United States Environmental Assessment Department of Agriculture Invasive Weed Management

Forest on the Service Cleveland National Forest

July 2014

Lead Agency: USDA Forest Service Cleveland National Forest 10845 Rancho Bernardo Road, Suite 200 San Diego, CA 92127-2107

San Diego, Orange and Riverside Counties, California

CHAPTER 1 Introduction

1.1 Document Structure

The Cleveland National Forest (CNF) has prepared this Invasive Weed Management Plan Environmental Assessment in compliance with the National Environmental Policy Act (NEPA) and other relevant federal laws and regulations. This environmental assessment discloses the direct, indirect, and cumulative environmental effects that would result from the proposed action and alternatives. The document is organized into the following parts:

• Chapter 1: Introduction. This chapter includes the background information on project area, the purpose and need for the project, and a description of the proposed action. This chapter also details how the public was informed of the proposal and how the public responded. • Chapter 2: Alternatives. This chapter provides a more detailed description of the proposed action as well as any alternative methods for achieving the stated purpose that may have been developed based on significant issues raised by the public and other government agencies during the scoping period. This chapter includes possible mitigation measures. • Chapter 3: Environmental Consequences. This chapter describes the affected environment for each resource, as well as the environmental effects of implementing the proposed action and any other alternatives. • Chapter 4: Agencies and Persons Consulted, and References. This section provides a list of preparers and agencies consulted during the development of the environmental assessment and a bibliography of references in the document. • Appendix A: Maps • Appendix B: Response to Comments

Additional documentation, including more detailed analyses of project-area resources, may be found in the project planning record located at the Cleveland National Forest Supervisor’s Office, 10845 Rancho Bernardo Road, Suite 200, San Diego, CA 92127.

1.2 Background

The spread of invasive weeds on National Forest System lands (NFS lands) is threatening the health of riparian, forest, chaparral and grassland ecosystems. Non-native invasive weed species reduces native biological diversity, negatively impact threatened and endangered species, degrade wildlife habitat, modify vegetative structure and species composition, change fire and nutrient cycles and degrade soil structure.

Cleveland National Forest Invasive Weed Management EA 1 The Cleveland National Forest Land Management Plan (LMP)(USDA 2005) has goals to reverse the trend of increasing loss of natural resource values due to invasive species (Goal 2.1), retain a natural evolving character within wilderness (Goal 3.2), improve watershed conditions through cooperative management (Goal 5.1), improve riparian conditions (Goal 5.2), and provide ecological conditions to sustain viable populations of native and desired non-native species (Goal 6.2). The LMP also directs the Forest to adopt a Weed Management Strategy that uses an integrated pest management approach (appendix M in the Forest Plan, part 3).

The LMP is responding to multiple directives and laws regarding invasive species including: • The Federal Noxious Weed Act of 1974 (7 USC 214), Section 15, 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 USC 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]). • Executive Order 13112 of February 3, 1999, Invasive Species, directs agencies to identify which actions could affect the status of invasive species; use an integrated weed management approach to managing invasive species; and not authorize, fund, or carry out actions that would likely cause or promote the introduction or spread of invasive species unless it can be shown the actions clearly outweigh the potential harm caused by invasive species. • The National Strategy and Implementation Plan for Invasive Species Management was completed in 2004 and has been updated in 2013 as the Forest Service National Strategic Framework for Invasive Species Management (USDA 2013). These documents directs Forest Service Units to adopt a “Systems Approach” to invasive species management. • The US Forest Service National Strategic Plan (USDA 2007) includes objectives to reduce adverse impacts from invasive and native species, pests, and diseases, and restore and maintain healthy watersheds and diverse habitats.

To implement the CNF Weed Management Strategy the Forest has implemented an integrated pest management (IPM) approach to invasive weed management. IPM in invasive weed management incorporates 1) prevention of weed infestations, 2) monitoring and assessment of weed populations, 3) utilizing the most appropriate control method including mechanical, biological, chemical and cultural control methods always considering human health, ecological impact, feasibility, and cost-effectiveness and 4) evaluating and monitoring success of control treatments.

The CNF prevention strategy for invasive weeds includes actions during project planning and implementation. Weed risk assessments are conducted as part of project planning. During project implementation, design criteria are put into place to minimize or prevent the introduction and spread of invasive weeds. These actions are guided by generally agreed upon best management practices to prevent the spread of invasive weeds (Cal-IPC 2012). These include vehicle washing, treating or avoiding known infestations in project areas, enforcing standards for

Cleveland National Forest Invasive Weed Management EA 2 weed free waddles and hydromulch and using weed free seed in revegation efforts . Forest personnel monitor invasive weed infestations regularly and have undertaken several post fire weed survey efforts. Volunteers have been enlisted to inventory invasive weeds in several locations on the Forest as well.

Since the adoption of the current LMP, the Cleveland National Forest has undertaken several invasive weed control projects as authorized by several separate NEPA decisions. The Forest undertook a project to eradicate the largest tamarisk infestation on the CNF at the confluence of Cottonwood and La Posta Creeks on the Descanso Ranger District near Lake Moreno, CA. This project was planned and undertaken in cooperation with the County of San Diego. The heavy infestation of tamarisk was cut and stumps were sprayed with triclopyr-based herbicide. Follow- up treatments have been ongoing. The project has been successful in drastically reducing tamarisk cover and native riparian vegetation is beginning to recover and replace areas previously dominated by tamarisk.

Following the 2007 wildfires, the CNF undertook manual riparian weed control in areas burned by the Witch Fire on the Palomar Ranger District. This included weed wrenching Spanish Broom, Tree Tobacco, and small Tamarisk plants in Santa Ysabel Creek and Carney Canyon. The Forest has also treated Spanish Broom along the Ortega Highway on the Trabuco Ranger District and Los Terrenitos Road on the Descanso Ranger District using herbicides. Volunteers have worked to manually clear invasive thistles in several location on the Trabuco Ranger District.

The Forest completed planning to remove multiple target invasive weed species from west- flowing drainages of the Santa Ana Mountains on the Trabuco Ranger District using a variety of methods, including herbicide. Under this planning document, the Forest has treated infestations of Arundo donax in San Juan, Hot Springs, Trabuco and Hot Springs Canyons. The Forest also has treated Spanish Broom in San Juan Canyon and has treated isolated Pampas Grass, Spanish Broom and tamarisk in San Mateo Wilderness in autumn 2013.

1.3 Purpose and Need

The primary purpose of this proposal is to plan for the eradication or control of certain weed populations on the Forest to improve ecosystem stability, native plant diversity, and wildlife habitat. The other purpose is to create a rapid response protocol for species that have the potential to become established and expand rapidly on the Forest. There is a need to provide for aggressive treatment of new infestations of invasive plants (in terms of new areas and new species) to allow for rapid treatment and containment of small infestations before they spread.

The CNF completed planning for forest wide invasive weed treatments in 2008 that authorized manual removal (non-herbicide) only. Several projects have been undertaken on the Forest treating invasive weeds utilizing manual removal methods only. These efforts have been worthwhile and have reduced the cover of invasive weed species in the locations they took place, but they have also illustrated the drawbacks of relying on manual treatment methods only when compared to locations where herbicide use was included. For example:

Cleveland National Forest Invasive Weed Management EA 3 • A black locust infestation covering approximately one acre has been repeatedly treated by manual cutting in Observatory Campground on the Palomar Ranger District. Trees were originally cut down in 2003, and rapidly resprouted. Repeated cuttings have been conducted since 2003 of repsrouts. In 2011 the Forest had access to a labor crew that was directed to grub out black locust roots. The effort took 10 persons one week. Despite these efforts some black locust remains on the site. This is a very accessible location. Less accessible infestations would not be able to receive the same level of retreatment and scaling up this level of effort to all infestations of root sprouting species across the Forest would be prohibitively expensive. • A small patch of yellow starthistle (approximate 1/3 acre) has been manually treated at Robert’s Ranch on the Descanso Ranger District. Crews have handpulled yellow starthistle plants for several years. The patch has been reduced in size and density, but treatment efforts have not happened in all years due to lack of available crews and difficulty scheduling at the proper time to avoid flowering and seed set. • A larger patch of yellow starthistle has been greatly reduced using volunteer crews manually pulling plants on the Trabuco Ranger District. Each year this effort involves volunteer crews working for up to six days to clear the approximately 2 acre infestation. Scaling this level of effort to all infestations of targeted annual plant species across the Forest would be prohibitively time consuming and difficult to organize.

This analysis includes manual treatments but also includes the use of specific herbicides. Adding herbicides greatly increases the ability to effectively treat many invasive weed infestations on the Forest as herbicides are often the most effective and inexpensive control option. For root sprouting woody species, the use of herbicides greatly increase the efficacy of initial treatments with their ability to kill root masses. Manual grubbing of root masses (see example above) is very time and labor intensive, and still has a lower success rate than herbicides due to the inability to remove all underground plant material. For annual species, herbicides allow for much faster treatment of an area and increase the window of time when successful treatment can occur. Manual treatments of species like yellow starthistle need to occur immediately before flowering, otherwise roots that remain in the soil after treatment have enough time to resprout and flower (UC-IPM 2007).

There is also a need to efficiently plan for out-year weed control projects. This will allow the Cleveland National Forest to be a more effective partner with neighboring jurisdictions in weed management. There has recently been an increasing interest from other agencies and groups to conduct weed control on Forest Service lands for mitigation purposes or as part of a cross- boundary weed control effort. Forestwide planning for a large number of invasive weed infestations will allow the Cleveland National Forest to respond and take advantage of these opportunities when they present themselves.

If the invasive weeds are left unchecked, the ecosystems in infested areas could dramatically change. Invasive plants create a host of adverse environmental effects, including displacement of native plants and reduction in habitat and forage for wildlife (including federally listed threatened and endangered, and Forest Service sensitive species); reduction in water quantity; potential reduction in soil productivity; and potential increase in the intensity and frequency of

Cleveland National Forest Invasive Weed Management EA 4 wildfires (Duncan 2005, Vila 2011). After wildfires, nonnative plant species typically re- establish more rapidly than native plants, suppressing the recovery of the native vegetation and allowing the invasive plants to expand their range. In addition, when wildfires occur too frequently some native vegetation loses the ability to recover, effectively converting high diversity native plant communities into low diversity non-native plant communities (Keeley 2012).

On the Cleveland National Forest, the upper San Diego River gorge provides dramatic examples of the interaction of wildfires and invasive weeds. The 2007 Witch Fire burned through much of this area, however in the riparian zone along the San Diego River it burned very spotty. Small portions of the riparian zone were completely burned, while other areas were unburned or lightly touched. Tamarisk cover in unburned areas remains sparse. However, in small patches were the native riparian canopy was removed, tamarisk cover has greatly increased. In upland portions of the gorge, that have seen repeated fires, including in 2003 and 2007, coastal sage scrub communities have been almost completely type converted to non-native annual grassland.

Riparian and aquatic ecosystems are a vital part of watershed functioning and provide essential habitat for many species-at-risk. Invasive, nonnative plant species, especially tamarisk and arundo on the Cleveland National Forest, threaten riparian and aquatic habitats. Nonnative plants typically provide poor habitat and food sources for native animal species and may reduce water quantity due to very high transpiration rates. The Forest Plan (USDA 2005) has goals for maintaining and improving riparian conditions (Goal 5.2). The desired condition is for RCAs to contain primarily ”… native species, with minimal or no presence of invasive nonnative plants.”

1.4 Proposed Action

The proposed action is to conduct invasive species control and/or eradication efforts on Cleveland National Forest lands for certain invasive weed species and specific infestations. The proposed action also includes rapid response for certain species not currently known to occur on the Cleveland National Forest and an adaptive management framework for treating newly discovered infestations of target species or newly discovered species. The project would use a mixture of mechanical and chemical treatments, and would occur as funding allows. Priority species with the greatest potential to expand and greatest ecological impact are tamarisk, giant reed (Arundo donax), and yellow starthistle. This project proposes the potential use of five specific herbicides. No aerial application of herbicides would occur. Treating the infestations as proposed would be an ongoing project. Work is likely to occur for ten to twenty years. The proposed action is described in detail in Chapter 2 of this EA.

1.5 Decision Framework

Based on the analysis contained in this environmental assessment and in the project record, the Responsible Official (Forest Supervisor) will select either the proposed action, the no action alternative, or an alternative to the proposed action for implementation. The Responsible

Cleveland National Forest Invasive Weed Management EA 5 Official may choose aspects of different alternatives provided that the effects of the modified alternative are adequately analyzed and disclosed in this EA. The Responsible Official will also determine whether the decision that is selected would have significant impacts. If a determination is made that no impact would be significant, then a “Finding of No Significant Impact” (FONSI) would be prepared. Significant impacts would require the preparation of an Environmental Impact Statement [40 CFR 1501.4 (c) and (e)]. The Forest Supervisor’s decision will be documented in a separate Decision Notice (FSH, 1909.15 - 40).

1.6 Public Involvement

The proposal is listed in the Schedule of Proposed Actions (SOPA). A scoping document and maps summarizing the proposed action was added to the Cleveland National Forest website in early September 2013. Over 700 postcards soliciting comments to the scoping document were mailed to the Cleveland National Forest mailing list, tribal governments, and also parties that have expressed interest in similar projects in the past. Three written comments were received during the scoping period.

The Draft EA was made available for a 30-day comment period through publication of a legal notice in the San Diego Union-Tribune on May 19, 2014, along with mailings to parties that have expressed interest in similar projects in the past. Two written comments were received during the comment period.

In response to comments, certain design criteria were added or clarified. A full response to the comments received from scoping and comment periods is found in Appendix B.

This project is subject to comment and objection procedures pursuant to 36 CFR 218, Subparts A and B. Only those who submitted timely, project-specific written comments during a public comment period are eligible to file an objection.

1.7 Issues

Based on internal and external scoping, the interdisciplinary team (ID team) developed a list of potentially significant issues. The ID team decided the following issues warranted full analysis with this environmental assessment to determine their significance.

• Impacts to human health and safety: specifically potential impacts from exposure to herbicide formulations, both for the general public and for workers on-site.

• Impacts to water quality: both downstream and immediately on site. Public scoping raised the concern about potential negative health effects of herbicide use to humans, pets and wildlife. Impacts to water quality from manual removal of weeds and impacts to water quality from the continued expansion of invasive weed species are also a concern.

• Impacts to vegetation: including riparian vegetation, R5 Regional Forester

Cleveland National Forest Invasive Weed Management EA 6 Sensitive plant species, Management Indicator Species (MIS) and federally listed endangered or threatened plant species from the action alternatives and from the continued expansion of invasive weeds.

• Impacts to cultural resources: including pre-historic and historic sites as well as culturally valuable plant species (gathered basketry materials).

• Impacts to wildlife: including federally listed threatened and endangered species, Forest Service management indicator species (MIS), and animal species on the R5 Regional Forester Sensitive animal species list from the action alternatives and from the continued expansion of invasive weeds.

Cleveland National Forest Invasive Weed Management EA 7

CHAPTER 2 Alternatives

2.1 Introduction

This chapter describes and compares the alternatives considered under this environmental analysis. This chapter presents the alternatives in comparative form, defining the differences between each alternative and providing a basis for choice by the decision maker and the public. Some information used to compare the alternatives is based on the design of the alternative and some information is based upon the environmental and social effects of implementing each alternative.

2.2 Alternatives considered in detail

Three alternatives were considered in detail for this project. The alternatives are described below.

For all alternatives, the project area includes the entire CNF (Trabuco, Palomar and Descanso Ranger Districts). The total land area of the Federal lands within the project boundary is 423,472 acres.

2.2.1 Alternative 1 – Proposed Action – Integrated Weed Management, Including Herbicides Alternative 1 is to conduct invasive weed control and eradication projects using a variety of methods, including herbicides. This alternative is described in full detail below in section 2.3.

2.2.2 Alternative 2 - Continued Manual and Mechanical Weed Control Efforts with No Herbicides Alternative 2 would continue current weed management options on the Cleveland National Forest to treat weeds with manual or mechanical removal methods without herbicide use. This alternative is already in place across much of the Cleveland National Forest where the use of herbicides has not already been analyzed. This alternative is being analyzed to determine the relative cost and benefit of manual treatment alone versus including herbicides as a management tool. This alternative is described in full detail below in section 2.4.

2.2.3 Alternative 3 - No Action – Conduct no weed control efforts on these infestations Under Alternative 3, no treatment of the specific weeds and infestations targeted in the action alternatives (Alternatives 1 and 2) would occur. This alternative is being analyzed to help illustrate the relative costs and benefits of the action alternatives by informing the public and the decision maker of the impacts of leaving these infestations untreated.

Cleveland National Forest Invasive Weed Management EA 8 2.3 Alternative 1- Proposed Action in Detail– Integrated Weed Management

The proposed action is to conduct invasive weed control or eradication efforts on CNF lands for infestations and species listed in Table 1 (p.15). Maps showing the project area and the locations of infestations described in Table 1 are contained in Appendix A. The proposed action also includes rapid response for certain species not currently known to occur on the CNF and an adaptive management framework for treating newly discovered infestations of target species and newly discovered species. The project would use a mixture of mechanical and chemical treatments determined by cost-effectiveness and resource considerations, and would occur as funding allows. Priority species with the greatest potential to expand and greatest ecological impact are tamarisk, giant reed (Arundo donax), and yellow starthistle. This project proposes the potential use of five specific herbicides. No aerial application of herbicides would occur.

For areas on the Trabuco Ranger District (riparian areas in west-flowing drainages) where previous invasive weed management planning has been completed, this analysis adds the option to use three additional herbicides (imazapyr, aminopyralid, and fluazifop-p-butyl) beyond the two already considered (glyphosate and triclopyr) and includes planning for upland infestations. For the remainder of the Forest, all five herbicides would become options.

The selection of control methods depends on the biology of the plant species and the level of infestation. The most appropriate control method is determined by considering whether a plant species can reproduce from root sprouts, cuttings or fragments and by the ease of removing the root system. The size and location of an infestation also plays a role in determining the most appropriate control method. Table 1 details a preferred and secondary removal method for each of the target species expected to be found in the project area. The table also details the decision point for each species for moving from the preferred to the secondary method of treatment.

An attempt will be made to limit herbicide control methods to no more than three seasons on any given infestation. The second and third seasons will involve targeted foliar applications on small resprouts. In general, after three years it is expected that new occurrences of target species in treated areas will be new sprouts that can be pulled manually. However, some large vigorous individuals of species with large suckering root masses may require additional follow up herbicide treatment after three years. Giant reed (Arundo donax) in particular may also require additional years of treatment as it does not respond well to manual removal.

Monitoring is also a key component to the proposed action. Monitoring is intended to provide baseline information, determine the effectiveness of treatment, quickly treat new populations, possibly lead to adaptive management based on unanticipated effects, and evaluate the restoration of treated sites.

Active restoration to achieve revegetation with native plants may be needed to ensure treated areas do not become re-established with invasive plant species. All surveys and monitoring would be documented in the project files.

Cleveland National Forest Invasive Weed Management EA 9 Herbicides being considered for use:

Glyphosate: Glyphosate is a broad spectrum herbicide and has proven successful in killing giant reed (Arundo donax) in Southern California (Bell 2011). Aquatically approved formulations of glyphosate would be used (for example Rodeo™, Aquamaster™). These formulations require the use of a surfactant. Average glyphosate application rate for these type of applications is approximately 2 lbs. a.i/acre (SERA 2011a). On the Cleveland National Forest, rates applied to treat Arundo donax on the Trabuco Ranger District have been between .5 and 1 lbs a.i./ acre.

Triclopyr: Triclopyr is a dicot (broadleaf) specific herbicide that is usually used to treat woody vegetation. For cut stump and basal bark applications the ester form of triclopyr is used, which is the form found in the trade formulations such as Garlon 4 or Pathfinder II. For foliar applications, the amine salt form of triclopyr, which is found in the trade formulation Garlon 3A, will be used. The average triclopyr application rate is 1 lb a.i./acre for Forest Service activities nationwide (SERA 2011c). On the Cleveland National Forest, at Cottonwood Creek, application rates for initial treatments of the largest and most dense tamarisk infestation on the Forest was 2 lbs. active ingredient/acre. Retreatment of resprouts at the same site the following year had application rates of 0.5 lbs a.i./acre of triclopyr. No infestations planned for treatment in this document are as large or dense as this tamarisk infestation, therefore application rates are not expected to exceed these values.

Imazapyr: Imazapyr is a non-selective broad spectrum herbicide used to treat a wide variety of species, especially in aquatic settings. Tradenames include Habitat, Stalker or Chopper. Application rates in Forest Service uses nationwide average 0.3 lbs. active ingredient/acre and can approach 1 lb. active ingredient/acre in certain situations. It is generally applied in targeted foliar applications, but can be used in cut surface application, and is often mixed with other herbicides (SERA 2011b).

Aminopyralid: Aminopyralid is a selective herbicide that treats broadleaf weeds and is especially effective against plants in the family Asteraceae, including thistles. It is found in the trade formulations Milestone and Milestone VM. It is usually applied over infested areas in a broadcast application where it will selectively kill species like yellow starthistle, while leaving most grasses unharmed (it has been shown to affect some non-native annual species). Application rates are generally 0.03 to 0.11 lbs active ingredient per acre (SERA 2007).

Fluazifop-p-butyl: Fluazifop-p-butyl is a selective, monocot specific herbicide used to target grass weed species. It is found in the trade formulations Fusilade II and Fusilade Fusion. It is generally applied as a broadcast application to remove grass weeds in agricultural settings but is increasingly being used to control non-native annual grasses in habitat restoration settings. Application rates for weed control in natural settings is between .05 and .3 lbs active ingredient/acre (EFSA 2010, Tu 2001).

Fluazifop-P-butyl will not be used on this project until the Forest Service Risk Assessment for this herbicide is completed and the worksheet calculations confirm that the potential exposures are below the level of concern as predicted by the sources of information used in this

Cleveland National Forest Invasive Weed Management EA 10 Environmental Assessment. The new worksheet and Risk Assessment will be made part of the project record.

*a.e = acid equivalent – this term applies to herbicides that are generally stored as salts in dry form and dissociate into an active form in solution. This is the most precise way of describing the amount of active herbicide being applied.

Surfactants and Dyes:

Most formulations of the herbicides being considered require the use of a non-ionic surfactant to be mixed with the herbicide before use. This project will use modified seed oil (MSO) type surfactants. Trade formulations of MSO surfactants include Hasten, Competitor, JLB Oil Plus, and Cide-Kick. In addition, the proprietary surfactant in Pathfinder II, a ready-to-use triclopyr- based product, is a modified seed oil. These types of surfactants are being used due to their favorable environmental profile. No petroleum or petrochemical-based surfactants would be used. No POEA surfactants (the surfactant found in the commercial glyphosate formula RoundUp) would be used (Bakke 2007).

A dye will be added to the mixture to help ensure adequate herbicide coverage and to avoid double-spraying. Dyes also make accidental spills easier to detect and track (Tu 2001).

Herbicide Mixtures:

This project may use a mixture of glyphosate and imazapyr (as shown in Table 1). Mixtures of glyphosate and imazapyr have been shown to be more effective at controlling weed species like giant reed (Arundo donax) than either herbicide used alone and with less total herbicide applied (Bell 2011). This mixture will be applied at rates of .25lbs a.i/acre imazpyr with 1.0 lbs ai/acre of glyphosate.

Treatment Prescriptions

Prescriptions for treatment would follow integrated pest management (IPM) for each treatment site. No single management technique is perfect for all invasive plant treatment situations. Multiple management actions are required for effective treatment. Integrated weed management includes an approach for selecting methods for eradicating, containing, controlling, and/or suppressing invasive plants in coordination with other resource management activities to achieve optimum management goals and objectives. This approach uses a combination of treatment methods, that when taken together, would eradicate, contain, control, or suppress a particular invasive plant species or infestation efficiently and effectively, with minimum adverse impacts to non-target organisms. This approach contrasts with the traditional approach of using a single treatment type, such as applying herbicides, to treat all invasive plant problems. Herbicides are one useful technique, but they are not the only method to control invasive plants and may not always be the most effective. In addition, there are multiple herbicides that can be effective for treating a given invasive plant species. Integrated weed management is species-specific, tailored to exploit the weaknesses of a particular invasive plant species, site-specific, and designed to be practical with minimal risk to the native organisms and their habitats.

Cleveland National Forest Invasive Weed Management EA 11

Treatment Method Descriptions

The treatment methods expected for each target species are shown in Table 1.

Herbicide Treatments:

Cut stump treatments involve cutting down the plant and immediately spraying, painting or dripping the stump with an herbicide. This method is used for the control of large woody plants. This method is likely to be used for the initial treatment of species like tamarisk, edible fig, tree of heaven and other root-sprouting tree species in Table 1. Herbicide is applied via backpack sprayer at close range to a stump, immediately after cutting using special nozzles that minimize overspray. Herbicide may also be “daubed” directly on a cut surface using a dauber wand or dripped using squeeze bottles. The technique is most effect in late summer and early fall when species are translocating nutrients to the roots prior to the dormant season. These techniques are effective while limiting the total amount of herbicide to be applied and lessening the possibility of overspray and herbicide drift (Tamarisk Coalition 2005, Carpenter 1998). Follow up foliar applications to resprouts will be necessary on a proportion of the plants treated.

Basal bark treatments involve spraying around the lower portion of the trunk of smaller trees and shrubs. It can be used in situations where levels of infestation are fairly low, and standing dead vegetation is acceptable. It is likely to be used for species like Spanish Broom where only isolated individuals are present.

Hack and Squirt or Injection treatments involve delivering herbicide directly to living tissue in tree species either by cutting into tree trunk and spraying herbicide on exposed cambium, or drilling and injecting herbicides with a syringe or needle. Like basal bark treatments, this technique can be used in situations where levels of infestation are fairly low, and standing dead vegetation is acceptable.

Foliar applications involve spraying green foliage on target species with directed spray from backpack type sprayers or boom sprayers. This method will be used on resprouts and smaller, herbaceous target species.

Broadcast applications may be used when applying selective herbicides like aminopyralid and fluazifop where target species are growing amongst desirable species, such as yellow starthistle growing throughout a meadow area or non-native annual grasses growing throughout a sensitive or endangered plant habitat. This application involves using boom or other controlled sprayers to deliver an even spray over the infested area. No aerial herbicide applications would be conducted.

Manual Treatments:

Hand pulling involves crews pulling target species out of the ground by hand. Annuals and tap- rooted plants are particularly susceptible to control by hand pulling. It is not as effective against many perennial invasive plants with deep underground stems and roots that are often left behind

Cleveland National Forest Invasive Weed Management EA 12 to resprout. For example, small Yellow Starthistle populations can be hand pulled in early summer before the plant has flowered and set seed.

The advantages of pulling include its initial small ecological impact, minimal damage to neighboring plants, and little (or no) cost for equipment or supplies. Normally effective with small populations and/or where a large pool of volunteer labor is available. The key to effective hand pulling is to remove as much of the root as possible while minimizing soil disturbance. For many species, any root fragments left behind have the potential to re-sprout, and pulling is not effective on plants with deep and/or easily broken roots. Disadvantages are that this method is labor and time intensive. Often times there are low mortality rates which require repeated re- treatments to be effective, which could increase the project cost and frequency of disturbance to the treatment area.

Weed Wrenching or Grubbing is method to try to manually remove root masses of sprouting woody species from the ground by using a weed wrench to add leverage to pull up roots, or digging with hand tools.

Mowing, chopping: Certain annual species may be mowed or weed whipped at appropriate times to prevent seed set. Treating areas in this way consistently every year can eventually exhaust the seed bank of undesirable annuals in specific areas.

Cutting: Species that do not sprout from roots (e.g. the palms) will simply be cut down using a chainsaw or hand saws. Repeated cutting of species that do resprout can eventually kill root systems by preventing the plant from recovering energy reserves. This could be used for individual plants in areas that are frequently visited, such as campgrounds or other administrative areas.

Biomass Removal:

In most cases, biomass from individual plants will be left in place, but may be bucked and stacked depending on the location. The current infestations slated for treatment are dispersed enough that biomass can be left in place to naturally decompose. If treatments occur where dead biomass presents a fire hazard, the plant material may be chipped, mulched or hauled to landfills or burnpiles offsite. Giant reed (Arundo donax) has the potential to sprout from cuttings. Arundo biomass will be stacked in areas away from stream channels where it will be unable to sprout and grow. Once fully dry, this biomass may be mulched or chipped if it presents a fire hazard. In some cases, biomass may be cut and stacked on top of the stumps help prevent resprouts from surviving.

The edible fig infestation in Trabuco and Holy Jim Canyons will require management of biomass. Work on this infestation will need to occur in stages and biomass may be hauled away, or chipped on site.

Post Treatment Restoration:

Active revegetation of treatment sites with native vegetation is not expected to be necessary for the majority of targeted infestations. Removing invasive weed infestations before they form

Cleveland National Forest Invasive Weed Management EA 13 monotypic stands allows for native vegetation around the treatment areas to naturally fill in cleared areas. It is possible that some areas will be reseeded with appropriate native vegetation post-treatment if natural regeneration is expected to be insufficient. In riparian areas it is possible that active revegetation will involve planting cuttings of sprouting species such as willow species or cottonwoods.

Treatment Schedule:

The infestations in Table 1 will be treated as funding allows. Partnerships with adjacent landowners and jurisdictions will likely drive treatment priorities in any given year. Only small areas of the forest will be treated in any given year. In recent years, budgets have allowed up to approximately 100 acres of NFS lands to be treated annually on the CNF. The actual canopy cover of invasive weeds in those treated acres is substantially less than the total area. Treating the infestations listed in Table 1 is a long term proposal. Work is likely to occur for ten to twenty years.

Species Priority: Priority 1 and 2 species, and rapid response species, are listed in Table 1. Table 2 contains a list of priority 3 species. The priority rankings are defined as follows:

Priority 1 species are species that are known to occur in the project area and have a high likelihood of spreading. These species are deemed controllable in specified areas due to their limited distribution and are known to have significant ecological impact.

Priority 2 are known to occur in the project area but have a lesser likelihood of spreading or appear to have a lesser ecological impact. These species will likely only be treated when occurring in areas where control work is occurring on Priority 1 species.

Rapid Response Species (RR): These are species that are currently not known to occur in the project area but are known /to invade the type of habitats found on the Cleveland National Forest. These are species with a known high level of ecological impact. There detection will trigger a rapid response keeping within the design criteria described in the proposed action.

Priority 3 species are species that are widespread and difficult to control (generally annual species with long lived or widespread seed banks). Many of the most impactful and widespread non-native species found on the Cleveland National Forest are included in this Priority 3 list (Table 2). These species include the suite of non-native annual grasses (bromes, wild oats etc) and non-native annual forbs (black mustard, tocalote, Italian thistle). Large scale efforts to control these species are not part of this proposed action due to the near impossibility of having a meaningful, sustainable impact on their occurrence and distribution on the Forest. These species will only be controlled when there is a specific concern with their presence due to other resource concerns or to meet restoration goals for establishment of native species. For example, a Priority 3 species would be controlled when it is impacting a localized population of a rare or endangered plant species. Priority 3 species may also be controlled in conjunction with active chaparral and coastal sage scrub restoration efforts to help with seeding or container plant establishment.

Cleveland National Forest Invasive Weed Management EA 14 Ongoing work occurs across the Cleveland National Forest to limit the impact of these species on native habitats through working to avoid type conversion of shrubland vegetation types, active restoration of burned areas, strategic placement of fuels treatments, recreation and OHV management, and grazing management.

Cleveland National Forest Invasive Weed Management EA 15 Table 1: The best control methods for each species depends on the biology of the plant species and the level of infestation. The preferred control method will be the first method to be tried for each species. If conditions (often determined by the size of plant or the infestation) make the preferred method impractical then the secondary method will be used. Methods are mostly determined by reproduction considerations of the plant and by the ease of removing the root system.

Control methods and estimated effort for each species: Reproduction Species Prior Size and locations of Preferred Control Method Secondary Control Method Decision Considerations ity infestations Point to (1,2, move to RR)* Secondary Control Rhizamatous, Giant Reed 1 Small infestation (@2 acres) Foliar application of glyphosate or None, Manual removal is difficult N/A reproduces from (Arundo in San Diego River, below imazapyr or mixture on small plants, due to depth of roots and rapid fragments and donax), El Capitan Dam. Small new sprouts. For larger plants and resprouting. root sprouting clumps in spring seeps clumps (overhead height) cut and pile above San Diego River on biomass in area where it cannot north face of El Cajon resprout. Allow plant root mass to Mountain. Continued effort resprout and conduct foliar application on resprouts in San Juan, of glyphosate, imazapyr, or mixture to Hot Springs and Trabuco kill root mass. Canyons. Detection elsewhere would trigger For individual plants, stem injection or immediate response. Highly cut stump treatments may be applied. impactful and quick spreading weed. Most Cut and pile dead stems on site. May likely in lower elevation, be chipped after fully dry. Follow up low gradient streams and treatment for sprouts in following year. spring areas.

Jubata grass 1 Small infestations (several Foliar application of glyphosate or Individual plants could be grubbed N/A (Cortaderia plants) in San Mateo mixture of glyphosate/imazapyr out manually. jubata), Canyon on Trabuco Ranger (similar to Arundo) Pampas District. Likely small grass infestations in other canyons Seed heads will be cut and bagged (Cortaderia on the District. before piling stems. selloana)

Cleveland National Forest Invasive Weed Management EA 16 Reproduction Species Prior Size and locations of Preferred Control Method Secondary Control Method Decision Considerations ity infestations Point to (1,2, move to RR)* Secondary Control Edible fig 1 Extensive population found Weed wrench small individuals (up to Cut stump with triclopyr or When fig has (Ficus in Trabuco and Holy Jim 2.5 inch diameter) if not part of large imazapyr; foliar spray resprouts developed Root sprouting - carica) Canyon. Not known clumps, leave biomass on site with imazapyr following year. into a thicket perennial elsewhere. Detection Biomass may be chipped, burned, of several the elsewhere would trigger or hauled away. individuals immediate response. Highly where manual impactful and quick root removal spreading weed. Most is unlikely, or likely in lower elevation, for low gradient streams and individuals spring areas. too large to wrench. Tamarisk 1 See information below and Weed wrench or hand pull small Cut stump with triclopyr or Herbicide spp. maps for specific individuals (new sprouts) < 1 inch, imazapyr or imazapyr/glyphosate used for infestations. Isolated leave biomass on site mixture, foliar spray resprouts with larger and individuals may be treated triclopyr or imazapyr following established outside if these areas if year. individuals found. where root removal is impossible with wrench. Tree 2 Numerous small infestations Weed wrench individuals in softer, Foliar or cut stump application of Infestations Tobacco and isolated patches, mostly sandy soils where entire root mass can glyphosate or cut/stump or individuals (Nicotiana adjacent to roads and be removed, leave biomass on site application of triclopyr. where root glauca), disturbed areas. Moderate mass cannot Castor Bean infestation in Santa Ysabel be removed (Ricinus Creek between Lake manually. communis) Sutherland and Pamo Valley.

Cleveland National Forest Invasive Weed Management EA 17 Reproduction Species Prior Size and locations of Preferred Control Method Secondary Control Method Decision Considerations ity infestations Point to (1,2, move to RR)* Secondary Control Brazilian 2 Isolated individuals Weed wrench small individuals (up to Cut stump with triclopyr or Herbicide and 2.5 inch diameter), leave biomass on imazapyr, Follow up foliar used for Peruvian site treatment of resprouts using individuals Pepper Tree glyphosate, imazapyr or too large to (Schinus imazapyr/glyphosate mixture in remove with spp.), second year. wrench. Russian Likely most Olive individuals (Elaeagnus will be too angustifolia) large to ,Acacia spp. wrench Artichoke RR Not known to occur in Small infestations have been Larger infestations (greater than 20 Large thistle project area. Infestations successfully treated with manual plants) will be treated by cutting infestations (Cynara occur adjacent to NFS lands grubbing and annual monitoring to plant to base and spraying stump (over 20 cardunculus near the town of Ramona. exhaust seed bed. Grubbing must with Glyphosate, or with foliar individuals) ) remove the root crown and top portion application of aminopyralid. that would be of the tap root. too difficult or result in too much ground disturbance to manually control.

Cleveland National Forest Invasive Weed Management EA 18 Reproduction Species Prior Size and locations of Preferred Control Method Secondary Control Method Decision Considerations ity infestations Point to (1,2, move to RR)* Secondary Control Fennel 2 Isolated small patches – Hand dig, or weed wrench individual Larger infestations (greater than 20 Large (Foeniculum Estimate 20 small plants. Bag and remove. Patrol for plants) will be treated with foliar infestations vulgare) occurrences across the CNF. resprouts following year. application of triclopyr, preferably (over 20 in early spring. individuals) that would be too difficult or result in too much ground disturbance to manually control. Tree of 1 Isolated individuals with Weed wrench small isolated trees Cut stump larger trees with If trees are Heaven patches of suckers, mostly (individuals that are not likely to be triclopyr or imazapyr. Manually larger than (Ailanthus near old homesites or along sucker sprouts off larger root mass). cut adjacent sprouts. Follow up 2.5 inch altissima) roads. Estimate 5-10 foliar spray of sprouts and suckers diameter or if occurences, mostly on Mt. following year. they are a Palomar, near Lake part of thicket Sutherland, High Point of stems Truck Trail, and Burney likely Ranch Area. connected to single root system.

Cleveland National Forest Invasive Weed Management EA 19 Reproduction Species Prior Size and locations of Preferred Control Method Secondary Control Method Decision Considerations ity infestations Point to (1,2, move to RR)* Secondary Control Spanish 1 Isolated individuals, known Weed wrench individuals up to 1 Cut stump, or basal bark Herbicide broom populations inches in diameter before seed heads application to larger plants with used on large (Spartium -20-30 individuals at “old form. Leave biomass on site. Follow triclopyr or imazapyr. Follow up individuals junceum) dam keepers” house near up to removed sprouts and seedlings. foliar spray of sprouts and suckers that can not Lake Sutherland dam. following year. be removed -100+ individuals along Los with wrench. Terrinitos Road and access road to well off Los Terrinitos Road. Infestation along Ortega Highway and also short distance near Ortega Highway on North Main Divide Road. Black 2 Isolated individuals – found Weed wrench individuals up to 2.5 Cut stump with triclopyr or Herbicide Locust near old homesites in inches in diameter before seed heads imazapyr, Follow up foliar used on large (Robinia Robert’s Ranch area and form. Leave biomass on site. Follow treatment of resprouts using individuals psuedoacaci King Creek. Several up to removed sprouts and seedlings. glyphosate, imazapyr or that can not a) individuals in San Diego imazapyr/glyphosate mixture in be removed River below Cedar Creek second year. with wrench. Falls. Several individuals in Observatory Campground and along East Grade Road on Palomar Mountain.

Cleveland National Forest Invasive Weed Management EA 20 Reproduction Species Prior Size and locations of Preferred Control Method Secondary Control Method Decision Considerations ity infestations Point to (1,2, move to RR)* Secondary Control Rock rose 2 About 100 plants behind Hand pull small isolated patches, Leave Foliar or cut/stump application of Infestations (Cistus house on east side town of biomass on site. Follow up to removed glyphosate or cut/stump or individuals creticus) Pine Valley along Old 80; sprouts and seedlings. application of triclopyr. where root several hundred plants at mass cannot Hwy 79 park and ride. be removed manually.

Perennial RR Not found in project area, Hand pull seedlings if detected in time. Foliar application at flower bud Mature plants pepperweed infestations below the forest stage of imazapyr or glyphosate. where roots (Lepidium known in the San Luis Rey Larger infestations may be mowed and soil latifolium) system. with thatch removal and herbicide fragments can applied to resprouts. Thatch not be removal improves contact with manually herbicides. removed.

Non-root Invasive 2 Isolated individuals – Cut down, bag and remove seed stalks None N/A sprouting species Palms - approximately 20 to 30 as much as possible. Mexican stems across the CNF. Fan Palm and Canary Island Date Palm (Washington ia robusta, Phoenix canariensis)

Cleveland National Forest Invasive Weed Management EA 21 Reproduction Species Prior Size and locations of Preferred Control Method Secondary Control Method Decision Considerations ity infestations Point to (1,2, move to RR)* Secondary Control Annual or Yellow 1 Occurs mainly on the Hand pull or cut plants to ground level Aminopyralid application over Infestations Biennial Species Starthistle(C Trabuco Ranger District. at initial flowering stage. Repeat infested area when plants are in or patches entaurea See infestation list below. annually to exhaust seed bank. seedling to midrosette stage. over one acre solstitialis) Small patch (1/4 acre) Patrol sight for manual removal, or in size. occurs on Roberts Ranch on spot foliar application of the Descanso RD. aminopyralid to control plants that survive intial treatment. Repeat annually until infestation is removed or small enough to switch to manual control. Medusahead RR Not found on the forest, Mow and remove thatch in small, Very dispersed infestations may be Manual grass – occurs in patches in the discrete infestations. Repeat annually spot treated with glyphosate or treatment is (Taeniather Mesa Grande area and Santa to prevent seed set for three years. fluazifop (in non-grazed areas) likely unless um caput- Ysabel Open Space annually until seed bank is infestation is medusae) preserves adjacent to the exhausted. Aminopyralid has also dispersed Forest. been shown to impact Medusahead over area and may be used. larger than an acre. Barbed RR Not found on the forest Mow and remove thatch in small, Very dispersed infestations may be Manual goatgrass currently, increasingly discrete infestations. Repeat annually spot treated with glyphosate or treatment is (Aegilops problematic in other parts of to prevent seed set for three years. fluazifop (in non-grazed areas) likely unless triuncialis California. annually until seed bank is infestation is L.) exhausted. dispersed over area larger than an acre.

Cleveland National Forest Invasive Weed Management EA 22 Reproduction Species Prior Size and locations of Preferred Control Method Secondary Control Method Decision Considerations ity infestations Point to (1,2, move to RR)* Secondary Control Crown 1 Found in small patches Hand pull individual plants in Foliar spray of glyophate or Larger Daisy below El Capitan Dam in infestation <20 plants. aminopyralid before flowering infestation of (Chrysanthe San Diego River Canyon. occurs. over 20 mum Becoming a major nuisance plants. coronarium) in coastal areas of Southern California. Occurring adjacent to forest in Ramona area. Unclear what the upper elevation limit for this species is. Fuller 2 Small patch in “Rodeo Hand pull individual plants in Foliar spray of glyophate or Larger Teasel Grounds” on Mt. Laguna infestation <20 plants. aminopyralid before flowering infestation of (Dipsacus occurs. over 20 sativus) plants. Sahara RR This plant is an aggressive Hand pull individual plants in Foliar spray of triclopyr or Larger Mustard invader of low lying desert infestation <20 plants. Revisit site glyphosate in early growth stage. infestation of (Brassica regions of the Southwest. It several time a year. over 20 tournefortii) is currently unknown plants. whether it will invade habitats on the CNF. Purple RR Known populations on Treatment same as Yellow Starthistle. starthistle Viejas Reservation adjacent (Centaurea to Forest. calcitrapa) Spotted RR Has occurred adjacent to Treatment same as Yellow Starthistle. Knapweed forest near Julian. (Centaurea maculosa)

Cleveland National Forest Invasive Weed Management EA 23 Reproduction Species Prior Size and locations of Preferred Control Method Secondary Control Method Decision Considerations ity infestations Point to (1,2, move to RR)* Secondary Control Stinkwort RR Increasing infestations in Handpull plants before flowering in the Foliar application of glyphosate on If infestations (Dittrichia coastal San Diego County. fall. young plants. grow to sizes graveolens) Unclear if it can invade at where elevations on the Forest. handpulling is not feasible. Manual control is preferred method for control of this species. Non-native 3 (see Found in almost all area on Small areas may be handpulled, or Overtop directed broadcast spray If area is annual below the CNF. Specific mowed or clipped before seed set if of Fluazifop, or directed spray of larger than grasses ) infestations proposed for manual disturbance is acceptable. glyphosate in spring before seed one acre, or treatment at this time are set. manual non-native grasses disturbance impacting San Diego would Thornmint populations near negatively Viejas Grade Road (patch < impact rare 1 acre) Treatment may native plant occur with active coastal populations sage scrub and chaparral being restoration efforts. restored.

Cleveland National Forest Invasive Weed Management EA 24 Reproduction Species Prior Size and locations of Preferred Control Method Secondary Control Method Decision Considerations ity infestations Point to (1,2, move to RR)* Secondary Control Non-native 3 (see Found in almost all area on Small areas may be handpulled, or Overtop directed broadcast spray If area is annual below the CNF. May be treated in mowed or clipped before seed set if of Aminopyralid (for thistles), or larger than broadleaf ) active coastal sage scrub or manual disturbance is acceptable. directed spray of glyphosate in several acres, species chaparral restoration efforts. spring before seed set. or manual disturbance would negatively impact rare native plant populations being restored.

Cleveland National Forest Invasive Weed Management EA 25

Tamarisk and Yellow Starthistle infestation locations (additional information for Table 1):

Tamarisk: Sparse infestations are defined as under 10 plants per linear mile of riparian corridor. Light infestations are defined as consisting of isolated individuals consisting of under 50 plants per linear mile of riparian corridor. Medium infestations are defined of consisting of 50-100 plants per linear mile of riparian corridor. Large infestations are defined as greater than 100 plants per linear mile of riparian corridor. • Hauser Canyon: Medium infestation on NFS lands, adjacent to larger infestations on City of San Diego lands adjacent to Barrett Lake. • La Posta Creek: Large infestation within mature willow riparian forest between “the Narrows” and site of previous Cottonwood Creek tamarisk removal project. Sparse infestation above the narrows to Thing Valley. • Pine Creek: Sparse infestation from Barrett Lake to Miners Road. • San Diego River Watershed: o Isolated individuals known to occur in Boulder Creek, Conejos Creek o Light to moderate infestation known to occur in Cedar Creek, Kelley Creek and Ritchie Creeks. o Light to moderate infestation in San Diego River below Cedar Creek. o Sparse infestation in San Diego River above Cedar Creek. o Isolated individuals below El Capitan Dam on NFS lands, adjacent to larger infestations on private and city lands. • Light infestation in Santa Ysabel Creek between Sutherland Reservoir and Pamo Valley (previously treated manually – needs follow up). • Light infestation in Santa Ysabel Creek between Pamo Valley and San Pasqual Valley. • Medium infestation in San Luis Rey River (main fork). • Medium infestation in Arroyo Seco Creek. • Isolated individuals known to occur in “Roberts Ranch” north of I-8 and east of Highway 79.

Isolated individuals may be treated if found in Kitchen Creek, Cottonwood Creek, Sweetwater River, Indian Creek.

Yellow Starthistle:

• Descanso Ranger District: Roberts Ranch – small, under 1 acre infestation – previously manually treated • Trabuco Ranger District: o Elsinore Peak – infestation covering several acres. Currently substantially reduced due to manual treatments by volunteers. o South Main Divide Road – isolated individuals along road. o Several acres of moderately dense infestation in meadow area approximate ¼ mile north of Elsinore Peak on South Main Divide Road. o Wildomar OHV area – scattered patches and individuals o Approximate ½ acre infestation in Ajachemen Meadow. o Bedford Peak

Cleveland National Forest Invasive Weed Management EA 26

Table 2: Priority 3 species include* Species Type Scientific Name Common Name Avena barbata Slender wild oats Avena fatua Wild oats Bromus hordeaceus Soft chess, Soft brome Bromus madritensis sspp rubens Red brome Bromus diandrus Ripgut brome Bromus tectorum Cheatgrass, Downy brome Brachypodium distachyon Purple false brome Non-native annual grasses Cynosurus echinatus Hedgehog dogtail Digitaria sanguinalis Hairy crabgrass Festuca myuros Rat’s tail fescue Festuca perennis Italian ryegrass Gastridium phleoides Nitgrass Hordeum murinum False barley Schismus barbatus Common Mediterranean grass Polypogon monspeliensis Rabbitsfoot grass Cynodon dactylon Bermuda grass Ehrharta calycina Perennial veldtgrass Elymus ponticus Tall wheat grass Phleum pratensis Timothy grass Non-native perennial grasses Poa bulbosa Bulbous bluegrass Poa pratensis Kentucky blue grass Sorghum halepense Johnsongrass Stipa miliacea Smilograss Amaranthus albus Prostrate pigweed Anthemis cotula Stinking chamomile Anthriscus caucalis Bur chevril Apium graveolens Wild celery Brassica nigra Black mustard Carduus pycnocephalus Italian thistle Centaurea melitensis Tocalote Chamaesyce maculate Spotted spurge Cirsium vulgare Bull thistle Cotula australis Australian brass buttons Erodium spp Filaree Euphorbia peplus Petty spurge Hirschfeldia incana Hoary mustard Hypochaeris glabra Smooth cat’s ear Lactuca serriola Prickly lettuce Non-native forbs Logfia gallica Narrowleaf cottonrose Malva spp Mallows Marrubium vulgare White horehound Matricaria discoidea Pineapple weed Medicago spp Bur clover Melilotus spp Sweet clover Oxalis spp Wood sorrels Plantago spp Plantain Pseudognaphalium luteoalbum Jersey cudweed Raphanus sativus Wild radish Rumex spp Dock Salsola australis Russian thistle Silybum marianum Milk thistle Sisymbrium spp Mustards Taraxacum spp. Dandelions Tribulus terrestris Puncture vine *This table is not a complete list of naturalized non-native species, but it does represent the bulk of the naturalized non-native species found on the Forest.

Adaptive Management Strategy and Rapid Response to New Species Invasive plant infestations constantly change and evolve, as do the infestations of individual invasive plant species and treatment methods, including herbicide use (i.e., concentrations of herbicide and application methods). New plant species may be detected that are not currently known to invade wildlands in Southern California. Early detection and rapid eradication of new invasive weed occurrences is the most efficient method for controlling their spread. The proposed action includes an

Cleveland National Forest Invasive Weed Management EA 27 adaptive management strategy that addresses these types of changes over the life of this project to allow for a rapid response for eradication, control and/or containment. Treatment of new species, and/or treatment of new areas within the project area will be part of the proposed action as long as the scope of the treatment and the effects of the treatment are within the range of those addressed in this analysis and all relevant design criteria can be followed. For example, new infestations of target species may be found beyond areas currently predicted and disclosed in Table 1. These individuals may be treated as long as impacts are within the range of those disclosed in this document. All treatments will adhere to applicable design criteria. Any proposal for treating a species not included in Table 1 would be reviewed by an appropriate interdisciplinary team; documented; and, treatment approved by the appropriate Responsible Official through a letter to the files. The documentation would be included in the project record available for public review. This strategy would not allow for the use of herbicides not addressed in this document; would not allow for aerial applications of herbicides; and, would not allow large heavy equipment into the treatment areas. The use of any new herbicides, aerial applications, or use of large heavy equipment would require new NEPA analysis, public involvement, documentation, and decision.

Design criteria applicable to manual and herbicide treatments:

• Workers would flag and follow consistent trails into and out of project areas, utilizing established trails where they exist.

• Areal extent of detrimental soil disturbance would not exceed 15 percent of the area dedicated to growing vegetation. Soil cover would be maintained at levels at least 90 percent of what existed before invasive weed removal. Soil cover would consist of rocks, litter, low-growing plants, and woody debris. • For small quantities (5 gallons or less), fueling of gas-powered machinery would not occur within 25 feet of any body of water or stream channel to maintain water quality. All other fueling must occur at a minimum of 150 feet from any body of water or stream channel unless prior-approved by a Forest Service hydrologist or biologist. (BMP 2.11; Road-10) • Hand crews will stay out of flowing or ponded water whenever possible. If hand removal requires entry into flowing or ponded water, keep the time in the water to a minimum. Wildlife Specific

• To avoid potential direct effects to arroyo toads, occupied and/or designated critical habitat would be avoided during the breeding season when toads are most likely to be encountered. Treatment activities would be conducted between September 01 and March 01.

• No treatment activities would be conducted in designated critical habitat and/or areas where least Bell’s vireos have been documented between March 01 and August 01. No treatment activities would be conducted in designated critical habitat and/or areas where Southwestern Willow Flycatcher have been documented between March 01 and Sept 01.

Botany Specific • In general, a buffer area of non-treatment of 25 ft. for TEPCS plant species will be delineated for all treatments. Exceptions may be made if the treatment is monitored by a Botanist or Botanist

Cleveland National Forest Invasive Weed Management EA 28 representative. Treatments near TEPCS plant species will not occur during the blooming period for that plant.

• As infestations of weeds are scheduled for treatment, pre-treatment site-specific surveys will be conducted to avoid impacts to Threatened, endangered, proposed, candidate and sensitive plant species (TEPCS species). TEPCS plant species populations will be flagged for avoidance. If TEPCS plant species are found, treatment monitoring will be conducted.

• There would be no removal of native riparian hardwood species.

Wilderness Specific

• Work crews will not work in Wilderness Areas during high use times (weekends and holidays).

• No powertools or other motorized equipment will be used in Wilderness Areas.

Heritage Specific

• The Forest would notify potentially affected Tribes annually to update them on the areas being proposed for invasive weed eradication each year. Any tribal concerns regarding the effects of previous treatments or proposed treatments would be considered and incorporated into the design of future treatment activities. This is to ensure invasive plant control activities do not impact traditional plant gathering activities.

• If any heritage resources or human remains are discovered prior to or during implementation of the project, all ground-disturbing project-related activities in the vicinity of the discovery would cease immediately, appropriate steps to secure the discovery would be taken, and the Heritage Resource Program Manager (HRPM) would be notified. Ground disturbing project related activities in the vicinity of the discovery could only be resumed upon approval by the HRPM.

Design criteria applicable only to herbicide applications:

• Herbicides would be applied using hand sprayers or backpack sprayers, potentially with daubing attachments, only or powered boom sprayers. No aerial application of herbicides would occur. All herbicide application would adhere to all applicable Federal laws and laws of the State of California and counties in which treatment occurs.

• Herbicide applications on woody perennial species would occur in the late summer/early fall when plants are translocating nutrients from the leaves to the root systems. This increases the likelihood of initial success and would result in reduced need for follow up treatment. This season also avoids critical breeding seasons for many wildlife species and flowering seasons for many native plant species. In addition, this time of year is also a time of reduced stream flows and limits the accidental introduction of herbicides to surface waters.

• Herbicide applications to annual species would occur during optimal timing for the species to prevent seed production.

• Where treatment areas occur adjacent to trails or other public use areas short term trail closures may occur.

Cleveland National Forest Invasive Weed Management EA 29 • Application of herbicides will follow all local, state, and federal laws and regulations as they apply to pesticides and all label language for the herbicide will be followed (BMP 5.8). • No foliar spray activities would be allowed if wind velocity is expected to exceed five miles per hour.

• No herbicide treatments would be allowed when rain is occurring or likely to take place within 48 hours.

• Herbicides would not be applied directly to surface waters. Treatments would be timed to minimize the potential for introduction of herbicide to surface waters. When a target species occurs adjacent to surface waters care will be taken to prevent herbicide drift to surface waters, including trimming and folding of plants away from waters.

• Work crews would be supervised to ensure that specific safety practices are followed. These practices include the use of appropriate protective clothing. Clean water and soap would be available for emergency washing.

• The Herbicide Transportation, Handling, and Emergency Spill Response Plan and spill kit will be on- site when herbicide treatment methods occur. The Plan will include reporting procedures, project safety planning, methods of clean-up of accidental spills, and information including a spill kit contents and location as noted in Forest Service Manual (FSM) 2150, Pesticide-Use Management and Coordination and Handbook (FSH) 2109.14, Pesticide-Use Management and Coordination Handbook. • No more than daily use quantities of herbicides will be transported to the project site. Herbicide containers must be secured and prevented from tipping during transport. Crews staging in remote locations in wilderness areas can bring sufficient quantities of herbicides to last for the planned duration of the field work. • Equipment used for transportation, storage, or application of herbicides will be maintained in a leak- proof condition. • To reduce the potential for spills, impervious material, such as a bucket, will be placed beneath mixing areas in such a manner as to contain any spills associated with mixing/refilling. • Immediate control, containment, and cleanup of fluids and herbicides due to spills or equipment failure (broken hose, punctured tank, etc.) will be implemented. All contaminated materials will be disposed of promptly and properly to prevent contamination of the site. All hazardous spills will be reported immediately to the Forest Hazardous Spill Coordinator. • Herbicide usage will be limited to the minimum amount required to be effective. • Mixing and loading of herbicide(s) will take place a minimum of 150 feet from any body of water or stream channel unless prior approval is obtained from a Forest Service hydrologist or biologist. • Herbicides will be colored with a biodegradable dye to facilitate visual control of application. • Herbicide spray equipment will not be washed or rinsed within 150 feet of any body of water or stream channel. All herbicide containers and rinse water will be disposed of in a manner that would not cause contamination of waters.

• Fluazifop-P-butyl will not be used on this project until the Forest Service Risk Assessment is completed and the worksheet calculations confirm that the potential exposures are below the level of concern as predicted by the sources of information used in this Environmental Assessment. The new worksheet and Risk Assessment will be made part of the project record.

Cleveland National Forest Invasive Weed Management EA 30 • When significant native perennial grass species are present, application of fluazifop will occur early in the spring to specifically target only annual grass species.

• Surveys will be conducted to insure that no listed, or rare asteraceae species are within treatment areas where aminopyralid is being used. Care will be taken to not directly apply aminopyralid to susceptible native species.

Wildlife Specific

• Application of herbicides with fluazifop-p-butyl would occur at least 100 feet from stream courses and waterbodies.

Botany Specific

• To avoid injury to native trees like Oaks, Sycamores and Cottonwoods, do not apply imazapyr within twice the drip line (tree canopy). • No herbicide treatments will be conducted within 25’ of Special Status plant species locations (R5 Sensitive, Federally Threatened and Endangered), except for Acanthomintha ilicifolia (San Diego Thorn-mint), where Fluazifop-b-butyl may be used to improve habitat conditions for the plant where it is being impacted by non-native annual grasses on Viejas Grade Road. • To avoid effects to adjacent non-target plants the area of treatment will be prepped by trimming back non-target plants or by pulling the weed stems away from other plants and down to the ground for foliar treatment.

Heritage Specific

• No plant species that are important to Native American plant-gathering activities are being targeted with herbicide application. Where target species are being treated in potential and known gathering areas, signs would be posted and individuals known to gather in the general area would be contacted.

2.4 Alternative 2 – Continued Manual and Mechanical Weed Control Efforts with No Herbicides

This alternative is to conduct invasive weed control or eradication efforts on CNF lands for infestations and species listed in Table 1 (p.15) using only manual or mechanical methods. Work could occur on all species in Table 1 that have manual control options. Each species in Table 1 with manual control options has an approximate “decision point” where manual control would be very time consuming and expensive. Infestations that are too large would likely not be tackled under this alternative. Certain species, like Arundo donax, which do not have demonstrated manual control options, would not be treated under this alternative.

Manual Methods that would be utilized are described under the Proposed Action (Section 2.3). All Design Criteria that are applicable manual treatments from the Proposed Action would be included in this alternative.

Because manual treatment is generally more time consuming and more labor intensive, it is expected that the number of acres treated annually would be approximately half of the Proposed Action. In addition, manual treatments generally require a greater effort for follow up treatments due to lower initial efficacy.

Cleveland National Forest Invasive Weed Management EA 31

2.5 – Comparison of Alternatives in terms of acres treated, efficacy, and invasive weed spread

Alternative 2 – Alternative 3 – No Alternative 1 – Evaluation Factor: Manual Removal Action – No weed Proposed Action Only treatments Number of acres treated Approximately 100-150 Approximately 50 - 75 N/A per year, including acres a year. acres a year. retreatments – assuming flat budgets. Efficacy of treatments. Herbicide treatments on Manual treatments on N/A the Cleveland National the Cleveland National Forest have generally Forest have generally resulted in 80-90% resulted variable initial mortality in initial mortality. It is expected treatments. there will be a higher percentage of resprouting plants and annual plants flowering and seeding in treated areas than under Alternative 1. Overall trend in invasive Overall reduction in Eradication of some Large increase in cover plant cover. cover of Priority 1 and 2 small infestations of and dominance of species, including their certain Priority 1 and 2 Priority 1 and 2 plant eradication from certain species in certain key species and successful stream courses if areas or stream courses.. establishment of several funding and However, unless RR species. Invasive partnerships continue or funding is greatly weed cover will likely expand. Limited to no expanded, this increase rapidly in successful introductions alternative will likely specific areas in of RR species. result in increases in response to fire and Priority 1 and 2 species other disturbances. across the Forest. Few successful introductions of RR species.

Cleveland National Forest Invasive Weed Management EA 32 CHAPTER 3 Environmental Consequences

3.1 Introduction

This section summarizes the physical, biological, social and economic environments of the affected project area and the potential changes to those environments due to implementation of the alternatives. It also presents the scientific and analytical basis for comparison of alternatives presented in the charts from Chapter 2.

3.1.1 Conformity with the Forest Plan

The proposed project is in compliance with the standards and guidelines of the Cleveland National Forest Land Management Plan (LMP),which states that there is a forest wide goal to “reverse the trend of increasing loss of natural resource values due to invasive species”(USDA 2005). The LMP implements the “National Forests of Southern California Weed Management Strategy” which encourages national forests to work cooperatively with other agencies and landowners to implement invasive species prevention and control programs. The strategy allows for the use of herbicides when the use is analyzed by appropriate NEPA documentation.

The Cleveland National Forest LMP planning process determined that San Mateo Creek, the San Luis Rey River, and Cottonwood Creek are eligible for Wild and Scenic River designations. This project will not have an impact on these waterways eligibility and should improve the areas unique natural resources.

Portions of the project are within the San Mateo Canyon, Aqua Tibia, Pine Creek and Hauser Canyon Wilderness areas. All three alternatives have the potential to impact the wilderness characteristics of these areas. These are discussed in the significance factors section (3.1.2) and also in the LMP Consistency Checklist – Appendix A. Herbicide applications and the use of certain equipment in wilderness area require the approval of the Regional Forester of Region 5 of the US Forest Service (see section 3.7 for discussion of this process).

Implementation of both Alternative 1 and Alternative 2 would be consistent with the Forest Plan and the Weed Management Strategy. Alternative 3 would not be consistent with the LMP because it does not reverse detrimental changes to riparian areas. A full consistency checklist of all applicable standards and guidelines from the LMP is contained in Appendix A.

3.1.2 Significance factors

The definition of “significance” in this document is taken from the Council on Environmental Quality (CEQ) (40 CFR 1508.27). Listed below are the ten intensity factors for determining significant effects under the CEQ regulations (40 CFR 1508.27). The context in which these intensity factors apply to the specific project is described with each factor. Factors which require further analysis are followed with information about where the analysis occurs in this document.

(1) Impacts both beneficial and adverse. A significant effect may exist even if the Federal agency believes that on balance the effect will be beneficial. This factor will be analyzed for all potential impacts. This factor most applies to the net benefit expected from removing invasive weed species from the project areas. This benefit cannot be used to “offset” a significant negative impact.

Cleveland National Forest Invasive Weed Management EA 33 (2) The degree to which the proposed action affects public health or safety. The use of herbicides is the factor of this proposed action most likely to cause concerns over impacts to public health and safety. Section 3.3 analyzes human health and safety.

(3) Unique characteristics of the geographic area such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas. The project area does not contain prime farmland, parklands, or designated wild and scenic rivers. San Mateo Creek, the San Luis Rey River, and Cottonwood Creek are listed in the Cleveland NF Land Management Plan as having the potential for wild and scenic river designations. Targeted infestations occur in the San Mateo Canyon, Aqua Tibia, Pine Creek and Hauser Canyon Wilderness areas. Infestations of Priority 1 or 2 species are not known to occur in Research Natural Areas (RNA’s) on the Cleveland National Forest. Impacts specific to wilderness and wild and scenic river resources are found in section 3.7 Impacts to historic and cultural resources are analyzed in Section 3.6. Impacts to wetland riparian habitats are discussed in section 3.4 and 3.5.

(4) The degree to which the effects on the quality of the human environment are likely to be highly controversial. Scoping efforts over previous similar projects have revealed controversy over whether herbicides are necessary to remove invasive weeds and whether removal of invasive weeds is necessary. These controversies are not about the effects of this proposed action. Scoping also revealed concerns about the environmental and human health effects of herbicide use. This analysis uses risk assessments developed for the Forest Service to analyze the effects of herbicide use in different use scenarios. This risk assessments compile all known scientific information about the proposed herbicides to model the effects using herbicides for this project (SERA 1997, SERA 2007, SERA 2011a,b,c). Analysis about the effects of herbicide use from this project can be found in Sections 3.3 -3.7.

(5) Degree to which the possible effects on the human environment are highly uncertain or involves unique or unknown risks. No alternative analyzed in this environmental assessment represents a new or untested approach to invasive weed management. There is abundant field experience described in the literature for all of the proposed methods for removing invasive species. Impacts from all alternatives are considered predictable.

(6) The degree to which the action may establish a precedent for future actions with significant effects or represents a decision in principle about future consideration. The proposed action would not establish a precedent for future actions, nor would it represent a decision in principle about future invasive weed treatments on the forest. Any future invasive weed treatment projects will be analyzed separately and on their own merits to determine a future course of action. This decision would apply only to actions described in this analysis.

(7) Whether this action is related to other actions with individually insignificant but cumulatively significant impacts While this environmental assessment analyzes the effects of invasive plant removal on Forest Service lands, the effects must be analyzed with other actions that may have impacts on similar resources. In this case, other actions to be considered are invasive weed removal projects on adjacent properties managed by different jurisdictions. The intent of this project is to work in coordination with weed removal efforts on adjacent properties. Other activities that have the potential to increase soil disturbance that could have a cumulative effect with this project are off-

Cleveland National Forest Invasive Weed Management EA 34 road vehicle activities and the use and maintenance of forest roads. These cumulative actions are analyzed in sections 3.3-3.7.

(8) The degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places, or may cause loss or destruction of significant scientific, cultural, or historical resources. There are archeological sites within the project area. Section 3.6 discusses impacts to these sites.

(9) The degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973 (Threatened, Endangered, Candidate (TEC Species)). This project occurs within potential habitats for several federally listed endangered species. Section 3.4 analyzes impacts to TEC species.

(10)Whether the action threatens a violation of Federal, State or local law or other requirements imposed for the protection of the environment. All applicable permits will be acquired before the start of the project and all appropriate regulatory agencies will be consulted. All applicable laws involving herbicide application will be followed. This document documents compliance with laws such as the Endangered Species Act, National Forest Management Act (NFMA), and the Clean Water Act.

3.1.3 Economic factors

This project (with action alternative) is not expected to have a significant negative effect on the local or regional economy. There will be some benefit through the hiring of labor and purchase of materials to the local economy. The removal of invasive weeds will improve water quality and stream flow into downstream reaches. This will have an economically beneficial effect.

While a full economic analysis is not warranted for this project, there are economic factors involved that differentiate the effects of the alternatives on the environment. Specifically, labor cost per hour and material costs between the two action alternatives are expected to be more or less equivalent. The cost of herbicide is generally negligible compared to labor costs. Therefore, it is expected that the proposed action (alternative one) will result in more areas treated due to quicker removal (cutting and spraying a stump is faster than digging out root masses so more plants could be treated per day) and a reduced need for follow up treatments (Section 2.5). Current funding has allowed the Cleveland National Forest to treat approximately 100 acres a year. These acres have mostly been treating infestations where herbicide use has been planned for and allowed. Much smaller acreages have been treated manually by Forest Service personnel and volunteers (15-20 acres per year). Also, due to the inconsistency of funding year to year and the possibility of diversion of funds for emergency use (wildfire), it is possible that treatments may occur but that follow up treatments might not occur or be delayed.

3.2 Herbicide Background

The bulk of the concern over invasive weed removal projects usually stems from concerns over the safety of using herbicides as part of the project. This section provides some background on the herbicides that are part of the proposed action and their fates in the environment. This information is referred to in subsequent sections when discussing effects of the proposed action.

Cleveland National Forest Invasive Weed Management EA 35 The environmental and human health consequences of using specific herbicides have been reported and disclosed during the chemical registration process. The Forest Service has supplemented this registration information with a series of risk assessments for each of the most commonly used herbicides by the Forest Service. These documents review available research and information on herbicides and then apply this information to conditions that will likely occur during Forest Service wildland herbicide applications. The risk assessments help rectify the often contradictory information about herbicides that can be found online and help make potential impacts of herbicide use in Forest Service projects more predictable. These risk assessment in concert with registration and label instructions will form the basis for the analysis of effects for all Forest Service activities that include the use of herbicides. This environmental assessment relies on five risk assessment documents; one for Glyphosate (SERA 2011a), one for Triclopyr (SERA 2011c), one for Imazapyr (SERA 2011b), one for Aminopyralid (SERA 2007), and one for surfactants commonly used with Glyphosate (SERA 1997). The Forest Service has not completed a risk assessment for fluazifop. Therefore this EA relies on a several other documents that assess the potential impacts of fluazifop, including a risk assessment conducted by the European Food Safety Authority, and registration and reevaluation documents from United States Environmental Protection Agency and Health Canada (EFSA 2010, Health Canada 2012, US-EPA 2005).

The Risk Assessments also contain worksheets for modeling exposure scenarios and thresholds of concern for each of these chemicals at different application rates and application methods. These worksheets are based on real world application scenarios and rates that are commonly used in Forest Service programs. The worksheets ultimately determine a “hazard quotient” (HQ) for various exposure routes. The HQ is basically the expected exposure divided by the exposure determined to cause detrimental effects. Therefore a HQ of one indicates an exposure scenario where the subject may receive a dose equal to the highest does determined to have no observable health effect (NOEL’s). HQ values exceeding 1 indicate that design criteria to mitigate the risk should be considered.

3.2.1 – Herbicides: The following sections summarize the general known environmental and human health concerns associated with each herbicide being proposed.

Glyphosate: Glyphosate is a broad spectrum herbicide that is the most widely used herbicide in the world. There are currently 35 commercial formulations, including Roundup and Rodeo. There is an extensive published literature on studies concerning the safety and relative toxicity of glyphosate.

The glyphosate risk assessment (SERA 2011a) and also a separate risk assessment for surfactants commonly used with glyphosate (SERA 1997) both examined the potential impacts from adjuvants used with glyphosate in field applications. These documents demonstrate that many surfactants commonly used are more toxic than glyphosate and carry unique ecological risks, especially to amphibians and aquatic organisms. There are extensive studies about the toxicity of glyphosate when used with POEA, the surfactant used in Roundup. Therefore surfactants will be limited to those described in the proposed action. This project, as stated in the proposed action, will use an aquatic approved formulation of glyphosate (such as Rodeo or Aquamaster) along with a methylated seed oil based surfactant. No formulations used will contain POEA, which is known to be toxic to amphibians and other aquatic organisms (SERA 1997).

Glyphosate is most often used with foliar applications where it is readily absorbed into plant tissue. It works by inhibiting a metabolic pathway (the shikimic acid pathway) that is unique to plants and is important for plant protein synthesis.

The main factor determining the fate of glyphosate in the environment is glyphosates strong affinity for binding to soil particles. Glyphosate binds strongly with soil particles and is generally not active nor mobile in the soil. Glyphosate is not readily metabolized by most plants, but it is metabolized and

Cleveland National Forest Invasive Weed Management EA 36 broken down by microbes. Glyphosate is eventually completely broken down to CO2 and water at in a matter of weeks to years depending on soil properties and the microbial environment. During this time it is essentially immobile and inert due to its strong soil binding properties. Glyphosate does not accumulate in the environment, nor does it bioaccumulate in organisms. Microbial degradation of glyphosate often produces aminomethyl phosphonic acid (AMPA) as an intermediate product. AMPA is also produced by degradation of many detergent products in the environment. AMPA is considered to be equal or less toxic than glyphosate and also binds readily to soil particles and is immobile in the soil. AMPA is eventually broken down to CO2 and phosphates (SERA 2011a).

Triclopyr: Triclopyr is a dicot (broadleaf) specific herbicide that works by mimicking the plant growth hormone auxin. It is generally used against woody vegetation, especially in cut stump or basal bark treatments. Application rates are expected to not exceed 1lb a.i/acre/year. There are two forms of triclopyr. Triclopyr BEE, which is often sold under the trade name Garlon 4, is commonly used for cut stump treatments. Triclopyr TEA, the amine salt form of triclopyr, which is found in the trade formulation Garlon 3A, is often used for foliar applications.

Triclopyr amine or ester quickly break down to triclopyr acid in the environment. Triclopyr acid degrades completely in the environment to carbon dioxide and water. The major intermediary metabolite of triclopyr is TCP. TCP is slightly more toxic to mammals and fish than triclopyr itself and its effects are considered in this environmental assessment and is modeled in exposure scenarios in the risk assessment for triclopyr. . Both triclopyr and TCP photo degrade rapidly and are not detectable on sprayed plant material or the soil surface within days of spraying. Triclopyr is rapidly broken down by sunlight in surface waters and has a half-life in these conditions of less than one day. TCP has a half-life ranging from approximately 4-8 days in these conditions. Triclopyr binds to clay and organic matter in the soil and is broken down by soil microbes. It has a half-life in soil of 46 days. The metabolite TCP is more mobile is soils and has a half-life of 90 days. Neither of these compounds shows indications of accumulating in the environment nor bioaccumulation (SERA 2011c).

Imazapyr: Imazapyr is a broad spectrum, non-selective pre and post emergent herbicide. It is an amino acid synthesis inhibitor. It is a slow acting, but highly effective herbicide. Application rates generally range from .03 – 1.5 lbs a.i/acre. It is applied to green vegetation (foliar application) and is often also used in tank mixes with glyphosate. Certain formulations can also be used for cut stump treatments. It is registered for use against aquatic weeds and is registered for application to surface waters, however no aquatic weeds are considered for treatment in this project.

Imazapyr has a very favorable toxicity profile, being considered to be practically non-toxic to humans, mammals, fish, birds, amphibians and invertebrates. The property of imazapyr of the most concern is its relative stability and mobility in the environment. Imazapyr remains active in the soil and can have impacts to non-target terrestrial plants. It breaks down slowly in soil due to microbial degradation with a half life of one to five months (Tu 2001). It can act as a pre-emergent and can prevent revegetation of treatment sites in short terms at higher application rates. It also does not bind to soil or organic matter so it is relatively mobile and has the potential to leach through soils into groundwater or surface waters. In surface waters, Imazapyr breaks down fairly rapidly through photohydrolysis with a half life of 1 to 2 days (US-EPA 2007).

Aminopyralid: Aminopyralid is a selective herbicide often used for treating non-native thistles and other broadleaf plants. It is an auxin inhibitor like triclopyr. It has a very favorable toxicity profile, being considered to be practically non-toxic to humans, mammals, fish, birds, amphibians and invertebrates. It is sold under the tradenames Milestone and Milestone VM. The labeled application

Cleveland National Forest Invasive Weed Management EA 37 rates for aminopyralid are 0.03 to 0.11 lb a.e./acre. The upper bound of this range is likely to be used for rhizomatous weeds. For non-rhizomatous weeds, the application rate will generally be about 0.078 lb a.e./acre. Aminopyralid remains active in the soil. The half-life of aminopyralid in soils ranges from 32 to 533 days, with a typical time of 103 days. It degrades via microbial degradation and sunlight. It is active in the soil, and is moderately mobile. It is not metabolized by mammals and can remain active in manure in animals that grazed in treated sites. Therefore it is important to not move grazing animals from treated areas to non-treated areas with sensitive vegetation.

Fluazifop: Fluazifop-p-butyl is a selective postemergence herbicide used for control of most annual and perennial grass weeds. It inhibits lipid synthesis in grasses and some other monocots. It has essentially no activity on broadleaf (dicot) species and can be sprayed overtop of many crops (including monocots in the lily and onion families). It is considered to be of low toxicity to birds and mammals, but is toxic to fish and aquatic invertebrates (Tu 2001).

Fluazifop-p-butyl binds strongly with soil particles and is rendered inactive in the soil. It has very low potential of moving off-site and contaminating ground or surface waters. It is broken down by microbial metabolism and has half-life in soils of one to two weeks. It will be applied with targeted foliar applications to grass weeds in restoration sites for coastal sage scrub vegetation and where non-native annual grasses are impacting habitat for threatened and endangered broadleaf plant species. Application rates range between .047 lbs/ai/acre to .375 lbs/ai/acre (Tu 2001).

3.2.2 Surfactants/Adjuvants and other inerts:

Most herbicides require the use of adjuvants, or additives to the tank mix. Surfactants are a particular type of adjuvant used to increase an herbicides effectiveness by increasing its ability to be absorbed by plants. In addition, herbicide formulations also contain other ingredients beyond the active ingredient called “inerts” that serve various purposes in the formulation. Any assessment of potential human health and ecological risk of herbicide use also needs to consider the toxicology of inerts and added adjuvants that are in the product or will be added to the herbicide in the field.

3.2.2.1 – Surfactants:

Modified seed oil (MSO) based surfactants will be used with all herbicides with this project. Examples of MSO based surfactants include the proprietary surfactant in Pathfinder II, Improved JLB Oil Plus and Cide-Kick, and MSO. These types of surfactants are considered to have very low toxicity (EPA category IV) and some of the main ingredients are registered food additives (Bakke 2007).

For aquatic approved formulations of glyphosate (like Rodeo), the surfactant used will be non-ionic, modified seed oil spreader such as Hasten or Competitor. It is important to state that these surfactants are different than the surfactant used in Round-up, which has been found to be toxic to amphibians. The surfactants that will be used were chosen due to their lower toxicity to amphibians and low toxicity to mammals and low risk to human health. It is not expected that these surfactants represent any risk of negative effects to human health or the environment at the low levels they will be used in this project (Bakke 2007, SERA 1997).

3.2.2.2 Inerts: The risk assessments analyze the potential for toxic or ecological effects of other ingredients in herbicide formulations beyond the active ingredients. These are called inerts.

The risk assessment for triclopyr looked at “inerts” and also surfactants that are contained in Garlon 4, and Pathfinder II (the trade formulations likely to be used.) One of these surfactants is known to be

Cleveland National Forest Invasive Weed Management EA 38 kerosene for some triclopyr based herbicides. The authors of the risk assessment were able to obtain a complete listing of ingredients but were unable to disclose them in the risk assessment for proprietary reasons. The risk assessment concluded that, based on known information, exposure to these adjuvants do not have negative effects at levels of exposure to Garlon 4 or Pathfinder II that would result in negative effects for triclopyr exposure (SERA 2011c). Therefore, exposure rates below levels of concern for triclopyr will not result in negative effects from adjuvants or surfactants in the trade formulations or with the addition of modified seed oil surfactants.

The risk assessment for aminopyralid shows that formulations currently on the market do not contain inerts or adjuvants other than water (SERA 2007). The risk assessments for imazapyr and glyphosate shows that formulations proposed for use do not contain inerts or adjuvants of concern (SERA 2001a, SERA 2001b). These herbicides both contain an isopropyl amine salt of the active ingredients and water. For all three of these herbicides the risk assessments conclude that potential impacts from inerts/adjuvants did not warrant further concern.

The risk assessment being used for fluazifop-b-butyl does not analyze the potential impacts of inerts or adjuvants. Inerts listed on the produce label for Fusilade II, a likely formulation being used, include naphthalene and petroleum based solvents and distillates. These ingredients do have toxic concerns associated with them. Naphthalene is most commonly associated with mothballs, and is also a byproduct of coal and other fossil fuel burning. Petroleum solvents are common inert ingredients in a variety of pesticides.

There is ample literature about the toxicity of both naphthalene and petroleum solvents. In general, these ingredients can have toxic effects related to central nervous system depression. This EA will rely on the Forest Service Risk Assessment for sethoxydim, a herbicide very similar to fluazifop-b-butyl. Sethoxydim is a monocot specific herbicide in the same class as fluazifop. It also has a similar toxicity profile. Common formulations of sethoxydim (Poast herbicide) also contain naphthalene and petroleum solvents/distillates as slightly higher percentages than common fluazifop formulations. The risk assessment for sethoxydim concludes that the naphthalene and petroleum solvents do not add significantly to the toxicity determinations for oral or dermal exposure but are a concern with inhalation exposure. This will be considered when determining potential health impacts while using fluazifop formulations, especially for applicators and workers (SERA 2001).

3.2.2.3 Colorants: Colorants will also be added to the herbicide mixture. These aid in helping herbicide applicators not miss plants or treat plants twice. They are also helpful for helping reduce worker or public exposure to treated vegetation. This project will utilize Hi-Light Blue dye or similar colorant. This colorant is a water soluble dye and contains no listed hazardous chemicals. It is considered virtually non-toxic to humans (Bakke 2007).

3.3 Human Health and Safety

3.3.1 Affected Environment

Two groups of people might be affected by this project: workers who are performing the eradication activities and members of the general public.

Contractors would most likely perform eradication activities for the Cleveland NF. Volunteers may be used for manual removal work. Work crews would be involved in various tasks including vegetation eradication, loading and unloading of materials, disposal of cut vegetation, and application of herbicides. Herbicide application would occur under the supervision of a licensed pesticide applicator.

Cleveland National Forest Invasive Weed Management EA 39 Members of the general public who might be affected by project-related activities include recreationists and recreation cabin residents. These groups or individuals would likely be in the project areas on a short-term basis. The time frames could vary from several hours to extended amounts of time in areas near treatment sites for the recreation cabin residents.

3.3.2 Environmental Consequences

The criteria for significance of impact in relation to human health and safety from herbicide use are discussed in detail in the USDA-Forest Service Forest National Risk Assessments for the herbicides being proposed. The risk assessments use widely accepted levels of exposure, both chronic and acute, to toxic chemicals that are deemed to present a human health risk. As is customary in human health risk assessments, these assumptions are highly conservative and represent exposures generally 100 times less than exposures that produced detectable negative effects in lab settings. The Risk Assessment then develop exposure scenarios for workers and for the general public to determine if it is possible that a person may be exposed to a level of the herbicide that may present a health risk. The European Food Safety Agency risk assessment for fluazifop-B-butyl uses a similar threshold for determining potential negative health effects (EFSA 2010).

The routes of exposure analyzed for workers included contact with herbicides through application spray activities and through accidental exposure (spills on bare skin, contaminated gloves etc.) For the general public, routes of exposure analyzed by the risk assessment included a direct spray on a child, exposure to contaminated vegetation, ingestion of contaminated crops, ingestion of contaminated water or fish, or swimming in contaminated water. Exposure scenarios for the public represent very conservative assumptions that assume exposures much greater than is likely. Therefore, when even under these exposure scenarios, there appears to be negligible or no risk of significant exposure, actual potential exposure risks to the public can be deemed at an acceptable level.

For chronic exposures, chronic reference doses (RfD’s) have been established by the Environmental Protection Agency (EPA) for each herbicide. For example, the dose of 0.05 mg/kg of body weight/day has been determined to be the chronic reference dose, or RfD, for triclopyr. This means that a person could receive a dose of 0.05 mg/kg/day throughout every day of his or her life without suffering adverse health effects. Short-term or acute excursions above the chronic RfD can occur without any known adverse health effects.

Due to the limited time frames of this project, acute exposure scenarios are more likely. The risk assessments use established numbers for the amount herbicide in a single dose which may cause health effects. For example, for triclopyr, the acute RfD is the same as the chronic dose, .05/mg/kg of body weight/day for women (.1/mg/kg for men) and for TCP, the value is 0.025 mg/kg/day.

The risk assessment also looked at “inerts” and adjuvants that are found in common herbicide formulations and tank mixes to determine if they may cause human health and safety risks at the use levels being proposed.

3.3.2.1 Alternative 1: Proposed Action

Direct Effects Exposure to herbicide ingredients and their metabolites is the primary concern for human health and safety in this alternative. Under this alternative, exposure to herbicide would mainly be a concern for workers in the project area applying the chemicals and recreationists hiking in recently treated areas. Some infestations occur adjacent to recreation cabins who spend a great deal of time in those project areas. Exposure of the general public to herbicides would likely only

Cleveland National Forest Invasive Weed Management EA 40 result from exposure to vegetation that has been recently sprayed. Most treatment areas are not heavily trafficked by members of the public. Where treatment areas occur adjacent to trails or other public use areas short term trail closures may occur (see design criteria).

Glyphosate: Glyphosate is considered to be of low toxicity to humans and mammals. It is not metabolized in the body and does not accumulate or concentrate in tissues. For glyphosate, the RfD has been determined to be 2mg/kg of body weight/day for both chronic and acute exposure. Glyphosate is poorly absorbed through the skin, so routes of exposure for glyphosate are mainly based on scenarios where contaminated water or vegetation is ingested. AMPA exposure were also analyzed for the general public. The likely source of exposure to TCP or AMPA would be ingestion of contaminated water or vegetation. (SERA 2011a)

For glyphosate, typical application rates used in Forest Service applications are 2lbs a.e*/ acre. These rates exceed those that have been used thus far on the Cleveland National Forest for treating Arundo donax. However, to be conservative, this analysis modeled an application rate of 3lbs a.e./acre to simulate a rate that may occur on very small scales (patches of Arundo) as part of this project during initial treatments. At the application rate of 3lbs a.e/acre only two exposure scenarios have hazard quotients that exceed the level of concern, and both of these scenarios are considered implausible to this project. The two scenarios are a child ingesting untreated water immediately after an accidental spill into surface waters and an adult female consuming treated vegetation immediately after spraying. These scenarios are considered implausible because surface waters are generally not ingested untreated on the Cleveland National Forest due to bacterial contaminants. In a spill scenario, personnel would be at the scene to prevent contact with the public of waters near the spill site. Vegetation is also not consumed on the Forest. There are no crops or gathered wild food sources in the project areas. There are no plausible exposure scenarios that lead to situations where workers or members of the general public would be exposed to levels of the glyphosate that would cause acute or chronic health concerns, even at this higher end of application rates (USDA 2014a).

Contact with contaminated vegetation will not lead to systemic exposure to glyphosate because it is poorly absorbed through the skin. Repeated dermal exposure has been reported to lead to minor skin irritation or rashes. This may be a factor for workers but can be mitigated by requiring the basic safety equipment, including long sleeves, pants and gloves (SERA 2011a).

The most likely route for oral exposure to glyphosate in this project is by drinking contaminated water. Several arundo infestations occur near where recreation cabins have drawn surface water for domestic use. Cabin owners are being required to phase out their use of surface water, but in the meantime some still pull water while streams are flowing and store the water in tanks for use during drier periods.

The risk assessment shows that under application rates of 3lbs a.e/acre adjacent to water, there is no concern that glyphosate nor AMPA concentrations reaching levels of concern (exposures above acute or chronic RfD) in adjacent waters without an accidental spill (USDA 2014a). This project will be using significantly less herbicide than this exposure scenario. Spraying of glyphosate will also be conducted in the late summer and fall when surface water is not present in these areas. This substantially reduces or eliminates the potential that glyphosate will be introduced to surface waters (see water quality section 3.5for discussion of potential for herbicide runoff.) In addition, glyphosate is easily removed from water by basic filtration due to its strong binding properties.

Cleveland National Forest Invasive Weed Management EA 41 Triclopyr: Triclopyr is considered moderately toxic to humans. TCP, its main intermediate metabolite is slightly more toxic than triclopyr. Routes of exposure for triclopyr include ingestion and absorption through the skin. For chronic exposure, a dose of 0.05 mg/kg of body weight/day has been determined by the Environmental Protection Agency (EPA) to be the chronic reference dose, or RfD, for triclopyr. For triclopyr, the acute RfD is the same as the chronic dose, .05/mg/kg of body weight/day for women (.1/mg/kg for men) and for TCP, the value is 0.025 mg/kg/day. Due to the limited time frames of this project, and the environmental degradation of triclopyr, acute exposure scenarios are more likely.

For the general public, the risk assessment for triclopyr concludes that at broadcast application rates of 2.0 lbs. per acre there are no plausible scenarios for exposure to triclopyr that would cause negative effects in the general public (SERA 2011c). Consumption of sprayed vegetation or contaminated fruit, or consumption of water immediately after an accidental spill due result in exposures that exceed levels of concern, but these scenarios are considered implausible. For TCP, GLEAMS modeling (discussed in section 3.5) shows that no hazardous exposure to TCP will occur as a result of this project, even under very conservative assumptions of a child consuming 1 liter of water per day from a treated creek.

Under typical exposure conditions for workers there would be no means of reaching a hazardous level of acute exposure to triclopyr (SERA 2011c). However, in the case of workers, safety measures need to be in place for workers applying triclopyr for more than three weeks in a row to avoid potentially dangerous chronic levels of exposure (SERA 2011c). These safety measures include wearing long sleeve shirts and protective gloves, and washing hands and clothing after each work day. These safety procedures are required by state and local laws and will be used in this project. Using these safety procedures, workers will not be exposed to potentially hazardous acute or chronic exposures to triclopyr.

Garlon 4, and Pathfinder II (the trade formulations likely to be used.) One of these adjuvants is known to be kerosene for the triclopyr based herbicides. The authors of the risk assessment were able to obtain a complete listing of ingredients but were unable to disclose them in the risk assessment for proprietary reasons. The risk assessment concluded that, based on known information, exposure to these adjuvants do not have negative effects at levels of exposure to Garlon 4 or Pathfinder II that would result in negative effects for triclopyr exposure (SERA 2011c). Therefore, exposure rates below levels of concern for triclopyr (exposure above acute or chronic Rfd) will not result in negative effects from adjuvants in the trade formulations.

Imazapyr: Imazapyr is considered practically non-toxic to mammals. An RfD of 2.5 mg/kg/day is used to characterize the risks of both short-term (acute) and longer-term (chronic) exposures and is the basis of determining the level of concern. This is a very conservative estimate because studies to date have found low and essentially undetectable acute and chronic (short or longer- term) systemic toxicity of this compound.

At maximum application rates of 1.5 lbs a.i/ acre delivered with targeted backpack foliar applications, only one exposure scenario leads to a dose above the level of concern. This is for a child accidentally drinking water into which a spill occurred. As with other herbicides, this exposure scenario is deemed implausible. Exposure to workers and the general public is below the level of concern in all other situations.

Aminopyralid: Aminopyralid is considered a reduced risk herbicide by the EPA and is generally applied at very low rates. The weight-of-evidence suggests that aminopyralid may not have any remarkable systemic toxic effects. The effects that are most commonly seen involve effects on the gastrointestinal tract after oral exposure and these may be viewed as portal of entry

Cleveland National Forest Invasive Weed Management EA 42 effects rather than systemic toxic effects. Aminopyralid is rapidly absorbed and excreted and is not substantially metabolized in mammals.

The chronic (long-term) reference dose (RfD)50 of 0.5 milligram of acid equivalent per kilogram body weight per day (mg a.e./kg bw/day or mg/kg/day) for aminopyralid. For incidental (acute, short-term and intermediate exposures), the US EPA has proposed an RfD of 1.0 mg a.e./kg bw/day or incident.

Based on the worksheet calculations completed for this project using the highest application rate proposed for this herbicide, no exposure scenarios, including accidental exposures to spills, are likely to have adverse effects on either workers or members of the general public. All scenarios analyzed are below the level of concern and plausible exposure scenarios are below the level of concern by several magnitudes.

Fluazifop-p-butyl: Fluazifop-P-butyl has low acute toxicity (EPA acute Toxicity Category III) by the oral, dermal and inhalation routes, is mildly irritating (EPA Toxicity Category IV) to the eye and skin. Toxic effects are primarily seen in the kidney and liver (US-EPA 2005).

In accordance with EPA’s Guidelines for Carcinogen Risk Assessment, Fluazifop-P-butyl is classified as “not likely to be carcinogenic to humans.” No mutagenic potential was observed in adequate in vivo and in vitrostudies with fluazifop-P-butyl (US-EPA 2005).

The European Food Safety Authority determined that, “The acceptable daily intake (ADI) is 0.01 mg/kg bw/d (expressed as fluazifop acid), based on the overall long-term NOAEL of 1 mg/kg bw/d and applying a safety factor of 100. The acceptable operator exposure level (AOEL) of fluazifop-p-butyl is 0.02 mg/kg bw/d, based on the NOAEL of 2 mg/kg bw/d found in the developmental rat study supported by the 90-d rat study and applying a safety factor of 100 (EFSA 2010).

The EFSA concluded that, “For hand-held application, the estimated operator exposure is below the AOEL (59% of the AOEL) if gloves are used during mixing and loading and application according to the UK POEM and considering a volume of dilution of 500L. Worker and bystander exposure is below the AOEL (30.4% and 1.4% of the AOEL, respectively). EFSA 2010”

The inerts contained in most commercial fluazifop formulations were not analyzed in the EFSA and Canadian Risk Assessments. However, Sethoxydim has a similar toxicology profile and inert/adjuvant composition to Fluazifop-P-butyl and a complete Forest Service Risk Assessment has been completed for Sethoxydim. Based on the worksheet calculations completed for this project using the highest application rate proposed for the herbicide sethoxydim (.375 lbs a.i/acre), no plausible exposure scenarios are likely to have adverse effects on either workers or members of the general public. Plausible, non-accidental exposure scenarios are below the level of concern by several magnitudes owing to the very low application rates necessary for this class of herbicides. The only exposure scenario that exceeds the level of concern is for a small child consuming water immediately after a spill. This scenario is implausible, especially since this herbicide will not be used within 100 feet of surface waters due to concerns with fish toxicity – see Section 3.4.

Non-herbicide related direct effects: Under this alternative, work crews would be exposed to typical hazards associated with field work, including heat, insects and snakes, and rough terrain.

Cleveland National Forest Invasive Weed Management EA 43 These hazards will be identified and mitigated as much as possible during the project implementation. Work crews would also be exposed to dangers inherit with using hand tools, especially chainsaws. These dangers would be mitigated with appropriate safety gear and training.

Indirect Effects No indirect effects on human health and safety are expected. The direct effects section analyzes all routes of potential exposure.

Cumulative Effects Cumulative impacts to human health from herbicide exposure could come from exposure to herbicides on Forest Service land and also from almost identical herbicide use projects on adjacent city/county/private owned lands. The hope for treatment of many of these infestations is that work will occur in concert with treatments of the same species on adjacent jurisdictions. For example, the treatment of tamarisk is Hauser Canyon will only be effective in conjunction with efforts to remove tamarisk on adjacent City of San Diego lands. The only other Forest Service activity currently proposing herbicide use in the project area is the Lake Morena Fuels Reduction project, that may use herbicide to reduce shrub cover in WUI threat zones. The direct effects section analyzes longer term exposures to herbicides that workers on the project will be exposed to. Members of the public may be exposed to herbicides on National Forest Service lands and on adjacent lands. These potential exposures (both acute and chronic) are within the scenarios used to analyze the direct effects of this project since these scenarios analyze based on application rates per acre over large project areas.

While this analysis did not research total annual herbicide use in San Diego, Riverside and Orange Counties, it is important to realize that the total amount of herbicide used by these projects (both on Forest Service and on lands treated by adjacent jurisdicitons) will be undoubtedly a tiny fraction of total herbicide used in the counties. Both glyphosate and triclopyr are sold over the counter and used extensively in home and commercial landscaping, golf and park maintenance and other similar applications. All proposed herbicides are available by permit to qualified applicators and also used extensively in commercial and agricultural applications. These uses, occurring nationwide, have not led to identifiable risks to human health from the herbicides being proposed. Therefore it is unlikely this project and similar projects will have a cumulative effect that would lead to significant effects on human health.

3.3.2.2 Alternative 2: Continued Manual and Mechanical Weed Control Efforts with No Herbicides Under this alternative, no herbicide would be used. Eradication of non-natives would occur by mechanical removal using hand tools.

Direct, Indirect and Cumulative Effects Under this alternative work crews would be exposed to typical hazards encountered when hand tools, especially chainsaws, are being used. They would also be exposed to typical field work hazards as described in previous section. These hazards will be identified and mitigated as much as possible during the project implementation. In addition, members of the general public, particularly recreationists that could walk into a work area, might have some degree of exposure to the same potential hazards. Mitigation can be implemented to limit the potential for exposure of the general public to work area hazards related to vegetation removal. Direct and indirect effects to human health and safety are limited to accidents. No cumulative effects to human health and safety are expected

Cleveland National Forest Invasive Weed Management EA 44 3.3.3.3 Alternative 3: No Action Under this alternative, no eradication activities would occur. Invasive weed species would continue to infest the project area. The primary adverse effect to human health and safety under this alternative involves wildfires. If invasive weeds, especially Arundo donax and Tamarisk spp. are not controlled in the project area there would continue to be a risk of wildfire and increased fire severity due to fuel loads that exceed levels found in native plant communities. As Arundo donax and other invasive weeds continue to infest the area, the risk of destructive wildfires would likely increase. However, it is difficult to determine the scale of this effect.

3.3.4 Significance Summary

Based on the criteria provided in section 3.5.2, Alternative 1 would not have a significant adverse effect on human health and safety. Alternative 2 would not have significant adverse effects on human health and safety. Alternative 3 would not have significant adverse effects on human health and safety.

3.4 Biology – Wildlife and Plant Species

3.4.1 Affected Environment

The proposed project area encompasses the entire Cleveland National Forest, which is approximately 460,000 acres in size. This include a significant portion of central San Diego County within the foothill and mountain zone, portions of southern Riverside County, and Forest Service lands within the Santa Ana Mountains of San Diego, Orange and Riverside Counties. This area includes 11 primary watersheds. Because of the size of the project area and its extensive geographical range, general habitat types or vegetation communities within the project area are diverse and include; sage scrub, chaparral, grassland, wetlands, riparian, oak woodland, mixed forest, desert scrub and desert wash.

Proposed invasive plant species control activities will occur primarily within riparian, grassland and disturbed habitat areas. Many populations of Priority 1 and 2 species on the Cleveland National Forest are found in association with roadsides and disturbed areas such as old home sites or other human activity locations. Current Priority 1 and 2 species populations on the Cleveland National Forest are also found in relatively low densities over a large geographical area. For example, most tamarisk populations within riparian areas are dispersed with scattered individuals over several linear miles of stream. The overall estimated amount of acres on the Cleveland National Forest for invasive treatments is minimal and includes a few hundred acres or a fraction of the overall percentage of the project area.

Special status species considered in this analysis are those which are state or federally threatened, endangered or candidate; and Regional Forester’s Sensitive Species. Only those species that are known or have the potential to occur within the project area are listed, and only those species with the potential to be negatively affected by project activities are addressed in detail. There are 95 endangered, threatened, candidate, and FS sensitive plant and animal species listed as occurring or potentially occurring on the Cleveland National Forest including 33 animal (Table 3) and 62 plant species (Table 4). Information on listed species which have the potential to occur within the proposed project area were identified from field surveys, USDA Forest Service information and the California Natural Diversity Data Base (CNDDB). Twenty-seven of the 95 species are federal and/or state listed as endangered or threatened and only three of these have potential to be negatively affected by the proposed project. These are Southwestern Willow Flycatcher, Least Bell’s Vireo and Arroyo Southwestern Toad.

This section presents a summary of the analysis and effects determination found in the Wildlife and Botany Biological Evaluation and Assessment for the Cleveland National Forest’s Invasive Weed

Cleveland National Forest Invasive Weed Management EA 45 Management Plant, prepared by Jeff Wells, Wildlife Biologist (USFS 2014a), which is found in the project record and incorporated here by reference.

Table 3: Special Status Animal Species 1 4 2 3

LISTED ANIMAL SPECIES Federal Listing State Listing List USFS on Documented Cleveland NF in Documented AreaProject OccurrencePotential in Project Area Suitable Habitat in AreaProject Designated Habitat in Project Area Potential For Negative Effects? BIRDS Bald Eagle* Haliaeetus leucocephalus E S Yes Yes - No Brown Pelican* Pelecanus occidentalis S Yes Yes - No California Spotted Owl Strix occidentalis occidentalis C S Yes Yes - No Southwestern Willow Flycatcher Empidonax trailii extimus E E Yes Yes Yes Yes Least Bell's Vireo Vireo bellii pusillus E E Yes Yes Yes Yes Gray Vireo Vireo vicinior S Yes Yes No California Gnatcatcher Polioptila californica T C Yes Yes Yes No San Diego Cactus Wren Campylorhynchus brunneicapillus C S Yes Yes - No Western Yellow-billed Cuckoo Coccyzus americanus occidentalis C E S No No No No - No MAMMALS Fringed Myotis Myotis thysanodes S ? ? Yes - No Pallid Bat Antrozous pallidus C S Yes Yes - No Townsend's Big-eared Bat Corynorhinus townsendii townsendii C S Yes Yes - No Stephen's Kangaroo Rat Dipodomys stephensi E E Yes Yes - No REPTILES and AMPHIBIANS Two-striped Garter Snake Thamnophis hammondii C S Yes Yes - No San Diego Mountain Kingsnake Lampropeltis zonata pulchra C S Yes Yes - No San Diego Ringneck Snake Diadiphis punctatus similis S Yes Yes - No Coastal Rosy Boa Charina trivirgata roseofusca S Yes Yes - No Red Diamondback Rattlesnake Crotalus ruber S Yes Yes - No Silvery Legless Lizard Anniella pulchra pulchra C S Yes Yes - No San Diego Horned Lizard Phrynosoma coronatum blainvillei C S Yes Yes - No Orange-throated Whiptail Asidoscelis hyperythra S Yes Yes - No Southwestern Pond Turtle Clemmys marmorata pallida C S Yes Yes - No Arroyo Southwestern Toad Bufo microscaphus californicus E C Yes Yes Yes Yes California Red-legged Frog ** Rana aurora draytoni T C No No No No No No Sierra Madre Yellow-legged Frog ** Rana muscosa E C S No No No No No No Large-blotched Salamander Ensatina eschscholtzii klauberi C S Yes Yes - No FISH Southern Steelhead Trout Oncorhynchus mykiss E C S Yes Yes Yes No Arroyo Chub Gila orcutti C S Yes Yes - No Santa Ana Speckled Dace C S Yes No No - No INVERTEBRATES Hermes Copper Butterfly Lycaena hermes C S Yes Yes - No Quino Checkerspot Butterfly Euphydryas editha quino E Yes Yes Yes No Laguna Mountain Skipper Pyrgus ruralis lagunae E Yes Yes Yes No Warner Springs Shoulderband Snail Rothelix warnerfontis S Yes Yes - No

Cleveland National Forest Invasive Weed Management EA 46 Table 4: Special Status Plant Species

1 3

2

Project AreaProject in Project Area in Project Area Cleveland NF Cleveland Documented in Documented in Documented on Documented on StateListing Suitable Habitat Habitat Suitable ForestService Potential Presence Presence Potential SPECIES FederalListing Acanthomintha ilicifolia San Diego Thorn-mint T E Yes Yes Yes Yes Allium munzii Munz's Onion E T Yes Yes Yes Yes Astragalus brauntonii Brauton's Milk Vetch E No No Yes Yes Baccharis vanessae Encinitas Baccharis T E Yes Yes Yes Yes Berberis nevinii Nevin's Barberry E E Yes Yes Yes Yes Brodiaea filifolia Thread-leaved Brodiaea T E Yes Yes Yes Yes Ceanothus ophiochilus Vail Lake Ceanothus T E Yes Yes Yes Yes Dodecahema leptoceras Slender-horned Spineflower E E Yes Yes Yes Yes Dudleya cymosa var. ovatifolia Oval-leaved Dudleya T Yes Yes Yes Yes Eryngium aristulatum var. parishii San Diego Button Celery E Yes Yes Yes Yes Poa atropurpurea San Bernardino Bluegrass E Yes Yes Yes Yes Abronia villosa v. aurita Sand Verbena S No No Yes Yes Arctostaphylos rainbowensis Rainbow Manzanita S Yes Yes Yes Yes Astragalus deanei Dean's Milk-vetch S Yes Yes Yes Yes Astragalus douglasii var. perstrictus Jacumba Milk-vetch S Yes Yes Yes Yes Astragalus oocarpus San Diego Milk-vetch S Yes Yes Yes Yes Astragalus pachypus var. jaegeri Jaeger's Milk-vetch S Yes Yes Yes Yes Atriplex parishii Parish's Bristlescale S No No Yes Yes Brodiaea orcuttii Orcutt's Brodiaea S Yes Yes Yes Yes Brodiaea santarosae Santa Rosa Basalt Brodiaea S Yes Yes Yes Yes Calochortus dunnii Dunn's Mariposa Lily R S Yes Yes Yes Yes Calochortus weedii var. intermedius Intermediate Mariposa Lily S Yes Yes Yes Yes Castilleja lasiorhyncha San Bernardino Mountains Owl's Clover S No No Yes Yes Caulanthus simulans Payson's Jewel-Flower S Yes Yes Yes Yes Ceanothus cyaneus Lakeside Ceanothus S Yes Yes Yes Yes Chorizanthe parryi v. parryi Parry's Spineflower S No No Yes Yes Deindrana floribunda Tecate Tarplant S No No Yes Yes Deindrana mohavensis Mojave Tarplant E S Yes Yes Yes Yes Dieteria asteroides var. lagunensis Laguna Mtn. Aster R S Yes Yes Yes Yes Delphinium hesperium ssp. Cuyamacae Cuyamaca Larkspur R S Yes Yes Yes Yes Dudleya multicaulis Many-stemmed Dudleya S Yes Yes Yes Yes Dudleya viscida Sticky Dudleya S Yes Yes Yes Yes Eriogonum evanidum Vanishing Wild Buckwheat S Yes Yes Yes Yes Galium angustifolium ssp. jacintum San Jacinto Mts. Bedstraw S Yes Yes Yes Yes Githopsis diffusa ssp. filicaulis Mission Canyon Bluecup S No No Yes Yes Hesperocyparis forbesii Tecate Cypress S Yes Yes Yes Yes Hesperocyparis stephensonii Cuyamaca Cypress S Yes Yes Yes Yes Heuchera abramsii Abram's Alumroot S No No Yes Yes Horkelia cuneata puberula Star Potentilla S Yes Yes Yes Yes Horkelia truncata Ramona Horkelia S Yes Yes Yes Yes Lepechinia cardiophylla Heart-leaved Pitcher Sage S Yes Yes Yes Yes Lessingia glandulifera var. tomentosa Warner Springs Lessingia S No No Yes Yes Lewisia brachycalyx Short-sepaled Lewisia S No No Yes Yes Lilium parryi Lemon Lily S Yes Yes Yes Yes Linanthes gracilis ssp. parishii Parish's Meadowfoam E S Yes Yes Yes Yes Linanthus orcuttii Orcutt's Linanthus S Yes Yes Yes Yes Monardella hypoleuca ssp. lanata Felt-leaved Monardella S Yes Yes Yes Yes Monardella macrantha ssp. hallii Hall's Monardella S Yes Yes Yes Yes Monardella nana ssp. leptosiphon San Felipe Monardella S Yes Yes Yes Yes

Cleveland National Forest Invasive Weed Management EA 47

1 3

2

NF Area Project AreaProject StateListing ForestService FederalListing Suitable Habitat in in Habitat Suitable Documented in Project Area Documented in Potential Presence in Project Project in Presence Potential SPECIES Cleveland Documented on Navarretia peninsularis Baja Navarretia S No No Yes Yes Nolina cismontana Chaparral Beargrass S Yes Yes Yes Yes Packera ganderi Gander's butterwort R S Yes Yes Yes Yes Penstemon californicus California Beardtongue S No No Yes Yes Phacelia keckii Santiago Peak Phacelia S Yes Yes Yes Yes Ribes canthariforme Moreno Currant S Yes Yes Yes Yes Satureja (Clinopodium) chandleri San Miguel Savory S Yes Yes Yes Yes Scutellaria bolanderi ssp. austromontana Southern Skullcap S Yes Yes Yes Yes Sibaropsis hammittii Hammitt's Clay-crest S Yes Yes Yes Yes Streptanthus campestris Southern Jewelflower S Yes Yes Yes Yes Symphyotrichum defoliatum San Bernardino Aster S Yes Yes Yes Yes Tetracoccus dioicus Parry's Tetracoccus S Yes Yes Yes Yes Thermopsis californica var. semota Velvety False Lupine S Yes Yes Yes Yes Thysanocarpus rigidus Rigid Fringepod S Yes Yes Yes Yes

3.4.2 Environmental Consequences

The risk to biological resources from the use of proposed herbicides is dependent upon many factors including herbicide type (toxicity), amount and duration of exposure, application method and area of use (habitat type). Proposed application methods of herbicides are almost exclusively limited to direct application (painting) of cut stems/trunks or direct foliar spraying with the use of back-pack sprayers. Broadcast spraying may be necessary on a limited basis, typically within non-native grassland areas or locations that have a large target invasive weed problem. This is expected for small areas infested with Yellow Starthistle using aminopyralid or to control certain non-native grasses using fluazifop. Adverse effects to wildlife and even non-target vegetation is expected to be minimal to negligible due to the limited extent and specific application sites of herbicides. Direct and indirect effects to wildlife from consuming contaminated plant material or invertebrates is not expected to be significant due to the limited amount of vegetation treated within a given area and that most targeted weed species are largely unpalatable to herbivores and insects. None of the listed herbicides is being proposed for use within aquatic habitats.

Toxicity effects of the proposed herbicides on biological resources are based primarily on Forest Service Risk Assessments conducted by Syracuse Environmental Research Associates, Inc. (SERA); (SERA 2007, 2011a, 2011b, 2011c). Risk assessments for Fluazifop-P-Butyl are based on information from the European Food Safety Authority (EFSA 2010), the United States EPA (2005), Health Canada (2012) and The Nature Conservancy (Tu et al. 2001). SERA Risk Assessments include extensive reviews which are based upon the best available science from peer reviewed scientific literature and EPA documents to describe the expected level of herbicide to be introduced into the environment and evaluate the associated risk of adverse effects to biological resources. These risk assessments and associated herbicide worksheets help identify resources that may be at risk and potential concerns that necessitate mitigation measures to protect and/or avoid adverse effects to natural resources.

The known and predicted impacts to wildlife and non-target vegetation within this analysis are based upon recommended and planned herbicide application rates. Risk assessments conducted by SERA that reach or approach a toxicity threshold are based upon worst case scenarios, including direct acute

Cleveland National Forest Invasive Weed Management EA 48 contact, ingestion of large amounts of contaminated food or prolonged exposure. None of these scenarios are expected under this proposed program and intentional misuse or accidental spills/contamination will always have potential impacts to wildlife, non-target vegetation and aquatic habitat.

3.4.2.1 Alternative 1: Proposed Action – Effects to Wildlife Direct Effects to Wildlife from Herbicides

Glyphosate is a broad spectrum herbicide and is the most widely used herbicide in the world. Currently there are at least 35 commercial formulations, including the trade names Roundup and Rodeo. Extensive published literature exists concerning the safety and toxicity of glyphosate. Glyphosate is typically used through foliar application where it is absorbed into the plant and inhibits the plant’s metabolic pathway. Glyphosate has a strong affinity to bind with soil particles and has low potential for mobility or transport and is not readily metabolized by most plants through the soil. Toxicity profiles to mammals, birds and other terrestrial wildlife indicate that glyphosate has a low potential for adverse effects. Toxicity to aquatic organisms is considered to be low; however some formulations may affect amphibians due to the surfactant POEA, which will not be used under this proposed program. Overall risk from this herbicide to wildlife and non-target plants is low and no aquatic applications are being proposed.

At the modeled application rate of 3lbs a.e/acre the SERA worksheets determined that several exposure scenarios have hazard quotients that exceed the level of concern for terrestrial wildlife. The upper bounds of exposures for small mammals, small birds and small insects consuming contaminated grass or broadleaf foliage exceed the level of concern. However, these exposures are not likely. The only infestations that will receive an application rate potentially nearing 3lbs/acre are Arundo donax patches, and these occur on very small scales. Arundo is not consumed by wildlife, especially small mammals and birds. Use of glyphosate on other target species will be limited to spot treatments in very small areas and will not result in large areas of potentially contaminated vegetation.

Triclopyr is a dicot (broadleaf) specific herbicide that is typically used to treat woody vegetation through cut stump, stem or basal bark application. Trade name formulations include Garlon 4 or Pathfinder II. For foliar applications, the trade formulations include Garlon 3A. Triclopyr affects the plant by mimicking the growth hormone auxin. Triclopyr degrades quickly in the environment particularly in sunlight and binds readily to clay and organic material. Toxicity to terrestrial animals is considered low and most likely through direct absorption or ingestion of sprayed plant material. At the modeled application rate of 2lbs/acre, the risk assessment worksheets show that consumption of vegetation by small birds and mammals surpass the level of concern. An accidental direct spray of an amphibian also surpasses the level of concern. Neither of these exposures are likely due to the use of this herbicide in limited areas of cut stem or stump vegetation and the unlikelihood of herbivory on cut and treated plant material, as well as timing of treatment when amphibians are unlikely to be above ground.

Triclopyr is considered potentially toxic to fish and other aquatic organisms through direct exposure or run-off. Effects of this herbicide on aquatic life should be reduced because there will be no direct aquatic application and due its limited persistence and that it would not be used during or within 48 hours of any precipitation.

Imazapyr is a broad spectrum non-selective herbicide used to treat a wide variety of species, especially in aquatic settings. Trade names include Habitat, Stalker or Chopper. It is generally applied in targeted foliar applications, but can be used in cut surface application, and is often

Cleveland National Forest Invasive Weed Management EA 49 mixed with other herbicides. Imazapyr affects plants by inhibiting amino acid synthesis. This herbicide is persistent in the soil and can have significant effects in post treatment areas on non- target vegetation. Imazypyr is considered practically non-toxic to both terrestrial and aquatic wildlife.

At an application rate of 1.5lbs/acre the only exposure scenarios that exceed the level of concern for terrestrial wildlife is consumption of contaminated short grass by small mammals and small birds. This scenario is not plausible for this project due to the fact that this herbicide will only be used in targeted spot treatments and mostly on woody vegetation.

Aminopyralid is a selective herbicide that treats broadleaf weeds and is especially effective against non-native thistles. It is found in the trade formulations Milestone and Milestone VM. It is usually applied over infested areas in a broadcast application. This herbicide is persistent and should not be applied in areas subject to grazing. Aminopyralid is considered practically non- toxic to both terrestrial and aquatic wildlife.

At an application rate of .078lbs/acre the only exposure scenarios that exceed the level of concern for terrestrial wildlife is consumption of contaminated short grass, tall grass, or broadleaf foliage by small birds. This scenario is not plausible for this project due to the fact that this herbicide will only be used in small scale broadcast applications over areas infested with target thistle species.

Fluazifop-p-butyl is a selective, monocot specific herbicide used to target grass weed species. It is found in the trade formulations Fusilade II and Fusilade DX. It is generally applied as a broadcast application to remove grass weeds in agricultural settings but is increasingly being used to control non-native annual grasses in habitat restoration settings. This herbicide has minimal affect to non-target herbaceous plant species and is not persistent in the soil. Fluazifop is considered slightly toxic to terrestrial wildlife as an irritant or if ingested. Toxicity to aquatic wildlife, particularly fish can be moderate to severe. Due to the potential effects to aquatic organisms, this herbicide will not be used within 100 feet of surface water.

Due to very low application rates ranging between .047 lbs/ai/acre to .375 lbs/ai/acre and the fact that this herbicide will only be used in very localized areas as part of restoration activities or endangered plant management, it is unlikely there will be significant exposures for terrestrial wildlife.

Non-Herbicide Direct and Indirect Effects to Wildlife

Effects to fish and wildlife from the manual cutting and eradication of nonnatives, from the temporary loss of vegetation cover, and from work crew presence are expected to be of the same nature as in Alternative two and are discussed in that section. However, impacts from work crew presence and mechanical disturbance will be less than for Alternative two due to a reduced need for follow up treatment and a reduced amount of ground disturbance from grubbing of root masses.

Long-term effects include increased water quantity and improved water quality for aquatic organisms and improved riparian woodland habitat for nesting birds through the control of invasive weeds. Eradication of non-natives would also decrease the likelihood of wildfires burning in riparian areas.

Cleveland National Forest Invasive Weed Management EA 50 In general, the proposed action will have long term beneficial effects from the removal of exotic vegetation that will be replaced by native species. This will provide improved habitat characteristics for native animal species.

Cumulative Effects to Wildlife

Related activities to the proposed action include the limited removal and control efforts of invasive plant species on and adjacent to the Cleveland National Forest. Invasive plant species control efforts on non-Forest Service lands has primarily involved the control and removal of arundo and tamarisk within the major riparian/stream drainages. The proposed action cumulatively benefits the project and surrounding areas by preventing the continued establishment and spread of invasive plant species on both Forest Service and surrounding lands. The proposed action will also assist in prevention and control of invasive plant species colonizing onto as well as from Forest Service lands. Proposed management activities for the control of invasive plant species are limited in both geographical area and only occur on in any specific area for a limited time period on an annual basis.

3.4.2.2 Alternative 2: Continued Manual and Mechanical Weed Control Efforts with No Herbicides – Effects to Wildlife Direct and Indirect Effects to Wildlife from Manual Control Alternative

This alternative will result in minor to moderate disturbance to the soil surface and vegetation communities to remove invasive weed root systems from the ground. Direct effects could be expected from noise associated with chainsaws and direct contact with machinery or with root pulling mechanisms, especially for burrowing species. The project would be scheduled outside the breeding season for birds of concern (migratory and special-status species) and amphibians. Therefore, nesting birds of these species and amphibian eggs would not be affected. Some wildlife species may be displaced by work crew activity and the cutting and piling of biomass. The effect would be temporary. There would be a higher risk of short-term decrease in water quality due to disturbed soils in the project area.

Long-term effects include increased water quantity and improved water quality for aquatic organisms and improved riparian woodland habitat for nesting birds through the control of invasive weeds. Eradication of non-natives would also decrease the likelihood of wildfires burning in riparian areas. However, this effect would be much less than the proposed action due to the smaller amount of areas that would be expected to receive treatment.

This alternative would require significantly more work crew presence and disturbance in habitats than the proposed action due to an increased need for follow up treatment and a larger initial effort to remove larger root masses. The beneficial effects of this alternative on habitat quality over the long term is expected to be less than the proposed action due to the decreased efficacy of manual treatments alone on removing species that sprout from root masses.

Cumulative Effects to Wildlife from Manual Control Alternative

Related activities to the proposed action include the limited removal and control efforts of invasive plant species on and adjacent to the Cleveland National Forest. It is unlikely that other jurisdictions would implement strictly manual control methods, so there is unlikely to be cumulative effects from ground disturbing activities. This alternative cumulatively benefits the project and surrounding areas by preventing the continued establishment and spread of invasive

Cleveland National Forest Invasive Weed Management EA 51 plant species on both Forest Service and surrounding lands, but to a lesser extent than the proposed action.

This alternative will also assist in prevention and control of invasive plant species colonizing onto as well as from Forest Service lands. Proposed management activities for the control of invasive plant species are limited in both geographical area and only occur on in any specific area for a limited time period on an annual basis.

3.4.2.3 Alternative 3: No Action – Effects to Wildlife

Direct and Indirect Effects to Wildlife from No Action Alternative

No direct effects would occur since no action is being taken. Indirect effects of this alternative are associated with ways in which the alternative would affect the habitat for fish and wildlife species. The proposed project area would experience a decrease in water quantity as increasing colonies of tamarisk and Arundo donax transpire more water. Invasive weeds in the project area would continue to propagate and expand in cover. This would make resources such as space, sunlight, and water unavailable for wildlife and fish species. Tamarisk and Arundo donax are highly flammable when dry and pose an increased threat of fire in riparian areas. Not treating infested areas also allows these species to spread and form new colonies downstream or in adjacent areas due to wind dispersal of seed, decreasing the habitat value for fish and wildlife species throughout the watershed and in adjacent watersheds. The short-term effect of this alternative is the maintenance of existing conditions with no effects on native vegetation due to disturbance from work crews or herbicides.

Cumulative Effects to Wildlife from No Action Alternative

The cumulative effect of this alternative is that the loss of native riparian and aquatic habitat caused by conversion to invasives would add to the loss of these threatened habitats in California. This would negatively affect fish and wildlife species that depend on these aquatic and riparian habitats.

3.4.2.4 Impacts to Special Status Wildlife Species from all Alternatives:

Federally listed threatened or endangered species

The Biological Assessment conducted for this project determined that the action alternatives may affect, but was not likely to adversely affect, three Federally listed wildlife species; California arroyo toad, least Bell’s vireo, and southwestern willow flycatcher. For all other federally listed species listed in Table 3, the action alternatives were determined to have either no effect, or a positive effect due to improved habitat conditions from the removal of invasive weed species.

California (Arroyo) Toad (Bufo microscaphus californicus)

Potential negative direct effects to this species from the action alternatives include the accidental death, injury or disturbance to individual toads from the grubbing and/or removal of larger vegetation from riparian areas. This impact is expected to be minimal with a low probability of occurrence. To avoid potential direct effects to arroyo toads, occupied and/or designated critical habitat would be avoided during the breeding season when toads are most likely to be encountered. Treatment activities would be conducted between September 01 and March 01. This time frame would also limit the potential effects of accidental aquatic habitat herbicide

Cleveland National Forest Invasive Weed Management EA 52 contamination. The five proposed herbicides have been shown to contain negligible toxicity levels to wildlife and a low level of persistence in the environment. In addition, treatment methods within riparian areas will be in a very limited application to individual targeted invasive weed plants. Broadcast spraying of herbicides is not being proposed nor is it necessary within riparian or wetland areas. Positive direct effects to this species from the utilization of herbicides is less soil and sub-soil disturbance from digging and grubbing activities.

There are no known potential negative indirect effects from the action alternatives to this species or its habitat. Positive indirect effects to this species include the removal of invasive weeds within riparian areas that can have a negative effect on water availability and stream flow conditions. Long term beneficial effects to this species from the proposed action include the removal of invasive weeds that will be replaced by native species which provide improved habitat characteristics for this and other native animal and plant species.

Potential negative direct, indirect and cumulative effects to this species from the no-action alternative include the continued degradation of riparian habitat from increased invasive weed species establishment. This ultimately leads to lower native plant diversity and associated negative impacts to habitat suitability for riparian and aquatic dependent species.

Least Bell’s Vireo (Vireo bellii pusillus)

No negative direct effects to this species are expected from the action alternatives. Occupied least Bell’s vireo habitat would be avoided during the breeding season. No treatment activities would be conducted in designated critical habitat and/or areas where vireos have been documented between March 01 and August 01. The five proposed herbicides have been shown to contain negligible toxicity levels to wildlife and a low level of persistence in the environment. In addition, treatment methods within riparian areas will be in a very limited application to individual targeted invasive weeds. Broadcast spraying of herbicides is not being proposed nor is it necessary within this habitat type.

Potential negative indirect effects from the action alternatives to this species include the short- term loss of vegetation within occupied habitat from the removal and/or spraying of dominant cover species such as tamarisk. This would be a short term impact, and primarily restricted to Hauser Canyon and La Posta Creek where tamarisk can be a dominant canopy cover species in some locations. Long term beneficial effects to this species from the proposed action include the removal of exotic vegetation that will be replaced by native species which provide improved habitat characteristics for this and other native animal and plant species.

Potential negative direct, indirect and cumulative effects to this species from the no-action alternative include the continued degradation of riparian habitat from increased invasive weed species establishment. This ultimately leads to lower native plant diversity and associated negative impacts to habitat suitability for riparian obligate bird species.

Southwestern Willow Flycatcher (Empidonax traillii extimus)

No negative direct effects to this species are expected from the action alternatives. Occupied and/or critical designated habitat areas for the willow flycatcher would be avoided during the breeding season. Treatment activities would be conducted between September 01 and March 01. The five proposed herbicides have been shown to contain negligible toxicity levels to wildlife and a low level of persistence in the environment. In addition, treatment methods within riparian

Cleveland National Forest Invasive Weed Management EA 53 areas will be in a very limited application to individual targeted invasive weed plants. Broadcast spraying of herbicides is not being proposed nor is it necessary within this habitat type.

Currently the southwestern willow flycatcher only occurs on Forest Service lands within the San Luis Rey River downstream of Lake Henshaw. This area contains no known priority exotic plant species populations so there are no proposed treatments within this area.

Potential negative indirect effects from the action alternatives to this species include the short- term loss of vegetation within occupied habitat from the removal and/or spraying of dominant cover species such as tamarisk. This would be a short term impact, and primarily restricted to Hauser Canyon and La Posta Creek where tamarisk can be a dominant canopy cover species in some locations. This potential impact is unlikely due to the fact that this species is not known to occur within these locations, however there is potential for this species to occur within these locations. Long term beneficial effects to this species from the proposed action include the removal of exotic vegetation that will be replaced by native species which provide improved habitat characteristics for this and other native animal and plant species.

Potential negative direct, indirect and cumulative effects to this species from the no-action alternative include the continued degradation of riparian habitat from increased invasive weed plant species establishment. This ultimately leads to lower native plant diversity and associated negative impacts to habitat suitability for riparian obligate bird species.

Forest Service Region 5 Regional Forester Sensitive Species

The list of R5 Regional Forester Sensitive Species analyzed for this project is shown in Table 3:

Gray Vireo Bald Eagle California Spotted Owl Brown Pelican San Diego Cactus Wren The Biological Evaluation determined that the proposed action will have no effect to the bald eagle, brown pelican, California spotted owl, gray vireo or San Diego cactus wren. This determination is based upon the following conditions: • These species have a very limited range within the Cleveland National Forest • Suitable habitat for these species is not near any non-native plant species occurrences and would not be affected by associated treatment activities. • These species would not be subject to acute or prolonged exposure to herbicides. • Risk assessments did not identify any impacts to the prey species of these animals.

Pallid Bat Fringed Myotis Townsend’s Big-eared Bat The Biological Evaluation determined that the proposed action will have no effect to the pallid bat, Townsend’s big-eared bat or fringed myotis. This determination is based upon the following conditions: • These species utilize treatment areas for nocturnal foraging. They are not subject to acute or prolonged exposure to herbicides. • Invasive weed species treatment actions are not proposed within any known or potential roosting or hibernation sites. • Risk assessments did not identify any impacts to the prey species of these animals.

Cleveland National Forest Invasive Weed Management EA 54

San Diego Mtn. Kingsnake San Diego Ringneck Snake Coastal Rosy Boa Silvery Legless Lizard San Diego Horned Lizard Red Diamond Rattlesnake Orange-throated Whiptail Large-blotched Salamander The Biological Evaluation determined that the proposed action will have no negative effects to the San Diego Mtn. kingsnake, coastal rosy boa, San Diego Horned lizard, Orange-throated whiptail, San Diego ringneck snake, silvery legless lizard and large-blotched salamander. This determination is based upon the following conditions: • All of these species either have the ability to avoid treatment activities by moving out of the immediate area or are species that spend a considerable amount of their lifespan under the cover of objects or underground and are not subject to injury or contamination by herbicides. • Proposed treatment activities will occur within a limited time frame and geographical area. Positive effects to these species from the action alternatives include: • Long term beneficial effects from the removal of exotic vegetation that will be replaced by native species which provide improved habitat characteristics for this and other native animal and plant species. • Reducing habitat degradation within suitable habitat areas. Negative effects from the no action alternative include: • Continued establishment and spread of invasive species which compete with beneficial natives and associated increase of habitat degradation.

Warner Springs Shoulderband Snail Two-Striped Garter Snake Southwestern Pond Turtle Arroyo Chub Santa Ana Speckled Dace The Biological Evaluation determined that the proposed action will have no affect to the shoulderband snail, two-striped garter snake, arroyo chub, southwestern pond turtle and Santa Ana speckled dace. This determination is based upon the following conditions: • The Warner Springs Shoulderband snail occurs within a very limited area of the Cleveland National Forest that is not proposed for invasive weed species treatments. This species occurs within seasonally or permanent wet areas of springs and seeps that would not be treated with herbicides. • Arroyo chub and Santa Ana speckled dace populations are limited to a few locations on the Cleveland National Forest. • No native riparian vegetation will be destroyed or removed. • No herbicides will be utilized in aquatic habitat or surface waters and risk assessments showed no non-accidental exposure scenarios that would be a concern for these species. • Foot traffic within riparian areas will be limited due to the low density of invasive weed species typically occurring within riparian habitat. No temporary roads and or trails are being proposed. • Herbicide application will be prohibited within a 48 hour window prior to expected precipitation. Positive effects to these species from the action alternatives include: • Long term beneficial effects from the removal of exotic vegetation that will be replaced by native species which provide improved habitat characteristics for these and other native animal and plant species. • Reducing habitat degradation within suitable habitat areas. Negative effects from the no action alternative include:

Cleveland National Forest Invasive Weed Management EA 55 • Continued establishment and spread of invasive species which compete with beneficial natives and associated increase of habitat degradation.

Management Indicator Species (MIS) - Wildlife

Table 5 shows wildlife Management Indicator Species. The proposed action will have no direct, indirect or cumulative negative effects to any Management Indicator Species because no activities are proposed that would fragment, reduce, or negatively impact vegetation or habitat conditions for the identified and/or representative species.

The proposed action alternative would benefit all listed Management Indicator Species by improving habitat conditions through removal of invasive weed species, thus reducing or eliminating habitat competition, degradation and associated changes to natural processes such as hydrology and fire frequency.

Under the no action alternative, it is highly probable that several and possibly all identified Management Indicator Species could be indirectly and cumulatively negatively affected by the continued establishment and spread of invasive weed species (Table 5).

Table 5 MIS Effects from Preferred and No Action Alternatives.

Management Indicator Species Forest Plan Habitat Effects To Species Effects To Species from Indicator from Proposed No Action? Action? Mountain Lion Fragmentation No Yes Mule Deer Healthy diverse habitats Yes - Positive Yes Arroyo Toad Aquatic habitat Yes- Positive Yes Song Sparrow Riparian habitat Yes- Positive Yes California Spotted Owl Montane Conifer Forest Yes- Positive Yes

3.4.3.1 Alternative 1: Proposed Action – Effects to Plants Direct and Indirect Effects to Native Vegetation

Herbicides are obviously designed to be toxic to plant life. However, herbicides vary in their ability to impact non-target plants through drift or in soil activity. Herbicide plant treatment may harm non-target plants, including culturally significant, and threatened, endangered, and sensitive plants. Non-target plants could be exposed to herbicide through herbicide drift or through runoff. Some damage to non-target plant individuals is probable despite cautious planning and implementation. The closer the non-target species is to the application site, the greater is the likelihood of damage.

Herbicide application effects to non-target plants (which include listed species) are analyzed in the herbicide risk assessments.

Exposure of non-target plants to herbicide may result in mortality to individuals, reduction of their productivity, or lead to abnormal growth patterns. The level and extent of damage to non- target plants depends on site-specific conditions, including wind speed, rainfall, and plant foliar

Cleveland National Forest Invasive Weed Management EA 56 interception. Susceptible species could be impacted by drift from 100 feet (typical Forest Service application rate—1 lb. a.e./acre (SERA, 2011c-triclopyr). Adverse effects would most likely be localized and short term, due to project design features such as doing cut and spray stump treatments, trimming or folding away susceptible vegetation, buffers, and instituting rain and wind speed restrictions for herbicide application.

Table 6 shows the herbicide specific risks to non-target plants. Imazapyr is the herbicide proposed for use with the most risk to non-target plants and native plant re-establishment. This is due to the fact that it is relatively persistent and mobile in the soil and remains active. Due to this fact, Imazapyr will not be applied within a distance of twice the drip line (canopy extent) of native riparian trees such as Coast Live Oaks and sycamores, cottonwoods and large willows. Imazapyr will also only be used in targeted spot treatments.

The two selective herbicides being proposed for use in this project (Fluazifop and Aminopyralid) may be broadcast sprayed over areas containing native vegetation in an attempt to control specific invasive weed species in those areas. These herbicides are likely to be directly applied to native species in these instances. • Fluazifop is a grass specific herbicide and may be used in restoration settings where native monocots including native perennial grasses may be present. Fluazifop is unlikely to directly impact non-grass monocots. It is not effective against sedges and can be applied overtop of ornamental crops in monocot families such as the onion and lily families. Native bulb/corm species likely to be present in these sites include Dichelostemma capitatum, and Sisyinchium bellum. Fluazifop will likely improve growing conditions for these species by removing non-native annual grasses.

Fluazifop has also been used to restore native perennial grass stands (Stipa pulchra) if the timing of application is done before native perennial grasses begin rapid spring growth (Bell et al 2013.) When significant native perennial grass species are present, application of fluazifop will occur early in the spring to specifically target only annual grass species.

Fluazifop is unlikely to have direct negative effects to native species if used as proposed.

• Aminopyralid is a selective herbicide that targets plants in the Asteraceae plant family. It may be used to treat certain thistle species, especially yellow starthistle. Yellow starthistle tends to form fairly monotypic stands, however there is a likelihood of native asteraceae species being present in and adjacent to target invasive weed stands. Surveys will be conducted to insure that no listed, or rare asteraceae species are within treatment areas. Care will be taken to not directly apply aminopyralid to susceptible native species. However, it is expected that some impacts to abundant native aster species may occur in very localized areas. For example, on Elsinore Peak there is an abundance of Tarweed (Deinandra fasciculata) growing in and around a yellow starthistle infestation. These plants are likely to be impacted by treatment of the yellow starthistle.

Direct effects on adjacent plant communities may occur as workers move throughout the project area. Native species may be stepped on and/or damaged. These effects would be temporary and can be reduced by using existing paths to access the project area. Direct effects on the riparian area include stepping on or physically damaging native riparian vegetation while treating non- natives and the killing and eradication of non-natives themselves, which would be a positive impact. Effects to non-target plants of manual treatments which will occur under this alternative are described under Alternative 2.

Cleveland National Forest Invasive Weed Management EA 57 Table 6. Highlighted specific toxicities to plants by herbicide.

Herbicide Toxicity to non-target plants

Nontarget species of dicots are likely to evidence adverse effects over the range of application rates (SERA 2007). Aminopyralid Aminopyralid also can impact some annual grasses and can act as a pre-emergent.

For relatively tolerant nontarget species of plants, there is no indication that glyphosate is likely to result in damage Glyphosate at distances as close as 25 feet from the application site. Nontarget terrestrial plants are not likely to be affected by runoff of glyphosate under any conditions (SERA 2011a).

Two forms of triclopyr could be used with differing degrees of effects. Triclopyr BEE (butoxyethyl ester) is more toxic to plants than triclopyr TEA (triethylamine salt). Triclopyr BEE formulations are more apt to damage Triclopyr plants from runoff than other formulations. Both formulations have been found to decrease the relative long-term abundance and diversity of lichens and bryophytes (SERA 2011c).

Damage to non-target plants can occur by being absorbed through roots (Tu et al. 2001) and by being transfered Imazapyr between root networks (SERA 2011b). Imazapyr can act as a pre-emergent herbicide, which could impact ungerminated native and nonnative plants.

The risk for non target terrestrial plants is indicated as low Fluazifop-b- with the application of mitigation measures such as spray buffers. (EFSA 2010) butyl

Cumulative Effects to Plants

Related activities to the proposed action include the limited removal and control efforts of invasive plant species on and adjacent to the Cleveland National Forest. Since the proposed action is not expected to have a significant negative effect on native plant populations or vegetation communities there are not expected to be any cumulative impacts from the proposed action. Invasive plant species control efforts on non-Forest Service lands has primarily involved the control and removal of arundo and tamarisk within the major riparian/stream drainages. The proposed action cumulatively benefits the project and surrounding areas by preventing the continued establishment and spread of invasive plant species on both Forest Service and surrounding lands. The proposed action will also assist in prevention and control of invasive

Cleveland National Forest Invasive Weed Management EA 58 plant species colonizing onto as well as from Forest Service lands. Proposed management activities for the control of invasive plant species are limited in both geographical area and only occur on an annual basis with a limited time period (> 5 yr. period).

3.4.3.2 Alternative 2: Continued Manual and Mechanical Weed Control Efforts with No Herbicides – Effects to Plants

Direct and Indirect Effects to Plants from Manual Removal Alternative

Manual removal on invasive weeds results in greater ground disturbance than herbicide alternatives. Digging and weed wrenching of root masses may damage adjacent native plants, and their root systems. Direct effects on adjacent plant communities may occur as workers move throughout the project area. Native species may be stepped on and/or damaged. These effects would be temporary and can be reduced by using existing paths to access the project area. Direct effects on the riparian area include stepping on or physically damaging native riparian vegetation while treating non-natives and the killing and eradication of non-natives themselves, which would be a positive impact.

The targeted nature of the weed removal activities and current limited distribution of weeds means that this alternative is not likely to have a significant or long term negative impact on native plants and vegetation communities.

Cumulative Effects to Plants from Manual Control Alternative

Related activities to the proposed action include the limited removal and control efforts of invasive plant species on and adjacent to the Cleveland National Forest. Since the proposed action is not expected to have a significant negative effect on native plant populations or vegetation communities there are not expected to be any cumulative impacts from the proposed action

3.4.3.3 Alternative 3: No Action – Effects to Plants

Direct and Indirect Effects to Plants from No Action Alternative

No direct effects would occur since no action is being taken. Indirect effects of this alternative are the increasing loss of habitat for native plants as invasive weed cover expands. Invasive weeds in the project area would continue to propagate and expand in cover. This would make resources such as space, sunlight, and water unavailable for plant species. Tamarisk and Arundo donax are highly flammable when dry and pose an increased threat of fire in riparian areas. Not treating infested areas also allows these species to spread and form new colonies downstream or in adjacent areas due to wind dispersal of seed. The short-term effect of this alternative is the maintenance of existing conditions with no effects on native vegetation due to disturbance from work crews or herbicides.

Cumulative Effects to Plants from No Action Alternative

Cleveland National Forest Invasive Weed Management EA 59 The cumulative effect of this alternative is that the loss of native plant habitat caused by conversion to invasives that would add to the loss of these threatened habitats in California. This would negatively affect native plant populations.

3.4.3.4 Impacts to Special Status Plant Species from all Alternatives:

Federally listed threatened or endangered species

The action alternatives are not expected to result in negative effects to the 14 federal or state listed plant species that may occur within the project area. Most of the listed plant species occurrences are well documented, are limited in range, and occur within specific habitat types that are not presently or expected to harbor invasive weed species. To avoid negative effects to listed plant species, all areas with known or potential occurrence of federally listed plant species will be pre-surveyed prior to any invasive weed treatment activities.

The Biological Assessment determined that the proposed Invasive Weed Management Plan action alternatives will have no negative effects to the 14 federal or state endangered or threatened plant species. This determination is based upon the following conditions: • Known threatened and endangered plant populations will be avoided during treatment activities. • Areas with known or potential endangered or threatened plant species populations will be pre-surveyed to document listed plant species locations. • Listed plant species occurrences are restricted to relatively small areas within the Cleveland National Forest. • No herbicide treatments will be conducted within 25’ of known listed plant species locations, except for Acanthomintha ilicifolia (San Diego Thorn-mint), where Fluazifop- b-butyl may be used to improve habitat conditions for the plant where it is being impacted by non-native annual grasses on Viejas Grade Road.

Positive effects to listed plant species from the action alternatives include: • Long term beneficial effects from the removal of exotic vegetation that will be replaced by native species which provide improved habitat characteristics for this and other native animal and plant species. • Reducing habitat degradation within suitable habitat areas.

Negative effects from the no action alternative include: • Continued establishment and spread of invasive species which compete with beneficial natives resulting in increased habitat degradation.

Regional Forester’s Sensitive Plant Species

The Biological Evaluation determined that the proposed Invasive Weed Management Plan may affect individuals but is not likely to result in a trend toward federal listing for Forest Service listed sensitive plant species. This determination is based upon the following conditions: • That some potential exists for individual plants to be harmed due to their previously unknown occurrence within the project area. • Known sensitive plant populations will be avoided during treatment activities.

Cleveland National Forest Invasive Weed Management EA 60 • Areas with known or potential sensitive plant species populations will be pre-surveyed to document listed plant species locations. • Listed plant species occurrences are restricted to relatively small areas within the Cleveland National Forest. • No herbicide treatments will be conducted within 25’ of sensitive plant species locations.

Positive effects to sensitive plant species from the action alternatives include: • Long term beneficial effects from the removal of exotic vegetation that will be replaced by native species which provide improved habitat characteristics for this and other native animal and plant species. • Reducing habitat degradation within suitable habitat areas.

Negative effects from the no action alternative include:

• Continued establishment and spread of invasive species which compete with beneficial natives resulting in increased habitat degradation.

Negative effects to both FS sensitive plant and animal species from the no action alternative include:

• Continued establishment and spread of invasive species which compete with beneficial natives resulting in increased habitat degradation. Under the No Action Alternative it is reasonable to assume that invasive weed species populations will continue to establish, increase and expand in range. Impacts associated with this will result in increased habitat degradation. Un-managed invasive weed populations may potentially result in significant negative impacts to habitat conditions including hydrology, plant species diversity and associated habitat suitability.

Management Indicator Species (MIS) - Plants

Table 7 shows plant Management Indicator Species. The proposed action will have no direct, indirect or cumulative negative effects to any Management Indicator Species because no activities are proposed that would fragment, reduce, or negatively impact vegetation or habitat conditions for the identified and/or representative species.

The proposed action alternative would benefit all listed Management Indicator Species by improving habitat conditions through removal of invasive weed species, thus reducing or eliminating habitat competition, degradation and associated changes to natural processes such as hydrology and fire frequency.

Under the no action alternative, it is highly probable that several and possibly all identified Management Indicator Species could be indirectly and cumulatively negatively affected by the continued establishment and spread of invasive weed species.

Table 7 MIS Effects from Preferred and No Action Alternatives.

Management Indicator Species Forest Plan Habitat Effects To Species Effects To Species from Indicator from Proposed No Action? Action? Engelmann Oak Oak regeneration Positive Negative

Cleveland National Forest Invasive Weed Management EA 61 Big Cone Douglas-Fir Big Cone Douglas-Fir Positive Negative Forest Coulter Pine Coulter Pine Forest Positive Negative California Black Oak California Black Oak Positive Negative Forest White Fir Montane Conifer Forest Positive Negative

3.5 Watershed Effects and Impacts to Water Quality

This section analyzes potential impacts to watershed function, and water quality from the proposed action. Some information about water quality is also contained in Section 3.3, Human Health and Safety, in regards to potential water contamination by herbicides.

A full analysis of impacts on key soils and hydrology issues from invasive weeds and proposed invasive weed treatments is found in the Watershed and Soils Specialist Report, found in the project record. This section presents a summary of the potential effects of the alternatives from this report. These potential effects include: Effects of invasive species on: • channel morphology. • flow and local water tables. • soil productivity. • fire recurrence intervals.

Effects of herbicides use: • On beneficial uses of water. • On water quality. • Toxicity in environment. • Migration to surface waters through runoff. • Migration to groundwater through infiltration. • On soil productivity.

Effects of manual weed removal activities: • On beneficial uses of water. • On water quality through sediment production.

3.5.1 Beneficial Uses The California Regional Water Quality Control Board, San Diego and Santa Ana Regions (SDRWQCB and SARWQCB) Basin Plans (California Water Quality Control Board, 1994) define beneficial uses of surface and groundwater on the Cleveland National Forest. The basin plans provide a listing of water quality standards for many substances, and lists streams and other water bodies which do not attain the water quality standards. The subwatersheds selected for analysis lie within the jurisdiction of the SDRWQCB. Beneficial uses across the CNF vary based on watershed. Beneficial uses in analysis subwatersheds are listed in Table 8 (A and B) and are taken from the San Diego Basin Plan (San Diego Regional Water Quality Control Board). Beneficial uses include: • Municipal and Domestic supply (MUN) o municipal or domestic use • Agricultural use (ARG)

Cleveland National Forest Invasive Weed Management EA 62 o waters are used for farming, horticulture or ranching. • Industrial Service Supply (IND) o waters are used for industrial activities that do not depend primarily on water quality. • Industrial Process Supply (PROC) o waters for industrial activities that depend primarily on water quality. • Ground Water Recharge (GWR) o waters are used for natural or artificial recharge of groundwater for purposes that may include, but are not limited to, future extraction, maintaining water quality or halting saltwater intrusion into freshwater aquifers • Freshwater Replenishment (FRSH) o water for natural or artificial maintenance of surface water quantity or quality. • Hydropower Generation (POW) o waters for hydropower generation. • Contact Water Recreation (REC-1) o waters are used for recreational activities involving body contact with water where ingestion of water is reasonably possible • Non-Contact Water Recreation (REC-2) o are used for recreational activities involving proximity to water, but not normally involving body contact with water where ingestion of water would be reasonably possible • Preservation of Biological Habitats of Special Significance (BIOL) o Waters that support designated areas or habitats, where the preservation or enhancement of natural resources requires special protection. • Warm Freshwater Habitat (WARM) o waters support warm-water ecosystems that may include, but are not limited to, preservation and enhancement of aquatic habitats, vegetation, fish and wildlife, including invertebrates • Cold Freshwater Habitat (COLD) o waters support cold-water ecosystems that may include, but are not limited to, preservations and enhancement of aquatic habitats, vegetation, fish and wildlife, including invertebrates. • Wildlife Habitat (WILD) o waters support wildlife habitats that may include, but are not limited to, the preservation and enhancement of vegetation and prey species used by waterfowl and other wildlife. • Rare, Threatened, or Endangered Species (RARE) o Waters that support habitats necessary for the survival and successful maintenance of plant or animal species established under state or federal law as rare, threatened or endangered. • Spawning, Reproduction, and/or Early Development (SPWN) o waters support high quality aquatic habitats necessary for reproduction and early development of fish and wildlife.

Cleveland National Forest Invasive Weed Management EA 63 Table 8 A and B: A) Beneficial uses of streams within analysis subwatersheds. Subwatershed Waterbody BENEFICIAL USES

MUN AGR IND PROC GWR FRSH POW REC1 REC2 BIOL WARM COLD WILD RARE SPWN Arroyo Seco Temecula I I I I I I I I I I I Creek Creek Boden Santa I I I I I I I I I I Canyon-Santa Ysabel Ysabel Creek Creek Canada San Luis I I I I I I I I I I Aguanga-San Rey River Luis Rey River Cedar Creek Cedar I I I I I I I I I Creek Conejos Creek Conejos I I I I I I I I I I Creek La Posta La Posta I I I I I I I I I I Creek Creek Lower Pine Pine Valley I I I I I I I I I I I Valley Creek Creek Middle Pine Pine Valley I I I I I I I I I I I Valley Creek Creek Morena Cottonwood I I I I I I I I I I I I Reservoir- Creek/ Cottonwood Hauser Creek Creek Morena I I I I I I I I I I I Creek Cottonwood I I I I I P I I I I I Creek Ritchie Creek- San Diego I I I I I I I I I San Diego River River Sutherland Black I I I I I I I I I I Lake-Santa Canyon Ysabel Creek Santa I I I I I I I I I I Ysabel Creek Witch I I I I I I I I I I Creek Upper Pine Pine Valley I I I I I I I I I I I Valley Creek Creek

Table 8B) Beneficial uses of water bodies within analysis subwatersheds. Subwatershed Waterbody BENEFICIAL USES

MUN AGR IND PROC GWR FRSH POW REC1 REC2 WARM COLD WILD RARE Sutherland Lake-Santa Sutherland Lake I I I I I I I I I I Ysabel Creek Lower Pine Valley/Morena Lake Barrett I I I I I I I I I I I Reservoir –Cottonwood Creek

Cleveland National Forest Invasive Weed Management EA 64 Morena Reservoir- Morena Reservoir I I I I I I I I I I I Cottonwood Creek Conejos Creek El Capitan I I I I I I I I I I Reservoir Arroyo Seco Creek Vail Lake I I I I I I I I I

3.5.2 Impaired streams and waterbodies

The State and Regional Water Boards assess water quality data for California's waters every two years to determine if they contain pollutants at levels that exceed protective water quality criteria and standards. There are several stream reaches within and downstream of the project area that are listed in California’s 2010 Integrated Report (Clean Water Act section 303(d)) 303(d) list of streams with impaired water quality (USEPA 2010). Table 9 is a list of the 303(d) list waters that are downstream or within areas of large to small weed infestation. As stated before, because these areas are expected to have the largest weed infestations compared to the rest of the forest, these areas would have the greatest potential for impacts from project activities. None of the streams on the Forest are listed as being impaired from pesticides.

Table 9 California 303(d) listing for waters near large to small invasive weed concentrations. Includes listed substance and drainage relation to potential treatments. Weed 303(d) listed Non-supported Spatial Relation to Subwatershed Listing Source infestation water Beneficial use weed infestation rating Municipal and Color Unknown Domestic supply Municipal and Manganese Unknown Domestic supply Municipal and pH Unknown Infestation located El Capitan Domestic supply Conejos Creek Small upstream of listed Lake Warm Urban waterbody. Phosphorous Freshwater runoff Habitat Warm Total Nitrogen Other Urban Freshwater as N runoff Habitat Infestation located Upper Pine Valley Pine Valley Municipal and Turbidity Unknown Small adjacent to 303d listed Creek River Domestic supply waters Warm Cottonwood Selenium Unknown Freshwater Infestation located Creek Lower Pine Valley Habitat upstream of listed Small-Sparse Creek Warm water Barrett Lake Selenium Unknown Freshwater Habitat Warm Cottonwood Selenium Unknown Freshwater Creek Infestation located Morena Reservoir- Habitat Large-Small adjacent to 303d listed Cottonwood Creek Warm waters Barrett Lake Selenium Unknown Freshwater Habitat Warm Infestation located Cottonwood La Posta Creek Selenium Unknown Freshwater Large-Sparse upstream of listed Creek Habitat waterbody

3.5.3 Environmental Consequences

Risk assessments for herbicides include the USDA FS GLEAMS modeling worksheets that have been developed by SERA for the Forest Service. GLEAMS modeling is used to make predictions about how

Cleveland National Forest Invasive Weed Management EA 65 much of the herbicides or their degradates may enter surface waters. GLEAMS modeling is an agricultural standard model to determine the effects of runoff after pesticide applications. The Risk Assessments try to predict how much herbicide would be introduced to surface water as a result of a modeled scenario where a 10 acre block of land is treated with herbicide adjacent and draining into a small stream or pond. This scenario is analyzed for a variety of soil conditions and rainfall rates. This scenario represents much greater and more concentrated application rates than are called for in this project.

3.5.3.1 Alternative 1: Proposed Action – Effects to Watersheds and Water Quality The potential direct and indirect effects for the various proposed treatments will be grouped into 1) herbicide treatments and 2) hand and mechanical treatments. It is likely that at any given treatment site a combination of the proposed treatments would be used.

Direct and Indirect Effects from Herbicides The use of herbicides within riparian areas is of great concern due to the potential for introduction of toxic chemicals into streams and potential subsequent effects to beneficial uses. Primary concerns related to toxicity that are discussed in this report are effects to water quality and soil productivity, including chemical risks, persistence in the environment, and mobility. Nearly all of the treatment areas are along stream channels and many of the invasive plant species grow along active channel banks or even within flowing streams. Thus, herbicides may be applied where they can quickly enter streams. Some of the streams in the project area are in narrow canyons with limited floodplains, where most of the invasive plant species grow. GLEAMS and Beneficial Uses GLEAMS modeling worksheets, developed by SERA for the Forest Service, were run for each of the proposed herbicides and are included in the project record. The model runs scenarios for toxicity to organisms (human, wildlife and plant) from the potential exposure to herbicides by contact or consumption of contaminated water through both the proposed use (non-accidental) and accidental (spills of herbicide) introducing herbicides to waters. Hazard quotients less than 1 are considered lower risk while hazard quotients greater than 1 are considered higher risk. The worksheets give the range and central value for the modeled hazard quotient. In the analysis below, the upper limit of the hazard quotient is used/referenced to reflect the greatest risk. The herbicide sethoxydim was used to model for fluazifop-p-butyl as there is not a worksheet available for fluazifop-p-butyl and sethoxydim has very similar environmental characteristics. To minimize risks to beneficial uses listed below, implementation will utilize design features and BMPs listed in the Proposed Action in Chapter 2. These practices will reduce risks of spills, transport of, transmission of, and exposure to herbicides. 1) Domestic and Municipal Water Supply: Potential risk to municipal and domestic water quality was determined by the results of water consumption from three scenarios: 1) from an accidental acute exposure, 2) from a non- accidental acute exposure, and 3) from chronic long term exposure. No non-accidental scenarios were shown to have the potential to impact this beneficial use for any of the proposed herbicides. For accidental exposures, glyphosate and triclopyr scored hazard quotients greater than 2 in scenario 1, accidental acute exposure to a child through water consumption. Imazapyr scored greater than 1 but less than 2. This scenario assumes immediate consumption of untreated contaminated water after spill. The design criteria will prevent the potential for spills of the magnitude modeled to occur. In scenario 3, modeling longer term exposures, none of the proposed herbicides were rated above 1. 2) Recreation Uses:

Cleveland National Forest Invasive Weed Management EA 66 Potential risk to recreational users is determined from the hazard quotients of exposure through water consumption and swimming. Water consumption is discussed above. None of the herbicides have hazard quotients above 1 in the swimming for one hour scenario. 3) Hydropower Generation, Industrial Process/Service Supply: The proposed herbicides are not estimated to have an effect on the following beneficial uses: hydropower generation, industrial process supply, or industrial service supply. 4) Agricultural use: All five herbicides score higher than 2 for use of contaminated irrigation water on herbicide sensitive plant species; however, only sethoxydim scores greater than 2 for use of contaminated irrigation water on herbicide tolerant species. The other four herbicides score less than 1 for use of contaminated irrigation water on herbicide tolerant species. This project will not be treating any areas near sources for irrigation waters and project design criteria will prevent the non-accidental contamination of water by any herbicides, so this beneficial use will not be affected. 5) Ground Water Recharge and Freshwater Replenishment While herbicides will not affect the quantity of water available for ground water recharge or freshwater replenishment, herbicides could affect the chemical water quality of surface and ground water. Direct spills, leaching and runoff would be the pathways for contamination. This scenario assumes application directly followed by a runoff producing storm. Glyphosate has very low mobility and has a hazard quotient score below 1 for both sensitive and tolerant plant species for exposures to contaminated runoff. The other four herbicides have hazard quotients that score above 2 for exposure of herbicide sensitive species to contaminated runoff. For exposure of herbicide tolerant species to contaminated runoff, imazapyr is the only herbicide that has a hazard quotient scoring above 1 and/or 2. This project will avoid application of herbicides within 48 hours of potential rainfall, so potential to impact non-target plants with contaminated runoff is low. 6) Aquatic Species, Mammals, Birds, and Habitat Detailed information on effects to wildlife and aquatic organisms can be found in the Section 3.4. No significant negative effects on this beneficial use are expected. Degradation and Environmental Characteristics. As discussed, there are several degradation pathways an herbicide may degrade through. Microbial degradation of the proposed herbicides is reliant on the combination of climate, soil, and herbicide characteristics. Soil moisture increases microbial activity and the rate of degradation of some herbicides, such as glyphosate and fluazifop-p-butyl. The soils in the analysis area tend to be well-drained to excessively drained. Although some herbicides degrade faster with higher soil moisture, the somewhat excessively drained and excessively drained soils transmit water quickly and as a result may have lower microbial activity, especially during warm, dry summers or periods of drought. The well-drained soils retain moisture longer and are expected to have higher microbial activity. Climate across the proposed treatment area tends to have warm, dry summers and cool, wet winters. It is expected that microbial activity will be highest in spring when there are increases in soil moisture and temperature. Dry years or periods of extended drought would be expected to have slower degradation rates as microbial activity would be limited.

Cleveland National Forest Invasive Weed Management EA 67 Adsorption of herbicides to soils can slow the degradation process and lead to persistence in the soil. Soils that are coarser grained and have lower organic matter percentages are less likely to retain herbicides through absorption. The majority of soils in the analysis areas tend to be coarser grained, so herbicides that form weaker bonds are less likely to adsorb and may be more readily metabolized by microbes. Overall, although the climate and soil conditions may reduce microbial degradation rates, the dry climate and sporadic precipitation will limit potential for transport events before at least partial degradation of the herbicide. BMPs, design features and label instructions will further reduce risks. Mobility and Environmental Factors Mobility of a given herbicide is reliant on the combination of climate, herbicide, and soil characteristics. The solubility and adsorption potential of the herbicide can affect risk of herbicide transport. However, the soil characteristics such as permeability and runoff can contribute to transport of herbicides to groundwater and/or surface waters. Climate can determine the likelihood of storm events and precipitation available to transport herbicides. The herbicides that have the highest potential for transport include imazapyr, triclopyr, and aminopyralid. Fluazifop-p-butyl and glyphosate tend to adsorb strongly to soils. Most of the soils in the analysis area have moderate to very rapid permeability which indicates that water moves quickly through the soil. The two major hydrologic soil types in the analysis area are types D and A. Group D tends to have increased runoff potential and shallower soils, which would increase risk of transport of herbicides. Group A, however, tends to be deeper with less runoff potential. The herbicides that have the highest potential for transport through runoff and leaching because of solubility or adsorption characteristics include imazapyr, triclopyr, and aminopyralid. Should these herbicides be transported it is important to note degradation pathways and rates. For example, although Triclopyr has potential to be transported off site because it is soluble and does not strongly bond to soils, triclopyr breaks down readily in both groundwater and surface water. Should aminopyralid or imazapyr be transported through runoff, sunlight breaks both down readily. Breakdown of aminopyralid without sunlight is much slower and imazapyr needs sunlight to broken down at all. Leaching potential should be low as herbicide applications will mostly occur during the dry season when there will be a lack of a wetting front to percolate the herbicides downward during the initial half-life. Fluazifop-p-butyl and glyphosate could still be transported off site via transport of sediments that the herbicide has adsorbed to. In general, less steep areas have lower risks of erosion. The highest concentration of invasive species tend to be in riparian and floodplain areas that are flatter than surrounding terrain but can be susceptible to flooding and transport.

Direct and Indirect Effects from Manual Treatments The non-herbicide treatments are analyzed together since the effects are primarily limited to the physical impacts of personnel entry. These techniques include hand pulling, weed wrenching or grubbing, mowing, chopping, and cutting. Hand pulling, weed wrenching or grubbing, mowing, chopping, and cutting have similar impacts to each other including ground disturbance due to foot traffic, creation of foot trails, and creating areas of bare, disturbed ground. Hand treatments typically require multiple entries, possibly several per year, increasing the potential for these effects. Sediment potential is slightly higher with hand pulling, weed wrenching, and grubbing because the action requires uprooting of the plant and increased soil disturbance. Cutting, mowing, and

Cleveland National Forest Invasive Weed Management EA 68 chopping would likely result in the least soil disturbance as they do not require uprooting of the plant. Areas of trampled or disturbed bare ground erode more readily than vegetated areas. Since most invasive species are relatively thin and scattered, it is anticipated that disturbed areas will be small and scattered so the overall impacts to soils and water quality would be negligible to minor. To minimize potential impacts to beneficial uses and water resources, applicable BMPs and design features would be implemented during project activities. Design features are listed under the proposed action in Chapter 2. Overall, the amount of soil disturbance generated by hand crews is expected to be negligible, very localized and short-term. To decrease potential impacts to water quality, BMPs and design features listed under mitigations would be followed. All the proposed treatments would be conducted by hand, requiring crews to make one to several entries into the treatment areas. Depending on the density of invasive plant species, the size of the field crews, and the number and timing of repeat entries, there could be negligible to minor risks of short-term, localized adverse impacts to soil and water quality due to trampling, soil disturbance, and erosion of bare soil. Use of herbicides has the potential for negligible to minor risks of short term, localized adverse effects on soil productivity and surface and ground water quality depending on quantities used and the characteristics of the herbicides and adjuvants used. Integration of design features, herbicide label instructions, and BMPs during implementation would minimize risks related to herbicides and project activities. Despite the short-term risk of negative effects, there would be long-term benefits to watershed and soil resources through the removal of invasive weeds and improvement of riparian habitat and hydrologic processes. Additionally, only a fraction of each subwatershed would be treated any given year reducing any risk of cumulative effects to soils, watershed resources, and beneficial uses.

Cumulative Watershed Effects Cumulative effects could result from federal and private land projects that remove vegetation and increase areas of bare ground subject to erosion and sediment transport to streams, or use herbicides or pesticides which could impact soil productivity and water quality, and from recent wildfires. The only other Forest Service activity currently proposing herbicide use in the project area is the Lake Morena Fuels Reduction project, which may use herbicide to reduce shrub cover in WUI threat zones. The herbicide treatments and potential effects from the proposed action would be scattered throughout the various sixth and seventh level subwatersheds that make up the analysis area. Herbicides could reach stream channels and could potentially be transported downstream to mainstems, reservoirs, and/or depositional reaches. Any detectable concentrations of herbicides reaching downstream reservoirs or watersources would be diluted to non-detectable concentrations at that point, so any potential risk of effects would end there. The risk of causing negative cumulative watershed effects from sediment is negligible. Sediment generated from project activities would not be detectable at the watershed scale nor would they contribute to a significant increase in soil disturbance. Any project related sediment would be diluted to non-detectable levels in downstream watersources, depositional areas, and reservoirs. The project would have beneficial effects for watershed resources as native species replace eradicated invasive weeds post-treatment. Any beneficial effects would not be detectable at the

Cleveland National Forest Invasive Weed Management EA 69 watershed scale as the actual acreage of treatment is small compared to the overall watershed acreage. Overall, the potential negative and beneficial cumulative effects of the proposed action activities would be negligible, localized, and short-term. The use of design features would minimize negative effects of erosion of bare ground and potential reduction in soil productivity. The removal of invasive plant species would result in beneficial effects of increase in soil productivity, improvements in local hydrologic processes, and a lower potential for decreases in water quantity when some invasive species, (e.g. tamarisk) are removed.

3.5.3.2 Alternative 2: Manual Removal Only – Effects to Watersheds and Water Quality In this alternative, more emphasis would be put on hand and mechanical treatments. Multiple entries would be necessary to accomplish project goals. Herbicides would not be used.

Direct and Indirect Effects The reliance on hand and mechanical treatments only would require additional crews and repeated entries to the treatment areas to implement the project. This would result in an increase in ground disturbance, trampling, and potential erosion from cleared areas proportional to the density of the invasive plant species. Additional sediment related to the increased ground disturbance could be transported to streams, somewhat increasing turbidity compared with Alternative 1. It is estimated that because Alternative 2 is more labor and time intensive than Alternative 1, Alternative 2 would take longer to treat impacted areas. The increased time frame and need for multiple entries could potentially delay the restoration process compared to Alternative 1. Since herbicides would not be used, there would be no other project related risks to water quality from this alternative. Following the design features pertaining to hand and mechanical treatments would be sufficient to minimize adverse effects for this alternative. This alternative would result in minor increases in soil disturbance and potential erosion over Alternative 1 because of the reliance on hand and mechanical treatment and potentially increased number of entries to fully treat infested areas. This could result in slight increases in turbidity in nearby streams. There is no potential for water quality impacts from herbicides in this alternative. This alternative would have negligible to minor, short-term, localized adverse impacts to soil and water quality and long-term beneficial effects. The short-term impacts would be physical (compaction, surface disturbance, bare areas) rather than chemical.

Cumulative Effects Cumulative effects would be the same as the trampling and potential erosion effects described in Alternative 1.

3.5.3.3 Alternative 3: No Action – Effects to Watersheds and Water Quality Under the No Action Alternative, no activities to control invasive species would occur. This alternative represents the existing conditions and future conditions if this project were not implemented, against which the other alternatives are compared.

Direct, Indirect, and Cumulative Effects Under this alternative, invasive species would continue to spread and increase occupation of riparian and other areas. Tamarisk, arundo, and fig are especially invasive and can rapidly form dense stands along stream channels and on floodplains.

Cleveland National Forest Invasive Weed Management EA 70 Tamarisk species have very long tap roots which can access shallow groundwater. Dense stands of tamarisk can reduce streamflow by direct water usage and by lowering groundwater levels. Arundo also forms dense stands and uses large volumes of water to support its rapid growth rates. Unimpeded growth of tamarisk and arundo could result in a decrease of stream flows, especially in smaller drainages (Muzika 2005, Benton 2005). Typical stream behavior in this area includes floods of various sizes which mobilize sediments and clear much of the vegetation from stream banks and floodplains. Dense stands of arundo or tamarisk can also affect stream morphology by unnaturally stabilizing stream banks, islands, sand bars, and floodplains. Tamarisk seeds and arundo roots can also be transported downstream during flood flows to colonize other areas. Water quality can be affected by these invasive plant species. A potential beneficial effect is that water temperature could be reduced as the increased shade from the invasive plant species provides shade. Tamarisk species have the ability to take up salts present in water and excrete it in their leaves. When these salts accumulate in soils beneath tamarisk stands, soil productivity is reduced and growth of other plant species is suppressed. These salts can also reach surface and groundwater through runoff or infiltration. Since there would be no treatment, there would be no potential impact to soils or water quality from herbicide use or multiple entries of personnel to remove invasive species. Many of the invasive plant species are highly flammable, especially tamarisk and arundo. As these species increase, they can affect the wildland fire regime by increasing fire severity and decreasing the return interval. This has adverse impacts in riparian areas which generally burn at lower fire severity than upland areas. Increased fire severity has negative impacts on soils including hydrophobicity (water repellency), which reduces infiltration, changes in soil structure, and destruction of soil biota. Following wildland fires, the first few years of rain would erode and transport ashes, nutrients, and sediments to the streams within the fire perimeter with a resultant decrease in water quality Allowing unimpeded spread of invasive species does not comply with the CNF Forest Plan or overall Forest Service direction. This alternative would result in the project area becoming further removed from the desired condition. Excluding wildland fire events, this alternative would result in long-term, adverse (reduction in water supply) and beneficial (maintenance of water quality) effects within riparian corridors. Including wildland fire effects, this alternative would result in adverse effects to water quality and quantity, soil structure, and the soil biological community. There are no mitigation measures or cumulative effects because there are no activities proposed for this alternative.

3.6 Heritage and Cultural Resources

3.6.1 Affected Environment

The Area of Potential Effects (APE) for the proposed project is limited to the mapped areas of invasives within the total proposed project planning area on the CNF. Portions of the proposed project planning area have been surveyed for cultural resources in support of previous projects on each of the Ranger Districts on the CNF. Previous survey has resulted in the identification and recordation of historic properties within the proposed project APE. However, previously surveyed areas within the proposed project APE account for a relatively small portion of the total APE of the proposed project and as yet unidentified and unrecorded historic properties may also exist within the proposed project APE. However, the proposed project APE is comprised primarily of riparian areas that are characterized by

Cleveland National Forest Invasive Weed Management EA 71 alluvial stream deposits that are low potential locations for the establishment or depositional retention of archaeological resources, and the presence of historic properties within the proposed project APE is relatively low. Cultural resources, particularly prehistoric archaeological deposits recorded in the vicinity of the proposed project APE are typically located on ridges, knolls, and elevated stream terraces that are not within the proposed project APE.

Certain classes of undertakings on Forest Service lands in Region 5 qualify as Screened Undertakings that are exempt from further review or consultation, as defined in Appendix A, and pursuant to Stipulation 7.1 of the Regional PA. Eradication or treatment of invasive plant species through the application of herbicides and manual treatments (including hand tools such as weed wrenches) fall within the description of Screened Undertakings that are exempt from further review or consultation. Specifically, part (g), (h), and (i) of Section 2.3 (Screened Undertakings (Class B) of Section 2.0 (Screened Undertakings (Class B Undertakings), of Appendix D (Exempt and Screened Undertakings), of the RPA states that: “(g) Applications of pesticides or herbicides that do not have the potential to affect access to or use of resources by Indians based on the nature of the undertaking or prior or current consultation with Indian tribes; (h) Activities limited within stream channels, not including terraces, cut banks, etc.; and (i) Activities that involve less than one cubic meter of cumulative ground disturbance per acre” qualify as Class B Screened Exemptions.

Impacts from the use of weed wrenches is similar in scale and extent to impacts from small hand spades, and the limited use of this tool falls within the definition of activities with little or no potential to adversely affect heritage resources. Based on this determination, no additional cultural resources survey or recordation is required prior to the implementation of the proposed project activities.

The proposed project APE may contain isolated individuals or small patches of plants that have a known cultural significance to Native Americans. Other culturally significant plants may be included within proposed treatment areas as well. Culturally significant plants are those that are typically collected and used as food, medicine, or for ceremonial purposes, or have been identified by Native Americans as important components of traditional practices. Table 1 contains a partial list of known culturally significant plants that may be found in the proposed treatment areas. The manual removal and specific herbicide application to the listed invasive plant species would not have an adverse effect on culturally significant plants, or to access or collection of these plants by Native Americans.

Table 10. Culturally Significant Plants Potentially Within the Proposed Project APE Common Name Scientific Name Basket Rush Juncus textilis Broadleaf Cattail Typha latifolia Bulrush Scirpus sp. Deer Grass Muhlenbergia rigens

3.6.2 Environmental Consequences

3.6.2.1 Alternative 1: Proposed Action

Direct, Indirect and Cumulative Effects Under this alternative, a combination of herbicidal and manual (hand tool) treatments would be applied to the targeted invasive species. As previously discussed, the application of herbicides and the use of hand tools for the eradication of invasive plant species would have no adverse effect on historic properties, in accord with the previously listed stipulations of the Regional PA.

Cleveland National Forest Invasive Weed Management EA 72

Although the list of herbicides proposed for treating invasive plant species are not designed to target plants desirable to Native Americans, the proposed herbicides have the potential to be applied to culturally significant plants, which is a concern for tribal groups that collect culturally significant plants for consumption or basketry purposes. Spot spraying and/or selective manual methods would be employed to limit unwanted spray drift onto culturally significant plants, if any. Limiting nozzle pressure and spray, and restricting herbicide application during high winds or expected precipitation would also serve to limit unwanted spray drift during broadcast application. However, this measure would not totally eliminate the potential for affecting culturally significant plants with herbicide. The CNF Heritage Program Manager (HPM) would coordinate with the CNF Invasive Weed Project implementation manager regarding the herbicide area planning and application implementation, and with tribal members that collect culturally significant plants in an effort to provide tribes with adequate information regarding the location and types of herbicide that would be implemented so that tribes could adjust their plant collection location and schedule in an effort to avoid collecting plants that may have been directly affected by herbicide application.

3.6.2.2 Alternative 2: Continued Manual and Mechanical Weed Control Efforts with No Herbicides

Direct, Indirect and Cumulative Effects

This alternative involves manual treatment only and would include no herbicide use. This alternative has already been analyzed and documented in a Decision Memo (CNF 2008). Manual treatment of invasive species would have no effect on historic properties, in accord with the previously listed stipulations of the Regional PA.

3.6.2.3 Alternative 3: No Action

Direct, Indirect and Cumulative Effects There would be no effect to historic properties under this alternative other than the natural processes that may already be occurring. However, the lack of any eradication treatments to invasive plant species could result in their proliferation competition with culturally significant plants. The potential exists for culturally significant plants to be negatively affected under Alternative 3.

3.7 Wilderness

3.7.1 Affected Environment

Targeted infestations occur in the San Mateo Canyon, Aqua Tibia, Pine Creek and Hauser Canyon Wilderness areas of the Cleveland National Forest which are managed in accordance with the Wilderness Act of 1984 in such a manner that ecosystems are unaffected by human manipulation and influences to the greatest extent possible so that plants and animals develop and respond to natural forces. Wilderness character in several of the subject areas is currently impacted by law enforcement activities involving the use of helicopters, as well as impacts from illegal immigration relating to unauthorized trails, litter and human waste.

The project area also includes the Recommended Wilderness (CNF) additions to Pine Creek, Hauser and Agua Tibia Wilderness Areas. In the CNF LMP, Recommended Wilderness is defined as: “land that the Forest Service is recommending to Congress for wilderness designation and will be managed in the

Cleveland National Forest Invasive Weed Management EA 73 same manner as existing wilderness so that the wilderness attributes of the area are retained until Congress passes legislation, or the area is released from consideration.”

The CNF is in the process of developing a Supplemental Environmental Impact Statement (SEIS) to analyze a proposed Land Management Plan (LMP) amendment which would designate additional areas of CNF as Recommended Wilderness. These include the Barker, Caliente and Eagle Peak Complex.

The use of mechanized equipment is generally prohibited in federally designated wilderness areas, “... except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act...( The Wilderness Act, 1964)” For the Cleveland National Forest, the R5 Regional Forester has the authority to authorize the use of mechanized equipment in Forest Service wilderness areas in certain situations. The use of herbicides in wilderness also requires R5 Regional Forester approval. The approval considers the relative impact of the activity (in this case herbicide use) on wilderness characteristics and weighs that impact against consideration of necessity, safety, potential alternatives, and cost effectiveness.

In order to receive approval the agency administrator must go through the Minimum Requirements Decision Guide (MRDG) process, which documents the necessity for the prohibited action in relation to the requirements for the administration of the wilderness area. In addition, for herbicide use approval, a Pesticide Use Proposal (PUP) is also prepared. This process also explores alternatives to the prohibited action. In the case of invasive weed removal activities, the Forest Service will have to also consider whether project goals could be accomplished using manual removal methods with non-powered hand tools. Trade-offs in terms of project success, cost effectiveness, and duration of the project will be considered before an approval for can be made.

The MRDG and PUP process will be completed after receiving comments to this Environmental Assessment and before a decision is made.

3.7.2 Environmental Consequences

3.7.2.1 Alternative 1: Proposed Action

Direct and Indirect Effects Invasive weed control activities as described for Alternative 1 are expected to have limited, intermittent and very short-term negative effects on Wilderness and Recommended Wilderness within the project area. The primary impacts would be activity from work crews travelling through areas and potentially using chainsaws if approved.

The proposed action, including herbicide treatment, is designed to protect the wilderness character of the Wilderness Areas proposed for treatment. Invasive plants detract from the natural beauty and naturally functioning ecosystems that are supposed to be represented in wilderness. Treatment and restoration activities are intended to reduce or eliminate the effect of invasive weeds in wilderness areas and help make native plant communities within wilderness more resilient to the effects of wildfire.

Some visitors may believe their wilderness experience is degraded when work crews are seen on the trail or at treatment areas in the wilderness. These temporary adverse impacts would vary depending upon the treatment method. Design features are included to limit work crew presence during high use times (e.g. weekends, holidays) and to inform wilderness users about the purpose and need to manage invasive plants inside wilderness. While there are temporary effects in

Cleveland National Forest Invasive Weed Management EA 74 wilderness using all treatment methods, in the long-term wilderness character and experiences would be enhanced and are best protected with this alternative.

Herbicide use, as with the other treatment methods, involves a temporary intrusion into the wilderness. It generally requires no ground disturbance, and individual plants are treated in minutes (dependent on size) and, generally, with a higher degree of effectiveness. Depending on the invasive plant species and size, repeat treatments in the wilderness with herbicide are expected to range between 10 to 20 percent. All of the herbicides proposed eventually break down completely in the environment, so herbicide residues will not persist in Wilderness environments.

Access into some of the remote wilderness areas is difficult and beyond a practical distance to hike in and out each day. Trails into some areas do not accommodate equestrian access, and other areas do not have existing trails. Remote areas may require temporary overnight stays. This could include the transport of equipment such as tents, sanitary facilities, cooking equipment, tools and equipment to support temporary crews.

With the use of herbicides, alternative 1 would require briefer stays and fewer overnight trips into the wildernesses when compared with alternative 3. This is because the ability to use herbicides in combination with other treatment methods would require less time (e.g. physical activities of digging out the root systems versus cutting and spraying or daubing), and herbicides are generally more effective than solely using manual and mechanical treatment methods. Adverse impacts with these design features would be low.

This alternative would have no effect on the undeveloped character of Wildernesses Conservation use would be protected by reducing the level of invasive plant interference with growth of native vegetation in riparian areas and degradation of habitat for native fish and wildlife species.

Cumulative Effects

Wilderness areas on the Cleveland National Forest are impacted by a variety of stressors associated with their proximity to major urban areas and the international border. Pine Creek and Hauser Wilderness areas are impacted by immigrant foot traffic, trash and law enforcement activities.

In addition to invasive weed control, the Cleveland National Forest may also be conducted feral pig eradication activities in Wilderness and Recommended Wilderness on the Forest during the same timeframes.

The Proposed Action may add to these impacts. However, these impacts will remain short term and temporary in nature and are not expected to cumulatively add to degradation of the Wilderness character in these areas.

3.7.2.2 Alternative 2: Continued Manual and Mechanical Weed Control Efforts with No Herbicides

Direct and Indirect Effects Invasive weed control activities as described for Alternative 2 are expected to have limited, intermittent and very short-term negative effects on Wilderness and Recommended Wilderness within the project area. The primary impacts would be activity from work crews travelling

Cleveland National Forest Invasive Weed Management EA 75 through areas. Powertools will not be utilized in Wilderness Areas. This alternative will also create more visible disturbance of vegetation and soil than the Proposed Action due to the need to dig or wrench out root masses of certain target plants.

Like the Proposed Action, this alternative may necessitate overnight stays in Wilderness by work crews. These stays would be expected to be longer than the Proposed Action due to the more labor intensive nature of the work to be performed.

This Alternative is also designed to protect the wilderness character of the Wilderness Areas proposed for treatment. Invasive plants detract from the natural beauty and naturally functioning ecosystems that are supposed to be represented in wilderness. Treatment and restoration activities are intended to reduce or eliminate the effect of invasive weeds in wilderness areas and help make native plant communities within wilderness more resilient to the effects of wildfire.

This alternative would have no effect on the undeveloped character of Wildernesses Conservation use would be protected by reducing the level of invasive plant interference with growth of native vegetation in riparian areas and degradation of habitat for native fish and wildlife species.

Cumulative Effects:

Cumulative impacts are similar to the Proposed Action except that worker presence in Wilderness areas is expected to be greater under this alternative due to the more time intensive nature of the work required.

3.7.2.3 Alternative 3: No Action

Direct, Indirect and Cumulative Effects

Under this alternative, there would be no impacts to Wilderness character from work crews, vegetation disturbance or herbicide application.

Impacts to natural processes in Wilderness as a result of invasive weed species would continue and is expected to increase under this alternative. Common disturbances in Wilderness, such as wildfire, could result in rapid expansion of invasive weed populations in Wilderness Areas, essentially replacing native plant communities in some locations.

Cleveland National Forest Invasive Weed Management EA 76 CHAPTER 4 Consultation and Coordination and References

The Forest Service consulted the following individuals, Federal, State, and local agencies, tribes and non-Forest Service persons during the development of this environmental assessment:

4.1. Interdisciplinary Team Members

Lance Criley, ID Team Leader, CNF Jeff Wells, Wildlife Biologist, CNF Kirsten Winter, Forest Biologist, CNF Steve Harvey, Heritage and Cultural Resources Program Manager, CNF Emily Fudge, Watershed Specialist, CNF Jeff Heys, Environmental Coordinator, CNF

4.1.3 Federal, State and Local Agencies

US Fish and Wildlife Service

4.1.4 Tribes

Tribes with Indian Reservations located within or in proximity to the project area were solicited for comments in the development of this environmental assessment.

4.1.5 Others

The Nature Conservancy

4.2. References Cited

Bakke, David 2007. Analysis of Issues Surrounding the Use of Spray Adjuvants With Herbicides. Written December 2002, revised 2007. Can be found online at http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_045552.pdf

Bell, Carl E. 1997. Ecology and management of Arundo donax, and approaches to riparian habitat restoration in Southern California. In Brock, J. H., Wade, M., Pysek, P., and Green, D. (Eds.): Plant Invasions: Studies from North America and Europe. Blackhuys Publishers, Leiden, The Netherlands, pp. 103-113.

Bell, Carl E. 2011. Giant Reed (Arundo donax L.) response to glyphosate and imazapyr. Journal of Aquatic Plant Management 49:111-113

Bell, C.E., J. Ekhoff and M. Witter. 2013. Herbicides as a tool for rescuing the California State Grass, Stipa Pulchra. Grasslands Fall 2013, pgs 5-11.

Cleveland National Forest Invasive Weed Management EA 77 Benton, Nancy, Gary Bell, Jil M. Swearingen. May 20, 2005. Fact Sheet: Giant Reed. Plant Conservation Alliance’s Alien Plant Working Group. http://www.nps.gov/plants/ALIEN/fact/ardo1.htm

Cal-IPC 2012. Preventing the Spread of Invasive Plants: Best Management Practices for Land Managers, 3rd Edition. Cal-IPC Publication 2012-03. California Invasive Plant Council, Berkeley, CA. Available at www.cal-ipc.org

Carpenter, Alan T 1998, Elemental Stewardship Abstract for Tamarix spp. The Nature Conservancy, Arlington VA. URL: http://www.imapinvasives.org/GIST/ESA/esapages/tamaramo.html

Duncan, Celestine L. and Janet K. Clark, Editors 2005. Invasive Plants of Range and Wildlands and Their Environemntal, Economic, and Societal Impacts. Weed Science Society of America, Lawrence KS

ESFA – European Food Safety Authority. 2010. Conclusion on the peer review of the pesticide risk assessment of the active substance fluazifop-P (evaluated variant fluazifop-P-butyl). EFSA Journal 2010;8(11):1905

Health Canada 2012. Fluazifop-P-butyl Re-evaulation Decision. Health Canada Pest Management Regulatory Agency. April 23, 2012

Hoshovsky, Marc 1986, Elemental Stewardship Abstract for Giant Reed. The Nature Conservancy, Arlington VA. Available http://www.invasive.org/gist/esadocs/documnts/arundon.pdf

Keeley, JE, TJ Brennan. 2012. Fire-driven alien invasion in a fire-adapted ecosystem. Oecologia 69(4): 1043-1052. doi: 10.1007/s00442-012-2283-8

McDaniel, Kirk C, Joseph M DiTomaso, Celestine A. Duncan, 2004. Tamarisk or Saltcedar, Tamarisk spp. In “Invasive Plants of Range & Wildlands and Their Environmental, Economic, and Societal Impacts”, Weed Science Society of America. Available: http://nmdaweb.nmsu.edu/DIVISIONS/APR/TAMARISK/McDaniel%20et%20al.SC.pdf

Muzika, Rose-Marie and Jil M. Swearingen. May 20, 2005. Fact Sheet: Saltcedar. Plant Conservation Alliance’s Alien Plant Working Group. http://www.nps.gov/plants/ALIEN/fact/tama1.htm SERA - Syracuse Environmental Research Associates, Inc. 1997. Effects of Surfactants on the Toxicity of Glyphosate, with Specific Reference to RODEO. Final Report. February 6, 1997. Syracuse, NY. Prepared for the Animal and Plant Health Inspection Service (APHIS). Available at: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml

SERA - Syracuse Environmental Research Associates, Inc. 2001. Sethoxydim [Poast] – Human Health and Ecological Risk Assessment. Final Report. October 31st, 2001. Fayetteville, NY. Prepared for the United States Forest Service, Forest Health Protection, Arlington, VA Available at: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml

SERA - Syracuse Environmental Research Associates, Inc. 2007. Aminopyralid –Human Health and Ecological Risk Assessments. Final report. June 28, 2007. Fayetteville, NY. Prepared for the United States Forest Service, Forest Health Protection, Arlington, VA. Available: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml

SERA - Syracuse Environmental Research Associates, Inc. 2011a. Glyohosate –Human Health and Ecological Risk Assessments. Final report. March 25, 2011. Manlius, NY. Prepared for the United

Cleveland National Forest Invasive Weed Management EA 78 States Forest Service, Forest Health Protection, Arlington, VA. Available: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml

SERA - Syracuse Environmental Research Associates, Inc. 2011b. Imazapyr –Human Health and Ecological Risk Assessments. Final report. Dec 16, 2011. Manlius, NY. Prepared for the United States Forest Service, Forest Health Protection, Arlington, VA. Available: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml

SERA - Syracuse Environmental Research Associates, Inc. 2011c Triclopyr –Human Health and Ecological Risk Assessments. Final report. May 24, 2011. Manlius, NY. Prepared for the United States Forest Service, Forest Health Protection, Arlington, VA. Available: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml

Tamarisk Coalition, 2005. New Mexico Options for Non-Native Phreatophyte Control. Prepared for the New Mexico Non-Native Phreatophyte/Watershed Interagency Workgroup. URL: http://www.nmda.nmsu.edu/wp-content/uploads/2012/06/2005_nmnpwmp.pdf

TAIC. 2005. Technology Associates International Corporation, Biological Assessment for Cottonwood Creek Invasive Species Removal Project, prepared for County of San Diego, Department of Public Works, September 26th, 2005.

Tu, Mandy, Callie Hurd, John M. Randall. 2001. Weed control methods handbook: Tools & Techniques for Use in Natural Areas. Version April 2001 (Some chapters updated in 2003 and 2004). The Nature Conservancy. URL: http://www.invasive.org/gist/handbook.html

UC-IPM 2007. Yellow Starthistle, Intergrated Pest Management for Home Gardeners and Landscape Professionals. University of California, IPM Online. Available online at www.ipm.ucdavis.edu

USDA Forest Service. 2005. Cleveland National Forest Land Management Plan. Pacific Southwest Region. Vallejo, CA. URL: http://www.fs.usda.gov/main/cleveland/landmanagement/planning

USDA Forest Service. 2007. Forest Service National Strategic Plan FY 2007-2012. FS-880. Washington DC. URL: http://www.fs.fed.us/publications/strategic/fs-sp-fy07-12.pdf

USDA Forest Service. 2013. Forest Service National Strategic Framework for Invasive Species Management. FS-1017. Washington DC. URL: http://www.fs.fed.us/foresthealth/publications/Framework_for_Invasive_Species_FS-1017.pdf

USDA Forest Service 2014a. Unpublished Document. Cleveland National Forest Invasive Weed Management - Worksheet for Glyphosate (3lbs/acre, Directed Backpack Foliar). Prepared by Lance Criley using SERA WorksheetMaker Version 6.00.10. In project record.

USDA Forest Service 2014a. Unpublished Document. Cleveland National Forest Invasive Weed Management - Worksheet for Triclopyr BEE (2lbs/acre, Directed Backpack Foliar). Prepared by Lance Criley using SERA WorksheetMaker Version 6.00.10. In project record.

USDA Forest Service 2008. Botany Biological Assessment/Biological Evaluation for Mechanical and Chemical Weed Treatments of Riparian Weed Species in Western-facing Canyons of the Trabuco Ranger District. Prepared by Lisa Young, Forest Botanist, for the Trabuco Ranger District

Cleveland National Forest Invasive Weed Management EA 79 USDA Forest Service 2009a. Wildlife Biological Evaluation for Trabuco District Riparian Invasive Removal Project, Cleveland National Forest. Prepared by Mary L. Thomas, District Wildlife Biologist, for the Trabuco Ranger District

USDA Forest Service 2009b. Wildlife Biological Assessment for Trabuco District Riparian Invasive Removal Project, Cleveland National Forest. Prepared by Mary L. Thomas, District Wildlife Biologist, for the Trabuco Ranger District

USDA Forest Service 2009c. Management Indicator Species Report for Trabuco District Riparian Invasive Removal Project, Cleveland National Forest. Prepared by Mary L. Thomas, District Wildlife Biologist, for the Trabuco Ranger District

USDA Forest Service 2009d. Biological Assessment for Steelhead Trout for Trabuco District Riparian Invasive Removal Project, Cleveland National Forest. Prepared by Mary L. Thomas, District Wildlife Biologist, for the Trabuco Ranger District

USDA Soil Conservation Service. 1973. Soil Survey, San Diego Area, California. USDA Soil Conservation Service and USDA Forest Service. Parts I and II plus maps.

US-EPA United States Environmental Protection Agency 2005. Report of the Food Quality Protection Act (FQPA) Tolerance Reassessment Progress and Risk Management Decision (TRED) for Fluazifop-P- butyl. EPA 738-R-05-005 September 2005

US-EPA United States Environmental Protection Agency 2007. Risks of Imazapyr Use to the Federally Listed California Red Legged Frog. Appendix A: Environemental Fate of Imazapyr and Imazapyr Transformation Products. Environmental Fate and Effects Division, Office of Pesticide Programs July 20, 2007 URL: http://www.epa.gov/oppfead1/endanger/litstatus/effects/redleg-frog/imazapyr/appendix- a.pdf

Vilà, M., Espinar, J. L., Hejda, M., Hulme, P. E., Jarošík, V., Maron, J. L., Pergl, J., Schaffner, U., Sun, Y. and Pyšek, P. 2011. Ecological impacts of invasive alien plants: a meta-analysis of their effects on species, communities and ecosystems. Ecology Letters, 14: 702–708. doi: 10.1111/j.1461- 0248.2011.01628.x

Weed Control Manual, Vol. 32. 1999. Meister Publishing Company. Willoughby, OH.

Zouhar, Kris 2003. Tamarix spp. In: Fire Effects Information System, [Online]. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory (Producer). Available: http://www.fs.fed.us/database/feis/

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Appendix A: Maps

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Appendix B: Response to Comments

Comments Received To Initial Scoping Letter and SOPA listing:

Letter from Orange County Chapter of the California Native Plant Society:

Comment 1 - Suggestions for clarifying common and scientific names for listed taxa and presenting species lists.

Response 1 - Changes were implemented in the EA.

Comment 2 – When comparatively small populations of Priority 3 species are controlled, there is a high probability they will reinvade. Consider a project area wide approach to controlling these species.

Response 2 – Priority 3 species will be controlled in specific restoration settings. The goal would be to aid in the reestablishment of native species in specific locations (for example, in coastal sage scrub restoration projects). The idea is that once native species are reestablished and vigorous, they will be able to occupy growing space in areas. It is unlikely, nor is it the goal, to completely remove priority 3 species from these sites. Priority 3 species are not possible to control at District wide or Forestwide scales due to limited resources and the fact that no methods have proven effective for controlling these species at these scales. The Forest does implement Integrated Pest Management practices to limit and lessen the impact of these species on native vegetation and habitats (See Section 2.3).

Comment 3 – Assure no Asteraceous species are within treatment areas using Aminopyralid.

Response 3 – The Proposed Action contains design criteria limiting herbicide use near certain special status plant species. Aminopyralid is most likely to be used in areas infested with Yellow Star Thistle. It is unlikely that significant populations of native Asters will be present in the midst of dense Yellow Starthistle infestations.

Comment 4 – Assure no native monocot species are within treatment areas using fluazifop.

Response 4 – The Proposed Action contains design criteria limiting herbicide use near certain special status plant species. Fluazifop is most likely to be used in areas dominated by non-native annual grasses in restoration settings, or in improving growing conditions for sensitive or endangered dicot plant species. Therefore it is unlikely to be used in areas with significant native grass or other monocots. Application will be focused using backpack type sprayers.

Comment 5 – Try painting or dripping herbicide from squeeze bottle in cut stump treatments as opposed to spraying.

Response 5 – Cut stump treatments may utilize these methods in many situations (See Section 2.3). In addition, spraying of cut stumps will be accomplished with backpack sprayers using nozzles specifically designed for such applications to limit spray drift.

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Comment 6 – When treating Cortaderia spp., seed heads should be bagged and taken offsite.

Response 6 – This has been added to the proposed action.

Email from Dick Artley, Grangeville, Idaho:

Comment 1 – States that glyphosate use should be reconsidered due to the belief it is carcinogenic.

Response 1 – The United Stated EPA considers glyphosate to be in “Group E” – no evidence of human carcinogenicity (SERA 2011a). The potential human health impacts of the proposed action are analyzed in section 3.3 of this EA.

Comment 2 – Commenter asks that proposed action only use herbicides that are safe and that safety can only be determined by independent, unbiased scientists.

Response 2 – The EA relies on Risk Assessments for each herbicide proposed for use to determine if their use would be safe as proposed. The Risk Assessment consists of exhaustive reviews of all literature about each chemical being proposed.

Letter from San Diego Archeological Society

Comment 1 - The EA needs to address the potential for impacts to cultural resources.

Response 1 – The analysis about impacts to cultural resources is found in Section 3.6 of the EA.

Comment 2 - The EA should include mitigation measures, as appropriate, including data recovery, site recordation, and activities up to and including curation in accordance with 36CFR79.

Response 2 - The Area of Potential Effects (APE) for the proposed Invasive Weed Management project is limited to the mapped areas of invasive plants within the total proposed project planning area on the Cleveland National Forest (CNF). There will be no construction or use of new access roads or staging areas associated with the proposed project. All portions of the APE are accessible from existing access roads and/or will be accessed by foot, and there will be no staging of equipment outside of existing access roads and parking areas. Portions of the proposed project planning area have been surveyed for cultural resources in support of previous projects on each of the Ranger Districts on the CNF. Previous survey has resulted in the identification and recordation of historic properties within the proposed project APE. However, previously surveyed areas within the proposed project APE account for only a portion of the total APE of the proposed project and as yet unidentified and unrecorded historic properties may also exist within the unsurveyed portions of the proposed project APE. However, the proposed project APE is comprised primarily of riparian areas that are characterized by alluvial stream deposits that are low potential locations for the establishment or depositional retention of archaeological resources, and the presence of historic properties within the proposed project APE is relatively low. Cultural resources, particularly prehistoric archaeological deposits recorded in the vicinity

Cleveland National Forest Invasive Weed Management EA 86 of the proposed project APE are typically located on ridges, knolls, and elevated stream terraces that are not within the proposed project APE.

Certain classes of undertakings on Forest Service lands in Region 5 qualify as Screened Undertakings that are exempt from further heritage program review or SHPO consultation, as defined in Appendix A, and pursuant to Stipulation 7.1 of the Programmatic Agreement among the U.S.D.A. Forest Service, Pacific Southwest Region (Region 5), the California State Historic Preservation Officer, the Nevada State Historic Preservation Officer, and the Advisory Council on Historic Preservation Regarding Processes for Compliance with Section 106 of the National Historic Preservation Act for Management of Historic Properties by the National Forest of the Pacific Southwest Region (Regional PA 2013). Eradication or treatment of invasive plant species through the application of herbicides and manual treatments (including hand tools such as weed wrenches) fall within the description of Screened Undertakings that are exempt from further review or consultation. Specifically, part (g), (h), and (i) of Section 2.3 (Screened Undertakings (Class B) of Section 2.0 (Screened Undertakings (Class B Undertakings), of Appendix D (Exempt and Screened Undertakings), of the RPA states that: “(g) Applications of pesticides or herbicides that do not have the potential to affect access to or use of resources by Indians based on the nature of the undertaking or prior or current consultation with Indian tribes; (h) Activities limited within stream channels, not including terraces, cut banks, etc.; and (i) Activities that involve less than one cubic meter of cumulative ground disturbance per acre” qualify as Class B Screened Exemptions.

Impacts from the use of weed wrenches is similar in scale and extent to impacts from small hand spades and will not involve more than one cubic meter of cumulative ground disturbance per acre within the proposed project APE. The limited use of this tool falls within the definition of activities with little or no potential to adversely affect heritage resources. Based on this determination, no additional cultural resources survey or recordation is required prior to the implementation of the proposed project activities, as there would be no effect to historic properties associated with the implementation of the proposed project.

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Comments Received To Draft Environmental Assessment:

Letter from Orange County Chapter of the California Native Plant Society:

Comment 1 - . Formatting comments. “Table 1,Control methods...,would be easier to follow if it were formatted to repeat its header row on each of its multiple pages. 2. Table 2, Priority 3 Species, is an improvement over the previous long text list, however it would be even more useful if the species were listed alphabetically by scientific name within each category.”

Response 1 – These changes are implemented in the Final EA.

Comment 2 – Commenter remains concerned that native plant species will be harmed while treating with the selective herbicides aminopyralid and fluazifop since these will likely be applied over some native species to select out target invasive weeds. Examples include native asteraceous species growing in and around yellow starthistle infestations and native bulb forming monocots growing in areas treated for non-native annual grasses. The commenter requests that extra measures be taken to locate and avoid all native species during treatments.

Response 2 – Fluazifop - More detail was added to the Final EA about the specific toxicity of Fluazifop in section 3.4.3.1. Fluazifop is a grass specific herbicide and is labeled to be applied over top of bulb forming ornamentals, such as plants in the lily and onion families. It is unlikely to harm native non-grass monocots growing in application areas. A design criteria was added regarding use of fluazifop where there are native perennial grasses present (such as Stipa pulchra). Studies shown that proper timing of fluazifop applications to treat non-native annual grasses can leave native perennials unharmed and help increase their relative ground cover. A citation to this study was added to the final EA (Bell 2013).

For aminopyralid, the Forest Service agrees that in some cases native asteraceous species may be harmed. More discussion and disclosure of this effect was added to Section 3.4.3.1 of the final EA. A design criteria was added to ensure that treatment areas are surveyed for potentially rare or limited distribution asteraceous species in areas proposed for treatment with aminopyralid and that care will be taken to limit exposure of native species to the herbicide. However, the Forest Service believes that harm to a few individuals of very common native species may be a necessary trade-off to remove yellow starthistle and other invasive thistle species from particular areas and that overall native plant population health will be improved.

Cleveland National Forest Invasive Weed Management EA 88

Letter from Dick Artley:

Comment 1 – (Listed as comment 1 in the letter and also in a section of requested changes to the EA) Wants information about alternatives to herbicides included in the EA and why these alternatives were not selected in lieu of herbicides, including information about cost differences and effectiveness differences.

Response 1 – This information was already included in the EA. The EA analyzed a complete non-herbicide alternative. Estimates of the relative effectiveness of the alternatives and differences in the amount of acres that could be treated between alternatives (due to costs and time) were included. The Cleveland National Forest has experience conducting invasive weed removal both manually and with herbicides. Lessons learned from these experiences were included in the EA.

Comment 2 – (Listed in section of requested changes to EA) “Include a disclosure in Chapter 3 that there is scientific disagreement about the safety of herbicides containing glyphosate. This would discuss the fact that research conducted by independent Ph.D. chemists indicates exposure to glyphosate-containing herbicides may cause major health problems in birds, fish and mammals (including humans … especially in children)”

Response 2 – In Chapter 3 of the EA there is already a statement about the use of the SERA Risk Assessments to help the decision maker, “rectify the often contradictory information about herbicides that can be found online and help make potential impacts of herbicide use in Forest Service projects more predictable.” However, the Forest Service disagrees that there is a significant scientific disagreement about the effects of glyphosate in the context we are proposing to use them here. The Forest Service also disagrees that there is a strong scientific case that exposures to glyphosate in the formulations and rates that we are proposing will cause any health problems in birds, fish and mammals.

Comment 3 – (Listed as comment 2-7, attachment 9a, and request for changes to EA) The commenter asks the Forest Service to consider numerous articles (a mixture of web published articles and reports, journal articles and news pieces) presenting an opposing view about the toxicity of glyphosate.

Response 3 – The Forest Service reviewed the entire list of new citations. Most of the sources linked to opinion pieces, or to various interpretations of scientific data that was already considered in the SERA Risk Assessment published in 2011. All journal articles mentioned that were published in peer reviewed scientific journals prior to 2011 were considered in the SERA Risk Assessment already. Many of the scientific papers mentioned were specifically about the toxic effects of the herbicide formulation RoundUp, which are attributable to the surfactant contained in the formulation. This project is not using RoundUp, nor any glyphosate formulation containing POEA based surfactants.

Three peer reviewed journal articles were referred to that were not included in the 2011 SERA Risk Assessment because they were recently published.

• Samsel and Seneff 2013, Glyphosate’s Suppression of Cytochrome P450 Enzymes and Amino Acid Biosynthesis by the Gut Microbiome: Pathways to Modern Diseases, Entropy 2013, 15(4) 1416-1463

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. The effect of glyphosate to P450 enzymes was considered in the SERA Risk Assessment. This particular article is a review of other research and does not present any new clinical or study data. The conclusions of this article have been widely rebutted , noting that much terminology used in the article occurs in no other publications.

• Jayasumana, Channa et al 2014, Glyphosate, Hard Water and Nephrotoxic Metals: Are They the Culprits Behind the Epidemic of Chronic Kidney Disease of Unknown Etiology in Sri Lanka? International Journal of Environmental Research and Public Health 2014, 11(2) 2125-2147

. This article presents a hypothesis and potential mechanisms for glyphosate interacting with heavy metals in water to cause kidney disease. The article presents no study or clinical data to test the hypothesis. The article is instead intended to promote further study. This project analyzed the impact of glyphosate use in an invasive weed treatment context. There is little chance that persons will ingest treated plant material, drink contaminated water, or any other exposure scenarios that may lead to adverse human health impacts.

• Majewski MS et al 2014, Pesticides in Mississippi air and rain: a comparison between 1995 and 2007. Environmental Toxicology and Chemistry 2014 Jun;33(6): 1283-93

. This article presents findings of detection of several pesticides in air and rain water along with changes in concentrations between 1995 and 2007. Glyphosate was not measured in 1995, but made up the majority of air and rain samples in 2007. This tracks with an increase in use due to the increase in GMO crop plantings that are resistant to glyphosate. Detections were made using highly sensitive measurements. Detections where measured in nanograms per cubic meter, rates far below any known to have a biological effect..

This project disclosed that glyphosate may drift or make it into water. The project analyzed these potential routes of exposure. This article brings no new information about potential exposures to glyphosate.

The rest of the listed citations were opinion pieces, or were about the effects of genetically engineered crops or legal actions taken by or against Monsanto. Several other links were to news pieces about potential bans to glyphosate or genetically engineered crops by foreign governments.

None of the included references added new scientific information about the actual toxicity of the proposed glyphosate formulations that would change the outcome of the analysis found in the Environmental Assessment.

ID team notes and additional information about how each reference was considered is contained in the project record.

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