3-97 of the Modoc National Forest, Final Environmental Impact Statement for the Land and Resource Management Plan (1991). A Management Indicator Species analysis for wildlife species was prepared to document the potential effects of implementation of the Proposed Action on these species. The analyses of Management Indicator Species are found in the BA, BE, and the MIS documents prepared for this project, which are summarized below and published in their entirety in the Appendix Volume. On January 10, 2001, President Clinton signed an Executive Order (Executive Order 13186) that required Federal Agencies to promote the conservation of migratory birds. The EO requires federal agencies to incorporate migratory bird habitat and population management objectives and recommendations into all phases of agency planning processes as appropriate. In order to do so, the Forest Service identifies management practices that may impact populations of migratory birds and develops management objectives or recommendations that avoid or minimize these impacts through the land management planning process. The MIS and TES species identified in the Forest Plan include several species of migratory birds, some of which are identified by USFWS as migratory species. The potential effects for all of these species are discussed below and in the supporting documentation. The fisheries section has been divided into four subsections: General Fisheries and Aquatic Resources Habitat Conditions and Threats, Threatened and Endangered Aquatic species, Forest Service Sensitive Aquatic species, and other Aquatic Management Indicator Species. The terrestrial wildlife section has been divided into four subsections: General Discussion of Effects of Selected Herbicides on Terrestrial Wildlife, Federally Listed Terrestrial Wildlife Species, Sensitive Terrestrial Wildlife Species, and Other Wildlife Management Indicator Species. The comments received on the DEIS focused on the effects of herbicide treatments on humans and wildlife species, including aquatic, terrestrial, and macro invertebrates. Commenters wanted to see specific analysis for each species and the effects of specific herbicides. The specialist reports which include the BAs, BEs and MIS reports are contained in their entirety in the Appendix sections U, V, and W in Volume 2, and the wildlife and riparian sections of the Response to Comments Volume are all summarized in the following sections.

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Fish and Aquatic Wildlife Species

Risk Assessment Information – Specific Sites Aquatic systems and riparian habitats are not the targets of herbicide treatment in this project; therefore, the effects to these systems and habitats should rarely occur and with low intensity. In this analysis, the Forest excluded all sites that were greater than 100 feet from water because the potential for contamination from the chemical was essentially zero because the chemical does not move that far off site under typical conditions. Typical conditions were described in the FEIS and were tied back to labeling requirements (wind speed, time until precipitation, droplet size, temperature limits for volatilization, etc.) For further information see the Project File, Volume 2, Part 2, Appendix U, Fish and Aquatic. The following are specific noxious weed occurrences within 100 feet of TES species habitat. WM012CIAR4 – This is a Canada thistle site of 0.08 acres. It is located near Fitzhugh Creek which is occupied by the Goose Lake redband trout. There are approximately 100 plants in the area. WM003LIDA – This is a Dalmatian toadflax site of 8.25 acres near Lassen Creek which is occupied by the Goose Lake redband trout. BV006CEDI3 – This is a Diffuse Knapweed site of 0.06 acres near Johnson Creek which is occupied by the Goose Lake redband trout and Modoc sucker. There are more than 100 plants in the area. BV004CEDI3 - This is a Diffuse Knapweed site of 0.08 acres near Johnson Creek which is occupied by the Goose Lake redband trout and Modoc sucker. There are more than 1000 plants in the area. BV006CEDI - This is a Diffuse Knapweed site of 0.87 acres near Johnson Creek which is occupied by the Goose Lake redband trout and Modoc sucker. There are approximately 100 plants in the area. WM002ISTI – This is a dyer’s woad site of 2.58 acres near Buck Creek which is occupied by Goose Lake redband trout. BV001SAAE – This is a Mediterranean sage site of 0.27 acres near Johnson Creek which is occupied by the Goose Lake redband trout and Modoc sucker. There are more than 100 plants in the area. BV260ONAC – This is a Scotch thistle site of 0.10 acres near Johnson Creek which is occupied by the Goose Lake redband trout and Modoc sucker. There are more than 100 plants in the area. BV002CEMA4 – This is a Spotted knapweed site of 0.31 acres near Johnson Creek which is occupied by the Goose Lake redband trout and Modoc sucker. There are approximately 300 plants in the area. BV117ONAC – This is Scotch thistle site of 0.15 acres near Ash Creek which is occupied by Modoc sucker. DG043ONAC – This is a Scotch thistle site of 0.09 acres near Cottonwood Campground. This is within Modoc sucker habitat. DG005CIAR4 – This is a Canada thistle site of 0.10 acres along the Fairchild Swamp ditch which is shortnose sucker habitat. This ditch is often seasonally dry.

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DG006CIAR4 - This is a Canada thistle site of 0.09 acres along the Fairchild Swamp ditch which is shortnose sucker habitat. This ditch is often seasonally dry. DG016CIAR4 - This is a Canada thistle site of 0.09 acres along the Fairchild Swamp ditch which is shortnose sucker habitat. This ditch is often seasonally dry. DH012CIAR4 – This is a Canada thistle site of 0.08 acres along Willow Creek near Clear Lake Reservoir, habitat for the Lost River and shortnose sucker. Total habitat affected: Lost River sucker, shortnose sucker, and Modoc sucker (endangered) is 2.29 acres. Goose Lake redband trout (sensitive) is 12.6 acres. There is overlap in the distribution of the Modoc sucker and Goose Lake redband trout, so the total area affected is 13.2 acres.

General Fisheries and Aquatic Resources: Habitat Conditions and Threats to Federally Listed Fish and Aquatic Wildlife Species The analysis area for this document includes the entire Modoc National Forest. This area encompasses about 1.6 million acres of Forest System lands as well as 337,000 acres of lands administered by other agencies or private landowners. The Forest has an incredibly diverse series of habitats ranging from sagebrush at the lowest elevations to white bark pine at the highest elevations. The table below documents the threatened, endangered, and proposed fish species that are present on the Forest. The USDI Fish and Wildlife Service letter dated July 11, 2005 (1-10- 05-105-SP) was used to determine the species that should be included in this analysis.

Table 3 - 67. Federally Listed Fish Species That Occur on or Downstream of the Modoc National Forest

Occur on Also Common Name Scientific Name Status Forest Forest MIS Shortnose sucker Chasmistes Endangered X X brevirostris Lost River sucker Deltistes luxatus Endangered X X Modoc sucker Catostomus microps Endangered X X Warner sucker Catostomus Threatened warnerensis Shasta crayfish Pacifastacus fortis Endangered Management Direction and Existing Conditions Management for the Forest is detailed in the Modoc National Forest Land and Resource Management Plan (Forest Plan)(1991), Lost River and Shortnose Sucker Recovery Plan (1993), Final Rule of Endangered Status and Critical Habitat for Modoc Sucker (1985). The following section provides a very brief account of the distribution and types of habitat utilized for each species analyzed within this document. Detailed species accounts for the Lost River sucker, shortnose sucker, and Modoc sucker can be found in previous Biological Consultations #1-1-96-F-57 and 1-10-96-F-35, Modoc National Forest Long Term Grazing Program.

Shortnose and Lost River Sucker Existing Conditions These species are found within the Lost River drainage on Devil's Garden and Doublehead Districts; these fish are known to be widespread in Willow, Boles, and Fletcher Creeks as well as in pools and wetlands. Primarily lake residents, the fish have been documented to successfully

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spawn, and live year round on the Forest. Radio-telemetry studies on these fish are on-going by National Biological Survey (NBS) and Bureau of Reclamation (BOR) personnel. Habitat for these species consists of open water in lakes and streams, except when they move upstream to spawn. Fish begin making short migrations up into streams when discharge increases at any time from early February through early April, although March is probably the most frequent month of movement. It appears that the spawning requirements for Lost River sucker are somewhat narrower than the shortnose sucker. In Willow Creek radio-tagged suckers were found to migrate only 3-6 km and remain on spawning grounds for 2-3 weeks (Perkins and Scoppetone 1996). The Lost River sucker requires well graveled riffles (>50%), although they will occasionally utilize well oxygenated spawning substrates upwelling springs. According to Perkins et al. (1995) they have evolved different feeding strategies. Apparently Lost River suckers are bottom feeders, while shortnose suckers feed on smaller food items within the water column.

Modoc Sucker Existing Conditions The Modoc sucker historically occurred in small tributaries of the Upper Pit River in Lassen and Modoc Counties, California, but is now found only in portions of two small drainage systems in Modoc County. Preferred habitat of the species consists of small streams characterized by large shallow pools with cover, soft sediments, and clear water. Food of the Modoc sucker consists of benthic invertebrates, algae, and detritus. During spring spawning runs, the species ascends creeks or tributaries that may be dry during summer months. A 1978 California Department of Fish and Game survey reported the species from eight creeks: Washington, Hulbert, Turner, Willow, Ash, Dutch Flat, Johnson, and Rush. Additional streams were inhabited by the species historically, but its small, often seasonally flowing stream habitat indicates that Modoc suckers may have never been common. Habitat degradation has removed natural barriers and allowed hybridization with the related Sacramento sucker (Catostomus occidentalis), threatening the genetic integrity of the Modoc sucker. On June 11, 1985, the Fish and Wildlife Service determined the Modoc sucker to be an endangered species. Critical habitat was also designated for the Modoc sucker. A designation of critical habitat does not create a management plan for a listed species. Designation does not automatically prohibit certain actions, establish numerical population goals, or prescribe specific management actions (inside or outside of critical habitat). However, critical habitat may provide added protection for areas designated and thus assist in achieving recovery. Areas designated as critical habitat receive protection under Section 7 of the Endangered Species Act with regard to actions carried out, funded, or authorized by Federal Agencies.

Warner Sucker Existing Conditions The Warner sucker is endemic to the streams and lakes of the Warner Basin in south-central Oregon. Early residents of the area recalled when the suckers and other fishes were very abundant and would ascend the creeks in the spring to spawn. The Warner sucker is currently known to occur in portions of Crump and Hart Lakes, the spillway canal north of Hart Lake, and portions of Snyder, Honey, Twenty mile, and Twelve mile Creeks. Suitable habitat includes large, shallow natural lakes, although fish would spread into sloughs and seasonal lakes during wet year; some resident fish are found in low gradient streams as well (Williams et al. 1989). Warner suckers use low to moderate gradient streams for spawning and rearing. In streams, larvae drift feed on zooplankton near the surface and as they get older then switch to foraging on algae and associated benthic food items (Kennedy). No treatments are being proposed within 5 miles of this species or its habitat. Therefore, there would be no direct, indirect, or cumulative effects to this species or its habitat.

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Shasta Crayfish Existing Conditions The range of the Shasta crayfish is very limited occurring only within the mid section of the Pit River drainage system of Shasta County. It is grouped into eight geographically isolated populations. One of these populations, the Fall River/Fall River Mill population, is considered to be extirpated. The total population in 1978 was estimated to be fewer than 6,000 individuals (Daniels 1980). Subsequent loss of habitat points to a 1988 population that probably numbered fewer than 3,000 individuals. They have a low abundance and their distribution is highly fragmented. Migration and genetic exchange between populations is limited by hydroelectric development, natural barriers, and loss of habitat (USFWS 1998). Shasta crayfish are found in cool, clear springs, lakes, and streams, frequently at or near a spring source, in areas with abundant volcanic rubble or boulders for escape cover from predators (Light and Clarke 1991). They prefer boulder/cobble substrate, but will also use silty substrate as long as rocks are not embedded. They have been observed using aquatic vegetation for cover, but use of vegetation is uncommon. The species prefers areas of water movement as in locations with distinct flow from a spring source. They are found in all habitat types, such as pools, riffles, and runs, but prefer runs. Hydroelectric developments have resulted in habitat loss and fragmentation. The introduction of nonnative crayfish species, particularly the signal crayfish, introduction of nonnative game fish species, pathogens from introduced species, hatchery management, trout habitat restoration, and Cray fishing have also contributed to a population decline. Sedimentation of lava substrate preferred by Shasta crayfish has been brought about through canalization, dredging, logging, forest fires, culverts and bridges, agriculture, grazing, and muskrat activity. This species was listed as a Federal endangered species in 1988. Critical habitat has not been designated. There is no habitat for Shasta Crayfish on the Modoc National Forest. This species only occurs about 25 miles west of the Modoc National Forest primarily in the Fall River and Hat Creek sub- drainages of the Pit River in Shasta County. Therefore, there would be no direct, indirect, or cumulative effects to this species or its habitat. Effects of Alternatives on the Lost River, Shortnose, and Modoc Suckers

No-Action Alternative (Alternative 1) Direct and Indirect Effects: Potential adverse effects to the aquatic environment from not controlling the spread of noxious weeds include but are not limited to, an increase in sedimentation, reduction in stream bank stability, elevated water temperature with the lack of canopy cover, and a potential decrease in the amount of organic matter available to enter affected streams. Without treatment, noxious weeds would likely become widely established across the Forest. This could lead to an increase in soil erosion (sediment deposition) and surface water runoff. Studies indicate a nearly three-fold increase in sediment yield from knapweed sites compared to an uninfested bunchgrass site. Cumulative Effects: Weeds would continue to invade and spread on the Forest. As this process occurs, weed control options become narrower. Loss of native vegetation could lead to changes in channel morphology as channel stability decreases.

Chapter 3—Affected Environment & Environmental Consequences 259 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Effects of Physical + Treatment Components on the Lost River Sucker, Shortnose Sucker, and Modoc Sucker—Alternatives 2 through 5, And 6 Direct and Indirect Effects: Physical + treatment as proposed are not expected to have any direct or indirect effects on the Lost River sucker, shortnose sucker, and Modoc sucker or habitat of the species. Cumulative Effects: The physical + treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result in better riparian condition, in turn providing more stable and useful aquatic habitat.

Effects of Herbicide Treatments on the Lost River Sucker, Shortnose Sucker, and Modoc Sucker Action Alternatives (Alternatives 2, 4, and 6) Direct and Indirect Effects: Direct effects to the Lost River sucker, shortnose sucker, and Modoc sucker would be primarily associated with herbicide application near streams and associated riparian areas, lakes, or wetlands. A total of 0.36 acres (4 sites) of noxious weeds are found adjacent to Lost River sucker and shortnose sucker habitat. A total of 1.93 acres (8 sites) of noxious weeds are found adjacent to Modoc sucker habitat Herbicides are applied in liquid formulations and are sprayed on foliage of the target vegetation. In some cases soil may be a major receptor and contamination can occur by chemicals leaching through the soil to the groundwater and ultimately reaching the aquatic environment. This method of introduction usually poses the least amount of risk to the aquatic environment because chemicals typically disappear from the ground surface by either plant uptake of the chemical, volatilization, and natural decomposition of the active ingredients or adsorption of the herbicide by soil particles. Design Standards or other prevention measures proposed to address this are included in all Alternatives utilizing chemical treatments. Surfactants are used in herbicide formulations to increase the absorption of the herbicide by lowering the surface tension of the targeted plants. Since herbicides are used to kill plants, using a surfactant to make it more effective is a moot point. Inert ingredients are used to improve the performance of a pesticide, and are ‘confidential business information’ of the chemical companies, and analysis of these herbicides is therefore impossible. Dyes would be used in herbicide treatments to show where the herbicide has been administered. Its effect on non-target terrestrial and aquatic species is unknown; however, its use has not resulted in any known problems. Using dyes can be an aid to making sure that only the target species is treated, and it has been recommended that dyes be used in the administering of herbicides. A synergistic effect is any effect of two herbicides acting together which is greater than the simple sum of their effects when acting alone: such herbicides are said to show synergism. The synergistic effect of the two mixes has been covered in Dave Bakke’s Specialist Report in support of the FEIS. Leaks, spills, and improper storage and handling of containers are the source of most pesticide related groundwater contamination. These impacts can easily be mitigated with proper training of personnel and proper storage and disposal of chemicals. Risk from an accidental spill of herbicide into a water body on the Forest is considered low. Another mode of pesticide entry to the aquatic system includes overland flow from precipitation events. Risk varies depending on soil composition and timing and intensity of precipitation events

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after application. Risk tends to be lower on well-vegetated forests and rangeland where soil infiltration is typically greater than precipitation. Overland flow occurs infrequently on most forest land because the infiltration capacity of the forest floor and soil is usually far greater than the rate of precipitation. Aquatic organisms are more at risk of negative impacts from herbicides in small perennial streams, or during late season when flow is reduced, due to their limited capability for dilution. Design Standards or other prevention measures proposed to address precipitation events are included in the Proposed Action. Design Standards for riparian areas would reduce the risk of direct and indirect effects. A reduction of noxious weeds in riparian areas and other aquatic habitats would benefit native plant species and result in better stream bank and riparian condition, in turn providing more stable and useful aquatic environments. Not all noxious weeds would be chemically treated. Even under the integrated weed management approach, not all weed populations would be eradicated, leaving an available seed source for continued propagation or the unlikely option of weeds being out-competed by native or desirable plant species. Cumulative Effects: No adverse downstream cumulative effects would be expected from situations involving herbicide runoff or leaching because of the method of application, Best Management Practices (BMPs) and Design Standards or other prevention measures designed to prevent these types of impacts from occurring.

Effects of Early Detection – Rapid Response Strategy on the Lost River sucker, shortnose sucker, and Modoc sucker Action Alternatives (Alternatives 4, 5, and 6) Alternatives 4, 5, and 6 include treatment of up to 200 acres (100 acres per year maximum) under this strategy. Only methods approved for use under this NEPA decision are approved for use, therefore the direct, indirect, and cumulative effects for the Early Detection – Rapid Response Strategy would be the same as listed above for the action Alternatives.

Cumulative Effects of Resource Activities on the Lost River sucker, shortnose sucker, and Modoc sucker. Timber and Silvicultural Activities: On average 2,500 acres are logged for saw logs with an additional 3,000 treated for wood fiber annually on the Modoc National Forest. Harvest prescriptions vary from clearcutting to understory thinning; however clearcutting has been radically reduced in over the past ten years. The various timber sales may have had effects on the species discussed in this document that would have been disclosed within their individual National Environmental Policy Act dictated documentation; discussing the potential effects of those projects is beyond the scope of this document. . The amplitude of effect future timber and silvicultural activities is expected to significantly decrease due to the institution of noxious weed prevention measures. Noxious weed locations would be presented as part of the ID team process so that activities in these areas can be avoided or mitigated (timing projects outside of high risk seasons). Logging systems design should maintain ground cover by minimizing ground disturbance and avoid opening up the overstory adjacent to noxious weed populations. Logging equipment would be washed to stem the transfer of noxious weeds (timber sale clause CT 6.343). Timber sale contract clauses C5.12 (Use of Road Purchaser), C5.4 (General and Special Maintenance Requirements), and C6.315 (Sale Operation Schedule) would be used to keep vehicles and equipment out of high-risk areas during weed seed production periods.

Chapter 3—Affected Environment & Environmental Consequences 261 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Timber harvest and silvicultural treatments would continue to be regulated so any potential adverse effects would be mitigated for during the project phase for all federally listed species. Therefore, between the measures to decrease noxious weeds and the mitigations of future timber harvest activities, there are no anticipated significant cumulative effects on T&E fish. Grazing: Grazing allotments occur on every acre of the Modoc National Forest, however, roughly 10% of these allotments are vacant and about 2% are in non-use. Approximately, 122,500 animal unit months of grazing occurs annually. There is also one wild horse territory with approximately 425 head. The greatest potential for livestock to spread noxious weeds is transportation in the animals’ hair. A secondary, but smaller concern could be the concentrated use of areas causing bare patches. If weed occurrences were adjacent, they could provide a seed bed. Livestock may be used as a tool to control of noxious weeds in the future, depending on the species and the estimated effectiveness of domestic animals. The integration of the new guidelines are hoped to minimize the potential spread of weed occurrences as well as new infestations. The following standards and guidelines would be utilized.  Annual operating plans would provide information to the permittees regarding noxious weed identification, methods of spread and prevention measures.  The exclusion of livestock (and wildlife where feasible) from high priority noxious weed sites should be considered where the animals are likely to cause spread of the weed off site Potential cumulative effects of livestock grazing are fairly minimal. Fire: Fire management activities that have the potential to spread noxious weeds can be separated into two categories: fuels management and suppression. Approximately 17,000 acres are proposed for fuels treatment per year across the Forest: 5,000 acres of prescribed burns and 12,000 acres of mechanical fuels manipulation. Areas that have mechanical treatments such as brush mowing and coniferous tree understory thinning are less likely to have potential to spread noxious weeds. Activities associated with mowing are not likely to leave bare spaces upon completion of the project. Plus, areas would be mowed when there is less of a chance of equipment spreading seed. Understory thinning would have the guidelines stated in the timber and silviculture section. Prescribed burns have a potential to increase the amount of noxious weed occurrences on the Forest. Areas that are left bare post fire would be considered for seeding with appropriate seed mixes. Other mitigations to minimize the potential for noxious weed spread would be implemented during prescribed burning activities. Timing of fire in relation to specific weed species in proposed burn area would be considered; if possible, time burning to control weeds. If burning must be during a high-risk period when weed populations are likely to be favored, NEPA documents will discuss the monitoring and prompt treatment immediately upon observing a weed problem. Monitor burned areas intensively the first year after burning, preferably for 3 years. Fire management treatments would continue to be regulated so any potential adverse effects would be mitigated during the project phase for all federally listed species. Therefore, between the measures to decrease noxious weeds and the mitigations of future fire management activities, the 3.42 acres that could be treated in Lost River sucker, shortnose sucker, and Modoc sucker, there are no expected cumulative effect on these three species.

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Wildfire and associated suppression and rehabilitation measures on the other hand certainly may provide both an excellent seed source and seed bed. Although there is little control of the location of wildfire, the following standards and guidelines would be implemented during the course of wildfire suppression. The use of high-priority sites for fire camps and staging areas would be avoided whenever any reasonable Alternative exists. Noxious weed prevention would be addressed in fire rehabilitation and restoration plans. There is no way of quantifying the location and extent of future wildlife fires, therefore a determination of the cumulative effects of fire on T&E fish is not possible. Recreation: Although there is a myriad of recreation associated activities that occur on the Modoc National Forest, the two past-times that have the greatest potential to cause the spread of noxious weeds are stock use and equestrian related events. Stock use on Modoc NF is estimated as 6,650 Recreation Visitor Days (RVD) annually with the vast majority within the South Warner Wilderness. Typically there is only one equestrian special use a year; however, there are a few other rides once every five years. Special event horse use averages roughly 50 horses for three days. In summary, there is a rather minor amount of stock and horse use on the Forest as a whole. In order to decrease the potential for weed introduction via these means, the following Operating Guides have been instituted.  Special emphasis would be placed on inventory and management of noxious weeds at trailheads.  Special Use Permits for equestrian groups would recommend pelletized feed be used rather than hay or straw.  Facilities and high-visibility travel ways would be maintained as weed free zones. Weeds at administration sites, visitor centers, and trailheads would be controlled. Information informing the public and forest service employees that these are "zero tolerance" areas would be posted. This would also be used as opportunities for education. Working cooperatively with the State of California, State of Nevada and the County Weed Boards we would strive to prevent the introduction and establishment of noxious weed infestations as a result of roads, recreation facilities, special use permits, timber harvest, and fuels treatment (see FSM 2081.2), Given the rather small and mostly localized use of stock and equestrians, plus the implementation of the above guidelines it is not anticipated that recreational activities would significantly contribute to noxious weed spread on this Forest. The implementation of the weed control program discussed in this document coupled with recreational activities that occur on the Forest would have no cumulative effect on the T&E fish species. Herbicide Treatments: Of the roughly 2.5 million acres of federal lands encompassed by our Modoc National Forest Map only 6,913 acres would receive treatment on the Modoc National Forest for noxious weeds or about 0.0028%. Of the roughly 4 million acres of state, private and federal lands encompassed by the Forest map, about 14,000 acres or .0056% are treated annually for noxious weed eradication (including the acres proposed by the Modoc National Forest). As stated previously, a maximum of 3.42 acres would be treated in areas that have any potential to effect Lost River sucker, shortnose sucker and Modoc sucker. Due to the location of most of the weed infestations in areas outside of live water occupied by T&E fish, the short duration of management activities, , and other mitigations specific within the Design Standards, there are no

Chapter 3—Affected Environment & Environmental Consequences 263 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

significant cumulative effects expected with implementation of mechanical, physical and chemical control activities associated with the Noxious Weed Treatment Project. Consultation to Date Forest and FWS personnel have been in continual contact during the course of the planning effort. A letter was received from the Fish and Wildlife Service on April 8, 2003, (ref 1-10-03-I-082), concurring with the Forest’s determination that the action “may affect, but is not likely to adversely affect the Modoc, Lost River, and shortnose suckers” for this project, previously named, “Noxious Weed Strategy Implementation Project”. The most current consultation with the Klamath Falls office occurred on January 31, 2007, when Rick Hardy was contacted regarding this document that would address specific changes that were included in the FEIS.

Determination for Federally Listed Species Based on the analysis of effects of the project this project would have “No Effect” on the Lost River sucker, shortnose sucker, Modoc sucker, Warner sucker, and Shasta Crayfish or their habitat with the implementation of the Action Alternatives. For the Warner Sucker and the Shasta Crayfish, this determination is based on the distance (over 5 miles) of the proposed treatment area from the Warner sucker and distance (25 miles) of the proposed treatment area from the Shasta crayfish. For the Lost River sucker, shortnose sucker, and Modoc sucker, this determination is based on the fact that Design Standards for RCAs have been established to protect these species, and the limited number of sites to be treated (2.29 acres, 12 sites). The only chemical proposed for use within 10’ of live water is a riparian approved formulation of Glyphosate. Vegetative or channel morphology change are not anticipated to be significant enough to affect the species.

Forest Service Sensitive Fish and Aquatic Wildlife Species The affected environment and environmental consequences of the Sensitive Fish and Aquatic Wildlife Species are summarized from the Biological Evaluation Report located in Appendix U. The table below indicates which species that occur or have habitat downstream from the Forest that may be affected by implementation of any of the Alternatives.

Table 3 - 68. USDA Forest Service Region 5 Sensitive Aquatic Species that occur or have habitat downstream from the Modoc National Forest.

Common Name Scientific Name Taxon Habitat That Forest Could Be Affected MIS California floater Anodonta californiensis invertebrate Scalloped juga Juga acutifilosa invertebrate Cascade frog Rana cascade amphibian Northern leopard frog Rana pipiens amphibian X Spotted frog Rana pretiosa amphibian X Northwestern pond turtle Clemmys marmorata marmorata reptile X Goose Lake sucker Catostomus occidentalis fish X lacusanserinus Goose Lake tui chub Gila bicolor thallassina fish X Goose Lake lamprey Lampetra tridentata ssp. fish X Goose Lake redband trout Oncorhynchus mykiss pop 6 fish X X Warner Valley redband Oncorhynchus mykiss pop 4 fish

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Common Name Scientific Name Taxon Habitat That Forest Could Be Affected MIS trout As detailed in the Biological Evaluation Report for Sensitive Fish and Aquatic Species the California floater, Scalloped juga, Cascade frog, and Warner Valley redband trout do not have suitable habitat that is directly, indirectly, or cumulatively affected by the Proposed Action and will not be carried forward in this analysis. The following section provides a very brief account of the distribution and types of habitat utilized for each species that could be affected by Alternatives analyzed within this document.

Goose Lake redband trout The name redband trout is used to cover a confusing complex of distinctive trout that occur in isolated headwater streams of the McCloud, Pit, Klamath, and Columbia River systems of California, Nevada, and Oregon. The Goose Lake redband trout is endemic to Goose Lake and its major tributaries (Lassen and Willow creeks in California and the extensive Thomas Creek system and Crane Creek in Oregon) as well as to smaller streams such as Cottonwood Creek in California and several small streams in Oregon. Berg (1987) reported that Joseph, Parker, and East creeks (tributaries of the upper Pit River in California) contained trout genetically similar to Goose Lake redband. This species has both lake and stream dwelling populations, which both rely on headwater streams for spawning. Riffles with clean gravels and suitable water temperatures are required. The long-term persistence of this fish depends largely on the health of populations in the headwater streams flowing into Goose Lake in Oregon and California, even though much of the conservation attention has focused on large fish in the lake itself. The extirpation of the lake population during a drought and its subsequent partial recovery indicate the probable importance of downstream colonization of the lake from headwater populations. Because of the high level of concern over extirpation of Goose Lake redband (and other native fishes) from Goose Lake when it dried up, conservation efforts have been under way in the watershed, by both agencies and private landowners, to restore streams (e.g., by changing grazing practices) and to remove or alter migration barriers (Moyle 2002). Populations are currently stable.

Goose Lake toy chub In California toy chubs are native mostly to interior drainages, except the Central Valley, and absent from all coastal drainages, except where introduced. In the Sacramento-San Joaquin drainage toy chubs are native only to Pit River downstream at least as far as Hat Creek and Lake Britton and to Goose Lake, although they have been introduced into some reservoirs and ponds in various locations. The Goose Lake tui chub is considered by Snyder (1908) to be the native tui chub of the upper Pit River from Big Valley upstream to and including Goose Lake. Hubbs et al. (1979) determined that the Pit River form and the Goose Lake form of tui chub were distinct and that the Goose Lake tui chub was a distinct subspecies with the thalassina name. Tui chubs in general are opportunistic omnivores and consume a wide variety of aquatic invertebrates (Moyle 1976). Tui chubs are abundant and widely distributed, and so are not in trouble as a species (Moyle 2002).

Goose Lake sucker The Goose Lake sucker is a described subspecies of Sacramento sucker. The Goose Lake sucker was originally described in 1913 as a subspecies (Fowler 1913) and further studies indicated that the subspecies was distinct, but the differences minor. During their second year, Goose Lake

Chapter 3—Affected Environment & Environmental Consequences 265 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

suckers migrate in April or May, depending on water temperature, to spawn in streams that are tributary to the lake (Martin 1967). Adults have been found in the lake, some of the streams, and some of the reservoirs throughout the year. During summer, young suckers are very abundant in shallow water among aquatic macrophytes. Goose Lake suckers feed primarily on algae and diatoms (Martin 1967).

Northwestern pond turtle Northwestern pond turtles have been sighted in several locations on the Forest, including Willow Creek on Big Valley RD, Lost River on Doublehead RD, and along the Pit River near Alturas. Pond turtles utilize a variety of habitats in areas with permanent or relatively permanent water that have a slower current. They require basking sites (e.g., partially submerged logs, rocks, open mud banks) and are omnivorous.

Northern leopard frog Historically, the northern leopard frog was widely distributed in North America, but uncommon and localized in California. Its known elevational range extends from 4,000 to 5,000 feet in California. In California, native populations of the northern leopard frog whose origin is largely unquestioned, are historically recorded from the Modoc and Lassen Counties. Recent surveys have indicate the species is nearly absent from these historical sites. No individuals of this taxon were encountered during field surveys by Jennings and Hayes (1994). The nearest recent siting was of a single adult at the Tule Lake National Wildlife Refuge in 1990. Depending on temperature and geography, northern leopard frogs enter hibernation during the fall and winter months and emerge from the bottom of aquatic habitats in the spring, as soon as ice melts. Northern leopard frogs require permanent aquatic habitat to breed, feed, and overwinter. Since this species is relatively susceptible to water loss, it is essential that a moist substrate occur in the vicinity of the aquatic habitat. As adults, they may take cover in grasslands, meadows, and pastures. Most of the essential habitat is no longer present or so fragmented that the habitat can no longer support populations of this taxon. Moreover, bullfrogs have become well established along RCAs where northern leopard frogs where historically present. Although the interaction between these two taxa is poorly understood, bullfrogs may have a negative effect on leopard frogs (Jennings and Hayes 1994).

Spotted frog The spotted frog is one of the most widely distributed taxon in the western United States; however, in California historical records indicate this species was present on the Modoc Plateau, Pit River drainage, and in the Warner Mountains. Its known elevational range extends from 3,200 to 4,800 feet. The spotted frog is a highly aquatic species typically found in permanent water such as streams, rivers, marshes, springs, pools, and small lakes. Spotted frogs do not seem to occur in stagnant water, which contain cattails. There is no specific data on feeding; however, the food eaten differs with age and size of the frog and includes many insects, arachnids, and mollusks. No individuals of this taxon were found during a concerted field effort on the Modoc Plateau, Pit River drainage, and in the Warner Mountains at sites where this taxon was historically present (Jenning and Hayes 1994). A single sub-adult frog reported in Cedarville in 1989 has been classified as a misidentification of the species (Hayes pers. comm.).

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Effects of the Alternatives on Sensitive Fish and Aquatic Species Northern leopard frog, Spotted frog, Northwestern pond turtle, Goose Lake sucker, Goose Lake tui chub, Goose Lake lamprey, and Goose Lake redband trout

No-Action Alternative (Alternative 1) Direct Effects and Indirect: Potential adverse effects to the aquatic environment from not controlling the spread of noxious weeds include but are not limited to, an increase in sedimentation, reduction in stream bank stability, elevated water temperature with the lack of canopy cover, and a potential decrease in the amount of organic matter available to enter affected streams. Without treatment, noxious weeds would likely become widely established across the Forest. This could lead to an increase in soil erosion (sediment deposition) and surface water runoff. Studies indicate a nearly three-fold increase in sediment yield from knapweed sites compared to an uninfested bunchgrass site. Cumulative Effects: Weeds would continue to invade and spread on the Forest. As this process occurs, weed control options become narrower. Loss of native vegetation could lead to changes in channel morphology as channel stability decreases. The no action Alternative is not expected to have any direct, indirect, or cumulative adverse effects on the Goose Lake sucker, Goose Lake tui chub, Goose Lake lamprey, Goose Lake redband trout, Northwestern pond turtle, northern leopard frog, and spotted frog.

Effects of Physical + Treatment Components (Alternatives 2 through 6) Direct and Indirect Effects: Physical + treatment as proposed is not expected to have any direct or indirect effects on the Goose Lake sucker, Goose Lake tui chub, Goose Lake lamprey, Goose Lake redband trout, Northwestern pond turtle, Cascade frog, northern leopard frog, and spotted frog Cumulative Effects: The physical + treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result better riparian condition, in turn providing more stable and useful aquatic habitat. Physical + treatment as proposed is not expected to have any direct, indirect, or cumulative adverse effects on the Goose Lake sucker, Goose Lake tui chub, Goose Lake lamprey, Goose Lake redband trout, Northwestern pond turtle, Cascade frog, northern leopard frog, and spotted frog

Effects of Herbicidal Treatments (Alternatives 2, 4, and 6) Direct and Indirect Effects: Direct effects to the Goose Lake sucker, Goose Lake tui chub, Goose Lake lamprey, Goose Lake redband trout, Northwestern pond turtle, northern leopard frog, and spotted frog would be primarily associated with herbicide application near streams and associated riparian areas, lakes, or wetlands. A total of 12.6 acres of noxious weeds are found adjacent to the habitat of these species.

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Herbicides are applied in liquid formulations and are sprayed on foliage of the target vegetation. In some cases soil may be a major receptor and contamination can occur by chemicals leaching through the soil to the groundwater and ultimately reaching the aquatic environment. This method of introduction usually poses the least amount of risk to the aquatic environment because chemicals typically disappear from the ground surface by either plant uptake of the chemical, volatilization, and natural decomposition of the active ingredients or adsorption of the herbicide by soil particles. Design Standards or other prevention measures proposed to address this are included in all Alternatives utilizing chemical treatments. Leaks, spills, and improper storage and handling of containers are the source of most pesticide related groundwater contamination. These impacts can easily be mitigated with proper training of personnel and proper storage and disposal of chemicals. Risk from an accidental spill of herbicide into a water body on the Forest is considered low. Another mode of pesticide entry to the aquatic system includes overland flow from precipitation events. Risk varies depending on soil composition and timing and intensity of precipitation events after application. Risk tends to be lower on well-vegetated forests and rangeland where soil infiltration is typically greater than precipitation. Overland flow occurs infrequently on most forest land because the infiltration capacity of the forest floor and soil is usually far greater than the rate of precipitation. Aquatic organisms are more at risk of negative impacts from herbicides in small perennial streams, or during late season when flow is reduced, due to their limited capability for dilution. Design Standards or other prevention measures proposed to address precipitation events are included in the Proposed Action. Detailed herbicide information was published in the DEIS, Appendix E, and is incorporated into this document by this reference. Appendix E consisted of a copy of information available on the Internet and was not republished in the FEIS to reduce costs. Summary information is found in Chapter 2 of the FEIS. Design Standards are prescribed for RCAs to protect sensitive fish and aquatic species. A reduction of noxious weeds in riparian areas and other aquatic habitats would benefit native plant species and result in better stream bank and riparian condition, in turn providing more stable and useful aquatic environments. Not all noxious weeds would be chemically treated. Even under the integrated weed management approach, not all weed populations would be eradicated, leaving an available seed source for continued propagation or the unlikely option of weeds being out-competed by native or desirable plant species. Cumulative Effects: No adverse downstream cumulative effects would be expected from situations involving herbicide runoff or leaching because of the method of application, Best Management Practices (BMPs) and Design Standards or other prevention measures designed to prevent these types of impacts from occurring.

Cumulative Effects of Resource Activities on the Sensitive Fish and Aquatic Species

Timber and Silvicultural Activities On average, 2,500 acres are logged for saw logs with an additional 3,000 treated for wood fiber annually on the Modoc National Forest. Harvest prescriptions vary from clear cut to understory thinning, however clearcutting has rarely been used in recent times. The various timber sales may have had effects on the species discussed in this document that would have been disclosed within their individual National Environmental Policy Act dictated documentation; discussing the potential effects of those projects is beyond the scope of this document. .

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The amplitude of effect future timber and silvicultural activities is expected to significantly decrease due to the institution of noxious weed prevention measures. Timber sales and other cultural treatments would need to have changes in planning and implementation. Noxious weed locations would be presented as part of the ID team process so that activities in these areas can be avoided or mitigated (timing projects outside of high risk seasons). Logging systems design should maintain ground cover by minimizing ground disturbance and avoid opening up the overstory adjacent to noxious weed populations. Logging equipment would be washed to stem the transfer of noxious weeds (timber sale clause CT 6.343). Timber sale contract clauses C5.12 (Use of Road Purchaser), C5.4 (General and Special Maintenance Requirements), and C6.315 (Sale Operation Schedule) would be used to keep vehicles and equipment out of high-risk areas during weed seed production periods. The current regulations are anticipated to minimize this type weed spread. Timber harvest and silvicultural treatments would continue to be regulated so any potential adverse effects would be mitigated for during the project phase for all sensitive species. Therefore, between the measures to decrease noxious weeds and the mitigations of future timber harvest activities, there are no anticipated significant cumulative effects on sensitive aquatic species.

Grazing Grazing allotments occur on every acre of the Modoc National Forest, however, roughly 10% of these allotments are vacant and about 2% are in non-use. Approximately, 122,500 animal unit months of grazing occurs annually. There is also one wild horse territory with approximately 425 head. The greatest potential for livestock to spread noxious weeds is transportation in the animals’ hair. A secondary, but smaller concern could be the concentrated use of areas causing bare patches. If weed occurrences were adjacent, they could provide a seed bed. Livestock may be used as a tool to control of noxious weeds in the future, depending on the species and the estimated effectiveness of domestic animals. The integration of the new guidelines are hoped to minimize the potential spread of weed occurrences as well as new infestations. The following standards and guidelines would be utilized. Annual operating plans would provide information to the permittees regarding noxious weed identification, methods of spread and prevention measures. The exclusion of livestock (and wildlife where feasible) from high priority noxious weed sites should be considered where the animals are likely to cause spread of the weed off site. Potential cumulative effects of livestock grazing are fairly minimal.

Fire Fire management activities that have the potential to spread noxious weeds can be separated into two categories: fuels management and suppression. Approximately 17,000 acres are proposed for fuels treatment per year across the Forest: 5,000 acres of prescribed burns and 12,000 acres of mechanical fuels manipulation. Areas that have mechanical treatments such as brush mowing and coniferous tree understory thinning are less likely to have potential to spread noxious weeds. Activities associated with mowing are not likely to leave bare spaces upon completion of the project. Plus, areas would be mowed when there is less of a chance of equipment spreading seed. Understory thinning would have the guidelines stated in the timber and silviculture section.

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Prescribed burns have a potential to increase the amount of noxious weed occurrences on the Forest. Areas that are left bare post fire would be considered for seeding with appropriate seed mixes. Other mitigations to minimize the potential for noxious weed spread would be implemented during prescribed burning activities. Timing of fire in relation to specific weed species in proposed burn area would be considered; if possible, time burning to control weeds. If burning must be during a high-risk period when weed populations are likely to be favored, NEPA documents will discuss the monitoring and prompt treatment immediately upon observing a weed problem. Monitor burned areas intensively the first year after burning, preferably for 3 years. Fire management treatments would continue to be regulated so any potential adverse effects would be mitigated during the project phase for all federally listed species. Therefore, between the measures to decrease noxious weeds and the mitigations of future fire management activities, the 12.6 acres that could be treated in Goose Lake sucker, Goose Lake tui chub, Goose Lake lamprey, Goose Lake redband trout, Northwestern pond turtle, northern leopard frog, and spotted frog habitat, there are no expected cumulative effect on these three species. Wildfire and associated suppression and rehabilitation measures on the other hand certainly may provide both an excellent seed source and seed bed. Although there is little control of the location of wildfire, the following standards and guidelines would be implemented during the course of wildfire suppression. The use of high-priority sites for fire camps and staging areas would be avoided whenever any reasonable Alternative exists. Noxious weed prevention would be addressed in fire rehabilitation and restoration plans. There is no way of quantifying the location and extent of future wildlife fires, therefore a determination of the cumulative effects of fire on sensitive aquatic species is not possible.

Recreation Although there is a myriad of recreation associated activities that occur on the Modoc National Forest, the two past-times that have the greatest potential to cause the spread of noxious weeds are stock use and equestrian related events. Stock use on Modoc NF is estimated as 6,650 Recreation Visitor Days (RVD) annually with the vast majority within the South Warner Wilderness. Typically there is only one equestrian special use a year; however, there are a few other rides once every five years. Special event horse use averages roughly 50 horses for three days. In summary, there is a rather minor amount of stock and horse use on the Forest as a whole. In order to decrease the potential for weed introduction via these means, the following Operating Guides have been instituted. Special emphasis would be placed on inventory and management of noxious weeds at trailheads. Special Use Permits for equestrian groups would recommend pelletized feed be used rather than hay or straw. Facilities and high-visibility travel ways would be maintained as weed free zones. Weeds at administration sites, visitor centers, and trailheads would be controlled. Information informing the public and forest service employees that these are "zero tolerance" areas would be posted. This would also be used as opportunities for education. Working cooperatively with the State of California, State of Nevada and the County Weed Boards we would strive to prevent the introduction and establishment of noxious weed infestations as a result of roads, recreation facilities, special use permits, timber harvest, and fuels treatment (see FSM 2081.2).

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Given the rather small and mostly localized use of stock and equestrians, plus the implementation of the above guidelines it is not anticipated that recreational activities would significantly contribute to noxious weed spread on this Forest. The implementation of the weed control program discussed in this document coupled with recreational activities that occur on the Forest would have no cumulative effect on the sensitive aquatic species.

Cumulative Effects of the Use of Herbicide Treatments within the Analysis Area on Sensitive Fish and Aquatic Species Of the roughly 2.5 million acres of federal lands encompassed by our Modoc National Forest Map only 6,913 acres would receive treatment on the Modoc National Forest for noxious weeds or about 0.0028%. Of the roughly 4 million acres of state, private and federal lands encompassed by the Forest map, about 14,000 acres or .0056% are treated annually for noxious weed eradication (including the acres proposed by the Modoc National Forest). As stated previously, a maximum of 12.6 acres would be treated in areas that have any potential to effect Goose Lake sucker, Goose Lake tui chub, Goose Lake lamprey, Goose Lake redband trout, Northwestern pond turtle, northern leopard frog, and spotted frog. Due to the location of most of the weed infestations in areas outside of live water occupied by sensitive aquatic species, the short duration of management activities, and other mitigations specific within the Design Standards, there are no significant cumulative effects expected with implementation of mechanical, physical and chemical control activities associated with the Noxious Weed Treatment Project.

Determinations of Effects on Sensitive Fish and Aquatic Species There will be a “No Impact” determination for all aquatic species for implementation of the No Action Alternative or the implementation of the prevention program. There will be a “No Impact” determination for all aquatic species for implementation of physical + treatment. The effects of these treatments are expected to be minor and temporary in duration. There will be a “No Impact” determination for the following species for implementation of chemical treatments: California floater, scalloped juga, Cascade frog, and Warner Valley redband trout. These species do not have suitable habitat that is directly, indirectly, or cumulatively affected. There will be a May impact individuals, but not likely to cause a trend to federal listing or a loss of viability” for chemical activities for the following species: Goose Lake sucker, Goose Lake tui chub, Goose Lake lamprey, Goose Lake redband trout, Northwestern pond turtle, northern leopard frog, and spotted frog. This determination is based on the fact that Design Standards have been established to protect these species, and the limited number of sites to be treated (12.6 acres). The only chemical proposed for use within 10 feet of live water is a riparian approved formulation of Glyphosate.

Forest Service Aquatic Management Indicator Species The purpose of this report is to evaluate and disclose the impacts of the Noxious Weed Treatment Project on the Fisheries and Aquatic Management Indicator Species (MIS) identified in the Forest (NF) Land and Resource Management Plan (Forest Plan) (USDA 1991). This report documents the effects of project Alternatives on the habitat of selected MIS. Detailed descriptions of the

Chapter 3—Affected Environment & Environmental Consequences 271 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Noxious Weed Treatment Project Alternatives are found in Chapter 2 of the Project Environmental Impact Statement (USDA 2007). MIS are animal or plant species identified in the Modoc NF Forest Plan (USDA 1991, which was developed under the 1982 National Forest System Land and Resource Management Planning Rule (1982 Planning Rule) (36 CFR 219). Guidance regarding MIS set forth in the Modoc NF Forest Plan directs Forest Service resource managers to (1) at project scale, analyze the effects of proposed projects on the habitats of each MIS affected by such projects, and (2) at the national forest (forest) or bioregional scale, monitor populations and/or habitat trends of forest MIS, as identified by the Forest Plan. Direction Regarding the Analysis of Project-Level Effects on MIS Project-level effects on MIS are analyzed and disclosed as part of environmental analysis under the National Environmental Policy Act (NEPA). This involves examining the impacts of the proposed project Alternatives on MIS habitat by discussing how direct, indirect, and cumulative effects would change the quantity and/or quality of habitat in the analysis area. Where the Modoc NF Forest Plan requires population monitoring or population surveys for an MIS, the project-level effects analysis for that MIS must be informed by population monitoring data, which are gathered at the forest or bioregional scale. Population monitoring and survey data are not generally gathered for site-specific projects. Therefore, adequately analyzing project effects to MIS, including Threatened, Endangered, and Sensitive (TES) species that are also MIS, involves the following steps:  Identifying which MIS have habitat that would be either directly or indirectly affected by the project Alternatives; these MIS are potentially affected by the project.  Identifying the Forest Plan forest-level or bioregional-level monitoring requirements for this subset of forest MIS.  Analyzing project-level effects on MIS habitats or habitat components for this subset of forest MIS.  Discussing forest or bioregional scale habitat and/or population trends for this subset of forest MIS.  Relating project-level impacts on MIS habitat to habitat and/or population trends for the affected MIS at the forest or bioregional scale.

These steps are described in detail in the Pacific Southwest Region’s draft document “MIS Analysis and Documentation in Project-Level NEPA, R5 Environmental Coordination” (USDA 2006). This Management Indicator Species (MIS) Report documents application of the above steps to select and analyze potentially affected MIS for the Noxious Weed Treatment Project. Direction Regarding Monitoring of MIS Population and Habitat Trends at the Forest and Bioregional Scales Forest or bioregional scale monitoring requirements for the Modoc NF’s MIS are found in the Monitoring Plan of the FOREST PLAN (USDA 1991) and in Appendix E of the Sierra Nevada Forest Plan Amendment Final Environmental Impact Statement (FEIS) (USDA 2001), as adopted by the 2004 Sierra Nevada Forest Plan Amendment (SNFPA) Record of Decision (ROD) (USDA 2004).

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Habitat Status and Trend The Modoc NF Forest Plan (USDA 1991) requires Forest-scale monitoring of habitat status and trend for select MIS on the Modoc NF; for MIS with habitat potentially affected by the Noxious Weed Treatment Project. Habitat trend is the direction of change in the amount of habitat between the time the Forest Plan was approved and the present. The methodology for assessing habitat status and trend is described in detail in the Modoc National Forest MIS Report (USDA 2007). Habitats are the vegetation types (for example, mixed conifer forest) and/or ecosystem components (for example, cliffs or lakes) and any special habitat elements (for example, snags) required by an MIS for breeding, cover, and/or feeding. Required habitat is identified using habitat relationships data or models. Habitat relationships for fish MIS are identified individually. Population Status and Trend Population monitoring requirements for the MIS of the Modoc NF are identified in either Appendix E of the Sierra Nevada Forest Plan Amendment (SNFPA) FEIS (USDA 2001), as adopted by the 2004 Sierra Nevada Forest Plan Amendment Record of Decision (ROD) (USDA 2004), or the Monitoring Plan of the Forest Plan (USDA 1991). For Modoc NF MIS (USDA 1991) that are listed in Appendix E of the SNFPA FEIS (USDA 2001), population monitoring requirements are identified in Appendix E. For all other Modoc NF MIS, population monitoring requirements are identified in the Forest Plan Monitoring Plan (USDA 1991). There are many types of population data, and this document identifies the type of population monitoring data required for each MIS. The population monitoring requirements for the MIS with habitat potentially affected by the Noxious Weed Treatment Project are summarized in Table 3-51 of this report. All population monitoring data are collected and/or compiled at the forest or bioregional scale, consistent with the Forest Plan as amended by the SNFPA “site specific monitoring or surveying of a proposed project or activity area is not required” (36 CFR 219.14(f)). Population status is the current condition of the MIS related to the type of population monitoring data (population measure) required in the Forest Plan for that MIS. Population trend is the direction of change in that population over time. As discussed in Appendix E of the 2001 SNFPA (USDA 2001), there is a wide range of monitoring data that can be used to describe the status and trend (or change) of populations, ranging from describing changes in distribution based on presence-absence data to describing changes in population structure. Distribution population monitoring consists of collecting presence data for the MIS across a number of sample locations; over time, changes in the distribution of the MIS can be identified and tracked. Presence data is collected using a number of direct and indirect methods, such as surveys (population surveys), bird point counts, tracking number of hunter kills, counts of species sign (such as deer pellets), and so forth. Presence population data for MIS are collected and consolidated by the Modoc NF in cooperation with State and Federal agency partners (including the California Department of Fish and Game, U.S. Geological Survey, and USDI Fish and Wildlife Service) or conservation partners (including Partners in Flight and various avian joint ventures). The Modoc NF’s MIS monitoring program for species typically hunted, fished, or trapped was designed to be implemented in cooperation with California Department of Fish and Game (CDFG), consistent with direction in the 1982 Planning Rule to monitor Forest-level MIS population trends in cooperation with state fish and wildlife agencies to the extent practicable (36 CFR 219.19(a)(6)). To be biologically meaningful for wide-ranging MIS, presence data are collected and tracked not only at the Forest scale, but also at larger scales, such as range wide, state, province, or important species management unit

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(for example, Deer Assessment Unit or waterfowl migratory routes). Population data at various scales are important to both assess and provide meaningful context for population status and trend at the Forest scale.

Selection of Level Fisheries and Aquatic MIS Management Indicator Species (MIS) for the Modoc NF are identified in the Forest Plan (USDA 1991). The Fisheries/Aquatic MIS analyzed for the Project were selected from this list of MIS identified in the Forest Plan and are listed below.. In addition, Table 3-69 identifies the status of the MIS (2nd column), reason each MIS was identified in the Forest Plan (3rd column) and discloses whether or not the MIS is potentially affected by the Noxious Weed Treatment Project (4th column).

Table 3 - 69. Fisheries/Aquatic Management Indicator Species Selected for Project-Level Analysis for the Noxious Weed Treatment Project, Modoc NF

Management Indicator Species Species Status Forest Plan Habitat Indicator Category for Project Analysis 1 Shortnose sucker Endangered Cold water aquatic 3 Lost river sucker Endangered Cold water aquatic 3 Modoc sucker Endangered Cold water aquatic 3 Goose Lake redband trout Sensitive Cold water aquatic 3 Rainbow trout Non-TES Cold water aquatic 3 Brook trout Non-TES Cold water aquatic 2 Brown trout Non-TES Cold water aquatic 3 Largemouth bass Non-TES Warm water aquatic 3 1 Category 1: MIS whose habitat is not in or adjacent to the project area and would not be affected by the project. Category 2: MIS whose habitat is in or adjacent to project area, but would not be either directly or indirectly affected by the project. Category 3: MIS whose habitat would be either directly or indirectly affected by the project. Brook trout, identified as Category 2 above, would not be further discussed because, although there is suitable habitat in the area, this species is found at higher elevations where no treatment is scheduled and therefore would have no impact on Forest-level brook trout habitat or population trends. The Fisheries/Aquatic MIS whose habitat would be either directly or indirectly affected by the Noxious Weed Treatment Project, identified as Category 3 in Table 3-69, are carried forward in this analysis, which will evaluate the direct, indirect, and cumulative effects of the Proposed Action and Alternatives on the habitat of these MIS. The MIS selected for Project-Level MIS analysis for the Noxious Weed Treatment Project are: Shortnose sucker, Lost River sucker, Modoc sucker, Goose Lake redband trout, rainbow trout, brown trout, and largemouth bass. Forest Plan Monitoring Requirements for Fish and Aquatic MIS The Modoc NF Forest Plan (USDA 1991) and Appendix E of the Sierra Nevada Forest Plan Amendment Final Environmental Impact Statement (USDA 2001), as adopted by the 2004 Sierra Nevada Forest Plan Amendment ROD (USDA 2004), identify Forest and bioregional scale habitat and population monitoring requirements for the Modoc NF MIS. As discussed in the introduction to this report, Forest-scale habitat monitoring requirements are identified in the Monitoring Plan of the Modoc NF Forest Plan (USDA 1991). For those Modoc NF MIS that are listed in Appendix E of the SNFPA FEIS (USDA 2001), population monitoring requirements are described in Appendix E. For all other Modoc NF MIS, population monitoring requirements are

274 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

described in the Forest Plan Monitoring Plan (USDA 1991). Habitat and population monitoring results for Modoc NF’s MIS are described in the Modoc National Forest Management Indicator Species Report (USDA 2007) and are summarized below for the MIS being analyzed for the Noxious Weed Treatment Project.

Table 3 - 70. Modoc NF Forest Plan MIS Requirements for the Selected Project-Level Fisheries/Aquatic MIS for the Noxious Weed Treatment Project (USDA 2007, as Amended by the SNFPA 2004)

SELECTED PROJECT- MIS Monitoring Requirements LEVEL MIS Habitat Population Shortnose sucker Stream surveys, photo points Recovery Plan Lost River sucker Stream surveys, photo points Recovery Plan Modoc sucker Stream surveys, channel profiles, Population sampling photo points Goose Lake redband trout Stream surveys, photo points Distribution/relative abundance Rainbow trout Stream/lake habitat surveys Distribution/population Brook trout Stream/lake habitat surveys Distribution/population Brown trout Stream/lake habitat surveys Distribution/population Largemouth bass Stream/lake habitat surveys Distribution/population Forest Plan, Monitoring Plan (USDA 1991). FEIS, Appendix E (USDA 2001). Methodologies for MIS Monitoring

Shortnose Sucker and Lost River Sucker Quality of habitat is assessed using a variety of techniques that range from subjective observation to intensive measurements. Photographs can be used to document conditions over time. Assessment of Proper Functioning Condition (PFC) can be used by Interdisciplinary teams to document observations of channel morphology and riparian vegetation. PFC is a nationally adopted protocol most useful in low gradient stream systems where range management is often the management practice of concern. Two other regionally adopted inventory protocols are used to evaluate habitat condition. Fish Habitat Inventory collects information at the scale of the habitat unit and is useful in characterizing condition. The R5 Stream Condition Inventory is used to monitor changes at the reach scale, and to compare reaches. Both methodologies include attributes most likely to be changed by management; these include shade, substrate composition, pools, channel shape, and large wood. Data is used to determine trend in conditions, and evaluated using data from similar streams, rather than against a model or set of standard objectives. The Modoc National Forest MIS Report (USDA 2007) provides additional information about the distribution and population trend for this species.

Modoc Sucker Important habitat components for the Modoc sucker include: the shading of streams by vegetation; coarse woody debris; the presence of pools in the summer; the presence of algae, detritus, and aquatic invertebrates; the presence of sand and gravels of various sizes not covered by sediment; and good water quality. This species is found in the riverine CWHR habitat type. Quality of Modoc sucker habitat is assessed using a variety of techniques that range from subjective observation to intensive measurements. Photographs can be used to document conditions over time. Assessment of Proper Functioning Condition (PFC) can be used by

Chapter 3—Affected Environment & Environmental Consequences 275 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Interdisciplinary teams to document observations of channel morphology and riparian vegetation. PFC is a nationally adopted protocol most useful in low gradient stream systems where range management is often the management practice of concern. Two other regionally adopted inventory protocols are used to evaluate Modoc sucker habitat condition. Fish Habitat Inventory collects information at the scale of the habitat unit and is useful in characterizing condition. The R5 Stream Condition Inventory is used to monitor changes at the reach scale, and to compare reaches. Both methodologies include attributes most likely to be changed by management; these include shade, substrate composition, pools, channel shape, and large wood. Data is used to determine trend in conditions, and evaluated using data from similar streams, rather than against a model or set of standard objectives. Channel cross-sections and vegetative green line survey are also used to monitor riparian condition over time. The Modoc National Forest MIS Report (USDA 2007) provides additional information about the distribution and population trend for this species.

Goose Lake Redband Trout Quality of redband trout habitat is assessed using a variety of techniques that range from subjective observation to intensive measurements. Photographs can be used to document conditions over time. Assessment of Proper Functioning Condition (PFC) can be used by Interdisciplinary teams to document observations of channel morphology and riparian vegetation. PFC is a nationally adopted protocol most useful in low gradient stream systems where range management is often the management practice of concern. Two other regionally adopted inventory protocols are used to evaluate redband trout habitat condition. Fish Habitat Inventory collects information at the scale of the habitat unit and is useful in characterizing condition. The R5 Stream Condition Inventory is used to monitor changes at the reach scale, and to compare reaches. Both methodologies include attributes most likely to be changed by management; these include shade, substrate composition, pools, channel shape, and large wood. Data is used to determine trend in conditions, and evaluated using data from similar streams, rather than against a model or set of standard objectives. The Modoc National Forest MIS Report (USDA 2007) provides additional information about the distribution and population trend for this species.

Rainbow Trout, Brown Trout, and Largemouth Bass Quality of habitat for these species is assessed using a variety of techniques that range from subjective observation to intensive measurements. Photographs can be used to document conditions over time. Assessment of Proper Functioning Condition (PFC) can be used by Interdisciplinary teams to document observations of channel morphology and riparian vegetation. PFC is a nationally adopted protocol most useful in low gradient stream systems where range management is often the management practice of concern. Two other regionally adopted inventory protocols are used to evaluate trout habitat condition. Fish Habitat Inventory collects information at the scale of the habitat unit and is useful in characterizing condition. The R5 Stream Condition Inventory is used to monitor changes at the reach scale, and to compare reaches. Both methodologies include attributes most likely to be changed by management; these include shade, substrate composition, pools, channel shape, and large wood. Data is used to determine trend in conditions, and evaluated using data from similar streams, rather than against a model or set of standard objectives. The Modoc National Forest MIS Report (USDA 2007) provides additional information about the distribution and population trend for these species.

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Effects of Proposed Action on Selected Fisheries and Aquatic MIS Detailed information on MIS for the Forest is documented in the Modoc Forest MIS Report (USDA 2007).

Shortnose Sucker and Lost River Sucker The shortnose sucker and Lost River sucker are federally listed endangered species; additional information on affected environment and environmental consequences of the Noxious Weed Treatment Project on these species is found in the project BA.

Habitat - Species Relationship Detailed information on MIS for the Modoc NF is documented in the Modoc National Forest MIS Report (USDA 2007), which is hereby incorporated by reference. The habitat requirements of the shortnose and Lost River suckers are not well known. It appears that the Lost River sucker is primarily a lake species and spends most of its time in fairly deep water (Moyle 2002). The shortnose sucker is thought to have a life history similar to the cui-ui (Chasmistes cujus) of Pyramid Lake, Nevada: it is thought to spend most of the year in the open waters of large lakes (Ibid). Cool water, high amounts of dissolved oxygen, and cool freshwater refuges appear to be important habitat components for both species (Buettner and Scoppettone 1991). When conditions become stressful in lakes, such as in the summer when there can be heavy algal blooms and fluctuations in dissolved oxygen, pH, and suspended and dissolved materials, areas where streams or springs flow into lakes may be important refugia (USFWS 1993).

Project-level Effects Analysis based on Habitat Key Habitat Factor(s) for the Analysis: The Forest Forest Plan identified these species as associated with riparian habitats. These species are found in the lacustrine and riverine CWHR habitat types.. Analysis Area for Project-level Effects Analysis These species migrate from Clear Lake Reservoir to spawn in Willow Creek and Boles Creek. Summer holding occurs in reservoirs as well as deeper pools within the channels. Current Condition of the Key Habitat Factor(s) in the Analysis Area There are currently 35.5 miles of stream habitat and 1,962 acres of reservoir habitat for the species on the Forest.

Alternative 1 (No Action) Direct and Indirect Effects to Habitat: Potential adverse effects to the aquatic environment from not controlling spread of noxious weeds include but are not limited to, an increase in sedimentation, reduction in stream bank stability, elevated water temperature with the lack of canopy cover, and a potential decrease in the amount of organic matter available to enter affected streams. Without treatment, noxious weeds would likely become widely established across the Forest. This could lead to an increase in soil erosion (sediment deposition) and surface water runoff.

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Cumulative Effects to Habitat As weed infestations become more severe, it becomes more difficult to restore natural or near natural conditions. Conditions arise where instead of using physical + treatments or relatively low applications of low toxicity herbicides, more intensive physical + treatment or intensive applications at higher concentrations of more toxic herbicides may be necessary to control later stages of weed infestations. When this occurs, the risk to the aquatic environment also increases and viability of aquatic species may also be at risk. It is anticipated that under the No Action Alternative there would be an increase in noxious weeds within suitable habitat. The relative cumulative effect to shortnose and Lost River suckers of this increase would be relatively small compared to the existing amount of habitat in the analysis area.

Alternatives 2, 4, and 6 Direct and Indirect Effects to Habitat: Mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result in better riparian condition, in turn providing more stable and useable aquatic habitat. Under these Alternatives, potential direct effects to aquatic resources would be primarily associated with herbicide application near streams and associated riparian areas, lakes, or wetlands. Most herbicides are applied in liquid formulations and are sprayed on foliage of the target vegetation. In some cases soil may be a major receptor and contamination can occur by chemicals leaching through the soil to the groundwater and ultimately reaching the aquatic environment. This method of introduction usually poses the least amount of risk to the aquatic environment because chemicals typically disappear from the ground surface by either plant uptake of the chemical, volatilization, and natural decomposition of the active ingredients or adsorption of the herbicide by soil particles. Norris et al. (1991), indicates leaching of chemicals through the soil profile is a process of major public concern, but is least likely to occur in Forest environments. Prevention measures proposed to address this are included as part of the Design Standards. Leaks, spills, and improper storage and handling of containers are the source of most pesticide related groundwater contamination. These impacts can easily be prevented with proper training of personnel and proper storage and disposal of chemicals. Risk from an accidental spill of herbicide into a water body on the Forest is considered low. Another mode of pesticide entry to the aquatic system includes overland flow from precipitation events. Risk varies depending on soil composition and timing and intensity of precipitation events after application. Risk tends to be lower on well-vegetated forests and rangeland where soil infiltration is typically greater than precipitation. Norris et al. (1991) indicated that overland flow occurs infrequently on most forestland because the infiltration capacity of the Forest floor and soil is usually far greater than the rate of precipitation. Aquatic organisms are more at risk of negative impacts from herbicides in small perennial streams, or during late season when flow is reduced, due to their limited capability for dilution. Prevention measures proposed to address precipitation events are included in the Design Standards. A reduction of noxious weeds in riparian areas and other aquatic habitats would benefit native plant species and result in better stream bank and riparian condition, in turn providing more stable and useful aquatic environments. An indirect effect of these Design Standards is that not all noxious weeds would be chemically treated. Even under the integrated weed management approach, not all weed populations would be eradicated, leaving an available seed source for continued propagation or the unlikely option of weeds being out-competed by native or desirable plant species.

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Cumulative Effects to Habitat The mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result better riparian condition, in turn providing more stable and useful aquatic habitat. Mechanical treatment as proposed is not expected to have any direct, indirect, or cumulative adverse effects on these species. No adverse downstream cumulative effects would be expected from situations involving herbicide runoff or leaching because of the method of application, Best Management Practices (BMPs), and Design Standards to prevent these types of impacts from occurring. See Appendix D for a list of the specific BMPs. It is not anticipated that there would be any cumulative effects by chemical spraying of noxious weeds due to the use of chemicals at only their prescribed label rate, the relative non-toxicity of the chemicals to other than target (i.e. plant) organisms, the use of riparian Design Standards, and the limited area of chemical treatment. Riparian habitat would benefit by decreasing weeds and the acreages to be treated are very small so there is no direct contact with fish and other aquatic species. It is anticipated that implementation of these Alternatives, in combination with these past, present, and reasonably foreseeable future actions, would result in the treatment of 0.36 acres (4 sites) of suitable habitat across the analysis area. Therefore, the cumulative effect to shortnose sucker and Lost River sucker under these Alternatives would be negligible compared to the amount of existing habitat in the analysis area.

Alternatives 3 and 5 Direct And Indirect Effects To Habitat Mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result in better riparian condition, in turn providing more stable and useful aquatic habitat. Cumulative Effects to Habitat The mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result better riparian condition, in turn providing more stable and useful aquatic habitat. Mechanical treatment as proposed is not expected to have any direct, indirect, or cumulative adverse effects on these species. Summary of Habitat and Population Status and Trend at the Forest and Bioregional Scale The Modoc NF Forest Plan (as amended by the SNFPA) requires Forest-scale habitat monitoring and bioregional-scale population monitoring for the shortnose sucker and Lost River sucker hence, the shortnose sucker and Lost River sucker effects analysis for the Noxious Weed Treatment Project must be informed by both habitat and population monitoring data. The sections below summarize the habitat and population status and trend data for the shortnose and Lost River sucker. This information is drawn from the detailed information on habitat and

Chapter 3—Affected Environment & Environmental Consequences 279 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

population trends in the Modoc National Forest MIS Report (USDA 2007), which is hereby incorporated by reference. Habitat Status and Trend Barring future water developments on the Modoc National Forest, the amount of habitat appears stable. As fish passage problems are recognized, it is probable that quality of habitat would be increased. Lost River sucker and shortnose sucker habitat on the Modoc is considered abundant and has remained relatively constant since the development of the Forest Plan (M.Yamagiwa pers. comm.). Population Status and Trend The shortnose and Lost River suckers were listed as endangered species on July 18, 1988 (USFWS 1988). No Critical Habitat has been designated. A recovery plan has been written for both species (USFWS 1993). Population decreases of these suckers seem to be primarily related to decreasing spawning habitat from damming, draining, and dredging of historical spawning areas (Ibid). Other predominant threats to these suckers are continued loss of habitat, water diversions, competition and predation by introduced species, hybridization with other sucker species, insularization of remaining habitats, and drought (USFWS 1988). Decreases in water quality resulting from timber harvest, dredging activities, removal of riparian vegetation, and livestock grazing may also cause problems for these species (USFWS 1988). All of the streams containing these fish on the Modoc National Forest have become seasonally flowing during the drought of the late 1980s and early 1990s. The varied causes for the declines in these two species are not clearly understood (USFWS 1988). What is clear is that there has been a drastic reduction in the spawning success of these long-lived species; for example, populations of both species in Oregon and in Copco Reservoir have not spawned for about 18 years (Ibid). Based upon recent surveys conducted by the National Biological Survey, there are 23,000 Lost River suckers and 73,000 shortnose suckers on the Modoc NF. According to past survey records there appears to be an increasing trend in the population numbers in the past ten year period (Ibid). Habitat availability trends for this same time period seem to be experiencing an increasing trend (Ibid). The Annual Monitoring Report for 2002 suggest that populations of these two species are relatively stable but the demographics of the populations appears to be changing. Data suggest that fish captured are beginning to appear in the older age class (U.S. Geological Survey 2003). Both the Lost River and Shortnose Suckers were petitioned for de-listing. The USFWS found that the petition did not present substantial scientific or commercial information indicating that either species warranted de-listing (67 FR 34422). Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Species Mechanical treatment as proposed would not alter or contribute to existing Forest-wide trend in population or distribution. Herbicide treatment would result in the treatment of 0.36 acres (4 sites) of suitable habitat across the analysis area. Therefore, the impact of the Noxious Weed Treatment Project would not alter or contribute to existing Forest-wide trend in population or distribution for the shortnose sucker and Lost River sucker.

280 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Modoc Sucker The Modoc sucker is a federally listed endangered species; additional information on affected environment and environmental consequences of the Noxious Weed Treatment Project on these species is found in the project BA.

Habitat - Species Relationship Detailed information on MIS for the Modoc NF is documented in the Modoc National Forest MIS Report (USDA 2007), which is hereby incorporated by reference. Suitable habitat consists of large, shallow, muddy-bottomed pools that are partially shaded by vegetation and contain cool (less than 77° F.), moderately clear water (Moyle 2002). The temperature of water in two Modoc sucker streams indicated that a maximum water temperature of less than 70° F., with daily temperature variations of less than 10° F., provides suitable conditions, and that maximum temperatures of 60 to 65° F. seem to be optimum (Studinski 1993). Most of the creeks in which Modoc suckers occur become seasonally flowing by mid summer, severely limiting the available habitat. Pools, especially during drought years, may be the most critical factor limiting populations (Ibid). The Modoc sucker utilizes toe-logs and tips of juniper revetments and coarse woody debris in streams for cover (USFS unpublished data). They also will use rocky substrate and algae if no other cover is available in the pool.

Project-level Effects Analysis based on Habitat

Key Habitat Factors for the Analysis The Forest Forest Plan identified these species as associated with riparian habitats. These species are found in the following CWHR habitat types: lacustrine and riverine.

Analysis Area for Project-level Effects Analysis The Modoc sucker occurs in two sub-drainages of the Pit River system within the Modoc NF in northeastern California. The streams in which this species occurs are characterized by low summer flows and large, shallow pools with cover, soft sediments, and clear water (USFWS 1985). In many cases, large sections of the streams have only subsurface flows in the summer and the suckers are confined to relatively small permanent pools (Studinski 1993). These streams are within the Devil's Garden and Big Valley Ranger Districts of the Modoc NF.

Current Condition of the Key Habitat Factor(s) in the Analysis Area The Modoc sucker has been extirpated from a significant portion of its naturally limited range due to hybridization with the Sacramento sucker (Catostomus occidentalis) (USFWS 1985) and habitat loss from overgrazing, siltation, channelization, and other agricultural activities (USFWS 1985). Habitat degradation has also eliminated some natural within-stream barriers that prevented Sacramento suckers from invading Modoc sucker habitat (USFWS 1985). Additional factors include predation by introduced brown trout (Salmo trutta) (Ibid) and the late 1980 and early 1990 drought, which has increased the number of creeks which were seasonally flowing during the summer.

Chapter 3—Affected Environment & Environmental Consequences 281 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Alternative 1 (No Action)

Direct and Indirect Effects to Habitat Potential adverse effects to the aquatic environment from not controlling spread of noxious weeds include but are not limited to, an increase in sedimentation, reduction in stream bank stability, elevated water temperature with the lack of canopy cover, and a potential decrease in the amount of organic matter available to enter affected streams. Without treatment, noxious weeds would likely become widely established across the Forest. This could lead to an increase in soil erosion (sediment deposition) and surface water runoff.

Cumulative Effects to Habitat As weed infestations become more severe, it becomes more difficult to restore natural or near natural conditions. Conditions arise where instead of using physical + treatments or relatively low applications of low toxicity herbicides, more intensive physical + treatment or intensive applications at higher concentrations of more toxic herbicides may be necessary to control later stages of weed infestations. When this occurs, the risk to the aquatic environment also increases and viability of aquatic species may also be at risk. It is anticipated, that under the No Action Alternative, there would be an increase in noxious weeds within suitable habitat. The relative cumulative effect to Modoc suckers would be relatively small compared to the existing amount of habitat in the analysis area.

Alternatives 2, 4, and 6

Direct and Indirect Effects to Habitat Mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result in better riparian condition, in turn providing more stable and useful aquatic habitat. Under these Alternatives, potential direct effects to aquatic resources would be primarily associated with herbicide application near streams and associated riparian areas, lakes, or wetlands. Most herbicides are applied in liquid formulations and are sprayed on foliage of the target vegetation. In some cases soil may be a major receptor and contamination can occur by chemicals leaching through the soil to the groundwater and ultimately reaching the aquatic environment. This method of introduction usually poses the least amount of risk to the aquatic environment because chemicals typically disappear from the ground surface by either plant uptake of the chemical, volatilization, and natural decomposition of the active ingredients or adsorption of the herbicide by soil particles. Norris et al. (1991), indicates leaching of chemicals through the soil profile is a process of major public concern, but is least likely to occur in Forest environments. Prevention measures proposed to address this are included as part of the Design Standards. Leaks, spills, and improper storage and handling of containers are the source of most pesticide related groundwater contamination. These impacts can easily be prevented with proper training of personnel and proper storage and disposal of chemicals. Risk from an accidental spill of herbicide into a water body on the Forest is considered low. Another mode of pesticide entry to the aquatic system includes overland flow from precipitation events. Risk varies depending on soil composition and timing and intensity of precipitation events after application. Risk tends to be lower on well-vegetated Forests and rangeland where soil infiltration is typically greater than precipitation. Norris et al. (1991) indicated that overland flow

282 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

occurs infrequently on most forestland because the infiltration capacity of the Forest floor and soil is usually far greater than the rate of precipitation. Aquatic organisms are more at risk of negative impacts from herbicides in small perennial streams, or during late season when flow is reduced, due to their limited capability for dilution. Prevention measures proposed to address precipitation events are included in the Design Standards. A reduction of noxious weeds in riparian areas and other aquatic habitats would benefit native plant species and result in better stream bank and riparian condition, in turn providing more stable and useful aquatic environments. An indirect effect of these Design Standards is that not all noxious weeds would be chemically treated. Even under the integrated weed management approach, not all weed populations would be eradicated, leaving an available seed source for continued propagation or the unlikely option of weeds being out-competed by native or desirable plant species.

Cumulative Effects to Habitat The mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result better riparian condition, in turn providing more stable and useful aquatic habitat. Mechanical treatment as proposed is not expected to have any direct, indirect, or cumulative adverse effects on these species. No adverse downstream cumulative effects would be expected from situations involving herbicide runoff or leaching because of the method of application, Best Management Practices (BMPs) and Design Standards to prevent these types of impacts from occurring. See Appendix D for a list of the specific BMPs. It is not anticipated that there would be any cumulative effects by chemical spraying of noxious weeds due to the use of chemicals at only their prescribed label rate, the relative non-toxicity of the chemicals to other than target (i.e. plant) organisms, the use of riparian Design Standards, and the limited area of chemical treatment. Riparian habitat would benefit by decreasing weeds and the acreages to be treated are very small so there is no direct contact with fish and other aquatic species. It is anticipated that implementation of these Alternatives, in combination with these past, present, and reasonably foreseeable future actions, would result in the treatment of 1.93 acres (8 sites) of suitable habitat across the analysis area. Therefore, the cumulative effect to Modoc sucker under these Alternatives would be negligible compared to the amount of existing habitat in the analysis area.

Alternatives 3 and 5

Direct and Indirect Effects to Habitat Mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result in better riparian condition, in turn providing more stable and useful aquatic habitat.

Cumulative Effects to Habitat The mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be

Chapter 3—Affected Environment & Environmental Consequences 283 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result better riparian condition, in turn providing more stable and useful aquatic habitat. Mechanical treatment as proposed is not expected to have any direct, indirect, or cumulative adverse effects on these species.

Summary of Habitat and Population Status and Trend at the Forest and Bioregional Scales The Modoc NF Forest Plan (as amended by the SNFPA) requires Forest-scale habitat monitoring and bioregional-scale population monitoring for the Modoc sucker; hence, the Modoc sucker effects analysis for the Noxious Weed Treatment Project must be informed by both habitat and population monitoring data. The sections below summarize the habitat and population status and trend data for the Modoc sucker. This information is drawn from the detailed information on habitat and population trends in the Modoc National Forest MIS Report (USDA 2007), which is hereby incorporated by reference.

Habitat Status and Trend Based on the observations of biologists, habitat availability, as a result of improved cattle allotment management, has increased over the past ten year period (M. Yamagiwa pers. comm.).

Population Status and Trend Past reports estimated the population of the Modoc sucker to be less than 5,000 individual fish (Moyle 2002) and 2,605 (Ford 1977), with the reproductive (effective) population being 200 and 104, respectively, based on length-frequency analyses (Ford 1977, USFS unpublished data). Moyle and Ford, however, did not census the entire reaches where Modoc suckers are known to exist. A more recent estimate of the effective population is 3,000 individual fish, which was determined from 1994 surveys conducted by the National Biological Survey (M. Yamagiwa pers. comm.). Population numbers for Modoc suckers is difficult to obtain and interpret. Visual counts have been conducted during night surveys with no definitive population numbers obtained, just distribution. It is known that there is a positive increase in numbers of Modoc suckers where exotic fish (largemouth bass) are removed (S. Reid pers. comm.). Based upon past survey records, it is estimated that the population trend for this species is increasing over the past ten year period (Ibid).

Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Species Mechanical treatment as proposed would not alter or contribute to existing Forest-wide trend in population or distribution. Herbicide treatment would result in the treatment of 1.93 acres (8 sites) of suitable habitat across the analysis area. Therefore, the impact of the Noxious Weed Treatment Project would not alter or contribute to existing Forest-wide trend in population or distribution for the Modoc sucker. Goose Lake Redband Trout

Habitat - Species Relationship Detailed information on MIS for the Modoc NF is documented in the Modoc National Forest MIS Report (USDA 2007), which is hereby incorporated by reference.

284 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

The Goose Lake redband trout is a Forest Service sensitive species. The name redband trout is used to cover a complex of distinctive trout that occur in isolated headwater streams of the McCloud, Pit, Klamath, and Columbia River systems of California, Nevada, and Oregon. The Goose Lake basin can be considered a disrupted part of the Sacramento River basin because Goose Lake has overflowed to the Pit River in historical times.

Project-level Effects Analysis based on Habitat

Key Habitat Factors for the Analysis The Forest Forest Plan identified these species as associated with riparian habitats. These species are found in the lacustrine and riverine CWHR habitat types.

Analysis Area for Project-level Effects Analysis The Goose Lake redband trout is endemic to Goose Lake and its major tributaries (Lassen and Willow creeks in California and the extensive Thomas Creek system and Crane Creek in Oregon) as well as to smaller streams such as Cottonwood Creek in California and several small streams in Oregon. Berg (1987) reported that Joseph, Parker, and East creeks, tributaries of the upper Pit River in California, contained trout genetically similar to Goose Lake redband trout. It is generally recognized that the native trout of the upper Pit River are Goose Lake redband trout.

Current Condition of the Key Habitat Factors in the Analysis Area The long-term persistence of this fish depends largely on the health of populations in the headwater streams flowing into Goose Lake in Oregon and California, even though much of the conservation attention has focused on large fish in the lake itself. The extirpation of the lake population during a drought and its subsequent partial recovery indicate the probable importance of downstream colonization of the lake from headwater populations. Because of the high level of concern over extirpation of Goose Lake redband trout (and other native fishes) from Goose Lake when it dried up, conservation efforts have been under way in the watershed, by both agencies and private landowners, to restore streams (e.g., by changing grazing practices) and to remove or alter migration barriers (Moyle 2002).

Alternative 1

Direct and Indirect Effects to Habitat Potential adverse effects to the aquatic environment from not controlling spread of noxious weeds include but are not limited to, an increase in sedimentation, reduction in stream bank stability, elevated water temperature with the lack of canopy cover, and a potential decrease in the amount of organic matter available to enter affected streams. Without treatment, noxious weeds would likely become widely established across the Forest. This could lead to an increase in soil erosion (sediment deposition) and surface water runoff.

Cumulative Effects to Habitat As weed infestations become more severe, it becomes more difficult to restore natural or near natural conditions. Conditions arise where instead of using physical + treatments or relatively low applications of low toxicity herbicides, more intensive physical + treatment or intensive applications at higher concentrations of more toxic herbicides may be necessary to control later stages of weed infestations. When this occurs, the risk to the aquatic environment also increases and viability of aquatic species may also be at risk.

Chapter 3—Affected Environment & Environmental Consequences 285 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

It is anticipated, that under the No Action Alternative, there would be an increase in noxious weeds within suitable habitat. The relative cumulative effect to Goose Lake redband trout would be relatively small compared to the existing amount of habitat in the analysis area.

Alternatives 2, 4, and 6

Direct and Indirect Effects to Habitat Mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result in better riparian condition, in turn providing more stable and useful aquatic habitat. Under these Alternatives, potential direct effects to aquatic resources would be primarily associated with herbicide application near streams and associated riparian areas, lakes, or wetlands. Most herbicides are applied in liquid formulations and are sprayed on foliage of the target vegetation. In some cases soil may be a major receptor and contamination can occur by chemicals leaching through the soil to the groundwater and ultimately reaching the aquatic environment. This method of introduction usually poses the least amount of risk to the aquatic environment because chemicals typically disappear from the ground surface by either plant uptake of the chemical, volatilization, and natural decomposition of the active ingredients or adsorption of the herbicide by soil particles. Norris et al. (1991), indicates leaching of chemicals through the soil profile is a process of major public concern, but is least likely to occur in Forest environments. Prevention measures proposed to address this are included as part of the Design Standards. Leaks, spills, and improper storage and handling of containers are the source of most pesticide related groundwater contamination. These impacts can easily be prevented with proper training of personnel and proper storage and disposal of chemicals. Risk from an accidental spill of herbicide into a water body on the Forest is considered low. Another mode of pesticide entry to the aquatic system includes overland flow from precipitation events. Risk varies depending on soil composition and timing and intensity of precipitation events after application. Risk tends to be lower on well-vegetated forests and rangeland where soil infiltration is typically greater than precipitation. Norris et al. (1991) indicated that overland flow occurs infrequently on most forestland because the infiltration capacity of the Forest floor and soil is usually far greater than the rate of precipitation. Aquatic organisms are more at risk of negative impacts from herbicides in small perennial streams, or during late season when flow is reduced, due to their limited capability for dilution. Prevention measures proposed to address precipitation events are included in the Design Standards. A reduction of noxious weeds in riparian areas and other aquatic habitats would benefit native plant species and result in better stream bank and riparian condition, in turn providing more stable and useful aquatic environments. An indirect effect of these Design Standards is that not all noxious weeds would be chemically treated. Even under the integrated weed management approach, not all weed populations would be eradicated, leaving an available seed source for continued propagation or the unlikely option of weeds being out-competed by native or desirable plant species.

Cumulative Effects to Habitat The mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result better riparian condition, in turn providing more stable and useful aquatic habitat.

286 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Mechanical treatment as proposed is not expected to have any direct, indirect, or cumulative adverse effects on these species. No adverse downstream cumulative effects would be expected from situations involving herbicide runoff or leaching because of the method of application, Best Management Practices (BMPs) and Design Standards to prevent these types of impacts from occurring. See Appendix D for a list of the specific BMPs. It is not anticipated that there would be any cumulative effects by chemical spraying of noxious weeds due to the use of chemicals at only their prescribed label rate, the relative non-toxicity of the chemicals to other than target (i.e., plant) organisms, the use of riparian Design Standards, and the limited area of chemical treatment. Riparian habitat would benefit by decreasing weeds and the acreages to be treated are very small so there is no direct contact with fish and other aquatic species. It is anticipated that implementation of these Alternatives, in combination with these past, present, and reasonably foreseeable future actions, would result in the treatment of 12.6 acres (9 sites) of suitable habitat across the analysis area. Therefore, the cumulative effect to Goose Lake redband trout under these Alternatives would be negligible compared to the amount of existing habitat in the analysis area. Rainbow Trout, Brown Trout, and Largemouth Bass The rainbow trout, brown trout, and largemouth bass are MIS game species on the Modoc NF. They are all found in lacustrine and riverine habitats on the Forest. These species have historically been moved and stocked in many streams and lakes of the Modoc NF throughout the 20th century, although many lakes and streams have naturally reproducing populations. It is unknown to what extent naturally reproducing rainbow trout are of native genetic stock, unaffected by hatchery introductions, while all brown trout and largemouth bass are non-native to the area.

Habitat - Species Relationship Detailed information on MIS for the Modoc NF is documented in the Modoc National Forest MIS Report (USDA 2007), which is hereby incorporated by reference.

Project-level Effects Analysis Based on Habitat

Key Habitat Factor(s) for the Analysis The Forest Forest Plan identified these species as associated with riparian habitats. These species are found in the following CWHR habitat types: lacustrine and riverine.

Analysis Area for Project-level Effects Analysis Rainbow trout are widely distributed throughout streams and lakes within the Sierra Nevada bio- region. Rainbow trout habitat on the Modoc is considered abundant and has remained relatively constant since the development of the Forest Plan (M. Yamagiwa pers. comm.). Brown trout are widely distributed throughout streams and lakes within the Sierra Nevada Bio- region. Brown trout habitat on the Modoc is considered abundant and well distributed at higher elevations across the Forest, primarily on the Warner Mountain Ranger District (M. Yamagiwa pers. comm.).

Chapter 3—Affected Environment & Environmental Consequences 287 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Available largemouth bass habitat on the Modoc National Forest consists primarily of Big Sage Reservoir with bass occupying several other small reservoirs on the Devil’s Garden and Doublehead Districts.

Current Condition of the Key Habitat Factor(s) in the Analysis Area Several grazing strategies have been implemented on allotments (containing rainbow trout) to improve riparian conditions. Habitat trend for rainbow trout on the Modoc appears to be stable at this time (M. Yamagiwa pers. comm.). This species has stable populations across the Sierra Nevada Bioregion. Some Forests, including the Modoc National Forest, are actively removing brown trout from streams to restore native fisheries and amphibian populations. The amount of largemouth bass habitat has remained relatively stable since the development of the Forest Plan, as the existing lakes and reservoirs have not undergone any substantial change in habitat conditions.

Alternative 1 Direct and Indirect Effects to Habitat Potential adverse effects to the aquatic environment from not controlling spread of noxious weeds include but are not limited to, an increase in sedimentation, reduction in stream bank stability, elevated water temperature with the lack of canopy cover, and a potential decrease in the amount of organic matter available to enter affected streams. Without treatment, noxious weeds would likely become widely established across the Forest. This could lead to an increase in soil erosion (sediment deposition) and surface water runoff. Cumulative Effects to Habitat As weed infestations become more severe, it becomes more difficult to restore natural or near natural conditions. Conditions arise where instead of using physical + treatments or relatively low applications of low toxicity herbicides, more intensive physical + treatment or intensive applications at higher concentrations of more toxic herbicides may be necessary to control later stages of weed infestations. When this occurs, the risk to the aquatic environment also increases and viability of aquatic species may also be at risk. It is anticipated, that under the No Action Alternative, there would be an increase in noxious weeds within suitable habitat. The relative cumulative effect to these species would be relatively small compared to the existing amount of habitat in the analysis area.

Alternatives 2 and 4 Direct and Indirect Effects to Habitat Mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result in better riparian condition, in turn providing more stable and useful aquatic habitat. Under these Alternatives, potential direct effects to aquatic resources would be primarily associated with herbicide application near streams and associated riparian areas, lakes, or wetlands. Most herbicides are applied in liquid formulations and are sprayed on foliage of the target vegetation. In some cases soil may be a major receptor and contamination can occur by chemicals leaching through the soil to the groundwater and ultimately reaching the aquatic

288 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

environment. This method of introduction usually poses the least amount of risk to the aquatic environment because chemicals typically disappear from the ground surface by either plant uptake of the chemical, volatilization, and natural decomposition of the active ingredients or adsorption of the herbicide by soil particles. Norris et al. (1991), indicates leaching of chemicals through the soil profile is a process of major public concern, but is least likely to occur in Forest environments. Prevention measures proposed to address this are included as part of the Design Standards. Leaks, spills, and improper storage and handling of containers are the source of most pesticide related groundwater contamination. These impacts can easily be prevented with proper training of personnel and proper storage and disposal of chemicals. Risk from an accidental spill of herbicide into a water body on the Forest is considered low. Another mode of pesticide entry to the aquatic system includes overland flow from precipitation events. Risk varies, depending on soil composition and timing and intensity of precipitation events after application. Risk tends to be lower on well-vegetated forests and rangelands where soil infiltration is typically greater than precipitation. Norris et al. (1991) indicated that overland flow occurs infrequently on most forestland because the infiltration capacity of the forest floor and soil is usually far greater than the rate of precipitation. Aquatic organisms are more at risk of negative impacts from herbicides in small perennial streams, or during late season when flow is reduced, due to their limited capability for dilution. Prevention measures proposed to address precipitation events are included in the Design Standards. The prescribed widths of the Riparian Conservation Areas (RCAs) are consistent with the Forest Plan as modified by the Sierra Nevada Framework ROD, 2001. The specified distances for perennial streams, lakes and special aquatic features is 300 feet, and 150 feet for seasonally flowing streams. Herbicide treatment for these For Alternatives 2 and 4 are as follows: From the High Water Mark outward to 10 feet to– no herbicide use. From a distance of 10 feet to 150 feet only aquatic Glyphosate may be applied by wicking on the plant. On seasonally flowing streams, Glyphosate, Clopyralid, Dicamba, and Triclopyr may be used farther than 150 feet. On perennial streams, Glyphosate, Clopyralid, Dicamba, and Triclopyr may be used farther than 300 feet. 2, 4-D would not be applied within 1,000 feet of surface or live water. A reduction of noxious weeds in riparian areas and other aquatic habitats would benefit native plant species and result in better stream bank and riparian condition, in turn providing more stable and useful aquatic environments. An indirect effect of these Design Standards is that not all noxious weeds would be chemically treated. Even under the integrated weed management approach, not all weed populations would be eradicated, leaving an available seed source for continued propagation or the unlikely option of weeds being out- competed by native or desirable plant species. Cumulative Effects to Habitat The mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result better riparian condition, in turn providing more stable and useful aquatic habitat. Mechanical treatment as proposed is not expected to have any direct, indirect, or cumulative adverse effects on these species. No adverse downstream cumulative effects would be expected from situations involving herbicide runoff or leaching because of the method of application, Best Management Practices (BMPs) and Design Standards to prevent these types of impacts from occurring. See Appendix D for a list of the specific BMPs. It is not anticipated that there would be any cumulative effects by chemical spraying of noxious weeds due to the use of chemicals at only their prescribed label rate, the relative non-toxicity of

Chapter 3—Affected Environment & Environmental Consequences 289 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

the chemicals to other than target (i.e. plant) organisms, the use of riparian Design Standards, and the limited area of chemical treatment. Riparian habitat would benefit by decreasing weeds and the acreages to be treated are very small so there is no direct contact with fish and other aquatic species. Under these Alternatives, the potential for direct and indirect effects to water quality would be prevented through the application of Design Standards. It is unlikely that these Alternatives would introduce pesticides into either the North/South Fork of the Pit River or Klamath River that are in excess of the applicable Basin Water Quality Plans and would meet state and federal water quality objectives (Adams 2007). Therefore, the cumulative effect to rainbow trout, brown trout, and largemouth bass under these Alternatives would be negligible.

Alternatives 3 and 5 Direct and Indirect Effects to Habitat Mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result in better riparian condition, in turn providing more stable and useful aquatic habitat. Cumulative Effects to Habitat The mechanical treatment of weed sites could result in some localized soil disturbance and possibly increased sedimentation of nearby drainages. These effects would be expected to be minor and temporary in duration because of the comparatively few acres of soil disturbance followed by the reclamation and restoration (where appropriate) of treated areas. Treatment would result better riparian condition, in turn providing more stable and useful aquatic habitat. Mechanical treatment as proposed is not expected to have any direct, indirect, or cumulative adverse effects on these species.

Alternative 6 Direct and Indirect Effects to Habitat See the discussion on Alternatives 2 and 4. The primary difference is that under this Alternative, the SMZs would be treated for noxious weeds by the use of herbicides other than Glyphosate. From the outer edge of the High Water Mark for a distance of 10 feet, aquatic formulations of Glyphosate may be used. From 10 feet from the edge of the High Water Mark outward, 2, 4- Damine, chlorsulfuron, and Glyphosate may be used. From 25 feet from the edge of the High Water Mark outward Clopyralid, Dicamba, Triclopyr, and Tank Mix #1 (chlorsulfuron + 2, 4-D amine) and Tank Mix #2 (Dicamba + 2, 4-D amine). Outside of 100 feet, ester forms of 2, 4-D may be used in the tank mix. In the areas under the Lahontan Water Quality Control Board jurisdiction (see Figure 3-2), with Alternative 6 no herbicide treatment will occur from the high-water mark for a distance of 10 feet. From a distance of 10 to 100 feet from the high-water mark, only aquatic glyphosate will be used. At a distance greater than 100 feet from the high-water mark, the other herbicides shown in the Alternative may be applied.

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Cumulative Effects to Habitat In this Alternative, 6.1 acres are within 10 feet of a waterway and 37.5 acres are located within 100 feet of water. The concentrations of herbicides that are proposed to be applied near or adjacent to water (within 25 feet of High Water Mark for streams, lakes, and special aquatic features) are less than label directions and are determined to be a low risk to adversely effect downstream beneficial uses (Adams 2007). Under these Alternatives, the potential for direct and indirect effects to water quality would be prevented through the application of Design Standards. It is unlikely that these Alternatives would introduce pesticides into either the North/South Fork of the Pit River or Klamath River that are in excess of the applicable Basin Water Quality Plans and would meet state and federal water quality objectives (Adams 2007). Therefore, the cumulative effect to rainbow trout, brown trout, and largemouth bass under these Alternatives would be negligible. Terrestrial Wildlife Species The analysis area for terrestrial species includes the entire Modoc National Forest. This area encompasses about 1.6 million acres of Forest System lands, as well as 337,000 acres of lands administered by other agencies or private landowners. The Forest has a diverse series of habitats, ranging from sagebrush at the lowest elevations to white bark pine at the highest elevations. Special habitats or features that support these species include black oak, aspen, wetlands, cliffs, talus slopes, snags, coarse woody debris, and lava-related features such as tubes, caves, and flows. Some species are limited to specialized habitats such as lava caves and tubes, while others like mule deer are found in all of the habitat types. Since the publication of the Draft Environmental Impact Statement for the noxious weed project, the Geographical Information System (GIS) data have been updated in 2005; therefore, there will be differences in the information provided between the DEIS and the FEIS and its supporting documentation with respect to noxious weed and wildlife occurrences. Exact acreages were used from the GIS runs, but they were for tracking purposes and not to connote any undue accuracy in the values.

Wildlife Management Direction Management direction and protection measures for bald eagle and its habitat are provided in a general way within the Endangered Species Act (1973), the Bald Eagle Protection Act (1940), and the Migratory Bird Treaty Act (1918), as well as the Forest Service Manual. Specific direction is found in the Pacific Bald Eagle Recovery Plan and the Modoc National Forest Land and Resource Management Plan (Forest Plan) (USFS 1991a). Although the bald eagle has been de-listed and is now considered a sensitive species, the following direction provides general guidance for management. With respect to the Endangered Species Act (ESA) (1973), “The purposes of this Act are to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, to provide a program for the conservation of such endangered species and threatened species, and to take such steps as may be appropriate to achieve the purposes of the treaties and conventions … [until] the measures provided pursuant to this Act are no longer necessary. Such methods and procedures include, but are not limited to, all activities associated with scientific resources management such as research, census, law enforcement, habitat acquisition and maintenance, propagation, live tarping, and transplantation, and in the

Chapter 3—Affected Environment & Environmental Consequences 291 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

extraordinary case where population pressures within a given ecosystem cannot be otherwise relieved, may include regulated taking.” The Migratory Bird Treaty Act (1918 as amended by PL 99-645 1986) states that, “Except as allowed by implementing regulations, this act makes it unlawful to pursue, hunt, kill, capture, possess, buy, sell, purchase, or barter any migratory bird, including the feathers or other parts, nests, eggs, or migratory bird products. Public Law 95-616 also ratified a treaty with the Soviet Union specifying that both nations will take measures to protect identified ecosystems of special importance to migratory birds from pollution, detrimental alterations, and other environmental degradations.” The Bald Eagle Protection Act (1940) imposes criminal and civil penalties on anyone (including associations, partnerships and corporations) in the U.S. or within its jurisdiction who, unless excepted, takes, possesses, sells, purchases, barters, offers to sell or purchase or barter, transports, exports or imports at any time or in any manner a bald or golden eagle, alive or dead; or any part, nest or egg of these eagles; or violates any permit or regulations issued under the Act. A criminal conviction requires that the violator acted knowingly or with wanton disregard of the consequences. Forest Service Manual direction states that Forests, “… conduct activities and programs to assist in the identification and recovery of threatened and endangered plant and animal species... Through the biological evaluation process, review actions and programs authorized, funded and carried out by the Forest Service to determine their effect on threatened and endangered species and species proposed for listing.” The manual also states that, Forests should, “Identify and prescribe measures to prevent adverse modification or destruction of critical habitat and other habitats essential for the conservation of endangered, threatened, and proposed species. Protect individual organisms or populations from harm or harassment as appropriate.” (USFS 1991a) The Pacific Bald Eagle Recovery Plan (USDI USFWS 1986) provides explicit direction for habitat management and population goals. Although there is no specific direction concerning noxious weed management in the recovery plan, the following guidelines could pertain to the project.  Maintain and enhance avian and mammalian food sources (1.312 found on page 46).  Maintain and enhance wetland areas for waterfowl production (1.3121 found on page 47).  Restrict human disturbance at eagle use areas (1.33 found on page 52).  Establish buffer zones around nest sites (1.331 found on page 53).  Exclude logging, construction, habitat improvement, and other activities during critical periods of eagle use (1.332 found on page 53).  Prohibit vehicle traffic at sensitive key areas during periods of eagle use (1.334 found on page 54).  Monitor levels of pollutants and the effects they may have on eagles (2.222 found page 61). In addition, the Modoc Forest Plan (USFS 1991b) direction for the bald eagles from page 4-26 is paraphrased below:  Implement the Bald Eagle Recovery Plan as applicable to the Modoc National Forest.  Manage habitats according to the Raptor Management Prescription.  Survey and manage occupied and potential sites.

292 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Wildlife Risk Assessment Methods and Definitions The analysis of potential effects to wildlife from the ingestion of herbicides was completed using various sources of information. Syracuse Environmental Research Associates, Inc. (SERA) risk assessments authored by Dr. Patrick Durkin, PhD under contract to the Forest Service, formed a basis for the narratives and tables. David Bakke, USDA Forest Service Region 5 Pesticide Use Specialist, developed the worksheets which contain these tables; they are found within the Project File for the Modoc NF Noxious Weeds Project. In addition, peer-reviewed journal articles provided insights to the potential effects of herbicides on wildlife conducted in field situations (as opposed to laboratory experiments), as well as the potential effects of noxious weeds on wildlife species and their habitats. The pesticide risk assessment consists of an estimate of the potential doses that different types of wildlife may be exposed to from the application of herbicides under various scenarios (e.g., a large bird consuming herbicide-contaminated vegetation). These doses are then compared against the lowest sub-chronic or chronic “No Observable Effect Level” (NOEL) or the “No Observable Adverse Effect Level” (NOAEL) for a comparable species. The ratio of the dose ingested to the NOEL/NOAEL is called a Hazard Quotient (HQ). The lowest NOEL or NOAEL is based on data from experiments on surrogate species (e.g., rats, dogs, ducks) instead of the species of interest themselves (spotted owls, marten, etc). By using the lowest NOEL/NOAEL regardless of the species, some of the interspecies variability is taken into account. This analysis includes a variance found within the application rate or the applied concentration of an herbicide, which may change based on local conditions. In addition, some variability occurs in the various scenarios, including the percentage of an animal’s diet containing contaminated materials (insects, vegetation, fish, small mammals) or a spill of a chemical into water. In either case, exposure depends on the amount of chemical hypothetically ingested or absorbed by a type of animal (e.g., predatory bird eating contaminated fish, small bird eating contaminated insects, carnivorous mammal eating prey). The risk is expressed as a central estimate bounded by lower and upper levels. Because of the need to encompass many different types of exposure as well as the need to express the uncertainties in the assessment, this risk assessment involves numerous calculations. These calculations are contained in worksheets in the project file for this FEIS, and are based on the SERA risk assessments for the various herbicides proposed for use in the FEIS. The acute scenarios discussed within the Biological Assessment, the Biological Evaluation, and the Management Indicator Species Report assume that 100% of the diet contains contaminated materials. For the chronic levels (on-site), the lower level consists of 10%, the central level consists of 30%, and the upper level consists of 100% of the diet in contaminated materials. As described in worksheets, exposure rates are expressed in milligrams (mg) of absorbed dose per kilogram (kg) of body weight per day. For the acute exposure scenario, the estimated residue level is taken as the product of the application rate and the residue rate. For the longer-term exposure scenario, a duration of 90 days is used, and the dissipation on the vegetation is estimated based on the estimated or established foliar halftimes. The quantitative risk characterization is expressed as the Hazard Quotient, which is the ratio of the estimated exposure doses to the lowest NOEL/NOAEL. The hazard quotient provides a way to relate the risk of the use of the various herbicides, so the decision maker can make an informed decision. Hazard Quotients greater than 1.0 are expressed in standard decimal notation and smaller numbers are expressed in scientific notations, e.g., 7 E-7 equivalent to 7×10-7 or 0.0000007.

Chapter 3—Affected Environment & Environmental Consequences 293 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

There are Hazard Quotients for each of the herbicides proposed for use within the Noxious Weed Project FEIS. Additives to the formulations that might be used when herbicides are applied are not considered quantitatively in this risk assessment, with the exception of surfactants containing nonylphenol polyethoxylate as an active ingredient. Acute exposure -- A single exposure or multiple exposures occurring within a short time (24 hours or less). Chronic exposure -- Long-term exposure. Lab studies extend over the average lifetime of the species (for a rat, exposure is two years). No Observable Effect Level (NOEL) – The dose of a chemical at which no statistically or biologically significant increases in frequency or severity of adverse effects were observed between the exposed population and its appropriate control. Effects may be produced at this dose, but they are not considered to be adverse to the organism. No Observable Adverse Effect Level (NOAEL) - The dose of a chemical at which no treatment related effects were observed. Federally Listed Terrestrial Wildlife Species The Forest has a diverse series of habitats ranging from sagebrush at the lowest elevations, to white bark pine at the highest elevations. The following table lists the federally listed wildlife species that are present on the Forest. The USDI Fish and Wildlife Service (USFWS) letter, dated July 11, 2005 (1-10-05-105-SP), was used to determine the species that should be included in this analysis. The most current species list was downloaded on June 19, 2008. The analysis includes the species included on both lists.

Table 3 - 71. Federally Listed Species Occurring On or Downstream of the Modoc National Forest

Common Name Scientific Name Status Bald Eagle Haliaeetus leucocephalus de-listed Northern Spotted Owl Strix occidentalis caurina Threatened The next phase of the analysis process involves deciding which species to carry forward to the effects section. This process is documented in the following table, which details the status of the species, and discloses whether or not they are potentially affected by the Noxious Weeds Treatment Project. As can be seen in the table below, the only terrestrial species potentially affected by the project, which will be carried forward for further analysis, is the bald eagle. The northern spotted owl will not be further discussed because the project does not directly or indirectly affect the habitat, or the Forest-level population trend.

Table 3 - 72. Selection of MIS for Project-Level Analysis for the Noxious Weed Treatment Project

Species Management Species whose Species whose habitat is Species whose Indicator habitat is not in or in or adjacent to project habitat would be Species adjacent to the area, but would not be either directly or project area, and either directly or indirectly be would not be indirectly affected by the affected by the affected by the project. project. project. Bald X X Eagle Northern Only physical + Spotted X treatments would occur Owl within habitat.

294 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Consultation to Date Forest and USDI Fish and Wildlife Service, Klamath Falls [Oregon] Fish and Wildlife Office, personnel have conducted ongoing consultation during the course of the planning effort. Over the years, the lead biologist for USFWS in the consultation process has changed; our new lead for consultation is Rick Hardy. Tony Hawkes, Wildlife Biologist and Contaminants Specialist, has also been included in this consultation process. US Fish and Wildlife Service correspondences completed for the informal consultation include 1- 10-03-I-082, 1-10-98-TA-042, 1-10-99-TA-067, 1-10-01-SP-020, 1-10-03-SP-037, 1-10-03-I- 082, 1-10-04-234, 1-10-05-I-021, 1-10-05-SP, and the letter of concurrence dated 8 March 2007. Three meetings between USFS and USFWS have occurred in Klamath Falls at the USFWS office. Mary Flores attended a meeting in Klamath Falls on January 7, 2003 with Leonard Le Captain, Tony Hawkes, and Stewart Reid to discuss the project as it stood at that point in time. On May 20, 2005, Mary Flores, Rick Hardy and Tony Hawkes discussed the weed project, especially in light of the change in the Design Standards for 2,4–D, tank mixes with 2, 4-D, and the addition of chlorsulfuron. A final, Request for Concurrence letter was sent to the Klamath Falls Office November 29, 2006; the concurrence letter for the Modoc NF Noxious Weeds Project is in Appendix A of the terrestrial BA. In addition, Mary Flores (USFS), Leonard Le Captain (USFWS), Rick Hardy (USFWS), and Tony Hawkes (USFWS) and USFWS front desk staff conducted numerous phone consultations, including, but not limited to October 26, 2000, December 12, 2000, November 18, 2002, November 26, 2002, December 16, 2002, December 18, 2002, January 7, 2003, February 10, 2003, March 31, 2003, December 12, 2003, August 31, 2004, September 14, 2004, November 3, 2004, February 14, 2005, February 15, 2005, March 15, 2005, March 25, 2005, April 5, 2005, August 24, 2005, September 13, 2005, September 19, 2006, and November 13, 2006. Other USFWS offices were contacted on various occasions as well.

Federally Listed Threatened and Endangered Wildlife Species The following species information is taken from the Biological Assessment located in Appendix V.

Bald Eagle (delisted) The Modoc NF has bald eagle nest sites dispersed across the Forest, based on data from April 2005. The territories are usually near lakes or streams with abundant fish and waterfowl food supplies. The trend for bald eagle has increased to the point that the US Fish and Wildlife Service is in the process of delisting this species. In certain areas within northeastern California, bald eagle nesting territories have exceeded recovery plan goals (J. Purvine and S. Clay, pers. comm.). There are five bald eagle territories that have the potential for noxious weed treatment on the Forest. Suitable habitat for bald eagles includes large trees for perching and nesting near lakes and large rivers. Polite et al (1990) state that 87% of bald eagle nest sites in California are within one mile of water, and that bald eagles require "large bodies of water, or free-flowing streams with abundant fish..." for feeding. Shimamoto (1981) suggests that bald eagles require their food supply to be within a mile of their nest. According to Shimamoto and Newman (1981), a suitable feeding site is usually within 12 miles of bald eagle roosts; and winter roosts have not been found greater than 20 miles from nest sites. Winter roosts are isolated stands of late-seral habitat on prominent topography near abundant winter food, which includes waterfowl and carrion. There

Chapter 3—Affected Environment & Environmental Consequences 295 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

are about 21,200 acres of occupied nesting habitat Forest-wide, based on the Forest EVEG data layer; there are 1,100 additional acres of potential habitat utilizing the same vegetation data. Foraging habitat on the Modoc National Forest often includes lakes, reservoirs, and streams as part of the nest stand. Often agricultural lands adjacent to or within the Forest are part of foraging areas. Bald eagles are frequently seen utilizing carrion (e.g., dead cows), waterfowl, and fish; however, ground squirrel and snake remains have also been found under active nests. One of the threats to bald eagle has been the ingestion of poisonous substances (USDA 2007b). Between 1947 and 1970, reproduction in most bald eagle populations had declined drastically (various authors in USFWS 1986). Research in the late 1950’s through the 1960’s indicated that certain organochlorine pesticides (e.g., DDE, the environmental form of DDT) caused excessive eggshell thinning, thereby interfering with productivity (various authors in USFWS 1986). This trend has reversed with the decrease of these pesticides in the environment; however, there is still concern about potential effects to bald eagles from environmental contaminants (USFWS 1986). Noise and potential harassment of eagles from management activities is also a concern. The most intensive disturbance would come from crews treating the weeds. In a model that assesses the effects of disturbance on breeding bald eagles, researchers found eagles responded differently to stimuli depending on the type and duration of disturbance (Grubb and King 1991). Their findings indicated that pedestrian activities near active nests provided the greatest amount of disturbance, and aircraft provided the least. They also found the distance to the disturbance was the most important aspect of human disturbance. Many studies on eagle and human disturbance have recommended buffers be placed around eagles. The width of these buffers varies with time of the year and the type of disturbance. Grubb and King (1991) recommended that a minimum buffer of 600 meters be instituted around breeding bald eagles. Values of 500 meters (Fraser et al. 1985) and 450 meters (Knight and Knight 1984) for nesting eagles and feeding eagles, respectively, have also been recommended. The restriction used in the Modoc Land and Resource Management Plan (Forest Plan) exceeds these recommendations. The Forest Plan direction is to institute a limited operating period within a ¼ (no line of sight to nest) to ½ mile (line of sight to nest) radius around active nest trees from November to mid August; this period equates to nest maintenance, courtship, incubation, rearing, and fledging of young. Key Bald Eagle Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, would have no effect on large nest trees, pilot trees, or foraging habitat for bald eagle; bald eagles are not directly tied to the noxious weeds food cover or food. The potential effects consist of the potential ingestion of contaminated prey and disturbance to nesting birds. Bald Eagle Analysis Area for Project-level Effects Analysis: The analysis area for bald eagle is limited to the 22,300 acres of occupied and potential habitat on the Forest. This habitat is mainly located on the Devil’s Garden and Big Valley RD, with scattered location on the rest of the Forest near suitable water bodies.

Alternative Analysis Effects for Bald Eagle Habitat

Alternative 1 (Current Management) Direct and Indirect Effects to Habitat: The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect on bald eagle habitat. There would be no change in the current or future amount of nest or pilot trees by the treatment of noxious weeds. Habitat for prey would remain the same or potentially improve. Zero % of the

296 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

current bald eagle habitat in the analysis area would be affected by implementation of Alternative 1. Cumulative Effects to Habitat: Because there is no direct or indirect effect to bald eagle habitat, there are no cumulative effects to bald eagle habitat under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat: GIS runs indicate that there are six noxious weed locations within ½ mile of bald eagle nests, and one noxious weed occurrence within potential habitat on National Forest System lands. There is a maximum of 4.74 acres of physical + treatments and a maximum 4.73 acres of herbicide treatments within occupied bald eagle habitat. Chemical treatments could be significantly less if the 3.84 acres of Mediterranean sage occurrence is treated using physical + methods. There is an additional 0.08 acres of weeds that could be sprayed in areas typed as potential bald eagle habitat. The Canada thistle (WM009CIAR4) occurrence consists of a series of old beaver ponds that are mostly sedimented into meadow habitat and do not contain fish (M. Yamagiwa, pers. comm.). They were typed as potential bald eagle habitat, due to an artifact in the data set. Therefore, there would be no effect to bald eagle or its habitat by the treatment of this weed occurrence.

Table 3 - 73. Weed Treatments by Alternative in Occupied Bald Eagle Habitat

ID Number Weed Name Acres Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Mediterranean DG018SAAE sage 0.53 mech&phys mech&phys mech&phys mech&phys P/H Mediterranean DG019SAAE sage 3.84 mech&phys mech&phys mech&phys mech&phys P/H BV186ONAC Scotch thistle 0.09 P/H mech&phys P/H mech&phys P/H BV185ONAC Scotch thistle 0.09 P/H mech&phys P/H mech&phys P/H BV194ONAC Scotch thistle 0.09 P/H mech&phys P/H mech&phys P/H DG006CIAR4 Canada thistle 0.09 none none none mech&phys herbicide Total Herbicide 0.27 0 0.27 0 4.73 Total Physical 4.64 4.64 4.64 4.74 4.64 There would be no direct effects to bald eagle habitat by physical + or chemical removal of weeds. No potential nest or pilot trees would be affected by this project. Terrestrial prey habitat would not be affected by the treatment of current weed occurrences. The largest weed occurrence, the 3.84-acre site of Mediterranean Sage DG019SAAE, is along the river and the highway. It is not a homogenous patch of weeds, so there would be other plants that would remain on site once the areas are treated (B. Raymond and C. Beyer, pers. comm.). All the other weed occurrences are small enough that there would be sufficient prey for eagles to utilize. Using Design Standards for no spray areas that protect Threatened and Endangered Species (TES) aquatic species as well as water quality, should minimize potential contamination of fish. There may be a beneficial effect to prey habitat by weed removal. Although bald eagles on the Modoc tend to forage on fish, waterfowl, and carrion, there have been remains of ground squirrels and other animals found under active nests. Eliminating weeds, thereby allowing native plants to thrive, could improve potential cover and food for some types of prey. Under Early Detection/Rapid Response management under Alternatives 4 to 6, additional weed occurrences could be treated. The Forest Service must consult with USFWS before treatment of any new sites in occupied bald eagle habitat is undertaken, in order to mitigate potential negative

Chapter 3—Affected Environment & Environmental Consequences 297 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

effects. Therefore, there are no direct or indirect effects to bald eagle habitat expected by the implementation of any Alternative. Cumulative Effects to Habitat: Because there are no direct or indirect effects to bald eagle habitat, there are no cumulative effects to bald eagle habitat under this Alternative.

Bald Eagle Population Status and Trend at the Forest Scale The Standards and Guidelines for bald eagle management found in the Modoc NF Forest Plan (as amended by the SNFPA 2001) focus on the implementation of the Pacific Bald Eagle Recovery Plan, as well as monitoring nesting and wintering bald eagle status. The sections below summarize population status and trend data for the bald eagle. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Population Status and Trend at the Bioregional Scale and Local Scales Population monitoring data is collected by the Modoc NF, as well as state and federal partners. The CDFG has coordinated annual, statewide breeding surveys since 1973 (CDFG 2006). During 1996, 1997, and 1998, 32 new bald eagle breeding territories were reported in California, resulting in a total of 180 territories known to have been occupied at sometime in the 1990s (CDFG 2006). The breeding range has expanded from portions of eight counties in 1981 to 27 of California's 58 counties currently. In addition to a constant upward trend in population, productivity data for the past ten years show that the recovery plan target fledgling rate has been met and relatively constant over this period (SNFPA 2001). Bald eagles have been monitored on Breeding Bird Survey (BBS) routes throughout California. California-wide BBS data for the period of 1966-2004 classifies bald eagle as “Definitely increasing” (Siegel and DeSante 1999) with a significant increase of 12.3% (range 9.2 to 15.3) per year.

Table 3 - 74. Bald Eagle Breeding Population Data for California, 1990 - 1999

No. of Known No. of No. of No. of Young No. of Young Fledged Year Territories Territories Territories Produced Per Territory Surveyed Occupied

1990 107 102 94 95 1.1

1991 111 105 90 82 1.0

1992 120 110 99 82 1.1

1993 127 116 102 103 1.1

1994 142 129 116 120 1.1

1995 146 129 105 89 0.9

1996 160 144 124 128 1.1

1997 171 160 142 140 1.1

1998 180 168 148 125 0.9

1999 188 180 151 138 1.0

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At the Sierra Nevada scale for the period of 1966-2004, bald eagles were detected at two BBS routes within the Sierra Nevada with a non-significant increase of 52.3% (range 5.5 to 99.2%) per year. Although the Regional Credibility ranking is “Red”, due to small sample size and low abundance, this increasing trend is consistent with the trends observed at the State and Survey- wide scales. Locally, bald eagles have increased as well. Before the Modoc National Forest Forest Plan was finalized, there were 10 active bald eagle territories on the Forest. During the planning phase for the Modoc Forest Plan, a recovery goal of 21 territories of bald eagle was established (USDA 1991b). As of 2005, there were 33 territories found on the Modoc National Forest. The current amount of viable territories is well above the recovery plan and Forest Forest Plan goals. In the last five years, 31 out of 33 territories have produced offspring,, often annually. The distribution for bald eagle has expanded since the time of the Modoc Forest Plan.

Table 3 - 75. Status of Bald Eagle Territories as of April 2006

Modoc National Forest Bald Eagle Breeding Territory Summary Number of BE territories before Forest Plan was finalized in 1991 10 Forest Recovery Goal for the # of BE territories per the Forest Plan Final EIS, pg. 3-98 21 Current Number of BE territories on Modoc National Forest as of 2005 33 Number of BE territories with documented nesting activity from 2000-2005 32 Number of BE territories which have produced young from 2000-2005 31

Direct and Indirect Effects of Physical + Methods for all Alternatives on Bald Eagle Populations Alternatives 3 and 5, as well as the physical + portions of 2, 4, and 6 would have no effect to bald eagles for the following reasons. There would be no chemicals utilized to treat weeds; therefore there would be no chance of ingestion of contaminated prey. In addition, any weed sites to be treated in a given year that are in bald-eagle nesting areas would be surveyed in order to determine reproductive status. If nesting eagles are present, a Limited Operating Period would be instituted up to ½ mile line of sight around active nest sites to minimize disturbance to nesting birds.

Direct and Indirect Effects of the Use of Herbicides (Alternatives 2, 4, and 6) on Bald Eagle Populations Four out of thirty-three territories currently have weed occurrences that include the use of herbicides under Alternatives 2, 4, and 6. Assuming a maximum of 4.73 acres (0.02%) out of 22,300 acres of occupied and potential habitat Forest-wide could be treated with herbicides. As can be seen by the table below, the only chemical of concern for bald eagle is 2, 4-D, which has hazard quotient ratings above 1.0 for a predatory bird consuming contaminated fish scenario. This table was generated based on information provided by Syracuse Environmental Research Associates, Inc. and provided by David Bakke, Region 5 USFS Pesticide-Use Specialist and Invasive Plants Coordinator. No other herbicides at the rates proposed for treatment, have hazard quotient ratings over 1.0 for either consumption of contaminated fish or mammals.

Chapter 3—Affected Environment & Environmental Consequences 299 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 3 - 76. Risk Assessment Values and Hazard Quotient Ratings for Acute Toxicity Levels for the Consumption of Contaminated Fish and Contaminated Small Mammals by a Predatory Bird by Chemical. (Acute scenario assumes the consumption of contaminated fish by piscivorous bird after an accidental spill of the pesticide into a pond.)

Exposure Assessment Value Chemical/Application Rate Hazard Quotient Rating* mg/kg/day or mg/kg/event Central Lower Upper Central Lower Upper 2,4 – D contaminated fish a) 1.5 lbs/ac 21.8 7.72 40.9 2.0 0.8 4.0 b) 2.0 lbs/ac 29.1 10.3 54.5 3.0 1.0 5.0 2,4 – D contaminated mammals a) 1.5 lbs/ac 4.8 4.8 4.8 0.5 0.5 0.5 b) 2.0 lbs/ac 6.46 6.46 6.46 0.4 0.4 0.4 Chlorsulfuron contaminated fish a) 1.0 oz/ac 0.059 0.02 0.1 4 x10-5 1 x10-5 6 x10-5 Chlorsulfuron contaminated mammals a) 1.0 oz/ac 0.2 0.2 0.2 1 x10-4 1 x10-4 1 x10-4 Clopyralid contaminated fish a) .25 lb/ac 0.09 0.03 0.1 1 x10-4 5 x10-5 3 x10-4 Clopyralid contaminated mammals a) .25 lb/ac 0.8 0.8 0.8 1 x10-3 1 x10-3 1 x10-3 Dicamba contaminated fish a) 1.0 lb/ac 0.24 0.08 0.4 0.02 6 x10-3 3 x10-2 b) 2.0 lbs/ac 0.4 0.17 0.899 0.04 0.01 0.07 Dicamba contaminated mammals a) 1.0 lb/ac 3.23 3.23 6.46 0.2 0.2 0.2 b) 2.0 lbs/ac 6.46 6.46 6.46 0.5 0.5 0.5 Glyphosate contaminated fish a) 3.75 lbs/ac 0.7 0.2 1.3 1 x10-3 5 x10-4 2 x10-3 Glyphosate contaminated mammals a) 3.75 lbs/ac 12.1 12.1 12.1 0.02 0.02 0.02 Triclopyr (Acid) contaminated fish a) 1.5 lbs/ac 0.452 0.16 0.848 8x10-4 3x10-4 2x10-3 Triclopyr (Acid) contaminated mammals a) 1.5 lbs/ac 4.8 4.8 4.8 9x10-3 9x10-3 9x10-3 Triclopyr (BEE) contaminated fish a) 1.5 lbs/ac 0.45 0.16 0.848 1x10-3 4x10-4 2x10-3 Triclopyr (BEE) contaminated mammals a) 1.5 lbs/ac 4.85 4.85 4.85 0.01 0.01 0.01 NPE contaminated fish ** 0.6 0.3 0.9 0.06 0.03 0.09 * Hazard Quotient is a value used to measure risk; values above 1 means there is a potential risk to the species by use of the chemicals at the given rate for the given scenario. ** No contaminated mammal values available The largest concentration of weeds that could be sprayed in one territory is 4.37 acres along Highway 299. These occurrences of Mediterranean Sage (DG018SAAE and DG019SAAE) do not have a history of foraging use, so ingestion of potentially contaminated materials in this territory is unlikely. There are 0.36 acres remaining Forest-wide in occupied bald eagle habitat that could be treated using herbicides. There is no concern for treating the 0.36 acres in occupied bald eagle habitat under Alternatives 2 and 4, because none of the weed occurrences use 2, 4-D under either Alternative. Under Alternative 6, only 0.27 acres Forest-wide could be treated with 2, 4-D either by itself or in a tank mix. Canada thistle (DG006CIAR4) is within 25 feet from the water’s edge. Based on information from Tony Hawkes, USFWS, a no-spray area of 25 feet from the water’s edge is used as the distance for a “Not likely to adversely affect” determination and would be

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sufficient for bald eagle protection, especially given our spot treatment of weeds (Design Standard DS-13). It is unlikely to the point of being discountable that bald eagles could consume sufficient amounts of contaminated prey to cause any direct or indirect effects to these birds. There is little potential of a spill effecting bald eagles on the remaining 0.27 acres Forest-wide in an occupied bald eagle habitat for the following reasons. Weed occurrence of Scotch thistle (BV0186ONAC) is not within 100 feet of a stream, thereby negating the likelihood that a spill would reach fish- bearing waters. The remaining 0.18 acres of weed occurrences are at least 25 feet from water; and Design Standard DS-13 should minimize the potential for contamination of fish. Even using a worst-case scenario, where the two weed occurrences of 0.09 acres (or 0.03% to 0.018% of a territory) in two separate bald eagle habitats had spills, it is not realistic that 100% of an eagles’ diet would contain contaminated prey. Therefore, treatment of weed occurrences within occupied bald eagle habitat is not expected to affect bald eagle individuals or the population of bald eagles on the Forest. Since nests are located within ½ mile of weed occurrences, there is a potential for disturbance to nesting birds. The largest concentration of weeds that could be sprayed in one habitat is 4.37 acres along Highway 299; it is at the edge of that particular territory and would not pose additional significant amount of disturbance. Other sites would be reviewed annually to determine potential for disturbance. Any potential disturbance would be mitigated by the use of a Limited Operating Period (LOP), if needed (DS 10). Annually, a program of work would be presented to biologists, so they can survey nests to determine if the nests are active and require a limited operating period to protect the bald eagle pair. In light of the information presented above, it is unlikely that there would be direct or indirect effects to individual birds (“Not likely to adversely affect”); there would be no direct or indirect effects to the bald eagle population on the Forest. Cumulative Effects to Bald Eagle Populations: Because there are no direct or indirect effects to the bald eagle population, there are no cumulative effects to bald eagle population under any action Alternative.

Effects on Habitat and Populations at the Bioregional Scale for the Bald Eagle The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for bald eagle. There is no potential effect to the population on the Forest. Therefore, the impact of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing bioregional-wide trend population distribution of the bald eagle.

Table 3 - 77. Summary of Approximate Annual Acres of Noxious Weed Treatment, by Jurisdiction

Other Modoc NF Tribal* Private Total Federal Pre-Modoc FEIS Hand treatments 30 505 26 87 648 Herbicide treatments 0 2,753 23 11,263 14,580 Post Modoc FEIS Hand treatments 1,500** 505 26 87 2,118 Herbicide treatments 1,500*** 2,753 23 11,263 16,080 * This data includes Ft. Bidwell and Pit River lands ** Maximum treated under Alternative 3 *** Maximum treated under Alternatives 2 and 4; Alternative 6 is a maximum of 522 acres/year

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The majority of the bald eagles nesting on the Modoc NF, forage on the Forest, although there is some use of areas off of the Forest, such as Goose Lake. Physical + treatments obviously will not cause any potential poisoning issues. The agricultural fields become more important to foraging eagles in the winter, when spraying does not occur. There could be a maximum of 1,500 acres sprayed annually on the Forest, or 0.089% of the Forest. Under Alternative 6 that number would decrease to a maximum of 522 acres, or 0.031% of the Forest. About 16,080 acres could have herbicides in roughly 3.5 million acres (Modoc NF and surrounding areas), which would be 0.46% of that gross area. Given the fact that most eagle foraging occurs away of the weed infestations during the time of active spraying, the small percentage of the area that is treated, and the Design Standards that protect eagles on the Forest specific to the Noxious Weed Treatment Project, there are no cumulative effects expected to bald eagles with implementation of activities in the Noxious Weed Treatment Project in light of other jurisdictions.

T&E Species (Bald Eagle) Determination Based on the analysis of effects of the project by Wildlife Biologist Mary Flores and with the concurrence of the US Fish and Wildlife Service, it is determined that the Alternatives have the following effects: Implementation of the Alternative 1 will have “No Effect” on the bald eagle or its habitat. Implementation of the Alternatives 2, 4, and 6, “May affect, but is not likely to adversely affect” the bald eagle or its habitat. Implementation of Alternatives 3 and 5 and the physical + treatments under 2, 4, and 6 will have a “No Effect” determination with implementation of the required surveys and limited operating periods (Design Standards).

Sensitive Terrestrial Wildlife Species The Affected Environment and Environmental Consequences of Sensitive Terrestrial Wildlife Species are displayed below under the Pacific Southwest Region (R5) Sensitive Species and R5 Sensitive Species That Are Also Modoc NF Management Indicator Species headings. R5 Sensitive Species that are also Modoc NF Management Indicator Species are not duplicated in the Management Indicator Species Section. Sensitive Species are described in full in the Biological Evaluation located in Appendix V.

Region 5 Sensitive Species California Spotted Owl There are two sub-species of spotted owl found on the Forest: northern spotted owl (Strix occidentalis caurina) and California spotted owl (Strix occidentalis occidentalis). The northern spotted owl sub-species is addressed in the terrestrial BA prepared for this project. The California spotted owl is discussed below. Direction in the Sierra Nevada Forest Plan Amendment ROD (USDA 2004) includes the maintenance of Spotted Owl Protected Activity Centers (PACs). Management for the California Spotted Owl was one of the driving forces behind the Sierra Nevada Forest Plan Amendment. There is only one California spotted owl PAC on the Forest, although extensive surveys (approximately 90,000 acres) to protocol have been conducted throughout the Forest. This PAC is on the Big Valley Ranger District near Manazanita Mountain. There was a pair of California

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spotted owls in this PAC during 1993, but since then only single birds have been detected through the 2006 field season (J. Rechtin, pers. comm.). During the assessment of habitats found within California, the California Spotted Owl Team did not delineate the rest of the Modoc National Forest within the main range for the California spotted owl (Verner et al. 1992). The scientists felt that the Modoc NF would be considered a population sink, where individual owls or pairs may establish themselves, but would not contribute genetic material into the main population. California spotted owls in northern Sierra Nevada are associated with mixed conifer and true fir types that have high canopy covers (>70% for nesting) and medium to large trees (Verner et al. 1992). The Manzanita Mountain owls are found in upper elevation mixed conifer habitat characterized by large old trees, with dense understory stocking of second growth. To date, no nesting or production of young have been documented. There are 1,151.5 acres within the one California spotted owl Protected Activity Center (PAC) on the Forest. The following information concerning food habits was obtained from Verner et al. (1992). Spotted owls consume a variety of different foods: small mammals, birds, frogs, bats, and insects. The most common prey items for spotted owls consists mainly of northern flying squirrels, woodrats, and gophers. Owls tend to forage in areas with medium to large trees, higher canopy closure, and large amounts of snags and logs, although they have been observed to forage for insects from bark, the ground, and even hawking them from the air (Neal et al. 1989 in Verner et al. 1992).

Effects of the Alternatives on the California Spotted Owl Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no affect on California spotted owl habitat. The spotted owls prefer older seral stage stands with large trees and snags, as well as logs. The potential effects are limited to the consumption of herbicide-contaminated prey materials, and disturbance.

Alternative 1 (Current Management) Direct and Indirect Effects: The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Therefore, there would be no potential for the consumption of contaminated prey. Implementing weed treatments under Alternative 1 would have no effect to spotted owl habitat. There would be no change in the current or future amount of large trees and snags or dead and downed materials by the treatment of noxious weeds. There would be no change in the amount of late seral stage habitat. Zero % of the current spotted owl habitat in the analysis area would be affected by implementation of Alternative 1. Cumulative Effects: Because there would be no direct or indirect effect to the California spotted owl or its habitat, there would be no cumulative effects to spotted owl or its habitat under this Alternative.

Alternatives 2 to 6

Direct and Indirect Effects Currently, there is one weed occurrence along the road system for a total of 0.1 acres that could be treated within the California spotted owl PAC. This occurrence could be treated by either physical or herbicide means. Weed treatment by either herbicide or physical means would have no effect on spotted owl habitat. There would be no removal of potential nest/roost trees. Weed treatments of 0.1 acre

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would still provide ample residual native vegetation for any potential prey within the 1,151.5-acre PAC. Therefore, weed treatments would have no impact to owl habitat under any alternative. Disturbance and potential ingestion of contaminated prey are the greatest concerns to the spotted owl. Although there have been no known nest sites within the PAC (including FY 2006), pre- treatment surveys would be conducted to protect nesting owls from disturbance. If owls are actively nesting, a Limited Operating Period (LOP), for weed treatment activities would be instituted to protect nest sites. There is little chance of owls being affected by the contamination of herbicides. Only 0.009% of the current PAC could receive herbicides. It is highly unlikely that 10% to 100% of the owl’s diet would be composed of contaminated prey on such a small site. In addition, none of the herbicides has a hazard quotient above 1 for a predatory bird ingesting contaminated mammals, making the risk of using these herbicides low (Table 3-78). Given the small acreage and the low risk from the herbicides proposed for use, there will be no discernable direct or indirect effects expected to the spotted owl by the implementation of herbicide treatments.

Table 3 - 78. Risk Assessment Values and Hazard Quotient Ratings for Acute Toxicity Levels for the Consumption of Contaminated Small Mammals by a Predatory Bird, by Herbicide Rates

Exposure Assessment Value Herbicide/Application Rate Hazard Quotient Rating mg/kg/day or mg/kg/event Central Lower Upper Central Lower Upper 2,4 – D a) 1.5 lbs/ac 4.8 4.8 4.8 0.5 0.5 0.5 b) 2.0 lbs/ac 6.46 6.46 6.46 0.4 0.4 0.4 Chlorsulfuron 1.0 oz/ac 0.2 0.2 0.2 1 x10-4 1 x10-4 1 x10-4 Clopyralid 0.25 lb/ac 0.8 0.8 0.8 1 x10-3 1 x10-3 1 x10-3 Dicamba a) 1.0 lb/ac 3.23 3.23 6.46 0.2 0.2 0.2 b) 2.0 lbs/ac 6.46 6.46 6.46 0.5 0.5 0.5 Glyphosate 3.75 lbs/ac 12.1 12.1 12.1 0.02 0.02 0.02 Triclopyr (Acid) 1.5 lbs/ac 4.8 4.8 4.8 9x10-3 9x10-3 9x10-3 Triclopyr (BEE) 1.5 lbs/ac 4.85 4.85 4.850.01 0.01 0.01 NPE No data No data No data No data No data No data Under the alternatives with Early Detection - Rapid Response activities, new occurrences would be reviewed by wildlife biologists prior to implementation. If concerns for spotted owl surface, additional Design Standards could be added if weed treatments were not consistent with the conditions analyzed above.

Cumulative Effects Past activities that have affected California spotted owls, or their habitat include the California Pines development (CalPines) which is adjacent to the National Forest. The CalPines area appears to have provided potential habitat for spotted owls at one time. The extensive system of roads, utility corridors and developed lots probably has reduced the suitability for spotted owls. Commercial timber harvest has also occurred on private lands adjacent to the National Forest. These actions included salvage harvest and regeneration harvest prescriptions. Regeneration harvest appears to have removed habitat in the past. Planned private activities include fuel break

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construction and maintenance within the CalPines development. Planned Federal activities within the area where California spotted owls may occur include the Rush2 Vegetation treatment project, which is proposing to treat approximately 3,600 acres of National Forest, including the owl- protected activity center and the owl home range core area. Thus, the proposed action for noxious-weed treatment would affect approximately 0.01% of the amount of land affected by the Rush2 project. This proposed project would have no direct effects and would have the indirect effect of potentially affecting a handful of prey items. Thus, the effects of this proposed action are undetectable against the backdrop of on-going projects and insignificant in scope and impact. Thus, this project would not contribute to any cumulative effect trend either positively or negatively. California Wolverine and Sierra Nevada Red Fox These species were lumped within this analysis for the following reasons. First, they are both large mammalian carnivores. Second, there is no current definitive evidence that they currently inhabit the Modoc NF. Third, their numbers would probably be low, if they currently exist based on historical sighting information. Finally, their ranges would be restricted to the upper elevations on the Forest, even though they might utilize different habitats within these areas. Therefore, the effects of implementation are similar, even if the magnitudes of potentially affected acreages are different. The SNFPA FEIS ROD states “Detection of a wolverine or Sierra Nevada red fox will be evaluated by a Forest carnivore specialist. When verified sightings occur, conduct an analysis to determine if activities within five miles of the detection have a potential to affect the species. If necessary, apply limited operating period from January 1 to June 30 to avoid adverse impacts to potential breeding. Evaluate activities of the Wolverine and Sierra Nevada Red Fox for a two- year period for detections not associated with a den site.” (SNFPA FSEIS Record of Decision (ROD), page 54, D-32). (USDA 2004). Wolverines in California were thought to be rare and declining in the 1950s (Banci in Ruggiero et al. (1994)). There are only a few old unconfirmed sightings of this wide-ranging Forest carnivore on the Forest. Wolverine presence has not been detected during track plate surveys, nor is there any presence of wolverine at baited camera stations placed to detect Forest carnivores. To the south, there have been no confirmed sightings of wolverine on the Lassen National Forest since at least 1980 (B. Turner, pers. comm.). Habitats used in the northern Sierra Nevada include mixed conifer, red fir, lodgepole pine, and dwarf alpine shrub (Zeiner and others 1990). Wolverines use a wide variety of habitats; caves, hollows in cliffs, hollow logs, rock outcrops, and burrows may be used for cover and dens. “Habitat is probably best defined in terms of adequate year-round food supplies in large, sparsely inhabited wilderness areas, rather than in terms of particular types of topography or plant associations” (Kelsall 1981 in Ruggiero et al. 1994). There are 130,121 acres of the potential wolverine habitat on the Forest. The model utilized a combination vegetation types at elevations 7,000 and greater. The dominant vegetation types included sagebrush and shrub communities, east-side pine, white and red fir, mixed conifer and lodgepole. Wolverine foraging information came from Ruggiero et al. (1994). Wolverines are considered opportunistic omnivores in the summer and scavengers in the winter. Carrion from large ungulates is considered important. “Wolverines are too large to survive on only small prey”, although small prey are important when large mammal carrion is unavailable. There were Sierra Nevada red foxes (SNRF) sighted in the Medicine Lake Highlands previous to the 1960s; there was also an unconfirmed sighting of a red fox in the Warner Mountains in the Bucher Creek area (Schempf and White 1977). Although there was a recent sighting of an

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unknown red fox near Hackamore on the Devil's Garden RD in pine/bitterbrush habitat in the summer, biologists felt that it was probably an escaped domesticated red fox (Tom Ratcliff, pers. comm.). The most recent sightings of Sierra Nevada red fox occur in the Lassen National Park/Lassen National Forest vicinity. According to Campbell et al. (2000), this species historically maintained a continuous distribution in high-elevation habitats in the Sierra Nevada; it “historically occurred in low densities”. Habitat for the red fox is not well understood. This fox usually resides in areas above 7,000 feet and seldom is detected below 5,000 feet (Schempf and White 1977). It appears to utilize mixed conifer, red fir and lodge pole pine forests, especially in proximity to meadows and riparian areas as well as brush fields. Forested habitats are used for reproduction and cover; young may be reared in cavities or spaces within rock piles or talus slopes (Campbell et al. 2000). The GIS query for potential habitat included the various vegetation types around wet meadows that occurred above 7,000 feet. The dominant vegetation types in the potential habitat include white fir, mixed conifer, lodgepole pine and wet meadows. There were 18,940 acres of potential habitat modeled for Sierra Nevada red fox (SNRF) on the Forest. The Sierra Nevada red fox prefers open areas while hunting, grassy parks and meadows, and open Forest stands (various authors in Schempf and White 1977). Diets for SNRF includes small mammals, birds, carrion, and fruits (Zeiner et al. 1990); in the western United States, the red fox diet was composed of mice, chipmunks, microtines, woodrats, squirrels, pikas, and rabbits/hares (various authors in Campbell et al. 2000). Territory size for SNRF is estimated to be greater than 1,700 to 3,900 acres, because the prey base is more limited in the Sierras (Duncan Interagency Workgroup in Campbell et al. 2000).

Effects of the Alternatives on the California Wolverine and Sierra Nevada Red Fox Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no effect on potential wolverine or SNRF habitat. These species use cavities and hollows to rear their young; they do not rely on weeds for food. The potential effects are limited to the consumption of herbicide-contaminated prey and disturbance.

Alternative 1 (Current Management) Direct and Indirect Effects The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Therefore, there would be no potential for the consumption of contaminated prey. Implementing weed treatments under Alternative 1 would have no effect to potential wolverine or SNRF habitat, nor would it affect any individual animals. None of the weed treatments occur within potential habitat for either species. There will be no change in the current or future amount of preferred denning or foraging habitats. Zero % of the current wolverine and SNRF habitat in the analysis area, would be affected by implementation of Alternative 1.

Cumulative Effects Because there is no direct or indirect effect to the wolverine or SNRF or their habitats, there are no cumulative effects to either species or their habitats under this Alternative.

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Alternatives 2 to 6

Direct and Indirect Effects There are no current occurrences for either species on the Forest. Both of these species are rare, and were included in the analysis because there are historical sightings on the Forest. There are no weed occurrences within potential SNRF habitat (Table 3-79). Therefore, there will be no effect to either SNRF or its habitat by the implementation of any Alternative. There is no chance of consumption of contaminated prey for wolverine under Alternatives 3 and 5 (Alternatives where no herbicides will be used), or the physical + treatments in 2, 4, and 6. There are 3.55 acres of weed occurrences within the highest potential wolverine habitat that could be treated by physical + or herbicide means under all five action Alternatives (Table 3-79). Therefore, a maximum of 0.003% of the modeled 130,121 acres of wolverine habitat would be treated by either physical + treatment or herbicides. Treating this small acreage with physical + or herbicide methods will have no biological relevance for a species with a home range greater than 50 miles (home range values from Banci 1994 in Campbell et al. 2000).

Table 3 - 79. Proposed Treatment Acres within Potential Wolverine and SNRF Habitat

Total Acres of Total Maximum Acres Total Maximum Acres of Species Potential Habitat of Physical + Herbicide Treatments * Forest wide Treatments * Wolverine 130,121 3.55 3.55 Sierra Nevada Red 18,940 0.00 0.00 Fox *This figure includes the maximum, where physical + or herbicide methods may be employed The maximum acres of potential wolverine habitat treated with herbicide under Alternatives 2 and 4 are 1.5 acres Forest-wide (or 0.001 % of the 130,121 acres potential habitat); under Alternative 6, the maximum acres of habitat treated with herbicide would be 3.55 (or 0.003 % of the potential habitat). The largest weed occurrence is 1.03 acres. None of the weed occurrences are in the Medicine Lake Highlands, which have the highest potential to support wolverine. No potential den sites will be affected by the implementation of any action Alternative. Potential prey will not be affected; therefore, there are no anticipated direct or indirect effects to denning or foraging habitat for wolverine. With the small acreage to be treated and its large home range, it is highly unlikely that wolverines would be affected by the consumption of contaminated prey. In addition, the hazard quotient ratings for all the herbicides that could be used to treat weeds on the Forest are less than 1, meaning there is little risk to the animals described given the parameters of the scenario (Table 3- 79).

Table 3 - 80. Hazard Quotient for Acute Levels for Mammal Eating Contaminated Mammals

Herbicide/Application Rate Exposure Assessment Rate Hazard Quotient Rating Central Lower Upper Central Lower Upper 2,4 - D a) 1.5 lbs/ac 3.15 3.15 3.15 0.3 0.3 0.3 b) 2.0 lbs/ac 4.2 4.2 4.2 0.4 0.4 0.4 Chlorsulfuron 1.0 lb/ac 0.131 0.131 0.131 0.002 0.002 0.002 Clopyralid 0.25 lb/ac 0.525 0.525 0.525 0.007 0.007 0.007 Dicamba a) 1.0 lb/ac 2.1 2.1 2.1 0.05 0.05 0.05

Chapter 3—Affected Environment & Environmental Consequences 307 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Herbicide/Application Rate Exposure Assessment Rate Hazard Quotient Rating Central Lower Upper Central Lower Upper b) 2.0 lbs/ac 4.2 4.2 4.2 0.09 0.09 0.09 Glyphosate 3.75 lbs/ac 7.87 7.87 7.87 0.04 0.04 0.04 Triclopyr (Acid & BEE) 1.5 lbs/ac 3.15 3.15 15 0.033. 0.03 0.03 When reviewing the literature, disturbance is the most likely potential effect to wolverine or SNRF. Wolverines choose natal den sites with high-elevation rocky substrates; the California sites were under rocky ledges above 10,000 feet elevation (various authors in Campbell 2000). Denning occurs in late winter and early spring for wolverine (Campbell 2000). SNRF young are born March to May (Zeiner et al. 1990). It is unlikely that weed treatment activities will affect wolverine or SNRF, because the habitats with the greatest potential of occupancy will be inaccessible during weed treatment implementation times. Under the Alternatives with Early Detection/Rapid Response activities, new occurrences will be reviewed by wildlife biologists prior to control implementation; if concerns for wolverine or SNRF surface, additional requirements could be added, if weed treatment areas were outside of the conditions analyzed within the FEIS. Given the small acreage to be treated, the low risk associated with the herbicides proposed for use on these species, and the low potential for disturbance, there are no direct or indirect effects for wolverine or SNRF or their habitats by the implementation of Alternatives 2 through 6. Cumulative Effects: Because there are no direct or indirect effects to the wolverine or SNRF or their habitat, there are no cumulative effects to either species or their habitats under Alternatives 2-6. Great Gray Owl Great gray owls have been detected near Medicine Lake (Doublehead). In addition, a great gray owl was seen at Crowder Flat Guard Station (Devil’s Garden) on a few occasions in 1993 (T. Ratcliff and M. Flores, pers. comm.). During the planning process for Sierra Nevada Forest Plan Amendment (USDA 2004), three great gray owl Protected Activity Centers (PACs) were established on the Warner Mountains, although there has never been conclusive evidence of occupancy. Great gray owls are uncommon throughout their range (Bull et al. 1989b). The Sierra Nevada Forest Plan Amendment ROD (USDA 2004) direction manages these owls using a series of Protected Activity Centers and survey. Maintaining meadow vegetation within and adjacent to PACs will improve habitat for voles and pocket gophers, the Great Gray Owl’s prey. (SNFPA FEIS, page 292 and the Final Supplemental Environmental Impact Statement (FSEIS ROD, page 39) (USDA 2004). Although they are usually associated with dense, timbered stands with large, open meadows nearby, great gray owls in northeastern Oregon nested in all types of forests; however, nests were more prevalent in over-mature or remnant stands of Douglas fir and grand fir Forest on north facing slopes (Bull and Duncan 1993, Bull et al. 1988). On the average, there are 3.2 larger live trees per acre (19.6 inches DBH) and 1 larger diameter snag (19.6 inches DBH). On their study site, Bull et al. (1988) found that 68% of the stick nests used by great gray owls were originally made by northern goshawks. Roosts sites were also in stands with 11 to 59% canopy cover. Habitat on the Forest for great gray owl was estimated in the following manner: quantification of the acreages within the PACs, and modeling of potential habitat. Within the great gray owl PAC’s set up by the Sierra Nevada Forest Plan Amendment (USDA 2004), there are a total of 598 acres of assorted vegetation types: lodgepole pine, Sierran mixed conifer, white fir, wet meadow, and sagebrush. An additional 2,025 acres of potential nesting habitat were modeled using EVEG data: mixed conifer, eastside pine, ponderosa pine, Jeffrey pine, Douglas-fir, white fir, red fir, and

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lodgepole pine with a tree size = 4, 5, 6 and canopy cover = 40% or greater, that were within 1,000 feet of meadows. Meadows associated with nest stands need to contain enough cover to provide for prey. Diets for great gray owls consisted mainly of voles and pocket gophers (Bull et al. 1989a). Males preferentially foraged in stands with 11 to 59% canopy cover, and avoided clearings.

Effects of the Alternatives on the Great Gray Owl Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no affect on great gray owl habitat. Great gray owls prefer older seral stage stands with large trees and snags, as well as logs near meadows. The main potential effect is limited to the consumption of herbicide-contaminated prey materials.

Alternative 1 (Current Management)

Direct and Indirect Effects The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Therefore, there would be no potential for the consumption of contaminated prey. None of the treatment areas are within the great gray owl PAC’s, therefore there will be no disturbance to owls by physical + treatments. Implementing weed treatments under Alternative 1 would have no effect on great gray owl habitat. There will be no change in the current or future amount of large trees and snags or dead and downed materials by the treatment of noxious weeds. There would also be no change in the amount of late seral stage or meadow habitat. Therefore, 0% of the current great gray habitat in the analysis area would be affected by implementation of Alternative 1.

Cumulative Effects Because there is no direct or indirect effect to the great gray owl or its habitat, there are no cumulative effects to great gray or its habitat under this Alternative.

Alternatives 2 to 6

Direct and Indirect Effects There are no weed treatments within any PAC or any potential habitat, so no great gray owl habitat would be affected by weed treatments. Nor would there be any disturbance or consumption of contaminated prey expected with implementation of the project. Therefore, there would be no effects to individual birds. Under the Alternatives with Early Detection/Rapid Response activities, new occurrences would be reviewed by wildlife biologists prior to implementation. The herbicides proposed for use have low hazard ratings for predatory birds consuming contaminated prey (Table 3-78). Depending on the size of the new weed occurrences, there should be little risk of effects by the consumption of contaminated prey. If concerns for great gray owl surface, additional Design Standards could be added if weed treatment areas were outside of the conditions analyzed within the FEIS. As stated above, there would be no treatments within any great gray owl PACs or potential habitat. Therefore, there will be no direct or indirect effects to great gray owl or its habitat by implementation of Alternatives 2 through 6.

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Cumulative Effects Because there is no direct or indirect effect to the great gray owl or its habitat, there are no cumulative effects to the great gray owl or its habitat under these Alternatives. Pallid and Townsend’s Big-eared Bats These species were lumped within this analysis for the following reasons. First, they are both mammalian insectivores. Second, there would not be any proposed treatment of roost sites for either species. Therefore, the effects of implementation are similar even if the magnitudes of potentially affected acreages are different. Although not highlighted specifically in the SNFPA Record of Decision, pallid bat direction consists of conservation measures listed in Volume 3 of the Sierra Nevada Forest Plan Amendment (USDA 2001, page 55 of Chapter 3, part 4.4). These measures are paraphrased as follows: Provide for hardwood stands into the future (especially older stands, to produce healthy hardwood crowns or regeneration as well as adequate flight space), adopt mine and cave plans, and develop a mosaic of stands in chaparral. Pallid bats have been found during hazard-tree removal and snag topping projects on the Forest; the individuals found were roosting under the bark of large pine snags. Pallid bats appear to prefer open, dry habitats with rocky areas for roosting and foraging (Zeiner et al. 1990, Philpott 1997). Radio tracking surveys by Southern Oregon State College found pallid bats roosting most commonly in large pine snags and occasionally in large live pine. They will also, on occasion, roost in rock crevices (Vaughan and O’Shea 1976) or man-made structures; a maternity roost with 39 bats was found in the side entrance way of a college boarding house in Inyo County (Szewczak et al. 1998). Night roosts in central Oregon were located in buildings, under rock overhangs, and under bridges (Lewis 1994). There are approximately 256,000 acres of habitat with a large pine component that could act as potential habitat Forest wide. Pallid bats are mainly insectivorous; however, they have been known to eat lizards and smaller bats while in captivity, as well as fruits and seeds (although there is speculation as to whether these events happened incidentally, while bats were feeding on insects on the plant parts) (Hermanson and O’Shea 1983). These bats may feed on insects taken from the ground or from the surfaces of vegetation (Hermanson and O’Shea 1983, Zeiner et al. 1990), but may also forage over open ground 0.5 to 2.5 meters (1.6 to 8 feet) above the ground (Zeiner et al. 1990). Pallid bats were documented to forage 1 to 3 miles from their day roost (Zeiner et al. 1990). Townsend’s big-eared bats (TBEB) roost in the lava caves on Doublehead RD near Lava Beds National Monument. There are scattered mine shafts elsewhere on the Forest that have the potential to support these bats. The High Grade Area in the northern Warner Mountains has the highest concentration of mines; however, there are also small, localized areas in the Medicine Lake Highlands, Adin Pass, and the Stone Coal area. This species is dependent upon caves, mines and buildings for roosting habitat (Campbell and MacFarlane 2000; Zeiner et al. 1990). Caves need to meet specific microclimatic conditions for successful roosting, and this species is very susceptible to disturbance (Campbell and MacFarlane 2000). In the Inyo Mountains, this species has been seen roosting in lava tube caves (Szewczak et al. 1998). This species has been documented to use sage-brush-grass steppe, juniper woodlands, and mountain brush communities in Utah (Sherwin et al. 2000). There are approximately 214,000 acres of foraging habitat within 10.5 kilometer of occupied caves. The habitat types from this query include bitterbrush, eastside pine, sagebrush, juniper, and mixed conifer. There is no GIS data for lava tube and mines, so additional potential habitat could not be modeled.

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TBEBs utilize caves, mine tunnels, and buildings for nursery colonies (Pierson 1988); they will return to these areas annually, if not disturbed. Hibernating sites tend to be structurally stable caves (Pierson 1988). In the Inyo and White Mountains, hibernation was considered to occur from November to March (Szewczak et al. 1998). They feed in a wide variety of habitats from open agricultural fields to dense Forest (Pierson 1988). Foraging habitats are varied, but this species concentrates primarily on moths (Zeiner et al. 1990). Although they are very specialized in their diet and take mostly moths, they have also been observed to feed on Neuroptera, Coleotera, Diptera, Hymenoptera (Kunz and Martin 1982). Data from California show that these bats may forage up to 10.5 km from the day roost, as well as tended to forage in the same areas each night (Fellers and Pierson 2002). There are reports of these bats gleaning insects from foliage (Zeiner et al. 1990); however, in a study from California, they usually capture prey 10 to 30 meters off the ground between mid to top of the canopy (Fellers and Pierson 2002).

Effects of the Alternatives on the Pallid and Townsend’s Big- eared Bats Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no affect on pallid bat or TBEB habitat. These bats roost in large trees, snags, caves, and rock crevices; none of these structures will be affected by weed-treatment activities. The potential effects are limited to the consumption of herbicide-contaminated prey and disturbance.

Alternative 1 (Current Management) Direct and Indirect Effects The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Therefore, there would be no potential for the consumption of contaminated prey. Implementing weed treatments under Alternative 1 would have no effect on the habitat for either bat species. There will be no change in the current or future amount of large trees and snags or caves by the treatment of noxious weeds. There would be no change in the amount of potential prey habitat, as there will be ample native plants for insects to use as food and cover. Therefore, 0% of the current bat habitat in the analysis area would be affected by implementation of Alternative 1. Cumulative Effects Because there is no direct or indirect effect to the pallid or TBEB or their habitat, there are no cumulative effects to pallid or TBEB or their habitat under this Alternative.

Alternatives 2 to 6

Direct and Indirect Effects Physical + and herbicide weed treatments will not affect pallid and TBEB roosting or foraging habitat by implementation of any action Alternatives. As stated in the SNFPA FSEIS (p. 419) roost sites are the primary limiting factor for Pallid and Townsend’s Big-eared bats (USDA 2004). A maximum of 2,586.59 acres of pallid bat potential habitat could receive physical + treatments and a maximum of 2,582.8 acres could receive herbicide treatments. A maximum of 1,939.23 acres for physical + treatment and a maximum of 1933.8 acres for herbicide treatments could occur in potential TBEB habitat. Therefore, 0.91% of the 214,000 acres of potential TBEB habitat could be treated Forest-wide and 1.01% of the 256,000 acres of potential pallid bat habitat Forest-wide could be treated (Table 3-81).

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Table 3 - 81. Proposed Treatment Acres within Potential Pallid and Townsend’s Big-eared Bat Habitat

Total Acres of Total Maximum Acres Total Maximum Acres of Species Potential Habitat of Physical + Herbicide Forest wide Treatments * Treatments * Pallid bat 256,000 2,586.59 2,582.8 Townsend’s big-eared bat 214,000 1,939.23 1,933.8

*This figure includes the maximum, where physical + or herbicide methods may be employed Although there are large acreages of weeds that could be treated either physical + ly or with herbicides within the potential foraging habitat for both species under Alternatives 2, 3 and 4, the effect to prey habitat should be minor for the following reasons. First, the vast majority of the weed patches are less than one acre (33 out of 35 weed occurrences for TBEB and 101 out of 109 for pallid bat). There are native plants that these insects can use in the matrix and directly adjacent to the weed occurrence. Second, revegetation of bare areas will provide food and cover for insects in the absence of the weeds. Finally, both bats utilize a wide variety of habitats for foraging, so they are not tied to one given area or vegetation type. Disturbance is not an issue for Townsend’s big eared bats, since weed treatment activities would be away from caves. Based on personal observations during snag improvement projects, George Studinksi (pers.comm.) noted that pallid bats did not fly from roost trees when contractors were within stands working on the habitat improvement projects; therefore, physical + treatments and pump sprayers (which are quieter than chainsaws) are expected to cause little disturbance; the exception would be weed whackers, which could be noisy and provide a source for disturbance. Pallid bats would have a potential risk of both direct contact with the herbicides and ingestion of contaminated insects, since they have been known to forage on the ground or from the surface of the vegetation. The drying times for herbicides are such that herbicides sprayed in the later afternoon would not be dry until after dark, when pallid bats would be out. The greatest potential for effect would be under Alternatives 2 and 4 in DH013ISTI (dyer’s woad), where up to 2,500 acres could be treated with herbicides. There would be little potential effect for direct contact under Alternative 6, because only the fringes of this weed occurrence would be treated. Townsend’s big eared bats (TBEB) are aerial foragers (Campbell and MacFarlane 2000); therefore, there should be no direct contact with herbicides. However, some contaminated insects could be sprayed and consequently ingested, especially within larger weed occurrences. The herbicides with the highest risk are 2, 4 –D and their associated tank mixes and Dicamba (2 lbs/acre) at all rates, as well as the higher concentrations of Dicamba (1 lbs/acre), Glyphosate, and Triclopyr (Table 3-82). The herbicide 2, 4-D is of the greatest concern under this scenario, because the hazard quotient exceeds 1 in all levels. Based on the SERA for 2, 4-D, the effects to small mammals includes neurotoxicity and some degenerative changes to various organs; these effects, although not fatal, could certainly make individual animals more susceptible to predation depending on the amount of herbicide consumed. It is important to note that this risk scenario assumes that 100% of the bats’ diet would be contaminated. The two bat species’ foraging behaviors only make this scenario realistic within the larger weed occurrences.

Table 3 - 82. Hazard Quotient for Acute Levels for Small Mammal Eating Contaminated Insects (100% of the diet)

Herbicide/Application Rate Exposure Assessment Rate Hazard Quotient Rating Central Lower Upper Central Lower Upper 2,4 - D

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Herbicide/Application Rate Exposure Assessment Rate Hazard Quotient Rating Central Lower Upper Central Lower Upper a) 1.5 lbs/ac 34.7 34.7 104 3.0 3.0 10.0 b) 2.0 lbs/ac 46.3 46.3 139 5.0 5.0 14.0 Chlorsulfuron 1.0 lb/ac 1.45 1.45 4.34 0.02 0.02 0.06 Clopyralid 0.25 lb/ac 5.78 5.78 17.3 0.08 0.08 0.2 Dicamba a) 1.0 lb/ac 23.1 23.1 69.4 0.5 0.5 1.5 b) 2.0 lbs/ac 46.3 46.3 139 1.0 1.0 3.0 Glyphosate 3.75 lbs/ac 86.7 86.7 260 0.5 0.5 1.5 Triclopyr (Acid & BEE) 1.5 lbs/ac 34.7 34.7 0 104. 0.3 0.3 1.0 For both TBEB and pallid bats, herbicide treatment of DH013ISTI (dyer’s woad) could have negative effects under Alternatives 2 and 4, where a roughly 2,000-acre block would be sprayed. Since bats may forage in the same areas each night, individuals for either species might ingest a significant portion of contaminated insects. This is not the case for this weed occurrence under Alternative 6, where only the treatment of the periphery of this occurrence is planned. Outside of the DH013ISTI (dyer’s woad), there are 4.06 acres of potential Townsend’s big-eared bat habitat that could be treated. There is 1 acre of DH001HYPE (Klamathweed) that is scheduled for physical + treatment under Alternatives 2 and 4; it could be treated with either physical + or herbicidal methods under Alternative 6. The remaining 3.06 acres are dispersed among 19 weed occurrences, and do not appear to have risks associated with implementation of Alternatives 2, 4 and 6, because of their small sizes. In potential pallid bat habitat, eight additional weed occurrences are greater than one acre (outside of the DH013ISTI [dyer’s woad]). Two weed occurrences (WM002CEDI3 [diffuse knapweed] and DG024SAAE [dyer’s woad]) are scheduled for physical + treatments under all Alternatives and would therefore pose no risk to pallid bats. The remaining occurrences could have herbicidal treatments and therefore may pose a risk to pallid bats. Under Alternatives 2 and 4, 30.98 acres of BV001CRVU2 (Crupina) could be sprayed. Since bats may forage in the same areas each night, individual pallid bats might ingest a significant portion of their diet in contaminated insects. Although Glyphosate is the preferred herbicide for the treatment of crupina, 2, 4-D could be used. As stated above, the hazard quotient is above 1.0 for all levels of 2, 4-D (Table 3-82). Therefore, some individuals could consume 100% of their diet in contaminated insects and consequently could suffer effects (including making them more susceptible to predation). This is not the case for the weed occurrences under Alternative 6, because only the periphery is proposed for treatment for this crupina occurrence. About seven acres of BV006LIDA (Dalmatian toadflax) could be sprayed under Alternatives 2 and 4. Bats foraging in a seven-acre block that has been treated with herbicides could undergo effects of herbicide ingestion, especially from 2, 4-D. However, the lava country does not produce the same amount of insects as the more mesic sites; therefore, it would be difficult for bats foraging in an area this size to consume 100% of their diet (B. Turner, pers. comm.). Under Alternative 6, only small satellites from the main weed occurrence could be sprayed; treatment of BV006LIDA (Dalmatian toadflax), which would pose no risk to pallid bats. Potentially, 32.20 acres of WM003LIDA (Dalmatian toadflax) could be treated with herbicides under Alternatives 2, 4 and 6. The impact is relatively small for the following reasons. Under Alternatives 2 and 4, there would be no 2, 4-D used on the site, because it is within 1,000 feet of water. Under Alternative 6, there would be no 2, 4-D used on the site, because it is larger than 2 acres. Design Standard DS-12b caps the size of weed occurrences treated with 2, 4-D to less than 2 acres. The other herbicides do not have hazard quotient ratings above 1.0 at the lower and central levels, and therefore pose less risk to mammals consuming insects under the above

Chapter 3—Affected Environment & Environmental Consequences 313 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

scenario. The second reason is the relatively small amount of toadflax present in the weed occurrence. The site is basically a large, contiguous matrix of native plants with small clumps of weeds (many of the patches of weeds were 10 feet by 10 feet). Although the entire weed occurrence encompasses roughly 40 acres, the weeds are actually distributed in small clumps, found in lava rock talus, an old road bed, and along old, dry, rocky streambeds. There were no toadflax plants along the main channels of Lassen Creek. Consequently, the chance of a pallid bat’s diet containing 10% to 100% contaminated insects would be remote under Alternatives 2, 4 or 6 for this weed occurrence. There are two additional weed occurrences above 1.0 acre in potential pallid bat habitat, where herbicides may be applied. There are 2.46 acres in BV302ONAC (Scotch thistle) and 1.13 acres in WM018ISTI (dyer’s woad). These occurrences are not expected to be large enough areas, where pallid bats could consume 100% of their diet in contaminated insects given the bats’ prey and foraging habits. As stated previously, the remaining 101 out of 109 sites are small (less than one acre) and scattered throughout the Forest, so there would not be large acreages where herbicides are concentrated within potential pallid bat habitat. Therefore, there is little anticipated risk for pallid bats to consume harmful levels of contaminated insects outside of DH013ISTI (dyer’s woad) and BV001CRVU2 (crupina). Under the Alternatives with Early Detection/Rapid Response activities, up to 100 acres per year could be treated Forest-wide. New occurrences will be reviewed by wildlife biologists prior to implementation to insure protection requirements are in place. To reiterate, the action Alternatives may impact individuals, but they are not likely to cause a trend toward listing for Townsend’s big-eared bat. The potential effects under Alternative 6 are vastly smaller than Alternatives 2 and 4 for TBEB, because only 4.06 acres could be treated with herbicides Forest-wide. In addition, no roost site will be affected, which is the primary limiting factor for this species. The action Alternatives may impact individuals, but they are not likely to cause a trend toward listing for pallid bat. The potential effects under Alternative 6 are vastly smaller than Alternatives 2 and 4, because only the periphery of the large weed occurrences could be treated. As with the TBEB, no roost site will be affected, this is also a limiting factor for pallid bats.

Cumulative Effects There are past, present, and reasonably foreseeable activities that cause disturbances to both bat species. Disturbance at roost sites is a critical issue for both species, and the potential effects of timber management, recreation and mineral development at known roost sites would need to be addressed site specifically under the appropriate NEPA decision, or working with the special-use coordinator. There are weed treatments using herbicides on the Lava Beds National Monument that could occur in potential Townsend’s big-eared bat (TBEB) foraging habitat. Weed treatments on the Lava Beds National Monument consist of a combination of physical + and herbicide treatment using Glyphosate. The Park personnel treated 473 acres, spraying approximately 10% of the area. There would be a low risk from additional consumption of contaminated insects, because the hazard quotient for Glyphosate exceeds one only at the upper levels. Under the upper-level scenario, the bats would need to consume 100% of their diets in contaminated insects. Given TBEB foraging strategies and prey preferences, this scenario is unlikely. For pallid bats, there are no known additional herbicides within the foraging habitat for the Modoc National Forest. Based on the information presented in this cumulative effects section, the implementation of Alternatives 2 through 6 may have an incremental impact on individual Townsend’s big-eared

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and pallid bats; however, no roosts will be affected by the implementation of activities described within the Noxious Weeds Treatment Project. According to the SNFPA Final Supplement Impact Statement (2004) (Appendix C page 419), “They [pallid and Townsend’s big-eared bats] appear to be most impacted by physical + changes or human disturbance of roost sites.” Therefore, Alternatives 2 through 6 may impact individuals, but are not likely to cause a trend to federal listing or a loss of viability for either species.

Introduction to Management Indicator Species Over the past fifteen years there have been changes to the status of the species covered under the Modoc NF MIS list. The federally listed and Forest Service sensitive species were based on the lists current for 1991. For example, in 1991, peregrine falcon was a federally listed species; currently, it is a Forests Service sensitive species. The Forest-wide MIS report summarizes the current known information about the Forest-scale population distributions and relationships to habitat of the MIS listed within the Modoc NF Forest Plan (USDA Forest Service 1991). The Modoc NF Forest Plan (USDA Forest Service 1991) requires a combination of species monitoring and habitat status, depending on the MIS (Table 3- 83). Appendix E of the Sierra Nevada Forest Plan Amendment (SNFPA) FEIS (USDA Forest Service 2001) as adopted by the 2004 SNFPA Record of Decision (ROD; USDA Forest Service 2004) amended the direction for species monitoring. The requirements for habitat monitoring are still found in the Modoc NF Forest Plan (USDA Forest Service 1991, Chapter 5, pages 5-1 to 5- 22). Table 1 displays the Modoc National Forest MIS and their current monitoring requirements.

Table 3 - 83. Monitoring Requirements for the MIS on the Forest (USDA 2001 as amended by SNFPA 2004)

MIS Monitoring Requirements MIS Habitatb Populationa Vegetation mapping, down log & Bioregional - status & change in American Marten snag transects geographic distribution Vegetation surveys, Habitat capability Bald Eagle Recovery Plan analyses Bighorn Sheep N/A - Extirpated N/A - Extirpated Blue/Sooty Grouse Vegetation mapping Distribution population Brook Trout Stream/lake habitat surveys Distribution population Brown Trout Stream/lake habitat surveys Distribution population Canada Goose Livestock utilization measurements Distribution population Golden Eagle Habitat utilization assessment Distribution population Goose Lake Redband Trout Stream surveys, Photo points Distribution / relative abundance Greater Sandhill Crane Livestock utilization measurements Distribution population Snag, down log transects; vegetation Hairy Woodpecker Distribution population mapping Largemouth Bass Stream/lake habitat surveys Distribution population Lost River Sucker Stream surveys, Photo points Recovery Plan Mallard Livestock utilization measurements Distribution population Stream surveys, Channel profiles, Modoc Sucker Population sampling b Photo points Mule Deer Vegetation sampling and mapping Distribution population Ground surveys and vegetation Northern Goshawk Bioregional - status & change measurement Osprey Habitat utilization assessment Distribution population Ground surveys during and after Peregrine Falcon Distribution population reintroduction efforts

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MIS Monitoring Requirements MIS Habitatb Populationa Snag transects, down log transects, Pileated Woodpecker Distribution population vegetation mapping Prairie Falcon Habitat utilization assessment Distribution population Habitat surveys including ecological Pronghorn condition (e.g., vegetation mapping, Distribution population condition and trend, etc.) Rainbow Trout Stream/lake habitat surveys Distribution population Red-breasted Sapsucker Vegetation sampling, photo points Distribution population Red-naped Sapsucker Vegetation sampling, photo points Distributionc Habitat surveys including ecological Sage Grouse condition (e.g., vegetation mapping, Distribution population condition and trend, etc.) Shortnose Sucker Stream surveys, Photo points Recovery Plan Spotted Owl, Northern Vegetation mapping / analysis Recovery Plan Swainson's Hawk Habitat utilization assessment Distribution / relative abundance Western Gray Squirrel Vegetation mapping Distribution population Willow Flycatcher Vegetation sampling, photo points Bioregional status and change Yellow Warbler Vegetation sampling, photo points Distribution population a Sierra Nevada Forest Plan Amendment, Appendix E b Modoc NF Forest Plan (USDA Forest Service 1991) c Monitoring requirements are in essence the same as the “Distribution population” data. As discussed in Appendix E of the 2001 SNFPA (USDA Forest Service 2001), there is a wide range of monitoring data that can be used to describe the change in populations. Some of these methodologies involve following the recovery plan for any listed species. Other monitoring is conducted as part of a larger, bioregional effort such as the information collected for willow flycatcher. Under the SNFPA, two additional types of monitoring were introduced into the Modoc National Forest Forest Plan requirements: distribution population monitoring and relative abundance population monitoring. Distribution population monitoring consists of collecting presence data for the MIS across a number of locations. Over time, changes in the distribution of the MIS may be identified and tracked. Presence data is collected using a number of direct and indirect methodologies, including but not limited to, bird point counts, herd composition counts run by California Department of Fish and Game, tracking numbers and locations of hunter takes, as well as queries of various databases housed at universities. Relative abundance population monitoring consists of monitoring sites that have been occupied by MIS within a given sample area as an index of abundance. Changes in occupancy over time are noted. This information is tracked in combination with distribution population monitoring to get information for species that have limited distributions. Population monitoring and survey data are not generally gathered for site-specific projects. The Modoc NF collects and consolidates presence data for various species in cooperation with State and federal agency partners (including California Department of Fish and game (CDFG)), U.S. Geological survey, and US Department of the Interior Fish and Wildlife Service) as well as other conservation partners (including Point Reyes Bird Observatory and Klamath Bird Observatory). The monitoring program for harvest species (i.e. species that are hunted, fished, or trapped) has been designed to be implemented in cooperation CDFG. This direction is consistent with both the 1982 Planning rule to monitor Forest-level MIS population trends in cooperation with state fish

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and wildlife agencies to the extent practicable (36 CFR 219.9(a)(6)), as well as Modoc Forest Plan direction. To be biologically meaningful for a wide-ranging MIS, presence data are collected and tracked not only at the Forest scale, but also at larger scales such as range-wide, state, province (Sierra Nevada for example), or management unit (for example, Deer Assessment Unit). Population data at various scales are important to both assess and provide meaningful context for population status and trend at the Forest-scale. Appendix E of the 2001 SNFPA FEIS and Chapter 2 of the 2004 SNFPA SEIS identify specific monitoring requirements for species, where landscape or bioregional scale is used (e.g., California spotted owl and American marten; USDA Forest Service 2006). The Modoc National Forest MIS report consists of species accounts for each MIS. The species accounts are based on the best current information on life history, habitat relationships, suitable habitat, and changes in distribution information for each MIS. Species distribution information is discussed at a variety of spatial scales, including the range of the species, State (i.e., California), Province (e.g., Sierra Nevada), and Forest. This information is discussed in terms of the current amount of habitat and the current species distribution from a Forest perspective. For each MIS, the time frame for the changes in distribution as well as trend in habitat is the adoption of the Forest Plan to the present. The current quantity of habitat present on the Forest has been delineated for each species based on GIS models, which incorporate changes in habitat since the Modoc Forest Plan was finalized.

Region 5 Sensitive Species That Are Also Modoc NF Management Indicator Species American Marten Direction for marten under the Modoc NF Forest Plan consisted of designating a minimum of 13 marten territories Forest-wide (four on the Doublehead District and nine on the Warner Mountain District). These territories were to encompass 2,000 acres and be managed to provide late seral habitat. They were established in areas that had previous sightings or provided the best potential to serve as marten habitat. Both the Northwest Forest Plan (USDA/USDI 1994) and the Sierra Nevada Forest Plan Amendment ROD (USDA 2004) amended the Modoc National Forest Land and Resource Management Plan direction. Both large-scale amendments to our Forest Plan stress the protection and management of late-seral habitats. Other direction involves the protection of marten den sites from disturbance from management treatments with a limited operating period (LOP) from May 1 through July 31, as long as habitat remains suitable (FSEIS Record of Decision (ROD), page 62, D-88 and D-89.) (USDA 2004). The intent of Late Successional Reserves and Managed Late Successional Areas (where the occupied den site is located) is to 1) Provide a distribution, quantity, and quality of old-growth forest habitat, sufficient to avoid foreclosure of future management options, 2) Provide habitat for populations of species that are associated with late-successional forests (specifically to protect the Scientific Advisory Team’s list of species closely associated with old growth), and 3) To help ensure that late-successional species diversity will be conserved, Riparian Conservation Areas and Critical Aquatic Refuges were established to benefit aquatic species, as well as provide for greater connectivity of late-successional forest habitat, which in turn improves travel and dispersal corridors for terrestrial animals and plants. Direction in the Sierra Nevada Forest Plan Amendment (USDA 2004) requires the identification of 100 acres of the highest quality habitat surrounding marten den sites. A biological evaluation for proposed vegetation treatments will

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determine what breeding disturbance is permissible within the 100 acres from May 1 to July 31 (Limited Operating Period).

Habitat - Species Relationship for American Marten Marten were found to prefer late-successional stands of mesic coniferous forest, especially those with complex physical structure near the ground (Buskirk and Powell, 1994 in Ruggiero et al. 1994). Suitable habitats on the Modoc consist of dense (>40% crown closure) coniferous forests that have significant amounts of snags and logs. Small clearings and riparian areas may also be used for foraging. Marten occur at elevations ranging from 4,000-13,000 feet in the northern Sierras. Habitat associations are characterized by dense canopied, multi-storied, multi-species climax coniferous forest with a high number of large snags and downed woody material. Habitat preference includes mature mesic forests of red fir, red fir/white fir mix, lodgepole pine, Sierran mixed conifer and Klamath mixed conifer. Current models suggest that 2.5 - 20 logs per acre and >3 snags per acre (>15"DBH) be left in managed areas to provide moderate suitability for marten. On the Modoc National Forest, marten have been sighted in mixed conifer (white fir dominated) and lodgepole pine habitats. Marten habitats on the Modoc National Forest are similar to the neighboring Lassen National Forest. Extensive survey work for Forest carnivores on the Lassen National Forest has included over 22,000 trap-nights (14,000 on the Eagle Lake Ranger District; and 8,000 on the Hat Creek Ranger District) with no detections of marten in eastside pine habitats (B. Turner and T. Rickman, pers. comm.). There are about 39,200 acres of various vegetation types found within Modoc NF marten territories. The major vegetation types are located within these territories: white fir, red fir, Sierran mixed conifer, and lodgepole pine. There are an additional 17,606 acres of potential marten habitat Forest wide, which is often located adjacent to these Forest marten territories. The vegetation types for this query included mixed conifer, Douglas-fir, white fir, lodgepole pine, and red fir with larger tree sizes and denser canopies. Home range sizes for males are larger than females and vary in size between 0.6 square miles (422 acres) and 1.7 square miles (1,088 acres) (Freel 1991). Marten give birth to their young in March and April; they are weaned in about 42 days (Ruggiero et al. 1994). The following information concerning food habits was obtained from Ruggiero et al. (1994). Marten consume a variety of different foods: small mammals, birds, fruit, carrion, and insects. The most common prey items for marten consists mainly of small mammals: voles, ground squirrels, and Douglas squirrels. Marten often forage in meadows and/or shrub patches.

Habitat Status and Trend at the Forest Scale for American Marten The trend for habitat in the Medicine Lake Highlands (MLH) is stable to increasing, in the higher elevation sites, and decreasing at the lower elevation sites, based on the following information. Fire exclusion and commercial timber management activities of the past 70 years or so, have resulted in elevated stand densities, insect and disease activity, which have augmented fuel loadings in most vegetation types in the MLH, thus increasing the risk of crown fire and large stand replacing fire events. The current trend for marten habitat within the area amended by the Sierra Nevada Forest Plan Amendment ROD (USDA 2004) maintains the current level of potential marten habitat on the Modoc National Forest.

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Project-level Effects Analysis based on American Marten Habitat Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no effect on American marten habitat. The marten prefer older seral stage stands with large snags, stumps, and logs; enhancing riparian areas under the Riparian Management Prescription were thought to improve potential marten prey (USDA 1991b, Page 3- 104). The potential effects are limited to the potential consumption of herbicide-contaminated prey and disturbance. Analysis Area for Project-level Effects Analysis: The analysis area for marten is limited to the 39,200 acres within the thirteen Modoc NF marten territories and the additional 17,606 acres of potential habitat Forest-wide. This habitat is limited to the upper elevations of the Forest that have mixed conifer, white and red fir, and lodgepole pine. In general, the marten territories and additional potential marten habitat include the Warner Mountain Ranger District and the Medicine Lake Highlands.

Alternative 1 (Current Management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect marten habitat. There will be no change in the current or future amount of large trees, snags, or dead and downed materials by the treatment of noxious weeds. Nor would there be any change in the amount of late seral stage habitat. Zero % of the current marten habitat in the analysis area, would be affected by implementation of Alternative 1. Cumulative Effects to Habitat Because there are no direct or indirect effects to marten habitat, there are no cumulative effects to marten habitat under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat: A maximum of 0.1 acres could receive physical + treatments and a maximum of 0.29 acres could receive herbicide treatment within marten Forest Plan territories (Table 3-84). A maximum of 2.039 acres within potential marten habitat could receive herbicide treatments (Table 3-84). Therefore, a maximum of 0.004% of the 56,806 acres of marten habitat Forest-wide could receive treatment.

Table 3 - 84. Proposed Treatment Acres within Marten Territories, Modoc National Forest

Total Maximum Acres Type of Marten Total Acres of Marten Total Maximum Acres of of Physical + Habitat Habitat Forest wide Herbicide Treatments * Treatments * Forest Plan territories 39,200 0.1 0.29 Potential 17,606 0.0 2.039 *This figure includes the maximum, where physical + or herbicide methods may be employed No marten den site would be removed by the implementation of Alternatives 2 through 6, nor would there be any reduction in habitat suitability for this species Forest-wide. In addition, none of the weed treatments is proposed near the known den site in the Medicine Lake Highlands.

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There should be no change in the amount or food resources available to marten. Marten have been documented to eat fruit; however, they are not known to consume noxious weeds. Although, some of the potential prey (small mammals and birds) could potentially use the thistle seeds as food on the WM008CIAR4 and WM004CIAR4 (Canada thistle) sites, there are several other species of native thistles in the Warner Mountains that could provide foraging opportunities for prey. The removal of weeds would also have no effect on insects, because there are still ample native plants to provide food and cover for them. Therefore, the decrease of a maximum of 2.039 acres of thistle would have no discernible effect on the amount of potential marten food. Cumulative Effects to Habitat: Because there are no direct or indirect effects to marten habitat, there are no cumulative effects to marten habitat under these Alternatives.

Project-level Effects Analysis based on American Marten Population Summary of Population Status and Trend at the Forest Scale: The Modoc NF Forest Plan (as amended by the SNFPA) requires bioregional-scale distribution population monitoring for marten. The sections below summarize population status and trend data for the marten. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

American Marten Population Status and Trend at the Bioregional Scale and Local Scales The California Natural Diversity Database (CNDDB) rank is “G5S3S4”: Global 5 indicates marten is globally “demonstrably secure; commonly found throughout its historic range”; State 3 / State 4 indicates that, in California, marten is between being ‘apparently secure’(G4) and ‘restricted range/rare’(G3). Recent studies and sightings indicate that martens are relatively well distributed in a pattern similar to their historical distribution in the Sierra Nevada (Kucera et al.1995). Marten have been tracked and monitored throughout the Sierra Nevada using a variety of survey techniques, including project level surveys; the Pacific Southwest Research Station (PSW) retrospective database (which incorporates CDFG information, historic data back to Grinnell et al. 1937 in Ruggiero et al (1994); and systematic surveys conducted from 1992 to 2002 by Zielinski, Truex, Carroll, Clevenger, and Campbell). Track plate and camera surveys to detect marten have been conducted at various locations on the Modoc National Forest from 1992 to 2007. The only known marten den site on the Forest is located near Medicine Lake (Doublehead Ranger District); however, there have been scattered incidental sightings of marten in the mixed conifer and white fir habitats north of Adin on the Big Valley Ranger District, and at various sites throughout the Warner Mountains. The pattern of distribution for marten, based on incidental sightings, has expanded to include the Big Valley Ranger District, since the time of the Modoc Forest Plan.

Effects of the Alternatives on American Marten There is no chance of consumption of contaminated prey under Alternatives 3 and 5 (Alternatives where no herbicides will be used), or the physical + treatments in 2, 4, and 6. There is a chance for disturbance at potential den sites; it should be a low likelihood, because these weed occurrences are usually inaccessible until later in June due to snow. There is a total of 0.19 acres that could be treated in a total of 5,279 acres within marten territories in the northern and central Warner Mountain District (2,560 acres in Pine Creek and 2,719 acres in the Payne Peak territories). There would be a slight potential for ingestion of

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contaminated mammals, if both roughly .1 acre weed occurrences, were sprayed. According to information from the SERA reports, none of the herbicides has a hazard quotient above one, so the risk to marten from a cumulative treatment of .2 acres is very low (See Table 3-79 in the wolverine/SNRF section of this document). Based on field studies, there appears to be little effect to potential prey from the use of herbicides under certain situations. Johnson and Hansen (1969) found litter size for deer mice was little affected by 2, 4-D. Sullivan (1990) found that the survival rate, body mass and growth rates of deer mice and Oregon vole were not affected by exposure to herbicides, and that this finding would indicate that there were little or no adverse effects on metabolic or general physiological processes in the development of young. McMurry et al. (1993) found that the woodrat population density was the highest on areas treated with Triclopyr, and postulated that there was an increase in forage and nest-building material, which supported the higher numbers of animals. These authors also found that there was no difference in reproductive activity, mean body weight, or animal condition between treated and control sites. Given the small acreage to be treated (0.4 acres total) and the low risks to prey presented by these small acreages, there would be inconsequential direct and no indirect effects to marten by implementation of Alternatives 2, 4, and 6. Under the Alternatives with Early Detection/Rapid Response activities, wildlife biologists would review new noxious weed treatment sites prior to implementation. If concerns for marten surface, (including conditions not covered within the analysis for the FEIS), additional Design Standards could be added. Cumulative Effects to Populations: There are few cumulative effects associated with physical + or herbicide treatments for the following reasons. The Pine Creek territory currently receives little use from recreationists, wood cutters, cattle, and mineral developments. There is little additional activity that could cause additional disturbances to denning animals. The Payne territory is fairly well roaded and does receive more use, especially near Dry Creek Basin and Upper Deep Creek, where there is a moderate level of camping, hunter, wood cutter, and cattle use. However, the unconfirmed marten sighting was in the northern portion of the territory in a canyon accessible only by foot. There is very little activity in this canyon, which is roughly two miles from the weed occurrences. Repeated weed treatments may cause a small amount of disturbance, but this is not expected to cause any loss of marten habitat or cause mortality. To reiterate, there would be inconsequential direct, no indirect, and inconsequential cumulative effects for marten by implementation of Alternatives 2 through 6 for the following reasons: Only a very small amount of weeds would be treated in marten territories and potential habitat, disturbance is expected to be minimal, and the low risk associated with these herbicides to predatory mammals consuming prey.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Bioregional-Scale Population Trends for the American Marten The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for marten. Nor is there any potential effect to the marten population on the Forest. Therefore, implementation of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing bioregional-wide trend in population distribution of marten.

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Greater Sandhill Crane The greater sandhill crane is a terrestrial MIS, a Forest Service Sensitive, and a California state threatened, fully protected species. Management Direction: Improve habitat quality by protecting meadows and wetlands associated with livestock grazing. Over time this would improve population status for the Greater Sandhill Cranes. (SNFPA Final Supplemental Environmental Impact Statement (FSEIS) USDA 2004, Appendix C, page 420).

Habitat - Species Relationship This species is most commonly found in and near wetlands, especially along margins of shallow water (Baker et al. 1995, Littlefield 1995a, Zeiner et al. 1990). Nesting has been documented on islands as well. Some more unusual nest sites include sagebrush and oak-dominated hillside (Ellis and Haskins 1985), black greasewood (Littlefield 1994), alkali bulrush (Littlefield 1994), Canada thistle (Littlefield 1994), desert saltgrass (Littlefield 1994), and barley (Littlefield 1994). Most (71%) of the nests that were in atypical habitats were destroyed or unsuccessful. A 210-acre area, which equates to the average size of a territory (Zeiner et al. 1990), was analyzed around each nest to approximate acreage of occupied habitat. According to the data in the query, there are roughly 10,000 acres of occupied habitat on the Forest. The major vegetation types found in proximity to the nest sites include the following: water, sagebrush, juniper, eastside pine, wet meadow/sedge, and annual grassland. An additional 181,521 acres of potential habitat were modeled using the EVEG data and extending 200 meters around all of the wetlands in the corporate Modoc National Forest lakes layer. Lack of concealing vegetation was a significant factor in loss of nest, which made nests more open to predation. Littlefield and Paullin (1990) found that nesting success in the absence of predator control was lower on wetlands grazed by livestock than on ungrazed wetlands. Coyotes, raccoons, and common ravens were common predators (Littlefield 1999, Littlefield 1995a, Littlefield 1995b). Nest success in the Ash Creek Wildlife Area (northeast of Bieber) was 36%, and Ash Creek Valley (16 km west of Madeline) was 0% (Littlefield 1995a). However, drought was likely to be a significant factor. Foraging habitat for sandhill cranes is varied and includes open grasslands, agricultural fields, as well as shallow marshes with emergent vegetation (Zeiner et al. 1990, Tacha et al 1992). Sandhill cranes are omnivorous, exploiting subsurface food items by probing with bills or by gleaning seeds and other foods from the ground. Foods vary widely, depending on seasonal availability (Tacha et al 1992). Non-migratory subspecies eat insects and their larvae, snails, reptiles, amphibians, nestling birds, small mammals, seeds of various plants, and berries (Tacha et al 1992). To illustrate this ability to utilize a broad scope of foods, Tacha et al. (1992) cite an example of sandhill crane diets of adults and young in southeastern Wisconsin. Both adult and young birds consumed invertebrates and small mammals and reptiles during early brood rearing; non-breeding adults ate mostly tubers of aquatic plants in spring and early summer, and then switched to cultivated grains in late summer.

Habitat Status and Trend at the Forest Scale for the Greater Sandhill Crane There were two foci in the Forest Plan to maintain or enhance crane habitat within the Modoc: development of wetlands and control of livestock grazing. In 1965, a program was initiated to increase wetland habitats; this program has been greatly expanded since the time of the Modoc Forest Plan. As of 2001, the majority of the wetlands development had been completed. New grazing practices have been implemented since the release of the Modoc Forest Plan. The retention of cover in addition to changes in livestock management (e.g., alteration of rotations,

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fencing pastures to exclude cattle at critical times) have helped provide for the increase in sandhill cranes seen on the Forest. Between wetland development and implementation of the Riparian Area Management Prescription, the trend for sandhill crane habitat on the Modoc National Forest is stable. It could potentially increase with further wetland development or livestock management changes, pending future funding.

Project-level Effects Analysis based on Greater Sandhill Crane Habitat Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will benefit sandhill crane. Cranes are not directly tied to the noxious weeds for cover or food. In fact, the replacement of natural cover by weeds has a detrimental effect to potential nesting cover. As stated above, the majority of sandhill crane nests that were placed in atypical plant cover were destroyed or unsuccessful. The potential effects from the implementation of the activities in the Noxious Weeds FEIS are limited to the consumption of herbicide contaminated plants and prey, as well as disturbance to nesting birds. Analysis Area for Project-level Effects Analysis: The analysis area for sandhill crane includes the estimated 10,000 acres of occupied habitat and the 181,521 acres of potential habitat. A majority of this habitat is located on the Devil’s Garden District, but is also scattered adjacent to wetlands across the Forest.

Alternative 1 (Current Management)

Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect on sandhill crane habitat. There would be no change in the current or future amount of nesting and foraging cover by the treatment of noxious weeds. Vegetation diversity is expected to remain basically the same on the 30 acres. Therefore, 0% of the current sandhill crane habitat in the analysis area would be affected by implementation of Alternative 1. Conversely, the effect of not treating the habitat could cause a significant decrease in the amount of potential cover for cranes.

Cumulative Effects to Habitat Because there is no direct or indirect effect to sandhill crane habitat, there are no cumulative effects to sandhill crane habitat under this Alternative.

Alternatives 2 to 6

Direct and Indirect Effects to Habitat There could be a maximum of 238.81 acres of physical + treatments and 236.99 acres of treatment with herbicides within the potential crane habitat. A maximum of 2.41 acres of herbicide and/or physical + treatments could take place within occupied crane habitat (Table 3- 85). A maximum of 0.131% of the potential and a maximum of .0241% of occupied sandhill crane habitat Forest-wide could receive herbicide treatments.

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Table 3 - 85. Proposed Treatment Acres within Greater Sandhill Crane Habitat

Type of Crane Total Acres of Crane Total Maximum Acres of Total Maximum Acres Habitat Habitat Forest wide Physical + Treatments * of Herbicide Treatments * Occupied 10,000 2.41 2.41 Potential 181,521 238.81 236.99 *This figure includes the maximum, where physical + or herbicide methods may be employed Direct effects to crane habitat include the potential loss of nesting cover and foraging habitat. As stated above, weeds do not provide adequate nesting cover, so removal of weeds, especially with revegetation efforts, would benefit cranes. Foraging habitat should either remain the same or improve. Cranes are not known to use noxious weeds as food; therefore, removal of weeds should not decrease the amount of food available to them. The removal of the weeds should provide improved habitat for small animals and insects. Subsequent replanting of bare areas would decrease the potential for reinfestation by weeds and provide better cover (depending on the plant species chosen for revegetation treatments). Therefore, there should be no negative direct or indirect effects to sandhill crane habitat by the implementation of Alternatives 2 through 6. Cumulative Effects to Habitat The cumulative effects to sandhill crane habitat under any Alternatives would be the increase of nesting and foraging habitat. As stated above, changes made to livestock management and the development of wetlands have helped provide for the increase in sandhill cranes seen on the Forest as evidenced in the increased numbers and distribution, since the time of the Modoc NF Forest Plan.

Project-level Effects Analysis based on Greater Sandhill Crane Populations Summary of Population Status and Trend at the Forest Scale: The Modoc NF Forest Plan (as amended by the SNFPA) requires Forest-scale distribution population monitoring for greater sandhill crane. The sections below summarize population status and trend data for the sandhill crane. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Population Status and Trend at the Bioregional Scale and Local Scales for the Sandhill Crane Greater sandhill crane is “S2” in California (NatureServe). This ranking stands for “Imperiled” at the state/province; this ranking is given to species/subspecies because of “rarity due to very restricted range, very few populations (often 20 or fewer), steep declines, or other factors making it very vulnerable to extirpation from the nation or state/province”. One factor may be where the sandhill cranes in California are nesting. Ivey and Herziger (2001) found the majority (63%) of sandhill crane territories in the 2000 statewide survey were on private lands, which may not provide secure habitat over time. However, when referring to the crane status in Oregon and California, Littlefield and Ivey (2001) stated that the upward trend should continue provided reproductive success was sufficient, breeding habitat remained secure and wintering habitats were protected. Although there are some Breeding Bird Survey (BBS) routes with decreasing trends in California, most of the routes had stable to increasing trends. In a statewide survey conducted specifically for sandhill cranes, Ivey and Herziger (2001) recorded a 68% increase in the total number of pairs recorded between the 1988 statewide survey to the 2000 statewide survey.

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At the Sierra Nevada scale for the period of 1968-2005, Sierra Nevada-wide BBS data classifies sandhill crane as 21.6, which is a positive trend. However, the Regional Credibility ranking is “red”, due in part to the sample size of two. A better measure of trend in the Sierra Nevada is the work completed by Ivey and Herziger (2001). They recorded increases in many of the sites in the Sierra Nevada between the 1988 statewide survey to the 2000 statewide survey, although there were localized decreases. An additional paper by Roberts et al. (1996) noted that the pairs in the South Fork of the Pit River (Modoc County) were stable as well. The Modoc NF uses data collected on, and adjacent to, the Forest in both Forest-level as well as project-level planning. Modoc NF staff has monitored sandhill cranes for various project-induced surveys and Forest Plan monitoring efforts from mid-1980 to the present. There were approximately 10 pairs of sandhill cranes in the late 1980’s during the development of the Modoc National Forest Forest Plan (US Forest Service 1991b – page 3-107). Currently, the Modoc National Forest has at least 40 locations where sandhill cranes have nested. The number of territories exceeds the Modoc NF Forest Plan goal of “approximately 20 pairs” (USDA 1991a. Page 4-28), and the distribution of cranes has expanded since the time of the Forest Plan.

Effects of the Alternatives on the Greater Sandhill Crane Direct and Indirect Effects: The two potential effects to sandhill crane populations come from disturbance to nesting birds and consumption of contaminated food. Weed treatments, both physical + and herbicide, would occur annually until both the weeds and their seed banks are eliminated, so there would be a slight chance for potential disturbance over time. Gary Ivey, sandhill crane species expert, stated that that crane nest success is generally about 50%, and brood survival is usually less than 10%, so caution [in implementing management activities] is advised. Design Standard DS-10 has been developed to provide a Limited Operating Period for nesting sandhill cranes, as recommended by Gary Ivey. Pre-season work plans (DS 02) are a critical component to implementation. Use of surveys and a limited operating period for nesting animals should minimize potential disturbance problems. As for the contamination risk from herbicides, there is little concern within occupied habitat for the following reasons. First, a maximum of 2.53 acres or .0253% Forest-wide could be treated with herbicides. The two largest occurrences (DG059ONAC (Scotch thistle) and DG001ISTI (dyer’s woad) are found in one territory; therefore, the vast majority of the herbicides used Forest-wide in occupied habitat (2.43 acres treated with herbicides out 2.73 acres of weed occurrences in occupied habitat Forest-wide) will be centralized in one territory. Second, the herbicide with the highest hazard quotients, 2, 4-D, will not be used under any Alternative. Both weed occurrences are within 1,000 feet of water (DG059ONAC is within the 300 foot SMZ and DG001ISTI (dyer’s woad) is within 10 feet of the water’s edge). Under Alternatives 2 and 4, 2, 4-D would not be used within 1,000 feet of water. Under Alternative 6, these occurrences would only be treated with physical + means. Third, these weed occurrences are located along a railroad outside of the wetland where the crane pair forages, which is mainly along the reservoir shores (J. Irvin, pers. comm.). Therefore, there would be no effect from consumption of contaminated materials by cranes within occupied habitat. Owing to the size of the following weed occurrences, there could be effects to sandhill cranes, who reside in potential habitat. Of the 236.99 acres within potential sandhill crane habitat that could receive herbicide treatments, 227.19 acres are included within two weed occurrences: BV006LIDA [Dalmatian toadflax] (217.19 acres in potential crane habitat) and WM009CIAR4 [Canada thistle] (10 acres in potential crane habitat).

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BV006LIDA (Dalmatian toadflax) - The majority of the area is lava reef country with open conifer stands. The entire weed occurrence is roughly 850 acres. In the area adjacent to Lava Lake, the toadflax has a patchy distribution consisting of small clumps of plants that are less than 0.001 acre in size. No toadflax occurrences were observed in the riparian margin of the lake where the potential crane habitat exists. There is a lava reef that surrounds the lake, so there is no chance of direct spray to any crane, nor is there a chance of drift. The chance of disturbance from treatment activity to nesting cranes is also low because of the presence of the lava reef, and wet road conditions do not allow access until late June. Therefore, under Alternatives 2 and 4, there would be no effect to sandhill crane by treatment of this weed occurrence. Under Alternative 6, only the exterior satellites of the weed occurrence would be treated, which are not within the potential crane habitat. There would be no risk to cranes by treatment of this weed occurrence under Alternative 6 as well. WM009CIAR4 (Canada thistle) - The site includes an old beaver pond that has sedimented in, surrounded by remnant aspen and scattered lodgepole pine and white fir; this area is tucked in the upper portion of the Mill Creek watershed and does not have potential habitat for nesting cranes (M. Flores, results of aspen monitoring within the area). It was listed as potential crane habitat, because of an artifact in the data set. Therefore, there would be no effect to cranes by the treatment of this occurrence under any Alternative. There are five other weed occurrences ranging from 1.0 to 1.43 acres. The potential effects to cranes by the treatment of DG059ONAC (Scotch thistle) and DG001ISTI (dyer’s woad) were discussed above in the paragraphs on occupied habitat. BV309ONAC would not be treated with herbicides under any Alternative. The occurrence near Snag Hill, BV307ONAC (Scotch thistle), has no known crane occupancy. Any potential effects would be very limited to cranes, due to the size and the isolation of this one small reservoir. Except for these five weed occurrences, the remaining 9.8 acres are weed occurrences that are less than one acre, and the vast majority of these occurrences are 0.1 acres or less; the treatment of these 0.1 acre weed occurrences is not expected to cause any significant adverse effects to cranes. Papers have shown that herbicides do drift and can affect wildlife (Ernst et al. 1991). The risk assessment for the re-registration for 2, 4-D states plainly that there could be concerns from volatilization and off-site deposition of 2, 4-D esters (US EPA 2005). The authors of this risk assessment add that the effect of volatility of 2, 4-D esters on non-target organisms should be viewed as a source of uncertainty in their assessment. Other authors have found upslope transport of pesticides (LeNoir et al. 1999), and that there may be evidence linking the presence of pesticides with declines in amphibians (Davidson et al. 2001; Davidson et al. 2002). However, the difference between amounts of herbicides used in these studies is a factor of 1,000 larger, when compared to the amount proposed in the Weed Treatment FEIS. In addition, these papers do not discuss spot treatments of noxious weeds, but boom applications (the Forest does not propose using boom application). Given the small size of the weed occurrences and the type of herbicide application, volatilization and drift are not expected to affect sandhill cranes. Under the Alternatives with Early Detection/Rapid Response activities, wildlife biologists will review new noxious weed treatment sites prior to implementation. If concerns for sandhill crane surface (including conditions not covered within the analysis for the FEIS), additional Design Standards could be added. To summarize, there is a small potential for direct effects and no indirect effects to individual cranes by the implementation of Alternatives 2-6. Relatively few acres Forest-wide could be treated in occupied or potential habitat and the vast majority of these occurrences are less than 0.1 acre, thereby minimizing the potential consumption of contaminated food. Disturbance would be minimized (hence the need for pre-treatment surveys and the LOP described in Design Standard

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DS-10). Therefore, the action Alternatives in the Noxious Weed FEIS may have some minor impacts to individuals, but will not lead trend toward listing. Nor will the weed treatment activities affect sandhill crane populations on the Forest. Cumulative Effects to Populations There is one territory Forest-wide, where herbicide treatment poses the greatest risk to cranes. There is a significant amount of human activity in the Hackamore Reservoir area based on information from Jim Irvin. (Mr. Irvin has 21 years as a Range Conservationist on the Modoc NF, and is very familiar with this area). Timber harvest activities include both commercial thinning and planting in plantations that are east, south, and west of the reservoir. There was also a prescribed fire south of the Reservoir in 2004; one of the objectives of this burn was to improve elk habitat. Water is drafted from the Reservoir during August and September for sheep use, but may be drafted from late July on if there is road maintenance that is needed. The drafting site is about ½ mile west of the nest site, so there is a low potential for disturbance. Grazing would be considered moderate to heavy; however, the area is in a pasture system, so it is not grazed two out of three years until after July 15, to promote waterfowl habitat. There are sheep corrals where gathering occurs northwest of the Reservoir. Potential effects to cranes from grazing would be fairly low, because of the timing and of activities. A low amount of fishing occurs from May until the end of June, so there is minimal potential disturbance to nesting cranes. Waterfowl hunting occurs from October to early January; the cranes usually have migrated outside of the area then, so potential impacts to cranes are light. All activities discussed above are either out of the nesting area or outside of the critical nesting time, and consequently pose little potential disturbance to cranes. Forest-wide, currently there are roughly 3,000 acres of utility corridors and 1,500 acres of communications facilities under permit, where vegetation removal may be conducted by the special-use permit holders. The Department of Defense had a radar installation south of Doublehead Mountain in open juniper/sage habitats. The area was roughly 1,000 acres, enclosed by an eight-foot fence. The installation is currently being dismantled, and would receive no further vegetation treatments. There is a 16- to 20- acre corridor that Bonneville Power Utility might spray annually, which flanks Highway 139 outside of crane habitat. Finally, there are communications sites that total roughly an acre of habitats that could be sprayed across the Forest. The rest of vegetation treatments involve usually hand grubbing, but may also include the felling of trees beneath telephone lines. Currently none of the other special-use permit holders are spraying herbicides. They will not be able to use herbicides unless they have authorization in writing from the Forest Service prior to any treatment. The Forest Service would utilize the guidelines outlined in the Noxious Weed FEIS for any herbicide treatments. Given the various Design Standards, there would be no cumulative effect from consumption of contaminated materials to the sandhill crane distribution on the Modoc National Forest. There could be a maximum of 1,500 acres sprayed annually on the Forest or 0.089% of the Forest. Under Alternative 6, that number would decrease to a maximum of 522 acres or 0.031% of the Forest. About 16,080 acres could have herbicides in roughly 3.5 million acres (state, private, tribal and other federal lands), which would be 0.46% of that gross area (see the Noxious Weeds Terrestrial BA for more detailed information). The sandhill cranes are foraging on the Forest in areas far away from these weed infestations on private, tribal and other federal lands during the time of active spraying. Once cranes utilize these areas during the staging period for migration, weeds are not usually being treated. Therefore, there are few additional cumulative effects expected to sandhill cranes from herbicides both on and surrounding the Modoc NF.

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Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Greater Sandhill Crane The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for greater sandhill crane. Nor is there any potential effect to the sandhill crane population on the Forest. Therefore, implementation of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing Forest-wide trend in population distribution of greater sandhill crane. Northern Goshawk The Modoc National Forest Land and Resource Management Plan (Forest Plan) (USDA 1991a) selected goshawk as an indicator of old Forest ecosystems; it is also considered an old-forest- associated species under the Sierra Nevada Forest Plan Amendment (USDA 2004). The Modoc National Forest direction for goshawk management specifies that the Forest will maintain 100 goshawk territories. Each territory consists of a minimum of 100 acres for primary and alternate nest stands. The Sierra Nevada Forest Plan Amendment direction (USDA 2004), which amended the Modoc Forest Plan, includes the use of monitoring and the establishment of Protected Activity Centers (PACs) to maintain northern goshawk viability across the Sierra Nevada (USDA 2004 Record of Decision, Pages 59, 60, 54, D34). These areas increased to 200 acres under this direction (USDA 2004 Record of Decision. Page 38). Limited Operating Periods have also increased to February 15 through September 15 (USDA 2004 Record of Decision, Page 60). The Big Valley Sustained Yield Unit is an exception to the SNFPA direction. In the Big Valley Sustained Yield Unit, northern goshawks may be managed under the direction of the Modoc NF Forest Plan (1991). In the Medicine Lake Highlands, which are managed under the direction of the Northwest Forest Plan (1994), there are no northern goshawk Protected Activity Centers. However, northern goshawk management is provided by the direction for the Managed Late Successional Area assessments. Habitat - Species Relationship: The attributes of northern goshawk nesting habitat are well documented. Research in northern California has shown that territory occupancy is positively correlated with the nest stand size. Occupancy nears 100 % for stands greater than 151 acres. Occupancy was 75-80 % at 100 acres (Woodbridge and Detrich 1994). Nest stands have relatively high tree canopy cover and a high density of large trees (Reynolds 1992). Richter (2000) did radio tracking in areas close to this project area and in similar habitat, and found an average canopy closure at the nest site of 84 %. Austin (1993) also concluded that adult goshawks generally avoid open (<40% canopy cover) Forest conditions. Desimone (1997) found occupied goshawk territories on the Fremont National Forest to have more closed, mid- to late-seral forest (>50% crown closure) than territories where goshawks could not be found. On the Lassen National Forest, Rickman (2001) found goshawk roost sites in all seasons to average 74 % canopy cover. The studies did not all use the same method for quantifying vegetation, but all show relatively high tree canopy densities. Local surveys on the Big Valley District support the density and tree size research; however, there are some instances locally where goshawks will select small inclusions in open habitat that would not be otherwise considered suitable. Ingraldi (1995) also found a similar trend with goshawks in Arizona where the birds selected larger and taller trees, a nest tree that was part of a clump, and often in the lower third of the slope. Fewer studies, however, have concentrated on the characteristics of suitable foraging habitat. Information from the Region 3 northern goshawk guidelines, states that the following characteristics are important for foraging stands: Portions of the foraging area should have mature

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to older stands with a minimum of 40% canopy cover, at least two large (greater than 18 inches DBH/30 foot tall) snags per acre, at least three large downed logs per acre, and a minimum of 3 to 5 mature and old trees per acre in groups or stringers with interlocking crowns (Reynolds et al. 1992). The snag dimensions were selected to meet the minimum requirement for prey species (Reynolds et al. 1992). Initial findings from one study in Arizona echo the Region 3 information indicating that “some goshawks selected for habitats with more and larger trees” (Beier 1995). Locally on the Modoc National Forest, other biologists have noted this trend for goshawks to use the large trees as perches for hunting (G. Studinski, pers. comm.). Although nest stands tend to have dense overstory canopy, a mixture of habitat types including riparian areas, is utilized for foraging. Prey remains under nests found on the Modoc National Forest indicate that these birds take both avian and mammalian prey (Studinski, pers. comm.; Promessi, Matson, and Flores 2004).

Habitat Status and Trend at the Forest Scale for the Northern Goshawk There are approximately 23,600 acres of various vegetation types within northern goshawk PAC’s set up during the Sierra Nevada Forest Plan Amendment (USDA 2004) analysis process. Vegetation types included within PAC’s are as follows: eastside pine, Sierran mixed conifer, white fir, and lodgepole pine with inclusions of sagebrush, montane chaparral, and various minor constituents. There are an additional 96,377 acres of potential goshawk habitat Forest-wide, which includes dense stands of mixed conifer, eastside pine, and white fir. The trend for goshawk habitat on the Modoc National Forest within the area amended by the Sierra Nevada Forest Plan Amendment (USDA 2004) is stable, since timber harvest is located outside of later successional stands.

Project-level Effects Analysis based on Habitat for the Northern Goshawk Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no effect on habitat for northern goshawk. Northern goshawks are tied to late-seral conifer stands and do not use noxious weeds for cover or food. The main potential effects are limited to the potential ingestion of contaminated prey and disturbance to nesting birds. Analysis Area for Project-level Effects Analysis: The analysis area for northern goshawk is limited to the 23,600 acres of occupied habitat and 96,377 acres of potential habitat on the Forest. This habitat is clustered on the Warner Mountain and Big Valley Districts, but is also localized on portions of the Modoc NF in later seral coniferous habitat.

Alternative 1 (Current Management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect on northern goshawk habitat. There will be no change in the current or future amount of large trees or late-seral coniferous habitat. Vegetation diversity is expected to remain unchanged. Aspen and meadow habitat, which are prime foraging areas, may be improved in very site specific locations. Zero % of the current northern goshawk habitat in the analysis area would be affected by implementation of Alternative 1.

Chapter 3—Affected Environment & Environmental Consequences 329 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Cumulative Effects to Habitat Because there is no direct or indirect effect to northern goshawk habitat, there are no cumulative effects to goshawk habitat under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat: There is a maximum of 4.48 acres of physical + treatment and 4.04 acres that could be receive herbicide treatments within occupied goshawk PAC’s. Eleven PAC’s could receive treatment; however, the majority of the treatment (3.48 out of 4.04 acres) would be in PAC R05F09D53T07. Although there are no PACs in the Medicine Lake Highlands, the weed treatments in the Highlands are physical + , and outside of the areas of known goshawk occupancy. A maximum of 325.07 acres of potential habitat could receive physical + treatments and 323.72 acres of herbicide treatments. Therefore, a maximum of 0.34% of the 96,377 acres of potential goshawk habitat Forest-wide could receive herbicide treatment (table below).

Table 3 - 86. Proposed Treatment Within Occupied and Potential Northern Goshawk Habitat

Type of Goshawk Total Acres of Goshawk Total Maximum Acres of Total Maximum Acres Habitat Habitat Forest wide Physical + Treatments * of Herbicide Treatments * Occupied 23,600 4.48 4.04 Potential 96,377 325.07 323.72

*This figure includes the maximum, where physical + or herbicide methods may be employed There would be no direct effect to goshawk nest tree or plucking posts from any type of weed treatment activity in either occupied or potential habitat. Nor would there be any changes to the overstory in late-seral coniferous habitat. Physical + and herbicide treatments would not affect potential prey habitat in occupied goshawk habitat, either Forest-wide or in R05F09D53T07. Twelve of the 14 weed occurrences are in occupied goshawk habitat are 0.1 acre or less, except for the weed occurrences within R05F09D53T07, which are not a homogeneous. Prey still would have both native plants for food and cover. Although some prey species could utilize weeds for food and cover, no prey species totally depends upon weed species; native vegetation would provide at least the same degree, if not, far surpassing weeds as prey habitat. The removal of the weeds should provide improved habitat for small animals. The only weed occurrence that could cause problems to prey habitat in potential goshawk habitat is DH013ITI (dyer’s woad). Subsequent replanting of large bare areas would decrease the potential for reinfestation by weeds, and provide better cover for prey. Therefore, there would be no negative direct or indirect effects to goshawk habitat by the implementation of Alternatives 2 through 6. Cumulative Effects to Habitat: Because there are no direct or indirect effects to northern goshawk habitat, there are no cumulative effects to goshawk habitat under these Alternatives.

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Project-level Effects Analysis based on Populations for the Northern Goshawk

Summary of Population Status and Trend at the Forest Scale The Modoc NF Forest Plan (as amended by the SNFPA) requires bioregional-scale distribution population monitoring for northern goshawk. The sections below summarize population status and trend data for the goshawk. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Population Status and Trend at the Bioregional Scale and Local Scales for the Northern Goshawk. Northern goshawk has been monitored on many of the National Forests within California. There is concern that northern goshawk populations and reproduction may be declining in North America and California, due to changes in the amount and distribution in habitat quality (various authors in USDA 2001 Volume 3 Chapter 3. Page 113). The trend for the northern goshawk was analyzed by the USFWS in the 1990’s. According to the section on the California Region, there was currently not sufficient evidence of a wholesale decline that would warrant listing (USFWS 1998). The Modoc National Forest initiated goshawk full scale monitoring in 1975, using intensive stand searches and monitoring of historic nest stands. Current surveys are completed per the Regional northern goshawk protocol. At the time of the development of the Modoc National Forest Forest Plan, the Forest had 81 pairs and territories. The Modoc National Forest currently manages for 143 northern goshawk Protected Activity Centers across the Forest, primarily in pine or mixed conifer stands. The current number of territories exceeds those recognized Modoc Forest Plan. However, the distribution of northern goshawk is similar to the pattern found in during the time of the Modoc NF Forest Plan.

Effects of the Alternatives considered within the Noxious Weeds FEIS for the Northern Goshawk Goshawks could potentially be affected by the ingestion of contaminated prey and disturbance at nest sites. Within occupied habitat, there is little concern for consumption of contaminated prey, because of the small acreage to be treated Forest-wide. The largest concentration of work in occupied habitat would be 3.48 acres in PAC RO5F09D53T07, where both WM001ISTI and WM002ISTI (dyer’s woad) could be sprayed under Alternative 6. There is little potential risk from raptors eating contaminated mammals; none of the hazard quotients are above 1.0 (see Table 3-78 in the spotted owl section of this document). Plus, the weed sites are small enough to make it unlikely that 10% to 100% of the goshawk’s diet would contain contaminated prey. Given the small acreage to be treated and low risk associated with these herbicides to raptors, use of herbicides should not impact individual goshawks. Basically, the same is true for potential goshawk habitat. Although there are 325.28 acres of weed occurrences that fall within potential goshawk habitat, the vast majority consists of 321.82 acres in DH013ISTI (dyer’s woad). The habitat in this weed occurrence was burned under a series of fires, and has no known goshawk occupancy. The next-largest weed occurrence in potential habitat, DG024SAAE (Mediterranean sage), is scheduled for physical + treatments only. The remaining weed occurrences are 0.3 acres and less. Because the herbicides proposed for use have hazard quotients less than 1.0, there is little risk to goshawk by the use of herbicides on these

Chapter 3—Affected Environment & Environmental Consequences 331 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

small acreages. Therefore, the treatment of weed occurrences under any Alternative is not expected to affect northern goshawk. The greatest potential for impacts to all goshawks is from disturbance during the nesting season. Physical + and herbicide weed treatments could occur annually. Eleven of the 143 PACs could receive physical + or herbicide treatments. Limited Operating Periods are standard clauses for all contracts, because the potential for disturbance to cause abandonment of nests and young. It is vital that annual pre-treatment surveys be conducted, so active nest sites could be protected. Under the Alternatives with Early Detection/Rapid Response activities, wildlife biologists would review new noxious weed treatment sites prior to implementation. If concerns for northern goshawk surface (including conditions not covered within the analysis for the FEIS), additional Design Standards could be added. To summarize, there are inconsequential direct effects and no indirect effects expected to goshawk by the implementation of Alternatives 2-6. The weed occurrences are small and scattered throughout the Forest. There is a low risk associated with these herbicides to raptors. Pre-treatment surveys and LOPS will protect nesting birds. Therefore, there may be impacts to individuals, but there will be no trend toward listing, nor would there be any effect to goshawk population viability. Cumulative Effects to Populations: With respect to disturbance, there would be a light to moderate amount of activities from recreation, wood cutting, and mineral use within the potentially affected PACs on all the Districts. There are rock quarries adjacent to two PACs on the Big Valley District; the potential for disturbance to goshawks is low because of the quarry and the time of year when materials are accessed. Current timber sales include clauses to implement a limited operating period where birds are actively nesting. Grazing is light to moderate in many of the PAC’s, because of their stand densities (little forage available). There are some areas of more concentrated livestock use near Cary Reservoir and Buck Creek (the Del Pratt territory). However, given the persistence of the territories with regard to goshawk reproduction, grazing does not appear to have affected northern goshawk. Given the rather small acreage Forest wide that could be treated in addition to the use of surveys, and Limited operating periods, there are no expected cumulative effects from implementation of Alternatives 2 through 6 on northern goshawk.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Bioregional-Scale Population Trends for the Northern Goshawk The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for northern goshawk. Nor is there any potential effect to the goshawk population on the Forest. Therefore, implementation of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing bioregional-wide trend in population distribution of northern goshawk. Sage Grouse Management direction for sage grouse under the Modoc Forest Plan (1991) is as follows: Within designated sage grouse habitat, manage big sagebrush and low sagebrush within an eight-mile radius of all identified leks (strutting grounds) in accordance with the moderate habitat capability level for sage grouse. Manage meadows, seeps, springs, and riparian areas within a two-mile radius of leks according to the Riparian Area Management Prescription to provide forbs desirable for sage grouse, such as dandelion (Taraxacum), yarrow (Achilla), and aster (Aster). Habitat - Species Relationship: As the name implies, this species is heavily dependent on sagebrush habitats. Sage grouse utilize sagebrush stands as both winter and nesting habitat; leks

332 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

are often located in open areas surrounding sagebrush (Connelly et al. 2000). Nesting habitat also appears to contain tall grass cover (Gregg et al. 1994) and denser shrub cover of intermediate height (DeLong et al. 1995). Many studies have focused on the importance of herbaceous cover as a key influencing the fate of sage grouse nests (various authors in Sveum et al. 1998). Sveum et al. (1998) believed disturbances the following factors negatively impacted sage grouse nesting habitat: damage to shrubs, reduction in herbaceous cover, and invasion of exotic plants into native plant communities. Sage grouse nesting usually begins in April and may continue into late May or early June in northeastern California and northwestern Nevada (E. Flores, pers. comm.). Sage grouse diets consist of forbs, sagebrush, and insects (Klebenow and Gray 1968); they rely on sagebrush in the winter (Zeiner et al. 1990). Sage grouse chicks were dependent on insects, but moved to more forbs as they aged (Klebenow and Gray 1968).

Sage Grouse Habitat Status and Trend at the Forest Scale A habitat analysis of the condition of sage grouse habitat was completed for the Clear Lake/Devil’s Garden area for inclusion in the “Draft Conservation Strategy for Sage Grouse and Sagebrush Ecosystems Within the Devil’s Garden/Clear Lake Population Management Unit” (August 15, 2006). Based on this analysis, the habitat was categorized as follows: a) 27 % of the Active Management Area of the Population Management Unit (PMU) on National Forest land has the desired species composition to provide adequate cover and forage to meet the seasonal needs of sage grouse; b) 13.5 % has the potential to produce sagebrush plant communities that have good understory composition of desired grasses and forbs, but lack adequate sagebrush canopy cover; c) 11.6 % with potential to produce sagebrush communities, but which are in transition to juniper woodland; d) 44.4 % which have crossed the threshold from sagebrush plant communities into juniper woodland. As part of the Noxious Weeds FEIS analysis, sage grouse habitat was modeled utilizing a four- mile radius buffer from the radio telemetry from collared sage grouse. The analysis area for sage grouse is roughly 53,300 acres of various habitat types within 4 miles of these areas. Scott Gardner, California Department of Fish and Game Sage Grouse Coordinator and Environmental Scientist with the Upland Game Program, recommended this figure would provide a good estimation of potential habitat for this project. The four mile radius is also greater than the two- mile figure recommended in Connelly et al.(2000). Mr. Gardner’s recommendation and the Connelly et al. (2000) information constitute the most recent recommendations and were followed in lieu of the habitat management recommendation cited in the Modoc NF Forest Plan (1991) to model occupied sage grouse habitat. It is important to note that 21,080 acres of the analysis area are of water, Clear Lake. The following are the major vegetation types: low sagebrush, juniper, sagebrush, water, annual grassland, and barren ground. The distribution, quantity, and quality of sage grouse habitat on the Forest has been affected by factors similar to those across the range of the sage grouse. The encroachment of western juniper into the sagebrush steppe has been a major factor, as well as many large fires within the area where the sage grouse leks were concentrated. Other factors affecting sage grouse habitat include the invasion of exotic grasses including cheatgrass and medusa head. According to the Modoc Forest Plan, major reasons for sage grouse decline include overgrazing before the 1950’s, sagebrush control, conversion of habitat to agricultural uses, maturation and decadence of sagebrush communities, juniper encroachment, and indiscriminant hunting (USDA 1991b. Page 3-108). Over the past two years, efforts by a multi-agency Local Sage Grouse Working Group have resulted in a Draft “Conservation Strategy for Sage Grouse (Centrocercus urophasianus) within

Chapter 3—Affected Environment & Environmental Consequences 333 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

the Devil’s Garden/Clear Lake Population Management Unit”. This plan sets the stage for cooperative efforts to restore sage grouse habitat within this PMU. Sage grouse habitat restoration projects, involving juniper removal, are currently in progress (2006) adjacent to Clear Lake, both on the Modoc National Forest and on the Clear Lake National Wildlife Refuge. In addition, juniper removal on a larger scale is currently under environmental analysis through the Sagebrush Steppe Ecosystem Restoration Project Environmental Impact Statement. Pending the implementation of restoration efforts, habitat has declined for sage grouse on the Forest since the time of the Modoc Forest Plan.

Sage Grouse Project-level Effects Analysis Based on Habitat Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no affect on habitat for sage grouse. Sage grouse use shrubs, native forbs and grasses as food and cover, and are not directly tied to the noxious weeds. The main potential effect is limited to the potential consumption of herbicide contaminated plant and insect materials by grouse. Analysis Area for Project-level Effects Analysis: The analysis area for sage grouse is 21,080 acres and located near Clear Lake.

Alternative 1 (current management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect to sage grouse habitat. There would be no change in the current or future amount of sagebrush by the treatment of noxious weeds. The treatments are not in occupied habitat; therefore, there would be no inadvertent decrease of grasses or forbs utilized by these grouse. Zero % of the current sage grouse habitat in the analysis area would be affected by implementation of Alternative 1. Conversely, the effect of not treating the habitat could cause a significant decrease in the amount of potential food and cover for grouse. Sveum et al. (1998) documented exotic plants (cheatgrass and knapweed) negatively impacted sage grouse nesting habitat; they believed that restoring native sagebrush communities would provide better [sage grouse] habitat.

Cumulative Effects to Habitat Because there is no direct or indirect effect to sage grouse habitat, there are no cumulative effects to sage grouse habitat under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat There are no physical + treatments proposed within four miles of occupied sage grouse habitat (Table 3-87). However, there are three locations where Canada thistle may be treated using herbicides near areas where radio collared birds have been detected. Each of the treatment areas is 0.10 acre for a total of 0.3 acres of herbicide use within sage grouse habitat. Therefore, a maximum of 0.0009% of the modeled 32,220 acres of sage grouse habitat could be treated.

334 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 3 - 87. Proposed treatment Within Occupied and Potential Sage Grouse Habitat

Total Acres of Sage Total Maximum Acres Type of Sage Total Maximum Acres of Grouse Habitat Forest of Physical + Grouse Habitat Herbicide Treatments * wide Treatments * Occupied/Potential 32,220 0.0 0.3

*This figure includes the maximum, where physical + or herbicide methods may be employed Herbicides, when utilized to kill sagebrush as has been done in the past, can cause a reduction in the quantity and quality of sage grouse habitat by the decrease in the quantity of sagebrush in treatment blocks (various authors in Connelly et al. 2000). This activity is not proposed under the Noxious Weed Project FEIS. The removal of a maximum of 0.3 acres of weeds is anticipated to improve habitat quality for the grouse. Sveum et al. (1998) stated, “Increasing native perennial bunchgrasses and forbs would enhance both cover and food in sagebrush cover types” [for sage grouse]. There would be no removal of sagebrush or preferred grasses and forbs for cover and food. Sage grouse are not known to use noxious weeds as food; therefore, removal of weeds should not decrease the amount of food available to them. The removal of the weeds will not affect insects, since there are ample native plants to provide insect food and cover. Subsequent replanting of bare areas would decrease the potential for reinfestation by weeds and provide better cover (depending on the plant species chosen for revegetation treatments). An interesting side note is that two publications recommended the judicious use of several management tools including herbicides to improve sage grouse habitat (DeLong et al. 1995, Connelly et al. 2000). Therefore, there should be inconsequential beneficial direct or indirect effects to sage grouse habitat by the implementation of Alternatives 2 through 6, because there is only 0.3 acres of sage grouse habitat planned for treatment. Cumulative Effects to Habitat: Because there are no direct or indirect effects to sage grouse habitat, there are no cumulative effects to sage grouse habitat under these Alternatives.

Project-level Effects Analysis based on Sage Grouse Populations Summary of Population Status and Trend at the Forest Scale: The Modoc NF Forest Plan (as amended by the SNFPA) requires Forest-scale distribution population monitoring for sage grouse. The sections below summarize population status and trend data for the sage grouse. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Population Status and Trend at the Bioregional Scale and Local Scales for Sage Grouse Sage-grouse range in California includes portions of the Modoc Plateau and the Great Basin in parts of Modoc, Lassen, Mono and Inyo Counties (Grinnell and Miller 1944). Greater sage grouse in northeastern California are most abundant in eastern Lassen County (north of Honey Lake) and east of Eagle Lake, and in the Surprise Valley in northeastern Modoc County. These areas contain approximately two-thirds of all of California's sage-grouse populations (Hall 1995). Little published information is available on California sage grouse population trends. According to Connelly et al. (2004), the proportion of active leks in California has remained relatively stable between 1965 and 2003, with five-year averages varying from 77% to 90% between 1965 and 2003. Modoc County appears to be the exception.

Chapter 3—Affected Environment & Environmental Consequences 335 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

California Department of Fish and Game records indicate there were thousands of sage grouse in northwestern Modoc County in the 1920s. By the 1950s, there were dramatic declines on the Devil’s Garden Plateau, where local populations were down to 75 to 150 birds. In the vicinity of Clear Lake on the Doublehead District, there were 46 active leks in the late 1940s and only nine active leks as of 1977. In the remainder of western Modoc County today, areas occupied by sage grouse include one active lek on the ‘Likely Tables’ southeast of Alturas, and anecdotal reports of sage grouse near Big Valley (recent counts of historic leks in the Big Valley area have turned up negative for sage grouse presence). The largest numbers of sage grouse in Modoc County are in the Surprise Valley northeast of the Modoc NF. Sage grouse on the Devil’s Garden Plateau reached peak population levels in the 1930s, but experienced dramatic declines after the 1960s (CDFG unpublished data). Count data for the majority of leks on and near the Modoc National Forest were spotty until the 1990’s, when regular counts of the lek at Clear Lake began. The only known remaining active sage grouse lek on Modoc NF is near Clear Lake. Based on the lek counts between 1989 and 2004, the estimated population of sage grouse on the Devil’s Garden plateau dropped from a peak during that period of 160 birds in 1990 to 31 in 2004.

Effects of the Alternatives on Sage Grouse Populations The ingestion and consequent incorporation of some herbicides could harm sage grouse. Blus et al. 1989 (in Connelly et al. 2000) reported “die offs” of sage grouse that were exposed to methamidiphos and dimethoate. The Noxious Weed FEIS does not propose use of either of these herbicides, nor does it propose treatment of plant species other than noxious weeds. However, grouse could consume non-target forbs affected by overspray or contaminated insects. Under the scenario for a bird consuming contaminated vegetation, 2, 4-D, and Triclopyr have hazard quotient ratings above one (Table 3-88). 2, 4-D is of greatest concern, because the hazard quotient rating is above one for every application rate. Under the scenarios for 2, 4 –D at the lower levels, only 10% consumption of contaminated vegetation in the animals diet caused potential health effects. Owing to the dearth of studies conducted on wild bird species, there is ambiguity in the extent of the effects due to ingestion of 2, 4-D. Utilizing the mammal information as a proxy for birds from the SERA report on 2, 4-D, there could be a chance of some degenerative changes to various organs. Depending on the extent of effect, an individual animal certainly could be at greater risk of predation.

Table 3 - 88. Herbicides and their Application Rates for Chronic Exposures to Large Birds (goose sized) Consuming Contaminated Vegetation Where There is a no-Spray Buffer and a Boom- Application Method on Site

Exposure Assessment Rate Herbicide/Application Rate Hazard Quotient Rating mg/kg/day or mg/kg/event Central Lower Upper Central Lower Upper 2,4 - D a) 1.5 lbs/ac 2.69 0.896 25.3 3.0 0.9 25 b) 2.0 lbs/ac 3.58 1.19 33.7 4.0 1.2 34 Chlorsulfuron 1.0 oz/ac 0.212 0.0708 2.0 0.002 5 x 10-4 0.01 Clopyralid 0.25 lb/ac 0.815 0.217 10.0 0.05 0.01 0.7 Dicamba a) 1.0 lb/ac 1.16 0.388 11.0 0.09 0.03 0.8 b) 2.0 lbs/ac 2.33 0.776 21.9 0.2 0.06 1.6 Glyphosate 3.75 lbs/ac 16.6 5.53 156 20. 0.06 1.6 Triclopyr (Acid & BEE) 1.5 lbs/ac 5.92 1.52 75.2 0.6 0.2 8.0 NPE 0.216 0.0576 2.85 0.02 0.006 0.3

336 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Note: Data for boom-sprayer application is for comparison purposes only. The Forest does not propose using mechanical boom sprayers. For the small bird consuming contaminated insects scenario, 2, 4-D (alone or in a tank mix), Dicamba, and the surfactant NPE all exceed hazard quotient ratings of 1 (table below).

Table 3 - 89. Hazard Quotient Ratings for a Small Bird eating Contaminated Insects – Acute Toxicity (100% of diet)

Herbicide/Application Rate Exposure Assessment Rate mg/kg/day Hazard Quotient Rating Central Lower Upper Central Lower Upper 2,4 - D a) 1.5 lbs/ac 56.4 56.4 169.0 6.0 6.0 17.0 b) 2.0 lbs/ac 75.2 75.2 226.0 8.0 8.0 23.0 Chlorsulfuron 1.0 lb/ac 2.35 2.35 7.05 0.001 0.001 0.004 Clopyralid 0.25 lb/ac 9.4 9.4 28.2 0.01 0.01 0.04 Dicamba a) 1.0 lb/ac 37.6 37.6 113.0 3.0 3.0 8.0 b) 2.0 lbs/ac 75.2 75.2 226.0 6.0 6.0 17.0 Glyphosate 3.75 lbs/ac 141.0 141.0 423.0 0.3 0.3 0.8 Triclopyr (Acid & BEE) 1.5 0.3 (ACID) 56.4 56.4 169 0.1 0.1 lbs/ac 0.4 (BEE) NPE 62.6 50.0 263.0 6.0 5.0 26.0 Design Standard DS-12a (no 2, 4-D or Dicamba in occupied sage grouse habitat) limits the types of herbicides that may be used to those with Hazard Quotients less than 1.0 in occupied sage grouse habitat. Under Alternatives 2, 4 and 6, the weeds would be treated with Glyphosate or chlorsulfuron, which have a low risk of toxic effects to birds eating contaminated vegetation or insects under the lower to central levels, which would be the most realistic scenarios. As to the potential effects from NPE, research indicates that surfactants such as NPE can have assorted detrimental effects on various species. Relyea (2005) suggested that the mortality in amphibians associated with Roundup (a brand of Glyphosate) was associated with the POEA surfactant found in the formulation. NPE has been documented to induce reproductive abnormalities in rats, specifically causing oxidative stress in the sperm (Chitra, Latchoumycandane and Mathur 2002). Although the doses in their study were well below what is in the above chart (1, 10, and 100 micrograms of 98% NPE/kg of animal weight), the rats were dosed for 45 days. The scenario for a small bird consuming contaminated insects assumes that 100% of the diet consists of NPE-contaminated materials. Given the small patch sizes of the weed occurrences (0.1 acre each, or 0.0009% of the potential sage grouse habitat); it is unlikely there would be enough contaminated insects in the diet to sustain the doses that would cause a risk. Treatment of noxious weeds (whether it is physical + or herbicide) could cause potential disturbance to birds. Therefore, the District Biologist would be consulted before treatment occurs in any given year in order to conduct surveys that may be needed to protect nesting birds. Under the Alternatives with Early Detection/Rapid Response activities, new occurrences would be reviewed by wildlife biologists prior to implementation; if concerns for sage grouse surface, additional Design Standards could be added if weed treatment areas were outside of the conditions analyzed within the FEIS. To summarize, there are few direct effects and no indirect effects expected to sage grouse by the implementation of Alternatives 2 through 6. The three weed occurrences are small and constitute significantly less than 1% (0.0009%) of the habitat. Design Standards will be implemented to further protect the birds. Therefore, there may be impacts to individuals, but there will be no trend toward listing, nor would there be any effect to the sage grouse population on the Forest.

Chapter 3—Affected Environment & Environmental Consequences 337 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Cumulative Effects to Sage Grouse Populations: The following information on the other activities occurring in the area was provided by Jim Irvin, who was associated with the Devil’s Garden/Doublehead District and is familiar with the area where the weeds occur. Access is limited near the weed occurrences in sage grouse habitat, so there would be little activity as far as hunting and fishing are concerned. There is a moderate amount of grazing by domestic livestock and wild horses in the area. There is both juniper removal and controlled burning to restore sage grouse habitat being planned. There could be a potential disturbance to sage grouse, but this issue would be handled through the Annual Allotment Instructions or project implementation phase (for the juniper removal and the prescribed fire). Therefore, the removal of a maximum of 0.3 acre of Canada thistle is not anticipated to have significant direct, indirect or cumulative effects to grouse under Alternatives 2 through 6.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Sage Grouse The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for sage grouse. Nor is there any potential effect to the sage grouse population on the Forest. Therefore, implementation of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing Forest-wide trend in population distribution of sage grouse. Swainson’s Hawk The Swainson’s hawk is a terrestrial MIS, a Forest Service Sensitive, and a California State threatened species. Habitat - Species Relationship: Nesting habitat for Swainson's hawk includes open habitats in scattered trees or small groves (Zeiner et al. 1990). Suitable nesting habitat includes the presence of adequate prey, open grasslands and occasional trees that are suitable for nesting (Bloom 1980). Locally, Swainson’s hawk have nested in western juniper, ponderosa, elm and sagebrush (Woodbridge et al. 1995), especially along agricultural fields. Normally found in grassland / Forest interface, this species is not common on the Forest. Juniper encroachment may have contributed to a decline in the amount of potential Swainson's hawk nesting and foraging habitat (Bloom 1980). Swainson's hawk foraging habitats include grasslands, sagebrush, alfalfa fields and hay fields. In Woodbridge et al. (1995), the authors state that cultivated alfalfa appears to have become a critical habitat element replacing the native grasslands. Risebrough et al. (1989) noted that the replacement of native grasses with sagebrush forming less botanically diverse stands may be a reason for the decline near our area. Woodbridge (1987) found similar Swainson’s hawk use of open habitats; foraging activity in dense sage-steppe grasslands was not observed. Average home ranges in northeastern California were 69 to 2,884 hectares (170 to 7,126 acres) (Woodbridge 1998). Diets of Swainson's hawks differ markedly between the breeding and non-breeding periods. Over most of the species' range, breeding Swainson's hawks show a strong dependence on ground squirrels, voles, or other abundant small mammal prey. Montane vole are consumed in NE California (Woodbridge 1991) and California vole in central California (Estep 1989). Prey species for the Great Basin area include California vole (Microtus californicus), Belding's ground squirrel (Spermophilus beldingi), and other various open-habitat grassland species of birds and reptiles (Bloom 1980). Insects comprise a large proportion of total individuals, but a negligible proportion of prey biomass during the breeding season.

338 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Following the breeding season, this species shifts from small mammals to insect prey. In northeastern California, montane voles and Belding's ground squirrels contributed over 70% of prey items identified by Woodbridge (1991). After the young fledge and begin to attain independence, diets begin to shift to insect prey. In northeastern California, pellets regurgitated by both adult and fledgling Swainson's hawks in August consisted almost entirely of grasshopper (Dichroplus sp.) parts.

Swainson’s Hawk Habitat Status and Trend at the Forest Scale Due to its association with grassland and agricultural fields, Swainson’s hawk is not common on the Modoc National Forest. Most of the foraging habitat is privately owned (USDA 1991b. Page 3-107). The known historic concentration of nest sites on the Modoc is in the extreme northwestern portion of the Forest on the Doublehead Ranger District, where 12 nest sites have been documented. This area is dominated by grasses, including Idaho fescue, bluebunch wheatgrass, Sandberg bluegrass, and Thurber needlegrass. Juniper trees occurring in the area are widely scattered and serve as the nesting substrate. To approximate occupied habitat for Swainson’s hawks on the Forest, a 0.7 mile radius, which equates to the average home range size of a Swainson’s hawk territory in northeastern California (Woodbridge 1998), was analyzed around each nest site. Based on this model, approximately 8,300 acres of occupied habitat are estimated to occur on the Modoc National Forest. Vegetation types in occupied habitat include wet meadows, sagebrush, agricultural fields, bitterbrush, and annual grassland. An additional 230,882 acres of potential habitat for Swainson’s hawk nesting and foraging habitat are available based on a vegetation query for juniper woodland with 0 to 9 % canopy closure, sage, perennial grasslands, alfalfa, fallow fields, and dry land pasture. Historically, this species was probably much more abundant on the Forest than it is currently. Juniper encroachment, resulting from fire suppression, and heavy livestock grazing in late 1800s and early 1900s, rendered much of the Forest unsuitable for nesting habitat. Removal of small diameter junipers, while leaving the larger trees, would enhance nesting habitat for Swainson’s hawks (USDA 1991b. Page 3-107). Juniper removal is currently under environmental analysis through the Sagebrush Steppe Ecosystem Restoration Project Environmental Impact Statement. This planning effort is on a landscape scale and includes National Forest and Bureau of Land Management land in Northeastern California. The draft EIS was released in 2007. Because of an increase in herbaceous non-native plant species (including cheatgrasses) and juniper on the Forest, the current trend for the habitat is decreasing for Swainson’s hawk, since the time of the Modoc Forest Plan.

Project-level Effects Analysis Based on Swainson’s Hawk Habitat Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no effect on Swainson’s hawk habitat. The potential effects are limited to the consumption of herbicide-contaminated prey and disturbance. Analysis Area for Project-level Effects Analysis: The analysis area for Swainson’s hawk consists of the 8,300-acre nest cluster on the Doublehead District and the 230,882 acres of potential habitat found elsewhere on the Forest. This habitat is limited to the lower elevations of the Forest, mainly in open shrub and juniper stands. In general, these areas are found on the interface between the Forest and the agricultural lands, as well as portions of the Doublehead and Devil’s Garden Districts. The only known occupied habitat is in the extreme northwestern corner of the Forest on the Doublehead District.

Chapter 3—Affected Environment & Environmental Consequences 339 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Alternative 1 (Current Management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect to Swainson’s hawk habitat. There would be no change in the current or future amount of nesting or foraging habitat by the treatment of noxious weeds. Zero % of the current Swainson’s hawk habitat in the analysis area would be affected by implementation of Alternative 1. Leaving weeds untreated can have some serious effects to Swainson’s hawk. Habitats dominated by exotic plant species can reduce prey availability. In northeastern California, weedy ruderal fields (growing where natural vegetational cover has been disturbed or removed) and cheatgrass- dominated grazing lands supported low prey populations and received little use by foraging Swainson's hawks (Woodbridge 1991). Estep (1989) reported a similar pattern in the Central Valley of California. Invasion by Russian thistle, cheatgrass and tumble-mustard (Symbrissum sp.) also results in increased fire potential, further reducing cover of less fire-resistant native perennial grasses and shrubs. Cumulative Effects to Habitat Because there is no direct or indirect effect to Swainson’s hawk habitat, there are no cumulative effects to Swainson’s hawk habitat under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat There are no weed treatments planned within 15 miles of occupied habitat. There would be a maximum of 23.02 acres of physical + treatments and 22.76 acres of herbicide treatments in the 230,882 acres, or 0.01% of potential Swainson’s hawk habitat Forest-wide.

Table 3 - 90. Proposed Treatments within Occupied and Potential Swainson’s Hawk Habitat

Total Acres of Total Maximum Acres Type of Swainson’s Swainson’s Hawk Total Maximum Acres of of Physical + Hawk Habitat Habitat Herbicide Treatments Treatments Forest wide Occupied 8,300 0.0 0.0 Potential 230,882 23.06 22.76

*This figure includes the maximum, where physical + or herbicide methods may be employed No nest trees or foraging habitat would be removed under any action Alternative. Most of the weed occurrences have native plants within their matrix; therefore, there would be native plants left to provide food and cover for potential prey. Based on the information from the previous section, prey habitat should be improved by the removal of noxious weeds. Although there may be beneficial direct or indirect effects to Swainson’s hawk habitat under any action Alternative, the extent of this beneficial effect is inconsequential, given their in relation to occupied habitat; therefore, there are no direct or indirect effects to Swainson’s hawk habitat. Cumulative Effects to Swainson’s Hawk Habitat Because there are no direct or indirect effects to Swainson’s hawk habitat, there are no cumulative effects to Swainson’s hawk habitat under these Alternatives.

340 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Project-level Effects Analysis based on Swainson’s Hawk Population Summary of Population Status and Trend at the Forest Scale: The Modoc NF Forest Plan (as amended by the SNFPA) requires Forest-scale distribution population and relative abundance monitoring for Swainson’s hawk. The sections below summarize population status and trend data for the Swainson’s hawk. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Swainson’s Hawk Population Status and Trend at the Bioregional Scale and Local Scale The Swainson’s hawk is currently identified as “Imperiled” in California (NatureServe 2006). Imperiled is defined as a result of rarity due to very restricted range, very few populations (often 20 or fewer), steep declines, or other factors making it very vulnerable to extirpation from the nation or state/province. The Swainson’s hawk has been detected on 19 BBS routes in California. Bloom (1980) reviewed historical records and egg collections to estimate the historical distribution of Swainson's hawks in California, and found that the current range of this species has been reduced dramatically from what it was historically. Currently, Swainson's hawks are absent from much of their historic breeding range in the central and southern portions of California, and overall may have declined by as much as 90% (Bloom 1980). In the ButteValley in northern California, the population has been stable at 65 to 80 pairs since the mid-1980s; however, reproductive success has declined post-1992 (Woodbridge unpub.). During the same time period, the adjacent Klamath Basin population declined by approximately 90%; from 40 pairs to <5 pairs (Risebrough et al. 1989). Large numbers of Swainson's hawks still occupy the Central Valley (estimated 420 to 1,000 pairs), but annual losses of territories to residential development and riparian habitat removal, and agricultural intensification are reported (CDFG 1988, Estep 1989). Conversely, Bloom (unpub.) reports apparent recolonization of historic habitats in Los Angeles County (Antelope Valley), and population increases in Owens valley, suggesting that the species' populations can respond to improved habitat conditions. Likewise, modest increases in small populations in Lassen County and the east side of the Sierra Nevada are likely linked to expansion of alfalfa cultivation (Bloom unpub.). The Modoc National Forest and various partners (e.g., Pete Bloom, a raptor expert) collect surveys and incidental sightings data on and adjacent to the Forest. Recent surveys have been conducted in 2001 to 2006 near the agricultural-Forest interface near Big Valley/Devil’s Garden Districts. No nesting birds have been detected on the Forest during these recent surveys. During the planning phase for the Modoc NF Forest Plan, there were 11 known nest sites on or immediately adjacent to the Modoc NF (UDSA 1991b. Page 3-107). To date, there are 15 occurrences and 12 nest sites located on the Forest in the extreme northwestern portion of the Doublehead Ranger District. The current Swainson’s hawk distribution and relative abundance are basically the same as described in the Modoc Forest Plan.

Effects of the Alternatives on Swainson’s Hawk The historic Swainson’s hawk nests are in the extreme northwest corner of the Forest. There are no weed occurrences planned for treatment within 15 miles of any historic Swainson’s hawk nest. Therefore, there is no disturbance to these species expected with implementation of the project. Limited Operating Periods on newly found active nests would further mitigate potential effects.

Chapter 3—Affected Environment & Environmental Consequences 341 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

There would be no potential for consumption of contaminated prey under Alternatives 3 and 5 and the physical + treatments under 2, 4 and 6. A maximum of 22.76 acres, or 0.01% modeled potential habitat could receive herbicide treatments under Alternatives 2, 4 and 6. None of those occurrences is near occupied habitat. The weed occurrences of greatest concern would be BV284ONAC (Scotch thistle), WM008LIDA, and WM010LIDA (Dalmatian toadflax), and DG019SAAE (Mediterranean sage). BV284ONAC (Scotch thistle) – The lower portion of the weed occurrence near the private land provides the best potential Swainson’s hawk habitat. There are patches of Scotch thistle all the way down the creek to the private land. Very little of the 12.66 acres of this weed occurrence located in potential Swainson’s hawk habitat would receive herbicides, because most thistle patches are small clumps of plants. The largest patch was roughly .1 acre. Some of the Scotch thistle stands were dense; however, there are native and non-native plants outside of these clumps, and often within them as well. Under Alternatives 2, 4 and 6, this weed occurrence may be treated with physical + or herbicide means (which includes goat grazing under Alternative 6). Because the condition of the weed occurrence, only a small acreage within the entire 12.66 acres would be treated, making it unlikely that a Swainson’s hawk would consume 100% of its diet in contaminated prey. Therefore, there are no anticipated effects by the treatment of this weed occurrence under Alternatives 2, 4, or 6 to Swainson’s hawk. There are 5.76 acres of two weed occurrences (WM008LIDA and WM010LIDA [Dalmatian toadflax]) near New Pine Creek on steep, timbered slopes that would probably not be used by nesting or foraging pairs. Throughout the Forest and the state, Swainson’s hawk foraging habitat is largely confined to the agricultural lands surrounding their nests. It is highly unlikely the birds would ingest a significant portion of their diet in contaminated mammals or insects from these two sites. Under Alternatives 2, 4, and 6, these occurrences are scheduled for Glyphosate. Glyphosate does not have a hazard quotient above 1.0 for either the consumption of contaminated mammals or contaminated insects scenarios. Therefore, treatment of these two occurrences is not expected to affect Swainson’s hawk for Alternatives 2, 4 and 6. There are 2.81 acres of DG019SAAE (Mediterranean sage) within potential Swainson’s hawk habitat. This occurrence would only be treated by physical + means under Alternatives 2 and 4. It could be treated by either physical + or herbicide methods under Alternative 6. It would not be treated with 2, 4-D under Alternative 6 because of Design Standard 12b, which limits the size of the weed sites that can be treated with 2, 4-D to less than 2 acres. Treatment of this weed occurrence under Alternative 6 is not expected to affect Swainson’s hawk, because the herbicides planned for use have lower hazard quotients, the area is considered potential habitat with no history of occupancy, and because of the small size of this occurrence. The rest of the 1.84 acres of weed occurrences in potential Swainson’s hawk habitat are less than one acre and scattered throughout the Forest. It is extremely unlikely that Swainson’s hawk would consume 100% of their diet in contaminated prey, where potential effects from herbicides would manifest themselves (i.e. cause harm to the bird). Under the Alternatives with Early Detection/Rapid Response activities, new occurrences would be reviewed by wildlife biologists prior to implementation; if concerns for Swainson’s hawk surface, additional Design Standards could be added if weed treatment areas are outside of the conditions analyzed within the FEIS. Based on the information presented above, there inconsequential direct and no indirect effects to Swainson’s hawk by the implementation of any action Alternative.

342 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Cumulative Effects to Populations The four weed occurrences mentioned above have little activity that would contribute to cumulative effects. WM008LIDA and WM010LIDA (Dalmatian toadflax) are on the edge of the Warner Mountain District in an area that does not have grazing, timber harvest, mining or recreation that occurs farther up the canyon (J. Irvin and M. Flores, pers. comm.). DG019SAAE (Mediterranean sage) is located by a quarry. No Forest Service activities occur in the area (J. Irvin, pers. comm.). BV284ONAC (Scotch thistle) is a gated area that is no longer used as a primary timber haul route. The area receives grazing, but otherwise there is only a small amount of hunting outside of the reproductive period. (B. Landoski, pers. comm.) Therefore, implementation of Alternatives 2-6 would have no cumulative effects to Swainson’s hawk individuals or populations.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Swainson’s hawk The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for Swainson’s hawk. Nor is there any potential effect to the Swainson’s hawk population on the Forest. Therefore, implementation of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing Forest-wide trend in population distribution of Swainson’s hawk. Willow Flycatcher The flycatcher is a terrestrial MIS, a Forest Service Sensitive, and a California State Endangered species. The Modoc National Forest Land and Resource Management Plan (Forest Plan) (USDA 1991a) states that application of the Riparian Area Management Prescription will maintain viable populations for this species (page 4-26). During the development of the Forest Plan, willow flycatchers were selected as an MIS, because they needed not only the presence of willows, but also a specific type of structure within riparian areas (USDA 1991b page 3-103). Currently, willow flycatchers are managed through a combination of surveys, livestock management, and protection of riparian ecosystems and meadows (USDA 2004 Record of Decision (ROD), page 11, 56-58.). Habitat - Species Relationship: The willow flycatcher is a summer resident of the Sierra Nevada and Cascade Ranges in elevations from 2,000 to 8,000 feet. They are most often associated with broad, open river valleys or large (> 20 acres) mountain meadows. However, they have been documented to use meadows that were an average of 10 acres (Harris et al. 1987) and as small as 0.62 acres (Scully 1995, Kings River Conservation District 1985). On the Modoc National Forest, they have also been detected in narrow riparian canyons (T. Ratcliff, pers. comm.). Dense willow thickets are necessary for cover, nesting, and roosting (Scully 1995, Sedgwick and Knopf 1992, Fowler et al. 1991). Willow stands interspersed with openings are preferred habitat (Sedgwick and Knopf 1992, Fowler et al. 1991); large patches of contiguous willow do not appear to be suitable (Sanders and Flett 1989). The presence of water appears to be an important component for suitable habitat (Bombay et al. 2001, Scully 1995). Drier conditions may have reduced or eliminated potential breeding sites for insects in the Sierra Nevada (Bombay et al. 2000). Insects are a primary staple for this species (Zeiner et al. 1990). Willow Flycatcher Habitat Status and Trend at the Forest Scale: Willow flycatcher habitat was modeled using the polygons delineated during the planning phase for the Sierra Nevada

Chapter 3—Affected Environment & Environmental Consequences 343 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Forest Plan Amendment, with an additional fifty-meter buffer. The fifty-meter value approximates a willow flycatcher territory (T. Benson, pers. comm.), so the buffer provided a conservative estimate of willow flycatcher habitat on the Forest. Based on this GIS query for willow flycatcher, there are 2,450 acres of occupied/potential/emphasis willow flycatcher habitat on the Forest. The following habitat types were included: wet meadow, sagebrush, juniper, and aspen. The sagebrush and juniper types are an artifact of the query. The authors of the wildlife sections of the Forest Plan and its supporting Final Environmental Impact Statement (FEIS) noted that livestock grazing and use of willows by beavers were two threats to willow habitat and subsequently the presence of willow flycatchers (USDA 1991b page 3-103). At the time of the FEIS, willow planting occurred on all of the Districts. Willow form and distribution appears to be stable to increasing on the Warner Mountain and Devil’s Garden Districts in the occupied and emphasis willow flycatcher habitat, since the time of the Modoc Forest Plan.

Willow Flycatcher Project-level Effects Analysis based on Habitat Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no effect on habitat for willow flycatcher; willow flycatchers are not tied to the noxious weeds for cover or food. The main potential effect is limited to the ingestion of contaminated insects. Analysis Area for Project-level Effects Analysis: The analysis area for willow flycatcher is 2,450 acres, which includes the occupied, potential and emphasis habitat used during the Sierra Nevada Forest Plan Amendment Project (USDA 2001). This habitat is found mainly on the Warner Mountain District, but occurs in scattered localized patches on the Forest.

Alternative 1 (Current Management)

Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect on willow flycatcher habitat. There will be no change in the current or future amount of willow habitat by the treatment of noxious weeds. Zero % of the current willow flycatcher habitat in the analysis area would be affected by implementation of Alternative 1.

Cumulative Effects to Habitat Because there is no direct or indirect effect to willow flycatcher habitat, there are no cumulative effects to willow flycatcher habitat under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat: There would be no treatment within any habitat with previous sightings, although three areas within potential habitat may be treated Forest-wide. A maximum of 0.3 acres or 0.012% of the 2,450 acres of potential willow flycatcher habitat Forest- wide could receive physical + or herbicide treatments. (table below)

344 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 3 - 91. Proposed treatment within Occupied and Potential Willow Flycatcher Habitat

Total Acres Willow Total Maximum Acres Type of Willow Total Maximum Acres of Flycatcher Habitat of Physical + Flycatcher Habitat Herbicide Treatments Forest wide Treatments Occupied 0.0 0.0 0.0 Potential/Emphasis 2,450 0.3 0.3

*This figure includes the maximum, where physical + or herbicide methods may be employed These birds nest in shrubs; no nesting habitat would be removed under any action Alternative. Willow flycatchers are primarily an aerial forager, including both hawking and hover-gleaning (various authors in Sedgwick, J. A. 2000). Prey habitat would not be affected, because there are currently no native insects that are reliant on weeds for food or cover. Moreover, sufficient native plants exist outside of the boundaries of the current weed occurrences. Therefore, there should be no negative direct or indirect effects to willow flycatcher habitat by the implementation of Alternatives 2 through 6. Cumulative Effects to Habitat: Because there are no direct or indirect effects to willow flycatcher habitat, there are no cumulative effects to willow flycatcher habitat under these Alternatives.

Project-level Effects Analysis to Willow Flycatcher Populations Summary of Population Status and Trend at the Forest Scale: The Modoc NF Forest Plan (as amended by the SNFPA) requires monitoring of the bioregional status and change in distribution for willow flycatcher. The sections below summarize population status and trend data for the willow flycatcher. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Willow Flycatcher Population Status and Trend at the Bioregional Scale and Local Scales Historically, willow flycatchers nested throughout California wherever thickets of riparian deciduous shrubs occurred (primarily Salix spp.). In the last four decades, however, willow flycatcher breeding populations have been extirpated from most of the lower-elevation riparian areas in California, and it appears that the species may no longer breed at elevations below 3,000 feet in the Sierra Nevada, in the Central Valley, and in the valleys of the Central Coast. Historic records combined with recent survey efforts indicate a long-term decline of willow flycatchers at elevations above 3,000 feet in the Sierra Nevada as well. Statewide willow flycatcher BBS data between 1966 to 2005 had a huge positive trend. The regional rating is red for meaning there is data with an important deficiency, and therefore caution needs to be used in utilizing the data. According to the California Partners in Flight Conservation Plan, there are insufficient data to determine trends in California of any subspecies of willow flycatchers. The current range of the Sierra Nevada subspecies of willow flycatchers (Empidonax traillii adastus and E. t. brewsteri) consists of isolated sites at relatively high elevations, between approximately 1,200 and 2,500 m (4,000 and 8,000 ft). Current estimates of the willow flycatcher population in the Sierra Nevada bioregion range between 300 to 400 individuals; the effective population size (number of breeding adults) is likely to be smaller. Records compiled from National Forests, researchers, scientific literature, and museum collections document 135 known locations within the bioregion. In most sites, only one willow flycatcher territory is recorded, but other sites have 3, 5, or as many as 32 willow flycatcher territories.

Chapter 3—Affected Environment & Environmental Consequences 345 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Population trends within the Sierra Nevada Demographic study sites indicate that the willow flycatcher population has experienced a significant decline since 1997. Although in 2002-2004, the number of territories detected has remained stable (range = 37 to 39), nesting success has remained lower than other values reported for passerines. The willow flycatcher data for the Modoc NF has been collected during both province-wide and project-specific willow flycatcher surveys, as well as from incidental sightings made by private citizens. This species has nested infrequently on the Modoc National Wildlife Refuge as well. Willow flycatchers have not been detected during any BBS surveys locally. Although occasional sightings have been found over time in six locations throughout the Modoc National Forest, there is no stable population of this species on the Forest. The current distribution of willow flycatcher is similar to the pattern described in the Modoc Forest Plan.

Effects of the Alternatives on Willow Flycatchers Direct and Indirect Effects Under Alternatives 3 and 5, as well as the physical + portions of 2, 4 and 6, there would be no potential for willow flycatchers to consume contaminated vegetation. The ingestion of contaminated insects is not expected to affect willow flycatchers for the following reasons for the herbicide portions of Alternatives 2, 4, and 6. First, none of the weed occurrences have had occupancy. Second, the areas where treatment could occur do not have a high potential for bird use. The two dyer’s woad sites (DH005ISTI and DH007ISTI) are in the road prism and would not affect potential foraging habitat. The birds, if present, would be in the willow thickets along the creek (P. Buettner, pers. comm.). The 0.07-acre weed occurrence on Lassen Creek is outside of the willow thicket in a draw off the main channel; therefore, it has little potential for foraging willow flycatchers. Third, it is very unlikely that a bird could consume 100% of its diet on these sites because they are all 0.13 acres or less. Finally, none of the sites would be treated with 2, 4-D (the herbicide of greatest concern) under Alternatives 2 and 4, because they all lie within 1,000 feet of water. Under Alternative 6, any of the herbicides could be used. However, given the small size of the weed occurrences and their locations outside of foraging habitat, it is unlikely that there would be an effect to willow flycatcher, even under Alternative 6. Therefore, there may be an impact to individuals, but no trend toward listing for implementation of the actions in the Noxious Weeds FEIS under Alternatives 2, 4, and 6. Under the Alternatives with Early Detection/Rapid Response activities, new occurrences would be reviewed by wildlife biologists prior to implementation; all weed treatment sites would need to meet water quality standards, and therefore will be limited in acre size as per the BMPs and Design Standards. Consequently, there are inconsequential direct and no indirect effects to willow flycatchers by the implementation of any action Alternative. Cumulative Effects A limited amount of hunting and fishing occur near the Lassen Creek weed occurrence. Fishing is regulated along Lassen Creek, due to the presence of red-band trout. The majority of the hunting would be in the fall for deer. The area is grazed under a rotation system developed to protect red-band trout in order to avoid listing of the species. Given light use in the area and no other herbicide use adjacent to the 0.07 acre of potential treatment, there would be no expected additional cumulative effects to willow flycatchers by implementation of any Alternative at the Lassen Creek site. Jim Irvin provided information on activities for the Doublehead sites. Grazing and recreation are the primary activities. The creek is within an enclosure, where grazing was excluded for a number of years. The area is now lightly grazed, but controlled to ensure riparian habitat improvement.

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There is a light amount of fishing, because this seasonally flowing creek becomes more of a series of pools once the spring flush has occurred. There are inconsequential direct, no indirect, and no cumulative effects expected with treatment at the Doublehead sites under Alternatives 2 - 6.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Bioregional-Scale Population Trends for the Willow Flycatcher The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for willow flycatcher. Nor is there any potential effect to the willow flycatcher population on the Forest. Therefore, implementation of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing bioregional-wide trend population distribution of flycatcher.

Summary of Sensitive Species Determinations In order to clarify, the determinations were put into tabular form. The May Impact cell means, “May impact individuals, but not likely to cause a trend to federal listing or a loss of viability.”

Table 3 - 92. Summary of Sensitive-Species Determination

Species Alt 1* Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 American Marten No Impact May Impact** No Impact May Impact** No Impact May Impact** California Spotted Owl No Impact May Impact** No Impact May Impact** No Impact May Impact** California Wolverine No Impact No Impact No Impact No Impact No Impact No Impact Greater Sandhill Crane No Impact May Impact No Impact May Impact No Impact May Impact Great Gray Owl No Impact No Impact No Impact No Impact No Impact No Impact Northern Goshawk No Impact May Impact** No Impact May Impact** No Impact May Impact** Pallid Bat No Impact May Impact May Impact May Impact No Impact May Impact** Sage Grouse No Impact May Impact** No Impact May Impact** No Impact May Impact** Sierra Nevada Red Fox No Impact No Impact No Impact No Impact No Impact No Impact Swainson's Hawk No Impact May Impact** No Impact May Impact** No Impact May Impact** Townsend's Big-eared Bat No Impact May Impact May Impact May Impact No Impact May Impact** Willow Flycatcher No Impact May Impact** No Impact May Impact** No Impact May Impact**

* There would be no impact in the short term, but significant increases in weeds could affect most species ** Minor potential effects to species – only 1 pair, only potential habitat or only small acreages affected

Modoc NF Management Indicator Species Blue Grouse (now known as Sooty Grouse) The sooty/blue grouse is a terrestrial MIS, as well as a game species in California. Habitat - Species Relationship: Sooty/blue grouse have a patchy distribution throughout the Forest in various coniferous habitats. Information on sooty/blue grouse distribution is based mostly on incidental sightings; however, the California Department of Fish and Game has conducted bag checks, hoot count transects, and habitat surveys sporadically since the 1950s. Sooty/blue grouse use open to mature stands of conifer types that are interspersed with openings and water (Zeiner et al. 1990a). Sooty/blue grouse use dense conifer cover for roosting. They nest on the ground in an area that has cover either next to a log or in brushy areas. They will brood their young in grass and forb stands. Locally on the Modoc National Forest, they are also frequently found in conjunction with aspen stands.

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Sooty/blue grouse consume mostly plant materials (conifer needles; buds, fruits, flowers, and seeds of various plants), but will also eat insects, snails, and spiders (Zeiner et al. 1990a). They pluck conifer needles from trees; however, they will also eat forbs and glean insects from vegetation and the ground. In Montana, the average summer home range size was 126 acres, and the average territory size was seven acres.

Project-level Effects Analysis Based on Habitat Key Habitat Factor(s) for the Analysis The proposed project, the removal of noxious weeds from Forest System Lands, will have no effect on habitat for sooty/blue grouse; sooty/blue grouse are not directly tied to the noxious weeds for cover or food. The main potential effect is limited to the potential consumption of herbicide contaminated plant and insect materials by grouse. Analysis Area for Project-level Effects Analysis The analysis area for sooty/blue grouse is limited to the 161,000 acres of potential habitat on the Forest. This habitat is limited to the upper elevations of the Forest that have mixed conifer, white fir, and red fir. In general, the areas include the Warner Mountain Ranger District, the Medicine Lake Highlands, roughly half of the Big Valley District, and localized portions of the Devil’s Garden District.

Alternative 1 (Current Management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect on sooty/blue grouse habitat. There would be no change in the current or future amount of dead and downed materials by the treatment of noxious weeds. Vegetation diversity is expected to remain the same or very site specifically, be improved on the 30 acres; the same is true for aspen and meadow habitat. Zero % of the current sooty/blue grouse habitat in the analysis area would be affected by implementation of Alternative 1. Conversely, the effect of not treating the habitat could cause a significant decrease in the amount of potential food sources for grouse.

Cumulative Effects to Habitat Because there is no direct or indirect effect to sooty/blue grouse habitat, there are no cumulative effects to sooty/blue grouse habitat under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat The Forest Service could spray a maximum of 39.25 acres or 0.024% of potential sooty/blue grouse habitat each year under this Alternative. Physical + treatments could occur on a maximum of 35.55 acres each year, which equals 0.025% of the total Forest-wide potential sooty/blue grouse habitat. There are a total of 161,000 acres of potential sooty/blue grouse habitat Forest- wide. (Table 3 - 73)

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Table 3 - 93. Proposed Treatment within Potential Sooty/Blue Grouse Habitat

Total Acres of Potential Total Maximum Acres of Total Maximum Acres of Habitat - Forest wide Physical + Treatments* Herbicide Treatments* 161,000 39.55 39.25

* This figure includes the maximum, where physical + or herbicide methods may be employed. Implementing weed treatments under Alternatives 2 through 6 would have no effect on sooty/blue grouse habitat. There would be no change in the current or future amount of dead and downed materials or vegetative diversity by the treatment of noxious weeds. Although the condition of aspen stands and meadows could be enhanced by decreasing the competition to native species from weeds, currently there would not be a discernable benefit to sooty/blue grouse habitat on a Forest-wide scale, because the proposed treatments blocks are small and scattered. Therefore, there are no direct or indirect effects to sooty/blue grouse habitat by the implementation of Alternatives 2-6. Cumulative Effects to Habitat Because there are no direct or indirect effects to sooty/blue grouse habitat, there are no cumulative effects to sooty/blue grouse habitat under these Alternatives.

Summary of Population Status and Trend at the Forest Scale The Modoc NF Forest Plan (as amended by the SNFPA) requires Forest-scale distribution population monitoring for sooty/blue grouse. The sections below summarize population status and trend data for the sooty/blue grouse. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Population Status and Trend at the Bioregional Scale and Local Scales Population monitoring data collected by the Modoc NF and partners at the bioregional scale indicate that sooty/blue grouse have an “increasing tendency” for the Sierra Nevada (Siegel and DeSante 1999). The distribution for sooty/blue grouse appears to be the same on the Forest as the one in 1991, when the Forest Plan was released.

Effects of the Alternatives Considered Within the Noxious Weeds FEIS. Physical + treatments under any Alternative would cause no risk of ingestion of contaminated vegetation. Sooty/blue grouse could ingest both contaminated plants and animals under Alternatives 2, 4 and 6. It is unlikely that the sooty/blue grouse would ingest sufficient herbicides to reach the acute toxicities scenario listed in Table 3 - 74 for any Alternative for the following reasons. First, the scenarios were developed for a boom application; the action Alternatives would spot treat noxious weeds (not use booms). Although there may be some overspray, the entire area would not receive a complete blanket of herbicide. Second, very little of the potential grouse habitat would be treated, and most of those weed occurrences are small blocks. Within the 161,000 acres of potential sooty/blue grouse habitat, there could be a total of 39.55 acres or 0.025% Forest-wide habitat affected by herbicides. Third, the majority of the weed occurrences within potential sooty/blue grouse habitat are less than one acre parcels (the majority are 0.1 acre) except for the following: [dyer’s woad] WM001ISTI (5.9 acres), WM002ISTI (5.78 acres),

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WM003ISTI (1.82 acres), WM004ISTI (6.51 acres), WM005ISTI (5.26 acres), WM008ISTI (2.02 acres) as well as WM009CIAR4 [Canada thistle] (5.84 acres). For the acute scenario, there appears to be no effect to the sooty/blue grouse population on the Forest for the following reasons. Treating the largest occurrence (5.9 acres) in potential sooty/blue grouse habitat would cover 4.68% of the total 126-acre home range. The assumption is that 100% of the birds’ diet would consist of contaminated vegetation or insect materials. The likelihood of a grouse ingesting 100% of its diet on these small areas is remote. In addition, dyer’s woad is found in many areas in the County and on the Forest; these six occurrences are not high priorities for treatment with herbicide. The WM009CIAR4 (Canada thistle) is scheduled to receive Clopyralid, which has hazard quotient ratings below 1.0, and therefore, is not considered a risk (Tables 3 - 93 and 3 - 88). In addition, all of these weed occurrences are localized in the northern Warner Mountain District, so the remaining sooty/blue grouse Forest-wide would be unaffected.

Table 3 - 94. Hazard Quotient Ratings for Acute Toxicity, Small Bird Eating Contaminated Insects (100% of diet)

Exposure Assessment Rate Herbicide/Application Rate Hazard Quotient Rating mg/kg/day Central Lower Upper Central Lower Upper 2, 4-D a) 1.5 lbs/ac 56.4 56.4 169.0 6.0 6.0 17.0 b) 2.0 lbs/ac 75.2 75.2 226.0 8.0 8.0 23.0 Chlorsulfuron 1.0 lb/ac 2.35 2.35 7.05 0.001 0.001 0.004 Clopyralid 0.25 lb/ac 9.4 9.4 28.2 0.01 0.01 0.04 Dicamba a) 1.0 lb/ac 37.6 37.6 113.0 3.0 3.0 8.0 b) 2.0 lbs/ac 75.2 75.2 226.0 6.0 6.0 17.0 Glyphosate 3.75 lbs/ac 141.0 141.0 423.0 0.3 0.3 0.8 0..3 Triclopyr (Acid & BEE) 56.4 56.4 169 0.1 0.1 (ACID) 1.5 lbs/ac 0.4 (BEE) NPE 62.6 50.0 263.0 6.0 5.0 26.0 The chronic scenario for ingestion of vegetation has a greater probability of reality. Under the lower and central scenario, the assumption is that the birds’ diet is 10% and 30% contaminated vegetation, which is realistic at the sites that are greater than five acres or in the same general location (the cluster of sites T47N, R15E, in occupied grouse habitat). At the lower or central rate of applications, the only herbicide with a hazard quotient rating above 1.0 for the chronic ingestion of contaminated vegetation (on site) is 2, 4-D (either alone or in a tank mix) (Table 3 - 88). Under Alternatives 2 and 4, there is no concern for the use of 2, 4-D because all of these weed occurrences are within 1,000 feet of water; therefore, 2, 4-D will not be used to treat them. Under Alternative 6, Design Standard DS-12b lessens the potential effect by limiting the size of a weed occurrence that could receive 2, 4-D to 2 acres and less. There is only one 1.82-acre dyer’s woad polygon that is in potential sooty/blue grouse habitat, which could receive 2, 4-D. This area would constitute 1.4% of a 126-acre territory making it unlikely that grouse could consume sufficient amounts of 2, 4-D to cause adverse effects. Given the implementation of Design Standards to minimize the potential risk to grouse and the use of spot treatments of noxious weeds (as opposed to boom sprayers), the use of herbicides will have little chronic effect to single grouse and will have no effect on the distribution of blue/sooty grouse on the Modoc National Forest.

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Under the Alternatives with Early Detection/Rapid Response activities, wildlife biologists would review new noxious weed treatment sites prior to implementation. If concerns for sooty/blue grouse surface (including conditions not covered within the analysis for the FEIS), additional Design Standards could be added. The sooty/blue grouse is well distributed across the Modoc NF. Because only a few individual birds could be affected in localized in the northern Warner Mountain District, implementation of Alternatives 2 through 6 would have no impact on the distribution of sooty/blue grouse. Nor would there be any direct or indirect effects to the whole population of sooty/blue grouse. Cumulative Effects to Populations: Since there are no direct or indirect effects to the sooty/blue grouse population, there would be no cumulative effects.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Sooty/blue grouse The cumulative effects of Alternatives 2 through 6 of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for sooty/blue grouse. The potential effect to the population is that no one potential home range would be affected by herbicides, although small portions of three potential home ranges could be. Therefore, the impact of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing Forest-wide population distribution trend for sooty/blue grouse. Canada Goose and Mallard The Canada goose and mallard are terrestrial MIS as well as a game species in California. Habitat - Species Relationship: Canada geese have a patchy distribution throughout the Forest, focused near lakes and streams; they use the Modoc NF for nesting and brood-rearing activities. Nest sites include scrapes in dense herbaceous vegetation, cliffs, platform nests in trees, hollows in trees, and on nesting islands (various authors in Bellrose 1980, Frost 1988). Although Canada geese will use a variety of nest substrates, there are three characteristics of nests sites that are fairly consistent: a close proximity to water, cover for the nest, and an uninterrupted view for the incubating bird (Bellrose 1980). About 90% of the nest sites were located within 50 yards of water (Bellrose 1980). Both adult and young Canada geese are primarily grazers (Cadieux, Gauthier, and Hughes 2004, Sedinger 1986). Canada geese feed on agricultural crops and wild grasses and forbs (Zeiner et al. 1990a). Mallards have the same patchy distribution throughout the Forest as Canada geese; according to Bellrose (1980), the results of most studies show that the majority of mallard nests are within 100 yards of water. Mallards also use the Modoc NF for nesting and brood rearing. Typical nesting habitat for mallards consists of scrapes in upland herbaceous vegetation in proximity to water (Drilling, Titman and McKinney 2002). Both seasonal and permanent water bodies are utilized (Drilling, Titman and McKinney 2002). Cover surrounding the nests in herbaceous vegetation is usually dense and about 24 inches in height (Bellrose 1980). Brood habitat for mallards includes riparian areas, with a mixture of open water with emergent vegetative cover. Mallards are mainly herbivorous utilizing domestic grains, forb seeds, and aquatic plants; they will however, also consume insects, invertebrates, tadpoles and small fish (Zeiner et al. 1990). Hatchlings basically feed on insects, but shift to seeds by six weeks (Chura 1961 in Zeiner et al. 1990a). Territory sizes varied from 163 acres to 1,797 acres (Zeiner et al. 1990a).

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Project-level Effects Analysis based on Canada Goose and Mallard Habitat Key Habitat Factor(s) for the Analysis The proposed project, the removal of noxious weeds from Forest System Lands, will have no effect on habitat for Canada geese or mallards; neither species is directly tied to the noxious weeds for cover or food. Tall whitetop has been shown to out-compete grasses, thereby decreasing waterfowl food resources (Bossard, Randal, and Hoshovsky 2000). Weeds provide less cover and may lead to greater predation. Mallard nests that are in poor cover, routinely fail on the Modoc National Forest (G. Studinski and M. Flores, pers. comm.). The main potential effect of the implementation of the Noxious Weed FEIS is limited to the potential consumption of herbicide-contaminated plant and insect materials by geese and mallards. Analysis Area for Project-level Effects Analysis The analysis area for Canada goose is 19,264 acres of potential nesting habitat on the Modoc National Forest (75,713 total acres modeled-56,449 acres of water). This habitat occurs to a large extent on the reservoirs on Devil’s Garden and Doublehead Ranger Districts, with small inclusions on habitat scattered on the rest of the Forest. The analysis area for mallard is 54,292 acres of potential mallard nesting habitat on the Modoc National Forest (111,037 total acres modeled-56,449 acres of water). This area is basically the same as the goose, except that it expands further from the water’s edge.

Alternative 1 (Current Management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect on Canada goose and mallard habitat. There would be no change in the current or future wetland habitat, because most of the work is outside of riparian habitats. Zero % of the current habitat for either species on the Forest would be affected by implementation of Alternative 1. Conversely, the effect of not treating the habitat could cause a significant decrease in the amount of potential food and cover for Canada goose and mallard. Cumulative Effects to Habitat Because there is no direct or indirect effect to Canada goose or mallard habitat, there are no cumulative effects to habitat for either species under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat Physical + treatments could occur on a maximum of 31.06 acres out of 19,264 acres, or 0.016% of potential goose habitat Forest-wide. There could be 119.31 acres of physical + treatments out of 54,292 acres or 0.22% of potential mallard. A maximum of 30.46 acres out of 19,264 acres, or 0.16% of potential habitat Forest-wide for goose habitat could be treated with herbicides; there would be 118.20 acres out of 54,292 acres, or .22% potential mallard habitat sprayed Forest-wide (Table 3 - 76).

352 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Table 3 - 95. Proposed Treatment Acres within Potential Canada Goose and Mallard Habitat

Total Acres of Total Maximum Acres Total Maximum Acres Species Potential Habitat of Physical + of Herbicide Forest-wide Treatments* Treatments* Canada goose 19,264 31.06 30.46 Mallard 54,292 119.31 118.20 *This figure includes the maximum, where physical + or herbicide methods may be employed. Noxious weeds do not provide optimal nesting or foraging cover. Nests located in poor cover routinely fail. In addition, revegetation of bare areas could provide cover currently being taken up by the weeds. Although treatment of noxious weeds would benefit both Canada goose and mallard foraging and nesting habitat, the potential beneficial effects on less than 0.5% of the habitat would not be discernable to Canada goose or mallard habitat by the implementation of Alternatives 2 through 6 on a Forest-wide scale (see paragraph above). Therefore, there are no direct or indirect effects to Canada goose and mallard habitat by the implementation of Alternatives 2 through 6. Cumulative Effects to Habitat Because there are no direct or indirect effects to Canada goose or mallard habitat, there are no cumulative effects to habitat for either species under these Alternatives.

Summary of Canada Goose and Mallard Population Status and Trend at the Forest Scale The Modoc NF Forest Plan (as amended by the SNFPA), requires Forest-scale distribution population monitoring for Canada goose and mallard. The sections below summarize population status and trend data for the both of these species. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Canada Goose and Mallard Population Status and Trend at the Bioregional Scale and Local Scales Population information for Canada goose has been obtained both by Modoc NF personnel and various state and federal partners. Based on California-wide BBS data for the period of 1966 to 2004, Canada goose is classified as “Likely increasing” (Siegel and DeSante 1999), with a non- significant increase of 3.2% (range -7.2 to 13.5) per year over the 39 routes. At the Sierra Nevada scale, for the period of 1966 to 2004, Sierra Nevada-wide BBS data classifies Canada goose as “increasing tendency” (Siegel and DeSante 1999) with a non-significant increase of 10.8% (range -5.8 to 27.4%) per year. Brood counts were conducted for geese and ducks for the Devil’s Garden District in 1975 to 1989, 1991, 1993, 2002, 2003, and 2006. Other information for the Forest consists of incidental sightings. According to Modoc NF data, Canada geese have expanded on the Forest since the time of the Forest Plan. The mallard is the most abundant waterfowl species in the Sierra Nevada. Population information for Canada goose has been obtained both by Modoc NF personnel and various state and federal partners. Sierra Nevada-wide BBS data for the period of 1966 to 2004 classifies mallard as “Definitely increasing” (Siegel and DeSante 1999), with a significant increase of 15.5% (range 5.6 to 25.4%) per year over 12 routes. The 2005 Midwinter Waterfowl Survey index for all ducks

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in California was 3.8 million, an increase of 18 % from 2004 and 20 % above the 10-year average. Generally, there was an upward trend among duck species such as mallard. Brood counts were conducted for all ducks including mallard on the Devil’s Garden District in 1975 to 1989, 1991, 1993, 2002, 2003, and 2006. Other information for the Forest consists of incidental sightings. Monitoring results documented in the Forest Plan FEIS indicate each nesting island annually produces 5 to 6 ducklings (USDA 1991b. Page 3-105). Based on brood count data, mallard production trends appear to have been stable to increasing on the Modoc National Forest since the time of the Forest Plan. Data from the adjacent Modoc National Wildlife Refuge for the past decade indicate that locally mallard populations are stable (barring drought cycles) (S. Clay, pers. comm.).

Effects of the Alternatives on the Canada Goose and Mallard Direct and Indirect Effects Physical + treatments under any Alternative would cause no ingestion of contaminated materials. Canada geese and mallards could potentially ingest both contaminated plants and animals under Alternatives 2, 4 and 6. The vast majority of the weed occurrences in potential Canada goose habitat are less than 1.0 acres (30 occurrences of the total 32 occurrences on the Forest); all but 6 out of 32 occurrences are less than 0.1 acre. The weed occurrences of greatest concern are to Canada goose are BV006LIDA (Dalmatian toadflax) and WM009CIAR4 (Canada thistle). BV006LIDA (Dalmatian toadflax) – The majority of the area is lava reef country with open conifer stands. The entire weed occurrence is roughly 850 acres. In the area adjacent to Lava Lake, the toadflax has a patchy distribution consisting of small clumps of plants that are less than .001 acre in size. No toadflax occurrences were observed in the riparian margin of the lake. A lava reef surrounds the lake, so there is no chance of direct spray of any MIS, nor is there a chance of drift. The chance of disturbance to nesting waterfowl is low, because of the lava reef buffer as well as the delayed accessibility into the area (the native surface roads don’t allow access until late June). Under Alternatives 2 and 4, the entire occurrence could be treated. There are 22.32 acres of potential Canada goose habitat that fall within the entire 850-acre weed occurrence; however, based on a site visit, no weeds would be treated in this potential habitat. Under Alternative 6, only the exterior satellites of the weed occurrence would be treated, which are not within the potential Canada goose habitat. Therefore, there would be no risk to Canada goose by treatment of this weed occurrence under any Alternative. WM009CIAR4 (Canada thistle) – This site consists of a heavily disturbed meadow, fringed by aspen and mixed conifer. The combination of the effects from beaver, livestock grazing, and the road system have led to an infestation of weeds in the meadow and along the road. Although the site was modeled as potential Canada goose habitat, the reality of the situation is the area consists of a series of old beaver ponds, which have become sedimented in to become meadows. The area does not have open water to act as potential Canada goose habitat. Therefore, there would be no effect to Canada goose by the treatment of this occurrence under any Alternative. The vast majority of the weed occurrences in mallard habitat are 0.1 acre or less (44 occurrences of the total 53 occurrences on the Forest). There are nine occurrences that are larger than 0.1 acre. Two of these occurrences are 0.13 and 0.75 acres, four of these occurrences are 1.0 acre, and one weed occurrence is 1.28 acres. Mallard territory sizes encompass hundreds of acres; therefore, it is very unlikely that a mallard would consume 10 to 30 % of its diet in contaminated vegetation or insects (even in a weed occurrence up to 1.23 acres). The largest two weed occurrences, where their treatment provides the greatest potential risk to mallards are BV006LIDA (Dalmatian

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toadflax) and WM009CIAR4 (Canada thistle). As stated above, the riparian areas would not be treated with herbicide in BV006LIDA (Dalmatian toadflax) under any Alternative. The WM009CIAR4 (Canada thistle) is not considered potential mallard habitat. Therefore, treatment of either weed occurrences under any Alternative would not affect mallard. Under the Alternatives with Early Detection/Rapid Response treatments, new occurrences would be reviewed by wildlife biologists prior to implementation; all weed occurrence implementation sites would need to meet water quality standards, and therefore would be limited in acre size as per the Best Management Plan’s (BMPs) and Design Standards. Additional Design Standards could be added, if weed treatment areas were outside of the conditions analyzed within the FEIS. Canada goose and mallard are well distributed across the Modoc NF in riparian habitats. Because there is a low potential for weed treatments to affect individual birds, implementation of Alternatives 2 through 6 would have no impact on the population or the distribution of Canada goose and mallard. Cumulative Effects to Canada Goose and Mallard Populations Because there are no direct or indirect effects to Canada goose or mallard populations, there are no cumulative effects to the population of either species under any Alternative.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Canada Goose and Mallard The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for Canada goose or mallard. There is no potential effect to the population of either species. Therefore, the impact of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing Forest-wide population distribution trend for Canada goose or mallard. Golden Eagle and Prairie Falcon The golden eagle and prairie falcon are both terrestrial MIS as well as Species of Special Concern in California. In addition, the golden eagle is listed as fully protected by California. Habitat - Species Relationship Golden eagles nest in open to semi-open habitat from sea level to 3,630 meters (Kochert et al. 2002). Preferred nesting habitat on the Modoc National Forest includes large trees (typically Ponderosa pine) and cliffs within eastside pine, western juniper, and sagebrush habitat types (USDA 1991b. Page 3-105). Golden eagles observed on and adjacent to the Modoc NF typically forage in open habitats such as grassland, shrub lands, and agricultural fields. Territory sizes ranged from 22 square miles in Idaho to 48 square miles in northern California (Zeiner et al 1990). Golden eagles typically forage in open habitats such as grassland and shrub lands (Kochert et al. 2002). An early study from central California showed that mammals made up 77 % of golden eagle diets (specifically ground squirrels, jackrabbits, and black-tailed deer fawn), although there was also an assortment of birds (including turkey vulture), snakes, and a few fish (Carnie 1954). Golden eagles have been known to take pronghorn fawns as well (Dunbar et al. 1999) or forage in riparian areas on waterfowl, marmots, and rock doves, if sagebrush and hence jackrabbits were limited (Marzluff et al.1997). Prairie falcons are found uncommonly throughout the Modoc National Forest in cliff and scarp habitats. They use open terrain for foraging interspersed with cliffs, canyons, and rock outcrops for nesting (Zeiner et al. 1990). The prairie falcon generally nests on cliffs that are 30 to 400 feet

Chapter 3—Affected Environment & Environmental Consequences 355 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

in height. Migration is limited to elevational changes with season; the birds migrate to the lower elevations in the winter (USDA 1991b.Page 3-106). They forage in open rangeland vegetation such as western juniper, sagebrush, east-side pine, and grasslands. These birds foraged over 300 km2 in southwestern Idaho (roughly 74,000 acres) (Marzluff et al. 1997). Marzluff et al (1997) reported that ground squirrels were prairie falcons’ primary prey, but would increase the amount of reptiles and birds, when ground squirrels were unavailable. Steenhof (1998) notes that falcon young forage on the ground and talus slopes for insects and lizards. In a study conducted in northeastern Wyoming, the authors found that prairie falcons selected foraging areas near their nest sites in areas of open grassland (Squires et al. 1993); preferred prey included ground squirrels and small passerines. These authors also noted that falcons could tolerate low levels of disturbance at their foraging sites as long as their eyries were protected from disturbance.

Project-level Effects Analysis based on Prairie Falcon and Golden Eagle Habitat Key Habitat Factor(s) for the Analysis The proposed project, the removal of noxious weeds from Forest System Lands, will have no affect on habitat for golden eagle or prairie falcon; neither species is directly tied to the noxious weeds for cover or food. Golden eagles use, large trees (typically ponderosa pine) or cliffs as nest sites. Prairie falcons utilize cliffs as nest substrate. The potential effects from activities discussed in the FEIS are from disturbance at the nest site and the potential consumption of herbicide contaminated prey by eagles or falcons. Analysis Area for Project-level Effects Analysis The analysis area for golden eagle consists of 93,884 acres of occupied and potential habitat on the Forest. There are 28,014 acres of occupied habitat within 0.5 miles of nest sites and 65,870 acres of potential golden eagle habitat Forest-wide. This habitat is focused on the outer fringes of the various Districts and within central portions of the Devil’s Garden and Doublehead Districts. Prairie falcons are found sporadically throughout the Forest, where suitable nesting cliffs are found. The Dome lands, the Pit River corridor, and the eastern scarp of the Warner Mountains provide the bulk of the concentrations of suitable habitat, although there are scattered cliffs throughout the Forest. The analysis area consists of concentric rings around known nest sites; there are 5,678 acres of habitat within 0.5 miles of known nest sites. Both species forage in open habitats across the Forest, so they could encounter contaminated prey at numerous locations. However, the territory sizes are enormous (75,000 acres and greater); there would be no scenario under any of the Alternatives, where either species could consume 10% of their diet that contained contaminated prey.

Alternative 1 (Current Management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect on golden eagle or prairie falcon habitat. There would be no change in the current or future amount of cliffs or large trees by the treatment of noxious weeds. Zero % of the current golden eagle or prairie falcon habitat in the analysis area would be affected by implementation of Alternative 1.

356 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Cumulative Effects to Habitat Because there is no direct or indirect effect to golden eagle or prairie falcon habitat, there are no cumulative effects to habitat for either species under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects There are a maximum of 5.7 acres or 0.02% out of 28,014 acres Forest-wide that could receive physical + treatments and 4.7 acres or 0.017% of herbicide treatments in occupied golden eagle habitat (Table 3 - 77). Within potential golden eagle habitat, 10.86 acres or 0.016% of 65,879 acres Forest-wide could receive physical + treatments and 9.58 acres or 0.015% could receive treatments with herbicides. There are 4.74 acres (0.083%) that could receive physical + treatments out of 5,678 acres of occupied prairie falcon habitat Forest-wide; there are 4.64 acres (0.082%) Forest-wide that could receive herbicide treatments (Table 3 – 77 ). Potential habitat was not modeled for prairie falcon, because of difficulties with the DEM model.

Table 3 - 96. Proposed treatment Within Golden Eagle and Prairie Falcon Habitat

Total Acres of Total Maximum Acres Total Maximum Acres Species Habitat of Physical + of Herbicide Forest -wide Treatments* Treatments* Golden - occupied 28,014 5.7 4.7 Golden - potential 65,870 10.86 9.58 Prairie falcon - occupied 5,678 4.74 4.64 * This figure includes the maximum, where physical + or herbicide methods may be employed No eagle or falcon nesting habitat would be affected under any action Alternative. According to the Modoc Forest Plan (1991a), the Forest is to maintain or improve habitat for potential prey species of the golden eagle. Removal of weeds is expected to improve cover and forage for a variety of eagle and falcon prey species including birds, deer, jack rabbits, and ground squirrels. Regardless, the weed occurrences still contain native plants within or adjacent to them, so there would be no change in foraging habitat for golden eagle or prairie falcons adjacent to nest sites. Cumulative Effects to Habitat Because there are no direct or indirect effects to golden eagle or prairie falcon habitat, there are no cumulative effects to habitat for either species under any Alternative.

Summary of Population of Golden Eagle and Prairie Falcon Status and Trend at the Forest Scale The Modoc NF Forest Plan (as amended by the SNFPA) (USDA 2001), requires Forest-scale distribution population monitoring for golden eagle and prairie falcon. The sections below summarize population status and trend data for these species. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Golden Eagle and Prairie Falcon Population Status and Trend at the Bioregional Scale According to the California Department of Fish and Game, golden eagles were once a common permanent resident throughout the open areas of California; numbers are now reduced near

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human population centers (e.g., San Diego County), where they declined from an estimated 85 pairs in 1900 to 40 occupied territories in 1999, due to extensive residential development. In general, however, populations seem stable. Approximately 500 pairs are estimated to nest in California. California-wide BBS data for the period of 1966 to 2004 classifies the golden eagle as “Likely increasing” (Siegel and DeSante 1999) with a non-significant increase of 1.5% (range - 1.6 to 4.5) per year over the 49 routes. Historically, the prairie falcon was also a common permanent resident throughout California, except for the humid northwest coast and higher mountains. California-wide BBS data for the period of 1966 to 2004 classifies this falcon as “Possibly increasing” (Siegel and DeSante 1999), with a non-significant increase of 2.1% (range -1.5 to 5.7) per year over the 26 routes. In addition, results of Christmas Bird Counts seem to indicate an overall trend has been stable to increasing with quite a bit of annual fluctuation in numbers.

Effects of the Alternatives Considered within the Noxious Weeds FEIS According to Forest Plan direction, eagle nests will be managed to minimize disturbance during the nesting season and to protect the nest tree; prairie falcon direction is to protect nesting birds from disturbance. Disturbance at active nest sites, as with all of the raptors, is the greatest source of concern. The Modoc Forest Plan allows for ¼ to ½ mile Limited Operating Period around active nests sites for both of these species. Utilizing these Limited Operating Periods in Design Standard DS-10 should ensure that there would be no direct effect to golden eagles or prairie falcons. A maximum of 0.017% of the occupied golden eagle habitat could have herbicides and 0.015% of the potential habitat is scheduled for herbicide treatments on the Forest. A maximum of 0.082% of the areas around prairies falcon nest sites have the potential for herbicide treatments. Both of these species forage widely; eagles have minimum territories of 22 square miles and prairie falcons have been known to forage over 74,000 acres. There is very little chance that predatory bird species that range as widely as these two do could ingest a 10 to 100% of their diet in sprayed mammals to cause any toxicological effects. In addition, none of the herbicides at the rates proposed for use have Hazard Quotients over 1.0, therefore, there is little risk of herbicide effects to predatory birds ingesting contaminated mammals. There was no herbicide risk scenario for a predatory bird ingesting contaminated birds; this scenario is not realistic because birds would flush before being sprayed in the course of weed treatment in response to their innate “Fight or Flight” response. Therefore, treatment of noxious weeds under any Alternative will have no effect on golden eagle or prairie falcon populations . Under the Alternatives with Early Detection/Rapid Response treatments, wildlife biologists would review new weed occurrences prior to implementation; if concerns for golden eagle or prairie falcon surfaced, additional Design Standards could be added if weed treatment areas were outside of the conditions analyzed within the FEIS. Cumulative Effects to Populations Because there are no direct or indirect effects to golden eagle or prairie falcon populations, there are no cumulative effects to populations for either species under any Alternative.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Golden Eagle and Prairie Falcon The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for golden eagle or prairie falcon. Nor will there be any potential effect to the population for either species. Therefore, the impact of the Noxious Weeds Project

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will not alter the existing Forest-wide trend in habitat, nor will it change the existing Forest-wide population distribution trend for golden eagle or prairie falcon. Hairy Woodpecker Both the hairy and pileated woodpeckers are terrestrial MIS, as well as non-game species in California. Habitat - Species Relationship: Habitat for hairy woodpeckers includes mixed conifer and riparian habitats with large trees present; tree canopy covers vary from sparse to intermediate (Zeiner et al. 1990a). Locally on the Modoc National Forest they have been observed in eastside pine as well (K. Romberger, pers. comm.). Hairy woodpeckers basically feed on insects; however, a small of their diet includes acorns, pine nuts, and sap (Zeiner et al. 1990a). They have been reported to forage at sapsucker wells (Ehrlich and Daily 1988), and glean materials off the edges exposed by pileated woodpeckers (Maxson and Maxson 1981). Hairy woodpeckers forage mainly in the crevices of the bark of live and dead trees as well as in logs and stumps (Zeiner et al. 1990a). Home range size, which equated to a territory, varied from 6 to 8 acres in central Oregon (Zeiner et al. 1990). Territories measured during nesting should be considered minimal areas (Jackson et al. 2002). Habitat for pileated woodpeckers consists of mature coniferous stands with numerous large snags, logs and stumps (Zeiner et al. 1990a). According to the bird conservation plan developed for pileated woodpecker (Robinson 2000), they will also nest in aspen and other hardwoods. During development of the Modoc NF Forest Plan, the authors noted that pileated woodpeckers were found on the Modoc National Forest in mixed conifer and red fir types (USDA 1991b. Page 3- 109). Pileated woodpeckers concentrate mostly on animal material; however, they will also use nuts, berries, and other fruit (Zeiner et al. 1990a); this species forages on decayed live and dead trees, logs and stumps. Home range size varies from 320 to 600 acres (Zeiner et al 1990).

Project-level Effects Analysis for the Hairy Woodpecker Key Habitat Factor(s) for the Analysis The proposed project, the removal of noxious weeds from Forest System Lands, will have no effect on habitat for either woodpecker species. Both species utilize snags and logs for foraging and nesting and are not directly tied to the noxious weeds for cover or food. The main potential effect is limited to the potential consumption of herbicide contaminated insect and plant materials. Analysis Area for Project-level Effects Analysis The analysis area for hairy woodpecker is limited to the 153,200 acres of potential habitat on the Forest; these conifer stands are scattered throughout the Forest. The analysis area for pileated woodpecker is limited to the 173,500 acres of potential habitat on the Forest. Habitat is limited to the upper elevations of the Forest that have mixed conifer, white fir, and red fir. In general, the areas include the Warner Mountain Ranger District, the Medicine Lake Highlands, roughly half of the Big Valley District, and localized portions of the Devil’s Garden District.

Alternative 1 (Current Management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical methods. Currently, the Forest does not use of herbicides to treat noxious weeds.

Chapter 3—Affected Environment & Environmental Consequences 359 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Implementing weed treatments under Alternative 1 would have no affect on habitat for either woodpecker. There would be no change in the current or future amount of dead and downed materials from the treatment of noxious weeds. Coniferous vegetation diversity, especially in the later-seral stage coniferous stands for pileated woodpecker, is expected to remain the same or be improved on micro-sites in the coniferous stands; the same is true for aspen and meadow habitat. Zero % of the current hairy or pileated habitat in the analysis area would be affected by implementation of Alternative 1. Cumulative Effects to Habitat Because there is no direct or indirect effect to hairy or pileated woodpecker habitat, there are no cumulative effects to habitat for either species of woodpecker under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat There are a maximum of 60.69 acres (0.04%) Forest-wide of proposed physical + treatments and a maximum of 56.22 acres (0.037%) with herbicide treatments within potential hairy woodpecker habitat (Table 3 – 78). There are a maximum of 51.35 acres (0.03%) out 170,000 acres with physical + and 50.81 acres (0.03%) with herbicide treatment within potential pileated woodpecker habitat Forest-wide (Table 3 – 78).

Table 3 - 97. Proposed Treatment Within Potential Hairy and Pileated Woodpecker Habitat

Total Acres of Total Maximum Acres Total Maximum Acres of Species potential Habitat of Physical + Herbicide Treatments* Forest-wide Treatments* Hairy woodpecker 153,200 60.69 56.22 Pileated woodpecker 173,500 51.35 50.81 * This figure includes the maximum, where physical + or herbicide methods may be employed. Implementing weed treatments under Alternatives 2 through 6 would have no effect on hairy or pileated woodpecker habitat. There would be no change in the amount of snags and logs, therefore, no nest or forage trees for either species would be removed under any action Alternative. There will be no change in the current or future amount of dead and downed materials by the treatment of noxious weeds. There will be no change to the overstory tree matrix by the implementation of noxious weed treatments, so there would be no change in vegetative diversity to effect either species. Although both hairy and pileated woodpeckers will take seeds and fruits (Jackson et al. 2002 for hairy woodpecker and Bull and Jackson for pileated woodpecker 1995), neither species is known to consume noxious weeds. Aspen and meadow habitat could be stable to increasing by the implementation of any action Alternative, because the treatment decreases the competition to native species by noxious weeds in very small, localized areas. Therefore, 0% of the current hairy or pileated habitat in the analysis area would be negatively affected by implementation of any action Alternative. Therefore, there will be no direct or indirect effects to hairy or pileated woodpecker habitat under any action Alternative. Cumulative Effects to Habitat Because there are no direct or indirect effects to hairy or pileated woodpecker habitat, there are no cumulative effects to habitat for either woodpecker species under these Alternatives.

360 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Summary of Hairy Woodpecker Population Status and Trend at the Forest Scale The Modoc NF Forest Plan (as amended by the SNFPA) requires Forest-scale distribution population monitoring for both species of woodpecker. The sections below summarize population status and trend data for these species. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Hairy Woodpecker Population Status and Trend at the Bioregional Scale Population monitoring data collected by various partners at the bioregional scale indicate that hairy woodpeckers are “definitely stable” for California and the Sierra Nevada (Siegel and DeSante 1999). Hairy woodpeckers are seen fairly frequently throughout the Modoc National Forest. They have been detected from 1910 to the present during a variety of surveys: turn-of-the-century surveys of avi-fauna (data from Natural History Collection for the University of California, Berkeley), Breeding Bird Survey routes, project-generated stand searches and point counts, as well as the Pacific Southwest Research Station (PSW) cavity-nesting bird study (Laudenslayer 2002). The distribution for hairy woodpecker appears to be the same as the one in 1991, when the Forest Plan was released. Population monitoring data collected by various partners at the bioregional scale indicate that pileated woodpeckers are “definitely stable” for California and “Possibly decreasing with a non- significant decrease of -1.8% per year” for the Sierra Nevada (Siegel and DeSante 1999). Pileated woodpeckers have been sighted infrequently on the Modoc National Forest. Data for pileated woodpecker consist of presence information from 1981 to the present, from Forest Service point counts, and various individual observers’ incidental sightings. The distribution for pileated woodpecker appears to be the same as the one in 1991, when the Forest Plan was released.

Effects of the Alternatives on Hairy Woodpeckers Direct and Indirect Effects There is an insignificant chance of either species eating contaminated vegetation under any Alternative. Alternatives 3 and 5 propose no herbicide treatments. The discussion below focuses on the herbicide portions of Alternatives 2, 4 and 6. There is little chance for ingesting contaminated materials for hairy woodpecker (i.e., prey species habitat), because they do not forage in weeds; they forage on snags, logs, and occasionally on a sapsucker well or on fruit. Therefore, the vast majority of their foraging areas would be uncontaminated. In northern California (near Truckee), “they (black-backed and hairy woodpeckers) foraged mostly on dead trees and drilled for their prey rather than gleaned.” (Raphael and White 1984). There are a five weed occurrences of sufficient size, where a significant amount of potentially contaminated insects could be ingested. The following section discusses occurrences within potential hairy woodpecker habitat. BV006LIDA (Dalmatian toadflax) – The majority of the area is lava reef with open conifer stands. The entire weed occurrence is roughly 850 acres. In the area adjacent to Lava Lake, the toadflax has a patchy distribution consisting of small clumps of plants that are less than .001 acre

Chapter 3—Affected Environment & Environmental Consequences 361 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

in size. Under Alternatives 2 and 4, the entire occurrence could be treated. There are 4.55 acres of potential hairy woodpecker habitat that could be treated, where insects could climb onto an adjacent snag and be potentially ingested. This could equate to roughly one territory or .003% of the potential hairy woodpecker habitat on the Forest. Given the hairy woodpeckers’ feeding preferences and the hairy woodpecker habitat condition in this weed occurrence, it is unlikely that there would be any effect to hairy woodpeckers by implementation of Alternative 2 or 4. Under Alternative 6, only the exterior satellites of the weed occurrence would be treated, so there would be no risk to hairy woodpecker under this Alternative. BV001CRVU2 (Crupina) – The area along Post Canyon has crupina present along the road into conifer at various levels of infestation. The largest concentrations are at the lower end of the canyon in the open sage habitats. Other plants, both native and exotic, are within the matrix. In Alternatives 2 and 4, the entire occurrence could be treated. Cumulatively, there are 16.11 acres of potential hairy woodpecker habitat that could have herbicide treatments within the entire 158 acre weed occurrence. The entire 16 acres equates to roughly two territories. The insects that would be found on herbaceous plants probably would not be the type that are found and consumed on snags and logs (R. Borys and D. Cluck, pers. comm.). In addition, crupina does not provide a fruit that would be ingested. Given the hairy woodpecker’s feeding preferences and the condition of the site, implementation of Alternatives 2 or 4 are not expected to affect hairy woodpecker. Under Alternative 6, only the exterior satellites would be treated, so there would be no risk to hairy woodpecker for this weed occurrence. WM003LIDA (Dalmatian toadflax) – The site is basically a large, contiguous matrix of native plants with small clumps of weeds (the patches of weeds are very small with most of them roughly 10 feet by 10 feet). Although the entire weed occurrence encompasses roughly 40 acres, the weeds are actually distributed in small clumps found in lava rock talus, an old road bed, and along old, dry, rocky streambeds. There were no toadflax plants along the main channels of Lassen Creek. There are 20.26 acres of potential hairy woodpecker habitat within the weed occurrence, but about one acre total of potential hairy woodpecker habitat would be treated. Consequently, the chance of a hairy woodpecker consuming 10 to 30% of its diet in contaminated insects would be improbable to the point of being discountable under Alternatives 2, 4 or 6. WM009CIAR4 (Canada thistle) – This site consists of a heavily disturbed meadow, fringed by aspen and mixed conifer. The combination of the effects from beaver, livestock and the road system has led to an infestation of weeds in the meadow and along the road. Although there are 5.36 acres of potential hairy woodpecker habitat that could receive treatment, given the situation at the site, only an insignificantly small portion of the potential hairy habitat would be treated. The weeds are basically not within the coniferous stand: therefore, the potential for insects to be contaminated while on an herbaceous plant and show up in the diet of a species known for foraging on snags and logs is so low, to the point of being discountable, in this weed occurrence. Therefore, there would be no effect to hairy woodpecker by the treatment of this occurrence under any Alternative. DH0131ISTI (dyer’s woad) – There are 3.53 acres of potential hairy woodpecker habitat that could be treated within this roughly 5,500-acre occurrence. The area is largely unsuitable for hairy woodpecker, and it is extremely improbable to the point of insignificance that hairy woodpecker would ingest 10 to 30% of their diet in contaminated insects, given their habitat and food preferences and the conditions of the vegetation under Alternatives 2 and 4. Only the satellite weeds would be treated under Alternative 6, so there would be no effect to hairy woodpecker under Alternatives 2, 4 and 6. Under the Alternatives with Early Detection/Rapid Response activities, wildlife biologists would review new noxious weed treatment sites prior to implementation. If concerns for hairy

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woodpecker surface (including conditions not covered within the analysis for the FEIS), additional Design Standards could be added. To summarize, there would be no direct or indirect effects to hairy woodpeckers by the implementation of Alternative 6. It is highly unlikely there would be any direct or indirect effects to hairy woodpeckers under Alternatives 2 and 4, given their preferences for foraging on snags and logs (which is what they are an indicator for on the Modoc National Forest), and the small amount of potential hairy woodpecker habitat to be treated, even in the largest weed occurrences. Cumulative Effects to Populations: Because there are no direct or indirect effects to hairy woodpeckers, there are no cumulative effects to hairy woodpeckers under any Alternative. These following paragraphs discuss occurrences within potential pileated woodpecker habitat and potential effects to pileated woodpeckers by their treatment. WM001ISTI, WM002ISTI, WM004ISTI, WM005ISTI, and WM008ISTI (all are dyer’s woad) are located in the northwestern corner of the Warner Mountain District. There are a total of 37.18 acres of dyer’s woad in potential pileated woodpecker habitat that could be treated with herbicides. These occurrences could be located within one potential pileated woodpecker territory, which ranges from 320 to 600 acres in size. However, pileated woodpeckers primarily consume carpenter ants (wood-boring ants) and other insects (Bull and Jackson 1995). Assuming that these occurrences are in one territory, about 9% of the area would be treated (using the smallest potential territory size and the largest concentration of weeds to be treated). Even combining these weed occurrences, the effect is improbable that 10 to 30% of a woodpecker’s diet would contain contaminated insects, because pileated woodpeckers do not forage on dyer’s woad and the contaminated insects would have to migrate to preferred foraging structures; as stated above, insects that prefer herbaceous plant species generally do not migrate to conifers. Therefore, there will be no effect to pileated woodpecker by the implementation of any Alternative for these weed occurrences. WM009CIAR4 (Canada thistle) – As stated above in the hairy woodpecker section, the majority of the weeds are outside of the conifer stand that could support pileated woodpecker. A total of 5.84 acres out of 320 to 600 acres within a potential territory could be treated. Even assuming that all of the insects in the area would be consumed, only 0.98% to 1.8% of the potential territory would be affected. The impact is so small that the effect can be discounted as insignificant. Therefore, treating this occurrence under any Alternative would not affect pileated woodpeckers. To summarize, given their preference for foraging on woody plants and the effects are localized in one area on the Warner Mountain District, there would be no direct or indirect effects to pileated woodpecker distribution or population by the implementation of any Alternative. Under the Alternatives with Early Detection/Rapid Response activities, wildlife biologists would review new noxious weed treatment sites prior to implementation. If concerns for pileated woodpecker surface (including conditions not covered within the analysis for the FEIS), additional Design Standards could be added. Cumulative Effects to Populations Because there is no direct or indirect effect to pileated woodpeckers, there are no cumulative effects to pileated woodpecker under any Alternative.

Chapter 3—Affected Environment & Environmental Consequences 363 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Hairy and Pileated Woodpecker The implementation of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing Forest-wide population distribution trend for hairy or pileated woodpeckers. Mule Deer and Pronghorn Both the mule deer and pronghorn antelope are terrestrial MIS, as well as a game species in California. Deer were selected as Management Indicator Species for the Forest, because it needs and prefers diverse habitats (USDA 1991b. Page 3-111). Antelope were selected as indicators of rangeland condition (USDA 1991b. Page 3-115). Habitat - Species Relationship: Mule deer utilize almost every acre on the Modoc National Forest for winter, transition, and summer range, as well as fawning areas, with the exception of the barren areas like the Burnt Lava Flow or large bodies of water like Clear Lake. Habitat for deer includes early to intermediate successional forests and brushlands; they prefer a mosaic of various aged vegetation that provides woody cover, meadow and shrubby openings and free water (Zeiner 1990b). According to the Fish and Game publication “Report to the Fish and Game Commission: An assessment of mule and black-tailed deer habitats and populations in California with special emphasis on public lands administered by the Bureau of Land Management and the United States Forest Service.” (California Dept. Fish and Game 1998), foraging habitat is a limiting factor for mule deer in northeastern California. Pronghorn utilize the lower elevation sage habitats mainly on the Devil’s Garden and Doublehead Districts. Pronghorn prefer open rangeland types that support a variety of vegetative types (Lee et al. 1998). Areas with low shrubs typify summer habitat with a diversity of native grasses and forbs (Gregg et al. 2001, Lee etal. 1998). According to Lee, et al. (1998), forbs were preferred, and “Thus, management decisions favoring the abundance of forb species are desirable to the welfare of pronghorn.”

Project-level Effects Analysis based on Habitat Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no negative affect on habitat for either mule deer or pronghorn; neither species is tied to the noxious weeds for cover or food. In fact, the removal of weeds on rangelands has been shown to benefit big game species. See the General Wildlife section of the Noxious Weeds FEIS for a discussion of the effects of noxious weeds on wildlife. The main potential effect is limited to the potential consumption of herbicide-contaminated plant materials. Analysis Area for Project-level Effects Analysis: The analysis area for mule deer is 1,587,564 acres, which includes cover, foraging and fawning habitats. This area covers most of the land on the Forest. The analysis area for pronghorn antelope is 791,867 acres of mainly lower-elevation habitat. The concentration areas include the Devil’s Garden District, the eastern and northern half of the Doublehead District, and the outer fringes of the Warner Mountain and Big Valley Districts.

Alternative 1 (Current Management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use of herbicides to treat noxious weeds.

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Implementing weed treatments under Alternative 1 would have no effect on habitat for mule deer or antelope. There would be no change in the current or future amount of preferred forage by the treatment of noxious weeds. There would be no change in the amount of cover. Zero % of the current mule deer and pronghorn habitat in the analysis areas would be affected by implementation of Alternative 1. Conversely, allowing weeds to increase in deer and pronghorn habitat would decrease habitat suitability. Cumulative Effects to Habitat Because there is no direct or indirect effect to mule deer or antelope habitat, there are no cumulative effects to habitat for either species under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat Deer are found on almost every acre of the Modoc NF; therefore, most of the Modoc NF is considered as occupied habitat. There are 1.74 acres of physical + treatments and 1.6 acres of herbicides that would not occur Forest-wide in deer habitat. Conversely, there is a maximum of 5,991.26 acres (0.38%) of physical + treatments and 6,866.4 acres (0.43%) of herbicide treatments that could occur in deer habitat Forest-wide. These figures do not include the Early Detection/Rapid response acres, which are discussed below. There is a maximum of 1,964.04 acres (0.25%) that could receive physical + treatments and 1,960.02 acres (0.25%) that could receive herbicide treatments in potential pronghorn habitat Forest-wide (Table below). The acreages includes both occupied and potential pronghorn habitat.

Table 3 - 98. Proposed Treatment Acres Within Potential Mule Deer and Pronghorn Habitat

Total Acres of Total Maximum Acres Total Maximum Acres Species Potential Habitat of Physical + of Herbicide Forest-wide Treatments* Treatments* Mule deer 1,587,564 5,991.26 6,866.4 Pronghorn 791,867 1,964.04 1,960.02 * This figure includes the maximum, where physical + or herbicide methods may be employed Since deer or pronghorn do not rely on noxious weeds as food or cover, there would be no change in the quantity of habitat by implementation under any Alternative for mule deer or pronghorn. Studies have shown that noxious weeds displace native herbaceous plants, thereby modifying the habitat suitability for various wildlife species or changing species interactions within ecosystems (e.g., grasslands can be modified to forb-dominated communities) (Belcher and Wilson 1989; Trammel and Butler 1995). Cheatgrass (Bromus tectorum) provides a classic example of this problem; cheatgrass is an introduced annual grass that has changed fire regimes, decreased above and below ground plant biomass, and altered ecosystem function (native grasses maintain live shoots into the summer that deer and antelope rely on, whereas cheatgrass does not) (Ogle et al. 2003)). Mule deer use of favored foraging habitat on the Theodore Roosevelt National Park was reduced by 70 % after invasion by leafy spurge (Trammel and Butler 1995). Results of a study conducted in Montana showed that mule deer did not use spotted knapweed, although it was common on their winter range (Guenther 1989 in Beck 1994). A study in Montana on Russian knapweed showed that areas heavily infested with knapweed displaced both wildlife and native plant species, which resulted in a loss of rangeland biodiversity (Kurz 1995 in Laufenberg et al. 2005). This loss of rangeland diversity would directly affect both deer and pronghorn, which are rangeland MIS.

Chapter 3—Affected Environment & Environmental Consequences 365 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Revegetation of large, bare areas can improve habitat for deer and antelope. Design Standards DS-20 and DS-21 allow for the site-specific assessment in order to determine, if revegetation is needed depending on the amount of bare area post-treatment. Although the removal of noxious weeds may benefit individual deer and antelope, the increase in habitat from the implementation of any Alternative would not be large enough to discern a change in the amount of habitat Forest-wide, because of the small percentages of habitat proposed for treatment. Therefore, there would be no direct or indirect effect to the amount of deer or pronghorn habitat by the implementation of Alternatives 2 through 6. Cumulative Effects to Habitat Because there are no direct or indirect effects to mule deer or pronghorn habitat, there are no cumulative effects to habitat for either species under any action Alternative.

Summary of Population Status and Trend at the Forest Scale The Modoc NF Forest Plan (as amended by the SNFPA) requires Forest-scale distribution population monitoring for mule deer and pronghorn. The sections below summarize population status and trend data for both species. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Population Status and Trend at the Bioregional Scale Mule deer is “S5- secure” (“demonstrably widespread, abundant, and secure”) in California (NatureServe 2006). Deer herds in California are tracked by Hunt Zones and by 11 deer assessment units, which include multiple hunt zones. The California Department of Fish and Game assesses mule deer population status and trend by both hunt zones and deer assessment units as part of their Environmental Documentation for the hunting program. Annual variation in deer population estimates may be high, due to annual changes in environmental conditions, and varies geographically.

Table 3 - 99. Mule Deer Population Trend for DAUs covering the Eldorado, Lassen, Modoc, Plumas, Sierra, and Stanislaus NFs. 1

Population DAU No. Name Hunting Zones Forests Trend1 DAU 4 Cascade, Northern Sierra C4 Lassen Declining DAU 5 Central Sierra Nevada D3 to D7 Stanislaus, Sierra, Increasing Eldorado, Plumas (western) DAU 6 South Sierra D8 to D10 Sierra, Stanislaus Stable DAU 9 Northeast California X-4 and X-3a Lassen, Modoc Stable2 DAU 10 Northeast Sierra X-6a and X-6b Lassen, Plumas Stable2 1 CDFG 2003. 2 Eastside deer populations (DAUs 9, 10) occupying Great Basin habitats experienced significant declines during 1990- 1996. However, these populations appear to have stabilized based on recent trend estimates (CDFG 2003). The Modoc National Forest is contained within Deer Assessment Unit 9. Deer are counted during the spring along fixed transects in order to provide an index to population trend within the DAU. The trend line for the data shows a downward trend, although not as significant downward trend as indicated by the r2 value near 0.5. The counts do show fluctuation in annual numbers that vary from +30% to -35% from the median value for the period. The trends thus appear to fluctuate, but do not show a sustained strong downward or upward trend.

366 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Pronghorn is “S4- secure” (“demonstrably widespread, abundant, and secure”) in California (NatureServe 2006). Historically, the pronghorn was the most abundant big-game animal in California, and inhabited the valley and foothill regions of much of the State. The northeastern population is managed for a desired population of 5,600 to 7,000 animals. Population numbers declined to approximately 2,000 animals prior to 1960. After 1960, the statewide pronghorn population gradually increased until 1992 when California supported more than 8,000 animals. Population numbers declined as a result of severe weather conditions in northeastern California during the 1992/1993 winter. Although population numbers have not yet increased to their 1992 levels, the current population is well above levels recorded during the 1950s. Since the 1950s, the state-wide pronghorn numbers have more than doubled. The population monitoring requirements for pronghorn antelope are based on distribution. Data on pronghorn numbers is based on input from California Fish and Game surveys, in addition to incidental sightings from Forest Service personnel. The distribution of antelope is the same as during the time of the Modoc Forest Plan. Since the 1992-93 winter kill, the antelope population has not increased, but has stabilized in the last few years.

Effects of the Alternatives Considered within the Noxious Weeds FEIS Under Alternatives 3 and 5, as well as the physical + treatment aspects of Alternatives 2, 4, and 6, there would be no potential ingestion of contaminated vegetation. Mule deer and pronghorn could ingest contaminated plants under Alternatives 2, 4 and 6. However, the greatest concern for potential toxic effects would only be in the largest weed occurrences. The assumptions for the scenarios developed to quantify hazard quotients, which provide a measure of risk, are as follows. Large mammal eating contaminated vegetation (acute) - 100% for the diet Lower, Central and Upper levels Large mammal eating contaminated vegetation (chronic on-site) - The diet would consist of contaminated materials; 10% for the Lower, 30% Central and 100% Upper levels.

Table 3 - 100. Herbicides and Their Application Rates for Acute Exposures to Large Mammals, Consuming Contaminated Vegetation, Where There is no Spray Buffer and a Boom Application Method

Exposure Assessment Rate Herbicide/Application Rate Hazard Quotient Rating mg/kg/day or mg/kg/event Central Lower Upper Central Lower Upper 2,4 – D a) 1.5 lbs/ac 25.8 25.8 72.8 3.0 3.0 7.0 b) 2.0 lbs/ac 34.4 34.4 97.1 3.0 3.0 10.0 Chlorsulfuron 1.0 oz/ac 1.07 1.07 3.04 .01 .01 0.04 Clopyralid 0.25 lb/ac 4.3 4.3 12.1 .06 .06 0.2 Dicamba a) 1.0 lb/ac 17.2 17.2 48.6 0.4 0.4 1.1 b) 2.0 lbs/ac 34.4 34.4 97.1 0.8 0.8 2.0 Glyphosate 3.75 lbs/ac 64.5 64.5 182 0.4 0.4 1.0 Triclopyr (Acid & BEE) 1.5 25.8 25.8 72.8 0.3 0.3 0.7 lbs/ac NPE 28.7 23.0 113 3.0 2.0 11.0 Note: Data for boom-sprayer application is for comparison purposes only. The Forest does not propose using mechanical boom sprayers.

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Table 3 - 101. Herbicides and Their Application Rates for Chronic Exposures (on site) to Large Mammals Consuming Contaminated Vegetation Where There is no Spray Buffer and a Boom Application Method

Exposure Assessment Rate Herbicide/Application Rate Hazard Quotient Rating mg/kg/day or mg/kg/event Central Lower Upper Central Lower Upper 2,4 - D a) 1.5 lbs/ac (on site) 1.72 0.572 1.7 16.2 0.6 16.0 b) 2.0 lbs/ac 2.29 0.763 21.5 2.0 0.8 22.0 Chlorsulfuron 1.0 oz/ac 0.136 0.0452 1.28 0.03 0.009 0.3 Clopyralid 0.25 lb/ac 0.521 0.138 6.39 0.03 0.009 0.4 Dicamba a) 1.0 lb/ac 0.744 0.248 7.00 0.02 0.006 0.2 b) 2.0 lbs/ac 1.49 0.496 14.0 0.03 0.01 0.3 Glyphosate 3.75 lbs/ac 10.6 3.53 99.7 0.06 0.02 0.6 Triclopyr (Acid & BEE) 3.78 0.969 48.0 0.8 0.2 10.0 1.5 lbs/ac NPE 0.138 0.0368 1.82 0.01 0.004 0.2 Note: Data for boom-sprayer application is for comparison purposes only. The Forest does not propose using mechanical boom sprayers.

Under Alternatives 2 and 4, 0.43% % of potential deer habitat Forest-wide could receive herbicides. This value drops significantly under Alternative 6, where a maximum of 522 acres could be treated using herbicide (Chapter 2 of FEIS). Home range size for does and fawns is approximately was 0.4 to 1.1 miles square (Zeiner et al 1990) or 256 to 704 acres. There is very little chance of mule deer receiving a large enough dose of contaminated vegetation in most weed occurrences for the following reasons. One, mule deer are not known to forage exclusively on the weed species selected for treatment. Two, most of the weed occurrences within potential habitat for deer are less than an acre. Therefore, it would be improbable to the point of insignificance that 10 to 100% of their diet would be in contaminated materials. The exception would be in the larger weed occurrences. Although weeds are not considered forage, there easily could be overspray onto non-target plants within the weed occurrence (R. Wilson, pers. comm.), especially in the more densely packed weed occurrences. These larger occurrences, where there is a greater risk to deer, are discussed below. DH013ISTI (dyer’s woad) (5,658 acres) – This dyer’s woad occurrence contains a variety of weed densities from homogeneous patches of weeds to single plants. The habitat includes plantations, burned east-side pine stands and shrub communities. About 1/3 of the weed occurrence consists of lava reefs, which do not have large amounts of suitable forage and cover for deer (J. Ivrin, pers. comm.). The deer that utilize the area of this occurrence typically are off- site (in Oregon) at the time of year treatment would occur. However, the area does contain winter deer range and a few residential animals could consume year-round (J. Irvin, pers.comm.). For the most part, when the deer are concentrated in this polygon, they are heavily utilizing browse. Under Alternatives 2 and 4, the entire occurrence could be treated. Those resident deer would probably not suffer effects associated with acute toxicities, which would require 100% of the diet to consist of contaminated vegetation. However, they could exhibit signs of toxicity associated with chronic exposures, especially at the lower (10% of the diet) and central values (30% of the diet) (Table 3 - 82). The only herbicide with hazard quotients over 1.0 at the lower and central levels is 2, 4-D. According to information for mammals from the SERA report on 2, 4-D, this herbicide has a low chance to cause “frank signs of neurotoxicity”, but has an 80% chance of

368 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

causing some degenerative changes to various organs. Although the effects do not appear to cause direct mortality to the animals, depending on the extent of the effect, individual animals could be at greater risk of predation. Treatment of this weed occurrence under Alternative 6 would cause no risk to the few resident deer, because only the outer edges would be sprayed to contain its spread. BV006LIDA (Dalmatian toadflax) – The majority of the area is lava reef country with open conifer stands. The entire weed occurrence is roughly 850 acres. In many areas, the toadflax has a patchy distribution consisting of small clumps of plants that are less than .001 acre in size. Under Alternatives 2 and 4, the entire occurrence could be treated. However, there would still be a basic matrix of native plants to provide food for deer, so neither the acute nor the chronic scenarios is likely under Alternatives 2 and 4. Under Alternative 6, only the exterior satellites of the weed occurrence would be treated. Given the site conditions and deer food preferences, there would be no risk to mule deer under any action Alternative for this occurrence. BV001CRVU2 (Crupina) – The area along Post Canyon has crupina present along the road into conifer at various levels of infestation. The largest concentrations were at the lower end of the canyon in the open sage habitats. Other plants, both native and exotic, were within the matrix. In Alternatives 2 and 4 the entire occurrence could be treated. The acute scenario of 100% of the diet consisting of contaminated vegetation is not likely, because deer are not documented to rely on crupina for food. However, like the large dyer’s woad occurrence, some individual deer could be affected by 2, 4-D under Alternatives 2 and 4. Under Alternative 6, only the exterior satellites of the weed occurrence would be treated, so there would be no risk to mule deer because of the limited exposure. Under the Alternatives with Early Detection/Rapid Response activities, wildlife biologists would review new noxious weed treatment sites prior to implementation. If concerns for deer surface, (including conditions not covered within the analysis for the FEIS), additional Design Standards could be added. Mule deer are well distributed across the Modoc NF. Because only a few individual deer could be affected on three weed occurrences, implementation of Alternatives 2 through 6 would have no impact on the distribution of deer. Nor would there be any direct or indirect effects to the whole population of deer, because of the animal use patterns for these weed occurrences is outside of the time of greatest potential for risk. Cumulative Effects to Populations of Mule Deer Since there are no direct or indirect effects to the mule deer population , there would be no cumulative effects. The potential effects to pronghorn from herbicide use are as follows. There are 229 weed occurrences that are one acre or less out of a total of 237 weed occurrences within potential pronghorn habitat. These occurrences are small to the point where there would not be sufficient contaminated vegetation to cause acute or chronic effects. DH013ISTI (dyer’s woad), BV284ONAC (Scotch thistle), and BV001CRUV2 (Crupina) cause the greatest concern. DH013ISTI (dyer’s woad) accounts for 1,743.68 acres of the total in both herbicide and physical + . Although the 6,000-acre dyer’s woad occurrence is within potential antelope habitat, it is north and west of the areas of greatest pronghorn concentration and use. During his 22 years on the Forest, Mr. Irvin has seen a maximum of twelve individual sightings of pronghorn in this weed occurrence (J. Irvin, pers. comm.). Plus, pronghorn daily movements have been documented to range from 0.06 to 0.5 miles (Zeiner et al 1990), so they would not remain in an area to perpetually consume contaminated vegetation. Therefore, treatment of noxious weeds with herbicides will not affect pronghorn under Alternatives 2, 4 and 6.

Chapter 3—Affected Environment & Environmental Consequences 369 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

There are 157.89 acres of potential pronghorn habitat in BV001CRUV2 (Crupina). This weed occurrence, in reality, does not provide potential habitat and is typed as such, only because an artifact of the way the lines depicting potential pronghorn habitat were drawn (B. Turner, pers. comm.). Therefore, there would be no risk to pronghorn by the treatment of this occurrence under any Alternative. BV284ONAC consists of small pockets of Scotch thistle that run the length of Messenger Gulch; although 16.31 acres of this polygon are typed as potential pronghorn habitat, very little of the total polygon would be treated because of the diffuse density of the weed distribution within the entire weed occurrence. Under the Alternatives with Early Detection/Rapid Response activities, wildlife biologists will review new noxious weed treatment sites prior to implementation. If concerns for pronghorn surface, (including conditions not covered within the analysis for the FEIS), additional Design Standards could be added. Pronghorn are well distributed across the Modoc NF within potential habitat. Because only a few individuals could be affected in localized areas, implementation of Alternatives 2 through 6 would have no impact on the distribution of pronghorn. Nor would there be any direct or indirect effects to the whole population of pronghorn, because pronghorn use patterns occurring outside of the large weed occurrences. Cumulative Effects to Populations of Pronghorn Antelope Because there are no direct or indirect effects to pronghorn antelope, there are no cumulative effects to pronghorn antelope populations or distribution under any Alternative.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Mule Deer and Pronghorn Antelope The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for mule deer or pronghorn antelope. There would be no effect to mule deer or pronghorn populations by the implementation of any action Alternative. Therefore, the impact of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing Forest-wide population distribution trend for mule deer or pronghorn antelope. Osprey The osprey is both a terrestrial MIS as well as Species of Special Concern in California. Habitat - Species Relationship: Osprey habitat varies greatly, but common denominators are (1) adequate supply of accessible fish within 10–20 km of nest; (2) open nest sites, which are generally elevated (e.g., trees, artificial platforms, towers, or bluffs); (3) ice-free season sufficiently long to allow fledging of young. In the western U.S. (Idaho, California, Oregon), most pairs (80–95%) nest in trees; historically in northeastern California (Tule Lake), 250 to 300 pairs nested in tall yellow pines (Pinus ponderosa) and junipers; nests were 12 to 30 meters from the ground. Ospreys on the Modoc National Forest utilize snags, platforms, or other structures in pine and mixed conifer habitats to situate their nests. Microhabitat for foraging also varies greatly. Osprey forage along rivers, marshes, reservoirs, ponds and lakes, which have a ready supply of fish. Osprey are visual hunters; therefore, foraging is less successful in water with thick emergent and submerged vegetation. Reservoirs often provide ample expanses of shallow, clear water—ideal conditions for hunting. Live fish comprised at least 99% of prey items recorded in almost every published account with a wide

370 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

variety of fish species taken; osprey will also use birds, reptiles, small mammals, amphibians, and invertebrates (Zeiner et al. 1990a). Nesting ospreys are able to adapt to certain level of disturbance (Bent 1937 and Palmer 1988a in USDA Forest Service 1994). Other authors have found that osprey will abandon the nest, especially when the disturbance is unexpected (various authors in USDA Forest Service 1994). Modoc NF has standards and guidelines in the form of Limited Operating Periods to protect nesting osprey.

Project-level Effects Analysis based on Osprey Habitat Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no affect on habitat for osprey. Osprey utilize trees and snags for nests, and do not use noxious weeds for cover or food. The potential effects from the project are disturbance at the nest site and potential ingestion of contaminated prey. Analysis Area for Project-level Effects Analysis: The analysis area for osprey is limited to the 13,238 acres of occupied habitat within 0.5 miles of nest sites and an additional 1,419 acres of potential habitat on the Modoc National Forest. This habitat is located around the reservoirs and lakes on the Forest; the greatest density is on the Devil’s Garden and Big Valley Districts.

Alternatives 1 (Current Management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect to osprey habitat. There would be no change in the current or future amount of large trees or snags by the treatment of noxious weeds. Zero % of the current osprey habitat in the analysis area would be affected by implementation of Alternative 1. Cumulative Effects to Habitat Because there is no direct or indirect effect to osprey habitat, there are no cumulative effects to osprey habitat.

Alternatives 2 to 6 There are a maximum of 0.46 acres (0.03%) that may be treated with physical + or herbicide means within the 13,238 acres of occupied habitat Forest-wide. There are an additional 9.99 acres (0.7%) of (WM009CIAR4) (Canada thistle) in potential habitat. (Table below)

Table 3 - 102. Proposed Treatment within Potential Osprey Habitat

Total Acres of Total Maximum Acres Total Maximum Acres of Species Habitat of Physical + Herbicide Treatments Forest- wide Treatments* Osprey – Occupied 13,238 0.46 0.46 Osprey - Potential 1,419 9.99 9.99

* This figure includes the maximum, where physical + or herbicide methods may be employed. The WM009CIAR4 (Canada thistle) occurrence consists of old beaver ponds that are mostly sedimented into meadow habitat and do not contain fish (M. Yamagiwa, pers. comm.). They were

Chapter 3—Affected Environment & Environmental Consequences 371 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

typed as potential osprey habitat, due to an artifact in the data set. Therefore, there will be no effect to osprey in treating this weed occurrence. No nest trees or nesting habitat would be removed under any action Alternative. Prey habitat should benefit from the treatment of weeds, because weeds in riparian habitats may cause increased sedimentation. Purple loosestrife (Lythrum salicaria), tall whitetop (Lepidium latifolium), and Canada thistle (Cirsium arvense) have the potential to locally contribute to unstable stream banks. Not only do species like tall whitetop exclude native species, but these species do not have root systems that withstand erosive forces of water, and could allow increased sedimentation into creeks as well as loss of bank habitat (www.cal-ipc.org; FEIS invasive plant database; Bossard, Randal, and Hoshovsky 2000). However, the beneficial effects to osprey habitat Forest-wide are small at this point; therefore, there would be no direct or indirect effect to osprey habitat by implementation of Alternatives 2 through 6. Cumulative Effects to Habitat Because there is no direct or indirect effect to osprey habitat, there are no cumulative effects to osprey habitat.

Summary of Osprey Population Status and Trend at the Forest Scale The Modoc NF Forest Plan (as amended by the SNFPA) requires Forest-scale distribution population monitoring for osprey. The sections below summarize population status and trend data for these species. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Population Status and Trend at the Bioregional Scale In California, the current osprey range is expanding south of San Francisco Bay along the southern limit of its range in western California and southward into the Sierra Nevada. California- wide BBS data for the period of 1966 to 2004 classifies osprey as “Definitely increasing” (Siegel and DeSante 1999), with a significant increase of 6.6% (range 2.3 to 10.9) per year over the 33 routes. At the Sierra Nevada scale, for the period of 1966 to 2004, Sierra Nevada-wide BBS data classifies osprey as “possibly increasing” (Siegel and DeSante 1999), with an increase of 33.6% (range 15.4 to 51.8%) per year over 5 routes. This trend is consistent with trends observed at the State and Survey-wide scales. Nest locations to date have been derived through a combination of incidental sightings, intensive nest stand searches, and BBS data. At the time of preparation, the Forest Forest Plan FEIS described the Forest as having seven active nesting territories (USDA 1991b). Currently, there are at least 14 territories, or twice the number that occurred in 1991.

Effects of the Alternatives on Osprey The only direct effect from physical + and herbicide treatments is the potential for disturbance to nesting osprey; literature has documented instances where osprey will abandon nests, if the activity is outside of their usual experience. The Modoc Forest Plan allows for up to 0.5 mile Limited operating periods around active nests sites. Pre-treatment surveys and Limited operating periods for active nest sites will take care of potential disturbance effects on nesting osprey. There is a small potential for herbicides getting into adjacent reservoirs and streams, thereby contaminating water and potentially harming fish in occupied osprey habitat; fish are the osprey’s dietary staple. The direct effects to fish and their habitat would be short-term (especially in a stream situation) as well localized in small patches (0.09 acres is the largest weed occurrence

372 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

size). The use of treatment buffers and a spill plan should minimize this potential harm to prey. Regardless, treatment with herbicides on 0.26 acres Forest-wide would not cause 10 to100% of an osprey’s diet to consist of contaminated fish. Under the Alternatives with Early Detection/Rapid Response treatments, new occurrences would be reviewed by wildlife biologists prior to implementation. All weed occurrence implementation sites would need to meet fish habitat and water quality standards, and therefore would be limited in acre size; in addition, treatment buffers adjacent to water, as per the Best Management Practices (BMPs) and Design Standards, will add extra protection. If treatment of new occurrences is outside of the conditions examined under the Noxious Weeds Treatment FEIS, additional Design Standards could be added.

Cumulative Effects to Populations Because there are no direct or indirect effects to osprey populations, there are no cumulative effects to osprey populations.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Osprey The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for osprey. Nor will there be any potential effect to the population for osprey. Therefore, the implementation of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing Forest-wide population distribution trend for osprey. Red-breasted and Red-naped Sapsuckers Red-breasted and red-naped sapsuckers are both terrestrial MIS, as well as a non-game species in California. Both red-naped and red-breasted sapsuckers were selected as Management Indicator Species for the Forest, because of “their affinity for snags or live trees with heart rot in or near riparian zones”. Both species prefer hardwoods for feeding and reflect the management of hardwood vegetation within riparian zones (US Forest Service 1991b. Page 3-110).

Habitat - Species Relationship Habitats used by red-breasted sapsucker include riparian, deciduous hardwood and various conifer stands, especially those stands adjacent to meadows, lakes, and slow-moving streams (Zeiner et al. 1990a). “[The red-breasted sapsucker] frequents sparse to moderate canopy with suitable snags for nest and roost excavation, especially in the vicinity of aspens, wet meadows, clearings, lakes, and other open habitats (Zeiner et al. 1990a)”. Data from Dr. Laudenslayer’s study on the Modoc National Forest showed red-breasted sapsuckers nesting in dry, open east- side pine stand, with few pine snags and juniper in the understory in addition to riparian habitats. Red-breasted sapsuckers forage mainly on deciduous hardwoods (Zeiner et al. 1990a), but sometimes conifers in east-side pine in northeastern California (Oliver 1970). The birds eat sap, cambium, and other tree tissues as well as arthropods (Zeiner et al. 1990a). Insects are gleaned or caught using a “fly catch” technique (Walters et al. 2002). Territory size was up to 15 acres around nest sites. Habitat types used by red-naped sapsuckers include mixed conifer, aspen, and montane riparian habitats, especially those areas with aspen, willow, and cottonwood (Zeiner et al. 1990). Although they will use a variety of trees including conifers, they “apparently prefer to nest in aspen and montane riparian habitats”; they also require snags or live trees with rot for excavating cavities

Chapter 3—Affected Environment & Environmental Consequences 373 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

(Zeiner et al. 1990a, Daily 1993). On the Humboldt-Toiyabe National Forest, red-naped sapsuckers used aspen more than any other habitats (Warkentin and Reed 1999). Red-naped sapsuckers appear to be omnivorous, foraging on insects and sap (Crockett and Hadow 1975); Zeiner et al. (1990a) also included berries in their diet. In Colorado, red-naped sapsuckers made wells in willows, where large sections of the bark were torn down to the cambium (Ehrlich and Dailey 1988). A study conducted in northwestern Montana found that sapsuckers were almost entirely dependent on conifer sap in the spring when they first arrive on site; the sap from aspen and birch is not important until after these species leaf out. Insects are not abundant in their diets’ until later in the season (Tobalske 1992). Territory size was up to 15 acres around nest sites.

Project-level Effects Analysis based on Sapsucker Habitat Key Habitat Factor(s) for the Analysis The proposed project, the removal of noxious weeds from Forest System Lands, will have no affect on riparian hardwood habitat, which is important for both sapsucker species. Neither species is known to use noxious weeds for cover or food. The main potential effect is limited to the potential consumption of herbicide contaminated insect and plant materials. Analysis Area for Project-level Effects Analysis: The analysis area for red-breasted sapsucker is limited to the 107,300 of potential habitat on the Forest. These conifer stands are scattered throughout the Warner Mountain Ranger District Forest. In addition, they are concentrated in the portions of the Big Valley, Devil’s Garden, and Doublehead Districts. The analysis area for the red-naped sapsucker is limited to 45,600 acres of potential habitat on the Forest. Habitat is located in proximity to aspen stands. In general, the areas are concentrated on the Warner Mountain Ranger District, with a few scattered pockets in other portions of the Forest.

Alternative 1 (Current Management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect on habitat for either sapsucker. There would be no change in the current or future amount of snags by the treatment of noxious weeds. There would be little if any change in the amount of willows and aspen. Zero % of the current red-breasted or red-naped sapsucker habitat in the analysis area would be affected by implementation of Alternative 1. Cumulative Effects to Habitat Because there is no direct or indirect effect to red-breasted or red-naped sapsucker habitat, there are no cumulative effects to habitat for either species of sapsucker under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat There are a maximum of 51.35 acres out of 107,300 acres (0.048%) where physical + treatments of potential red-breasted sapsucker habitat Forest-wide could occur (13). There are a maximum of 49.93 acres (0.047%), where herbicide treatments may be applied within potential red-breasted sapsucker habitat Forest-wide. There are a maximum of 14.7 acres out of 45,600 acres (0.032%)

374 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

where physical + or herbicide treatments could be applied within potential red-naped sapsucker habitat Forest-wide (Table below).

Table 3 - 103. Proposed Treatment within Potential Red-breasted and Red-naped Sapsucker Habitat

Total Acres of Total Maximum Acres Total Maximum Acres of Species Potential Habitat of Physical + Herbicide Treatments* Forest-wide Treatments* Red-breasted Sapsucker 107,300 51.35 49.93

Red-naped Sapsucker 45,600 14.7 14.7

* This figure includes the maximum, where physical + or herbicide methods may be employed. Implementing weed treatments under Alternatives 2 through 6 would have no effect on red- breasted or red-naped sapsucker habitat. There will be no change in the current or future amount of snags for nesting or foraging trees, nor will there be any change in the amount of shrubs for foraging under implementation of any action Alternative. Aspen and meadow habitat could be stable to improved by the implementation of any action Alternative in very small areas, because the treatment decreases the competition to native species by noxious weeds. Just like the hairy and pileated woodpeckers, the sapsuckers spend their time foraging in trees and willows. According to Walters et al. (2002), foraging red-breasted sapsuckers in a California study spent 73% of their time in trees, 21% on snags, 3% on logs, 1% on the ground and 1% in the air. Since native trees and shrubs will remain as part of this FEIS, there will be little if any change to potential prey habitat by implementation of any Alternative. Therefore, there will be no direct or indirect effects to habitat for either sapsucker under any action Alternative. Cumulative Effects to Habitat Because there are no direct or indirect effects to red-breasted or red-naped sapsucker habitat, there are no cumulative effects to habitat for either sapsucker species under these Alternatives.

Summary of Sapsucker Population Status and Trend at the Forest Scale The Modoc NF Forest Plan (as amended by the SNFPA) requires Forest-scale distribution population monitoring for both sapsuckers. The sections below summarize population status and trend data for the red-breasted and red-naped sapsucker. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007a), which is hereby incorporated by reference.

Sapsucker Population Status and Trend at the Bioregional and Local Scales Population monitoring data collected by various partners at the bioregional scale indicate that red- breasted sapsuckers as “possibly decreasing” (Siegel and DeSante 1999), with a non-significant decrease of -3.18% (range -7.8 to 1.6%) per year for the Sierra Nevada. Population trends have also been evaluated using the Institute for Bird Populations’ Monitoring Avian Productivity and Survivorship program (MAPS), which oversees a nationwide dataset of mist-netting stations. MAPS data for red-breasted sapsucker between 1992-2001 for the entire Northwest region, (which includes 12 MAPS stations in the Sierra Nevada) showed an average 2-year population change of 0.28% (s.e.= 7.3). These data infer that red-breasted sapsucker populations across most of their range may be stable.

Chapter 3—Affected Environment & Environmental Consequences 375 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Red-breasted sapsuckers have been detected from 1910 to the present during various surveys on the Modoc NF. Historical records of specimens collected from the Berkeley Natural History Museum date back to 1910 and the 1940’s. More recently, red-breasted sapsucker presence/absence on the Modoc National Forest has been noted under the following efforts: project-generated stand searches conducted for various species, the Pacific Southwest Research Station (PSW) cavity nesting bird study (Laudenslayer 2002), and during province and Forest level surveys for willow flycatcher. The distribution for red-naped sapsuckers is the same as during the Modoc Forest Plan. California has only a small sliver of the red-naped sapsucker range in North America. According to BBS staff biologists, there has only been one red-naped sapsucker sighting for California. This sighting was west of the Modoc NF. Siegel and DeSante (1999), who used BBS data as part of their conservation assessment, also stated that there was insufficient data to determine a trend for red-naped sapsucker for the Sierra Nevada. However, there is an increase in the trend of the red- naped sapsucker data for 1966 to 2003 in a large portion of the red-naped sapsucker range. Red-naped sapsuckers have been sighted infrequently on the Modoc National Forest; the majority of the sightings are on the Warner Mountain Ranger District. Red-naped sapsuckers have been detected during stand searches conducted for various projects, the Pacific Southwest Research Station (PSW) cavity nesting bird study (Laudenslayer 2002), and project-level surveys for willow flycatcher. In addition, there are historical records of specimens collected from the Modoc NF at the Berkeley Natural History Museum. In the PSW study, red-naped sapsuckers were detected at various locations on the Modoc NF, however, no nest sites were found. The distribution for red-naped sapsuckers is basically the same as during the Modoc Forest Plan.

Effects of the Alternatives on Sapsuckers There is very little chance of either species receiving a large enough dose of contaminated vegetation or insects to cause a risk to individual birds for the following reasons. They forage mainly on trees, willows, and snags. Most of the weed occurrences within potential habitat red- breasted or red-naped sapsuckers are less than an acre; therefore, it would be unlikely that 10 to 30% of their diet would be in contaminated materials. The larger occurrences, where there is a greater likelihood of contamination are discussed below. The weed occurrences in potential red- breasted sapsucker habitat are followed by the red-naped weed occurrences.

Red-breasted sapsucker occurrences BV006LIDA (Dalmatian toadflax) – The majority of the area is lava reef country with open conifer stands. Under Alternatives 2 and 4, there are 4.55 acres within potential red-breasted sapsucker habitat in the entire 850 acre toadflax occurrence that could be treated. This 4.55-acre area would be included in one territory or 0.004% of the potential red-breasted sapsucker habitat on the Forest. It is highly unlikely that insects would climb from a weed onto an adjacent tree or willow and be ingested, because the insects tend to utilize specific types of plants (e.g., insects like carpenter ants utilize wood fiber and would not tend to concentrate on herbaceous weeds). Moreover, the toadflax has a patchy distribution consisting of small clumps weeds within a matrix of native plants, so herbicides would not be applied to a 4.55-acre block. Given their feeding preferences and the diffuse nature of the toadflax within the occurrence, it is unlikely to the point of being discountable that there would be any effect to red-breasted sapsuckers by implementation of Alternative 2 or 4. Under Alternative 6, only the exterior satellites of the weed occurrence would be treated, so there would be no risk to red-breasted sapsucker under this Alternative.

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WM003LIDA (Dalmatian toadflax) – As stated under the hairy woodpecker discussion, this occurrence actually encompasses a series of very small patches. Although there are 20.26 acres of potential red-breasted sapsucker habitat, only about one acre of potential habitat would be treated. Consequently, the chance of a red-breasted sapsucker consuming 10 to 30% of its diet from treated plants would be remote under Alternatives 2, 4 and 6. BV001CRVU2 (Crupina) – The area along Post Canyon had crupina present along the road into conifer at various levels of infestation. The largest concentrations were at the lower end of the canyon in the open sage habitats. Other plants, both native and exotic, are within the matrix. In Alternatives 2 and 4, the entire occurrence could be treated. There are 12.96 acres of potential red-breasted sapsucker habitat that could be treated. This could equate to one territory. Most of the insects would not cross over from herbaceous weeds to snags and logs. In addition, crupina does not provide a fruit that would be ingested either. Given the red-breasted sapsuckers’ feeding preferences, implementation of Alternatives 2 or 4 are not expected to affect this sapsucker. Under Alternative 6, only the exterior satellites of the weed occurrence would be treated, so there would be no risk to red-breasted sapsucker. BV302ONAC (Scotch thistle) – The site is within mixed conifer habitat with a high degree of incense cedar. Many of the trees are small diameter (sapling and pole sized) (J. Landoski, pers. comm.), and would not be considered prime potential red-breasted sapsucker habitat. According to the database, there are only 40 plants, so the potential for contamination of a large part of a sapsucker’s diet would also be low. Given that only 2.41 acres of potential red-breasted sapsucker could be treated, the low suitability of the area for sapsuckers, and the low number of weeds to be treated, use of herbicides are not expected to have any affect to red-breasted sapsucker under any Alternative for this weed occurrence. WM009CIAR4 (Canada thistle) – Although the beaver degraded this site, there could be potential red-breasted sapsucker in close juxtaposition to contaminated insects. The sapsuckers would not forage on thistles, but ants could be sprayed and move onto willows, where they could be consumed by sapsuckers. Assuming that a potential territory encompasses 15 acres, 3.21 acres or 21.4% of a potential territory could be treated. Clopyralid would be the preferred herbicide for treatment under Alternatives 2, 4 and 6; the hazard quotient for a small bird consuming insects is less than 1.0, so the risk of toxic effects to birds is small. Design Standard DS-12b would limit the use of 2, 4-D on the site, thereby further minimizing the potential for toxic effects to this species. Under the Alternatives with Early Detection/Rapid Response activities, wildlife biologists would review new noxious weed treatment sites prior to implementation. If concerns for red-breasted sapsuckers surface (including conditions not covered within the analysis for the FEIS), additional Design Standards could be added. To summarize, the use of herbicides will have discountable effects to single red-breasted sapsuckers and will have no direct or indirect effect on the distribution and population of red- breasted sapsucker on the Modoc National Forest for the following reasons. One, only a small amount of potential red-breasted sapsucker habitat is scheduled to be treated (even in the largest weed occurrences). Two, the treatment consists of spraying weeds not preferred foraging structures (trees, snags, logs, and willows). Three, prey should be largely unaffected, because there would be a small amount of insect migration from weeds to woody structures. Finally, the lower hazard quotient rating for herbicides scheduled for use. Cumulative Effects to Populations: Because there are no direct or indirect effects to red-breasted sapsucker population and distribution , there are no cumulative effects to red-breasted sapsucker population or distribution under any Alternative.

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Occurrences within potential red-naped sapsucker habitat and potential effects to this species by their treatment. WM004ONAC (Scotch thistle) – The vegetation on this site is dominated by a pine plantation with most trees about 20 to 30 feet tall and is not considered red-naped sapsucker habitat. The vegetation understory was generally sparse consisting of shrubs, forbs and grasses. Therefore, implementation under Alternatives 2, 4 and 6 are not expected to effect red-naped sapsucker for this site. WM009CIAR4 (Canada thistle) – The beaver severely degraded this potential red-naped sapsucker habitat site, so there is little chance for red-naped sapsucker to consume contaminated insects. Clopyralid would be the preferred herbicide for treatment under Alternatives 2, 4 and 6; the hazard quotient for a small bird consuming insects is less than 1.0, so the risk of toxic effects to birds is small. Design Standard 12b would limit the use of 2, 4-D on the site, thereby further minimizing the potential for toxic effects to this species. Therefore, treatment of this site is not expected to effect red-naped sapsucker under any Alternative. Under the Alternatives with Early Detection/Rapid Response activities, wildlife biologists would review new noxious weed treatment sites prior to implementation. If concerns for red-naped sapsuckers surface (including conditions not covered within the analysis for the FEIS), additional Design Standards could be added. Cumulative Effects to Populations: Because there are no direct or indirect effects to red-naped sapsuckers, there are no cumulative effects to red-naped sapsucker populations or distribution under any Alternative.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Red-naped and Red-breasted Sapsucker The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for either sapsucker species. There is the potential effect to one potential red-breasted sapsucker territory and no red-naped sapsucker territories. Therefore, the impact of the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing Forest-wide population distribution trend for red-breasted or red-naped sapsucker. Western Gray Squirrel The western gray squirrel is a terrestrial MIS, as well as a game species in California. Habitat - Species Relationship: Habitat for this species includes dense stands of large trees and snags with abundant cavities and food, preferably near water; the authors went on to state that this species “require large trees, mast, and snags” (Zeiner et al. 1990). In the Mammalian Species Number 474: Sciurus griseus, they noted that gray squirrels utilize various habitats that have oaks (Carraway and Verts 1994). These authors also noted that gray squirrel’s use cavities that have been excavated by woodpeckers for raising young. Squirrels were found to prefer areas with a patchy understory that had a greater diversity of food producing trees and shrubs (Ryan and Carey 1995). These stands also needed to have connected tree canopies to allow arboreal travel especially within 66 yards of the nest (Ryan and Carey 1995). There are 1,447 acres of oak and an additional 125,473 acres of mixed conifer habitat on the Modoc N.F. that were modeled as potential habitat. Food studies conducted in part in Shasta and Tehama Counties noted that squirrels mainly used hypogeous fungi and acorns, as well as a variety of plant and animal matter (Stienecker 1977,

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Stienecker and Browning 1970). A study in Oregon found that gray squirrels used conifer seeds; some of the cones were cached for winter (Carraway and Verts 1994).

Project-level Effects Analysis based on Habitat Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no affect on oak habitat for western gray squirrel; gray squirrel are not reliant on noxious weeds for cover or food. The main potential effect is limited to the potential consumption of herbicide contaminated plant and insect materials by gray squirrel. Analysis Area for Project-level Effects Analysis: The analysis area for western gray squirrel is limited to the 126,920 acres of potential habitat on the Forest. The highest-quality oak habitat is limited to the Big Valley and Devil’s Garden Districts. The low-incidence habitat is found on the Warner Mountain and Big Valley Districts.

Alternative 1 (Current Management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use of herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect on gray squirrel habitat. There will be no change in the current or future amount of oaks, which are a primary focus of the Forest Plan Standards and Guidelines for squirrel habitat. Nor will there be any change in the amount of large trees, which provide food and cover. Zero % of the current western gray squirrel habitat in the analysis area would be affected by implementation of Alternative 1. Cumulative Effects to Habitat Because there is no direct or indirect effect to western gray squirrel habitat, there are no cumulative effects to squirrel habitat under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat There were no noxious weed occurrences within the oak polygons found throughout the Forest, which is the habitat with the greatest amount of squirrels. Tree cavities and dreys would not be removed under any action Alternative. There is a maximum of 47.3 acres (0.038%) that could be treated with herbicides in low-incidence potential squirrel habitat (Table 3-85, below).

Table 3 - 104. Proposed Treatment within Low-Incidence Potential Gray Squirrel Habitat

Total Acres of Potential low Total Maximum Acres of Total Maximum Acres of incidence Habitat Forest- Physical + Treatments* Herbicide Treatments* wide 125,473 47.69 47.3

* This figure includes the maximum, where physical + or herbicide methods may be employed According to food studies completed in northern California, the following foods were the highest volume in the samples: fungi, acorns, pine nuts, insects, and green vegetation (forbs) (Stienecker 1977, Stienecker and Browning 1970). Fungi, acorns, and pine nuts would not be affected by herbicides or physical + treatments of weeds. The removal of noxious weeds would not affect potential insect prey habitat, because there are currently no native insects that require weeds for

Chapter 3—Affected Environment & Environmental Consequences 379 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

food or cover. In addition, sufficient native plants exist outside of the boundaries of the current weed occurrences to provide forbs for insects and squirrels. Therefore, there will be no direct or indirect effects to western gray squirrel habitat by implementation of any Alternative. Cumulative Effects to Habitat Because there are no direct or indirect effects to western gray squirrel habitat, there are no cumulative effects to gray squirrel habitat under these Alternatives.

Summary of Western Gray Squirrel Population Status and Trend at the Forest Scale The Modoc NF Forest Plan (as amended by the SNFPA) requires Forest-scale distribution population monitoring for western gray squirrel. The sections below summarize population status and trend data for the gray squirrel. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Western Gray Squirrel Population Status and Trend at the Bioregional and Local Scales Western gray squirrel is “S4, Apparently Secure” (“Uncommon but not rare; some cause for long- term concern due to declines or other factors”) in California (NatureServe 2006). With respect to northeastern California, Fish and Game personnel believe the gray squirrel population seems to be stable (Tim Burton and Scott Hill, pers. comm.). Richard Shinn noted that locally in Modoc County, the squirrel populations receive little hunting pressure (R. Shinn, pers. comm.). Dr. Laudenslayer is currently working with mammalogists from San Jose State University to determine if there has been a range extension of grey squirrels into Surprise Valley (east of the Modoc National Forest). Data for gray squirrel on the Forest consists of series of incidental sightings data. Gray squirrels have been observed almost entirely in oak habitat on the Modoc National Forest. There are a few sightings in pine stands on the Devil’s Garden Ranger District and a few sightings in higher- elevation mixed conifer habitats of the Big Valley and Warner Mountain Districts (George Studinski, Ken Romberger, and M. Flores, pers. comm). Gray squirrels have not been detected during mammalian surveys conducted at several locations on the Warner Mountain District by San Jose State University staff (J. Matson, pers. comm.). The vast majority of the gray squirrel observations east of the oak habitat on the Modoc NF have been in Surprise Valley (B. Laudenslayer, pers. comm.).

Effects of the Alternatives on Western Gray Squirrels Direct and Indirect Effects Under Alternatives 3 and 5 (non-herbicide Alternatives), as well as the physical + treatment aspects of Alternatives 2, 4, and 6, there would be no potential ingestion of contaminated materials. The potential for ingestion of enough contaminated material to cause an effect to gray squirrel population would a very minor for the following reasons. First, there are no weed occurrences in the oak habitats, where the highest density of squirrels exist. Second, conifer, fungal materials, and native plants would remain on site. Finally, the largest weed occurrences within the low- incidence gray squirrel habitat are found on the Warner Mountains, where there are few gray squirrels.

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There is a maximum of 47.0 acres (0.038%) in low-incidence gray squirrel/conifer habitat, which could be treated with herbicides Forest-wide. There have been no gray squirrels detected in the largest weed occurrences (WM001ISTI, WM002ISTI, WM003ISTI, WM004ISTI, and WM005ISTI – [dyer’s woad] and WM009CIAR [Canada thistle]). The rest of the occurrences in potential low-incidence squirrel habitat are small and scattered. It is not likely that 10 to 100% of a gray squirrel’s diet would consist of contaminated vegetation, because of the low density of squirrels on the Warner Mountain District in addition to the gray squirrels’ feeding preferences (which do not appear to include weeds). Under the Alternatives with Early Detection/Rapid Response activities, which wildlife biologists would review, prior to implementation; if concerns for western gray squirrel surface, additional Design Standards could be added, if weed treatment areas were outside of the conditions analyzed within the FEIS. To summarize, the use of herbicides will have no direct or indirect effect on the distribution and population of gray squirrel on the Modoc National Forest for the following reasons. One, only a small amount of potential gray squirrel habitat is scheduled for treatment, and it is outside of the area of known occupancy. Two, the treatment consists of spraying weeds, not preferred foraging and reproductive structures. Three, food should be largely unaffected, because their foraging preferences. Cumulative Effects to Populations Since there are direct or indirect effects to western gray squirrels, there are no cumulative effects to western gray squirrel population or distribution.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Western Gray Squirrel The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for western gray squirrel. There are no potential effects to the squirrel population. Therefore, the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing Forest-wide population distribution trend for western gray squirrel. Yellow Warbler The yellow warbler is a terrestrial MIS as well as a Species of Special Concern in California. Habitat - Species Relationship: Yellow warblers are found in various shrubby riparian areas in localized areas throughout the Forest. General habitat for yellow warblers includes both open- canopy riparian woodlands in addition to open conifer stands with substantial amounts of shrubs in the understory (Zeiner et al. 1990). King et al. (2001) found that yellow warblers on the Lassen National Forest and Lassen Volcanic National Park utilized “encroaching” lodgepole pine near meadows for nesting, perching, and singing. During the breeding season, open- to medium- density woodlands and Forests with a dense shrub understory are frequently used (Zeiner et al. 1990). Yellow warblers forage in trees and shrubs; the males tended to forage in areas that were less dense, presumably to be more visible to aid in territory boundary defense (Busby and Sealy 1979). A study in Utah found that they never foraged on the ground; a similar study in Wyoming found that they foraged on the ground about 4% of the time (Lowther et al. 1999). Numerous authors have found that their diet is composed of arthropods; the diet varied based on the type of prey available (Busby and Sealy 1979; Lowther et al. 1999).

Chapter 3—Affected Environment & Environmental Consequences 381 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Project-level Effects Analysis based on Habitat Key Habitat Factor(s) for the Analysis: The proposed project, the removal of noxious weeds from Forest System Lands, will have no effect on riparian habitat for yellow warbler; yellow warblers are not reliant on noxious weeds for cover or food. The main potential effect is limited to the potential consumption of herbicide contaminated insect materials by yellow warbler. Analysis Area for Project-level Effects Analysis: The analysis area for yellow warbler is 53,000 acres of potential habitat Forest-wide. The habitat is distributed throughout the Big Valley and Warner Mountain Districts, with a few localized areas on the Devil’s Garden and Doublehead Districts.

Alternative 1 (Current Management) Direct and Indirect Effects to Habitat The Forest Service currently treats 20 to 30 acres a year by physical + methods. Currently, the Forest does not use herbicides to treat noxious weeds. Implementing weed treatments under Alternative 1 would have no effect on yellow warbler habitat. There would be no change in the riparian vegetation consisting of shrubs and trees that comprise nesting and foraging habitat. Zero % of the current yellow warbler habitat in the analysis area would be affected by implementation of Alternative 1. Cumulative Effects to Habitat Because there is no direct or indirect effect to yellow warbler habitat, there are no cumulative effects to yellow warbler habitat under this Alternative.

Alternatives 2 to 6 Direct and Indirect Effects to Habitat A maximum of 0.2 acres (0.0004%) Forest-wide could receive physical + or herbicide treatments within potential yellow warbler habitat.(Table below) These warblers nest in trees and shrubs, so no nesting habitat would be removed under any action Alternative. A study in Utah found that they never foraged on the ground; a similar study in Wyoming found that they foraged on the ground about 4% of the time (Lowther et al. 1999). Prey habitat would not be affected, because there are currently no native insects that are reliant on weeds for food or cover. Moreover, sufficient native plants exist outside of the boundaries of the current weed occurrences to provide food and cover for prey. Therefore, no foraging habitat would be removed with implementation of any action Alternative. Since there will be no direct or indirect effect to nesting and foraging habitat, there will be no direct or indirect effect to yellow warbler habitat by the implementation of any Alternative.

Table 3 - 105. Proposed Treatment within Potential Yellow Warbler Habitat

Total Acres of Potential Total Maximum Acres of Total Maximum Acres of Habitat Forest-wide Physical + Treatments* Herbicide Treatments* 53,000 0.2 0.2

* This figure includes the maximum, where physical + or herbicide methods may be employed

382 Chapter 3—Affected Environment & Environmental Consequences Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Cumulative Effects to Habitat Because there are no direct or indirect effects to yellow warbler habitat, there are no cumulative effects to yellow warbler habitat under these Alternatives.

Summary of Yellow Warbler Population Status and Trend at the Forest Scale The Modoc NF Forest Plan (as amended by the SNFPA) requires Forest-scale distribution population monitoring for yellow warbler. The sections below summarize population status and trend data for the yellow warbler. This information is drawn from the detailed information on population trends in the Modoc National Forest MIS Report (USDA 2007b), which is hereby incorporated by reference.

Yellow Warbler Population Status and Trend at the Bioregional and Local Scales Yellow warbler has been monitored throughout California. California-wide BBS data for the period of 1966 to 2004 classify yellow warbler as “possibly decreasing” (Siegel and DeSante 1999), with a non-significant decrease of -1.4% (range -3.3 to 0.4) per year. The Regional Credibility ranking is “Blue” (“data with larger sample size, at least moderate precision, and at least moderate abundance on routes”). The Christmas Bird Count for California data shows huge annual fluctuations in the yellow warbler numbers, but that the overall trend has increased. At the Sierra Nevada scale for the period of 1966 to 2004, Sierra Nevada-wide BBS data classifies Yellow warbler as “possibly decreasing” (Siegel and DeSante 1999) with a non- significant decrease of -2.4% (range -6.2 to 1.5%) per year. The Regional Credibility ranking is “Blue” (“data with larger sample size, at least moderate precision, and at least moderate abundance on routes”). Yellow warblers have been sighted on the Modoc National Forest from 1910 to the present. This species is found sporadically in riparian areas containing a variety of shrub species throughout the Forest. Presence data has been collected as part of surveys for avi-fauna conducted in the early part of the century (1910 survey by Taylor and Bryant; 1920 survey by White), a series of incidental sightings by biologists and technicians, surveys conducted for the Tuscarora Pipeline Project, and during riparian point counts run for willow flycatcher. Yellow warbler appears to be distributed in various areas across the Forest similar to the pattern discussed in the Modoc Forest Plan.

Effects of the Alternatives on Yellow Warblers Direct and Indirect Effects Forest-wide a maximum of 0.2 acres could receive herbicide or physical + treatments. Under Alternatives 3 and 5 (non-herbicide Alternatives) as well as the physical + treatment aspects of Alternatives 2, 4, and 6, there would be no potential ingestion of contaminated materials. The effects discussed below pertain to herbicide treatments considered under Alternatives 2, 4 and 6. According to the literature, yellow warblers feed on insects taken from shrubs and trees, although there is a low risk of gathering contaminated insects from the ground. Given that there are only 0.2 acres out of 53,000 acres (0.0004%) of potential habitat Forest-wide that could receive herbicides treatments and the fact that this species mainly gleans insects from trees and shrubs, direct and indirect effects are too small to the point of being discountable.

Chapter 3—Affected Environment & Environmental Consequences 383 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

For the small bird consuming contaminated insects scenario, 2, 4-D (alone or in a tank mix), Dicamba, and the surfactant NPE all exceed hazard quotient ratings of 1.0. Neither of the two weed sites would be treated with 2, 4-D under Alternatives 2 and 4, because they both lie within 1,000 feet of water. Under Alternative 6, any of the herbicides could be used. However, the assumption behind this scenario is that 100% of the diet consists of contaminated insects. Given the small size of the weed occurrence and their foraging preferences, this potential effect is small to the point of being discountable. Under the Alternatives with Early Detection/Rapid Response activities, new occurrences would be reviewed by wildlife biologists prior to implementation; all weed-occurrence implementation sites would need to meet water quality standards, and therefore will be limited in acre size as per the Best Management Practices (BMPs) and Design Standards. Consequently, there are inconsequential direct and indirect effects to individual yellow warblers and no direct or indirect effects to the yellow warbler distribution or population by the implementation of any Alternative. Cumulative Effects to Populations Since there are no direct or indirect effects to the yellow warbler distribution or population on the Forest, there are no cumulative effects to yellow warbler population.

Relationship of Project-Level Impacts to Forest-Scale Habitat and Population Trends for the Yellow Warbler The cumulative effects of the Action Alternatives of the Noxious Weeds Project will result in no decrease in Forest-wide habitat for yellow warbler. There are also no potential effects to the Modoc NF yellow warbler population. Therefore, the Noxious Weeds Project will not alter the existing Forest-wide trend in habitat, nor will it change the existing Forest-wide population distribution trend for yellow warbler. Terrestrial Invertebrates Terrestrial invertebrates are important components of Forest and rangeland ecosystems. They serve many vital roles, including pollinating plants, enriching and aerating soils, and serving as food items for many larger species of animals. The diversity of invertebrate species on the Modoc National Forest probably includes thousands of species, but little is known about their identities, local distributions or abundance. Public comment was received concerning the potential impacts of the proposed herbicide use on terrestrial invertebrates. It is difficult to evaluate the impacts of weed treatments to invertebrate populations on the Modoc National Forest for several reasons. Information on distribution of species across the Forest is lacking, especially for less collectable invertebrates. For example, no information on the distribution or even the species of earthworms present on the Modoc National Forest could be found. Various species of earthworms have been reported in coniferous forests, aspen groves, grassland/shrubland, pastures and cultivated lands (Gonzalez et al. 2003 and James 2000). However, in the Columbia Basin, Fender, in an undated personal communication with James (1995), reportedly believes areas of bitterbrush, juniper, and sagebrush lack earthworms. Due to the lack of specific information it must be assumed that earthworms, either native or introduced, exist on the Forest on all sites with sufficient soil. Arid sites with very shallow soils quite likely lack earthworms. Other issues contributing to the difficulty of evaluating impacts of weed treatments on invertebrate populations including the following. Invertebrates are a highly diverse group, some with hard, dry, protective exoskeletons, while others have soft, moist skins. No doubt their physiologies and their sensitivities to habitat disruption and herbicides vary widely. And finally,

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the published research that has been done on the impacts of herbicides on a relatively limited number of invertebrate species may not be representative of the thousands of species that are assumed to inhabit the Forest. The analysis below expands on the DEIS and responds to the concern that the Forest should analyze the impacts to invertebrates.

Direct and Indirect Effects

Alternative 1 (The No Action Alternative) Managing the Forest under this Alternative would result in unimpeded encroachment by noxious weeds, including species currently found on the Forest and new species likely to appear on the Forest in the future. These noxious weeds would compete with native plant communities on which many native invertebrate species depend. This may adversely affect some individual terrestrial invertebrates but is unlikely to affect populations of invertebrate species.

Alternatives 3 & 5 (The No Herbicide Alternatives) Alternatives 3 and 5 rely on physical + and cultural methods to control or eradicate noxious weed infestations. These control methods would result in disturbance of the soil surface, alteration of the habitat of invertebrates, and temporary disruption of food sources for terrestrial invertebrate species. These impacts may adversely affect some individual terrestrial invertebrates, but are not expected to adversely affect terrestrial invertebrate populations.

Alternatives 2, 4 and 6 (The Herbicide Alternatives) Alternatives 2, 4 and 6 rely on a combination of physical + , cultural and herbicide treatment methods to control or eradicate weed infestations. In addition to the possible direct and indirect effects of physical/cultural methods listed above, the possible effects on terrestrial invertebrates include death or injury due to toxic effects of herbicides, alteration of habitat by herbicides, depression of populations, and possible interruption of food supplies. The very small percentages of the Forest proposed for treatment under these Alternatives, and the mosaic of disturbed and undisturbed areas these treatments would produce, indicate the impacts to terrestrial invertebrate habitat would be very minimal. These Alternatives could result in adverse impacts to some individuals, but are not expected to adversely impact terrestrial invertebrate populations.

Cumulative Impacts

Alternative 1 (The No Action Alternative) If no action is taken to control noxious weeds, soil disturbance caused by other Forest activities such as logging, thinning, prescribed fire and grazing may add to conditions that favor encroachment of noxious weeds, thereby increasing the noxious weed problem, however, the magnitude of this problem is not expected to adversely affect invertebrate populations, although some individuals may be adversely impacted.

Alternatives 3 and 5 (The No Herbicide Alternatives) Other Forest activities such as logging, thinning, prescribed fire and/or grazing may result in habitat alteration, physical injury, and temporary interruption of food supplies for terrestrial invertebrates. These effects could add to the impacts of physical and cultural treatment methods. However, all of these activities combined involve very small percentages (in the range of 1 % or

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less) of the Forest under each of these Alternatives, leaving the vast majority of Forest acres undisturbed by these activities. And even within these “disturbed” project areas the management activities tend to leave a mosaic of treated and untreated areas, which would still provide usable habitat for many terrestrial invertebrates. Cumulative impacts of Forest activities under these “no herbicide” Alternatives, are not expected to result in adverse impacts to invertebrate populations, although some individuals may be adversely impacted.

Alternatives 2, 4 and 6 (The Herbicide Alternatives) Other Forest activities such as logging, thinning, prescribed fire and/or grazing may result in habitat alteration, physical injury, and temporary interruption of food supplies for terrestrial invertebrates. These effects could add to the impacts of herbicides and physical + treatments on terrestrial invertebrates. However, all of these activities combined involve very small percentages (in the range of 1 % or less) of the Forest under each of these Alternatives, leaving the vast majority of Forest acres undisturbed by these activities. And even within these “disturbed” project areas the management activities tend to leave a mosaic of treated and untreated areas which would still provide usable habitat for many terrestrial invertebrates. Cumulative impacts of Forest activities under Alternatives 2, 4 and 6, are not expected to result in adverse impacts to invertebrate populations, although some individuals may be adversely impacted.

Consistency with Forest Plans and Other Laws and Policies The Modoc National Forest Land and Resource Management Plan states in the Record of Decision that, “Maintaining the biodiversity of ecosystems, including the diversity of plants, fish, and wildlife and the age diversity of habitats, is a primary objective.” The National Forest Management Act includes direction to preserve and enhance the diversity of plant and animal communities, including endemic and desirable naturalized plant and animal species, so that the diversity is at least as great as that which would be expected in a natural forest and the diversity of tree species is similar to that existing in the planning area (36 CFR 219.26 and 219.27). Similarly, 36 CFR 219.19 states, “Fish and wildlife habitat shall be managed to maintain viable populations of existing native and desired non-native vertebrate species in the planning area. … In order to ensure that viable populations will be maintained, habitat must be provided to support, at least, a minimum number of reproductive individuals and that habitat must be well distributed so that those individuals can interact with others in the planning area.” In the absence of detailed knowledge of all the invertebrate species on the Forest, their life histories, distributions and population dynamics, the best approach to evaluating the potential effects of these treatment Alternatives is to ask the following questions. Will there be a significant amount of habitat in the study area that will not be affected by herbicides? And will that habitat be distributed so that individual invertebrates can interact with others in the planning area? The answer to both of these questions is yes. Therefore, the treatment activities proposed in the FEIS are unlikely to adversely affect any invertebrate populations, or reduce the diversity of invertebrate communities, and thus the treatment Alternatives are in compliance with applicable Forest Laws and Policy.

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Findings

Short-term Uses and Long-Term Productivity NEPA requires consideration of “the relationship between short-term uses of man’s environment and the maintenance and enhancement of long-term productivity” (40 CFR 1502.16). As declared by Congress, this includes using all practicable means and measures, including financial and technical assistance, in a manner calculated to foster and promote the general welfare, to create and maintain conditions under which man and nature can exist in productive harmony, and fulfill the social, economic, and other requirements of present and future generations of Americans (NEPA Section 101). Implementation of any of the Alternatives may result in some unavoidable short-term effects. The Alternatives were designed to enhance conditions by controlling or eliminating noxious weed sites on the Forest, thus improving site productivity in the long term.

Unavoidable Adverse Effects This FEIS discloses that there are no unavoidable adverse effects associated with implementation of any of the action Alternatives. The No Action Alternative (Alternative 1) would continue the adverse effect noxious weeds have on the natural, social, and economic resources of the Forest.

Irreversible and Irretrievable Commitments of Resources Irreversible commitments of resources are those that cannot be regained, such as the extinction of a species or the removal of mined ore. Irretrievable commitments are those that are lost for a period of time such as the temporary loss of timber productivity in forested areas that are kept clear for use as a power line rights-of-way or road Alternative 1, the no action Alternative, would result in the irretrievable loss of Forest resources. Under this Alternative, an irretrievable loss of site productivity would result as weeds spread uncontrolled at current sites of infestation. These sites would otherwise receive treatment through selection of any of the action Alternatives. In addition, additional irretrievable loss of soil productivity could occur under this Alternative due to the uncontrolled spread of noxious weeds into areas that are currently not infested. Under Alternative 1, there would also be irretrievable impacts to native plant communities if noxious weeds spread from untreated areas and dominate large areas that cannot be treated. The spread of noxious weeds on the Forest has the potential to disrupt and alter native plant communities. Alternatives 2-6 would not result in any irretrievable or irreversible commitments of resources. Implementation of the Design Standards will result in no irretrievable or irreversible loss of Forest resources.

Legal and Regulatory Compliance NEPA at 40 CFR 1502.25(a) directs “to the fullest extent possible, agencies shall prepare draft environmental impact statements concurrently with and integrated with …other environmental review laws and executive orders.” The Proposed Action and Alternatives comply with the following laws and executive orders.

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Forest Service Authorities for Invasive Species Management The Forest Service has many unique characteristics and authorities to enable it to play a major role in the management of invasive species. Many of these authorities also apply to other Forest Service management activities which do not focus strictly on invasive species management, such as our authority to manage rangelands, conduct research, or enforce public use activities. In addition to these, invasive species are regulated and/or managed through a variety of statutes administered by the States such as State noxious weeds or animal pest species laws and the Forest Service cooperates with the States to implement those. Other Federal agencies also administer laws such as the Lacey Act, the Plant Protection Act, the Animal Damage Control Act, the Federal Seed Act, the Non-indigenous Aquatic Nuisance Prevention and Control Act, and the Alien Species Prevention and Enforcement Act to address invasive species issues. The Modoc National Forest works cooperatively with various stakeholders to implement these authorities on as appropriate. The following orders or statutes are the primary authorities to allow the Forest Service to conduct invasive species management activities to meet resource management goals and objectives:

The Organic Administration Act (16 U.S.C. 551) The USDA's authority to make rules and regulations protecting National Forests is set forth in section 1 of the Organic Administration Act (16U.S.C. 551). This provision provides broad authority to protect National Forests from "destruction by fire and depredations" and to issue regulations "as will insure the objects of such reservation, namely to regulate their occupancy and use and to preserve the Forest thereon from destruction." As shown in this FEIS noxious weed infestations are a destructive effect on the Forest environment and, therefore without implementing any of the action Alternatives the Modoc NF would violate this Act.

Multiple-Use Sustained-Yield Act of 1960 (MUSY, 16 U.S.C. 528- 531) USDA manages National Forests for multiple uses under the Multiple-Use Sustained-Yield Act of 1960 (MUSY, 16 U.S.C. 528-531). MUSY provides in part A that "the National Forests are established and shall be administered for outdoor recreations, range, timber, watershed, and wildlife and fish purposes" (16 U.S.C. 528). As shown in this FEIS noxious weed infestation are detrimental to outdoor recreation, range, timber, watershed, and wildlife and fish resources. Therefore without implementing any of the action Alternatives would violate this Act.

Forest and Rangeland Renewable Resources Planning Act of 1974, as amended by National Forest Management Act (16 U.S.C. 1604) The Forest and Rangeland Renewable Resources Research Act of 1978 is the Department of Agriculture's primary authority to conduct research activities, including research relating to invasive species. The Act contains expansive authority to conduct research and technology development on, and with applications for, all U.S. lands related to the protection, conservation, and sustainable use of natural resources. The Act also authorizes competitive grants to conduct research, and authorizes cooperative agreements with university, industry, and other partners as needed to complement national program needs. The Act provides for the protection of soil productivity, evaluation of effects on management indicator species, and other standards and guidelines, especially those dealing with water quality.

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The Modoc Forest Plan implements the provisions of the Act, and the Alternatives in the FEIS are consistent with the Act.

Federal Noxious Weed Act of 1974 (7 U.S.C. 2814) Although the Plant Protection Act superseded and repealed most of the Federal Noxious Weed Act of 1974 (FNWA), it left intact section 15 of the act, "Management of undesirable plants on Federal lands" (7 U.S.C. 2814). Section 15 of the FNWA requires Federal land management agencies to develop and establish a management program for control of undesirable plants that are classified under State or Federal law as undesirable, noxious, harmful, injurious, or poisonous, on Federal lands under the agency's jurisdiction (7 U.S.C. 2814(a)). The Act also requires the Federal land management agencies to enter into cooperative agreements to coordinate the management of undesirable plant species on Federal lands where similar programs are being implemented on State and private lands in the same area (7 U.S.C. 2814(c)). The Secretaries of Agriculture and the Interior must coordinate their respective control, research, and educational efforts relating to noxious weeds (7 U.S.C. 2814(f)). USDA's Departmental Regulation 9500-10 sets forth the Departmental policy relating to the management and coordination of noxious weeds activities among the agencies within USDA and other entities. Selection of any of the action Alternatives would provide compliance with this act while the No Action Alternative (Alternative 1) would not provide the Forest with a “management program for control of undesirable plants that are classified … as … noxious, harmful, injurious, or poisonous …”. Selection of any of the action Alternatives would provide the Forest with a program to treat noxious weeds.

Public Rangelands Improvement Act of 1978; and Federal Land Policy and Management Act of 1976 Several statutes provide funding for rangeland rehabilitation and range improvements on public rangelands, including activities designed to control or manage invasive plants. Section 5 of the Public Rangelands Improvement Act of 1978 (43 U.S.C. 1904(c)) authorizes funding for on-the- ground rangeland rehabilitation and range improvements on some of the rangelands managed by the Forest Service. Additionally, range betterment funds, provided under section 401 of the Federal Land Policy and Management Act of 1976 (43 U.S.C. 1751), can be used for variety of range rehabilitation and improvement activities, specifically including weed control, on certain National Forest System rangelands. The Act of April 24, 1950, pertaining to range improvements, states that of the moneys received from grazing fees, a portion can be used for the "eradication of poisonous plants and noxious weeds in order to protect or improve the future productivity of the range" (16 U.S.C. 580(h)). The actions proposed in this FEIS would be funded under the authority of this Act.

Cooperative Forestry Assistance Act of 1978 Under cooperative authorities, the Secretary of Agriculture may assist other Federal, State, and private entities in controlling and managing invasive species on other Federal lands and non- federal lands. The Secretary's primary cooperative authority for invasive species is section 8 of the Cooperative Forestry Assistance Act of 1978 (16 U.S.C. 2104). Section 8(b) authorizes the Secretary of Agriculture to conduct activities and provide technical assistance relating to insect infestations and disease conditions affecting trees on National Forest System lands, on other Federal lands (in cooperation with other Federal Departments) and on

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non-Federal lands (in cooperation with State officials, other entities, or individuals). These activities include in part: conducting surveys to detect and appraise insect infestation and disease conditions; determining biological, chemical, and mechanical measures necessary to prevent, retard, control or suppress incipient, potential, threatening, or emergency insect infestations and disease conditions affecting trees; planning, organizing, directing, and performance measures the Secretary determines necessary to prevent, retard, control, or suppress incipient potential, threatening, or emergency insect infestations and disease epidemics affecting trees; and providing technical assistance to maintain healthy Forests and manage the use of pesticides (16 U.S.C. 2104(b)). Section 8(g) of the Act (16 U.S.C. 2104(g)) also authorizes the Secretary to provide financial assistance through the Forest Service to State entities and private forestry or other organizations to monitor Forest health and protect Forest lands. The Cooperative Forestry Assistance Act of 1978 as amended by the Federal Agriculture Improvement and Reform Act of 1996 Subtitle G Sect. 373, gives authority to provide support for good Forest management practices, including financial assistance to maintain healthy timber ecosystem to prevent incursion of invasive species, on privately owned non-industrial forestlands. The Modoc National Forest anticipates utilizing cooperators and other agencies, tribes, and volunteers to meet the objectives of this FEIS through authorities granted under this Act.

Forest and Rangeland Renewable Resources Research Act of 1978 The Forest and Rangeland Renewable Resources Research Act of 1978 is the Department of Agriculture's primary authority to conduct research activities, including research relating to invasive species. The Act contains expansive authority to conduct research and technology development on, and with applications for, all U.S. lands related to the protection, conservation, and sustainable use of natural resources. The Act also authorizes competitive grants to conduct research, and authorizes cooperative agreements with university, industry, and other partners as needed to complement national program needs. The Modoc National Forest anticipates utilizing cooperators and other agencies, tribes, and volunteers to meet the objectives of this FEIS through authorities granted under this Act.

National Environmental Policy Act (42 U.S.C. 4231 et seq.) Compliance with the National Environmental Policy Act (NEPA) can serve to identify actions that are likely to affect invasive species or be affected by them. The rationale behind the NEPA process - that agencies should be fully informed of the consequences of their actions before making a decision - is especially important when dealing with an issue like invasive species, where problems are often unanticipated side effects of otherwise desirable actions. Analysis and interagency, intergovernmental, and public review and comment that identify potential problems for a particular Proposed Action may also yield ideas for Alternative methods of approaching an issue or other forms of mitigation. In 2001 noxious weed treatments were stopped as the Forest Supervisor determined that actions could no longer occur under the 1981 NEPA Decision Notice. However, due to the complexity and lengthy NEPA processes involved completion of the project was not possible until now. Past NEPA documents were not completed primarily due to the analysis process and concern of the continuous appeals and/or litigation brought against all Forest Service projects involving the use of herbicides by several special interest groups.

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Development of the DEIS, response to comments on the DEIS, and finalizing the FEIS have resulted in detailed documentation of the effects of treatments but is not anticipated to change the need to control noxious weeds or the eventual end results. FEIS Chapter 2, and Appendix J and K document the extensive public involvement and collaboration efforts that were completed during development of this statement. The extensive efforts and analysis paralyses involved in meeting Forest Service NEPA requirements and responding to public comments have delayed implementation of a noxious weed treatment program for two years. The Draft EIS was made available to EPA and the Public on December 17, 2004 with a NOA published on December 29, 2004. The FEIS does provide a ‘hard look’ at treatment methods, Alternatives, and effects. While the FEIS consideration of current scientific literature and other agency registrations and certifications of the methods provides evidence that none of the Proposed Actions will adversely affect the environment or human health when carried out in accordance with label instructions, there is a portion of the public that believe that no herbicides should be used because any risk is too great, regardless of the cost or effectiveness in relation to any other treatment method. This final EIS, which includes the Response to Comments on the draft EIS, displays the potential risks, costs associated with treatment methods, and effects of the Alternatives in accordance with the National Environmental Policy Act. Based on his review of this document, the supporting project record, and the review of public, agency, and tribal concerns, the Forest Supervisor will decide which treatments and mitigations will be applied to control or eliminate noxious weeds on the Modoc National Forest, or whether to take no action.

Executive Order 13175 of November 6, 2000 Consultation and Coordination with Indian Tribal Governments This executive order directs Federal Agencies to develop an “accountable process” for ensuring meaningful and timely input by tribal officials in development of legislation and regulatory policies that have tribal implications. The Executive Order applies to regulations, legislative comments or proposed legislation, and other policies, statements, or actions that have substantial direct effects on one or more Tribes, on the relationship between the Federal Government and Tribes, or on the distribution of power and responsibilities between the Federal Government and Tribes. The Tribal Relations Section of Chapter 3 indicates that a thorough process of Tribal Consultation was carried out through the development of the DEIS and FEIS.

Invasive Species Executive Order 13112 of February 3, 1999 Directs federal agencies to use relevant programs and authorities to:  Prevent the introduction of invasive species;  Detect and respond rapidly to and control populations of such species in a cost-effective and environmentally sound manner;  Monitor invasive species populations accurately and reliably;  Provide for restoration of native species and habitat conditions in ecosystems that have been invaded;  Conduct research on invasive species and develop technologies to prevent introduction and provide for environmentally sound control of invasive species; and

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 Promote public education on invasive species and the means to address them; and  Not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species in the United States or elsewhere unless, pursuant to guidelines that it has prescribed, the agency has determined and made public its determination that the benefits of such actions clearly outweigh the potential harm caused by invasive species; and that all feasible and prudent measures to minimize risk of harm will be taken in conjunction with the actions.  Executive Order 13112 further requires federal agencies to pursue the duties set forth in this section in consultation with the National Invasive Species Council, consistent with the National Invasive Species Management Plan and in cooperation with stakeholders, as appropriate, and, as approved by the Department of State, when working with international organizations and foreign nations. This FEIS is in response to the second bullet above specifically to provide the Modoc National Forest with the tools and program to “Detect and respond rapidly to and control populations of such species in a cost-effective and environmentally sound manner”.

Other Principal Environmental Laws The following laws contain requirements for protection of the environment that apply to the Proposed Action and Alternatives are discussed in the appropriate sections above:  Endangered Species Act discussed in Vegetation and Wildlife Sections, of Chapter 3 and shows that none of the Alternatives will adversely affect endangered species.  Clean Water Act discussed in Watershed Section and shows that all Alternatives comply with the Clean Water Act.  Clean Air Act discussed in Air Section of Chapter 3 which shows there is no adverse impact to air resources.  National Historic Preservation Act discussed in Heritage Resources Section of Chapter 3 and the Design Standards set in Chapter 2 protect resources under the National Historic Preservation Act.

Executive Orders The following executive orders provide direction to federal agencies that apply to the Proposed Action and Alternatives:  Indian Sacred Sites, Executive Order 13007 of May 24, 1996 is discussed in Heritage Resources Section. No impacts to Indian Sacred Sites have been identified.  Protection of Wetlands, Executive Order 11990 of May 24, 1977 is discussed in Watershed Section. No adverse impacts are expected to occur from implementation of any of the Alternatives.  Executive Order 12898 of February 11, 1994 (environmental justice) is discussed in the “Analysis of Social and Economic Effects” and “Environmental Justice” sections. No disparate or adverse effects are identified to groups of people identified in Civil Rights statutes or Executive Order 12898 from any of the Alternatives.

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Special-Area Designations All the action Alternatives are in compliance with the laws, policies and regulations, as well as Forest Plan direction pertaining to research natural areas, inventoried roadless areas, wilderness area management, and wild and scenic river study areas as displayed above under the specific special-area designation discussions. There are no municipal watersheds identified within the Modoc National Forest (See “Tribal and American Indian Uses; Alternatives 2, 4, and 6; Community Drinking Water” in this FEIS). Chapter 2 describes and compares the Alternatives considered for the Modoc National Forest Noxious Weed Treatment Project. It describes both Alternatives considered in detail and those eliminated from detailed study. The Alternatives are presented in tabular format so that the Alternatives and their environmental impacts can be readily compared.

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Consultation and Coordination

Preparers The Forest Service consulted the following individuals, Federal, State, and local agencies, tribes and non-Forest Service persons during the development of the draft and final environmental assessment.

ID Team Members The following is a list of contributors, writers, and editors, to this Environmental Impact Statement. Numerous other resource specialists also contributed in many ways to this document. Their time and assistance for completion of this document is greatly appreciated. Peter Adams – Hydrologist Peter holds a Bachelor of Science degree in Watershed Science, with a minor in Soils from the Utah State University. Peter has completed additional agency training in Applied Geomorphology and Proper Functioning Condition and Assessment. He has been working as a Hydrologist for the past 18 years with multiple agencies including US Geological Survey, Bureau of Indian Affairs and the USDA Forest Service. Peter has also served as a Soil Scientist for the Bureau of Indian Affairs during the 1980’s. Since 1993, Peter has served as a District Hydrologist on the Sierra and Mendocino National Forests prior to coming to the Modoc National Forest in 2004. Peter has also served on R5’s Regional Review Team for multiple projects including the QLFG EIS in 2002. Suraj Ahuja -- Air Resources Specialist Dr. Ahuja is currently a Province Air Quality Specialist for the Forest Service supporting air program for the eight northern National Forests in California. He has worked for the Forest Service for twenty years in the Southwest and Pacific Southwest Region in various positions. He holds a Ph.D. from the University of California at Davis. He also has Air Quality Certification from University of California (Extension) Davis. He has written various technical documents and papers for Forest-wide and Region-wide use. Edith Asrow – Ecosystems Staff Officer Edith holds a Bachelor of Arts degree in Urban Studies and Journalism from Syracuse University, and a Master of Science Degree in Wildland Resource Science from the University of California, Berkeley, School of Forestry. Her major fields of study for her Master of Science were Wildlife Management and Physiological Plant Ecology. Edith has worked for the R-5 Regional Wildlife Staff, the R-5 Information Staff, and the Tahoe, Klamath and Modoc National Forests. She served as District Ranger of the Warner Mountain Ranger District, Modoc National Forest from January 1991- July 1995, when she took over as Ecosystem Staff Officer for the Modoc National Forest.

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Dave Bakke – Human Health and Risk Assessments David holds a Bachelor of Science degree in Forestry from the University of California, Berkeley. David also completed the Pacific Southwest region's Advanced Course in Forest Ecology and Silviculture gaining certification in Silviculture and the National Advanced Pesticide Management Training Course. David is a California state-certified pesticide applicator. He has been working for the USDA Forest Service for 28 years, with the last 7 years as this Region's Pesticide-Use Specialist, responsible for program direction and review of pesticide uses in the Region. David spent 20 years on the Eldorado National Forest, as a silviculturist, involved in the completion of NEPA planning documents involving herbicides, including the writing of site- specific risk assessments. In his current position, David has been involved with project-specific appeals, litigation, and NEPA analysis. He peer reviews technical articles and writes internal pesticide documents. David is a member of the Society of American Foresters, the Society for Environmental Toxicology and Chemistry, and is a California Registered Professional Forester (#2054). Keith Bryan – Fire/Fuels Specialist Keith has been working for the USDA Forest Service for 30 years. The last three years as the Assistant Forest Fire Management Officer for Fuels and Fire Ecology for the Modoc National Forest. Keith started his Fire career with the California Division Of Forestry in 1969. He then worked on the Tahoe National Forest in Region 5 and the Coronado National Forest in Region 3 before coming to the Modoc in 1980. He worked as an Engine Captain for 14 years and has spent the last 10 years working in Fuels. Sue Becker - Hydrologist Sue Becker has a Bachelor of Science degree in Soil and Water Science from UC Davis. Sue has 14 years of experience in assessment of potential effects of land management activities on water quality, stream flow volume, and riparian health. She has worked on the Shasta-Trinity NFs; Klamath NF; and for the Pacific Southwest Research Station and the Natural Resources Conservation Service. Sue is currently working as a District Resource Officer on the Six Rivers National Forest. Cheryl Beyer – Botanist Cheryl has a Bachelor of Science degree in Botany and a Masters’ degree in Natural Resource Conservation from the University of Montana, Missoula. She has worked in botany for 10 years for the Forest Service in Regions 1, 4, 5, and 6 and for BLM in Oregon. She has taught botany at Umpqua Community College, while in Oregon, and is currently the Forest Botanist on the Modoc National Forest. Cheryl’s expertise includes vascular plants, bryophytes, lichens and fungi, and she recently published an article in the Bulletin of the California Lichen Society. “Solorina spongiosa: A new species record for Nevada.” Jayne Biggerstaff – Lands and Minerals Specialist

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Jayne holds a Bachelor of Arts degree in History and Social Science from Harding University, a minor in Natural Resource Management from Cal Poly, and a Master of Arts degree in Behavioral Science from the University of California. Jayne has worked for the USDA for about 25 years, the last 4 of which has been as Special Uses and Minerals Administrator for the Forest. Prior to that time, Jayne worked for about 10 years as Assistant Culturist on the Warner Mountain District, 3 years in farm loan servicing with the Farmers Home Administration, and the remaining 8 years in various administrative positions including Personnel and Resources. David Bolsover—Writer-Editor David has worked for the Forest Service since 1994, first as an Accounting Technician then as Writer-Editor. He has a BA in Political Science from California State University at Long Beach, a BA in German from the University of Alabama in Birmingham, an MA in music from the University of Miami, and a certificate in Russian from the Defense Language Institute, West Coast Division. John Clark – Writer-Editor and Wildlife Biologist John holds a Bachelor of Science degree in Wildlife Management with a minor in Range Management from Humboldt State University. He also holds a Master of Science degree in Wildlife Science from Oregon State University and teaching credentials from Chapman University. In addition to teaching at the high school and community college level, John worked as a wildlife biologist for the US Fish and Wildlife Service on the Yukon Delta and Kern National Wildlife Refuges. He is currently the wildlife biologist on the Devil’s Garden Ranger District. Bruce Davidson – Botanist Bruce holds and Bachelor of Science degree in Botany from Oregon State University. He has worked in noxious weed management and federally listed plant management programs for over 14 years. Bruce worked on the Malheur, and Modoc National Forest and worked with the Bureau of Land Management. Bruce is currently working on the Lake Tahoe Basin Management Unit. Irene Davidson – Botanist, Interdisciplinary Team Leader (2000-2003) Botanist (1998- 2000) Irene holds a Bachelor of Science in Horticulture from Oregon State University. Irene has worked on the Malheur, Umpqua, and Modoc National Forests, and with the BLM in Roseburg Oregon. She now works of the Lake Tahoe Basin Management Unit. Mary Flores – Wildlife Biologist Mary holds a Bachelor of Science degree in Wildlife Biology with a minor in Soil Science from Colorado State University in Ft. Collins, Colorado. She also holds a Masters of Science degree in Pedology (Soil Genesis) with a concentration in Wildlife Management from South Dakota State University in Brookings, South Dakota. She is currently the Warner Mountain Ranger District Wildlife Biologist for the Modoc National Forest. Her main duties include planning, implementing, and monitoring on projects that cover Forest, range, wildlife, and recreation management. She also served as a Regional Emphasis Leader for the Partners in Flight

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Program. Mary has worked permanently for the USDA Forest Service for 14 1/2 years on 2 National Forests. Prior to that time, she worked for a variety of agencies in 5 states on both research and management projects. Gerry Gates - Forest Archaeologist/Heritage Resource Program Manager Gerry received his BA in Anthropology (Archaeology emphasis) in 1973 and MA in Anthropology (Archaeology emphasis) in 1978 from California State University-Northridge. He began his career in Federal service with the National Park Service in 1973 at Hubbell Trading Post National Historic Site on the Navajo Reservation in Arizona. He started with the US Forest Service in 1976 as a summer seasonal Archaeologist and was hired as the Forest Archaeologist in August of 1977. He has held that position since then. Robert Haggard – Public Services Staff Officer - Interdisciplinary Team Leader Robert holds a Bachelor of Science degree in Forest Management from Stephen F. Austin State University in Nacogdoches, Texas. He is currently the Public Services Staff Officer for the Modoc National Forest providing staff leadership for the planning, geographic information systems, engineering, and recreation groups. Robert has worked for the USDA Forest Service for 29 years, with the last 15 years in planning working at 5 National Forests within four regions and on a flood prevention project within the State and Private Forestry branch of the USDA Forest Service. Louis Haynes – Public Affairs Officer Louis holds a Bachelor of Science Degree in Community Service and Pre-Law from Eastern Oregon University. Louis served as a Public Affairs Specialist on the Modoc National Forest from March 2002 to October 2006. Louis is currently assigned to Ashley National Forest in Northeastern Utah as the Forest Public Affairs Officer. Louis is a graduate of the Department of Defense Information School for Public Affairs Officers at Fort Meade Maryland and has served as the Deputy Public Affairs Officer at Fort Bliss Texas during his 11 years of active duty in the U.S. Army as an Armor and Public Affairs Officer. Jim Irvin – Ecosystems Staff Officer and District Ranger Jim holds a Bachelor of Science degree in Rangeland Management from the California State University, Chico. He has been working for the USDA Forest Service for 25 years. He has been a Rangeland Management Specialist for 24 years working on three National Forests. As a Rangeland manager his duties included management of the District rangelands, minerals, hydrology, soils, botany, special uses, and Heritage resources. For six years he was the Forest Rangeland Program Manger, which included oversight of the Modoc Forest Noxious Weed Program. He has served as Ecosystem Staff Officer for the Modoc National Forest, providing staff leadership for the range, hydrology, timber, wildlife, fisheries, botany, lands, minerals, soils, special uses, ecology, and heritage resources groups. Since July, 2005 Jim has been the District Ranger of the Warner Mountain – Devil’s Garden Ranger District. Rob Jeffers – Range Specialist

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Rob Jeffers holds a Bachelor of Science degree in Wildlife Management, with minors in Range Management and Outdoor Recreation, from Humboldt State University in Arcata, CA. He is currently the Rangeland Program Manager for the Modoc National Forest. Rob recently transferred to the USDA- Forest Service from the USDI- Bureau of Land Management, where he worked for 27 years. While in the Bureau, he served in various positions relating to the Rangeland Management and Wild Horse and Burro programs in northeastern California and central Nevada. Dan Meza – Tribal Relations Specialist Dan’s expertise is in Law and Policy on Government-to-Government responsibilities with Indian Tribes which he has been doing for the past 4 years. Dan has served in details in the tribal relations operations at the Regional. Before serving as Tribal Relations Specialist on a full-time basis Dan represented tribal relations while working on engineering, fire and vegetative management crews for over 15 years for the Modoc National Forest. Barbara Ott – Social Scientist Barbara holds a Bachelor of Arts degree in Business Administration from Chadron State College in Nebraska and a Master of Science degree in Management with an emphasis in Public Administration and a special study of rural community development from Colorado State University. She has completed additional agency training in social and economic analysis. Barb has worked for the Forest Service for 28 years and has been conducting social and economic analyses for the last ten years. Her recent assignments include four years as a Social Scientist on the Custer National Forest and six years as a Social Scientist and a core member of the Forest Plan Revision Team for the Uinta National Forest. Barb’s current assignment is as a Social Scientist with TEAMS Planning Enterprise. Sean Redar – GIS Coordinator Sean Redar is currently the Forest GIS Coordinator for the Modoc National Forest. Previously, Sean was a GIS Analyst and Field Botanist on the San Bernardino National Forest for 7 years. Sean holds bachelor degrees in biology and environmental studies and a master of science in biology. Traci Silva – GIS Specialist Traci has worked on the Modoc National Forest for 24 years as a forestry technician and resource clerk. She has been working as Forest GIS Specialist for over 10 years completing specialist training in database management and geospatial analysis. Bill Schoeppach – Vegetation Specialist Bill holds a B.S. in forest management from the University of Montana. He has completed the Pacific Southwest Region’s Advanced Course in Forest Ecology and Silviculture at the University of Washington and Oregon State University. Currently he is certified as a Silviculturist in R-5. Bill has worked as a reforestation culturist on the Mendocino and Idaho Panhandle National Forests, a District Silviculturist on the Klamath National Forest, and presently as the Forest Vegetation Manager on the Modoc for a total of 28 years.

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Robert Trujillo – Environmental Coordinator Robert Trujillo holds a B.S. in Biology form the University of New Mexico, as well as a M.S. and a Ph.D. in Wildlife and Fisheries Sciences from Texas A&M University. He began his career with the Forest Service on the Modoc National Forest in 2005. Robert has attended regional training in Forest Plan Implementation (1900-1), the Forest Service’s NEPA training class. He has extensive research experience and has published in peer reviewed journals. Marty Yamagiwa – Forest Biologist Marty holds a Bachelor of Science degree in Wildlife Management, Fisheries Emphasis, from Humboldt State University. He began his career on the Mendocino National Forest as a fisheries/wildlife biologist trainee. He has been working on the Modoc National Forest for 18 years, 6 years as the district wildlife biologist on the Warner Mt. Ranger District, 11 years as the Forest Fisheries biologist, and is currently the Forest Biologist with wildlife and fisheries program management responsibilities. Jenny C. Fryxell - Hydrology and Soils, TEAMS, a U.S. Forest Service enterprise team Jenny holds a Bachelor of Arts in Earth Science from Augustana College, Rock Island, Illinois and a Master of Arts in Earth Sciences, with a minor in soils, from Montana Sate University, Bozeman, Montana. She is currently a hydrologist with the Forest Service enterprise team TEAMS and works out of Driggs, Idaho. In this position she has provided expertise in soils and hydrology for the last six years. For the 15 years prior to that, Jenny worked as a hydrologist on the Tongass National Forest, in Alaska. For the last three of those years she was the District hydrologist for the Juneau Ranger District and Admiralty National Monument.

Contributors

Federal, State, and Local Agencies California Department of Fish and Game, Sacramento CA California Department of Food and Agriculture - Bezark, Larry, G California Department of Food and Agriculture - Piroske, Carrie California Regional Water Quality Control Board Lahontan - Churchill, Jason California State Resources Agency, Sacramento CA Honey Lake Valley Resource Conservation District - Anton, Robert, E Lassen County, Board of Supervisors Lassen County, Department of Agriculture, Smith - Kenneth, R Modoc County Land Use Committee – Sean Curtis Modoc County, Board of Supervisors - Dave, Bradsha Modoc County, Department of Agriculture - Moreo, Joe Modoc County, Department of Health Services - Farnam, Greg Modoc Noxious Weed Working Group - Steffek, Mark State of California, Office of the Governor, Sacramento CA US Environmental Protection Agency Region IX - Hanf, Lea, B

Native American Tribes Alturas Rancheria

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Fort Bidwell Paiute Tribe Pit River Tribe

Others Albaugh, Dale California Native Plant Society - Chipping, David Californians Against Toxic Substances - Clary, Patty Californians for Alternatives to Toxics - Harrison, Pete California Indian Basketweavers – Parker, Vivian Klamath Forest Alliance and California Citizens for Alternatives to Pesticides, - Greenburg, Geba Klamath Forest Alliance and Klamath Siskiyou Wildlands - Chichizola, Regina Modoc County Cattlemen's Association, - Smith, Dennis, C. Modoc County Farm Bureau - Ingraham, Elizabeth Salmon River Restoration Council - Bruckere, Petey The Nature Conservancy -

Distribution of the Environmental Impact Statement This environmental impact statement has been distributed to individuals who specifically requested a copy of the document and those who submitted substantive comments on the draft environmental impact statement. In addition, copies have been sent to the following Federal agencies, federally recognized tribes, State and local governments, and organizations:

Federal Agencies and Officials Advisory Council on Historic Preservation, Washington DC

U.S. Department of Agriculture Animal and Plant Health Inspection Service, Riverdale MD Forest Service, Washington, DC National Agricultural Library, Beltsville MD Natural Resource Conservation Service, Washington DC USDA, OPA Publication Stockroom, Washington DC USDA, Office of Civil Rights, Washington DC

Regional Offices Pacific Southwest Region, Vallejo California Pacific Northwest Region, Portland Oregon

National Forests Humboldt-Toiyabe National Forest Klamath National Forest Lassen National Forest Plumas National Forest Shasta-Trinity National Forest Fremont-Winema National Forest

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Environmental Protection Agency US Environmental Protection Agency Region IX - Hanf, Lea, B US Environmental Protection Agency, Office of Environmental Review, Washington DC

Federal Aviation Administration Regional Administrator – Lawndale, CA

Federal Energy Regulatory Commission Director, Office of NEPA Policy and Compliance

Federal Highway Administration Western Resource Center, San Francisco CA

National Oceanic & Atmospheric Administration National Marine Fisheries Service, Long Beach, CA

U.S. Army Engineer Division South Pacific, San Francisco, CA

U.S. Coast Guard (USCG) Environmental Management, Washington DC

U.S. Department of the Interior Bureau of Land Management, Alturas CA Bureau of Land Management, Cedarville CA Bureau of Land Management, Lakeview OR Bureau of Land Management, Susanville CA Fish and Wildlife Service, Klamath Falls OR USDI, Office of Environmental Policy and Compliance - Patricia, Port, S

U.S. Environmental Protection Agency (EPA) US Environmental Protection Agency Region IX - Hanf, Lea, B

Surface Transportation Board Chief, Energy and Environment, Washington DC

U.S. Senators Senator Dianne Feinstein Senator Barbara Boxer

U.S. Representatives Representative Walley Herger Representative John Doolittle

State and Local Agencies California Regional Water Quality Control Board Lahontan - Churchill, Jason

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California Department of Food and Agriculture - Piroske, Carrie California Department of Food and Agriculture - Bezark, Larry, G California Department of Fish and Game, Sacramento CA California State Resources Agency, Sacramento CA State of California, Office of the Governor, Sacramento CA Lassen County, Board of Supervisors Lassen County, Department of Agriculture, Smith - Kenneth, R Honey Lake Valley Resource Conservation District - Anton, Robert, E Modoc County, Board of Supervisors - Dave, Bradsha Modoc County, Department of Agriculture - Moreo, Joe Modoc County, Department of Health Services - Farnam, Greg Modoc Noxious Weed Working Group - Steffek, Mark

Native American Tribes Alturas Rancheria Cedarville Rancheria Fort Bidwell Paiute Tribe Klamath Tribes Pit River Tribe

Organizations California Indian Basketweavers California Native Plant Society California Wilderness Coalition Californians Against Toxic Substances Californians for Alternatives to Toxics Klamath Forest Alliance and California Citizens for Alternatives to Pesticides Klamath Forest Alliance and Klamath Siskiyou Wildland Modoc County Cattlemens’ Association Modoc County Farm Burea Salmon River Restoration Counci The Nature Conservancy

Universities University of California at Davis

Libraries Modoc County Library Lassen County Library Siskiyou County Library

News Media Modoc County Record Modoc Independent News Mountain Echo Herald and News

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Individuals Anderson, Karen, L Artley, Richard Case, Bob Chichizola, Regina Copeland, John Dubose, Dave Estes, Catherine R Franklin, Bonnie Hultgren, Arne Katzenmeyer, Adene, M Kessler, John, S Nord, Torben Richardson, Jeff Schmidt, Marlene Silvaggio, Tony Swanson, John, R Thesken, Jay Volberg, Kristin

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Glossary

Acronyms Ae: Acid equivalent Ai: Active ingredient ADP: Adenosine diphosphate AEL: Adverse-effect level ANC: acid neutralizing capacity APCD: Air pollution control district AQRV: Air quality related values ATP: Adenosine triphosphate BE/BA: Biological Evaluation/ Biological Assessment BLM: Bureau of Land Management BMP: Best Management Practice BCF: Bioconcentration factor CANSAC: California and Nevada Smoke and Air Consortium CAR: Critical Aquatic Refuge CARB: California Air Resources Board CATs: Californians for Alternatives to Toxics CO: Carbon monoxide CWHR: California Wildlife Habitats Relationships System DBH: Diameter at Breast Height DEIS: Draft environmental impact statement DFC: Desired future condition DHS: (California) Department of Health Services DPR: (California) Department of Pesticide Regulation DWEL: Drinking water equivalent level EA: Environmental assessment EIS: Environmental impact statement EPA: Environmental Protection Agency

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ERA: Equivalent roaded acres ESA: Endangered Species Act FARSITE: Fire area simulator FEIS: Final environmental impact statement GIS: Geographic information system g: gram gpa: gallons per acre HAP: Hazardous air pollutants HQ: Hazard quotient IWM: Integrated Weed Management kcal/g: Kilocalories per gram LC50: Lethal concentration for 50% of population LD50: Lethal dose for 50% of population LOAEL: Lowest observed adverse effects level LOEC: Lowest observable effect concentration LOEL: Lowest observed effects level LOP: Limited Operating Period MCL: Maximum contaminant level meq/l: milliequivalents per liter mg/kg: milligrams per kilogram Mg/L: Milligrams per liter MIS: Management Indicator Species Modoc NF: Modoc National Forest MRL: Minimal risk level NAAQS: National ambient air quality standard NEPA: National Environmental Policy Act NF: National forest NFS: National Forest System NFMA: National Forest Management Act NOAEL: No observed adverse effects level NOEL: No observed effects level

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NOI: Notice of Intent NOX: Nitrous oxide NO2: Nitrogen dioxide NPE: Nonylphenol polyethoxylate NRC: National Research Council NTMB: Neotropical migratory bird NVUM: National Visitor Use Monitoring Survey O3: Ozone Pb: Lead PH: Acidity PM2.5: Particulate matter smaller than 2.5 microns PM10: Particulate matter smaller than 10 microns PAC: Protected Activity Center POEA: Ethoxylated tallow amine surfactant ppb: Parts per billion ppm: Parts per million RD: Ranger District RfD: Reference dose RCA: Riparian Conservation Area ROD: Record of Decision SMZ: Streamside Management Zone TOC: Threshold of concern ug: microgram SAT: Scientific Advisory Team SERA: Syracuse Environmental Research Associates SIP: State implementation plan SNEP: Sierra-Nevada Ecosystem Project SNFPA: Sierra-Nevada Forest Plan Amendment SOHA: Spotted Owl Habitat Area TES: Threatened and endangered species TMRC: Theoretical maximum residue concentration

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UF: Uncertainty factor USDA: United State Department of Agriculture USFWS: Untied States Fish and Wildlife Service WRAP: Western Regional Air PartnershipTerms

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Definitions Absorption: The process by which the agent is able to pass through the body membranes and enter the bloodstream. The main routes by which toxic agents are absorbed are the gastrointestinal tract, lungs, and skin. Acetylcholine: A naturally occurring herbicide responsible for the transmission of impulses between nerve cells or between nerve cells and an effector cell (such as a muscle cell). Broken down to inactive compounds by acetylcholinesterase. Acetylcholinesterase: An enzyme responsible for the degradation of acetylcholine to acetic acid and chlorine. The inhibition of this enzyme leads to an excess of acetylcholine in nerve tissue. This can lead to a broad spectrum of clinical effects (Table 7-2). Acid equivalent (a.e.): The acid equivalent of a salt or ester form of the active ingredient of an herbicide is that portion of the molecule that represents the parent acid form of the molecule. Active ingredient (a.i.): The main ingredient produces the desired effect. Acute exposure: A single exposure or multiple exposures occurring within a short time (24 hours or less). Additive effect: A situation in which the combined effects of two chemicals is equal to the sum of the effect of each chemical given alone. The effect most commonly observed when two chemicals are given together is an additive effect. Adenosine Diphosphate (ADP): A molecule used as a substrate in metabolism of nutrients in which the herbicide energy in the nutrient is converted to ATP. Adenosine Triphosphate (ATP): A molecule used as an energy source in many bioherbicide reactions in living things. During the energy transfer process, the ATP is converted to ADP and inorganic phosphorous. Adjuvant(s): Formulation factors used to enhance the pharmacological or toxic agent effect of the active ingredient. Adrenergic: A type of nerve that uses an adrenaline like substance as a neurotransmitter. Adsorption: The tendency of one herbicide to adhere to another material. Adverse-Effect Level (AEL): Signs of toxicity that must be detected by invasive methods, external monitoring devices, or prolonged systematic observations. Symptoms that are not accompanied by grossly observable signs of toxicity. In contrast to Frank-effect level. Aerobes: Organisms that require oxygen. Affected Environment: The physical, biological, social, and economic environment where human activity is proposed.

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Alkaline phosphatase: An enzyme that occurs in various normal and malignant tissues. The activity of the enzyme in blood is useful in diagnosing many illnesses. Allelopathic effects: Literally reciprocal pathology. In plant pathology, the term is used to describe the release of substances from one plant that may have an adverse effect on another plant. Allometric: Pertaining to allometry, the study and measure of growth. In toxicology, the study of the relationship of body size to various physiological, pharmacological, pharmacokinetic, or toxicodynamic processes among species. Alternative: In project planning, a given combination of resource uses and mix of management practices that achieve a desired management direction, goal, or emphasis. Ameliorate: To improve or become more satisfactory. Anaerobes: Organisms that do not require oxygen. Aquatic ecosystems: The stream channel, lake, or estuary bed, water, biotic communities, and habitat features that occur therein. Ascites: The accumulation of fluid in the peritoneal cavity. This condition may be caused by increased venous pressure or decreased plasma albumin and is often associated with cardiac failure, cirrhosis of the liver, or renal deficiency. Ataxia: inability to coordinate muscle activity; loss of balance Best Management Practices (BMPs): A practice, or combination of practices, that is determined by the state to be the most effective, practicable (including technological, economic, and institutional considerations) means of preventing, or reducing the amount of pollution generated by non-point sources to a level compatible with water quality goals. Bioconcentration factor (BCF): The concentration of a compound in an aquatic organism divided by the concentration in the ambient water of the organism. Biodiversity: The distribution and abundance of different plant and animal communities and species, habitats, seral stages, and special habitat components in an ecosystem. Biologically sensitive: A term used to identify a group of individuals who, because of their developmental stage or some other biological condition, are more susceptible than the general population to an herbicide or biological agent in the environment Broadleaf weed: A non-woody dicotyledonous plant with wide bladed leaves designated as a pest species in gardens, farms, or forests. California Spotted Owl Protected Activity Center: A 300-acre, protected area in which California Spotted owls find suitable nesting sites and several suitable roosts, and in which they carry out at least half of their nighttime foraging during the breeding season California Wildlife Habitat Relationships System (CWHR): The California Wildlife Habitat Relationships System includes habitat relationships models for over 600 wildlife species in the State of California. The system was designed as a planning tool to predict wildlife species

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communities, habitat suitability, and differences in habitat values between two situations for geographic locations and habitats in California. The system provides species habitat suitability ratings for feeding, cover, and foraging in varying habitat types and seral stages. These suitability ratings are converted to numeric values, and the three values are averaged to calculate overall habitat values for each habitat type and seral stage, for particular species. The California Wildlife Habitat Relationships System can be used to predict differences in habitat values between two habitat conditions, and can indicate which species may be negatively or positively affected, based on differences in habitat values between the two habitat conditions. Cancer potency parameter: A model-dependent measure of cancer potency (mg/kg/day)-1 * over lifetime exposure. [Often expressed as a q1 which is the upper 95% confidence limit of the

first dose coefficient (q1) from the multistage model.] Carcinogen: A herbicide capable of inducing cancer. Carcinoma: A malignant tumor. Carrier: In commercial formulations of insecticides or control agents, a substance added to the formulation to make it easier to handle or apply. Cholinergic: Refers to nerve cells that release acetylcholine. Chronic exposure: Long-term exposure studies often used to determine the carcinogenic potential of chemicals. These studies are usually performed in rats, mice, or dogs and extend over the average lifetime of the species (for a rat, exposure is 2 years). Confounders: A term used in discussions of studies regarding human populations (epidemiology studies) to refer to additional risk factors that if unaccounted for in a study, may lead to erroneous conclusions Connected actions: Exposure to other chemical and biological agents in addition to exposure to the control agent during program activities to control vegetation. Contaminants: For herbicides, impurities present in a commercial grade herbicide. For biological agents, other agents that may be present in a commercial product. Controls: In toxicology or epidemiology studies, a population that is not exposed to the potentially toxic agent under study. Cooperative Agreement: A written agreement between the Forest Service and a county, State, or Federal agency entered into pursuant to the Federal Noxious Weed Act of 1974, as amended by section 1453 of the Food, Agriculture, Conservation and Trade Act of 1990, when there is an exchange of funds from one agency to another (FSM 1580). Creatine: An organic acid composed of nitrogen. It supplies the energy required for muscle contraction. Creatinine: The end product of the metabolism of creatine. It is found in muscle and blood and is excreted in the urine.

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Cumulative effects: Changes as a result of more than one action that may enhance or degrade a specific site. Cumulative exposures: Exposures that may last for several days to several months or exposures resulting from program activities that are repeated more than once during a year or for several consecutive years Cytosolic: Found in the cytoplasm of a cell. Dermal: Pertaining to the skin. Dermatitis: Inflammation of the skin, either due to direct contact with an irritating substance, or to an allergic reaction. Directed Spray: is accomplished by wand with regulated nozzle in such a fashion that spray is directed within 1 to 2 feet of the target vegetation. This spraying is done at an angle to reduce overspray. Plants that are three feet tall are left standing. Taller plants are will need to be cut or bent to insure that spray is within three feet of the ground. Dislodgeable residues: The residue of a herbicide or biological agent on foliage as a result of aerial or ground spray applications, which can be removed readily from the foliage by washing, rubbing or having some other form of direct contact with the treated vegetation. Dose-response assessment: A description of the relationship between the dose of a herbicide and the incidence of occurrence or intensity of an effect. In general, this relationship is plotted by statistical methods. Separate plots are made for experimental data obtained on different species or strains within a species. Draft Environmental Impact Statement: The statement of environmental effects required for major Federal actions under Section 102 of the National Environmental Policy Act (NEPA), and released to the public and other agencies for comment and review. Drift: That portion of a sprayed herbicide that is moved by wind off a target site.

EC100: A concentration that causes complete inhibition or reduction. As used in this document, this values refers to a complete inhibition of growth.

EC50: A concentration that causes 50% inhibition or reduction. As used in this document, this values refers to a 50% inhibition of growth. Endangered Species: Any species listed in the Federal Register as being in danger of extinction throughout all or a significant portion of its range. Endocrine: The system in the body consisting of organs that generates compounds that are transported elsewhere in the body and used for regulation of some other part of the body. Examples are the thyroid, the adrenals, and the pituitary glands. Endogenous: Growing or developing from or on the inside. Enzymes: A biological catalyst; a protein, produced by an organism itself, which enables the splitting (as in digestion) or fusion of other herbicides.

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Epidemiology study: A study of a human population or human populations. In toxicology, a study that examines the relationship of exposures to one or more potentially toxic agent to adverse health effects in human populations. Estrogen: Any of several steroid hormones produced chiefly by the ovaries and responsible for promoting estrus and the development and maintenance of female secondary sex characteristics. Estrogenic: a substance that induces female hormonal activity. Exposure assessment: The process of estimating the extent to which a population will come into contact with a herbicide or biological agent. Fetal anomaly: An abnormal condition in a fetus, which is usually the result of a congenital defect. Fibroma: A benign tumor composed mainly of fibrous or fully developed connective tissue. Forest Plan: The Land and Resource Management Plan for the Modoc National Forest. Formulation: A commercial preparation of a herbicide including any inerts or contaminants. Frank effects: Obvious signs of toxicity. Frank-effect Level (FEL): The dose or concentration of a herbicide or biological agent that causes gross and immediately observable signs of toxicity. Gavage: The placement of a toxic agent directly into the stomach of an animal, using a gastric tube. Genotoxic: Causing direct damage to genetic material. Associated with carcinogenicity. Gestation: The period between conception and birth; in humans, the period known as pregnancy. Half time or half-life: For compounds that are eliminated by first-order kinetics, the time required for the concentration of the herbicide to decrease by one-half. Hazard identification: The process of identifying the array of potential effects that an agent may induce in an exposed human population. Hazard Quotient (HQ): The ratio of the estimated level of exposure to the RfD or some other index of acceptable exposure. Hematological: Pertaining to the blood. Hematology: One or more measurements regarding the state or quality of the blood. Henry's law constant: An index of the tendency of a compound to volatilize from aqueous solutions. Herbaceous: A plant, annual, biennial, or perennial, that does not develop persistent woody tissue above the ground, but whose aerial portion naturally dies back to the ground at the end of a growing season.

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Herbicide: A chemical used to control, suppress, or kill plants. Histopathology: Signs of tissue damage that can be observed only by microscopic examination. Home range: The area to which activities of an animal are confined during a defined period of time. Humoral: of, or related to, elements in the blood. Hydrolysis: Decomposition or alteration of a herbicide substance by water. Hydroxylation: The addition of a hydrogen-oxygen or hydroxy (-OH) group to one of the rings. Hydroxylation increases the water solubility of aromatic compounds. Particularly when followed by conjugation with other water soluble compounds in the body, such as sugars or amino acids, hydroxylation greatly facilitates the elimination of the compound in the urine or bile. Hymolytic anemia: A medical condition in which the number of red blood cells is decreased due to intravascular fragmentation or destruction. Hyperemia: An increase in the amount of blood in an organ or region of the body with distention of the blood vessels. This may be caused either by an increase in dilation of the blood vessels (active hyperemia) or a hindrance of blood drainage from the site (passive hyperemia). Hyperplasia: An abnormal increase in the number of cells composing a tissue or organ. Hypoactivity: Less active than normal. Hypovolemia: Low or decreased blood volume. If this condition is sufficiently severe, the individual may go into shock and die. Immunotoxic – damaging to the immune system. In vitro: Isolated from the living organism and artificially maintained, as in a test tube. In vivo: Occurring in the living organism. Inerts: Adjuvants or additives in commercial formulations of Glyphosate that are not readily active with the other components of the mixture. Integrated Weed Management (IWM): An IWM program is an interdisciplinary management approach for selecting methods for preventing, containing, and controlling noxious weeds in coordination with other resource management activities to achieve optimum management goals and objectives. Methods include: education, preventive measures, herbicide, cultural, physical or mechanical methods, biological control agents, and general land management practices, such as manipulation of livestock or wildlife grazing strategies that accomplish vegetation management objectives. (FSM 2080.5) Intraperitoneal: Injection into the abdominal cavity. Invertebrate: An animal that does not have a spine (backbone). Irritant effect: A reversible effect, compared with a corrosive effect.

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Larva (pl. larvae): An insect in the earliest stage after hatching.

Lethal Concentration50 (LC50): A calculated concentration of a herbicide in air to which exposure for a specific length of time is expected to cause death in 50% of a defined experimental animal population.

Lethal Dose50 (LD50): The dose of a herbicide calculated to cause death in 50% of a defined experimental animal population over a specified observation period. The observation period is typically 14 days. Limited Treatment (a type of weed treatment): Perimeter treatment only to contain infestation. Lowest-Observed-Adverse-Effect Level (LOAEL): The lowest dose of a herbicide in a study, or group of studies, that produces statistically or biologically significant increases in frequency or severity of adverse effects between the exposed population and its appropriate control. Lowest-Observed-Effect Level (LOEL): The lowest dose of a herbicide where no adverse treatment-related effects were observed. Lymph: A clear water fluid containing white blood cells. Lymph circulates throughout the lymphatic system, removing bacteria and certain proteins from body tissue. It also is responsible for transporting fat from the small intestine and supplying mature lymphocytes to the blood. Lymphatic: Pertaining to lymph, a lymph vessel, or a lymph node. Lymphocyte: white blood cell involved in immune system. Malignant: Cancerous Management Indicator Species (MIS): Animals or plants identified in Forest Land and Resources Management Plans (LRMPs, or Forest Plans) developed under the 1982 Planning Rule, that are selected because their population changes are thought to indicate the effect of Forest Service management activities (USDA Forest Service, Pacific Southwest Region, Sierra Nevada Forest Plan Amendment Final Environmental Impact Statement, 2001: 69). Margin of safety (MOS): The ratio between an effect or no effect level in an animal and the estimated human dose. Metabolite: A compound formed as a result of the metabolism or bioherbicide change of another compound. Metameter: Literally, the unit of measure. Used in dose-response or exposure assessments to describe the most relevant way of expressing dose or exposure. Microorganisms: A generic term for all organisms consisting only of a single cell, such as bacteria, viruses, and fungi. Microsomal: Pertaining to portions of cell preparations commonly associated with the oxidative metabolism of herbicides.

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Minimal Risk Level (MRL): A route-specific (oral or inhalation) and duration- specific estimate of an exposure level that is not likely to be associated with adverse effects in the general population, including sensitive subgroups. Mitochondria: Subcellular organelles involved in the conversion of food to stored energy. Monitoring: The collection of information over time, generally on a sample basis to measure change in an indicator or variable, for purposes of determining the effects of resource management treatments. Most sensitive effect: The adverse effect observed at the lowest dose level, given the available data. This is an important concept in risk assessment because, by definition, if the most sensitive effect is prevented, no other effects will develop. Thus, RfDs and other similar values are normally based on doses at which the most sensitive effect is not likely to develop. Mutagenicity: The ability to cause genetic damage (that is damage to DNA or RNA). A mutagen is substance that causes mutations. A mutation is change in the genetic material in a body cell. Mutations can lead to birth defects, miscarriages, or cancer. Myeloma: Primary tumor of the bone marrow. Myotonic: Pertaining to muscle spasms. National Environmental Policy Act (NEPA): The United States’ basic national charter for protection of the environment. It establishes policy, sets goals, and provides means for carrying out the policy. The Act directs agencies to inform the public of projects, and that agencies consider public comment. National Forest Management Act (NFMA): The National Forest Management Act of 1976 amended the Resources Planning Act to direct the Secretary of Agriculture to develop direction and guidance for management of lands and resources of National Forest System lands. Neuropathy: Damage to the peripheral nervous system. Neurotransmitter: A substance used by a nerve cell in the transmission of impulses between nerve cells or between nerve cells and an effector cell. Non-native plants: A plant grown outside of its natural range. Non-target: Any plant or animal that a treatment inadvertently or unavoidably harms. No-observed-adverse-effect level (NOAEL) -- The dose of a chemical at which no statistically or biologically significant increases in frequency or severity of adverse effects were observed between the exposed population and its appropriate control. Effects may be produced at this dose, but they are not considered to be adverse. No-Observed-Adverse-Effect Level (NOAEL): The dose of a herbicide at which no statistically or biologically significant increases in frequency or severity of adverse effects were observed between the exposed population and its appropriate control. Effects may be produced at this dose, but they are not considered to be adverse.

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No-Observed-Effect Level (NOEL): The dose of a herbicide at which no treatment-related effects were observed. Noxious weed: Those plant species designated as noxious weeds by the Secretary of Agriculture or by the responsible State official. Noxious weeds generally possess one or more of the following characteristics: aggressive and difficult to manage, poisonous, toxic, parasitic, a carrier or host of serious insects or disease, and being non-native or new to or not common to the United States or parts thereof. (FSM 2080.5) Octanol-Water Partition Coefficient (Kow ): The equilibrium ratio of the concentrations of a herbicide in n-octanol and water, in dilute solution. Oxidative phosphorylation: An metabolic process in which the metabolism of molecules in or derived from nutrients is linked to the conversion (phosphorylation) of ADP to ATP, a major molecule for storing energy in all living things. Parenteral: Any form of injection. Partition: In chemistry, the process by which a compound or mixture moves between two or more media. Pathogen: A living organism that causes disease; for example, a fungus or bacteria. Pathway: In metabolism, a sequence of metabolic reactions. Perennial plant: A plant species having a lifespan of more than 2 years. Perennial stream: A stream that flows throughout the year. Permeability: The property or condition of being permeable. In this risk assessment, dermal permeability refers to the degree to which a herbicide or herbicide in contact with the skin is able to penetrate the skin. pH: The negative log of the hydrogen ion concentration. A high pH (>7) is alkaline or basic and a low pH (<7) is acidic. Pharmacokinetics: The quantitative study of metabolism (i.e., the processes of absorption, distribution, biotransformation, elimination).

Physical (a type of weed treatment): hand-pulling, hoeing, grubbing. Physical (a type of weed treatment): hand-pulling, hoeing, grubbing, clipping seed head or plant, trimming with string trimmer, covering with mulch or tarp. Phytoestrogen: A naturally occurring compound of plants, such as soybeans, or plant products, such as whole grain cereals, that acts like estrogen in the body. pKa: The negative log of the hydrogen ion concentration or pH at which 50% of a weak acid is dissociated. Plasma cholinesterase: Another term for Pseudocholinesterase. The normal physiological role of this cholinesterase is not known. Inhibition of this enzyme is considered an index of exposure to many organophosphate insecticides.

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Plasma: The fluid portion of the blood in which particulates are suspended. Prospective: looking ahead. In epidemiology, referring to a study in which the populations for study are identified prior to exposure to a presumptive toxic agent, in contrast to a retrospective study. Protected Activity Center (PAC): This refers to areas of delineation around habitat for a specific animal. Protected activity centers are designed to minimize land disturbance within the delineated area. Pseudocholinesterase: A term for cholinesterase found in the plasma. The normal physiological role of this cholinesterase is not known. Inhibition of this enzyme is considered an index of exposure to many organophosphate insecticides. Reference dose (RfD) -- Oral dose (mg/kg/day) not likely to be associated with adverse effects over a lifetime exposure, in the general population, including sensitive subgroups. RfD: A daily dose that is not anticipated to cause any adverse effects in a human population over a lifetime of exposure. The U.S. EPA derives these values. Reproductive effects: Adverse effects on the reproductive system that may result from exposure to a herbicide or biological agent. The toxicity of the agents may be directed spray to the reproductive organs or the related endocrine system. The manifestations of these effects may be noted as alterations in sexual behavior, fertility, pregnancy outcomes, or modifications in other functions dependent on the integrity of this system. Resorption: Removal by absorption. Often used in describing the unsuccessful development and subsequent removal of post-implantation embryos. Retrospective: Looking behind. In epidemiology, referring to a study in which the populations for the study are identified after exposure to a presumptive toxic agent, in contrast to a prospective study. Riparian Conservation Area (RCA): The delineations of RCAs for this FEIS as described below, are from the Sierra Nevada Forest Plan Amendment FEIS Record of Decision (USDA Forest Service Pacific Southwest Region 2004 p.42), and for this FEIS the terms RCA and Streamside Management Zone (SMZ) are interchangeable. (Also see definition of Streamside Management Zone in this glossary.) Perennial Stream RCA: 300 feet on each side of the stream, measured from the bank full edge of the stream. Seasonally Flowing Stream RCA (includes intermittent and ephemeral streams): 150 feet on each side of the stream, measured from the bank full edge of the stream Special Aquatic Feature RCA (includes lakes, wet meadows, bogs, fens, wetlands, vernal pools, and springs): 300 feet from edge of feature or riparian vegetation, whichever width is greater.

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Route of exposure: The way in which a herbicide or biological agent enters the body. Most typical routes include oral (eating or drinking), dermal (contact of the agent with the skin), and inhalation. Ruderal: A ruderal plant grows where the natural vegetational cover has been disturbed by humans. Scientific notation: The method of expressing quantities as the product of number between 1 and 10 multiplied by 10 raised to some power. For example, in scientific notation, 1 kg = 1,000 g would be expressed as 1 kg = 1 x 103 g and 1 mg = 0.001 would be expressed as 1 mg = 1 x 10-3. Seasonally flowing stream: Any non-permanent flowing drainage feature having a definable channel and evidence of annual scour and deposition, including ephemeral and intermittent streams with a definable channel and evidence of annual scour or deposition. Sedimentation: The process of sediment deposition, usually resulting from erosion. Seed bank: Seeds that remain in the ground even after weeds are treated by herbicides or physical methods. They can remain viable for many years. Sensitive subgroup: Subpopulations that are much more sensitive than the general public to certain agents in the environment. Sensitive: Sensitive species for herbicide testing are those plant species used in testing that are more sensitive to the herbicides. These are not Forest Service Sensitive (FS sensitive) species. Sensitization: A condition in which one is or becomes hypersensitive or reactive to an agent through repeated exposure. Soil Quality Standards (SQS): Threshold values that indicate when changes in soil properties and soil conditions would result in significant change or impairment of productivity potential, hydrologic function, or buffering capacity of the soil. Detrimental soil disturbance is the resulting condition when threshold values are exceeded. Specialized pollination system: Association between a flowering plant species and a specific pollinator that is required to achieve cross-pollination and seed production. Species-to-species extrapolation: A method involving the use of exposure data on one species (usually an experimental mammal) to estimate the effects of exposure in another species (usually humans). Streamside Management Zone: An administratively designated zone adjacent to seasonally flowing and perennial channels, and around standing bodies of water, wetlands, springs, seeps, and other wet or marshland areas. SMZ is also meant to include naming conventions for streamside buffering areas such as stream projection zones, riparian reserves, riparian habitat conservation areas, and so forth. For the Noxious Weeds FEIS, the designated zone for all SMZs are the Riparian Conservation Areas on the Modoc National Forest. (Also see definition of Riparian Conservation Area in this glossary.) Therefore, for the Noxious Weeds FEIS, the terms SMZ and RCA are interchangeable. The Definition of SMZ is from Water Quality Management

Glossary 419 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

for Forest System Lands in California: Best Management Practices (USDA Forest Service Pacific Southwest Region 2000. p. 14). Sub-chronic exposure: An exposure duration that can last for different periods of time, but 90 days is the most common test duration. The subchronic study is usually performed in two species (rat and dog) by the route of intended use or exposure. Substrate: With reference to enzymes, the herbicide that the enzyme acts upon. Surfactant: A specific type of additive to a pesticide formulation that is intended to reduce the surface tension of the carrier, to allow for greater efficacy of the pesticide. Synapse: The space between two nerve cells or a nerve cell and an effector cell such as muscle. Synergistic effect: A situation is which the combined effects of two herbicides is much greater than the sum of the effect of each agent given alone. Systemic toxicity: Effects that require absorption and distribution of a toxic agent to a site distant from its entry point at which point effects are produced. Systemic effects are the obverse of local effects. Teratogenic: Causing structural defects that affect the development of an organism; causing birth defects. Teratology: The study of malformations induced during development from conception to birth. Terrestrial: Anything that lives on land as opposed to living in an aquatic environment. Threatened and Endangered Species (TES): A plant or animal species identified, defined, and recorded in the Federal Register, as being in danger of extinction throughout all or a significant portion of its range, in accordance with the Endangered Species Act of 1976. Threshold of Concern (TOC): The level of watershed disturbance that, if exceeded, could create adverse watershed or water quality effects, in spite of application of Best Management Practices and other Design Standards or other prevention measures. Activities near the threshold of concern create increased risks for adverse water quality effects and a possible need for additional analysis or extraordinary mitigation, including rescheduling of projects. Threshold: The maximum dose or concentration level of a herbicide or biological agent that will not cause an effect in the organism. Thymus: A small gland that is the site of T-cell production. The gland is composed largely of lymphatic tissue and is situated behind the breastbone. The gland plays an important role in the human immune system. Toxicity: The inherent ability of an agent to affect living organisms adversely. Uncertainty factor (UF): A factor used in operationally deriving the RfD and similar values from experimental data. UFs are intended to account or (1) the variation in sensitivity among members of the human population; (2) the uncertainty in extrapolating animal data to the case of

420 Glossary

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

humans; (3) the uncertainty in extrapolating from data obtained in a study that is less than lifetime exposure; and (4) the uncertainty in using LOAEL data rather than NOAEL data. Usually each of these factors is set equal to 10. See Table 2-5 for additional details. Undesirable Plants: Plant species that are classified as undesirable, noxious, harmful, exotic, injurious, or poisonous pursuant to State or Federal laws. Species listed as threatened or endangered by the Secretary of the Interior according to the Endangered Species Act of 1973 are not classified as undesirable plants. Upland vegetation: A plant species that is nearly always found in upland areas. Upland areas are any areas that do not qualify as a wetland because the associated hydrologic regime is not sufficiently wet to elicit development of vegetation, soils, or hydrologic characteristics associated with wetlands (U.S. Army Corps of Engineers, 1989). Urinalysis: Testing of urine samples to determine whether toxic or other physical effects have occurred in an organism. Vehicle: A substance (usually a liquid) used as a medium for suspending or dissolving the active ingredient. Commonly used vehicles include water, acetone, and corn oil. Vertebrate: An animal that has a spinal column (backbone). Vertical dispersion parameter: A term that mathematically describes the upward dispersion of a gas as it travels downwind. Volatile: Referring to compounds or substances that have a tendency to vaporize. A material that will evaporate quickly Watershed: A region or land area drained by a single stream, river, or drainage network. Xenobiotic – A substance not naturally produced within an organism; substances foreign to an organism. Xenoestrogen – An estrogen not naturally produced within an organism. Zwitterion: A molecule with regions of both positive and negative charges.

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Literature Cited Adams, Peter. 2007a. Draft Noxious Weed FEIS Hydrology and Soils Report. Forest Service, U.S. Department of Agriculture, Modoc National Forest, Alturas, California, USA. Adams, Peter L. 2007b. H20 and Soil Herb document. Forest Service, U.S. Department of Agriculture, Modoc National Forest, Alturas, California, USA. Adams, Peter L, 2007c. Review of the MDF LRMP -Water document. Forest Service, U.S. Department of Agriculture, Modoc National Forest, Alturas, California, USA. Agency for Toxic Substances and Disease Registry (ATSDR). 2004. Guidance Manual for the Assessment of Joint Toxic Action of Chemical Mixtures. U.S. Department of Health Services, Public Health Service, ATSDR, Division of Toxicology. May 2004. 108 pp. On-line (accessed on May 26, 2005) at http://www.atsdr.cdc.gov/interactionprofiles/ipga.html. Aly, O.M., and S. D. Faust, 1964. Studies on the fate of 2, 4-D and ester derivatives in natural surface waters,. Agric. Food Chem. 12(6):541-546. Anderson, A. E., and O. C. Wallmo. 1984. Odocoileus hemionus. Mammalian Species No. 219, 9pp. Anderson, J. P. E., 1982, Soil respiration, Pages 831-871 in A. L. Page, R. H. Miller, and D. R. Keeney, editors, Agronomy Monograph Number 9: Part 2, Chemical and biological properties. Second edition, American Society of Agronomy and Soil Science Society of America, Madison, Wisconsin Arthur, M.A., and Wang, Y. 1999. Soil nutrients and microbial biomass following weed control treatments in a Christmas tree plantation. Soil Science Society of America Journal 63(3): p.629-37. Audus , L.J.,1960 Herbicide behavior in the soil. Chapter 5 in physiology and biochemistry of herbicides. L.J. Audus ed. Academic press, New York, N.Y. 555 pgs. Austin, K. 1993. Habitat use and home range size of breeding northern goshawks in the southern Cascades. Masters Thesis, Oregon State University. Bais, H.P., R.Vepachedu, S. Gilroy, R.M. Callaway, J.M. Vivanco. 2003. Allelopathy and exotic plant invasion: from molecules and genes to species interactions. Science. 301: 1377-1380 Baker, B., B. Cade, W. Mangus, and J. McMillen. 1995. Spatial analysis of snadhill crane nesting habitat. 59(4): 752-758. Bakke, David. 2001, A Review and Assessment of the Results of Water Monitoring for Herbicide Residues, For the Years 1991 to 1999, USFS Region Five. Albany, CA. Bakke, David. 2003. Analysis of Issues Surrounding the Use of Spray Adjuvants With Herbicides. Pacific Southwest Research Station, USDA Forest Service, Albany, CA. Bautista, Shawna. 2004.

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Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Index 2,4-D ...... 4, 27, 29, 30, 33, 36, 47, 48, 49, 125, 128, 129, 142, 148, 149, 159, 181, 50, 55, 56, 57, 58, 63, 64, 65, 66, 67, 68, 190, 192, 195, 201, 228, 229, 230, 231, 69, 70, 77, 79, 89, 91, 92, 163, 166, 168, 234, 242, 244, 246, 249, 252, 254, 290, 169, 171, 172, 173, 174, 175, 176, 177, 300, 301, 302, 307, 312, 313, 314, 325, 178, 179, 180, 181, 183, 228, 289, 290, 326, 327, 331, 342, 346, 350, 354, 362, 295, 299, 300, 312, 313, 321, 326, 336, 363, 368, 369, 376, 377, 384 337, 342, 346, 350, 368, 369, 377, 378, American marten...xii, 315, 317, 318, 384, 425, 431, 434, 440, 441, 442, 448, 319, 320, 321, 347 449 Aquatic... ..i, v, vii, xii, 2, 7, 9, 35, 36, 39, Adaptive...... ii, iii, v, vii, 1, 16, 19, 37, 81 40, 41, 44, 45, 46, 47, 48, 50, 52, 54, 55, Adaptive management...... v, vii, 1 56, 57, 58, 64, 66, 67, 68, 69, 70, 82, 98, Air quality .... x, 95, 96, 97, 98, 239, 394, 109, 110, 112, 119, 120, 121, 122, 124, 405, 406 138, 145, 149, 152, 186, 220, 243, 250, Alternative 1...... ii, ix, x, xi, 39, 43, 74, 255, 256, 257, 259, 260, 261, 264, 265, 75, 80, 81, 118, 126, 139, 142, 157, 161, 266, 267, 268, 269, 270, 271, 274, 275, 162, 189, 191, 192, 198, 199, 201, 212, 277, 278, 279, 282, 283, 284, 285, 286, 213, 214, 221, 231, 232, 240, 243, 244, 287, 288, 289, 290, 291, 297, 317, 322, 245, 247, 250, 251, 259, 267, 277, 282, 351, 388, 405, 410, 418, 420, 429, 434, 285, 288, 296, 302, 303, 306, 309, 311, 438 319, 323, 329, 334, 340, 344, 348, 352, Blue grouse...xii, 1, 347, 348, 349, 350, 356, 359, 360, 364, 365, 371, 374, 379, 351 382, 385, 387, 389 Brown trout..... 274, 281, 287, 288, 290, Alternative 2...... i, iii, v, ix, x, xi, 9, 38, 291 39, 44, 45, 74, 75, 79, 80, 81, 125, 126, California spotted owl ...... xii, 302, 139, 140, 141, 142, 145, 147, 148, 157, 303, 347, 410 158, 159, 189, 190, 191, 194, 195, 201, California wolverine.....xii, 305, 306, 214, 215, 216, 217, 219, 220, 221, 222, 347 223, 224, 226, 229, 230, 232, 233, 234, Canada goose and mallard ....351, 241, 242, 243, 247, 249, 250, 251, 252, 352, 353, 355 319, 362, 368, 376 Canada thistle...... 8, 23, 29, 93, 112, Alternative 3...... iii, iv, ix, x, xi, 51, 74, 147, 149, 187, 192, 240, 249, 251, 256, 75, 80, 81, 125, 126, 140, 141, 147, 148, 257, 297, 300, 320, 322, 325, 326, 334, 159, 160, 189, 191, 194, 195, 201, 220, 338, 350, 354, 355, 362, 363, 371, 372, 221, 222, 224, 226, 227, 228, 233, 234, 377, 378, 381 237, 241, 242, 244, 248, 249, 251, 252, Chlorsulfuron...... iv, vi, 13, 21, 28, 29, 301 30, 31, 33, 36, 41, 42, 62, 63, 64, 65, 66, Alternative 4.....iii, ix, x, xi, 52, 54, 74, 67, 68, 69, 70, 77, 79, 91, 122, 124, 128, 75, 79, 80, 81, 125, 127, 141, 148, 159, 131, 133, 135, 137, 142, 148, 150, 154, 189, 191, 194, 223, 224, 225, 226, 230, 157, 158, 163, 169, 171, 172, 173, 174, 231, 232, 234, 241, 244, 249, 251 175, 176, 177, 178, 179, 180, 181, 182, Alternative 5 ..iii, iv, v, ix, x, xi, 21, 59, 228, 290, 295, 300, 304, 307, 313, 336, 60, 61, 74, 75, 80, 81, 121, 123, 125, 127, 337, 350, 367, 368, 440, 441, 449 128, 141, 142, 148, 159, 189, 190, 192, Clopyralid ... v, 21, 27, 28, 29, 33, 34, 41, 195, 201, 226, 227, 228, 232, 234, 237, 44, 46, 47, 48, 49, 50, 52, 55, 56, 57, 58, 242, 244, 249, 252 62, 63, 64, 65, 66, 67, 68, 69, 77, 79, 91, Alternative 6...... iv, vi, ix, x, xi, 21, 22, 92, 119, 122, 124, 126, 127, 129, 132, 31, 33, 36, 38, 41, 43, 61, 62, 63, 70, 74, 133, 135, 137, 150, 154, 157, 163, 165, 75, 78, 79, 80, 81, 118, 121, 122, 124, 169, 171, 172, 173, 174, 175, 176, 177,

Index 453 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

178, 179, 180, 181, 182, 214, 223, 228, Endangered Species... 247, 254, 258, 289, 290, 300, 304, 307, 313, 336, 337, 291, 297, 392, 406, 412, 420, 421, 427 350, 367, 368, 377, 378, 440, 441, 442, Environmental impacts ....1, 21, 39, 448, 449 393 Common crupina... iv, 4, 8, 11, 23, 59, Federally listed species ...239, 255, 61, 128, 129, 141, 158, 189, 190, 192, 262, 263, 270, 315 226, 229, 242, 249, 250 Fire ...... x, xi, 2, 5, 9, 24, 27, 28, 29, 42, 72, County... i, 3, 4, 13, 22, 23, 39, 76, 78, 79, 73, 86, 87, 88, 89, 92, 93, 94, 95, 96, 97, 83, 90, 91, 92, 93, 95, 153, 154, 155, 157, 98, 99, 120, 121, 123, 155, 162, 184, 192, 184, 185, 187, 188, 191, 192, 204, 205, 197, 199, 204, 237, 239, 240, 243, 246, 206, 207, 209, 210, 212, 215, 246, 250, 250, 254, 262, 263, 269, 270, 318, 327, 258, 259, 263, 266, 270, 310, 325, 335, 338, 339, 340, 365, 385, 386, 388, 395, 336, 341, 350, 358, 378, 380, 399, 400, 398, 406, 427 402, 437, 438, 445 Fish .. 10, 16, 109, 110, 117, 118, 163, 170, Crupina ... iv, 4, 8, 11, 23, 59, 61, 75, 128, 171, 179, 184, 216, 217, 240, 254, 255, 149, 189, 190, 192, 226, 229, 242, 249, 257, 258, 259, 262, 263, 264, 265, 268, 250, 313, 314, 362, 369, 377 273, 279, 280, 283, 284, 285, 287, 290, Dalmatian toadflax. 8, 17, 22, 23, 61, 293, 295, 296, 297, 299, 300, 301, 316, 75, 112, 117, 128, 129, 141, 146, 147, 351, 355, 370, 371, 372, 373, 386, 388, 149, 154, 158, 187, 188, 192, 201, 229, 408, 431, 437, 438, 442, 443, 447, 451, 231, 233, 235, 256, 313, 325, 326, 342, 452 343, 354, 355, 361, 362, 369, 376, 377 Fuels. ...xi, 4, 5, 72, 86, 87, 93, 94, 96, 97, Design Standards .. vi, x, xvi, 1, 7, 18, 98, 99, 105, 199, 237, 243, 246, 250, 262, 21, 22, 24, 37, 39, 43, 44, 53, 59, 62, 70, 263, 269, 271, 395 86, 99, 100, 101, 118, 119, 120, 121, 124, Glyphosate...... v, 4, 7, 9, 21, 27, 28, 29, 127, 128, 129, 130, 136, 138, 141, 142, 31, 33, 34, 35, 38, 40, 41, 42, 43, 44, 45, 145, 147, 153, 158, 159, 164, 191, 196, 46, 47, 48, 50, 52, 54, 55, 56, 57, 58, 62, 216, 218, 221, 224, 228, 230, 233, 245, 64, 65, 66, 67, 68, 69, 70, 77, 79, 91, 92, 246, 248, 252, 260, 261, 264, 268, 271, 93, 96, 98, 99, 111, 119, 122, 123, 124, 278, 279, 282, 283, 286, 287, 289, 290, 125, 126, 127, 129, 132, 134, 135, 137, 291, 295, 297, 302, 304, 308, 309, 321, 138, 142, 145, 146, 147, 148, 149, 150, 326, 327, 332, 337, 342, 346, 350, 351, 152, 154, 158, 163, 165, 166, 169, 171, 355, 358, 363, 366, 369, 370, 373, 377, 172, 173, 174, 175, 176, 177, 178, 179, 378, 381, 384, 387, 392, 420 180, 181, 182, 183, 184, 188, 191, 214, Dicamba .. v, 4, 13, 21, 27, 28, 29, 30, 31, 217, 223, 228, 264, 271, 289, 290, 300, 33, 34, 35, 36, 37, 40, 41, 42, 44, 46, 47, 304, 308, 312, 313, 314, 336, 337, 342, 48, 49, 50, 52, 55, 56, 57, 58, 62, 63, 64, 350, 367, 368, 414, 425, 427, 428, 429, 65, 66, 67, 68, 69, 70, 77, 79, 91, 92, 111, 433, 435, 439, 440, 441, 442, 448, 451, 119, 122, 124, 126, 127, 129, 132, 133, 452 135, 137, 140, 142, 148, 150, 154, 157, Golden eagle... 292, 355, 356, 357, 358, 163, 169, 171, 172, 173, 174, 175, 176, 426, 433, 434, 443 177, 178, 179, 180, 181, 182, 183, 214, Goose Lake redband trout...... 256, 223, 228, 289, 290, 300, 304, 307, 312, 257, 265, 267, 270, 271, 274, 275, 285, 313, 336, 337, 350, 367, 368, 384, 429, 286, 287 434, 441, 448 Grazing ....iii, vi, 6, 10, 13, 22, 24, 25, 50, Dyer’s woad...... iv, 8, 59, 61, 189, 190, 52, 58, 59, 61, 71, 74, 76, 88, 92, 105, 240, 242, 249, 250, 429 109, 110, 128, 129, 130, 141, 148, 156, Early detection-rapid response 160, 190, 193, 194, 195, 196, 199, 201, ...... v, 111, 141, 148, 153 203, 209, 212, 215, 220, 226, 229, 237, 239, 242, 249, 259, 262, 265, 269, 280,

454 Index

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

285, 288, 322, 327, 332, 338, 339, 340, 366, 370, 372, 373, 375, 378, 380, 381, 342, 343, 344, 346, 354, 385, 386, 389, 383, 388, 406, 415, 445, 446 414, 432 Manual treatment...iii, 5, 8, 9, 40, 42, Great gray owl ...... 308, 309, 310, 425 59, 61, 127, 128, 130, 160, 189, 190, 192, Greater sandhill crane...... 322, 324, 221, 222, 226, 241, 244, 245, 248, 249, 328, 428, 431, 433 260, 267, 271 Hairy woodpecker...... 359, 360, 361, Mechanical treatment...... iii, 18, 38, 362, 363, 377 61, 87, 89, 92, 160, 162, 202, 214, 221, Hand pulling ... 4, 5, 7, 8, 25, 44, 50, 51, 223, 241, 262, 269, 279, 283, 286, 289, 52, 58, 59, 61, 65, 74, 126, 128, 129, 144, 290 215, 220, 223, 226 Mediterranean sage ... 8, 23, 93, 155, Heritage resources. 38, 40, 159, 160, 156, 187, 192, 239, 256, 297, 331, 342, 161, 218, 222, 224, 230, 233, 397 343 Hexazinone ... v, 4, 21, 33, 92, 154, 217, Modoc county... 3, 4, 13, 39, 76, 78, 79, 440 91, 92, 93, 187, 188, 191, 192, 204, 205, Human health...... ii, xi, 6, 10, 19, 35, 206, 207, 209, 210, 212, 246, 250, 258, 101, 156, 161, 162, 163, 164, 166, 167, 325, 335, 336, 380, 399, 400, 402, 438 183, 184, 186, 190, 197, 207, 210, 211, Modoc County .. 3, 4, 13, 22, 23, 39, 76, 213, 215, 216, 217, 218, 220, 221, 222, 78, 79, 91, 92, 93, 111, 153, 154, 155, 229, 230, 237, 238, 239, 391, 395, 429, 156, 187, 188, 191, 192, 204, 205, 206, 439, 440, 441, 442, 449 207, 209, 210, 212, 238, 246, 250, 258, Integrated weed management 325, 335, 336, 380, 399, 400, 402, 438 ... vi, ix, 1, 4, 6, 11, 37, 38, 43, 75, 86, 87, Modoc plateau ...... 101, 102, 203, 266, 406, 414 335 Inventoried roadless areas..... 86, Modoc sucker. 256, 257, 258, 260, 261, 197, 199, 200, 201, 202, 204, 393 263, 264, 274, 275, 276, 281, 282, 283, Issues. ....i, ii, iii, ix, x, 11, 12, 14, 16, 18, 284, 429, 443, 447 19, 39, 51, 52, 59, 61, 71, 81, 82, 108, Monitoring ...vi, x, xi, xii, 1, 3, 4, 11, 34, 118, 136, 161, 166, 211, 224, 227, 229, 36, 37, 44, 85, 87, 101, 111, 118, 125, 230, 302, 312, 314, 338, 384, 388, 390, 137, 197, 203, 205, 218, 219, 222, 225, 423, 428, 429, 445, 446 227, 230, 231, 233, 255, 262, 270, 272, Klamath weed ..... 8, 12, 23, 30, 43, 45, 273, 274, 275, 276, 279, 280, 284, 298, 112, 187, 192, 235, 313 315, 316, 317, 320, 324, 325, 326, 328, Knapweed ... iv, 8, 23, 27, 28, 45, 46, 47, 331, 335, 341, 345, 349, 353, 354, 357, 49, 51, 54, 55, 57, 60, 64, 65, 66, 67, 68, 361, 366, 367, 372, 375, 380, 383, 390, 69, 77, 78, 92, 93, 106, 112, 113, 117, 396, 407, 409, 416, 423, 431, 445, 449, 155, 162, 187, 188, 191, 192, 198, 239, 450 240, 256, 259, 267, 313, 334, 365, 430, Mule deer.. 208, 291, 364, 365, 366, 368, 432, 444 369, 370 Largemouth bass..274, 284, 287, 288, Musk thistle .. 25, 28, 45, 48, 51, 54, 56, 290, 291 60, 63, 64, 67, 68, 77, 93, 112, 113, 117, Leafy spurge .. 162, 188, 365, 424, 432, 141, 192 433, 452 Native Americans ...... ii, 5, 19, 73, 81, Management indicator species 159, 160, 171, 207, 210, 211, 213, 216, (MIS) .... xii, 11, 40, 239, 254, 255, 256, 217, 218, 221, 224, 227, 230, 231, 232, 257, 264, 271, 272, 273, 274, 275, 276, 233, 234, 235, 237 277, 280, 281, 284, 287, 293, 294, 298, NEPA ...... ii, iii, 1, 4, 11, 18, 44, 71, 72, 75, 302, 315, 316, 317, 320, 322, 324, 331, 86, 93, 94, 95, 139, 142, 157, 204, 212, 335, 338, 341, 343, 345, 347, 349, 351, 232, 234, 261, 262, 270, 272, 314, 387, 353, 354, 355, 357, 359, 361, 364, 365, 390, 391, 395, 399, 401, 406, 412, 416

Index 455 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

Northern goshawk...... 308, 328, 329, Prairie falcon....xii, 316, 355, 356, 357, 330, 331, 332, 423, 424, 427, 431, 438 358 Noxious weed strategy...... 264 Preferred alternative...... iv, ix Noxious weeds... ..i, ii, iii, iv, v, vi, vii, Prescribed fire... 24, 72, 73, 87, 89, 92, x, xi, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 19, 21, 97, 98, 99, 105, 155, 156, 199, 237, 246, 22, 24, 25, 32, 33, 39, 40, 41, 42, 44, 51, 327, 338, 385, 386 52, 59, 61, 62, 71, 73, 74, 75, 81, 82, 87, Pronghorn...... 208, 355, 364, 365, 366, 88, 89, 90, 91, 92, 93, 97, 99, 105, 106, 367, 369, 370, 428, 430, 438 107, 111, 113, 117, 119, 120, 121, 122, Proposed action..... i, ii, iii, v, ix, x, xi, 123, 125, 126, 127, 128, 129, 131, 139, xii, 1, 7, 9, 10, 11, 12, 15, 18, 19, 39, 44, 140, 141, 147, 148, 149, 153, 154, 155, 71, 81, 83, 86, 87, 95, 101, 118, 124, 126, 160, 161, 162, 163, 165, 169, 187, 188, 153, 154, 156, 159, 191, 192, 193, 199, 189, 190, 191, 192, 193, 194, 195, 196, 204, 212, 214, 239, 243, 244, 247, 251, 197, 198, 199, 200, 201, 202, 203, 204, 253, 254, 255, 261, 265, 268, 274, 277, 207, 209, 210, 211, 212, 213, 214, 215, 305, 387, 390, 391, 392 220, 221, 223, 226, 228, 230, 234, 235, Public involvement...... 391 236, 237, 238, 239, 240, 241, 242, 243, Purpose and Need...i, v, ix, 1, 5, 6, 7, 244, 245, 246, 247, 248, 249, 250, 251, 10, 18, 39, 44, 71, 193, 212 252, 253, 254, 259, 260, 261, 262, 263, Rainbow trout 274, 287, 288, 290, 291, 267, 268, 269, 270, 271, 277, 278, 279, 424 282, 283, 285, 286, 287, 288, 289, 290, Rangelands...... 2, 5, 154, 183, 193, 196, 293, 294, 295, 296, 301, 303, 306, 309, 212, 215, 289, 364, 388, 389, 397, 427, 311, 315, 319, 320, 321, 323, 324, 326, 428 327, 328, 329, 331, 332, 333, 334, 335, Recreation ....xi, 2, 4, 5, 86, 88, 94, 110, 336, 337, 338, 339, 340, 343, 344, 346, 118, 155, 190, 193, 196, 197, 198, 199, 347, 348, 349, 350, 351, 352, 353, 355, 200, 201, 202, 203, 205, 207, 208, 212, 356, 358, 359, 360, 364, 365, 366, 367, 218, 220, 233, 237, 243, 251, 263, 270, 369, 370, 371, 373, 374, 375, 378, 379, 271, 314, 332, 343, 346, 388, 396, 397, 381, 382, 384, 385, 387, 388, 389, 391, 398 414, 417, 419, 426, 434, 435, 450 Red-breasted sapsucker .316, 375, Osprey ...... 370, 371, 372, 373 378, 451 Pallid and Townsend’s big- Red-naped sapsucker...... 374, 376, eared bats...... xii, 310, 311 428 Perennial pepperweed ... vi, 22, 240 Research natural areas...... i, xi, 76, Physical and mechanical 199, 203, 393 treatment methods .... .i, 9, 18, 40, Riparian areas...... 6, 9, 10, 26, 88, 99, 44, 74, 76, 160, 188, 189, 190, 191, 194, 100, 109, 110, 112, 113, 117, 135, 137, 210, 213, 216, 218, 220, 221, 222, 223, 158, 196, 240, 260, 261, 268, 278, 282, 224, 226, 227, 229, 230, 241, 242, 244, 283, 286, 288, 289, 306, 318, 319, 329, 245, 246, 248, 249, 250, 251, 252, 260, 332, 343, 345, 351, 355, 381, 383 267, 271, 278, 282, 285, 288, 294, 296, Risk ...ii, iv, 4, 7, 22, 26, 28, 33, 37, 42, 44, 297, 299, 302, 303, 306, 307, 309, 72, 85, 87, 89, 90, 96, 98, 100, 101, 109, 311, 312, 313, 314, 315, 319, 320, 321, 110, 120, 121, 123, 125, 131, 135, 136, 323, 324, 325, 329, 330, 331, 332, 334, 137, 139, 140, 145, 147, 153, 156, 160, 335, 337, 340, 342, 344, 345, 346, 348, 161, 162, 163, 164, 165, 166, 167, 168, 349, 352, 353, 354, 356, 357, 360, 364, 169, 170, 171, 172, 173, 174, 175, 177, 365, 367, 369, 371, 372, 374, 375, 379, 178, 179, 181, 182, 183, 184, 185, 186, 380, 382, 383, 385, 386 190, 204, 215, 216, 217, 218, 220, 221, Plumeless thistle ...... 8, 23, 187, 191, 224, 227, 229, 230, 231, 233, 234, 238, 192 239, 244, 247, 252, 260, 261, 262, 268,

456 Index

Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

269, 270, 278, 282, 283, 285, 286, 288, Squarrose knapweed .. 92, 155, 191, 289, 291, 293, 294, 300, 304, 307, 308, 192 309, 312, 313, 314, 318, 321, 325, 326, St. Johnswort.... 8, 43, 45, 77, 112, 235 327, 331, 332, 336, 337, 349, 350, 354, Strategy ..iii, iv, v, 4, 5, 9, 11, 52, 59, 62, 358, 362, 367, 368, 369, 370, 376, 377, 87, 100, 127, 128, 129, 194, 195, 224, 378, 383, 391, 392, 395, 406, 411, 416, 239, 261, 451 417, 426, 445, 448, 451, 452 Tall whitetop ...... 191, 192, 372 Roads...... 8, 87, 88, 90, 96, 105, 109, 112, Tank mix .... iv, 31, 36, 40, 132, 133, 195, 118, 131, 137, 140, 149, 157, 193, 197, 290, 295, 300, 312, 337, 350, 384, 434 200, 204, 208, 237, 238, 263, 271, 304, Treatment priorites...... 9 354 Treatment protocol ...... vi Safety .... ii, vi, 19, 22, 32, 81, 90, 91, 161, Tribal relations 162, 163, 164, 166, 167, 172, 174, 176, consultation...... 12, 15, 16, 17, 71, 111, 177, 182, 183, 190, 208, 216, 217, 218, 119, 210, 231, 233, 235, 236, 237, 264, 221, 224, 227, 229, 230, 233, 415, 429 295, 392 Sage grouse...... xii, 40, 316, 332, 333, issues and concerns...... ii, iii, 19, 52, 334, 335, 336, 337, 338, 347, 424, 426, 211, 232, 235, 236, 237 427, 430, 432, 437, 443 Triclopyr.. v, 4, 21, 29, 31, 33, 35, 36, 41, Scotch thistle . 8, 23, 92, 112, 147, 148, 44, 46, 50, 52, 55, 57, 58, 62, 64, 66, 69, 149, 154, 155, 156, 187, 188, 189, 192, 77, 91, 119, 122, 124, 126, 127, 129, 132, 198, 236, 239, 248, 253, 256, 297, 301, 133, 136, 137, 138, 140, 142, 150, 154, 314, 325, 326, 342, 343, 369, 370, 377, 158, 163, 165, 166, 169, 171, 172, 173, 378 174, 175, 176, 177, 178, 179, 180, 182, Sensitive species..... 5, 6, 10, 11, 192, 183, 184, 185, 214, 217, 223, 228, 289, 200, 201, 239, 247, 248, 249, 251, 252, 290, 300, 304, 308, 312, 313, 321, 336, 253, 254, 255, 269, 285, 291, 315, 419, 337, 350, 367, 368, 440, 441, 448 424 Water quality . 6, 10, 12, 17, 34, 36, 39, Sierra Nevada red fox...... xii, 305, 99, 100, 107, 111, 118, 119, 120, 121, 306, 307, 347 122, 123, 134, 136, 145, 146, 149, 153, Soil ...i, ii, iv, 2, 5, 6, 7, 8, 9, 10, 19, 25, 26, 197, 212, 219, 225, 230, 231, 240, 275, 30, 31, 32, 33, 34, 35, 36, 38, 42, 71, 72, 280, 290, 291, 297, 346, 355, 373, 384, 82, 87, 89, 99, 100, 101, 102, 103, 104, 388, 395, 399, 401, 410, 420, 446, 447 105, 106, 107, 109, 118, 119, 120, 121, Watershed ... 5, 10, 17, 40, 42, 111, 113, 122, 123, 129, 130, 131, 132, 133, 134, 119, 120, 123, 135, 140, 141, 143, 150, 135, 136, 139, 140, 141, 142, 143, 145, 153, 156, 157, 158, 159, 237, 265, 285, 146, 147, 148, 157, 160, 170, 172, 185, 326, 388, 394, 420, 421 189, 190, 191, 192, 196, 198, 200, 203, Wavyleaf thistle ...... v 204, 219, 220, 221, 222, 225, 227, 230, Western gray squirrel...... 378, 379, 231, 239, 240, 241, 242, 243, 244, 245, 380, 381, 439, 443 246, 248, 250, 259, 260, 261, 267, 268, Wilderness..i, vi, xi, 22, 84, 86, 96, 197, 277, 278, 279, 282, 283, 285, 286, 288, 198, 199, 202, 203, 263, 270, 305, 393, 289, 290, 384, 385, 387, 388, 394, 395, 402 396, 419, 423, 425, 439, 444, 451 Wildlife..i, iv, vi, 2, 5, 6, 7, 10, 17, 22, 38, Sooty grouse...... xii, 315, 347 39, 88, 92, 97, 118, 186, 193, 198, 199, Special interest areas...... 199, 203, 204, 208, 212, 215, 220, 237, 239, 240, 204 245, 254, 255, 256, 262, 263, 269, 270, Special uses... xi, 87, 90, 155, 238, 396, 273, 291, 293, 294, 304, 308, 309, 314, 397 317, 321, 326, 332, 337, 342, 344, 346, Spotted knapweed...... 93, 106, 112, 351, 355, 358, 362, 363, 364, 365, 369, 113, 139, 192, 198, 240, 365, 432 370, 373, 377, 378, 381, 384, 386, 388,

Index 457 Modoc National Forest Noxious Weed Treatment Project Environmental Impact Statement

396, 397, 398, 399, 405, 408, 410, 414, Yellow starthistle ...... 3, 23, 31, 190, 426, 427, 430, 431, 436, 437, 438, 439, 191, 192, 198, 239, 240, 426 443, 444, 447, 452 Yellow warbler...... 381, 382, 383, 384, Willow flycatcher...... 316, 343, 344, 425 345, 346, 347, 376, 383, 424, 429, 431, 439

458 Index