Willow Sump Invasive Plant Project Environmental Assessment

United States Department of Willow Sump Invasive Plant Agriculture

Forest Service Project

Pacific Northwest Environmental Assessment

Region Umpqua National Forest North Umpqua Ranger District

March 2015

WILLOW SUMP INVASIVE PLANT PROJECT ENVIRONMENTAL ASSESSMENT

Douglas County Oregon

Lead Agency: USDA Forest Service, Umpqua National Forest Service

Responsible Official: Bill Mulholland, District Ranger North Umpqua Ranger District Umpqua National Forest 18782 North Umpqua Highway Glide, OR 97443 Phone: (541) 496-3532

For More Information Contact: Bryan Benz, Team Leader North Umpqua Ranger District 18782 North Umpqua Highway Glide, OR 97433 Phone: (541) 496-4169 Email: [email protected]

Abstract:

This Environmental Assessment (EA) documents one action alternative and the no action alternative for treatment activities within the Willow Sump Project Area, Adaptive Management Area of the Little River Watershed on the Umpqua National Forest, North Umpqua Ranger District. Alternative 2 has been identified as the preferred alternative.

Contents Willow Sump Invasive Plant Project ...... 1 Environmental Assessment ...... 1 Umpqua National Forest ...... 1 North Umpqua Ranger District ...... 1 January 2015 ...... 1 WILLOW SUMP INVASIVE PLANT PROJECT ...... 2 ENVIRONMENTAL ASSESSMENT ...... 2 Abstract: ...... 2 TABLES ...... 7 FIGURES ...... 8 CHAPTER 1 ...... 9 Purpose and Need for Action ...... 9 Project Location...... 9 Relationship to other Planning Documents and Analyses ...... 12 Need for Action ...... 13 Proposed Action ...... 13 Decisions to be made ...... 14 Scoping ...... 14 Project Implementation ...... 15 CHAPTER 2 ...... 16 Alternatives, Including the Proposed Action ...... 16 INTRODUCTION ...... 16 Alternatives Considered, But Eliminated From Detailed Study ...... 16 Alternative 1 – No Action ...... 17 Alternative 2 – Proposed Action ...... 17 Best Management Practices, Mitigation Measures, Project Design Features, and Monitoring ...... 17 Purpose Project Design Feature Source ...... 17 Pre-Project Planning – To ensure project is implemented appropriately ...... 18 To Prevent Spread of Invasives from Treatment Activities or Re-Introduction on a Treated Site .... 18 Field Operations / Worker Safety...... 18 3

Public Health / Public Notification ...... 20 To Protect Soils, Water Quality, Fisheries and Aquatic Organisms ...... 20 To Ensure the Protection of Threatened, Endangered, Sensitive (TES) or other Rare and Uncommon Plant Species ...... 21 To Ensure Protection of Heritage Resources ...... 21 To Protect Wildlife...... 21 CHAPTER 3 ...... 22 Affected Environment and Environmental Effects ...... 22 INTRODUCTION ...... 22 Treatment Assumptions and Scenarios ...... 22 Basis for Cumulative Effects Analysis ...... 23 Herbicides, Adjuvants, Surfactants and Inert Ingredients ...... 24 Herbicide Risk Assessments ...... 24 Incomplete or Unavailable Information ...... 25 Invasive Plants/Noxious Weeds ...... 25 Existing and Desired Conditions - Invasive Plants/Noxious Weeds ...... 25 Alternative 1- No-action Alternative...... 26 Alternative 2 – Proposed Action...... 26 Herbicide Risk Assessments ...... 27 Willow Sump EA Human Health Effects Analysis ...... 27 Human Health Impact Analysis (Worker and Public Exposure to Herbicide)...... 27 Effects of No Action to Human Health ...... 27 Effects of the Proposed Action to Human Health ...... 27 Botany ...... 29 Effects of Herbicides to Non-Target Vegetation ...... 29 Survey and Manage Botany Species ...... 30 Threatened, Endangered, and Sensitive Botany Species Biological Evaluation ...... 30 Pre-field Review - Threatened, Endangered, and Sensitive Botany Species ...... 30 Direct, Indirect and Cumulative Effects ...... 30 Aquatic Environment ...... 31 Hydrological Background ...... 31

Relevant Standards and Guidelines ...... 34 Aquatic Conservation Strategy ...... 35 Watershed Analysis Recommendations ...... 36 Existing and Desired Conditions – Water Quality ...... 36 Direct Effects ...... 37 Indirect Effects ...... 40 Aquatic Conservation Strategy ...... 42 Cumulative Effects ...... 44 Fisheries ...... 44 Existing Conditions ...... 44 Aquatic Biological Evaluation and Essential Fish Habitat ...... 44 Direct and Indirect Effects ...... 46 Cumulative Effects...... 46 Aquatic Conservation Strategy ...... 46 Threatened and Sensitive Wildlife Species ...... 47 Direct, Indirect, and Cumulative Effects ...... 48 Wildlife Effects Analysis for Herbicides ...... 55 Discussion - Threatened Wildlife Species ...... 55 Discussion - Sensitive Wildlife Species ...... 57 Crater Lake Tightcoil (Pristiloma arcticum crateris) ...... 57 Red-necked Grebe (Podiceps grisegena) ...... 58 Horned Grebe (Podiceps auritus) ...... 59 Oregon Spotted Frog (Rana pretiosa) ...... 61 Northern Pacific Pond Turtle (Actinemys marmorata marmorata) ...... 62 Bufflehead (Bucephala albeola) ...... 64 Black Swift (Cypseloides niger) ...... 65 Yellow Rail (Coturnicops noveboracensis) ...... 66 Purple Martin (Progne subis) ...... 68 Pacific Fringed Myotis (Myotis thysanodes vespertinus) ...... 69 Townsend's Big-eared Bat (Corynorhinus townsendii) ...... 70 Summary of effects/impacts determinations ...... 71 5

Survey and Manage Wildlife Species ...... 72 Management Indicator Species ...... 73 Landbirds ...... 75 Migratory Bird Treaty Act and Landbird Analysis...... 75 Recreation...... 80 Relevant Standards and Guidelines ...... 80 Direct and Indirect Effects ...... 81 PDFs ...... 81 CHAPTER 4 ...... 84 Consultation with Others ...... 84 Public Involvement ...... 84 Agency and other Government Consultation ...... 84 Interdisciplinary Team ...... 84 GLOSSARY ...... 85 REFERENCES ...... 94 APPENDIX 1 ...... 102

TABLES Table 1. Connected Actions associated with the Proposed Action ...... 23 Table 2. Displays the risk assessments for herbicides and surfactants considered in this EA...... 24 Table 3. Project Effects Assessment for Threatened, Endangered & Sensitive Plants . Error! Bookmark not defined. Table 4. Determination of effects to Threatened and Sensitive Aquatic Species...... 47 Table 5. Threatened and Sensitive Wildlife on the Umpqua National Forest, North Umpqua RD from .... 48 Table 6. Wildlife Sensitive Species pre-field review and summary...... 53 Table 7. Determination of Impact or Impacts to Threatened or Sensitive Wildlife Species ...... 71 Table 8. Survey and Manage Wildlife Species (2011) found on the Umpqua National Forest ...... 72 Table 9. Summary of Determination of Impacts to Survey and Manage Species ...... 73 Table 10. Management Indicator Species and Habitats They Represent ...... 73 Table 11. Summary of Determination of Impacts to Management Indicator Species ...... 74 Table 12. USFWS Birds of Conservation Concern (BCC) within the Partners in Flight Bird Conservation Region 5, Northern Pacific Rain forest...... 77 Table 13. Landbirds identified as Focal Species by the Partners in Flight document “Habitat Conservation for Landbirds in the Coniferous Forests of Western Oregon and Washington” version 2.0 by Altman and Alexander 2012...... 79 Table 14. Water Quality Limited Streams downstream of the Project Area...... 37 Table 15. Glyphosate Hazard Quotients for Wildlife ...... Error! Bookmark not defined. Table 16. Imazapyr Hazard Quotients for Wildlife ...... Error! Bookmark not defined. Table 17. Umpqua National Forest Weed List ...... Error! Bookmark not defined.

FIGURES Figure 1. Willow Sump Project Vicinity Map ...... 10 Figure 2. Willow Sump Project Map ...... 11 Figure 3. Location of Willow Sump within Emile Subwatershed and Little River Watershed, including major streams...... 32 Figure 4. Willow Sump Area ...... 33 Figure 5. The Willow Sump area including Emile Creek...... 34

CHAPTER 1 Purpose and Need for Action

This Environmental Assessment (EA) analyzes a range of alternatives, including a no-action alternative and action alternatives. Chapter 1 describes the Purpose and Need for action and the Proposed Action for the project. This chapter also describes the project location, outlines applicable management direction, addresses the scope of the decision, summarizes the scoping process, and lists the issues identified during scoping.

Project Location The 2-acre Willow Sump project area is located on the North Umpqua Ranger District of the Umpqua National Forest (UNF), approximately 24 road miles southeast of Glide, Oregon (Figure 1). The project area lies within the Emile Creek (6,652 acres) sub-watershed located within the Little River watershed. The planning area is situated within T27S, R1W, Section 2 and 3, Willamette Meridian, Douglas County, Oregon. The approximate two acre planning area is administered by the U.S. Forest Service.

Figure 1. Willow Sump Project Vicinity Map

Figure 2. Willow Sump Project Map

Relationship to other Planning Documents and Analyses The 1990 Umpqua National Forest Land and Resource Management Plan (LRMP) and its amendments to date, including the 1994 Record of Decision for Amendments to Forest Service and Bureau of Land Management Planning Documents within the Range of the Northern Spotted Owl (NWFP), provide broad management direction for the Willow Sump project. The planning area is within Management Area 10 as defined by the LRMP, and the Adaptive Management Areas (AMA) and Riparian Reserves as defined by the NWFP. Management Area 10 provides for production of timber on a cost-efficient sustainable basis consistent with other resource objectives. Although this project area falls within Management area 10, this project does not have a timber component associated with the proposed action and will not provide for timber production. Adaptive Management Areas are landscape units designated to encourage the development and testing of technical and social approaches to achieving desired ecological, economic, and other social objectives. Riparian Reserves provide an area along all streams, wetlands, ponds, lakes, and unstable and potentially unstable areas where riparian-dependent resources receive primary emphasis. This EA incorporates by reference to the Final Environmental Impact Statement (FEIS) of the 1990 Umpqua National Forest LRMP, as amended, and the 2005 Final Environmental Impact Statement for the Pacific Northwest Region Invasive Plant Program. This EA also incorporates by reference the recommendations and analysis in the 1995 Little River and the 2001 Little River Watershed Total Maximum Daily Load (TMDL) Appendix C Federal Water Quality Restoration Plan, and the 2008 North Umpqua Sub-basin Water Quality Restoration Plan. 1995 Little River WA relevant recommendations:  Unique Habitats: Work to control non-native/noxious plants. Willow Flats area was listed as the second priority in this endeavor (Recommendations p. 9)  Non-native Species: Slow and/or curtail the spread of non-native species (Recommendations p. 13)

This EA incorporates by reference the Project Record (40 CFR 1502.21). Chapter 3 provides a summary of the specialists input in adequate detail to support the rationale for the decisions and the appendices provide supporting documentation. The Project Record contains supplemental information and other technical documentation used to support the analysis and conclusions in this EA. Incorporating this information implements the CEQ Regulations provision that agencies should reduce National Environmental Policy Act (NEPA) paperwork (40 CFR 1500.4), and that environmental documents shall be “analytic rather than encyclopedic, and shall be kept concise and no longer than absolutely necessary (40 CFR 1502.2)”. The objective is to furnish adequate site-specific information to demonstrate a reasoned consideration of the environmental impacts of the alternatives and how these impacts can be mitigated, without repeating detailed analysis and background information available elsewhere. The Project 12

Record is available for review at the Umpqua National Forest Supervisor’s Office, 2900 N.W. Stewart Parkway, Roseburg, Oregon 97471.

Need for Action Yellow floating heart was first discovered in Willow Sump during 2011 when surveys were conducted by the Center for Lakes and Reservoirs, Portland State University. Aerial photography has shown an increase of the population size over the last seven years. Currently, yellow floating heart covers 1.2 acres of the 2 acre sump. It is forming a mat on the surface of the sump, excluding native aquatic species. It is reducing the habitat for plants or animals and will eventually limit the recreation values associated with this site. It is providing a source for spread of this Class A noxious weed. The need is for eradication of a Class A noxious weed (yellow floating heart) so that we are in compliance with Oregon Department of Agriculture (ODA) noxious weed management policy as described by ORS 569.180 and eliminate a source of spread of this plant to other water bodies on the forest and other ownerships. The desired condition is an area free of aquatic invasive species that will continue to provide habitat and recreation values. The purpose is to cost-effectively eradicate yellow floating heart while 1) maintaining the Willow Sump as a recreation site 2) minimizing adverse effects of treatment to human health, non- target organisms, native fish and wildlife habitat, watersheds, and the environment. Since the population was discovered, treatments have included hand pulling and applying geo- textile fabric to the existing population. The hand pulling treatments have had no observable effect on the rate of spread of the infestation. The geo-textile fabric was more effective; however, this method is not feasible to eradicate the entire infestation. Herbicide applications on yellow floating heart elsewhere (D. Jacobson 2013, pers. Comm., 15 February) have indicated that eradication is possible if treatments are allowed to continue for a number of years

The measure used in the analysis for this project is:  Whether or not yellow floating heart can be cost-effectively eradicated from Willow Sump

Proposed Action The Proposed Action (Alternative 2) was designed to meet the Purpose and Need by implementing the following activities:

 Forest Service proposes to foliar spot spray of yellow floating heart using aquatic labeled herbicides (glyphosate and imazapyr) from the shoreline of Willow Sump or by watercraft will be conducted by either Forest Service personnel or designated contractors. Herbicide would be applied to the leaves of yellow floating heart (herbicide would not be added to the water directly and overspray would be minimized).

 Treatments would continue until the population has been eradicated. It is estimated that treatments could continue for up to ten years with the first few years making the largest impacts to the population. Subsequent treatments would target the diminishing populations until the species was eradicated from the sump.

Decisions to be made Based on the analysis documented in this Environmental Assessment, the Forest Supervisor of the Umpqua National Forest will decide the following:

 To implement the project as proposed (Alternative 2) or to not implement the project at this time (Alternative 1).

 If the project is implemented, which mitigation measures, project design features, monitoring, and best management practices are necessary to achieve resource goals, objectives, and desired future conditions.

 Whether or not the project will cause a significant effect on the human environment that would require preparation of an Environmental Impact Statement.

Scoping Public involvement for the Willow Sump Project began with the mailing of the October 2012 Schedule of Proposed Actions (SOPA). A scoping notice describing the project components and querying interest in a field trip was sent to 20 members of the public on October 12, 2012, which initiated the 21 day formal scoping period. In addition to the scoping notice being sent out, we posted a scoping notice at the sump to inform any members of the public who might be using the area during hunting season. We did not receive any interest from the public for a field trip to this site. We received one comment from the Oregon Department of Fish and Wildlife. The Willow Sump Project Record contains a detailed scoping summary that describes Forest Service outreach efforts, the scoping comments received for the project, and how the Forest Service addressed scoping comments in the Willow Sump EA.

Issues and Concerns Issues are based on unresolved conflicts concerning alternative uses of available resources that are generally raised during scoping and can be used as the basis for formulating and comparing alternatives to the Proposed Action, for prescribing mitigating and monitoring measures, or for identifying environmental analysis needs (40 CFR 1502.14). Scoping during the Willow Sump planning process identified 0 issue(s) that could be used to develop an alternative to the Proposed Action:

Issues: There were no issues raised from the public to suggest an alternative.

Issues that did not drive Alternatives

All comments received during scoping are included in the Willow Sump project record. Comments that raised concerns, but did not provide a cause and effect statement to become an issue that would drive an alternative, have been identified and resolved by: clarifying the Purpose and Need or the Proposed Action in Chapter 1; by addressing the concern in developing or including Project Design Features (PDFs), Best Management Practices (BMPs), or Mitigation Measures in Chapter 2; or by disclosing effects in the analyses of Chapter 3. As these concerns were resolved as described below, they did not drive the development of an alternative to the Proposed Action and as such will not be discussed or analyzed further.

Concerns addressed by clarification of the Proposed Action in Chapter 1 Oregon Department of Fish and Wildlife recommended that we use an aquatic-safe herbicide that has minimal impacts on fish and wildlife and non-target plant species. This comment is addressed in the proposed action under the type of herbicides that would be used to meet the purpose and need.

Concerns addressed by PDFs, BMPs, and Mitigation Measures in Chapter 2 Oregon Department of Fish and Wildlife recommended that we limit the amount of herbicide used by getting as close as possible to target plants and not over-spraying. In addition, ODFW suggests taking measures to limit the attenuation of the herbicide into non-target areas of Willow Sump and Emile Creek and to be notified of herbicide application dates and any observation of fish and wildlife distress or mortalities. These comments are addressed through project design features and mitigation measures in chapter 2 of the EA.

Concerns addressed by the analyses in Chapter 3 Oregon Department of Fish and Wildlife would like to be made aware of steps that will be taken to limit the spread of herbicide into Emile Creek and whether or not drainage to the riparian area is expected. The disclosure of effects from this issue will be addressed in chapter 3.

Project Implementation Should the action alternative be selected as a result of this NEPA process, the Forest Service would implement the associated activity work through contracts starting in August of 2015. Timeframe?

Chapter 2 – Alternatives Willow Sump Invasive Plant Project EA

CHAPTER 2 Alternatives, Including the Proposed Action

INTRODUCTION

The National Environmental Policy Act (NEPA) requires analysis of a proposed action and other reasonable alternatives, including no action. The no action alternative provides a baseline for estimating environmental effects. Two alternatives, including no action, for the Willow Sump Invasive Plant Project are considered in detail. The proposed action was developed to best meet the purpose and need. In addition, three other alternatives were considered, but eliminated from detailed study. After considering and implementing potential alternative treatments, we found that herbicides will be necessary to cost-effectively eradicate yellow floating heart from Willow Sump. The other methods are either prohibitively expensive (or have other unacceptable effects), or would not result in full eradication of yellow floating heart.

Alternatives Considered, But Eliminated From Detailed Study The following alternatives were considered, but eliminated from detailed consideration because they are not likely to meet the need for cost-effective eradication of yellow floating heart in Willow Sump. These alternatives were suggested during internal scoping. Mechanical pulling. This alternative would manually remove the yellow floating heart floating from the sump. An assessment was done on this alternatives effectiveness to meet the purpose and need. Previous years attempt at implementing this method resulted in breaking off the rhizomes and fragmenting the plant which leads to the creation of more plants. In addition to the direct impacts to the plant, this method is not a viable option due to the economics and the amount of person hours needed to effectively implement this method. Over 800 person hours, some volunteer, were used on a small portion of the infestation over a three week period. Within one month, there was no evidence of the work that was completed because the yellow floating heart had been replaced with new plants. This alternative was eliminated from study because mechanical pulling would not result in eradication of yellow floating heart from Willow Sump. Geo-textile fabric. An alternative was considered to apply geo-textile to the approximate 1.2 acres of the infestation. A small portion, approximately 1/10th of an acre, of the population was treated during 2012 with this method and appears to be effective. However, the entire sump must be treated to meet the need for action and it is estimated that this would involve over 70 person days to install the geo-textile fabric. In addition to the application of the geo-textile fabric, at least one third of the mostly willow species along the embankment would have to be removed in order to apply the geo-textile fabric to the water’s edge. The removal of willows would nearly double the amount of person days involved with this alternative. This would be cost prohibitive. The removal of the mostly willow species would create undesirable ground disturbance and increase the cost of treatment. This method would not be a feasible solution for eradicating the yellow floating heart and thus, this alternative was not developed for detailed study. 16

Chapter 2 – Alternatives Willow Sump Invasive Plant Project EA

Permanent draining of Willow Sump and berm removal. An alternative was considered to remove the berm and drain the sump. This alternative was rejected because draining of the sump under this alternative would not assure complete draw down of the water and thus might not result in full eradication of yellow floating heart. In addition, draining the sump would 1) reduce the usability of Willow Sump as a recreation site and 2) increase sediment downstream. Therefore, this alternative was considered but eliminated from study.

Removal of berm, draining of Willow Sump, and re-building of berm. An alternative was discussed to remove the berm, drain the sump, and then re-build the berm so as to only remove the recreation site for a couple of years. An assessment was done on this alternatives ability to meet the purpose and need. This alternative would modify a recreation site on the Umpqua National Forest for only a couple of years. Draining of the sump under this alternative would not assure complete draw down of the water and still might provide habitat for limited populations of yellow floating heart. The additional costs associated with re-building the berm to current specs would dramatically increase the costs beyond the range of implementing the proposed action and would not be feasible to implement.

Alternative 1 – No Action Under Alternative One, no treatments would occur. On-going activities would occur within the vicinity of Willow Sump but efforts would not be directed towards eradicating the yellow floating heart. Activities such as noxious weed control adjacent to the site and monitoring of the yellow floating heart would continue.

Alternative 2 – Proposed Action This alternative is the proposed action used in the scoping process. The proposed action was developed to meet the purpose and need. It includes the following:  Foliar spray of aquatic labeled herbicides (glyphosate and imazapyr) from the shoreline or watercraft. Herbicide would be applied to the leaves of yellow floating heart (herbicide would not be added to the water directly and overspray would be minimized).

Best Management Practices, Mitigation Measures, Project Design Features, and Monitoring

Purpose Project Design Feature Source

Chapter 2 – Alternatives Willow Sump Invasive Plant Project EA

The following measures apply to the action alternatives. These requirements will be implemented in order to meet laws, regulations, and policies. In most cases they have been designed to reduce potential environmental effects. Mitigation measures are defined as actions that:

 avoid the impact all together;  minimize impacts by limiting the degree or magnitude of the action;

 rectify the impact by repairing, rehabilitation, or restoring;  reduce the impact over time by applying maintenance operations (such as road maintenance). General Water Quality Best Management Practices (BMPs), symbolized by a checkmark (√), are mitigation measures prescribed to protect the beneficial uses of water and to address water quality objectives as required by the Federal Clean Water Act and the 1990 Umpqua National Forest LRMP, as amended. Each BMP is listed by the code used in the National Core BMP Technical Guide (USFS 2012). A complete BMP checklist is included in the Project Record. Other mitigation not related to compliance with the Clean Water Act is indicated by a round bullet (). Some of the items listed are Standards and Guidelines (S&Gs) from the Umpqua National Forest LRMP and Northwest Forest Plan are also listed as a (). Monitoring is delineated by a lightning bolt ().

Pre-Project Planning – To ensure project is implemented appropriately The nature of invasive plant management requires ongoing project review and evaluation. The current location of this invasive plant within the sump will vary and is likely to change over the life of the project. As such, conditions would be confirmed prior to treatment and appropriate design features would be applied. Apply PDFs (including Terms and Conditions from consultation with regulatory agencies) depending on site conditions.

To Prevent Spread of Invasives from Treatment Activities or Re-Introduction on a Treated Site  Vehicles and equipment (including personal protective clothing) used for invasive plant treatment activities would be cleaned prior to entering National Forest land. Umpqua Forest Plan Standard (standard #2 from 2005 R6 ROD)  Where practical, thoroughly clean and inspect all equipment and clothing before moving off treatment areas.

Field Operations / Worker Safety  Herbicides would be used in accordance with label instructions, except where more restrictive measures are required as described below. Herbicide applications will only treat the minimum area necessary to meet site objectives. Herbicide formulations would be limited to 2 active ingredients: glyphosate and imazapyr. (Chem-1, Chem-2, and Chem-4 from BMP Guide)

 Maintain the herbicide application equipment in proper operating condition by calibrating, cleaning and repairing the equipment as necessary to ensure effective and accurate pesticide 18

Chapter 2 – Alternatives Willow Sump Invasive Plant Project EA

applications and to reduce leaks, spills, or other unintended discharges of herbicide. (DEQ requirement and BMP Chem-3).

 A Pesticide Discharge Management Plan would be developed and an NPDES permit would be obtained prior to implementing any treatments (DEQ requirement).

 Herbicide use would comply with terms and conditions of DEQ 2300A permit, including standards on herbicide selection, reporting, spill response, and licensed applicators (DEQ requirement and BMP Chem-1)

 Workers will use appropriate personal protective clothing and equipment at all times during application. Traffic control and signing during invasive plant-treatment operations will be used as necessary to ensure safety of workers and the public.

 Herbicide applications would occur when wind velocity is between two and eight miles per hour. The less than 2 mph standard is to avoid spraying during inversions. During application, weather conditions would be monitored periodically by trained personnel. No spraying would occur if measurable precipitation is occurring or is predicted to occur within 24 hours within the given treatment area. Local conditions to be monitored by the licensed applicators.

 A spill cleanup kit would be available whenever herbicides are transported or stored to contain any accidental spills. (FSH 2109 and BMP Chem-1).

 The licensed applicator is responsible for the immediate cleanup of all spills. An Herbicide Transportation and Handling Safety/Spill Response Plan would be the responsibility of the herbicide applicator.  Address spill prevention and containment.  Estimate and limit the daily quantity of herbicides to be transported to treatment sites.  Manage and store chemicals in accordance with all applicable federal, state or local regulations, including label directions.  Transport and handle chemical containers in a manner that minimizes the potential for leaks and/or spills.  Require that impervious material be placed beneath mixing areas in such a manner as to contain small spills associated with mixing/refilling.  Require a spill cleanup kit be readily available for herbicide transportation, storage and application (minimum FOSS Spill Tote Universal or equivalent).  Outline reporting procedures, including reporting spills to the appropriate regulatory agency.  Ensure applicators are trained in safe handling and transportation procedures and spill cleanup.  Require that equipment used in herbicide storage, transportation and handling are maintained in a leak proof condition.  Specify mixing and loading locations away from water bodies so that accidental spills do not contaminate surface waters.  Require that spray tanks be mixed or washed in a designated area away from the surface water.

Chapter 2 – Alternatives Willow Sump Invasive Plant Project EA

 Ensure safe disposal of herbicide containers. Source: FSH 2109.14 Reduce likelihood of spills and to contain any spills. Reduce potential for adverse effects from accidental spills.

 Estimate and limit the daily quantity of herbicides to be transported to treatment sites to reduce potential for spills.

 Minimize traffic in riparian reserves, including aquatic influence zone to minimize trampling and to protect the riparian habitat.

Public Health / Public Notification  The public would be notified about upcoming herbicide treatments via the local newspaper (news release), Forest Service website, fliers, or posting signs.

 Willow Sump recreation area would be posted in advance of herbicide application. Posting would indicate the date of treatments, the herbicide used, Forest Service contact information, and when the area may be reentered.

To Protect Soils, Water Quality, Fisheries and Aquatic Organisms  Coordinate project with state water quality and/or fish and wildlife agencies as necessary (BMP Chem-4)

 Avoid applying chemicals in situations where it could enter downstream waters. Herbicide application would not occur when outflow stream has continuous surface flow. (BMP Chem-4)

 Locate operation bases in appropriate sites where possible spills would not enter surface waterbodies or groundwater aquifers. (BMP Chem-5)

 Ensure that mixing equipment, containers and spill kits are in place and adequate for the project size and chemicals to be used. (BMP Chem-5)

 Herbicide treatment must not cause or contribute to the violation of water quality standards. Dissolved Oxygen standard: for waterbodies identified by the department as providing cold water aquatic life, the dissolved oxygen may not be less than 8.0 mg/L as an absolute minimum. (OAR 340-041-0016)

 Visual assessments will be conducted during and after herbicide application in the area in and around where herbicides are applied for possible and observable adverse impacts caused by an application of pesticides (BMP Chem 6, DEQ requirement)

 Implementation and effectiveness of BMP’s will be monitored during and after of application to identify unintended effects, the need for corrective actions, or adaptive management needed. (BMP Chem-4 and Chem-6)

Chapter 2 – Alternatives Willow Sump Invasive Plant Project EA

 Oregon Department of Fish and Wildlife (ODFW) Guidelines for Timing of In-Water Work Periods will be followed or negotiated with ODFW. The ODFW in water work timing guidelines can be found at: http://www.dfw.state.or.us/lands/inwater.

To Ensure the Protection of Threatened, Endangered, Sensitive (TES) or other Rare and Uncommon Plant Species

 Forest Service Botanists will work closely with herbicide applicators to ensure project design features are implemented and will monitor and document the results.

To Ensure Protection of Heritage Resources

 Native plants will be allowed to regenerate on site. Local tribes will be consulted with to ensure culturally sensitive species are maintained.

To Protect Wildlife  Spray only during times of ideal weather conditions to avoid the necessity of additional treatments. Minimize the number of treatments conducted to reduce unnecessary potential adverse impacts to aquatic and terrestrial wildlife.

 Conduct herbicide treatments late in the breeding season to minimize potential toxic effects to breeding amphibians. Late-season treatments will also reduce impact to terrestrial wildlife species that may be impacted by human disturbance during the breeding season.

CHAPTER 3 Affected Environment and Environmental Effects

INTRODUCTION This chapter describes the components and scope of the human environment that may be affected by implementation of the alternatives outlined in Chapter 2 and discloses the potential consequences of implementing each alternative including the project design features associated with the proposed action. A complete description of each alternative is found in Chapter 2. This chapter represents the scientific and analytic basis for comparison of alternatives. The effects are discussed in terms of social and environmental changes from the current condition and include quantitative assessments where possible as well as qualitative assessments. All discussions are referenced by the Final environmental Impact Statement (FEIS) of the 1990 Umpqua National Forest LRMP, as amended and the 2005 Final environmental Impact Statement for the Pacific Northwest Region Invasive Plant Program (2005 R6 ROD). This EA also incorporates by reference the recommendations and analysis in the 1995 Little River and the 2001 Middle North Umpqua Watershed Analyses (WA), as well as the 2001 Little River Watershed Total Maximum Daily Load (TMDL) Appendix C Federal Water Quality Restoration Plan, and the 2008 North Umpqua Sub-basin Water Quality Restoration Plan. This chapter also incorporates by reference all reports and analysis prepared by resource specialists, which are summarized in this chapter.

Treatment Assumptions and Scenarios The analysis in this chapter of the EA is based on the assumption that treatments would not be considered 100 percent effective immediately after the initial entry. Initial treatment is proposed to treat 50% of the invasive plants at the site. Although the herbicide analysis considers the size of the sump and the infestation, treating only 50% of the infestation will further diminish the effects of any herbicide treatment. Entries would be required in subsequent years until this species is eradicated. The following assumptions were made about treatment scenarios. Eighty percent effectiveness is assumed for each treatment after each year. For example, if 1.0 acre is treated in year one and the treatment is 80% effective, and then 0.2 acres would need to be treated in year 2.

The treatments are projected to recur twice a year during the summer, when outflow is minimal, for up to ten years. Although the site may be cleared before ten years, the scenario used for analysis assumes a ten year period.

Imazapyr and/or glyphosate would be used; with the relative amounts expected to vary depending on effectiveness over time. 22

Basis for Cumulative Effects Analysis The Council on Environmental Quality issued a memo stating that agencies are not required to “catalogue or exhaustively list and analyze all individual past actions” (CEQ memo, June 24, 2005). Instead, agencies should use scoping to focus on relevant past actions and discuss their relevance in terms of the cause and effect they had on a resource. This direction is followed in the Willow Sump Invasive Plant Project; the following tables are displayed to summarize information known about the sub-watersheds that constitute the Willow Sump planning area. Discussion of these activities occurs throughout this chapter, where relevant. Tables X-X documents the relevant past, present, and reasonably foreseeable activities that may contribute to cumulative effects for the Willow Sump Invasive Plant Project. The cumulative effects considered in this EA are related to the risks to the human environment associated with herbicide exposure and the various resource areas. The risk of adverse effects to invasive plant treatments have been minimized by the Project Design features (PDF’s) as described in chapter 2 and therefore the potential for cumulative effects is minimal.

Table 1. Relevant past, present, and reasonably foreseeable activities that may contribute to cumulative effects for the Willow Sump Invasive Plant Project.

Activity Decade Acres/Miles Comments Final Overstory 1970’s 128 Overstory removal primarily through ground Removal 1980’s 810 based and skyline logging. 1990’s 94 TOTAL ACRES 1,032 Clear-cut Harvest 2000’s xxxx xxxxxx on Private Lands Reforestation 2,000’s 396 Reforestation was accomplished using shovels, 396 hoedads, and other planting implements. TOTAL ACRES Animal Damage 1980’s 75 Netting Control 2,000’s 288 repellants/tubing/ 363 TOTAL ACRES Road Building 1980’s 36 Building of system roads for logging and 1990’s 2 transportation purposes. 2000’s 3 206 miles Includes ML 1, 2, 3, and 4 roads. TOTAL MILES Instream Fish 2000’s 2.5 miles Placement of large wood in Negro Creek (0.5 Habitat miles) and White Creek (2.0 miles). Enhancement Noxious Weed 2007 30 acres Pulling of known population of Scotch Broom Treatments on roads in the Emile Planning Area.

Herbicides, Adjuvants, Surfactants and Inert Ingredients

Herbicide Risk Assessments The effects from the use of any herbicide depends on the toxic properties (hazards) of that herbicide, the level of exposure to that herbicide at any given time, and the duration of that exposure. The R6 2005 FEIS used the herbicide risk assessments to evaluate the potential for harm to non-target plants, wildlife, human health, soils and aquatic organisms from the herbicides considered for use on the Willow Sump Invasive Plant Project located on the Umpqua National Forest. Risk assessments were conducted by an independent third party, Syracuse Environmental Research Associates, Inc. (SERA) The Risk Assessments relied upon peer reviewed articles from the open scientific literature and current Environmental Protection Agency (EPA) documents, sometimes including Confidential Business Information to identify the hazard, estimate the exposure, identify dose-response relationships and then characterize risk to human health and the environment. The risk assessments considered worst-case scenarios including accidental exposures and application at maximum label rates. The R6 2005 FEIS added a margin of safety to the SERA Risk Assessments by making the thresholds of concern substantially lower than normally used for such assessments. Although the risk assessments have limitations (see R6 2005 FEIS pages 3-95 through 3-97), they represent the best science available. In addition to the analysis of potential hazards to human health and the environment from herbicide active ingredients, Bakke (2003, 2007) and SERA Risk Assessments have evaluated available scientific studies of potential hazards of other substances associated with herbicide applications: impurities, metabolites, inert ingredients, and adjuvants. The Forest Service maintains a Pesticide management and Coordination website that contains human health and ecological risk assessments; pesticide use policy information; pesticide labels; material safety data sheets; and reports on pesticide use across National Forest System lands: http://www.fs.fed.us/foresthealth/pesticide.

Table 2. Displays the risk assessments for herbicides and surfactants considered in this EA. Herbicide Date Final Glyphosate March 25, 2011 Imazapyr December 16, 2011 Surfactants & Adjuvants January 2007 NPE Surfactants May 2003 Effect of Surfactants on Toxicity February 1997 of Glyphosate Use and Assessment of Marker December 1997 Dyes used with Herbicides

Incomplete or Unavailable Information Risk assessments have a high degree of uncertainty in interpretation and extrapolation of data. Uncertainty may result from a study design, questions asked (and questions avoided), data collection, data interpretation, and extreme variability associated with aggregate effects of natural and synthesized chemicals on organisms, including humans, and with ecological relationships. Due to data gaps, assessments rely heavily on extrapolation from laboratory animal tests (USDA Forest Service 2005a). Regardless of disadvantages and limitations of ecological and human health risk assessments, risk assessments can determine (given a particular set of assumptions) whether there is a basis for asserting that a particular adverse effect is possible. The bottom line for all risk analyses is that absolute safety can never be proven and the absence of risk can never be guaranteed (SERA 2007). Further, a risk assessment has only been completed on one surfactant type (NPE) (Bakke 2003, 2007). Limited information on other surfactants, adjuvants, and inert ingredients is available in Bakke (2003, 2007) and various risk assessments. Since risk assessments have not been completed for most surfactants, adjuvants and inert ingredients, information regarding the toxicity and effects of these chemicals is largely unavailable. For risk assessments considering adjuvants, surfactants and inert ingredients in herbicide mixtures, the information within the risk assessment may not be complete. SERA (2007) discuss how the risk assessments apply generally accepted scientific and regulatory methodologies to encompass these uncertainties in predictions of risk. SERA risk assessments identify and evaluate incomplete and unavailable information that is potentially relevant to human health and ecological risks. Each risk assessment identifies and evaluates missing information for that particular herbicide and its relevance to risk estimate. Such missing information may involve any of the three elements needed for risk assessments: hazard, exposure, or dose-response relationships. A peer-review panel of subject matter experts reviewed the assumptions, methodologies and analysis of significance of any such missing information. SERA address and incorporate the findings of this peer review in its final herbicide risk assessment.

Invasive Plants/Noxious Weeds

Existing and Desired Conditions - Invasive Plants/Noxious Weeds An invasive plant is a non-native plant whose introduction does or is likely to cause economic or environmental harm or harm to human health (Executive Order 13112). Invasive plants are distinguished from other non-native plants in their ability to spread (invade) into native ecosystems. Some species of invasive plants are listed by the Secretary of Agriculture or by the responsible State official as “noxious weeds.” The term “invasive plants” more broadly encompasses all invasive, aggressive, or harmful non- indigenous plant species, whether designated noxious or not. The Umpqua National Forest has classified its invasive plants into four categories: high priority species (Forest Rating A) for which treatment of all known sites is a priority, lower priority species (Forest Rating B) which are generally too widespread for control to be feasible, detection species (Forest Rating D) which are surveyed for and would become high-priority if found, and other weeds of interest (Forest 25

Rating O). At the time that this population was first discovered in 2011 by the Center for Lakes and Reservoirs, Portland State University, this species was not on the Umpqua NF invasive plant list. Although at the time of discovery, yellow floating heart was and still is listed as a Class A noxious weed by the Oregon Department of Agriculture (ODA) and is deemed for eradication. Yellow floating heart is an invasive plant and also a State-listed noxious weed in Oregon. This plant forms dense patches that compete with native species and can form thick mats that cause stagnant areas in the water with little oxygen for fish or other aquatic species. The current population of yellow floating heart covers approximately 1.25 acres of the 2 acre Willow Sump. Yellow floating heart is an aquatic perennial invasive plant with leaves attached to stalks that arise from underwater rhizomes that are imbedded in the sediment. Reproduction can occur from seeds, rooting at nodes of rhizomes, and can be regenerated from plant fragments. Rhizomatous perennial invasive plants are typically difficult to treat manually because there is a high likelihood of plants reproducing from vegetative parts. The continuing spread of this infestation over the last few years and into the foreseeable future has the potential to impact the recreational activities associated with this site and have detrimental effects to the environment. The greatest risk of human-caused noxious invasive plant introduction into the proposed area is from recreational vehicles and water craft that have the potential to transport weed seeds and fragments from infested sites to non- disturbed areas. Invasive plant seeds and fragments can also be moved by wind, water, animals, and humans. The established population of this aquatic invasive on the Umpqua NF serves as a source for further dispersal into streams and other adjacent waterbodies.

Alternative 1- No-action Alternative. The absence of any activities under the no action alternative would result in the continued spread of the yellow floating heart population within the project area and an increased potential to spread into other water bodies. The long term changes would result in a decrease of habitat quality, recreation values, and would continue to displace native vegetation, and alter ecosystem structures and functions. Because the no-action alternative would rely upon ineffective treatments, resulting in a degraded habitat, there would be associated affects to this alternative.

Alternative 2 – Proposed Action. Alternative 2 proposes to use an adaptive management strategy to eradicate this invasive species from Willow Sump. Given the size of the infestation, herbicide treatments would be the first method of use to treat this population. As the size of the population is decreased due to repetitive yearly applications of herbicides it would be possible to shift to a manual or mechanical method of treatment if necessary. The eradication of yellow floating heart from the sump would lead to increasing the habitat quality and the recreation values associated with this site.

Herbicide Risk Assessments

Willow Sump EA Human Health Effects Analysis

Human Health Impact Analysis (Worker and Public Exposure to Herbicide) This section focuses on the health effects to workers and the public if herbicides are used as proposed in the alternatives. The Forest Service prepared herbicide risk assessments in 2011 for glyphosate and imazapyr that address potential risks to human health from herbicide use. The risk assessments include peer-reviewed articles from the open scientific literature and current EPA documents. Along with active ingredients, the assessments also reviewed herbicide additives, inert ingredients, and impurities, where information was available.

The dose of herbicide received by a worker or a member of the public under each exposure scenario is compared with the corresponding herbicide “Reference Dose” (RfD) established by EPA or by the Forest Service/SERA risk assessment for acute and/or chronic exposures. The RfD establishes the level below which no adverse effects to human health would be expected.

RfDs are established by taking the no observable adverse effect level (NOAEL) for each herbicide and then adjusting it to compensate for uncertainty. Most frequently, a RfD is 1/100th of the lowest NOAEL, but it may be even lower in some cases. The RfD is also referred to as the toxicity threshold or threshold of concern. The Hazard Quotient (HQ) is the ratio of the estimated level of exposure compared to the RfD. When a predicted dose is less than the RfD, then the HQ (dose/RfD) is equal to or less than 1, and toxic effects are unlikely for that specific herbicide application (i.e., the use is presumably safe). No chemical is studied for all possible effects and the use of data from laboratory animals to estimate hazard or the lack of hazard to humans of other species is an uncertain process. Thus, prudence dictates that normal and reasonable care should be taken in the handling of any chemical.

The risk assessments were interpreted based on specific site conditions at Willow Sump and the specific herbicide application rates proposed. A spreadsheet was prepared quantifying potential exposure to herbicide assuming the yellow floating heart is treated using both glyphosate and imazapyr in a mixed tank.

Effects of No Action to Human Health There would be no potential herbicide impacts to human health under no action because no herbicide would be sprayed to treat yellow floating heart.

Effects of the Proposed Action to Human Health

Worker Herbicide Exposure Analysis Herbicide applicators are more likely than the general public to be exposed to herbicides. Worker exposure is influenced by the herbicide application and concentration rate; the number of hours worked per day; the acres treated per hour; and variability in human dermal absorption rates.

Worker exposures are most likely to involve splashing a solution of herbicides into the eyes or on the skin. Two general types of exposure are modeled: one involving direct contact with a solution of the herbicide and another associated with accidental spills of the herbicide concentrate onto the surface of the skin. Exposure scenarios involving direct contact with herbicide solutions are characterized by immersing unprotected hands for 1 minute or wearing contaminated gloves for 1 hour. Workers are not likely to immerse their hands in herbicide; however, the contamination of gloves or other clothing is possible.

Exposure scenarios involving chemical spills onto the skin are characterized by a spill onto the lower legs as well as a spill onto the hands. In these scenarios, it is assumed that a solution of the chemical is spilled onto a given surface area of skin and that a certain amount of the chemical adheres to the skin.

Workers are unlikely to be exposed to a harmful amount of herbicide when treating Willow Sump. None of the individual or “mixed tank” exposure scenarios, accidental or operational, resulted in a worker receiving harmful doses of herbicide.

Public Herbicide Exposure Analysis The general public would not be exposed to substantial levels of any herbicides used in the implementation of this project. There is virtually no chance of a person being directly sprayed during this project, given public notification, signage, and temporary closures. However, even if they were directly sprayed with an herbicide or mix, they would not receive a harmful dose of herbicide through the skin. A person swimming in Willow Sump soon after treatment also would not be exposed to a harmful dose of herbicide. A person drinking water from Willow Sump would not be exposed to a harmful dose of herbicide even if 200 gallons of herbicide mix were spilled into the pond.

Endocrine Disruption The potential for the proposed herbicides to cause endocrine disruption effects was addressed in the risk assessments.

Endocrine disruption may bepossible after exposure to some glyphosate formulations. Endocrine disruption appears to be associated with the surfactants rather than glyphosate itself. Aquatic formulation of glyphosate does not contain POEA surfactants implicated in concern over endocrine effects (SERA Glyphosate Risk Assessment 2011).

In the review of the mammalian toxicity data on imazapyr, U.S. EPA Office of Pesticide Programs concluded that “there was no evidence of estrogen, androgen and/or thyroid agonistic or antagonistic activity shown.” SERA found that this conclusion was reasonable, based on their review of current information in the 2011 imazapyr risk assessment.

Environmental Justice and Disproportionate Effects This project is would not result in disproportionate effects to any minority or low income group. The project would likely be implemented by Forest Service and Oregon Department of Agriculture employees who are well trained in herbicide application. Certified applicators would manage the

herbicide spraying. This project is unlikely to affect anyone gathering or consuming forest products, including people who subsist on vegetation, game or fish from the National Forest.

Cumulative Effects Cumulative effects to human health from herbicide treatment at Willow Sump combined with herbicide use elsewhere are unlikely. Very little herbicide use occurs on the Umpqua National Forest and the location of Willow Sump is far from private lands where herbicide may be used.

Cumulative doses are possible within the context of this project, or when combined with herbicide use on adjacent lands or home use by a worker or member of the general public. However, the risk is very small that a person would receive additive exposures during the time period in which the herbicide remained in their body. These herbicides do not bio-accumulate in people and are rapidly eliminated from the body.

Combinations of lower-toxicity chemicals used in low doses (less than one tenth of RfD) have rarely demonstrated synergistic effects. Review of the scientific literature on toxicological effects and toxicological interactions of agricultural chemicals indicate that exposure to a mixture of pesticides is more likely to lead to additive rather than synergistic. Based on the limited data available on chemical combinations involving the twelve herbicides considered in this EIS, it is possible, but unlikely, that synergistic effects could occur as a result of exposure to the herbicides considered in this analysis. Synergistic or additive effects, if any, are expected to be insignificant (R6 2005 FEIS p. 4-3).

Botany

Effects of Herbicides to Non-Target Vegetation Herbicide applications are designed to kill the target plants. Some damage to non-target plant species such as the willow species that line the shoreline of the sump and the native Potamogeton sp. growing in the aquatic environment is likely under Alternative 2 despite careful planning and implementation. Treatments such as spot spraying and other PDF’s will be used to minimize the effects to non-target plant species. Alternative 2 limits the potential direct and indirect effects due to PDFs and other layers of caution, reducing the potential for cumulative effects, even when this project is considered with other past, present and future projects. While some commonly used herbicides are associated with hazards to non- target plants, harmful amounts of herbicides coming into contact with non-target plants as a result of Forest Service applications would be very limited in temporal and spatial scales, occurring only in the immediate vicinity of the invasive plants treated. Also, the PDFs and buffers would minimize the amount of herbicide exposure possible and eliminate scenarios where concentration of herbicide could affect population levels. The analysis assumes that possible repeated treatments within the same season do not overlap in time or space, or result in a cumulative effect. If repeated treatments are necessary it is usually a result of 29

missed plants during the first herbicide application. In this instance a second herbicide application would not overlap spatially or in time. In summary, there would be no cumulative effects to non-target plants (including sensitive and Survey and Manage species) from invasive plant treatments.

Survey and Manage Botany Species No ground disturbing activities or harvesting of any timber will occur during the implementation of this project. Because the project boundary does not contain suitable habitat for any of the survey and manage species surveys were not conducted within the project area.

Threatened, Endangered, and Sensitive Botany Species Biological Evaluation This Biological Evaluation evaluates potential impacts to Threatened, Endangered, or Sensitive (TES) vascular plants, lichens, and bryophytes from the Willow Sump Invasive Plant Project. It is Forest Service policy to “ensure that Forest Service actions do not contribute to loss of viability of any native or desired plant or contribute…trends towards Federal listing of any species” (FSM 2672.41). There are currently 39 vascular plant species, 20 fungi, 12 lichens, and 24 bryophytes listed as Sensitive on the Umpqua National Forest (Table 45). There are two species known or suspected to occur on the Forest that are listed under the Endangered Species Act. Lupinus sulphureus ssp. kincaidii (Kincaid’s lupine) is listed as Threatened and has been documented on the Tiller Ranger District located on the Umpqua National Forest. Plagiobothrys hirtus (rough popcorn flower) is listed as Endangered. It occurs primarily in the vicinity of Sutherlin in northern Douglas County but has not been documented on the Forest to date.

Pre-field Review - Threatened, Endangered, and Sensitive Botany Species The man-made sump proposed for treatment under Alternative 2 does not provide suitable habitat for rare plant species. There are no listed or sensitive species documented within the project area. Because there is no potential habitat or listed species documented within the project area, there would be a “No Effect” to any T&E species and a “No Impact” to any of the Forest Service Sensitive species.

Direct, Indirect and Cumulative Effects

Threatened or Endangered Plants There is no suitable habitat for either species that are listed under the Endangered Species Act. Kincaid’s lupine occurs in low-elevation upland prairies and is primarily known from Willamette Valley grasslands although there are isolated occurrences documented throughout the Umpqua basin. Rough popcorn flower is confined to low-elevation wetlands in the vicinity of Sutherlin in northern Douglas County. There are no known sites of either species near the planning area. Because there is no suitable habitat in or near any of the proposed activities under Alternative 2 there would no direct, indirect or cumulative effects to either species. Therefore there would be “No Effect” to either listed species resulting from either alternative.

Sensitive Botany and fungi Species There are no known sensitive botany or fungi species sites within the Willow Sump Invasive Plant Project area. The described suitable habitat for most of these species is not an aquatic environment. 30

Therefore, the potential for one of these sensitive species being present and being directly or indirectly impacted under the action alternative is minimal. For these reasons, activities proposed under Alternative 2 will have a no impact to individuals or habitat and will not likely contribute to a trend toward Federal listing or cause a loss of viability to the population or species” for those sensitive species with potential habitat within the project area. Because there is no suitable habitat in or near any of the proposed activities under Alternative 2 there would no direct, indirect or cumulative effects to any of the species listed.

Aquatic Environment The condition of the aquatic environment and its relationship to the proposed action was assessed during the scoping process. Concerns about herbicide toxicity on non-target species were expressed, but was determined to not be a significant issue. This is due to the selection of relatively low-toxicity herbicide, the small amount of herbicide to be used and application methods which will minimize non- target exposure. Additionally, extensive project design features and Best Management Practices will be used to minimize impacts to the aquatic environment. This section of the Environmental Assessment is included for disclosure purposes. This aquatic analysis focuses on how the Willow Sump alternatives affect physical and biological processes at various scales. This includes site specific disclosure at the scale of Willow Sump and at various larger scales including the Little River Watershed1. Each of the various aquatic sections is summarized in terms of the Aquatic Conservation Strategy(ACS) as clarified in the 2004 ROD (USDA/USDI 2004).

Hydrological Background Willow Sump is a 2.2 acre lake constructed in 1963 on what was likely a wetland area, for the purposes of providing water during fire suppression operations, and for recreational fishing. It is located within the Upland Plateau landform within the Western Cascades Geological Province. Upland Plateau's are elevated, gently-sloping and smooth land surfaces near the top of the watershed where erosion has done the least amount of work. Thousand foot-thick rocks resistant to erosion have preserved these gentle surfaces in an otherwise highly dissected and eroded landscape. Stream gradients and stream densities are low. Willow Sump is considered a moist/warm land unit type with relatively deep soils and gentle terrain. Winter flows may be lower and more prolonged compared to more flashy winter flows in basins with a predominance of dry warm land units. Also, the moist/warm weathering environment

1 A “watershed” is a subdivision of land that is based on hydrologic drainage and defined by a national hierarchical system, which delineates hydrologic drainage in nested multi-level subdivisions (FGDC, 2002). The watershed level subdivides the “sub- basin” level (4th level). The 5th level watershed in this situation is Little River which is subdivided by five smaller subwatersheds (6th level). The subwatersheds are subdivided by drainages (7th level), which is the smallest hydrologic subdivision.

increases soil depth and soil water storage so excess water is continually released into streams even during the summer drought (USDA/USDI 1995).

Figure 3. Location of Willow Sump within Emile Subwatershed and Little River Watershed, including major streams.

Willow Sump has an approximately 500 acre drainage basin and is within the Emile sub-watershed in the Little River Watershed (Figure 3). About 91% of the Emile sub-watershed, including Willow Sump, is within the transitional snow zone hydrologic regime where rain-on-snow events drive the largest flood levels. Most of the approximately 65 inches of annual precipitation falls as rain or snow between

November and April, with very little rainfall in summer. At an elevation of 1,230 feet, snowpack is relatively thin and short-lived compared to the High Cascades.

Figure 4. Willow Sump Area

A small perennial stream flows into Willow Sump from the north through a narrow band of wetlands (Figure 4). A small outlet stream exits the lake at the end of the constructed berm at the southeast corner of the lake. This outlet, not the original channel before berm construction, is perched above a large wetland complex below the berm, and runs approximately 100’ before diffusing into the perennially saturated wetland with multiple channels. During the lowest flows of the year, this channel barely flows out of the lake, then goes subsurface shortly after leaving the lake. Engineering records show a culvert through the berm, but no culvert could be found during the summer of 2012, and is probably partially to completely filled in. An extremely small flow of water was detected during summer low flows that appeared to be leaching though the berm into the wetland in one area and could be coming from the old culvert. The wetland below the lake is a long linear wetland averaging 130’ wide, along a nameless stream that continues for approximately 0.7 miles where it joins Emile Creek, a class 2

(resident fish-bearing) stream (Figure 5). Emile Creek flows about 6.4 miles until joining Little River, a class 1 (anadromous) stream.

Figure 5. The Willow Sump area including Emile Creek.

Depth measurements were taken by boat in the summer of 2012; maximum depth was 8’ but average depth was 5’. Average depth in the area infested with Yellow floating heart was 3.5’.

Relevant Standards and Guidelines

To meet the Clean Water Act and the Standards and Guidelines in the Umpqua Land and Resource Management Plan (LRMP), the beneficial uses of waters must be identified and management activities planned so they will not interfere with or be injurious to the beneficial uses of adjacent and downstream waters (USDA 1990). The relevant beneficial uses of the North Umpqua River and its tributaries, including Willow Sump as determined by Oregon Department of Environmental Quality are: 1) public and private domestic water supply; 2) industrial water supply; 3) irrigation; 4) livestock watering; 5) fish and aquatic life; 6) wildlife and hunting; 7) fishing; 8) water contact recreation; 9) aesthetic quality (ODEQ 2003).

The relevant Standards and Guidelines from the Umpqua LRMP related to water quality include:

Watershed cumulative effects and water quality, S&G 1: The beneficial uses of water must be identified and management activities planned so they would not interfere with or be injurious to the beneficial uses of adjacent and downstream waters. Water quality, S&G 20: Water quality will be protected when planning activities which will affect domestic and public water supplies. Water quality, S&G 21: Comply with State requirements in accordance with the Clean Water Act through planning, application and monitoring of Best management Practices (BMPs).

Aquatic Conservation Strategy The compatibility with the objectives of the Aquatic Conservation Strategy (ACS) of the Northwest Forest Plan is discussed in this section and the results of watershed analyses are presented, a description of the existing condition of the important physical and biological components of the ACS are discussed, and conclusions are presented regarding how the alternatives move conditions toward desired conditions in terms of the nine ACS objectives. The ACS objectives are: 1. Maintain and restore the distribution, diversity, and complexity of watershed and landscape- scale features to ensure protection of the aquatic systems to which species, populations and communities are uniquely adapted. 2. Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, longitudinal, and drainage network connections include floodplains, wetlands, upslope areas, headwater tributaries, and intact refugia. These network connections must provide chemically and physically unobstructed routes to areas critical for fulfilling life history requirements of aquatic and riparian-dependent species. 3. Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom configurations. 4. Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. Water quality must remain within the range that maintains the biological, physical, and chemical integrity of the system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and riparian communities. 5. Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the sediment regime include the timing, volume, rate, and character of sediment input, storage, and transport. 6. Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic and wetland habitats and to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial distribution of peak, high, and low flows must be protected. 7. Maintain and restore the timing, variability, and duration of floodplain inundation and water table elevation in meadows and wetlands. 8. Maintain and restore the species composition and structural diversity of plant communities in riparian areas and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody debris sufficient to sustain physical complexity and stability.

9. Maintain and restore habitat to support well-distributed populations of native plant, invertebrate and vertebrate riparian-dependent species.

The Standards and Guidelines from the Northwest Forest Plan related to water quality include relevant to the Willow Sump project:

General Riparian Area Management RA-3: Herbicides and other chemicals shall be applied only in a manner that avoids impacts that retard or prevent attainment of ACS objectives.

Watershed Analysis Recommendations Relevant recommendations from the 1995 Little River Watershed Analysis: Unique Habitats: Work to control non-native/noxious plants. Willow Flats area was listed as the second priority in this endeavor (Recommendations p. 9 Non-native Species: Slow and/or curtail the spread of non-native species (Recommendations p. 13)

Existing and Desired Conditions – Water Quality

Willow Sump is a eutrophic lake, meaning that enough nutrients are available to support a high amount of primary production through algae and other plants. This primary production produces food for other organisms, creating a diverse food web. Such eutrophic lakes characteristically support low water clarity. Due to the shallowness of Willow Sump, it is unlikely that seasonal thermal stratification occurs. Aquatic plants play a vital role in the complex system of chemical cycling in a waterbody. They can influence the amount of oxygen in the water, which in turn affects pH. Without external influences, dissolved oxygen (DO) and pH would reach an equilibrium concentration as a function of barometric pressure and water temperature. However, the growth and respiration of algae and other plants causes daily cyclical swings in DO and pH concentrations. Oxygen is produced during photosynthesis and consumed during respiration and decomposition. Because it requires light, photosynthesis occurs only during daylight hours. Respiration and decomposition, on the other hand, occur 24 hours a day. This difference alone can account for large daily variations in DO concentrations. During the night, when photosynthesis cannot counterbalance the loss of oxygen through respiration and decomposition, DO concentrations steadily decline. They are lowest just before dawn, when photosynthesis resumes (Michaud 1991). Dissolved oxygen also varies seasonally, with temperature having a big influence. Colder water has the potential to hold more dissolved oxygen than warmer water, so in general, DO is highest during winter and lowest during summer. In addition to plant production, oxygen enters lakes from the atmosphere, from streams flowing into the lake and from ground-water discharge. The water quality standard for Dissolved Oxygen in Willow Sump, identified as providing habitat for cold-water aquatic life, is not less than 8.0 mg/L as an absolute minimum (OAR-340-041-0016). Similarly, inorganic carbon (i.e., carbon dioxide) is consumed and released through photosynthesis and respiration. Through the carbonate balance, as inorganic carbon is consumed, the concentration of the hydrogen ion decreases which increases the pH. Alkalinity, which dampens the daily swing in pH, is 36

naturally low in the Umpqua Basin (ODEQ 2006). The Water Quality standard for pH in Willow Sump is 6.5 to 8.5; a pH outside this range is considered not meeting the standard (OAR-340-041-0326). Diurnal algae-driven pH cycles within Little River where pH has been monitored can be as extreme as 9.1 in late afternoon and 7.8 in the morning. Algae growth also has seasonal fluctuations which affect nutrients, as algae numbers increase, sometimes exponentially during “blooms”, then crash when nutrient availability decreases and other conditions change. Elevated nutrient concentrations, specifically phosphorus and nitrogen, encourage plant growth. There are a number of natural processes that add nutrients to water including leaching from the soil and degradation of plant material. As the plants grow, they consume phosphorus and nitrogen. As plants respire and die, nutrients are released back into the water. Plants consume nitrogen and phosphorus at a fixed ratio, therefore, if one nutrient is in short supply, it will limit the growth regardless of the concentration of the other nutrient. The state of Oregon has established water quality standards set out in Chapter 340, Division 41 of the Oregon Administrative Rules. Water bodies that do not meet state water quality standards are termed “water quality limited” and are placed on a list in accordance with Section 303(d) of the federal Clean Water Act (303(d) list). Neither Willow Sump nor the unnamed stream that drains it is 303(d) listed for water quality. Emile Creek, 0.7 miles downstream was 303(d) listed in 1998 for summer rearing temperature (exceeding a 7-day average maximum temperature of 64.4 degrees F) and summer pH (exceeding 8.5)(Table 14). In the Little River Watershed, analysis has established that pH is closely linked with temperature, and as temperature is decreased, pH will meet the standard. The Little River Watershed TMDL, approved in 2002, addressed both parameters (ODEQ 2001), but it is likely that both standards are still not being met.

Table 3. Water Quality Limited Streams downstream of the Project Area.

Waterbody River mile Parameter Season Emile Creek 0 to 1.0 Rearing Temperature Summer Emile Creek 0 to 7.5 pH Summer

No long term or continuous water quality monitoring has been done in Willow Sump. On 8/8/12, the temperature near the surface of the Willow Sump was 72 degrees F, and at a depth of 18” it was 66 degrees F. On 9/10/12 (a cloudy day) at 11:35 the water temperature was 64 degrees, and pH was 7.4.

Direct Effects Direct effects in the context of water quality are those that would occur in Willow Sump and are triggered immediately as a result of the Willow Sump alternatives. Under Alternative 1, Yellow floating heart would continue to reduce habitat for native macrophytes and reduce photosynthesis of phytoplankton where they are shaded out.

Under Alternative 2, some short-term adverse effects related to the application of herbicide would occur when either Glyphosate or Imazapyr would be applied, but eradication of this non-native species would also restore native species habitat and water quality. Differences in toxicities to aquatic species are sometimes substantial among the various glyphosate formulations. Treatment in Willow Sump would use one of the less toxic formulations of aquatic glyphosate such as Rodeo or Aquamaster, along with one of the less toxic non-ionic surfactants such as Agridex (SERA 2011). The formulation that would be used in Willow Sump is an aquatic formulation which would likely contain the isopropylamine salt form of glyphosate. Glyphosate is soluble in water and tends to adsorb (bind) tightly to sediment, organic matter, and soil, becoming essentially unavailable to plants or other aquatic organisms once it enters eutrophic waters such as Willow Sump. The low mobility of glyphosate in soil indicates minimal potential for the contamination of groundwater. Herbicidal effects are limited primarily to plants which receive direct foliar application. Glyphosate degrades primarily through microbial breakdown. Half-life of glyphosate in water has been documented to be from 1.5 to 90 days depending on conditions such as pH, sediment chemistry, temperature and other variables. Many studies done in natural pond settings recorded half-life of 7 to 14 days. Most studies on toxicity to aquatic organisms consider the effects of only the glyphosate and do not assess effects from added surfactants or effects from AMPA (aminomethylphosphonic acid), a biodegradation product that also has some toxic properties similar to glyphosate. Under Alternative 2, it is expected that the application of glyphosate herbicide would kill approximately 30% of the Yellow floating heart that is treated per year; multiple years of treatments would be needed to eradicate the floating heart, with reduced amounts of herbicide being necessary each year. Some of the more sensitive non-target plants near the treated area, including algae would also likely die (see Botany section of this report for more information). An analysis of projected glyphosate levels in Willow Sump during the initial application when levels would be at their highest, shows that the peak concentration is expected to be around 0.28 mg/L, although could range between 0.14 to 0.69 mg/L. The “No Observed Adverse Effect Concentration” (NOAEC) level for sensitive algae is 0.23 mg/L and for tolerant species the NOAEC level is 59 mg/L. Austin et al. (Austin, Harris and Lucey 1991) studied the effects of glyphosate on periphyton in artificial streams and noted an increase in periphyton at concentrations of 0.0019 to 0.2874 mg/L. The authors suggest that algae are using glyphosate as a phosphorus source. Another study shows that sub-toxic levels of glyphosate can stimulate algae growth (Schaffer and Sebetich 2004). Forlani et al. (Forlani et al. 2008) found that 6 strains of Cyanobacteria showed a high tolerance for glyphosate, and were also able to utilize glyphosate as a phosphorus source under certain conditions. Given the expected concentration of glyphosate during treatment, some algae would likely be killed during treatment, but many would likely survive. Since some species are more tolerant than others, the species composition may be altered somewhat, and given the tolerance level for cyanobacteria, there may be an elevated risk of a cyanobacteria (blue-green) algae bloom as more sensitive competitors are reduced . If Imazapyr were used instead of glyphosate, the maximum concentration at application is expected to be 0.11 mg/L, but could range from 0.06 to 0.28 mg/L. Imazapyr has been found to be more effective at

killing the target species compared to Glyphosate, so it is likely that fewer treatments would be necessary to eradicate the population. However, because of this increased efficacy, non-target macrophytes would also be more likely to be killed during treatment. NOAEC levels for macrophytes range from 0.003 to 0.1 mg/L. Imazapyr is not effective at killing submergent plants; however, plants rooted near the treatment site could die if imazapyr inadvertently contacts the leaves or the soil where they are rooted. Imazapyr is highly mobile in water and is does not adsorb to sediment. Shoreline plants that have roots that extend into the water near treatment, will generally not be adversely affected by uptake of the herbicide from the water (Habitat product label). The primary mechanism for degradation is photolysis (breakdown from sunlight). Half-lives found in natural ponds ranged from 2 to 20 days in surface water (EPA, 2006), depending on conditions. Imazapyr would have little effect on algae (SERA 2011b). The peak concentration of imazapyr during treatment is expected to be 0.11 mg/L. The NOAEC for algae ranges from 7.6 to 50.9 mg/L, well above possible maximum concentrations in Willow Sump. Many of the studies on aquatic herbicides cover herbicide effects alone and do not include effects from the use of surfactant which is often recommended to increase efficacy. During application in Willow Sump, a low toxicity surfactant such as Agridex would be used. Little data is available on effects of surfactants on aquatic organisms, but a risk assessment for glyphosate states that “some surfactants such as Agri-Dex (LC50 >1000 mg/L) are virtually nontoxic, and the use of a nontoxic surfactant would have no substantial impact on the risk characterization (SERA 2011a). A risk assessment for imazapyr states that “there is no basis for asserting that the use of surfactants with imazapyr applications is likely to pose an acute hazard to aquatic species” (SERA 2011b). This statement applies only to potential acute risks. A useful compendium on the longer-term toxicity of nonionic surfactants to aquatic organisms has not been identified; thus, the potential for longer-term risks cannot be assessed. The consequent decomposition of killed plants would have some effects on dissolved oxygen, pH, nutrients and algae growth. Imazapyr would have little effect on algae, but would likely kill more macrophytes (both target and non-target) than glyphosate, although it is not considered effective on submerged plants. Some reduction in DO would result from the decreased oxygenation from reduced photosynthesis, and from decomposition of plants and algae that will die from the herbicide treatment, since decomposer bacteria consume oxygen. If DO levels become too low, aquatic organisms can suffer adverse effects, including fish kill. Another possible result of extremely reduced DO is the release of phosphorus from lake sediments into the water column. Treatments would occur during summer when water temperature will be warm; lowering the amount of DO that can be held in the water. DO is expected to decrease after treatment, but probably will not decline enough to exceed the water quality standard or lead to the release of sediment phosphorus. A large DO reduction is unlikely due to the small percentage of the lake being treated at a time (1/2 acre of a 2.2 acre lake). Some change in nutrients would be expected as plant material decays, releasing nutrients into the water; this would likely be a short term effect as surviving organisms would continue to utilize these nutrients. pH in the lake could also change somewhat as algae composition changes; this too is likely to be a short term effect as more tolerant species may be stimulated, but more sensitive ones may decrease.

To reduce the adverse effects mentioned above, herbicide that is formulated for use in water will be spot sprayed using a backpack sprayer. This method of application would minimize the inadvertent spraying on non-target plants, minimize the total amount used and limit the amount that goes directly into the water since most would be intercepted by the Yellow floating heart leaves. Treatment would only be done when no rain is predicted for at least 24 hours to prevent washing of herbicide into the water.

Indirect Effects Indirect effects are those that could either occur later in time or downstream from the proposed activities within the project site. Under Alternative 1, Yellow floating heart will likely eventually cover the entire surface of Willow Sump. This dense cover would eliminate available space and sunlight for native macrophytes and reduce photosynthesis of phytoplankton which is the foundation of the aquatic food chain. This would result in a shift of species composition throughout the lake impacting the food chain and fisheries. This disruption of nutrient cycling and productivity would be a long term effect since Yellow floating heart would likely persist indefinitely. The domination of the lake by Yellow floating heart and replacement of native plants would probably alter DO and pH although it is difficult to quantify the extent. Studies of invasive species impacts on ecology, including biogeochemistry, suggest that ecosystem alteration may be relatively common among invasive non-indigenous species (Gordon 1998) Another indirect effect that would likely result from Alternative 1, would be the spread of the Yellow floating heart to new waterbodies via fragments transported by boats or birds, or the intentional transplanting by people for horticultural purposes. This spread could lead to effects similar to those mentioned for direct effects of Alternative 1 in Willow Sump above, but in different waterbodies in the future. Under Alternative 2, if glyphosate were used, some would be carried by water and sediment into the wetland area via the outflow stream. Expected peak concentration of glyphosate in the lake during application is 0.28 mg/L. The NOAEC for sensitive macrophytes is .082 mg/L while for tolerant macrophytes; NOAEC is 170 mg/L. As the herbicide travels thru the water, the glyphosate would adsorb to sediments, lowering the concentration available for herbicidal effects. Several studies on the fate of glyphosate in ponds have found that glyphosate quickly dissipates from the water column as it adsorbs to organic and inorganic sediments (Goldsborough and Beck 1989, Tsui and Chu 2008, Newton et al. 1994). While adsorbed to sediment, glyphosate is not available for plant uptake or for microbial breakdown, the primary decomposition process that ultimately removes glyphosate and its products from the environment. The half-life of glyphosate can range from 1.5 to 70 days depending on several site specific variables that include pH and the prevalence of metals in the sediment. Many pond studies found half-lives in the 10 to 20 day range. Glyphosate that was absorbed by the target plants can also be released back into the water column as those plants decompose; increasing the time that glyphosate persists in the pond. A small flow of water would be flowing into the pond during and after application, diluting the peak concentration and microbial decomposition would further reduce the concentration in the outflow over time. Therefore, herbicidal effects to wetland plants is expected to be minimal due to 40

the targeted application of the herbicide, microbial decomposition, dilution from inflow, and the strong adsorption of glyphosate to sediments, preventing it from being readily moved downstream or taken up by non-target plants downstream (Tsui and Chu 2008). The fate of imazapyr in the aquatic environment is quite different from that of glyphosate. Imazapyr only weakly adsorbs to sediment, so it is highly mobile in the water column. The primary process for decomposition of imazapyr is photolysis; in water exposed to sunshine. This process breaks down imazapyr quickly in clear shallow water, resulting in half-lives of approximately 2 to 20 days. The extent to which photolysis will impact the degradation of imazapyr in the field, however, is likely to vary substantially with factors such as shade, turbidity, depth and whether water is stagnate or mixing. The half-life of imazapyr in pond studies in Florida and Missouri at an application rate of 1.5 ae/ac.(initial concentrations of 0.028 to 0.261 mg/L) were found to be 4 to 15 days (MDEP, 2012). Willow Sump has little shade, but turbidity is likely to slow photolysis; some mixing occurs with the very small inflow/outflow volume during summer low flow; depths are shallow to moderate, averaging about 5’ overall. Half-life used in the Willow Sump analysis was 65 days, but ranging from 25 to 180 days. Imazapyr is an effective aquatic herbicide and damage to aquatic macrophytes following aquatic applications is likely to be evident for a prolonged period of time following aquatic applications (SERA 2011b), although this effect would be variable by species, since some are more sensitive to imazapyr than others. Plants in the wetland downstream of the pond, would not likely be greatly impacted as contaminated water moves downstream. The label for Habitat, an aquatic formulation of imazapyr, states that “Shoreline plants that have roots that extend into the water in an area where the herbicide has been applied generally will not be adversely affected by uptake of the herbicide from the water.” Several potable water intakes are located downstream of the project area, but all are far enough away that chemical treatment will not affect human health. The Maximum Contaminant Level (MCL) is the highest level of contaminant that is legally allowed in drinking water. The MCL is enforceable and is typically measured in milligrams (mg) of contaminant per liter (L) of water. The MCL for glyphosate is 0.7 mg/L. The expected concentration during application in Willow Sump is 0.28 mg/L, with a maximum possible of 0.68 mg/L. No MCL has been established for Imazapyr at this time. The expected concentration of imazapyr in the water during treatment is 0.11 mg/L. The requirements for use concerning potable water intakes on the product labels for Rodeo and Aquamaster (aquatic glyphosate formulations) and Habitat (aquatic imazapyr formulation) specify the products are not to be applied within 0.5 mile of an active potable water intake. The nearest water intake for drinking water consumption downstream of the Willow Sump project area is located approximately 8.2 miles downstream in Little River. The concentration of glyphosate in the water during application would not exceed the MCL for glyphosate, and the label offsets for intakes are also being met. Glyphosate levels would fall rapidly within the pond as it adsorbs to sediment and organic particles. Imazapyr levels would also fall substantially when exposed to sunlight in the pond. Any contaminated pond water leaving the pond would flow out slowly through the small outlet stream and through the well-vegetated, low gradient wetland area for approximately 0.7 miles. This slow flow and filtering would allow remaining chemicals to be further degraded or adsorbed before entering Emile Creek. Water then flows approximately 6.4 miles in Emile Creek before joining Little River which has a 45,300 acre drainage basin 41

above this confluence. Baseflow discharge at the mouth of Emile Creek was 0.7 cubic feet/second (5.2 gallons/second) on 9/1/07 and discharge in Little River just downstream from the nearest water intake, was 14.4 cubic feet/second (107 gallons per second) on 8/12/07. The amount of dilution, adsorption and degradation occurring before treated Willow Sump water would reach the potable water intakes, would result in undetectable levels of chemical at the intakes.

Aquatic Conservation Strategy The Aquatic Conservation Strategy (ACS) was developed to restore and maintain the ecological health of watersheds and aquatic ecosystems contained within them on public lands (USDA/USDI 2004). Complying with ACS objectives means that an agency must manage the riparian-dependent resources to maintain the existing condition or implement actions to restore conditions. Improvement relates to restoring biological and physical processes within their ranges of natural variability. Consistency with the nine ACS Objectives is found below:

1. Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale features to ensure protection of the aquatic systems to which species, populations and communities are uniquely adapted. If left untreated under Alternative 1, the spread of Yellow floating heart could displace native aquatic plants at other sites throughout the watershed and across the landscape. Alternative 2 contributes to a restorative effect on Objective 1 by eradicating an invasive plant which is currently displacing native aquatic plants.

2. Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, longitudinal, and drainage network connections include floodplains, wetlands, upslope areas, headwater tributaries, and intact refugia. These network connections must provide chemically and physically unobstructed routes to areas critical for fulfilling life history requirements of aquatic and riparian-dependent species. It is possible that under Alternative 1, connectivity for some small species could be degraded if the Yellow floating heart population becomes widespread and dense enough to affect their movement, either in Willow Sump or at another site where plants are spread to. Alternative 2 would not affect connectivity at the site or watershed scale, and so is consistent with this objective.

3. Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom configurations. Neither alternative would likely influence the physical integrity of banks and bottoms in Willow Sump, however If left untreated under alternative 1, Yellow floating heart could spread and inhabit new sites, including slow-moving stream areas where a dense growth of Yellow floating heart could lead to channel deposition, hence alteration in channel morphology over time. Under Alternative 2, physical integrity would be maintained.

4. Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. Water quality must remain within the range that maintains the biological, physical, and chemical integrity of the system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and riparian communities. No adverse impacts to water quality would occur from herbicide application under Alternative 1, however the colonization by Yellow floating heart

would continue. Studies of invasive species impacts on ecology, including biogeochemistry, suggest that ecosystem alteration may be relatively common among invasive non-indigenous species (Gordon 1998)

As disclosed above under the Water Quality discussion, some adverse effects are expected under Alternative 2 since the use of chemical herbicide would affect water chemistry and phytoplankton. These effects are expected to be short term and would only impact an extremely small percentage of the watershed. Many BMP’s and Project Design Features are required in order to reduce the adverse impacts to water quality as much as possible.

5. Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the sediment regime include the timing, volume, rate, and character of sediment input, storage, and transport. Neither alternative would likely influence the sediment regime in Willow Sump, however if left untreated under Alternative 1, Yellow floating heart could spread and inhabit new sites, including slow-moving stream areas where a dense growth of Yellow floating heart could lead to some channel deposition where fine sediments are captured and stored. Under Alternative 2, sediment regime would be maintained.

6. Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic and wetland habitats and to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial distribution of peak, high, and low flows must be protected. Neither alternative would likely influence in-stream flows so Objective 6 would be met under either alternative.

7. Maintain and restore the timing, variability, and duration of floodplain inundation and water table elevation in meadows and wetlands. Neither alternative would likely influence the water table in Willow Sump, however Under Alternative 1; Yellow floating heart could spread to other waterbodies, which could include slow-moving streams. If such an infestation became large, it could potentially alter streamflow and sediment routing, leading to alteration of floodplain inundation. Under Alternative 2, instream flows would be maintained to flow that occurs under natural vegetation conditions.

8. Maintain and restore the species composition and structural diversity of plant communities in riparian areas and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody debris sufficient to sustain physical complexity and stability. The establishment and expansion of the Yellow floating heart population in Willow Sump has reduced space and nutrients for native plants, and habitat for native animals that depend on native aquatic plants. Under Alternative 1, Yellow floating heart would continue to reduce habitat for native macrophytes and reduce photosynthesis of phytoplankton where they are shaded out, thereby altering the food web. Alternative 2 would restore native species composition and structural diversity of the aquatic plant community that existed before Yellow floating heart establishment at the site level, and would prevent the degradation of habitat at other sites if the Yellow floating heart were to spread.

9. Maintain and restore habitat to support well-distributed populations of native plant, invertebrate and vertebrate riparian-dependent species. The establishment and expansion of the Yellow floating 43

heart population in Willow Sump is creating a monoculture with reduced space and nutrients for native plants, and habitat for native animals that depend on native aquatic plants. Under Alternative 1, Yellow floating heart would continue to reduce habitat for native macrophytes and reduce photosynthesis of phytoplankton where they are shaded out. Alternative 2 would restore the aquatic habitat that existed before Yellow floating heart establishment at the site level and would prevent the degradation of habitat at other sites if Willow Sump Yellow floating heart were to spread.

Cumulative Effects Cumulative effects are the relevant impacts on the environment which result from the incremental impact of the proposed action when added to other past, present, and reasonably foreseeable future actions. Under alternative 1, Yellow floating heart is likely to persist and spread within Willow Sump, and possibly to other waterbodies, causing some adverse effects to water quality and aquatic habitat that would add to the adverse effects of other aquatic invasive populations that exist currently or in the future within the watershed. Currently no such sites are known in the watershed, but could occur on private land. No adverse effects from herbicide application would occur under Alternative 1 that would add to cumulative effects. Under Alternative 2, short-term adverse effects to water quality and aquatic habitat would occur from herbicide application that would add to similar cumulative effects. Within the immediate vicinity of Willow Sump, and the inlet and outlet streams, water quality was probably adversely affected by the application fertilizer and pesticide in the past during timber harvest, but these activities have not occurred on forest service projects in recent past. Farther downstream, pesticides and fertilizers are still being used that could affect Little River water quality, but the small quantity of herbicide used in the Willow Sump project, and the degradation and dilution of the herbicide before reaching Little River, there would be no incremental effect when combined with the impacts of other past, present, and reasonably foreseeable future activities.

Fisheries

Existing Conditions The Little River Watershed Analysis provides a detailed description of fish habitat in the planning area and is incorporated by reference into this document. The following paragraphs summarize key information regarding habitat conditions relevant to the Willow Sump treatment project.

Aquatic Biological Evaluation and Essential Fish Habitat There are four fish species and two aquatic mollusk species that have special status on the Umpqua National Forest: Oregon Coast (OC) Coho salmon (Federally listed as threatened under ESA) - Oregon Coast Coho salmon (Oncorhynchus kisutch) use within the Little River watershed extends from the mouth upriver to just below the Black Creek confluence. Coho salmon are also found to occupy the 44

lower reaches of several large tributaries to Little River: Emile Creek, Wolf Creek/Egglestron Creek, Jim Creek, and Cavitt Creek. The Coho salmon distribution in Emile Creek is limited to the lower reach for approximately one mile above Little River.

Coho salmon use the Emile Creek sub-watershed for spawning, rearing, and migration.

1) Pacific Coast (PC) chum salmon (FS Sensitive) - Chum salmon (O. keta) have not been known to occur in the North Umpqua Sub-basin. Chum salmon are located approximately 180 miles downstream of the Willow Sump planning area.

2) Oregon Coast (OC) steelhead trout (FS Sensitive) - Steelhead (O. mykiss) is the most abundant and widely distributed anadromous salmonid in the North Umpqua Sub-basin, including the Little River watershed. Steelhead trout distribution extends approximately three miles above the Black Creek confluence in mainstem Little River. Steelhead also occupy the lower reaches of most major tributaries to Little River, including Taft Creek, Clover Creek, Black Creek, White Creek, Negro Creek, Emile Creek, Wolf Creek, Greenman Creek, Cavitt Creek, Jim Creek, and other smaller tributaries.

Steelhead use in Emile Creek is limited to the lowest reach and totals approximately one mile of suitable habitat. Steelhead use Emile Creek for spawning, rearing, and migration.

3) Umpqua Chub (FS Sensitive) - The Oregon chub (Oregonichthys crameri) is endemic to the Umpqua River Basin (the mainstem Umpqua River, South Umpqua River, and to a lesser extent North Umpqua River). Habitat selection by the chub is moderate to slow flowing water (runs and channel margins). Surveys conducted in 1998 indicated distribution extended up the North Umpqua River to an area that is approximately 30 miles downstream from the Willow Sump planning area.

4) Rotund Lanx (FS Sensitive) - The rotund lanx (Lanx subrotuna) is known to occur within the Little River watershed. The rotund lanx is a small freshwater limpet and the current distribution appears to be scattered and local in portions of the Umpqua River below the confluence with Little River, all of Little River, portions of the South Umpqua and major tributaries above Roseburg, and Cow Creek. The rotund lanx is found in unpolluted rivers and large streams at low to moderate elevations. They prefer highly oxygenated, swift-flowing streams with stable cobble, boulder or bedrock substrates. They are not typically found where aquatic macrophytes and epiphytic algae occur. A 2006 aquatic mollusk survey found this species in the mainstem North Umpqua. They have never been identified in Emile Creek.

5) Western Ridged Mussel (FS Sensitive) – The Western ridged mussel (Gonidea angulata) is suspected to occur on the Umpqua National Forest, however no known sites occur within the Little River watershed. Western ridged mussels occur in streams of all sizes and are rarely found in lakes or reservoirs. They are found mainly in low to mid-elevation watersheds, and do not often inhabit high elevation headwater streams where western pearlshells can be found. They

often share habitat with the western pearlshell throughout much of the Pacific Northwest. They are more tolerant of fine sediments than western pearlshells and occupy depositional habitats and banks. They can withstand moderate amounts of sedimentation, but are usually absent from habitats with unstable or very soft substrates. Lack of information on life history, reproduction, and ecology of western ridged mussels will hinder effective conservation and management. The Western ridged mussel has not been identified in Emile Creek.

Direct and Indirect Effects The proposed action will not authorize any activities that would modify in-stream habitat or otherwise directly affect fish or sensitive aquatic invertebrates or habitat; thus, there are no measurable direct effects associated with any alternative. No meaningful direct impacts to the species described above living in the Emile Creek sub-watershed are expected from the treatment proposed under the action alternative. This conclusion is based on the following rationale: the mitigation measures to only treat Willow Sump when no or very limited outflow is occurring, , utilizing herbicides that pose low risk to fish and aquatic organisms, and limit spraying to when winds are between 2-8 mph will minimize the amount of herbicide that has the potential to travel downstream. Further, given the fact that no listed or sensitive fish species or their habitat is present in Emile Creek for over ten stream miles ensures that any residual herbicide in the water column will be adsorbed to organic matter or otherwise become biologically unavailable before active herbicide can reach anadromous habitat. None of the connected actions described in Chapter 2 proposed under the action alternative would result in any indirect effects over the long-term or in downstream areas as described previously. All of these connected actions are minor activities of limited scope and duration. As such, the connected actions would have little chance of resulting in a negative effect to water quality or instream habitats, but may have long term beneficial effects.

Cumulative Effects The Willow Sump action alternative does not have the potential to result in any meaningful cumulative effects to threatened or sensitive aquatic species because no direct or indirect effects are anticipated to occur.

Aquatic Conservation Strategy No meaningful or measurable negative impacts to habitat elements or the associated beneficial uses of water are expected from the proposed activities as described in Chapter 2. The project as proposed is not expected to impact the attainment of the aquatic conservation strategy objectives at the watershed scale.

Determination of Effects

Essential Fish Habitat – No Adverse Affect As discussed above throughout this aquatic section, it is unlikely that downstream effects would occur that would adversely affect any Essential Fish Habitat as defined under the Magnuson-Steven Fishery 46

Conservation and Management Act (MSA) for salmon commercial fisheries. EFH is further addressed in the Fisheries Biological Assessment (Appendix XX).

Listed/Sensitive Fish and Aquatic Invertebrate Species Oregon Coast Coho Salmon: No Effect (NE). Pacific Coast Chum Salmon, Umpqua Chub, Oregon Coast Steelhead, Western Ridged Mussel, and Rotund Lanx: No Impact (NI) The Willow Sump treatment area was designed in part to minimize negative effects to aquatic resources, while still meeting the resource objectives associated with the project. The implementation of this project would likely result in effects of discountable probability or insignificant/immeasurable magnitude to the chemical contamination indicator. Neutral effects are expected to the temperature, sediment/turbidity, substrate, large wood, peak/base flows, pool frequency, large pools, off-channel habitat, width/depth ratio, barriers, refugia, stream banks, floodplain connectivity, and drainage network indicators. The proposed action will have no direct, indirect, or cumulative effects to listed fish species or critical habitat. No actions are proposed within a reasonable proximity to listed critical habitat or that would directly affect the channels of any stream reaches which may be inhabited by listed fish species.

Table 4. Determination of effects to Threatened and Sensitive Aquatic Species.

Species Alt 2

OC Coho salmon and designated critical habitat NE

Oregon Coast steelhead (sensitive) NI

Umpqua Oregon chub (sensitive) NI

Pacific Coast chum salmon (sensitive) NI Rotund Lanx NI Western Ridged Mussel NI

Threatened and Sensitive Wildlife Species The National Forest Management Act (16 U.S.C. 1600) requires the Forest Service to maintain viable populations of existing native and desired non-native wildlife when projects are planned (36 CFR 219.19). Guidelines for each planning area must provide for a diversity of plant and animal communities based on the suitability of the specific land area. The Forest Service established a Sensitive Species Program and a Biological Evaluation process (FSM 2672.4) to ensure species population viability. 47

Regional Foresters are responsible for identifying and maintaining a list of sensitive species occurring within their region. This list includes species for which there is a documented concern for viability within one or more administrative unit within the species’ historic range (FSM 2670.22, WO Amendment 2600- 95-7). These species may require special management emphasis to ensure their viability and to preclude trends toward endangerment that would result in the need for Federal listing. This regional list was last updated on December 01, 2011. The Forest Service Manual (FSM 2672.4) requires a biological evaluation to determine potential effects of proposed activities on sensitive species. This evaluation analyzes alternatives and discusses the potential effects on the population or its habitat within the area and on the species as a whole, and makes recommendations for removing, avoiding, or compensating for adverse effects. In addition, the Umpqua National Forest’s Land Management Plan standard and guidelines for wildlife (USDA 1990) states:

6. Any management activity that will negatively affect plant or animal species listed on the Regional Forester’s Sensitive Species list, or their habitat will be modified to either avoid (preferable) or minimize the impact. Activities will not be permitted if they will result in the loss of a colony or subpopulation that is important in the natural distribution of the species.

A pre-field review was performed to determine which sensitive species are most likely to be impacted by the proposed action. Table XX provides a list of the 2011 Regional Forester’s sensitive wildlife species for the Umpqua National Forest and status on the North Umpqua Ranger District. Table XX summarizes the presence or absence and potential impacts on these species and/or their habitat within or adjacent to Willow Sump associated with the pre-field review. It is based on the latest documented survey and occurrence data, scientific literature review, GIS analysis and field review. Impact or effect determinations are made for each species based on this review. If an impact or effect is anticipated, further analysis and discussion of the direct, indirect and cumulative effect or impact is provided.

Direct, Indirect, and Cumulative Effects Direct effects are defined as those effects that would occur as a result of project implementation. Indirect effects are those that are related to the project and would potentially occur at a later time and place. Cumulative effects are the effects of the project that would incrementally add to other past, present, or reasonably foreseeable activities. Past timber management and associated activities, road building and maintenance, prescribed burning, and habitat restoration have all occurred in the watershed where Willow Sump is located. There are no reasonably foreseeable activities that will occur in the Willow Sump project area.

Table 5. Threatened and Sensitive Wildlife on the Umpqua National Forest, North Umpqua RD from Regional Foresters Revised List, December 2011.

Common Name Scientific Name Habitat Description and Information

Common Name Scientific Name Habitat Description and Information Northern spotted owl Strix occidentalis caurina Old growth conifer forests or younger forests with old growth remnant structures such as large trees, snags and down wood. Structural components required for food, cover, nest sites, and protection from weather and predation. Documented on the Umpqua National Forest (UNF) including the North Umpqua Ranger District. Johnson’s hairstreak Callophrys johnsoni Late successional conifer forests; larvae feeds on dwarf mistletoe (Arceuthobium) growing primarily on western hemlock (Tsuga heterophyla); to a lesser degree on other conifers. Documented on the UNF including the North Umpqua Ranger District. Coronis fritillary Speyeria coronis coronis Wide-ranging in many habitats; associated with lower elevation canyons and grasslands as well as mid-montane meadows and forest margins; larvae feed on violet. Suspected on the UNF. Mardon skipper Polites mardon Isolated populations in grassy lowlands or subalpine meadows; rocky serpentine meadows; larvae feed on grasses. Closest population is in Siskiyou mountains. Suspected on the UNF. Siskiyou short-horned Chloealtis aspasma Grassland-dependent; occurs in grassland/ herbaceous habitats and appears to be associated grasshopper with elderberry plants. Closest population is in Siskiyou mountains. Suspected on the UNF. California Shield-Backed Vanduuzeeina borealis A tall grass prairie specialist, this subspecies Bug californica inhabits medium to high elevation (2950 feet) in natural balds and meadows. Suspected on the UNF. Gray-Blue Butterfly Plebejus podarce Inhabits high elevation wet subalpine meadows; known from Oregon south through the Sierra klamathensis Nevada; formerly considered a subspecies of the Arctic Blue butterfly. Documented on the UNF, Diamond Lake Ranger District. Evening fieldslug Deroceras hesperium Low to mid-elevations; associated with perennially wet meadows in forested habitats with a variety of low vegetation, litter, and debris; rocks may be used. Suspected on the UNF. Leaf litter; mature and old forests; some specimens found in Lane County. Suspected on Cascade Axtail Slug Carinacauda stormi the UNF. Oregon Shoulderband Helminthoglypta hertleini Prefers areas of herbaceous vegetation in rocky areas such as talus deposits and outcrops;

deciduous leaf litter and/or woody debris; woody debris often used as refugia. Documented on the 49

Common Name Scientific Name Habitat Description and Information UNF, Tiller Ranger District. Chace sideband Monadenia chaceana Found in rocky areas, talus deposits and riparian areas although rocky forested habitats are

preferred; also associated with large woody debris or leaf litter and herbaceous vegetation in more mesic, forested habitats. Documented on the UNF; Tiller, North Umpqua and Diamond Lake Ranger Districts. Crater lake tightcoil Pristiloma arcticum crateris Associated with perennially wet environment in mature conifer forests and meadows above 2000’ in vegetation or under rocks and woody debris; suitable habitat is generally within 10 meters of open water; found in areas that remain under snow for long periods in the winter. Documented on the UNF, Diamond Lake Ranger District. Red-Necked Grebe Podiceps grisegena Winters on the Pacific and Atlantic oceans, breeds on freshwater lakes. Consistently breeds only at

Klamath Lake. One summer record for Diamond Lake (1931); extremely rare in winter away from the coast; would be a rare migrant on the Diamond Lake Ranger District. Horned Grebe Podiceps auritus Favors large areas of open water; open water with shallow margins and tall emergent vegetation for

breeding; forages in open fresh or salt water. Rare breeder east of the Cascades; uncommon winter resident of Umpqua valley in areas of open, ice- free water. Documented on the UNF, Diamond Lake Ranger District. Foothill yellow-legged frog Rana boylii Ranges from northwest Oregon to Baja California. Usually found near streams and rivers; most common in low gradient reaches with exposed bedrock and gravel/cobble bars with gravel substrates. Documented on the UNF, North Umpqua and Tiller Ranger Districts. Oregon spotted frog Rana pretiosa Marshes, lakes and ponds with warm shallow water and in some cases slow-moving streams;

marsh specialist. There have been no detections of this species although surveys for it have been conducted. Suspected on the UNF. Northern Pacific pond Actinemys marmorata Inhabits marshes, ponds, lakes or slow-moving turtle portions of rivers and streams; altered habitats marmorata such as reservoirs and abandoned gravel pits. Large amounts of emergent logs, vegetation or rock are needed for basking and cover; sparse vegetation - usually short grasses or forbs - characterize most nesting areas. Documented on 50

Common Name Scientific Name Habitat Description and Information the UNF; North Umpqua and Tiller Ranger Districts. Bufflehead Bucephala albeola Uncommon spring migrant and common fall migrant. Summers on wooded lakes and rivers; nests in tree or snag cavities near High Cascade lakes and ponds; winters on lakes that do not completely freeze over; also coastal waters. Documented on the UNF, Diamond Lake Ranger District. Black swift Cypseloides niger Aerial feeder; forages for flying insects over forests and open areas. Nests in small colonies on ledges or mountain crevices in dark inaccessible sites with unobstructed flight path; associated with waterfalls. Forages over several square kilometers. Documented on the UNF; North Umpqua, Cottage Grove and Diamond Lake Ranger Districts. American peregrine falcon Falco peregrinus Vertical rock cliffs with ledges or potholes. Nests on horizontal ledges or small caves, often near anatum prominent riparian habitat such as rivers or wetlands. Documented on the UNF; North Umpqua, Tiller and Diamond Lake Ranger Districts. Yellow Rail Coturnicops noveboracensis Summers in wet meadows and marshes; winters on grasslands, fields, and coastal marshes.

Considered a very local summer resident of the Klamath Basin and a vagrant elsewhere. Although surveys have been conducted, there are no records for this species on the Forest. Suspected on the UNF. Lewis’s Woodpecker Melanerpes lewis Open pine forests and oak woodlands near water; primary cavity excavator; migrant in Douglas

County. Documented on the UNF, Diamond Lake Ranger District. White-headed Picoides albolarvatus Open ponderosa pine stands or mixed conifer Woodpecker forests dominated by ponderosa pine. Primary

cavity excavator; permanent resident in upper

reaches of the Umpqua River basin. Documented on the UNF, Diamond Lake Ranger District. Purple Martin Progne subis Aerial feeding habitat generalist; found in open areas; prefers open water source with nearby

foraging habitat. Rare breeder in Douglas County. Suspected on the UNF. Bald Eagle Haliaeetus leucocephalus Uses scattered old-growth conifer trees in proximity to open water near rivers, lakes, and reservoirs with plentiful prey. Feeds primarily on

Common Name Scientific Name Habitat Description and Information fish, but will also eat waterfowl and carrion. Documented on the UNF; breeds on Diamond Lake Ranger District. Harlequin Duck Histrionicus histrionicus Found along swift, rocky, large streams or rivers. During the breeding season, adults require fast- flowing water with midstream loafing sites nearby. Nests on ground under the shelter of vegetation, rocks, or large woody debris in close proximity to water. Documented on the UNF; North Umpqua, Diamond Lake, and Tiller Ranger Districts. Pacific pallid bat Antrozous pallidus pacificus Found in open, arid habitats as well as oak and ponderosa pine forests. Roosts in caves, mines,

man-made structures, trees and snags. Ground feeder that requires open areas to forage. Suspected on the UNF. Pacific fringed myotis Myotis thysanodes Uses caves, mines, buildings, bridges, trees and vespertinus snags. Forages for insects; aerial feeder but can glean from foliage and ground. Documented on the UNF; North Umpqua and Tiller Ranger Districts. Townsend’s big-eared bat Corynorhinus townsendii Uses caves for breeding and hibernation; maternal colony on North Umpqua RD. Documented on the

UNF; all Ranger Districts. Pacific fisher Martes pennanti Utilizes large late-successional forest patches interconnected with other forest patches. Diet consists of small and medium-sized forest mammals. Large dead wood important; uses ground burrows, tree cavities, witches brooms or other clumped growth; most maternal females use tree cavities of large trees and snags. Documented on the UNF; Diamond Lake and Tiller Ranger Districts. Wolverine Gulo gulo Associated with remote, high elevation subalpine/alpine forests to above timberline; large

home ranges. Found in a variety of habitats; feed on big game and small mammals. Surveys have been conducted on the forest but there have been no confirmed detections of this species. Suspected on the UNF.

Table 6. Wildlife Threatened and Sensitive Species pre-field review and summary

Species or habitat present Threatened and Sensitive in (or adjacent to) project Impact (or effect) Potential loss of viability expected as a result of or a trend toward Species area? the project? listing? Northern spotted owl Adjacent foraging habitat No effect No Johnson’s hairstreak No suitable habitat present No impact No Coronis fritillary No suitable habitat present No impact No Mardon skipper No suitable habitat present No impact No Siskiyou short-horned No suitable habitat present No impact No grasshopper California Shield-Backed Bug No suitable habitat present No impact No Gray-Blue Butterfly No suitable habitat present No impact No Evening fieldslug No suitable habitat present No impact No Cascade Axtail slug No suitable habitat present No impact No Oregon Shoulderband No suitable habitat present No impact No Chace sideband No suitable habitat present No impact No

Low probability of species Not Likely to Contribute presence; potential habitat to a Trend towards May impact individuals Crater Lake tightcoil occurs adjacent to the Federal Listing or loss of or their habitat project area viability to the population or species. Not Likely to Contribute Low probability of species to a Trend towards presence; potential habitat May impact individuals Red-Necked Grebe Federal Listing or loss of occurs within the project or their habitat viability to the area population or species. Not Likely to Contribute Low probability of species to a Trend towards presence; potential habitat May impact individuals Horned Grebe Federal Listing or loss of occurs within the project or their habitat viability to the area population or species. Foothill yellow-legged frog No suitable habitat present No impact No Not Likely to Contribute Low probability of species to a Trend towards Oregon spotted frog presence; potential habitat May impact individuals Federal Listing or loss of occurs within the project or their habitat viability to the area population or species Species presence possible; Not Likely to Contribute Northern Pacific pond turtle May impact individuals potential habitat occurs to a Trend towards 53

Species or habitat present Threatened and Sensitive in (or adjacent to) project Impact (or effect) Potential loss of viability expected as a result of or a trend toward Species area? the project? listing? within the project area or their habitat Federal Listing or loss of viability to the population or species Not Likely to Contribute Low probability of species to a Trend towards presence; potential habitat May impact individuals Bufflehead Federal Listing or loss of occurs within the project or their habitat viability to the area population or species. Not Likely to Contribute Low probability of species to a Trend towards May impact individuals Black swift presence; potential foraging Federal Listing or loss of or their habitat habitat viability to the population or species No suitable habitat present; American peregrine falcon No impact No potential foraging impacts Not Likely to Contribute Low probability of species to a Trend towards Yellow rail presence; potential habitat May impact individuals Federal Listing or loss of occurs within the project or their habitat viability to the area population or species. Lewis’s woodpecker No suitable habitat present No impact No

White-headed woodpecker No suitable habitat present No impact No

Not Likely to Contribute Low probability of species to a Trend towards Purple martin presence; potential habitat May impact individuals Federal Listing or loss of occurs within the project or their habitat viability to the area population or species Bald eagle No suitable habitat present No impact No Harlequin duck No suitable habitat present No impact No Pacific pallid bat No suitable habitat present No impact No Pacific fringed myotis Potential foraging habitat No impact No Townsend’s big-eared bat Potential foraging habitat No impact No Pacific fisher No suitable habitat present No impact No Wolverine No suitable habitat present No impact No

There are 16 species with no suitable habitat within the Willow Sump project action area (as described above in Table 2). The Willow Sump project will have no impact on these species and they will not be discussed further.

Wildlife Effects Analysis for Herbicides

Potential effects to wildlife from the proposed use of glyphosate and imazapyr rely on the respective ecological risk assessments (2011a, b). An ecological risk assessment uses available data to evaluate the likelihood that adverse ecological effects may occur as a result of herbicide use.

Similar to the human health risk assessment, the wildlife analyses compare the toxicity value of the herbicide to the estimated dose and produces a “Hazard Quotient” that is an indicator of risk. When the Hazard Quotient is less than 1.0, the dose is less than the toxicity value. Whenever sufficient data were available to determine the dose that resulted in no observable adverse effects (NOAEL), the NOAEL was used as the toxicity value. Therefore, when a Hazard Quotient is less than 1.0, the estimated dose is less than the “no effect” dose, and potential effects are discountable.

NOAEL or NOAEC (No-Adverse-Effect-Level or No-Adverse-Effect-Concentration) data are available as the toxicity value for most non-target wildlife for imazapyr and glyphosate. For glyphosate, all Hazard Quotients for non-target birds, mammals, amphibians and invertebrates are below 1.0 (Appendix 1), so no impact to FS sensitive wildlife will occur.

Similarly, all Hazard Quotients for imazapyr are also below 1.0. Toxicity data for effects of imazapyr to amphibians is not available in the risk assessments. However, recent publications in peer-reviewed journals indicate that imazapyr is not toxic and poses a low risk to amphibians (Yahnke et al. 2013).

Discussion - Threatened Wildlife Species

Northern Spotted Owl (Strix occidentalis caurina) The Northern Spotted Owl was listed as Threatened under the Endangered Species Act (ESA) in 1990 (USDI 1990) and Critical Habitat was first designated in 1992 (USDI 1992) with additional revisions of critical habitat since that time (USDI 2008 and 2012). Spotted owls are associated with mature and old- growth coniferous and mixed conifer-hardwood forests that have the necessary structure and other characteristics suitable for nesting, roosting and foraging (USDI 2011). Nesting, roosting, and foraging habitat (NRF) for the spotted owl is strongly associated with late-successional forests containing large conifers with broken tops or cavities for nesting, multiple canopy layers for thermal regulation and protection from predation and adequate amounts of large dead wood on the forest floor to support populations of prey (Thomas et al. 1990). Northern spotted owls prey upon flying squirrels (Glaucomys

sabrinus) and woodrats (Neotoma spp.) preferentially, but they will consume other rodents (Zabel et al. 1995).

Status of the Northern Spotted Owl in the Vicinity of the Project Area There have been no recent surveys conducted for spotted owls in the area of Willow Sump. Due to the lack of recent survey data, spotted owl activity centers and home ranges within 1.2 miles (provincial home range radius) of the project area were assessed using the method identified by USDI-USDA (2008). During the final location refinement required by USDI-USDA (2008) the Forest’s level one consultation team utilized the Forest’s 2008 NRF map (Davis and Lint 2005). That analysis shows one northern spotted owl activity center at the home range distance of 1.2 miles from Willow Sump. This is a historic activity center that was confirmed in 1988.

Direct, Indirect and Cumulative Effects – Northern Spotted Owl Habitat: There is one known spotted owl home range within 1.2 miles of Willow Sump. As no spotted owl habitat will be removed or altered by actions associated with this project there are no habitat impacts to the spotted owl. Disturbance: Spotted owls can be affected through noise-generating disturbance within close proximity to both known spotted owl activity centers and spatially suitable habitat that may support nesting owls (USDI 2009). Activities that produce noise above ambient levels have the potential to disturb nesting spotted owls and disrupt normal reproductive activities. Disturbance could cause nest abandonment, flushing of adults off eggs thereby exposing them to harm, depressed feeding rates as well as avoidance of otherwise suitable habitat. For this reason, disturbance is mitigated by applying seasonal restrictions to activities that have the potential for causing disturbance. For the spotted owl, a disturbance seasonal restriction may be applied during the critical breeding period of March 1 through July 15. Activities associated with Willow Sump will not cause noise above ambient levels and may occur outside of the critical breeding period. As a result, there will be no disturbance impacts to spotted owls as a result of this project. There will be no direct or indirect effects to the northern spotted owl as a result of this project nor are there any reasonably foreseeable activities that may impact the northern spotted owl.

Critical Habitat Effects – Northern Spotted Owl Willow Sump is located outside of 2012 revised spotted owl critical habitat.

Effects Determination – Northern Spotted Owl and Critical Habitat

Alternative 1 Alternative 1 is the No Action alternative and has no identified direct, indirect or cumulative effects. Since this alternative reflects the current condition, there will be “No Effect” to the Northern Spotted Owl.

Alternative 2 Alternative 2 is the proposed action. As the Willow Sump Project will not remove or degrade any suitable spotted owl habitat nor will it cause disturbance to spotted owls, this project will have No Effect on the northern spotted owl. As Willow Sump is located outside of 2012 designated critical habitat and no habitat will be altered with this project, there will be No Effect to northern spotted owl critical habitat.

Discussion - Sensitive Wildlife Species

Crater Lake Tightcoil (Pristiloma arcticum crateris)

Existing Condition - Crater Lake Tightcoil This species is found sparsely distributed throughout the Oregon Cascades, at moderate to high elevations, ranging from 2750 – 6400 feet (Duncan 2004). Habitat is defined as perennially moist situations in mature conifer forests and meadows among rushes, mosses and other surface vegetation or under rocks and woody debris within 33 feet of open water in wetlands, springs, seeps and streams. It generally occurs in areas which remain under snow for long periods in the winter. Riparian sites which experience periodic flooding or large fluctuations in water level are not suitable habitat for this species. Loss or degradation of wetland habitat leading to loss of populations at sites occupied by the Crater Lake Tightcoil is considered to be the major threat to the species. Activities that compact soils or snow, disturb ground vegetation and/or litter, remove woody debris, alter temperature and/or humidity of the microsite, or alter the water table could be harmful to the habitat of this species. These activities include water diversions and improvements, livestock grazing and timber harvesting activities (Duncan 2004). Conservation measures for this species include minimizing temperature and humidity fluctuations in perennial wet areas. This includes maintaining natural understory vegetation and organic litter and coarse woody debris on the ground. The Crater Lake tightcoil has been documented at 174 sites in Region 6 and has been located on both sides of the Oregon Cascades. Nineteen of these sites are on the Umpqua National Forest and represent a total of 77 individuals detected from 2000 - 2003. All observations on the Forest are on the Diamond Lake Ranger District. The Crater Lake tightcoil was not encountered during the initial field review for this project and has not been documented on the North Umpqua Ranger District. The closest known species occurrence to Willow Sump is 23 miles to the southeast in the Clear Creek tributary of Fish Creek on the Diamond Lake Ranger District.

Direct, Indirect and Cumulative Impacts - Crater Lake Tightcoil There is a low probability of this species occurring in the project area as there have been numerous project-level surveys on the North Umpqua Ranger District with no detections of the Crater Lake Tightcoil. No ground disturbance will occur in riparian habitat adjacent to Willow Sump nor will terrestrial habitat be treated. However, it is possible that this species could be present along the edge of Willow Sump at the time of treatment If so, this could result in potential trampling of individuals or 57

poisoning from spray drift, which could impact individuals of this species if they were to be present in the project area at the time of treatment. Willow Sump is part of a much larger complex of wetland habitat in the area of Willow Flats. There are 89 acres of wetland habitat in this wetland complex, of which Willow Sump comprises two acres. In the larger context of habitat in the Willow Flats area the proposed action will have minimal, if any, impact to habitat utilized by the Crater Lake Tightcoil. There are very limited potential direct and indirect effects of the proposed action. As there are no reasonably foreseeable activities that will occur in the Willow Sump project area, there are no cumulative effects to the Crater Lake Tightcoil.

Determination of Impacts - Crater Lake Tightcoil

Alternative 2 Alternative 2 is the proposed action. While it is unlikely that this alternative will negatively impact suitable habitat or individuals, there is that possibility if individuals are present and are trampled or contaminated. The effects determination for the Crater Lake Tightcoil is May Impact Individuals or Habitat, but Will Not Likely Contribute towards Federal Listing or Cause a loss of Viability to the Population or Species (MIIH).

Red-necked Grebe (Podiceps grisegena)

Existing Condition - Red-necked Grebe The Red-necked Grebe is a large grebe with a long, stout, yellowish bill and drab grey coloration with a pale breast during winter. Males in breeding plumage have a black cap, white cheek extending around the head, rufous neck, and brown body. Nests are made of reeds and are found along the margins of shallow freshwater lakes in the northern U.S., Canada and Alaska. They winter along coastal estuaries and to a lesser extent interior freshwater lakes and saturated marshes (Stout and Neuchterlein 1999). They feed by diving, and their prey consists of a variety of fish, aquatic invertebrates and occasionally amphibians. Threats to this species include degradation of habitat, including pollution (oil spills and bioaccumulation of pesticides and heavy metals in prey items) in wintering grounds, and loss of breeding habitat through draining of potholes for agriculture and road building (Stout and Neuchterlein 1999). The red-necked grebe has not been documented on the North Umpqua Ranger District and the closest observations of the species are 30 miles east of Willow Sump on the Diamond Lake Ranger District. Red- necked grebes have been observed on Diamond and Lemolo Lakes during the fall from September

through November (Fix 1990, Umpqua Valley Audubon 2006). It is likely that they are a regular visitor to these lakes in the fall but that they do not occur in large numbers.

Direct, Indirect and Cumulative Impacts - Red-necked Grebe The red-necked grebe was not encountered during the initial field review for this project. No red- necked grebe nests have been documented and the species is not suspected of nesting along the shoreline of Willow Sump. As the proposed action is restorative in nature it is expected that overall water quality will improve following treatment since the population of Yellow Floating Heart will decrease. This would benefit the red-necked grebe if it utilizes Willow Sump. There is the potential for minor disturbance impacts such as the temporary displacement of red-necked grebes if individuals are present during the time of treatment. If they were to utilize Willow Sump for feeding they could ingest treated water or prey. However, the effects of glyphosate at the concentrations proposed for the project are below the level of toxicity that could cause harm (Appendix 1 Table 1). The effects of imazapyr at the concentrations proposed for the project are also below the level of toxicity that could cause harm for those species tested (Appendix 1 Table 2). Treatment of Willow Sump will not reduce the ability of the pond to support the red-necked grebe. In fact, the opposite is expected as treating the population of Yellow Floating Heart will be restorative and in time will improve aquatic habitat potentially utilized by the red-necked grebe. This would benefit the red-necked grebe if it does use Willow Sump. There are very limited potential direct and indirect effects of the proposed action. As there are no reasonably foreseeable activities that will occur in the Willow Sump project area, there are no cumulative effects to the Red-necked Grebe.

Determination of Impact - Red-necked Grebe

Alternative 2 Alternative 2 is the proposed action. As the red-necked grebe has never been documented on the North Umpqua Ranger District it is highly unlikely that it utilizes Willow Sump. The proposed herbicides do not pose a risk to the red-necked grebe. The action alternative will not impact suitable habitat but it may disturb individuals if they are in the project area during treatment, therefore the determination for the red-necked grebe is May Impact Individuals or Habitat, but Will Not Likely Contribute towards Federal Listing or Cause a loss of Viability to the Population or Species (MIIH).

Horned Grebe (Podiceps auritus)

Existing Condition - Horned Grebe The Horned Grebe is a small black and white waterbird with a short, pale bill, and red eye. During the breeding season the male develops a yellow patch behind the eye, and the neck and belly turn rufous in 59

color. They breed in the northern US (including the Malheur National Wildlife Refuge), Canada, and Alaska in small to moderate sized freshwater ponds and marshes with emergent vegetation (Stedman 2000) and nest among tall vegetation in shallow water, favoring areas with much open water (NatureServe 2007). They over-winter on coastal estuaries, inland lakes, rivers and reservoirs (Stedman 2000). They feed by diving, and their prey is mainly aquatic arthropods in the summer, fish and crustaceans in the winter. Threats to this species include degradation of habitat, primarily through oil spills and pesticide accumulation in prey items (Stedman 2000). There are no records for Horned Grebe on Diamond or Lemolo Lakes (located on the Diamond Lake Ranger District) from point count monitoring of these locations from 1996-2006, suggesting that Horned Grebes do not nest at these lakes (Umpqua Valley Audubon 2006). Fix (1990) calls the Horned Grebe very uncommon, but a regular migrant in the spring and fall on Diamond and Lemolo Lakes. He observed Horned Grebes both in October 1989 and May 1988. The closest recently documented individual is 62 miles northeast of Willow Sump and was detected on the Deschutes National Forest in 2011.

Direct, Indirect and Cumulative Impacts - Horned Grebe No horned grebes were encountered during the initial field review for this project. No horned grebe nests have been documented and the species is not suspected of nesting along the shoreline of Willow Sump. As the proposed action is restorative in nature it is expected that overall water quality will improve following treatment since the population of Yellow Floating Heart will decrease. There is the potential for minor disturbance impacts such as the temporary displacement of horned grebes if individuals are present during the time of treatment. If they were to utilize Willow Sump for feeding they could ingest treated water or prey. However, the effects of glyphosate at the concentrations proposed for the project are below the level of toxicity that could cause harm (Appendix 1 Table 1). The effects of imazapyr at the concentrations proposed for the project are also below the level of toxicity that could cause harm for those species tested (Appendix 1 Table 2). Treatment of Willow Sump will not reduce the ability of the pond to support the horned grebe. In fact, the opposite is expected as treating the population of Yellow Floating Heart will be restorative and will improve aquatic habitat potentially utilized by the horned grebe. This would benefit the horned grebe if it does use Willow Sump. There are very limited potential direct and indirect effects of the proposed action. As there are no reasonably foreseeable activities that will occur in the Willow Sump project area, there are no cumulative effects to the Horned Grebe.

Determination of Impact - Horned Grebe

Alternative 2 60

Alternative 2 is the proposed action. As the horned grebe has never been documented on the North Umpqua Ranger District it is highly unlikely that it utilizes Willow Sump. The proposed herbicides do not pose a risk to the horned grebe. The action alternative will not impact suitable habitat but it may disturb individuals if they are in the project area during treatment, therefore the determination for the horned grebe is May Impact Individuals or Habitat, but Will Not Likely Contribute towards Federal Listing or Cause a loss of Viability to the Population or Species (MIIH).

Oregon Spotted Frog (Rana pretiosa)

Existing Condition - Oregon Spotted Frog The Oregon spotted frog favors lakes and slow moving streams associated with a permanent water source with a soft and muddy bottom. Spotted frogs are a marsh specialist with a strong preference or requirement for warmer waters. They are often found in water or at the water’s edge floating on the surface or resting on aquatic vegetation. Diet consists of invertebrates caught above and below the surface. Oregon spotted frogs are early to late breeders depending on elevation. Egg masses are typically deposited on top of one another in a communal fashion, not attached to vegetation, and are deposited in warmer shallow water making them susceptible to mortality due to freezing or drying (Cushman and Pearl 2007). There are no documented populations on the Forest. Amphibian surveys were conducted at Willow Sump in 2001 and no Oregon spotted frogs were detected.

Direct, Indirect and Cumulative Impacts - Oregon Spotted Frog No spotted frogs were encountered during the initial field review for this project. The Oregon spotted frog has not been documented on the North Umpqua Ranger District and was not detected at Willow Sump during amphibian surveys. However, it is possible that this species could be present at Willow Sump at the time of treatment. If so, they could be exposed to contaminated water or ingest treated water or prey. The only study available on the toxicity of imazapyr to amphibians is as yet unpublished but shows very low toxicity (www.cal-ipc.org/symposia/archive/pdf/2008/7T rumbo.pdf, accessed August 2012) (Yahnke et al.2013). Based on current risk assessments, the proposed herbicides do not pose a risk to the Oregon spotted frog (Yahnke et al.2013). Treatment of Willow Sump will not reduce the ability of the pond to support the Oregon spotted frog. In fact, the opposite is expected as treating the population of Yellow Floating Heart will be restorative and in time will improve aquatic habitat potentially utilized by the Oregon spotted frog. This would benefit the Oregon spotted frog if it does use Willow Sump. Willow Sump is part of a much larger complex of wetland habitat in the area of Willow Flats. There are 89 acres of wetland habitat in this wetland complex, of which Willow Sump comprises two acres. In the larger context of habitat in the Willow Flats area the proposed action will have minimal, if any, impact to habitat utilized by the spotted frog. However, any potential impacts to its food source are expected to be minimal if invertebrates are affected by the proposed treatment.

There are very limited potential direct and indirect effects of the proposed action. As there are no reasonably foreseeable activities that will occur in the Willow Sump project area, there are no cumulative effects to the Oregon spotted frog.

Determination of Impact - Oregon spotted frog

Alternative 2 Alternative 2 is the proposed action. As the Oregon spotted frog has never been documented on the North Umpqua Ranger District it is highly unlikely that it utilizes Willow Sump. However, it is still possible the spotted frog could be present in the project area. The proposed herbicides do not pose a risk to the Oregon spotted frog. The action alternative will not impact suitable habitat but it may disturb individuals if they are in the project area during treatment, therefore the determination for the Oregon spotted frog is May Impact Individuals or Habitat, but Will Not Likely Contribute towards Federal Listing or Cause a loss of Viability to the Population or Species (MIIH).

Northern Pacific Pond Turtle (Actinemys marmorata marmorata)

Existing Condition - Northern Pacific Pond Turtle This highly aquatic turtle occurs in streams, ponds, lakes, and wetlands. It spends much of its life in water, but requires terrestrial habitats for nesting, where it spends the winter months. In drier regions where stream habitats dry up in the summer, they were documented to use upland habitats an average of 50 m from stream channels (Rathbun et al. 2002). Reese and Welsh (1997) documented overwintering on the average about 200 meters, but as far as 500 meters from river systems, and mainly on north and east facing slopes. Prey items are ingested in the water. Preferred food items include aquatic insect larvae, crustaceans, and annelids although they will also consume Rana boylii tadpoles and egg masses (Bury 1986; Holland 1994). The greatest single threat to the pond turtle is habitat destruction, alteration and fragmentation (Ashton et al 1997, NatureServe 2007). Habitat impacts can be caused by conversion of wetlands to farmland, water diversions and dams, channelization, mining, logging, and urbanization. Associated with habitat fragmentation is the effect on genetic isolation. Lack of genetic variability may be a serious threat to the continued survival of populations in Oregon and Washington and are discussed in detail by Holland (1991). Other threats include: motor vehicle traffic, human recreation activities in occupied habitat, chemical spills, exotic predators, grazing, fire, and drought. The Northern Pacific pond turtle has been documented at two locations on the North Umpqua Ranger District, one at Lake in the Woods in the Little River drainage and the other at Cavitt Lake in the Cavitt Creek drainage. These observations took place during pond turtle surveys conducted in 1999 and 2000. There are a number of ponds on the district that have potential habitat for this species. 62

Direct, Indirect and Cumulative Impacts - Northern Pacific Pond Turtle No Northern Pacific pond turtles were encountered during the initial field review for this project. The Northern Pacific pond turtle has not been documented at Willow Sump and was not detected during amphibian surveys conducted in 2001. It is possible that the pond turtle may utilize Willow Sump as there is potential suitable habitat there. As the proposed action is restorative in nature it is expected that overall water quality will improve following treatment since the population of Yellow Floating Heart will decrease. This would benefit the pond turtle if it utilizes Willow Sump. There is the potential for direct impacts to the pond turtle if individuals are present during the time of treatment. If they were to utilize Willow Sump they could come in contact with contaminated water or ingest treated water or prey. Data is lacking for herbicide effects to reptiles. Based on the lack of risk to amphibians from glyphosate and imazapyr, it seems unlikely that pond turtles would be more susceptible than amphibians, but actual response to herbicide exposure is unknown. There may be a direct impact to the pond turtle from exposure to contaminated water and prey. The Northern Pacific pond turtle has been detected at two sites on the North Umpqua Ranger District and at 186 sites on the TLRD. It is well-distributed along the South Umpqua River as well as several of its subdrainages. In all, the pond turtle has been documented at over 500 sites in the state of Oregon ranging from the Columbia Gorge down to the very southwest corner of the state. Any potential impacts to the pond turtle as a result of the proposed treatment will have no effect to the population as a whole. Willow Sump is part of a much larger complex of wetland habitat in the area of Willow Flats. There are 89 acres of wetland habitat in this wetland complex, of which Willow Sump comprises two acres. In the larger context of habitat in the Willow Flats area the proposed action will have minimal, if any, impact to habitat utilized by the pond turtle. Treatment of Willow Sump will not reduce the ability of the pond to support the Northern Pacific pond turtle. In fact, the opposite is expected as treating the population of Yellow Floating Heart will be restorative and will improve aquatic habitat utilized by the pond turtle and its prey. As there are no reasonably foreseeable activities that will occur in the Willow Sump project area, there are no cumulative effects to the Northern Pacific Pond Turtle.

Determination of Impact - Northern Pacific Pond Turtle

Alternative 2 Alternative 2 is the proposed action. The Northern Pacific pond turtle has not been documented at Willow Sump but there is potential habitat for the species. If present, they could be exposed to contaminated water or prey. The determination for the Northern Pacific pond turtle is May Impact 63

Individuals or Habitat, but Will Not Likely Contribute towards Federal Listing or Cause a loss of Viability to the Population or Species (MIIH).

Bufflehead (Bucephala albeola)

Existing Condition - Bufflehead Buffleheads are small diving ducks that can be found on small ponds to large lakes, and larger streams and rivers. They typically nest at high-elevation forested lakes in the central Cascades, in natural tree cavities or abandoned holes of northern flickers. In freshwater, these ducks feed on aquatic insects, snails, amphipods, small fishes and some aquatic vegetation. Marshall et al. (2003) describes the species as possibly the most ubiquitous diving duck in western Oregon during the late fall through early spring. However, the breeding population is considered sensitive by ODFW because of its small size and limited nesting habitat. Threats to the bufflehead are hunting, human disturbance from high recreation use at Cascades lakes (during the breeding season) and a shortage of suitable natural nesting cavities due to forestry practices. In the winter, buffleheads are most often found in coastal areas. There are no documented observations of the bufflehead in the vicinity of Willow Sump. The nearest detection of the species is over five miles north of the project area. Ten buffleheads were observed on a private pond north of the North Umpqua River during the winter in 1993. Nesting on the Umpqua National Forest was confirmed when buffleheads nested at the sewage ponds adjacent to Diamond Lake (Fix 1990). Reproduction on the Forest was again confirmed when an adult and eight young were observed at Teal Lake just south of Diamond Lake in July of 2010.

Direct, Indirect and Cumulative Impacts - Bufflehead No buffleheads were encountered during the initial field review for this project. No bufflehead nests have been documented and the species is not suspected of nesting along the shoreline of Willow Sump. There is the potential for minor disturbance impacts such as the temporary displacement of buffleheads if individuals are present during the time of treatment. If they were to utilize Willow Sump for feeding they could ingest treated water or prey. However, the effects of glyphosate at the concentrations proposed for the project are below the level of toxicity that could cause harm (Appendix 1 Table 1). The effects of imazapyr at the concentrations proposed for the project are also below the level of toxicity that could cause harm (Appendix 1 Table 2.) Willow Sump is part of a much larger complex of wetland habitat in the area of Willow Flats. There are 89 acres of wetland habitat in this wetland complex, of which Willow Sump comprises two acres. In the larger context of habitat in the Willow Flats area the proposed action will have minimal, if any, impact to habitat utilized by the bufflehead. As the proposed action is restorative in nature it is expected that overall water quality will improve following treatment since the population of Yellow Floating Heart will decrease. Treatment of Willow Sump will not reduce the ability of the pond to support the bufflehead. In fact, the opposite is expected as treating the population of Yellow Floating Heart will be restorative and will improve aquatic habitat potentially utilized by the bufflehead. This would benefit the bufflehead if it utilizes Willow Sump.

There are limited potential direct and indirect effects of the proposed action. As there are no reasonably foreseeable activities that will occur in the Willow Sump project area, there are no cumulative effects to the Bufflehead.

Determination of Impact - Bufflehead

Alternative 2 Alternative 2 is the proposed action. The bufflehead has never been documented at Willow Sump and it is unlikely that it utilizes the pond. The proposed herbicides do not pose a risk to the bufflehead. The action alternative will not impact suitable habitat but it may disturb individuals if they are in the project area during treatment, therefore the determination for the bufflehead is May Impact Individuals or Habitat, but Will Not Likely Contribute towards Federal Listing or Cause a loss of Viability to the Population or Species (MIIH).

Black Swift (Cypseloides niger)

Existing Condition - Black swift The black swift is a summer breeding visitor to western North America. It nests in small colonies at sites behind waterfalls, in caves or deep gorges, or sea cliffs and sea caves. It remains unclear where most birds of this species spend the winter. They are thought to winter in South America. Moisture and deep shade are associated with nest site location. The general relative inaccessibility of nest sites suggests that problems at these sites are currently not a major problem, although increasing numbers of recreational rock climbers, hikers, and cave explorers using areas near waterfalls may disturb birds (Audubon Society Watchlist 2007). A more likely broad-scale threat is from a decrease in aerial insect abundance due to habitat loss and use of pesticides on breeding and wintering grounds. Birds may also be ingesting pesticides directly and bio-accumulating them in tissues, which may cause decreases in reproductive output and increases in adult mortality, especially under extreme weather conditions (Audubon Society Watchlist 2007). There is no waterfall habitat at Willow Sump although there several locations on the North Umpqua Ranger District where waterfalls can be found. There are five waterfalls on the Umpqua National Forest where black swifts have been confirmed. The nearest waterfall where the black swift has been observed is Grotto Falls which is 1.3 miles west of Willow Sump.

Direct, Indirect and Cumulative Impacts - Black swift The black swift forages on the wing over forests and open areas, often at great heights, feeding on airborne insects (Stone 2007). As the black swift may make long foraging trips during the day it is possible that it may forage in the vicinity of Willow Sump. There is the potential for minor disturbance impacts such as the temporary displacement of the black swift if individuals are foraging at Willow Sump during the time of treatment. 65

The insect prey that black swift consume are unlikely to be contaminated by the treatment of the yellow floating heart in the pond. However, to estimate potential for a “worst-case” exposure, the insect- eating small bird scenario was used to assess risk of herbicide exposure to black swift. For both glyphosate and imazapyr, even if a swift ate nothing but insects sprayed directly at the highest application rate, the HQ’s are below 1.0. For this dose to occur, black swifts would have to eat contaminated insects almost exclusively and it is very unlikely that this would happen. Therefore, there is no indication that glyphosate or imazapyr use in the proposed project poses a risk to black swift. The black swift has been documented at 40 locations throughout Region 6 from Canadian border to the southwest corner of Oregon. Any potential impacts to the black swift as a result of the proposed treatment not affect the population as a whole. There are limited potential direct and indirect effects of the proposed action. As there are no reasonably foreseeable activities that will occur in the Willow Sump project area, there are no cumulative effects to the Black swift.

Determination of Impact - Black swift

Alternative 2 Alternative 2 is the proposed action. The black swift has not been documented at Willow Sump and there is no waterfall habitat in the vicinity of the project area. If the black swift utilized the pond for aerial foraging, the consumption of contaminated insects does not indicate a risk to the birds. The action alternative may disturb individuals if they are in the project area during treatment, therefore the determination for the black swift is May Impact Individuals or Habitat, but Will Not Likely Contribute towards Federal Listing or Cause a loss of Viability to the Population or Species (MIIH).

Yellow Rail (Coturnicops noveboracensis)

Existing Condition -Yellow Rail The Yellow Rail is an incredibly secretive bird who is generally only identified by the insect like ticking vocalizations of males at night (Audubon Society Watchlist). It is a small bird with a yellow bill, buffy yellow breast, and buff and black streaked back. The yellow rail breeds in large wet meadows or marshes with sedges and grasses, while they over winter in salt marshes, rice fields and wet meadows. They feed on freshwater snails, insects, small crustaceans and seeds (Audubon Society Watchlist 2007). Threats to Yellow Rails include loss of wetland habitats required for breeding through the draining of wetlands for agriculture and flood control. They are on the Audubon Society’s Watchlist as a red species, meaning that their population is declining rapidly/and or they have small populations, face major conservation threats, and are typically threatened in their global distribution (Audubon Society Watchlist 2007).

There have been no observations of the yellow rail on the Umpqua National Forest. The closest known detection of this species is approximately 44 miles northeast of Willow Sump at Big Marsh on the Deschutes National Forest.

Direct, Indirect and Cumulative Impacts - Yellow Rail It is unlikely that the yellow rail utilizes Willow Sump, and no yellow rails were detected during the initial field review for this project. No yellow rail nests have been documented and the species is not suspected of nesting along the shoreline of Willow Sump. There is the potential for minor disturbance impacts such as the temporary displacement of yellow rails if individuals are present during the time of treatment. If they were to utilize Willow Sump for feeding they could feed on contaminated insects. There is no quantitative dose estimate available for contaminate aquatic insects. The exposure estimate for consuming directly sprayed terrestrial insects likely provides a good estimate of potential dose. So, the insect-eating small bird scenario was used to assess risk of herbicide exposure to yellow rail. For both glyphosate and imazapyr, even if a rail ate nothing but insects sprayed directly at the highest application rate, the HQ’s are below 1.0. For this dose to occur, yellow rails would have to eat contaminated prey almost exclusively and it is very unlikely that this would happen. Therefore, there is no indication that glyphosate or imazapyr use in the proposed project poses a risk to yellow rail. Willow Sump is part of a much larger complex of wetland habitat in the area of Willow Flats. There are 89 acres of wetland habitat in this wetland complex, of which Willow Sump comprises two acres. In the larger context of habitat in the Willow Flats area the proposed action will have minimal, if any, impact to habitat utilized by the yellow rail in this area. There are no negative cumulative impacts to the yellow rail associated with the action alternative. Treatment of Willow Sump will not reduce the ability of the pond to support the yellow rail. In fact, the opposite is expected as treating the population of Yellow Floating Heart will be restorative and will improve aquatic habitat potentially utilized by the yellow rail. In the long term this would benefit the yellow rail if it were to use Willow Sump. As the proposed action is restorative in nature it is expected that overall water quality will improve following treatment since the population of Yellow Floating Heart will decrease. There are very limited potential direct and indirect effects of the proposed action. As there are no reasonably foreseeable activities that will occur in the Willow Sump project area, there are no cumulative effects to the Yellow Rail.

Determination of Impact - Yellow Rail

Alternative 2 Alternative 2 is the proposed action. The yellow rail has never been documented at Willow Sump. The proposed herbicide use does not pose a risk to the yellow rail. The action alternative will not impact 67

suitable habitat but it may disturb individuals if they are in the project area during treatment, therefore the determination for the yellow rail is May Impact Individuals or Habitat, but Will Not Likely Contribute towards Federal Listing or Cause a loss of Viability to the Population or Species (MIIH).

Purple Martin (Progne subis)

Existing Condition - Purple Martin This is a common and well-known species in the eastern US, but in the Pacific Northwest this species has a patchy and irregular distribution. Preferred habitat includes lowland areas such as agricultural fields, wetlands, lakes, and shrublands that provide suitable flying insect forage base. The purple martin is a secondary cavity nester, requiring suitable woodpecker created cavities for successful reproduction (Brown 1997). The species has been recorded in two years of Audubon survey data in or around the Diamond Lake area. The closest documented sighting of the purple martin is an observation approximately 23 miles northwest of Willow Sump.

Direct, Indirect and Cumulative Impacts - Purple Martin Suitable habitat for the purple martin will not be impacted by the proposed action but its flying insect prey base may be affected. In addition, there is the potential for minor disturbance impacts such as the temporary displacement of the purple martin if individuals are foraging at Willow Sump during the time of treatment. If they were to utilize Willow Sump for feeding they could ingest treated water or prey. The flying insects that the purple martin utilizes as prey are unlikely to be exposed by the proposed treatment. However, to estimate potential for a “worst-case” exposure, the insect-eating small bird scenario was used to assess risk of herbicide exposure to Purple Martin. For both glyphosate and imazapyr, even if a purple martin ate nothing but insects sprayed directly at the highest application rate, the HQ’s are below 1.0. There is no indication that the proposed treatment poses a risk to the purple martin. The proposed action will not impact habitat for the purple martin. There are very limited potential direct and indirect effects of the proposed action. As there are no reasonably foreseeable activities that will occur in the Willow Sump project area, there are no cumulative effects to the Purple Martin.

Determination of Impact - Purple Martin

Alternative 2 Alternative 2 is the proposed action. The purple martin has not been documented at Willow Sump. However, it is still possible it could utilize the area of the pond for aerial foraging. If the purple martin were to utilize the pond for foraging, the consumption of contaminated insects does not indicate a risk to the birds. The action alternative will not impact suitable habitat but it may disturb individuals if they 68

are in the project area during treatment, therefore the determination for the purple martin is May Impact Individuals or Habitat, but Will Not Likely Contribute towards Federal Listing or Cause a loss of Viability to the Population or Species (MIIH).

Pacific Fringed Myotis (Myotis thysanodes vespertinus)

Existing Condition - Pacific Fringed Myotis This bat is often described as a cave-dwelling bat (Verts and Carraway 1998, Cristy and West 1993). However, fringed myotis are known to roost in rock crevices, bridges, buildings, large trees and snags (Cross et al. 1996, Weller and Zabel 2001). Weller and Zabel (2001) documented that habitat use by this species is influenced by the availability of large (>12 inch dbh), tall snags for roosting. Roosts tend to be near stream channels which are used for travel and foraging corridors, and also occurred in portions of stands that had lower canopy closures. Fringed myotis often utilized snags in semi-open areas and forest edges (Cross et al. 1996) and seemed to prefer snags over green trees for roosting. The Fringed myotis is very well-distributed along the Western Cascades from the Canadian border to southwest Oregon. It has been documented on all four ranger districts on the forest. The nearest detection of the species on the North Umpqua Ranger District is 5.5 miles southwest of Willow Sump on a tributary of Black Creek.

Direct, Indirect and Cumulative Impacts - Pacific Fringed Myotis There is no suitable habitat for the fringed myotis at Willow Sump that will impacted by the proposed treatment. The flying insects utilized for prey are unlikely to be exposed by the proposed treatment. However, to estimate potential for a “worst-case” exposure, the insect-eating small mammal scenario was used to assess risk of herbicide exposure to Pacific fringed myotis. For both glyphosate and imazapyr, even if a bat ate nothing but insects sprayed directly at the highest application rate, the HQ’s are below 1.0. For this to be a measurable impact fringed myotis would have to eat contaminated insects almost exclusively and it is very unlikely that this would happen. Therefore, there is no indication that the proposed treatment poses a risk to the Pacific fringed myotis. The proposed action will not impact habitat for the fringed myotis. There are very limited potential direct and indirect effects of the proposed action. As there are no reasonably foreseeable activities that will occur in the Willow Sump project area, there are no cumulative effects to the Pacific Fringed Myotis.

Determination of Impact - Pacific Fringed Myotis

Alternative 2 Alternative 2 is the proposed action. The Pacific fringed myotis has not been documented at Willow Sump. However, it is still possible it could utilize the area of the pond for aerial foraging. If the bat

utilized the pond for aerial foraging, the consumption of contaminated insects does not indicate a risk to the Pacific fringed myotis. As the Pacific fringed myotis is a nocturnal forager, disturbance to individuals during treatment is not a concern. The determination for the Pacific fringed myotis is No Impact.

Townsend's Big-eared Bat (Corynorhinus townsendii)

Existing Condition - Townsend's Big-eared Bat The Townsend's big-eared bat uses caves, abandoned mines, deep rock crevices, shaded rock overhangs, boulder talus, bridges and buildings for roosting, birthing and rearing of young. Hibernacula and maternal roost sites are the most sensitive to human disturbances (Piaggio and Sherwin 2005). The Townsend's big-eared bat is very well-distributed throughout Oregon and Washington on both sides of the Cascades. It has been documented on all four ranger districts on the forest. There are no known nursery colonies or winter hibernacula for this bat in or closely adjacent to Willow Sump. The nearest documented sighting on the North Umpqua Ranger District is a single bat observed six miles northeast of Willow Sump along Fairy Creek in the summer of 1993.

Direct, Indirect and Cumulative Impacts - Townsend's Big-eared Bat There is no suitable habitat for the Townsend's big-eared bat at Willow Sump that will impacted by the proposed treatment, but its flying insect prey base may be affected. Risk of herbicide exposure is the same as discussed above for the Pacific fringed myotis. The proposed action will not impact habitat for the Townsend's big-eared. There are very limited potential direct and indirect effects of the proposed action. As there are no reasonably foreseeable activities that will occur in the Willow Sump project area, there are no cumulative effects to the Townsend's Big-eared Bat.

Determination of Impact - Townsend's Big-eared Bat

Alternative 2 Alternative 2 is the proposed action. The Townsend's big-eared bat has not been documented at Willow Sump. However, it is still possible it could utilize the area of the pond for aerial foraging. If the bat utilized the pond for aerial foraging, the consumption of contaminated insects does not indicate a risk to the Townsend's big-eared bat. As the Townsend's big-eared bat is a nocturnal forager, disturbance to individuals during treatment is not a concern. The determination for the Townsend's big-eared bat is No Impact.

Summary of effects/impacts determinations Table 3 summarizes the determinations of effects/impacts of the proposed action at Willow Sump for Region 6 threatened or sensitive wildlife species that are documented or suspected to occur on the North Umpqua Ranger District or the Umpqua National Forest.

Table 7. Determination of Impact or Impacts to Threatened or Sensitive Wildlife Species

Species Willow Sump Proposed Action Northern spotted owl NE Johnson’s hairstreak NI Coronis fritillary NI Mardon skipper NI Siskiyou short-horned Grasshopper NI California Shield-Backed Bug NI Gray-Blue Butterfly NI Evening fieldslug NI Cascade Axetail Slug NI Oregon Shoulderband NI Chase Sideband NI Crater Lake tightcoil MIIH Red-necked Grebe MIIH Horned Grebe MIIH Foothill yellow-legged frog NI Oregon Spotted Frog MIIH Northern Pacific pond turtle MIIH Bufflehead MIIH Black swift MIIH American Peregrine Falcon NI Yellow Rail MIIH Lewis’s Woodpecker NI White-headed Woodpecker NI Purple Martin MIIH Bald eagle NI Harlequin Duck NI Pallid Bat NI

Species Willow Sump Proposed Action Pacific fringed myotis NI Townsend’s big-eared bat NI Pacific fisher NI Wolverine NI

Threatened and endangered species determination calls follow nomenclature established by the US Fish and Wildlife Service: NE= No Effect Sensitive species determinations follow nomenclature established in the Forest Service Handbook: NI= No Impact MIIH= May Impact Individuals or Habitat but will not Likely Contribute to a Trend towards Federal Listing or Cause a Loss of Viability to the Population or Species

Survey and Manage Wildlife Species On December 17, 2009, the U.S. District Court for the Western District of Washington issued an order in Conservation Northwest, et al. v. Sherman, et al., No. 08-1067-JCC (W.D. Wash.), granting Plaintiffs’ motion for partial summary judgment and finding NEPA violations in the Final Supplemental to the 2004 Supplemental Environmental Impact Statement to Remove or Modify the Survey and Manage Mitigation Measure Standards and Guidelines (USDA and USDI, June 2007). In response, parties entered into settlement negotiations in April 2010, and the Court filed approval of the resulting Settlement Agreement on July 6, 2011. Projects that are within the range of the northern spotted owl are subject to the survey and management standards and guidelines in the 2001 ROD, as modified by the 2011 Settlement Agreement. The Willow Sump Project is consistent with the Umpqua National Forest Land and Resource Management Plan as amended by the 2001 Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines (2001 ROD), as modified by the 2011 Settlement Agreement. No ground disturbing activities or harvesting of any timber will occur during the implementation of this project. Because the Willow Sump project boundary does not contain suitable habitat for any survey and manage wildlife species, surveys were not conducted within the project area.

Table 8. Survey and Manage Wildlife Species (2011) found on the Umpqua National Forest

Taxa Common Name Scientific Name Vertebrate Great gray owl Strix nebulosa Vertebrate Red tree vole Arborimus longicaudus

Mollusk Evening fieldslug Deroceras hesperium Mollusk Oregon Megomphix Megomphix hemphilli Mollusk Chace sideband Monadenia chaceana Mollusk Crater Lake tightcoil Pristiloma arcticum crateris

Table 9. Summary of Determination of Impacts to Survey and Manage Species

Habitat Present in or Species Potentially Present Species Adjacent to the in or adjacent to the Project Proposed Action Project Area Area Great grey owl No No No Impact Red tree vole Yes Yes No Impact Evening fieldslug No No No Impact Oregon Megomphix Yes Yes No Impact Chace sideband No No No Impact Crater lake tightcoil Yes Yes No Impact

Management Indicator Species The Umpqua National Forest Land and Resource Management Plan (LRMP) (USDA 1990) identified a number of terrestrial wildlife species with habitat needs that are representative of other wildlife species with similar habitat requirements for survival and reproduction. Seven species and one group of species (cavity nesters) were designated as Management Indicator Species (MIS) in the LRMP (Table 6). These species were selected to track and evaluate the effects of Forest management activities on all wildlife species that occur on the Forest.

Table 10. Management Indicator Species and Habitats They Represent

Umpqua National Forest Management Indicator Species Common Name Scientific Name Habitat Indicator Habitat Impacted? Mature/Old Growth Northern Spotted Owl Strix occidentalis caurina No Conifer Habitat Mature/Old Growth Pileated Woodpecker Dryocopus pileatus No Conifer Habitat High Elevation Mountain Pine Marten Martes americana No Hemlock/Lodgepole Pine Haliaeetus Bald Eagle Special Management No leucocephalus 73

Peregrine Falcon Falco peregrines Special Management No Cervus elaphus Roosevelt Elk Big Game Winter Range No roosevelti Blacktail Deer Odocoileus hemionus Big Game Winter Range No Cavity Nesters Snag Habitat No

There are no impacts to suitable habitat for MIS species. Potential impacts to individuals of these species may include disturbance; if so, disturbance impacts would be localized and short term, both spatially and temporally. Additional impacts to individuals may include ingesting water from Willow Sump that has been treated. The effects of glyphosate or imazapyr at the concentrations proposed for the project are below the level of toxicity that could cause harm to these species (Appendix 1). No suitable habitat for Management Indicator Species will be impacted by the proposed action. There will be no effect or impact to MIS species population trends or viability at the project or forest level with the Willow Sump Project.

Table 7 summarizes the determinations of effects/impacts of the proposed action at Willow Sump for Umpqua National Forest Management Indicator Species.

Table 11. Summary of Determination of Impacts to Management Indicator Species

Habitat Present in the Species Potentially Present Species Proposed Action Project Area in the Project Area Northern spotted owl Yes Yes No Impact Pileated Woodpecker Yes Yes No Impact Pine Marten Yes Yes No Impact Bald Eagle No No No Impact Peregrine Falcon No No No Impact Roosevelt Elk Yes Yes No Impact Blacktail Deer Yes Yes No Impact Cavity Nesters Yes Yes No Impact Pileated Woodpecker Yes Yes No Impact

Landbirds

Migratory Bird Treaty Act and Landbird Analysis Population declines of some landbirds resulted in the creation of a Landbird Strategic Plan (USDA 2000) that set management goals and actions for providing sustainable habitat for them. The Landbird Strategic Plan called for utilizing Bird Conservation Plans developed regionally by Partners in Flight working groups to incorporate landbird management into forest plans and at all levels of the Forest Service (USDA 2000). Federal land management agencies are required by treaty and executive order to consider the effects of their land management activities on a variety of bird species. Guidance for these assessments of effects includes the following:  The Migratory Bird Treaty Act of 1918 (MBTA) The MBTA implements various treaties and conventions between the U.S., Canada, Japan, Mexico and the former Soviet Union for the protection of migratory birds. Under the act, it is unlawful to pursue, hunt, take, capture (or kill) a migratory bird except as permitted by regulation (16 U.S.C. 703-704). The regulations at 50 CFR 21.11 prohibit the take, possession, import, export, transport, sale, purchase, barter, or offering of these activities, or possessing migratory birds, including nests and eggs, except under a valid permit or as permitted in the implementing regulations (Director's Order No. 131). A migratory bird is any species or family of birds that live, reproduce or migrate within or across international borders at some point during their annual life cycle. The U.S. Fish and Wildlife Service (FWS) is the lead federal agency for managing and conserving migratory birds in the United States; however, under Executive Order (EO) 13186 all other federal agencies are charged with the conservation and protection of migratory birds and the habitats on which they depend. In response to this order, the Forest Service has implemented management guidelines that direct migratory birds to be addressed in the NEPA process when actions have the potential to negatively or positively affect migratory bird species of concern.  Executive Order 13186 (66 Fed. Reg. 3853, January 17, 2001) “Responsibilities of Federal Agencies to Protect Migratory Birds

This Executive Order directs federal agencies to avoid or minimize the negative impact of their actions on migratory birds, and to take active steps to protect birds and their habitat. This Executive Order also requires federal agencies to develop Memorandum of Understandings (MOU) with the FWS to conserve birds including taking steps to restore and enhance habitat, prevent or abate pollution affecting birds, and incorporating migratory bird conservation into agency planning processes whenever possible. The Forest Service has completed, and are currently implementing, their MOU’s with the USFWS.  Forest Service & USFWS MOU:

The purpose of this MOU is, “to strengthen migratory bird conservation by identifying and implementing strategies that promote conservation and avoid or minimize adverse impacts on migratory birds through enhanced collaboration between the Parties, in coordination with State, Tribal, and local governments.” Under the MOU the Forest Service Shall:

Address the conservation of migratory bird habitat and populations when developing, amending, or revising management plans for national forests and grasslands, consistent with NFMA, ESA, and other authorities listed above. When developing the list of species to be considered in the planning process, consult the current (updated every 5 years) USFWS Birds of Conservation Concern (2008 BCC), State lists, and comprehensive planning efforts for migratory birds. Within the NEPA process, evaluate the effects of agency actions on migratory birds, focusing first on species of management concern along with their priority habitats and key risk factors. To the extent practicable:

Evaluate and balance long-term benefits of projects against any short- or long-term adverse effects when analyzing, disclosing, and mitigating the effects of actions. b. Pursue opportunities to restore or enhance the composition, structure, and juxtaposition of migratory bird habitats in the project area. c. Consider approaches, to the extent practicable, for identifying and minimizing take that is incidental to otherwise lawful activities, including such approaches as: 1. altering the season of activities to minimize disturbances during the breeding season; 2. retaining snags for nesting structures where snags are underrepresented; 3. retaining the integrity of breeding sites, especially those with long histories of use and; 4. giving due consideration to key wintering areas, migration routes, and stop-over habitats. 5. minimizing or preventing the pollution or detrimental alteration of the environments utilized by migratory birds whenever practical by assessing information on environmental contaminants and other stressors relevant to migratory bird conservation.

 PIF Bird Conservation Regions (BCR’S)

Bird Conservation Regions (BCRs) are ecologically distinct regions in North America with similar bird communities, habitats, and resource management issues. BCR’s are a hierarchical framework of nested ecological units delineated by the Commission for Environmental Cooperation (CEC). The CEC framework comprises a hierarchy of 4 levels of eco-regions. At each spatial level, spatial resolution increases and eco-regions encompass areas that are progressively more similar in their biotic (e.g., plant and wildlife) and abiotic (e.g., soils, drainage patterns, temperature, and annual precipitation) characteristics. The Umpqua falls within BCR 5 (Northern Pacific Forest).

The Partners in Flight Habitat Conservation for Landbirds in the Coniferous Forests of Western Oregon and Washington list of focal species (2012) and USFWS Birds of Conservation Concern (BCC, 2008) list for the project area was reviewed. Those species and habitats that are found within BCR 5 are described in Table 8.

Table 12. USFWS Birds of Conservation Concern (BCC) within the Partners in Flight Bird Conservation Region 5, Northern Pacific Rain forest.

Present on Bird Species Preferred Habitat the Umpqua

Winters along the coast from AK to Baja CA. Transients can be Yellow-billed Loon found on inland bodies of water. No

Prefer coastal mudflats, sandy ocean beaches, wet margins of Marbled Godwit (nb) large reservoirs or brackish lakes and sewage ponds. No

Found along the coast foraging in open estuarine tide flats, inland Red Knot (Roselaari ssp.) (nb) on margins of sewage ponds & at larger brackish lakes. No

A bird of wet mud or shallow water with underlying mud. Short-billed Dowitcher (nb) Common in tidal mudflats and adjacent shallow water. No

Aleutian Tern Primarily pelagic, coming to land only to nest and roost. No

Found in marine, coastal estuarine, salt marsh brackish and freshwater habitats near large bodies of water. Often nests on Caspian Tern islands in rivers and salt lakes. No

Arctic Tern Found offshore migrating along the coast, rarely near land. No

Found in nearshore (within 5 km) waters and within 50 miles Marbled Murrelet inland in old growth forest stands. No

Kittlitz’s Murrelet Alaskan species. No

Nests on ledges or shallow caves in steep rock faces and canyons, usually near or behind waterfalls and sea caves. Forage over Black Swift1 forests and open areas in montane habitats. Yes

Found in a variety of habitats, most likely in brushy areas with Rufous Hummingbird1 flowers and forests with a well-developed understory. Yes

Found in narrow, moist coastal fog zones in open areas of coastal Allen’s Hummingbird scrub. Nest in nearby wooded areas. Yes

Open conifer forests (< 40 % canopy cover) and edge habitats where standing snags and scattered tall trees remain after a Olive-sided Flycatcher1 disturbance. Yes

Present on Bird Species Preferred Habitat the Umpqua

Associated with riparian shrub dominated habitats, especially Willow Flycatcher (non-listed brushy/willow thickets. In SE WA also found in xeric brushy subspecies) uplands. Yes

Horned Lark (Strigata ssp.) (ESA Open fields with short herb dominated ground cover < 31 cm tall candidate) and patches of bare ground. Yes

Oregon Vesper Sparrow (Affinis Lightly grazed pastures with scattered shrubs and grass height < ssp.) 30-60 cm) high Yes

Marshes with open water and on lakes and reservoirs supporting Western Grebe (nb) emergent vegetation. Yes

Nests on ledges or shallow caves in steep rock faces and canyons, usually near or behind waterfalls and sea caves. Forage over Laysan Albatross (nb) forests and open areas in montane habitats. No

Black-footed Albatross (nb) Pelagic, far offshore seabird No

Pink-footed Shearwater (nb) Pelagic offshore seabird No

Red-faced Cormorant Alaskan species No

Pelagic Cormorant (pelagicus Year round nearshore marine and estuarine habitats, on ledges ssp.) and vertical cliffs, on rocky islands and headlands. No

Associated with large bodies of water, forested areas near the Bald Eagle (delisted species) ocean, along rivers, and at estuaries, lakes and reservoirs. Yes

A habitat generalist that prefers to nest in mature forests with Northern Goshawk large trees on moderate slopes with open understories. Yes

Peregrine Falcon (delisted species) Wide range of habitats, nests on cliff ledges, bridges, quarries. Yes

Black Oystercatcher Rocky shores and sand/gravel beaches along the coast. No

Small and partly wooded patches of water, and high altitude bogs Solitary Sandpiper (nb) and wet meadows No

Migrates through east of the Cascade crest. A wader of shallow pools often found near mudflats on seasonally flooded fields and Lesser Yellowlegs (nb) small isolated ponds. Maybe

Migrating through coastal estuarine mud flats and on sandy ocean beaches. Inland on fields or mud flats around lakes and Whimbrel (nb) ponds. No

Present on Bird Species Preferred Habitat the Umpqua

Short-grass or mixed-prairie habitats with flat to rolling Long-billed Curlew (nb) topography. Also found in agricultural fields. No

Hudsonian Godwit (nb) Rare migrant along the west coast. No nb= non breeding within this BCR, 1species are also focal species identified in Altman and Alexander 2012.

Table 9 displays a list of Focal Landbird Species identified in the 2012 PIF habitat conservation plan as occurring on the Umpqua National Forest that may be present in the area of Willow Sump and could be affected by the proposed action.

Table 13. Landbirds identified as Focal Species by the Partners in Flight document “Habitat Conservation for Landbirds in the Coniferous Forests of Western Oregon and Washington” version 2.0 by Altman and Alexander 2012.

Forest Stage Habitat Attribute Focal Species

Large snags Pileated Woodpecker

Old-Growth/Mature Forest Large trees Brown Creeper (Multi-Layered/Late- Successional) Deciduous canopy/sub-canopy trees Pacific-slope Flycatcher Mid-story tree layers Varied Thrush

Closed canopy Hermit Warbler

Mature/Young Forest (Multi- Open mid-story Hammond’s Flycatcher Layered/Understory Reinitiating) Deciduous understory Wilson’s Warbler

Forest floor complexity Winter Wren

Young/Pole Forest (Understory Black-throated Gray Reinitiating/Stem Exclusion) Deciduous canopy trees Warbler

Residual canopy trees Olive-sided Flycatcher Sapling/Seedling Forest (Stand Snags Northern Flicker Initiation/Early Successional) Deciduous shrub layer Orange-crowned Warbler

Mineral springs Band-tailed Pigeon

Unique Forest Habitats or Wet meadows Lincoln’s Sparrow Conditions Alpine grasslands American Pipit

Waterfalls Black Swift

Nectar-producing plants Rufous Hummingbird

Large hollow snags Vaux’s Swift

Landscape mosaic forest Blue (Sooty) Grouse

Pine-oak canopy/subcanopy trees Purple Finch

Dense shrub understory Nashville Warbler

Klamath Mountains Mixed Shrub-herb interspersion understory Hermit Thrush Conifer/Mixed Conifer-Hardwood Forests Forest canopy edges Western Tanager Montane brushfields Fox Sparrow

Post-wildfire Lazuli Bunting

Direct, Indirect and Cumulative Effects There would be no direct habitat effects for any of these species as no habitat manipulation would occur as a result of the proposed action. However, as described earlier in this document, there could be an indirect impact to landbirds that feed upon insects. Insects would have to be present at the time of treatment and then those same insects would have to be ingested. Because of the low likelihood of this, any potential impacts to landbirds from this scenario are expected to be minimal.

Because of the very minor limited, short-lived direct and indirect effects of this action, and as there are no reasonably foreseeable activities that will occur in the Willow Sump project area, there are no cumulative effects to landbirds.

Determination of Impacts - Landbirds The impact of the project is very limited in scope and will have no measurable negative affect on individuals or populations. The proposed action will not alter the population trends of these landbird species in western Oregon or Washington. The determination for landbirds is No Impact.

Recreation Primary recreational opportunities within the planning area boundary during the busy recreation season (Memorial to Labor Day) include moderate use in the form of dispersed camping, fishing, sightseeing and wildlife viewing. Off season recreation includes hunters in October. Willow Sump Camp is a primitive dispersed campsite that includes a wooden table and a T12 restroom. Located next to willow sump, this dispersed campsite caters primarily to fishermen along with sightseeing and wildlife viewing. There are no trails that connect directly to this site.

Relevant Standards and Guidelines

No specific LRMP Standards and Guidelines apply to the planning area. All general Standards and Guidelines for this area (primarily regarding dispersed recreation sites) would continue to be met with this project.

Direct and Indirect Effects

Alternative 1 Under Alternative 1, Willow Sump and Willow Sump Camp users would experience long-term direct effects associated with the decline in fish populations as yellow floating heart continues to take over the sump. Considering the primary use at Willow Sump is fishing, most users who visit Willow Sump on a recurring basis would be affected. Users would be displaced to other similar lakes in the area.

Alternative 2 (Proposed Alternative) Under alternative 2, Willow Sump and Willow Sump Camp users would experience some short term closures on the area during activities and a 48 hour period following activities. Activities may occur as early as July or as late as September and may include up to two herbicide treatments per season with yearly recurrence during the life of the project. Exact timing of the herbicide will be based on the most efficient approach to eliminate the yellow floating heart invasive, but can be expected during the first week of August and the third or fourth week of August. Herbicide activities may last up to 4 days at most, with a likely estimate of 2 days. While activities would attempt to focus activities on a Monday when use would be the lowest, the primary driver in herbicide use would be weather, and as such coinciding with a Monday may not be possible. The closure would be recommended in order to minimize possible unintentional contact with the herbicide. Impacts to health, if any, would be minimal if the closure is not followed, however unintentional ingestion of water while swimming would pose the greatest risk. See health and safety section for an in-depth evaluation of the herbicide on public health. Effects of the closure would affect all users, which are primarily composed of fishermen. Users would be displaced to other similar lakes in the area. Mitigation measures included will ensure that the public is informed with approximate treatment dates X weeks in advance via FS News Releases and signs at Willow Sump Camp.

PDFs The Public would be notified about upcoming herbicide treatments via FS News Releases and posting signs. The FS News Releases and the signs posted at the Willow Sump recreation area would indicate the approximate dates of treatment, the herbicide use, Forest Service Contact Information, and when the area maybe reentered. (Standard #23, R6 2005 ROD).

Heritage Resources

No heritage resources were associated with this undertaking during project review. Following Stipulation IIIA.3(C) of the PA the Forest Archaeologist has determined project activities have met the criteria of No potential to cause effects for heritage resources as described in the PA under Programmatic Review. 81

CHAPTER 4 Consultation with Others

Public Involvement Formal scoping (a process used to surface issues) began when the project was first listed in the Umpqua National Forest Quarterly Schedule of Proposed Actions (SOPA) on the 15th of October 2012. A scoping notice describing the project components and querying interest in a field trip was emailed to 20 members of the public and other government entities on the 15th of October 2012 with the intent of introducing the Proposed Action and soliciting issues. For a complete list of the members of public and other government entities with which this scoping notice was sent to please see the project record. No members of the public attended the proposed date for the field trip. Two comment letters were received during scoping: one during the formal scoping period and one after the formal scoping period had ended.

Agency and other Government Consultation The regulatory agencies charged with overseeing the Endangered Species Act (U.S. Fish and Wildlife Service and NOAA Fisheries) were consulted as appropriate during the planning process. No formal consultation was required with NFMS, as this project is expected to have no effect to ESA aquatic species.

Interdisciplinary Team The following people are members of the Interdisciplinary Team (IDT) that participated in the preparation or review of all or part of this environmental assessment:

Bryan Benz Project Manager, Botanist Steve Burns Fisheries Biologist Amy Rusk Hydrologist/Aquatic Terri Stone Wildlife Biologist Miguel Amat y Leon Recreation Specialist Angie Snyder Archaeologist

In addition, the following people assisted in developing the proposal or in the editing and review of this document:

Carol Cushing District Ranger (retired) Bill Mulholland District Ranger, Line Officer 84

Richard Helliwell Forest Botanist Josh Chapman Forest Wildlife Biologist Shawna Bautista Region 6 Pesticide Use and Invasive Plant Coordinator Rochelle Desser Region 6 Invasive Plants NEPA and Monitoring Coordinator

GLOSSARY Active ingredient (a.i.) - In any pesticide product, the component (a chemical or biological substance) that kills or otherwise controls the target pests. Pesticides are regulated primarily on the basis of active ingredients. The remaining ingredients are called "inerts".

Acute effect - An adverse effect on any living organism in which severe symptoms develop rapidly and often subside after the exposure stops.

Acute exposure - A single exposure or multiple brief exposures occurring within a short time (e.g., 24 hours or less in humans). The classification of multiple brief exposures as “acute” is dependant on the life span of the organism.

Acute toxicity - Any harmful effect produced in an organism through an acute exposure to one or more chemicals.

Additive effect - A situation in which the combined effects of exposure to two chemicals simultaneously is equal to the sum of the effect of exposure to each chemical given alone. The effect most commonly observed when an organism is exposed to two chemicals together is an additive effect.

Adaptive management - A continuing process of action-based planning, monitoring, researching, evaluating, and adjusting with the objective of improving implementation and achieving the goals of the standards and guidelines (USDA, USDI 1994a).

Adjuvant(s) - Chemicals that are added to pesticide products to enhance the toxicity of the active ingredient or to make the active ingredient easier to handle or mix.

Affected Environment - Existing biological, physical, social, and economic conditions of an area subject to change, both directly and indirectly, as the result of a proposed human action.

Agent - Any substance, force, radiation, organism, or influence that affects the body. The effects may be beneficial or injurious.

Amphibian - Any of a class of cold-blooded vertebrates (including frogs, toads, or salamanders) intermediate in many characteristics between fishes and reptiles and having gilled aquatic larvae and air-breathing adults.

Anadromous - Fish that spend their adult life in the sea but swim upriver to fresh water spawning grounds to reproduce.

Anaerobic - Life or process that occurs in, or is not destroyed by, the absence of oxygen.

Annual - A plant that endures for not more than a year. A plant which completes its entire life cycle from germinating seedling to seed production and death within a year. (Dayton, 1950)

Anoxia - Literally, "without oxygen". A deficiency of oxygen reaching the tissues of the body especially of such severity as to result in permanent damage.

Aquatic Label: Some herbicides are labeled by EPA for direct application in water. Aquatic labeled herbicides are not necessarily less hazardous to aquatic organisms than other herbicides, but have been more extensively tested (however, aquatic labeled herbicides are less hazardous to aquatic organisms than their terrestrial formulations). Aquatic labeled herbicides would be favored over effective non- aquatic labeled herbicides that pose lower risk to aquatic organisms, assuming compliance with label advisories.

Aqueous - Describes a water-based solution or suspension.

Background level - In pollution, the level of pollutants commonly present in ambient media (air, water, soil).

Best management practices (BMP) - A practice or combination of practices determined by a state or an agency to be the most effective and practical means (technological, economic, and institutional) of controlling point and non-point source pollutants at levels compatible with environmental quality.

Bioaccumulation: The increase in concentration of a substance in living organisms as they take in contaminated air, water, or food because the substance is very slowly metabolized or excreted (often concentrating in the body fat).

Bioconcentration - The accumulation of a chemical in tissues of a fish or other aquatic organism to levels greater than in the surrounding water.

Bioconcentration factor (BCF) - The concentration of a compound in an aquatic organism divided by the concentration in the ambient water of the organism.

Biodegradability - Susceptibility of a substance to decomposition by microorganisms; specifically, the rate at which compounds may be chemically broken down by bacteria and/or natural environmental factors.

Biologically sensitive - A term used to identify a group of individuals who, because of their developmental stage or some other biological condition, are more susceptible than the general population to a chemical or biological agent in the environment.

Body Burden - The amount of a chemical stored in the body at a given time, especially a potential toxin in the body as the result of exposure.

Broadcast application - In pesticides, to spread a chemical over a broad area. 86

Candidate Species - Those plant and animal species that, in the opinion of the Fish and Wildlife Service (FWS) or NOAA Fisheries, may qualify for listing as endangered or threatened. The FWS recognizes two categories of candidates. Category 1 candidates are taxa for which the FWS has on file sufficient information to support proposals for listing. Category 2 candidates are taxa for which information available to the FWS indicates that proposing to list is possibly appropriate, but for which sufficient data are not currently available to support proposed rules.

Cation - Positively charged ions in a solution.

Cation Exchange Capacity - a measure of the number of sites on mineral soil colloids and organic matter that are available to hold compounds with positive charges within the zone of microbial influence.

Chemical Control - The use of naturally derived or synthetic chemicals called herbicides to eliminate or control the growth of invasive plants.

Chronic exposure - Exposures that extend over the average lifetime or for a significant fraction of the lifetime of the species (for a rat, chronic exposure is typically about 2 years). Chronic exposure studies are used to evaluate the carcinogenic potential of chemicals and other long-term health effects.

Chronic RfD - An estimate of a lifetime daily exposure level for the human population, including sensitive subpopulations, that is likely to be without an appreciable risk of deleterious effects. Chronic RfDs (reference doses) are specifically developed to be protective for long-term exposure to a compound (7 years to lifetime).

Chronic toxicity - The ability of a substance or mixture of substances to cause harmful effects over an extended period, usually upon repeated or continuous exposure sometimes lasting for the entire life of the exposed organism.

Code of Federal Regulations (CFR) - Document that codifies all rules of the executive departments and agencies of the federal government. It is divided into fifty volumes, known as titles. Title 40 of the CFR (referenced as 40 CFR) lists all environmental regulations, including regulations for EPA pesticide programs (40 CFR Parts 150-189).

Colluvium - soil material or rock fragments moved downslope by gravitational forces.

Connected actions - Exposure to other chemical and biological agents in addition to exposure to a specific pesticide formulation in a field application to control pest organisms.

Contaminants - For chemicals, impurities present in a commercial grade chemical. For biological agents, other agents that may be present in a commercial product.

Control - Means, as appropriate, eradicating, suppressing, reducing, or managing invasive species populations, preventing spread of invasive species from areas where they are present, and taking steps such as restoration of native species and habitats to reduce the effects of invasive species and to prevent further invasions (Executive Order 13112, 2/3/99).

Cumulative Effect - The impact on the environment that results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions—regardless of what agency (federal or non-federal) or person undertakes such other actions. Cumulative impacts can result from individually minor, but collectively significant, actions taking place over a period of time (40 CFR 1508.7).

Cumulative exposures - Exposures resulting from one or more activities that are repeated over a period of time.

Dosage/Dose - 1. The actual quantity of a chemical administered to an organism or to which it is exposed. 2. The amount of a substance that reaches a specific tissue (e.g. the liver). 3. The amount of a substance available for interaction with metabolic processes after crossing the outer boundary of an organism.

Dose Rate - In exposure assessment, dose per time unit (e.g. mg/day), sometimes also called dosage.

Dose Response - Changes in toxicological responses of an individual (such as alterations in severity of symptoms) or populations (such as alterations in incidence) that are related to changes in the dose of any given substance.

Drift - That portion of a sprayed chemical that is moved by wind off a target site.

Emergent - For purposes of this project, the term “emergent” is used to better describe ground conditions relative to where invasive plants are growing alongside a stream or other waterbody. Emergent vegetation is defined as plants that grow from below the water line to above the water line. Free floating vegetation is not considered emergent and will not be treated with herbicides under this project.

Endangered Species –Any species listed in the Federal Register as being in danger of extinction throughout all or a significant portion of its range.

Endangered Species Act (ESA) - A law passed in 1973 to conserve species of wildlife and plants determined by the Director of the Fish and Wildlife Service or the NOAA Fisheries to be endangered or threatened with extinction in all or a significant portion of its range. Among other measures, ESA requires all federal agencies to conserve these species and consult with the Fish and Wildlife Service or NOAA Fisheries on federal actions that may affect these species or their designated critical habitat.

Exposure assessment - The process of estimating the amount of contact with a chemical or biological agent that an individual or a population of organisms will receive from a pesticide application conducted under specific, stated circumstances.

Exposure Scenario: The mechanism (for example, by skin or ingestion) by which an organism (person, animal, fish) may be exposed to herbicides active ingredients or additives. The application rate and method influences the amount of herbicide to which an organism may be exposed.

Exotic - “Not native; introduced from elsewhere, but not completely naturalized” (Harris, 1994). See “Alien Species”.

Federally Listed Species - Formally listed as a threatened or endangered species under the ESA. Designations are made by the FWS or NMFS.

Ground water - The supply of fresh water found beneath the Earth's surface, usually in aquifers, which is often supplies wells and springs.

Half-life or halftime - The time required for the concentration of the chemical to decrease by one-half. For example if the half-life of a chemical is 10 days, half the product would be broken down 10 days after application; after 10 more days, half of that half of the product is broken down, etc.

Hazard Quotient (HQ): The Hazard Quotient (HQ) is the amount of herbicide or additives to which an organism may be exposed (dose) divided by the exposure threshold of concern (No Observable Adverse Effect Level – NOAEL). An HQ less than or equal to 1 indicates an extremely low level of risk. A HQ below 1 indicates a level below a threshold of concern.

Herbicide - A chemical preparation designed to kill plants, especially weeds, or to otherwise inhibit their growth. - A chemical preparation designed to kill plants, especially weeds, or to otherwise inhibit their growth.

Inerts - Anything other than the active ingredient in a pesticide product; not having pesticide properties.

Infested Area - A contiguous area of land occupied by a single invasive plant species. An infested area of land is defined by drawing a line around the actual perimeter of the infestation as defined by the canopy cover of the plants, excluding areas not infested. Generally, the smallest area of infestation mapped will be 1/10th (0.10) of an acre or 0.04 hectares. (NRIS Standards).

Integrated Weed Management (IWM) - An interdisciplinary weed management approach for selecting methods for preventing, containing, and controlling noxious weeds in coordination with other resource management activities to achieve optimum management goals and objectives (FSM 2080.5).

Interdisciplinary team (IDT) - A group of individuals with varying areas of specialty assembled to solve a problem or perform a task. The team is assembled out of recognition that no one scientific discipline is sufficiently broad enough to adequately analyze the problem and propose an action.

Introduced Species - An alien or exotic species that has been intentionally or unintentionally released into an area as a result of human activity. “Introduced (agricultural crops may fit the definition as well as ‘native’ or ‘introduced’ wildland species) or exotic species whose genetic material originally evolved and developed under different environmental conditions than those of the area in which it was introduced, often in geographically and ecologically distant locations” (Brown, 1997). See also “Noxious Weed” and “Exotic.”

Introduction - “The intentional or unintentional escape, release, dissemination, or placement of a species into an ecosystem as a result of human activity” (Executive Order 13112, 2/3/99). 89

Invasive Plant Species - An alien plant species whose introduction does or is likely to cause economic or environmental harm or harm to human health (Executive Order 13112, 2/3/99).

Irreversible effect - Effect characterized by the inability of the body to partially or fully repair injury caused by a toxic agent.

Irritant - Non-corrosive material that causes a reversible inflammatory effect on living tissue by

Label - All printed material attached to or part of the pesticide container.

Level of Concern (LOC) - The concentration in media or some other estimate of exposure above which there may be effects.

Lowest Observed Adverse Effect Level (LOAEL): The lowest dose of a chemical in a study, or group of studies, that produces statistically or biologically significant increases in frequency or severity of adverse effects between the exposed and control populations.

Manual Control - The use of any non-mechanized approach to control or eliminate invasive plants (i.e. hand-pulling, grubbing).

Material safety data sheet (MSDS) - a compilation of information required under the OSHA Communication Standard on the identity of hazardous chemicals, health and physical hazards, exposure limits, and precautions.

Mechanical Control - The use of any mechanized approach to control or eliminate invasive plants (i.e. mowing, weed whipping, weed whacking, hot foam)

National Environmental Policy Act (NEPA) - An Act passed in 1969 to declare a National policy that encourages productive and enjoyable harmony between humankind and the environment, promotes efforts that prevent or eliminate damage to the environment and biosphere, stimulates the health and welfare of humanity, enriches the understanding of the ecological systems and natural resources important to the nation, and establishes a Council on Environmental Quality (USDA, USDI 1994a).

National Forest Management Act (NFMA) - A law passed in 1976 as an amendment to the Forest and Rangeland Renewable Resources Planning Act, requiring preparation of Forest Plans and the preparation of regulations to guide that development (USDA, USDI 1994a).

National Marine Fisheries Service (NMFS) - The federal agency that is the listing authority for marine mammals and anadromous fish under the ESA.

National Pollutant Discharge Elimination System (NPDES) - As authorized by the Clean Water Act, the NPDES permit program controls water pollution by regulating point sources that discharge pollutants into waters of the United States. An NPDES permit is required for herbicide use into water or adjacent conveyances with a hydrologic surface connection to water at the time of application. Native Species - With respect to a particular ecosystem, a species which, other than as a result of

Non-target - Any plant or animal that is not the intended organism to be controlled by a pesticide treatment.

No Observable Adverse Effect Level (NOAEL): Exposure level at which there are no statistically or biologically significant differences in the frequency or severity of any adverse effect in the exposed or control populations.

No Observed Effect Concentration (NOEC): Synonymous with NOEL.

No Observed Effect Level (NOEL): Exposure level at which there are no statistically or biologically significant differences in the frequency or severity of any effect in the exposed or control populations.

Not Likely to Adversely Affect (NLAA) - determinations are applied to those species that had very little habitat on National Forests in Region Six, were not in habitats susceptible to invasive plants, or were known to tolerate herbicide treatments without effects.

Periphyton – tiny aquatic organisms that live attached to rocks and other submerged structures

Persistence - refers to the length of time a compound, once introduced into the environment, stays there.

Personal Protective Equipment (PPE) - Clothing and equipment worn by pesticide mixers, loaders and applicators and re-entry workers, hazmat emergency responders, workers cleaning up Superfund sites, etc., which is worn to reduce their exposure to potentially hazardous chemicals and other pollutants.

Pest - An insect, rodent, nematode, fungus, weed or other form of terrestrial or aquatic plant or animal life that is classified as undesirable because it is injurious to health or the environment. Pesticide - Any substance used for controlling, preventing, destroying, repelling, or mitigating any pest. Includes fungicides, herbicides, fumigants, insecticides, nematicides, rodenticides, desiccants, defoliants, plant growth regulators, and so forth. (W, modified).

Pesticide tolerance - the amount of pesticide residue allowed by law to remain in or on a harvested crop. pH - The negative log of the hydrogen ion concentration. A high pH (>7) is alkaline or basic and a low pH (<7) is acidic.

Phytoplankton - freely floating, often minute plant and plant-like organisms that drift with water currents.

Reference Dose (RfD): The RfD is a numerical estimate of a daily exposure to the human population, including sensitive subgroups such as children, that is not likely to cause harmful effects during a lifetime. RfDs are generally used for health effects that are thought to have a threshold or minimum dose for producing effects.

Riparian Area - A geographic area containing an aquatic ecosystem and adjacent upland areas that directly affect it (Northwest Forest Plan).

Risk - the chance of an adverse or undesirable effect.

Risk assessment - the qualitative and quantitative evaluation performed in an effort to estimate the risk posed to human health and/or the environment by the presence or potential presence and/or use of specific chemical or biological agents.

Sensitive species – Species identified by the Regional Forester for which population variability is a concern, as evidenced by significant current or predicted downward trend in population numbers or density; or significant current or predicted downward trends in habitat capability that would reduce a species existing distribution (FSM 2670).

Standards and guidelines - The rules and limits governing actions, as well as the principles specifying the environmental conditions or levels to be achieved and maintained (USDA, USDI 1994a).

Subchronic exposure - An exposure duration that can last for different periods of time (5 to 90 days), with 90 days being the most common test duration for mammals. The subchronic study is usually performed in two species (rat and dog) by the route of intended use or exposure.

Subchronic toxicity - the ability of one or more substances to cause effects over periods from about 90 days but substantially less than the lifetime of the exposed organism. Subchronic toxicity only applies to relatively long-lived organisms such as mammals.

Submerged Aquatic Vegetation - Vegetation that lives at or below the water surface; an important habitat for young fish and other aquatic organisms.

Substrate - With reference to enzymes, the chemical that the enzyme acts upon.

Surface water - All water naturally open to the atmosphere (rivers, lakes, reservoirs, streams, impoundments, seas, estuaries, etc.) and all springs, wells, or other collectors which are directly influenced by surface water.

Surfactant - a surface active agent; usually an organic compound whose molecules contain a hydrophilic group at one end and a lipophilic group at the other. Promotes solubility of a chemical, or lathering, or reduces surface tension of a solution.

Survey and Manage – mitigation measure adopted as a standard and guideline within the Northwest Forest Plan Record of Decision that is intended to mitigate impacts of land management efforts on those species that are closely associated with late-successional or old-growth forests whose long-term persistence is a concern. These measures apply to all land allocations and require land managers to take certain actions relative to species of plants and animals, particularly some amphibians, bryophytes, lichens, mollusks, vascular plants, fungi, and arthropods, which are rare or about which little is known. These actions include: (1) manage known sites; (2) survey prior to ground-disturbing activities; (3) conduct extensive and general regional (strategic) surveys. 92

Take - To kill or capture a species covered by the ESA.

Threatened species - Plant or animal species likely to become endangered throughout all or a significant portion of its range within the foreseeable future. A plant or animal identified and defined in accordance with the 1973 Endangered Species Act and published in the Federal Register (USDA, USDI 1994a).

Threshold - The maximum dose or concentration level of a chemical or biological agent that will not cause an effect in the organism.

Threshold of Concern: A level of exposure below which there is a low potential for observable adverse effects to an organism. The No-observed-adverse-effect level (NOAEL) is the exposure level at which there are no statistically or biologically significant differences in the frequency or severity of any

Tolerances - Permissible residue levels for pesticides in raw agricultural produce and processed foods. Whenever a pesticide is registered for use on a food or a feed crop, a tolerance (or exemption from the tolerance requirement) must be established. EPA establishes the tolerance levels, which are enforced by the Food and Drug Administration and the Department of Agriculture.

Toxicity - The inherent ability of an agent to affect living organisms adversely. As defined by U.S. EPA, toxicity is “...the degree to which a substance or mixture of substances can harm humans or animals.

Toxicology - The study of the nature, effects, and detection of poisons in living organisms. Also, substances that are otherwise harmless but prove toxic under particular conditions. The basic assumption of toxicology is that there is a relationship among the dose (amount), the concentration at the affected site, and the resulting effects.

Treated area - An infested area where weeds have been treated or retreated by an acceptable method for the specific objective of controlling their spread or reducing their density. (NRIS Standards).

REFERENCES Altman, B. and J.D. Alexander. 2012. Habitat conservation for landbirds in coniferous forests of western Oregon and Washington. Version 2.0. Oregon-Washington Partners in Flight (www.orwapif.org) and American Bird Conservancy and Klamath Bird Observatory.

Abrams, L. 1923-1960. Illustrated flora of the Pacific States, Vol. 1-4. Stanford University Press, Stanford, California.

Arora, D. 1986. Mushrooms demystified. Ten Speed Press, Berkeley, California

Ashton, D.T., A.J. Lind, and K.E. Schlick. 1997. Western Pond Turtle (Clemmys marmorata) Natural History. USDA Forest Service, Pacific Southwest Research Station.

Audubon Society. 2007. Black Swift (Cypseloides niger) http://audubon2.org/watchlist/viewSpecies.jsp?id=38

Audubon Society. 2007. Yellow Rail (Coturnicops oveboracensis). http://web1.audubon.org/science/species/watchlist/profile.php?speciesCode=yelrai

Austin, A., G. Harris & W. Lucey (1991) Impact of an organophosphate herbicide (Glyphosate) on periphyton comuunities developed in experimental streams. Bull Environ Contam Toxicol, 47, 29-35

Bautista, Shawna. 2012. Personal Communication. R6 Pesticide Use & Invasive Plant Coordinator, US Forest Service State & Private Forestry. Portland, OR.

Brown, Charles R. 1997.Purple Martin (Progne subis), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/287

Bury, R. B. 1986. Feeding ecology of the turtle, Clemmys marmorata. Journal of Herpetology, Vol. 20, No. 4, pp.515-521.

Castellano, M.A., J.E. Smith, T. O’Dell, E. Cázares, and S. Nugent. 1999. Handbook to strategy 1 fungal taxa from the Northwest Forest Plan. Gen. Tech. Rep. PNW-GTR-476. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 195 p.

Castellano, M.A., E. Cázares, B. Fondrick, and T. Dreisbach. 2003. Handbook to additional fungal species of special concern in the Northwest Forest Plan. Gen. Tech. Rep. PNW- GTR-572. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 144 p.

Cristy, R.E. & S.D. West. 1993. Biology of bats in Douglas-fir forests. USDA Forest Service Gen. Tech. Rep. PNW-GTR-308. 27pp.

Cross, S.P., H. Lauchstedt & C. Harmes. 1996. Characterizing forest roost sites of some bats of special concern occurring in Roseburg and Medford BLM Districts. Final Report – Department of Biology. Southern Oregon State College, Ashland, OR. 47pp

Cushman, K.A., and C.A. Pearl. 2007. A Conservation Assessment for the Oregon Spotted Frog (Rana pretiosa). USDA Forest Service Region 6 and USDI Bureau of Land Management, Oregon and Washington. http://www.fs.fed.us/r6/sfpnw/issssp/documents/planning-docs/ca-ha-rapr-2007-03- 27.doc

Davis, R. and J. Lint. 2005. Chapter 3: Habitat Status and Trend. In Lint, Joseph, tech. coord. 2005. Northwest Forest Plan—the first 10 years (1994–2003): status and trends of northern spotted owl populations and habitat. Gen. Tech. Rep. PNW-GTR-648. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 176 p.

Derr, C., R. Helliwell, A. Ruchty, L. Hoover, L. Geiser, D. Lebo, and J. Davis. 2003. Survey protocols for survey & manage category A & C lichens. USDA Forest Service, USDI Bureau of Land Management, and USDI Fish & Wildlife Service, Portland, Oregon.

Derr, C., R.D. Lesher, L. Geiser, and M. Stein. 2003b. 2003 Amendment to the survey protocol for survey & manage category A & C lichens. USDA Forest Service, USDI Bureau of Land Management, and USDI Fish & Wildlife Service, Portland, Oregon.

Duncan, N. 2004. Conservation Assessments for Crater Lake Tightcoil (Pristiloma arcticum crateris), Oregon Shoulderband (Helminthoglypta hertleini), and Chace Sideband (Monadenia chaceana). USDA-For. Serv. and USDI-BLM. Roseburg, OR.

EPA, 2006. Reregistration Eligibility Decision for Imazapyr. EPA 738-R-06-007

Exeter, R.L., L. Norvell and E. Cazares. 2006. Ramaria of the Pacific Northwestern United States. USDI BLM/OR/WA/PT-06/050-1792, Salem, OR 157 p.

Fix, D. 1990. Birds of Diamond Lake. Compiled on September 27, 1990, unpublished.

Forlani, G., M. Pavan, M. Gramek, P. Kafarski & J. Lipok (2008) Biochemical Bases for a Widespread Tolerance of Cyanobateria to the Phosphonate Herbicide Glyphosate. Plant Cell Physiol., 49, 443-456.

Giachini, A.J. 2005. Systematics, phylogeny, and ecology of Gomphus sensu lato. Dissertation, Oregon State University, Corvallis, Oregon.

Goldsborough, L. G. & A. E. Beck (1989) Rapid Dissipation of Glyphosate in Small Forest Ponds. Arch. Environ. Contam. Toxicol., 18, 537-544.

Gordon, D. (1998) Effects of Invasive, Non-indigenous Plant Species on Ecosystem Processes: Lessons from Florida. Ecological Applications, 8, 975-989.

Helliwell, R. 2005. Abundance and distribution of the aquatic moss, Scouleria marginata, in the North Umpqua Rivers, Umpqua National Forest, Oregon. Report to the Interagency Specieal Status/Sensitive Species Program, Portland, OR 12 p.

Helliwell, R. 1998. Rare vascular plants of the Umpqua National Forest. Umpqua National Forest, Roseburg, OR 84 p.

Helliwell, R. and D. York 2006. A habitat suitablility model for two rare lichens using ecological niche factor analysis - draft. Umpqua National Forest, Roseburg, OR 15 p.

Hickman, J.C., Ed. 1993. The Jepson manual, higher plants of California. University of California Press, Berkeley, California.

Hitchcock, C.L., and A. Cronquist. 1973. Flora of the Pacific Northwest. University of Washington Press, Seattle, Washington.

Hitchcock, C.L., A. Cronquist, M. Ownbey, and J.W. Thompson. 1955-1969. Vascular plants of the Pacific Northwest, Parts 1-5. University of Washington Press, Seattle, Washington.

Holland, D. C. 1994. The Western Pond Turtle: Habitat and History. Oregon Department of Fish and Wildlife for U. S. Department of Energy Bonneville Power Administration. Final Report.

Holland, D. C. 1991. A synopsis of the ecology and status of the western pond turtle (Clemmys marmorata) in 1991. Prepared for the USFWS, National Ecology Research Center, San Simeon Field Station.

Kozloff, E.N. 2005. Plants of Western Oregon, Washington & British Columbia. Timber Press, Portland, OR

Lawton, E. 1971. Moss flora of the Pacific Northwest. Hattori Botanical Laboratory, Obi, Nichinan-shi, Miyazaki-ken, Japan.

Lesher, R.D., C.C. Derr, and L.H. Geiser. 2003. Natural history and management considerations for Northwest Forest Plan survey and manage lichens. USDA Forest Service, Pacific Northwest Region, Portland, Oregon.

Marshall, D.B., M. G. Hunter, and A. L. Contreras, Editors. 2003. Birds of Oregon: A General Reference. Oregon State University Press, Corvallis, OR.

McCune, B. and L. Geiser. 1997. Macrolichens of the Pacific Northwest. Oregon State University Press and USDA Forest Service Publishing. Corvallis, Oregon.

MDEP (Massachusetts Department of Environmental Protection), 2012. Imazapyr: Review for Use in Lakes & Ponds in Massachusetts

Michaud, J. 1991. A Citizens Guide to Understanding and Monitoring Lakes and Streams. Washington State Department of Ecology.

NatureServe. 2007. NatureServe Explorer: An online encyclopedia of life [web application]. Version 6.2. NatureServe, Arlington, Virginia. Available http://www.natureserve.org/explorer.

Newton, M., L. Horner, J. Cowell, D. Shite & E. Cole (1994) Dissipation of Glyphosate and Aminomethylphosphonic Acid in North American Forests. J. Agric. Food Chem., 42, 1795-1802.

ODEQ. 2001. Little River Watershed TMDL. ed. O. D. o. E. Quality.

---. 2003. Designated Beneficial Uses, Umpqua Basin. ed. O. D. o. E. Quality.

---. 2006. Umpqua basin total maximum daily load (TMDL) and water quality management plan (WQMP). ed. O. D. o. E. Quality. Medford, Oregon.

Piaggio, A, and R. Sherwin. 2005. Species Account for Corynorhinus townsendii, Townsend’s big- eared Bat. Western Bat Working Group. http://wbwg.org/species_accounts/vespertilonidae/coto.pdf

Schofield, W. 2002. Field guide to liverwort genera of Pacific North America. University of Washington Press, Seattle, WA.

SERA (Syracuse Environmental Research Associates, I. 2011a. Glyphosate Human Health and Ecological Risk Assessment Final Report. USDA Forest Service, Southern Region.

---. 2011b. Imazapyr Human Health and Ecological Risk Assessment Final Report. ed. S. R. USDA Forest Service.

SERA (Syracuse Environmental Research Associates, Inc.). 2007. Preparation of Environmental Documentation of Risk Assessments. SERA MD 2007-01a. January 21, 2007.

Stout, Bonnie E. and Gary L. Nuechterlein. 1999. Red-necked Grebe (Podiceps grisegena), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology;

Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/465doi:10.2173/bna.465

Stedman, Stephen J. 2000. Horned Grebe (Podiceps auritus), The Birds of North America online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/505

Stone, T. 2007. Species Fact Sheet for the Black Swift (Cypseloides niger). August 31, 2007. http://www.fs.fed.us/r6/sfpnw/issssp/documents/planning-docs/sfs-vert-bi-Cypseloides- niger- 2007-08-31.doc

Thomas, J.W., E.D. Forsman, J.B. Lint, E.C. Meslow, B.R. Noon, & J. Verner. 1990. A conservation strategy for the northern spotted owl. A Report by the Interagency Scientific Committee to address the conservation of the northern spotted owl. U.S. Department of Agriculture, Forest Service, and U.S. Department of Interior, Fish and Wildlife Service, Bureau of Land Management, and National Park Service. Portland, Oregon. 427pp.

Turtles--an International Conference. State University of New York, Purchase, New York.

Tsui, M. T. & L. M. Chu (2008) Environmental fate and non-target impact of glyphosate-based herbicide (Roundup) in a subtropical wetland. Chemosphere, 71, 439-446.

Umpqua Valley Audubon Society. 2006. Survey Results from the Diamond Lake Ranger

District, 1996-2006. Data compiled by M. Jones, report by B. Ryan and S. Vecchio.

United States Department of Agriculture and U.S. Department of Interior. 1994. Record of decision for amendments to Forest Service and Bureau of Land Management Planning Documents within the ranger of the northern Spotted Owl: Standards and guidelines for management of habitat for late-successional and old-growth forest related species within the range of the Northern Spotted Owl. http://www.reo.gov/library/reports/newroda.pdf

USDA Forest Service, U.S. Department of Interior Bureau of Land Management. 1994. Record of decision for amendments to Forest Service and Bureau of Land Management planning documents within the range of the northern spotted owl, Portland, Oregon.

USDA/USDI. 2008. Methodology for estimating the number of northern spotted owls affected by proposed federal actions. Version 2.0. Oregon Fish and Wildlife Office, Fish and Wildlife Service, Portland, OR.

USDA, Forest Service. 2004. Regional Forester’s sensitive plant list. Pacific Northwest Region, July, Portland, Oregon.

USDA, Forest Service. 2005. Pacific Northwest Region Invasive Plant Program, Preventing and Managing Invasive Plants, Final Environmental Impact Statement, Record of Decision. R6- NR-FHP-PR-02-05. Portland, Oregon.

USDA, Forest Service and USDI, Bureau of Land Management. 1999. Survey protocols for protection buffer bryophytes, version 2.0

USDA, Forest Service and USDI, Bureau of Land Management. 1994. Final supplemental environmental impact statement on management of habitat for late- successional and old-growth forest related species within the range of the northern spotted owl (Northwest Forest Plan). Portland, Oregon.

USDA. U.S. Forest Service. 2000. USDA Forest Service Landbird Strategic Plan. 24 Pp. http://www.fs.fed.us/biology/resources/pubs/wildlife/landbird.pdf

USDA. U.S. Forest Service. 2009. Invasive Plant Treatment Draft Supplemental Environmental Impact Statement; Deschutes and Ochoco National Forests, Crooked River National Grassland. June 2009.

USDA. U.S. Forest Service. 2011. Regional Forester’s Sensitive Species List

USDA, Umpqua NF. 2006. Forest Database GIS Layer of Special Status Botanical Species, March 9 version. Supervisor’s Office, Roseburg, Oregon.

U.S. Department of Agriculture Forest Service, U.S. Department of Interior Bureau of Land Management. 2001. Record of Decision for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines in Forest Service and Bureau of Land Management Planning Documents Within the Range of the Northern Spotted Owl.

United States Department of Agriculture, U.S. Forest Service. 1990. Land and resource management plan, Umpqua National Forest. Pacific Northwest Region. http://www.fs.fed.us/r6/umpqua/projects/plandocs/umpqua-lrmp.pdf

U.S. Department of Interior. U.S. Fish and Wildlife Service. 1990. Endangered and threatened wildlife and plants; determination of threatened status for the northern spotted owl. Federal Register 55:26114–26194.

USDI. U.S. Fish and Wildlife Service . 1992. Endangered and Threatened Wildlife and Plants; Determination of Critical Habitat for the Northern Spotted Owl. Federal Register Vol. 57, No. 10:1796-1838. January 15, 1992.

USDI. U.S. Fish and Wildlife Service 2008. Endangered and threatened wildlife and plants; revised designation of critical habitat for the northern spotted owl; final rule. 50 CFR Part 17, Federal Register, August 13, 2008. Pages 47326- 47522.

USDI. U.S. Fish and Wildlife Service. 2008. Birds of Conservation Concern 2008. United States Department of Interior, Fish and Wildlife Service, Division of Migratory Bird Management, Arlington, Virginia. 85 pp. [Online version available at http://www.fws.gov/migratorybirds/

USDI. U.S. Fish and Wildlife Service 2009. Informal consultation regarding proposed fiscal year 2009-2018 Umpqua National Forestwide activities that may affect northern spotted owls. Roseburg Field Office of the USFWS. Letter to Cliff Dils from Jim Thrailkill, 17, April 2009

USDA. 1990. Umpqua National Forest Land and Resource Management Plan and FEIS., ed. P. N. R. USDA Forest Service. Roseburg, OR.: Umpqua National Forest.

USDA/USDI. 1995. Little River Watershed Analysis. ed. U. N. F. M. S. R. Area. Roseburg, OR.

---. 2004. Record of Decision Amending Resource Management Plans for Seven BLM Districts and Resource Management Plans for 19 National Forests within the Range of the Northern Spotted Owl; Decision to Clarify Provisions Relating to the Aquatic Conservation Strategy. ed. U. D. o. A. a. U. D. o. Interior. Portland, OR.

USDI. U.S. Fish and Wildlife Service. 2011. Revised Recovery Plan for the Northern Spotted Owl, Strix occidentalis caurina. U.S. Fish and Wildlife Service, Portland, Oregon

USDI. U.S. Fish and Wildlife Service 2012. Endangered and Threatened Wildlife and Plants; Designation of Revised Critical Habitat for the Northern Spotted Owl; Final Rule. 50 CFR Part 17, Federal Register / Vol. 77, No. 233 / December 4, 2012. Pages 71876- 72068.

Verts, B.J. & L.N. Carraway. 1998. Land mammals of Oregon. Univ. of California Press, Berkley, CA. 800pp.

Wagner, D.D. and J. Christy. 1996. Guide for the identification of rare, threatened or sensitive bryophytes in the range of the northern spotted owl, Western Washington, Western Oregon, and Northwestern California. USDI and USDA publication. Eugene, Oregon.

Weller, T.J. & C.J. Zabel. 2001. Characteristics of fringed myotis day roosts in northern California. Journal of Wildlife Management. 65(3):489-497

Yahnke, A. E., Grue, C. E., Hayes, M. P. and Troiano, A. T. (2013), Effects of the herbicide imazapyr on juvenile Oregon spotted frogs. Environmental Toxicology and Chemistry, 32: 228– 235. doi: 10.1002/etc.2048

York, D. and R. Helliwell. 2006. A habitat suitablility model for six rare Pacific Northwest fungi using ecological nich factor analysis – draft. Umpqua National Forest, Roseburg, 100

OR 28p.

Zabel, C. J., K.M. McKelvey, and J.P. Ward, Jr. 1995. Influence of primary prey on home- range size and habitat-use patterns of northern spotted owls (Strix occidentalis caurina). Canadian Journal of Zoology 73:433-439.

101

APPENDIX 1

Syracuse Environmental Research Associates (SERA) Analysis and Hazard Quotients for Wildlife - Herbicide Risk Assessment

As described earlier in this document, toxicity data for glyphosate and imazapyr has been analyzed as part of Forest Service/SERA risk assessments. When enough data was available for a particular type of animal, an exposure scenario was developed and a quantitative estimate of dose received by the animal type in the scenario was calculated (SERA 2007). If species- specific information was not available, toxicity testing was conducted on representative species of birds, mammals, freshwater fish, and aquatic invertebrates.

SERA analysis provided baseline data for worksheets created by the regional pesticide use coordinator for the application of glyphosate and imazapyr at Willow Sump. It should be noted that those worksheets assessed treatment of the entire 2.2 acre pond at one time instead of treating it in stages; proposal is for treating less than 20% of the total area of the pond each time. The infestation of Yellow Floating Heart is approximated one acre in size and 1/3 of the infested area will be treated with each application. Even when assessing impacts for treating the entire pond all at once, all values for impacts to wildlife species with completed risk assessments were below the threshold of concern. With less than 20% of the total area of the pond being treated with each application those impacts will be far less than what is documented in Tables 1 and 2 and the thresholds of concern would be that much lower.

Any hazard quotient less than 1.0 indicates that any adverse effects are not plausible. This is particularly true because we are using NOAELs (no-adverse-effect-levels) for the toxicity values. A Hazard Quotient less than 1.0 means the dose was less than the no-effect level (Shawna Bautista, personal communication).

As all values for the Hazard Quotients for competed risk assessments are well below 1.0 as shown in Tables 1 and 2, these levels have been determined to be below the no-effect level and thus no negative impacts are expected for these wildlife species from the treatment of Willow Sump with either glyphosate or imazapyr. With less than 20% of the total area of the pond being treated with each application it is anticipated that for those wildlife species where a risk assessment has not been completed those impacts will not be cause for concern. A described above, Willow Sump is part of a much larger complex of wetland habitat in the area of Willow Flats. There are 89 acres of wetland habitat in this wetland complex, of which Willow Sump comprises two acres. If there are impacts to species that do not have risk assessments completed, it will impact a small portion of the habitat utilized by those species in the Willow Flats area. There is no risk to these species range-wide.

102

Table 15. Glyphosate and Imazapyr Hazard Quotients for Wildlife

103