environmental assessment for the pioneer invasive plant...

United States Department of Agriculture

Forest Service

Pacific Southwest Region

May 4, 2015

Environmental Assessment for the

Pioneer Invasive Plant Treatment Project

Lassen National Forest Eagle Lake Ranger District Lassen County, California

Canada thistle (Cirsium arvense) along a tributary of Willard Creek

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Introduction The Eagle Lake Ranger District (ELRD) of the Lassen National Forest (LNF) is proposing the Pioneer Invasive Plant Treatment (Pioneer) Project. This project would analyze and treat priority invasive plant infestations on up to 80 acres within approximately 26,600 acres of LNF lands annually, using a combination of manual, cultural, and chemical methods.

Management Direction

Invasive species have been identified by the Chief of the Forest Service as one of the four greatest threats to forest health (for more information, see http://www.fs.fed.us/projects/four-threats). Invasive plants can have strong negative effects on wildland values.

The proposed action is consistent with the 1992 Lassen National Forest Land and Resource Management Plan (LRMP) and 1993 Record of Decision (ROD) as amended by the Sierra Nevada Forest Plan Amendment (SNFPA) FSEIS and ROD (2004) and the Sierra Nevada Forests Management Indicator Species Amendment FEIS and ROD (2007a). The SNFPA ROD directs the Forest Service to undertake invasive plant management and to prioritize activities in the following order: 1) prevent new introductions of invasive species; 2) conduct early treatment of new infestations; and 3) contain or control established infestations (USDA Forest Service 2004, page 36).

The Forest Service Manual 2900 (USDA Forest Service 2011) directs the Forest Service to use an integrated pest management (IPM) approach for invasive species control, develop and utilize site-based and species-based risk assessments to prioritize the management of invasive species infestations, and to use a structured decision-making process and adaptive management to help identify and prioritize invasive species management approaches and actions. IPM requires integration of multiple program components- (prevention, early detection/rapid response, mapping, control, re-vegetation and monitoring) with site-specific selection of treatment methods (manual, chemical, biological and cultural) based on factors including effectiveness, feasibility, ecological impact, and safety.

The Forest Service has existing procedures in place for invasive plant prevention, inventory, and monitoring as part of the IPM approach. When prioritizing infestations for treatment, the management goal and treatment strategy for each infestation would vary according to the target species’ biology, the size of infestation, the values at risk from the infestation, and treatment effectiveness.

Pioneer Invasive Plant Treatment Project Environmental Assessment 5/4/2015 1

http://www.fs.fed.us/projects/four-threats

Project Area

The project area is located in the southern portion of the ELRD, adjacent to State Highway 36, approximately six miles southwest of Susanville in Lassen County (Figure 1). Diamond Mountain, Coyote Peak, and Hamilton Mountain are prominent features within the area. Important drainages in the area include Upper Willard Creek, a tributary to the Susan River, and its tributaries. The total project area encompasses approximately 30,941 acres, 26,600 of which are on LNF lands (Appendix A). It includes portions of Township (T) 29 North (N), Range (R) 10 East (E), Sections 11-15, 20-24, 25-29, 31-35, T29N, R11E, Sections 31 and 32, T28N, R10E, Sections 1-4, 9-12, 13-16, 21-23, 26-29, 32, T28N, R11E, Sections 1-6, 7, 10, 11, 18, and T28N, R12E, Sections 4-6, 8-12, and 13-16 of the Mount Diablo Meridian.


Figure 1: Project Vicinity Map


Vegetation types in the area include eastside pine, mixed conifer, true fir, aspen, riparian woodland, and non-forested communities that include brush fields and wet and dry meadows. The proposed project area is split between the Hamilton (31), Willard (32), and Diamond (33) management areas from the LRMP. There are no special land designations, such as wilderness or research natural areas, within the project area.

The project area includes the portion of the LNF that burned in the 2007 Moonlight Fire, and the two subwatersheds, Mountain Meadows Creek and Upper Willard Creek that were directly affected by the fire. On September 3, 2007, the Moonlight Fire ignited on the Plumas National Forest (NF). The fire burned approximately 65,000 acres before it was contained on September 15, 2007. The fire burned through a mosaic of ownerships, which included 45,514 acres on the Plumas NF and 562 acres on the Lassen NF; it also burned large parcels of private timberland. In order to address adjacent invasive plant infestations that are at high risk of infesting the Moonlight Fire area, the proposed project area began with the two affected subwatersheds on the LNF. Since streams and roads act as vector corridors for invasive species that allow the spread into uninfected areas, the project area was then expanded beyond the two subwatersheds because additional invasive plant infestations were discovered in vector corridors, many of which lead into the Moonlight Fire area on both the Lassen and Plumas National Forests.

This project area covers the treatment areas presently inventoried as well as new or previously undiscovered infestations that would be treated using the range of methods described in detail under Alternative 1-the Proposed Action using an Early Detection/Rapid Response approach. The intent of the Early Detection/Rapid Response is to treat new infestations when they are small so that the likelihood of adverse treatment effects is minimized. The approach is based on the premise that the impacts of similar treatments to similar sites and acreages are predictable, even though the precise location or timing of the treatment may be unpredictable.

Invasive plants currently known in the project area include cheatgrass (Bromus tectorum), spotted knapweed (Centaurea stoebe spp. micranthos), Canada thistle (Cirsium arvense), Klamathweed (Hypericum perforatum spp. perforatum), dyer’s woad (Isatis tinctoria), perennial pepperweed (Lepidium latifolium), and medusahead (Elymus caput-medusae). These invasive plants are found throughout the project area, but the highest concentrations are found within riparian areas along the main channel and the West Fork of Willard Creek.

Purpose and Need for Action Purpose of Project

The purpose of this project is to reduce the spread of infestations that threaten wildland values in a timely and cost-effective manner, while protecting human health and ecosystem functions, and restoring rare plant occurrences and openings degraded by invasive species infestations. Invasive species reduce the quality and quantity of habitat for wildlife and fish by reducing forage, shelter, and cover. Rare native plants can be directly displaced by spreading invasive plant infestations. Invasive plants can also reduce an ecosystem’s capacity to provide clean water, productive soils, and defensible space for fire management.


They can also degrade recreational opportunities by impeding access and affecting scenic qualities. The proposed project is intended to create the ability to rapidly respond to new (currently nonexistent or undocumented) invasive plant infestations and new invasive plant species.

Need for Action

Invasive plants are one of the most serious environmental issues facing land managers today. Millions of acres of public lands in the United States are rapidly undergoing degradation because of the spread of invasive plants (USDA Forest Service 1998). Invasive plant populations often grow exponentially, and current inventories show that weeds are spreading at an increasing rate within Region 5 of the Forest Service, as well as nationally (USDA Forest Service 2000).

The Lassen National Forest has been treating invasive plants across the forest for over 20 years using primarily manual methods. This strategy is labor intensive sometimes requiring multiple visits to sites each year. In addition, three of the seven species within the project have a rhizomatous1 root system, which means manual treatments such as hand pulling and shoveling are useful only in removing the potential for spreading these species by seed, but do nothing to control the infestation. As a result, the 10 plus years of manual treatments to many of the known sites within the Pioneer Project area have done little to reduce or eliminate these invasive species infestations. Currently invasive plants are known at approximately 135 locations, which are negatively impacting approximately 274 acres across the project area. There is a need for elimination or control of known priority infestations and for prevention of the establishment of new infestations of invasive plants to protect resource areas.

The location, severity, and management of the Moonlight Fire has created a very high risk for invasive plant introduction and spread within the subwatersheds affected by the fires. During the Moonlight Fire, fire suppression and very high burn severity resulted in considerable ground disturbance, leaving favorable conditions for the establishment and spread of invasive plants. Furthermore, the fire occurred near high traffic areas such as roads, trailheads, campgrounds, and facilities, which were heavily infested with invasive plants. These infested areas can act as source populations for invasive plant introduction and spread into less-invaded portions of the project area, mainly along stream and road corridors. For example, the only known location of dyer’s woad (Isatis tinctoria) in the project area was found in a landing next to a spot fire. Past efforts to eradicate this occurrence have been ineffective and the species is now moving into the surrounding burned timber stand, and due to its location on a system road, threatens to spread throughout the project area. As a result, there is a need to reduce the risk of invasive plant introduction and spread within and adjacent to the highly disturbed Moonlight Fire footprint.

Invasive species also disrupt ecosystems by displacing native plants, reducing species diversity, degrading wildlife habitat, and altering physical ecosystem processes. Having evolved elsewhere, they are out of balance with the existing ecosystem. They often have no natural predators to keep them in check in

1 Having horizontal, underground stems that often send out roots and shoots from nodes. New plants develop from the shoots.


their new habitats, and correspondingly often contribute less to the food chain than native plants. They can alter ecosystem processes such as hydrology, and increase soil erosion, siltation in streams, fire return intervals, and fire severity (Bossard et al. 2000).

The negative effects from invasive species have become apparent for the Forest Service Sensitive plant species Penstemon sudans (Susanville beardtongue), which is being impacted by the invasion of cheatgrass (Bromus tectorum) at various sites within the project area. In occurrences where cheatgrass cover is high, Penstemon sudans cover is low relative to uninfested occurrences. This inverse relationship is consistent with cheatgrass invasion trends across the Intermountain West where cheatgrass is a monoculture or major understory component on approximately 3 million acres (Zouhar 2003). There is a need to reduce cheatgrass cover within occurrences of Penstemon sudans to improve habitat for this Sensitive plant species within the project area.

Invasive species do not recognize land ownership boundaries and can spread indiscriminately between National Forest System (NFS) lands and neighboring areas. Effective invasive plant management requires cooperation with adjacent public land managers and private landowners. Currently, the only known treatments within the project area are being conducted by Caltrans within their right-of-way along Highway 36. Lack of appropriate and effective invasive plant treatment by the Forest Service could increase invasions on both NFS and private lands within the project area. There is a need to complement the work being done by others in the proposed project area with Forest Service treatments to help manage invasive species and spread of infestations on NFS lands as well as adjacent private lands.

Invasive plants migrate, establish, and spread rapidly and unpredictably. Some species spread at rates of eight to twelve percent per year (USDA Forest Service 1998). New invasive plant species and new infestations of known species are discovered every year on NFS lands. Timeliness of action is important because the cost, difficulty, and potential adverse effects of invasive control increases with the scale of infestation. The location of infestations along roads and riparian areas increases the threat of spreading weeds within the project area. Treatment is more likely to be effective if infestations are treated when they are still small using the Early Detection and Rapid Response approach. Flexibility in treatment strategy is important because infestations may not respond predictably to treatment, they may shift or grow rapidly, and new invasive plant species and infestations can represent currently unforeseen threats to wildland values. There is a need for flexibility to adapt to changing conditions and respond rapidly to invasive plant threats that may be currently unknown within the project area.


Alternatives

Alternative 1 - Proposed Action

To achieve the desired condition within the Pioneer Project area the Forest Service proposes to:

1. Treat currently identified high priority invasive plant infestations at 110 known locations on approximately 72 acres;

2. Establish a prioritization and treatment protocol that would allow for adaptive management of known infestations and evaluation of expanding and newly arising invasive plant occurrences for treatment;

3. Treat future (currently unknown) invasive plant infestations—up to 80 acres annually; and 4. Restore openings and rare plant occurrences degraded by invasive species infestations.

Treatment would consist of manual, chemical, and cultural methods, or a combination of these methods using an integrated pest management (IPM) approach (Table 5). Adaptive Management of existing infestations would be applied using an Early Detection/Rapid Response approach to invasive species within the project area. This approach allows for quick reaction to new disturbances that can lead to rapid weed spread and is an essential piece of an effective invasive species control program.

The project’s total annual treatment area would be up to 80 acres. This estimated treatment acreage was based on proposed treatment of known infestations (~72 acres) plus additional acreage for expanding known infestations and new (currently nonexistent or undocumented) infestations. If additional species are added to the Lassen National Forest Invasive Plant List (USDA Forest Service 2014a) in the future, infestations of these species would also be considered for treatment within the project area. Treatment methods for new infestations would be limited to those analyzed in the proposed action and all project design features would apply to all new treatments. Project operations would begin in increments starting in 2015 and continue annually until weed management goals are met or until such time as new information warrants additional environmental analysis.

All invasive plant infestations are not equally threatening to wildland values so infestations would be prioritized based on their size, their threat to wildland values, and their likelihood to spread into uninfested areas (Table 1). Prioritization would be conducted by the project manager, with input from an interdisciplinary team. The goal of prioritization would be to concentrate treatment resources on the highest priority infestations and to minimize the total long-term workload, cost, and resource impact of invasive plant control. Control would occur only when careful consideration indicates that leaving an invasive plant infestation unchecked would result in more damage than controlling it with available methods. In general, the Forest Service would act to prevent new infestations and assign highest priority to existing infestations that are the fastest growing, most disruptive, and affect the most highly valued resources.


Table 1. Prioritization for treating invasive plant infestations in the Pioneer Project area

Priority Management Goal

1

Eradicate: • Newly discovered invasive species • Species with very few isolated infestations • Small infestations of taprooted species

2

Control or Eradicate: • Fast-growing species that:

o Impact high value resources o Are relatively isolated from other infestations; OR o Occur along spread vectors, such as roads, streams, campgrounds, landings and cinder pits.

3 Eradicate: Small, isolated infestations of slow-growing species Control: Fast-growing species that are rapidly expanding

4

Control: • Large infestations that:

o Are adjacent to other large infestations o Occur in highly disturbed areas o Do not occur along spread vectors o Are not rapidly spreading

• Rhizomatous species where available methods have not proven effective

5 Contain: • Species of very wide distribution where control or eradication is not deemed feasible

Eradicate: Attempt to totally eliminate an invasive plant species, recognizing that this may not actually be achieved in the short term since re-establishment/re-invasion may take place initially; Control: Reduce the infestation over time; Contain: Prevent spread of the weed beyond the current perimeter of infested areas.

For most invasive species encountered in the project area, infestations are both small and isolated, so eradication would be the management goal (Table 2). However, for species with large or widespread infestations, the management goal would depend upon the threat and spread risk. A few species (i.e. medusahead and cheatgrass) are so widespread that eradication is not a feasible goal at this time. Attempts would be made to contain spread through prevention measures; however, treatment would only be considered when infestations of these species threaten high value resources such as such as Sensitive plant occurrences and degraded openings, or are located along vector corridors.

While cheatgrass is a low priority for treatment across the project area, it is a high priority for control where it occurs at high densities within occurrences of the Forest Service Sensitive plant species Penstemon sudans. As such, treatment of cheatgrass would occur within up to three acres annually on portions of Penstemon sudans occurrences that have high (>50%) cover of cheatgrass and low (<1%) cover of native grasses. If monitoring shows an increase in P. sudans cover, density, or flowering following cheatgrass treatment additional sites with these characteristics may be selected for future treatment (Appendix D).


Table 2. Current management goals and proposed initial treatment methods for known invasive plant infestations within the Pioneer Project area.

Species (common name)

Management Goal

Proposed Initial Treatment Number of

Infestations

Acres Currently Identified

Manual* Chemical Cultural Bromus tectorum (cheatgrass)

Control within P. sudans; Contain others

Fluazifop-p-butyl – directed spray

6 2.6

Centaurea stoebe ssp. micranthos (spotted knapweed)

Eradicate HP, D 1 0.1

Eradicate HP, D glyphosate or aminopyralid - directed spray

8 11.8

Cirsium arvense (Canada thistle) Eradicate

glyphosate or aminopyralid – directed spray or select

75 33.4

Elymus caput-medusae (medusahead)

Contain HP glyphosate –

broadcast or directed spray

prescribed fire, flaming and seeding

3 21.2

Contain HP flaming and seeding 14 1.9

Hypericum perforatum ssp. perforatum (Klamathweed)

Eradicate glyphosate or

aminopyralid - directed spray

1 0.1

Isatis tinctoria (dyer’s woad) Eradicate HP, D glyphosate-

directed spray seeding 1 0.4

Lepidium latifolium (perennial pepperweed) Eradicate glyphosate -

directed spray 1 <0.1

* Manual Methods; HP- Hand Pulling, D- Digging

In addition, the Pioneer Project proposes to use an integrated approach to restore openings degraded by invasive annual grass species (primarily medusahead) within the project area. These areas are located along roads that can serve as potential vectors for the spread of weeds into uninfested areas within and outside of the project area. To restore these areas, treatment would consist of prescribed fire followed by a broadcast application of glyphosate to initially remove invasive annual grasses from the site. A follow-up application of glyphosate may be needed to completely achieve the desired control of medusahead within these areas.

In the fall, these areas would be revegetated with native species using broadcast and/or a rangeland drill methods. Plugs of live locally adapted plants could also be used if an appropriate source is available. In addition, mulch may be used to ensure germination and seedling survival. Several years of medusahead control may be required to reduce and/or eliminate it from these areas. No more than 20 acres are proposed to be treated annually using this method.

The Lassen National Forest proposes to use the following treatments for any currently known invasive plant infestations within the project area and new infestations located in the future. Treatment methods would be tailored to each infestation and could be used alone or in combination using an integrated pest management (IPM) approach. For a full description of treatment methods refer to Table 5.


Manual treatment—Techniques include digging, hand pulling, clipping, mulching, or tarping. Currently all species, with the exception of Canada thistle, Klamathweed and pepperweed infestations could be treated with manual methods. Up to 38 acres could be treated annually alone or in combination with other methods.

Chemical treatment—Herbicides would be considered where manual or mechanical treatment is infeasible or ineffective. Up to 80 acres may be treated annually using herbicide. No aerial application of herbicides is proposed in this project. Application methods would include select, directed or broadcast spray.

Cultural treatment—Cultural methods are activities that enhance and maintain the growth of desired vegetation to prevent and control invasive plant species infestations (USDA Forest Service 2013). Cultural methods would include seeding, prescribed fire or thermal methods, in which plants are heated and killed through desiccation. Up to 24 acres would be treated annually in combination with other methods within the project area.

Selection of treatment method would follow the process outlined below in Figure 2. It would be conducted by the project manager, with input from an interdisciplinary team. Initial treatment methods were selected based the species present within the project area. Generally, chemical treatment is considered after other methods are deemed ineffective or infeasible. Currently, chemical treatment is being considered as an option for treatment for all species within the project area; however, many of these species would be treated using an integrated approach that includes one or more methods besides chemical. For some species such as Canada thistle, chemical treatment is the only option due the nature of the species. There are an additional 11 invasive plant species currently listed on the Lassen National Forest Invasive Plant List (USDA Forest Service 2014a) that have the potential to be found within the project area. Any species on the Lassen National Forest Invasive Plant List may be prioritized for treatment. Treatment methods for new infestations would be limited to those analyzed in the proposed action and all project integrated design features (Table 6) would apply to all new treatments. Monitoring would occur throughout the life of the project to ensure treatment methods for individual infestations are appropriate and effective (Appendix D). Adjustments, such as a change in methods or timing would be recommended during the Annual Implementation Review Process (Appendix B).


Herbicides Proposed The U.S. Environmental Protection Agency (US EPA) must register all herbicides prior to their sale, distribution, or use in the United States. In order to register herbicides for outdoor use, the EPA requires the manufacturers to conduct toxicity testing on representative species of birds, mammals, freshwater fish, aquatic invertebrates, and terrestrial and aquatic plants. An ecological risk assessment uses the data collected to evaluate the likelihood that adverse ecological effects may occur as a result of herbicide use. The California EPA registers herbicides as well. The Lassen National Forest would only use those herbicides registered by both the US EPA and California.

The Forest Service (FS) conducts its own risk assessments, focusing specifically on the type of herbicide uses in forestry applications by contracting with Syracuse Environmental Research Associates, Inc. (SERA) to conduct human health and ecological risk assessments for herbicides that may be proposed for use on NFS lands. Risk assessments for all proposed herbicides can be found at http://www.fs.fed.us/foresthealth/pesticide/risk.shtml or are available upon request.

The SERA risk assessments represent the best science available, using peer-reviewed articles from the scientific literature and current US EPA documents to estimate the risk of adverse effects to non-target organisms. The risk assessments consider worst-case scenarios including accidental exposures and application at maximum label rates. Only herbicides that have SERA risk assessments are proposed in this action (Table 3).

The following herbicides are proposed for use in the Pioneer Invasive Plant Treatment Project:

Aminopyralid (trade names include Milestone®): This herbicide provides mainly pre- and post- emergence control of many annual, biennial, and perennial invasive plant species, including knapweeds and Canada thistle. It is selective and it does not injure grasses or many broadleaf species, though it can injure legumes (Fabaceae) and members of the sunflower family (Asteraceae). Aminopyralid has an estimated half-life of 35 days and can be considered highly mobile in most soils. It is generally applied to young weeds that are actively growing during time of application. For some species, aminopyralid can provide residual (preemergence) control, thereby reducing the germinitation of target plants and the need for retreatments.

Fluazifop-p-butyl (trade names include Fusilade DX®): This is a post-emergence lipid synthesis inhibitor that is selective on both annual and perennial grasses but does little or no harm to broad-leaved plants, including dicots and ferns. It is relatively immobile in the soil and has an average soil half-life of 15 days. This herbicide is most effective on cheatgrass when applied prior to tillering at the 4-leaf to 5-leaf stage.

Glyphosate (trade names include Accord®, Aquamaster®): This is one of the most widely used herbicides available. It is non-selective (broad spectrum), so it may injure non-target plants. It provides only post-emergent control and is not absorbed through roots. It is non- persistent and relatively immobile in the soil. Plants treated with glyphosate can take several weeks to die; repeat


http://www.fs.fed.us/foresthealth/pesticide/risk.shtml

application is often necessary to remove plants that were missed during the first application.

Herbicides would be applied in accordance with:

1. Product label directions;

2. California Department of Pesticide Regulation requirements;

3. U.S. Environmental Protection Agency requirements;

4. Forest Service best management practices for water quality (Appendix C); and

5. Forest Service direction (FSM 2900, 2150 and 2200) and Handbook (FSH 2109.14).

In addition, the project would include a Pesticide Use Spill Plan and prior to any herbicide use a Pesticide Use Proposal (PUP) (FS-2100-2) and safety plan (FS-6700-7) would be completed by the project lead and approved by the Eagle Lake Ranger District, District Ranger. The Forest Supervisor has delegated authority to the District Rangers to approve projects proposing ground-based applications of non-restricted use chemicals on the LNF. The Pioneer Project is proposing only ground-based applications of non-restricted use chemicals and all herbicides proposed are currently labeled for use in California.

Table 3: Comparison of herbicides proposed for invasive plant treatments Herbicide Name Mode of Action

Target Weed Species

Soil Persistence* Effective Timing

Aminopyralid Growth regulator Broadleaf species 35 days Post-emergence from rosette to beginning of bolt.

Fluazifop-p-butyl

Lipid synthesis inhibitor

Annual and perennial grasses 15 days

Post-emergence, before bolt when cheatgrass is tillering at the 4-leaf to 5-leaf stage.

Glyphosate Amino acid synthesis inhibitor

Non -selective

None: not biologically available to plants

Broadleaf species: Post-emergence rosette to flowering, or fall applications before killing frost. Grasses: Tillering stage (late April to early May)

*Based on average half-life

The estimated annual acreage for chemical treatment is 80 acres and was based on initial proposed treatment of known infestations (~72 acres) plus additional acreage for expanding known infestations and new (currently nonexistent or undocumented) infestations. Assuming that initial treatment is effective, over time, the volume of herbicide used per acre is anticipated to decrease at each treatment site and within the entire project area. The acres infested, however, may remain static for an extended time, as infestations are controlled and reduced in density, but not eradicated. A maximum volume per acre is set for each herbicide (Table 4). Project integrated design features contain additional resource-specific restrictions on treatments (Table 5), including setting stream buffers for each herbicide and application method (Table 7).


Table 4. Herbicide Application Rate limits

Herbicide Active Ingredient measured as active ingredient (a.i.) or acid equivalent (a.e.)

Expected Application Rate pounds a.i. or a.e. per acre

Maximum Annual Application Rate pounds a.i. or a.e. per acre per year

Maximum Annual Treatment number of treatments per site per year

Aminopyralid (a.e.) 0.078 0.11 directed/select--1

Fluazifop-p-butyl (a.i) 0.375 1.125 directed -1

Glyphosate (a.i.) 2.00 4.00 broadcast - 2 directed/select--2

Application rate ranges are those analyzed in SERA risk assessments, which considers likely USFS application methods and label recommended rates.

Proposed herbicide treatments would be implemented during the time of the year when application would be most effective for each species. Aminopyralid is the preferred product for use when possible, due to its selective control of non-target plants, soil residual properties, low toxicity, and overall effectiveness on target plant species (SERA 2007; DiTomaso, Kyser et al. 2013). If new or resurgent target plants emerge, then the infestation may be promptly retreated to ensure effective control (glyphosate only). The project includes a strategy to monitor whether treatments are effective and implemented as designed.

Surfactants and marker dyes may be added to any herbicide application, unless limited by specific project design features. Surfactants and marker dyes are adjuvants—compounds that improve mixing, application, or effectiveness of an herbicide. Marker dyes are used to visually confirm the location of the herbicide application; this assists applicators in limiting application to target plants and reduces the risk of application to non-target organisms and areas. Surfactants enhance absorbing, spreading, sticking, and other properties of herbicides, allowing for use of lower application rates. California does not register surfactants specifically for aquatic use; however, the Washington State Department of Ecology (WSDE) does (2013). As a result, the Washington list would be consulted for surfactants approved for aquatic use. Any chemical found on this list and also registered for use in California could be considered for use in riparian areas of the project (CDNR 2013).

Annual Implementation Review Process

Changes in infestation conditions, treatment effectiveness, and resource conditions may result in the need to adapt treatment prescriptions and treat different locations. Accordingly, the project’s annual program of work may vary spatially and proportionally by treatment method; this is a critical component of an IPM approach. Each year, prior to implementation, an annual treatment plan would be developed and reviewed by the appropriate resource specialists to ensure that the proposed treatment is within the scope of the Decision Notice (Appendix B). Notification on the Forest website would occur to ensure that landowners, partners, regulatory agencies, and Tribes are aware of the proposed treatments.


Table 5. Proposed methods for the treatment of invasive plants in the Pioneer Project Treatment Method

Description

MANUAL

Hand Pulling

Pulling or uprooting plants by hand. It can be effective against certain herbaceous invasive plants, particularly annuals and tap-rooted plants. It is not effective against perennial invasive plants with deep underground stems and roots that are often left behind to resprout.

Clipping Cutting or removing seed heads and/or fruiting bodies to prevent germination. This method is labor-intensive and feasible only for very small infestations.

Digging Using hand tools such as shovels and sharp shooters (shovels with a narrow blade).

Mulching Covering with certified weed-free mulch such as rice straw, grass clippings, wood chips, or newspaper. Mulching is a non-selective treatment and may injure non-target plants.

Tarping

Placing tarps (visqueen, geocloth, or similar material) to shade out or solarize—injure by long exposure to heat of the sun—plants. Tarping is most effective when the soil is damp. Tarping is a non-selective treatment and may injure non-target plants.

CHEMICAL Select

Touching individual target plants with applicators containing herbicide. Because these methods involve direct application, there is a very low likelihood of drift or delivery of herbicides away from treatment sites. Select applications are used in sensitive areas, such as near water, to avoid applying herbicide on the soil, in the water, or to non-target plants. These methods can be used in more variable conditions than directed or broadcast spraying. Specific methods include: Dip & clip–Cutting tool is first dipped in concentrated herbicide, then used to cut target plant; this may be used on individual or groups of target plants Hack & squirt, cut stump–Herbicide is applied to cut surfaces, such as tree or shrub stumps, to eliminate or greatly reduce re-sprouts; this is used on individual target plants Wick, wipe, drizzle–Target plants by touched with a wipe or wick containing herbicide; this may be used on individual or groups of target plants

Directed spray

Spraying herbicide on individual target plants and/or soil adjacent to plants using a regulated nozzle. A regulator nozzle helps to concentrate application towards target plants. This method uses a backpack-mounted wand sprayer or a truck-mounted hose sprayer.

Broadcast spray

Spraying herbicide to an entire infested area, rather than to individual target plants, using a regulated nozzle. This method uses a truck- or ATV-mounted boom sprayer. Broadcast methods are used for denser infestations where application to individual plants would not be feasible. No aerial applications of herbicides are proposed in this project.

Herbicides would be applied according to label directions. Chemical treatments may include use of adjuvants such as surfactants and dyes. Herbicide use is timed to the growth stage and physiology of the target species.

CULTURAL

Thermal

Using heat to desiccate and kill plants. Methods include steaming, flaming, torching, infrared, or microwave. While some equipment uses an open flame. Thermal treatment is only executed when weather and fuel conditions permit and requires certain fire safety precautions. This method is most effective for seedlings and plants in the rosette stage. It can be used in combination with other methods to treat seedlings that germinate after mature plants are removed.

Prescribed Fire

Directly killing a plant through prescribed fire methods. This method can be used to reduce weed infestations in native communities. Can be used in combination with other methods. Not suitable for all species. Timing of the fire is crucial to the effectiveness of the treatment.

Seeding Use of native grasses, forbs, trees and shrubs to prevent and control infestations as well as provide competition for resources would be used in combination with other methods, to prevent spread and restore sites degraded by weed infestations. Methods for reseeding could include drilling, broadcast seeding or plugs.

Although grazing can be effective invasive plant treatment methods, it has been excluded from this proposed project. Animal safety and the location of grazing allotments severely restrict where grazing could be considered. If grazing is considered the only effective and feasible treatment for a particular infestation, then additional environmental analysis would be undertaken to allow for such treatment.


Integrated Design Features (IDFs)

Under certain conditions, some of the proposed methods may present a risk to human health or ecosystem functions, such as water quality and sensitive species. In order to ensure that human health and ecosystem functions are protected during treatment, an interdisciplinary team developed project design features that would a) set safety guidelines, including safe handling of chemicals and public notification prior to treatment; and b) limit the scope of certain treatments near certain resources (Table 6).

Project integrated design features are critical to the project’s goal of rapidly responding to changing conditions and are considered part of the proposed action. They provide clear direction for protecting resources, while still allowing enough flexibility that new and expanding infestations can be effectively and rapidly treated. IDFs would apply to any treatment undertaken as part of this project, including new infestations, expanding infestations, and new invasive species, and would be included in the Annual Implementation Review process.

Table 6. Project Integrated Design Features IDF Project Integrated Design Features (IDFs)

Herbicide Application

1 Herbicide application would comply with product label directions and applicable legal requirements.

2 Herbicide formulations would be limited to those containing one or more of the following 3 active ingredients: aminopyralid, glyphosate and fluazifop-p-butyl. Herbicide applications would only treat the minimum area necessary to meet site objectives.

3 Herbicide application methods are limited to select (e.g. wicking, wiping, dipping clippers), directed spray (use of backpack sprayer or hand held nozzle to aim application at specific target species), and broadcast spray (truck or ATV mounted boom sprayer) as permitted by the product label and IDFs. No aerial herbicide applications would occur.

4 Spray application drift control measures: 1) Only ground based equipment would be used 2) All applications would cease when weather conditions exceed those on the label 3) Applications would not be performed when the National Weather Service forecasts a greater than 50 percent probability of measurable precipitation (greater than 0.1") within the next 24 hour period. 4) Applications would cease when wind speed exceeds 10 mph or 5 mph when spraying near Rare plants (IDF#

29) 5) Spray nozzles would produce a relatively large droplet size (500- 800 microns) 6) Low nozzle pressures would be used (15 psi) 7) Spray nozzles would be kept within 20 inches of target vegetation during spraying 8) A pressure gauge or pressure regulator would be required on each backpack sprayer

5 Herbicides would be applied under the direction of a certified applicator in accordance to label instructions and applicable federal and state pesticide laws.

6 Personal Protective Equipment (PPE) would be used in accordance with the product label and California Department of Pesticide Regulation requirements.

7 Chemicals would be stored in designated storage facilities consistent with FSH 2109.14, Chapter 40. Unused herbicides would be disposed of in accordance with the product label and FSH 2109.14, Chapter 40. If the product label and FSH differ, the more restrictive storage and disposal guidelines would be followed.


IDF Project Integrated Design Features (IDFs)

Cultural Resources

8 Local Native American Tribes would be consulted on the entire project area to allow tribal members an opportunity to provide input. Species identified by tribes would be protected in the same manner as Rare Plant Species (see below).

9 Ground disturbing actions (e.g. grubbing with a shovel) would not be used in known cultural resource sites, unless there is on-site monitoring by a staff archeologist or the technique has been agreed to by a staff archeologist who has determined that the technique would have no effect on cultural resources.

10 If cultural resources are discovered during project implementation where none are known, the Eagle Lake RD Heritage Resources Staff would be contacted immediately and the discovery would be dealt with as appropriate.

11 No herbicide application would take place in the Roxie Peconom campground 7 days before and 7 days after the annual Bear Dance, traditionally held in June.

Fire and Fuels

12 Fire lines would be constructed for prescribed fire operations, except where existing roads, skid trails, or natural barriers would serve as control lines. Hand lines would not be constructed within Riparian Conservation Areas, but fire would be allowed to back into the site. If needed, wet line would be used. Hand lines would also not be constructed in cultural resource sites.

13 Fueling of drip torches would not occur within 25 feet of surface waters, except at existing facilities.

14 Vehicles and/or equipment that are driven and/or come in contact with medusahead sites should be carefully inspected prior to leaving the site. When appropriate, vehicles and equipment would be washed and cleaned to prevent seed or plant fragment movement.

15 Vehicle and equipment wash stations would be designated by a botanist prior to project implementation. These areas would be surveyed for weeds and treated accordingly if needed.

Hydrology

16 All surfactants used near water will be approved for aquatic applications (WSDE 2013 and CPRD 2013).

17 All wells, ponds, and springs used for domestic water supplies would be protected with a 200-foot buffer for herbicide treatment and mixing. These would be reviewed each year during the annual implementation process.

18 Streams used for domestic water supply (e.g. West Fork of Willard Creek) would be protected with a 15 feet buffer for 0.5 miles upstream of the diversion point for herbicide treatment and a 200-foot buffer around the diversion intake. Within this buffer, only select methods would be used.

19 Herbicide mixing would not occur within 150 feet of live surface waters.

20 Herbicide use buffers have been established for streams and other water bodies (listed in Table 7). Buffers vary by herbicide and application method. Tank mixtures would apply the largest buffer as indicated for any of the herbicides in the mixture.

Range 21 Grazing permitees would be informed of any herbicide use within allotments and timing of treatments would be

coordinated as necessary.

Recreation

22 For herbicide treatment within 100 feet of roads, Roxie Peconom campground, and established dispersed camping sites, cautionary notice signs would be in the treatment area prior to herbicide treatments.



Silviculture 23 When using glyphosate, avoid or shield plantation conifers seedlings and desired woody vegetation (black oak,

aspen, cottonwood, willow, etc.) seedlings when spraying nearby.

24 Do not use herbicides that target broadleaf or woody species when possible, if working near desired woody vegetation seedlings. Soils

25 Application of Aminopyralid (including equipment rinsing) would not occur on deep, coarse textured, saturated soils. The appropriate FS specialists would be consulted about the proper timing of herbicide application in the spring prior to treatments.

Botany 26 No broadcast herbicide application would occur within 100 feet of Sensitive or Special Interest plant species

(Rare plants). No directed spray or select application would occur within 25 feet of Rare plant species, with the exception of Penstemon sudans located within cheatgrass treatment areas, where the application of fluazifop-p-butyl may occur. Buffers may be waived if plants are covered by a protective barrier. Under saturated/wet soil conditions, select is the only herbicide application permitted within 100 feet of Rare Plant species. Modifications may be made with consultation with a staff botanist.

27 When Rare plant species are within 25 feet of digging, covering, or flaming treatments, plants would be clearly identified and care taken to avoid direct impacts to individuals. No buffers are required for hand pulling.

28 Only locally adapted native plant species would be used for revegetation. All mulch and seed material would be certified weed- free.

29 Glyphosate or aminopyralid spray applications would not occur when the wind velocity is greater than five miles per hour when working within 200 feet of rare plant occurrences.

30 All contractors would be instructed on the proper identification of rare plant species prior to project implementation activities.

31 Rare plant surveys would be conducted within 500 ft. of new infestations identified for chemical treatment, and within 25 ft. of new infestations identified for manual treatments prior to implementation.

Wildlife 32 Northern goshawk: Use of mechanical equipment (e.g. weed whacker, ATV, chainsaw) would be prohibited

within approximately ¼ mile of a nest site during the breeding season (February 15 - September 15), unless surveys confirm that northern goshawks are not nesting.

33 California Spotted Owls: Use of mechanical equipment (e.g. weed whacker, ATV, chainsaw) would be prohibited within approximately ¼ mile of nest sites during the breeding season (March 1 - August 31), unless surveys confirm that California spotted owls are not nesting.

In addition to IDFs designed for the project, the following buffers have been designed to minimize or eliminate risks to aquatic resources and water quality (Table 7). Toxicity, soil mobility, and runoff potential were considered in selecting buffer distances and application methods allowed. In some instances, buffer distances are greater than those allowed on the product label, in order to comply with USFS Best Management Practices for Water Quality (Appendix C).


Table 7. Water feature buffers for herbicide application Water Feature

Her

bici

de A

ctiv

e In

gred

ient

LIVE WATER (Perennial/intermittent streams. ponds, springs, seeps, seasonal wetlands and wet meadows)

NO LIVE WATER (seasonally flowing / intermittent channels that support a continual strip of riparian vegetation)

Dry washes without riparian vegetation

Herbicide Application Method

Broadcast spray

Directed spray

Select

Broadcast spray

Directed spray

Select

No buffer required,

unless otherwise

specified by project design

features.

Aminopyralid

Treatment not proposed 10 ft. Water’s edge

Treatment not proposed 10 ft. No buffer

required

Fluazifop-p-butyl Treatment not proposed 50 ft. Treatment not

proposed Treatment not proposed 25 ft. Treatment not

proposed Glyphosate 50 ft. 10 ft. Water’s edge 25 ft. 10 ft. No buffer

required Buffer distances are measured from the edge of scoured continuous channel or water’s edge. Dry seasonal wetlands and meadows- no buffer required for direct spray or select treatments for glyphosate and aminopyralid. Fluazifop-p- butyl would not be used within 25 ft. of dry seasonal wetlands and meadows. Buffers for domestic water sources are specified in IDF 17 & 18. Select methods near live water would use an aquatic formulation of Glyphosate.

Alternative 2 - No Action

Under the No Action alternative, current management plans would continue to guide management of the project area. Primarily manual control efforts would occur under this alternative. No mechanical, chemical, or cultural treatment activities would be implemented, except those for which there is existing environmental analysis.

Public Involvement

Scoping

Scoping for this project was initiated on September 8, 2014. Individuals and groups that expressed interest in response to the SOPA and all adjacent landowners were mailed a copy of the scoping document for this project. Two individuals/organizations responded in writing during the scoping period. The analysis of the public comments is contained in the document titled, “Pioneer Project Public Scoping Issue Analysis and Alternative Development” (located in the Pioneer Project record, ELRD office).

Issues

The Forest Service separates issues into two groups: significant and non-significant issues. Significant issues are defined as directly or indirectly caused by implementing the proposed action. Non-significant issues are identified as: 1) outside the scope of the proposed action; 2) already decided by law, regulation, Forest Plan, or other higher level decision; 3) irrelevant to the decision to be made; or 4) conjectural and not supported by scientific or factual evidence. The Code of Federal Regulations (40 CFR Part 1501.7(3))


of The Council on Environmental Quality’s (CEQ) NEPA regulations requires us to, “Identify and eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review…” No significant issues were identified from the public scoping comments.

Alternatives Considered but Eliminated from Detailed Study

Two additional alternatives were suggested during scoping and project development but it was determined that these would not meet the purpose and need of the project.

Alternative 3 — Aerial Application of Herbicides

Aerial application of herbicides was not considered in detail because the potential risks to human health and resources outweigh the potential habitat improvements that might be gained through treatment. The prioritized infestations are small enough to allow for cost-effective ground-based herbicide treatments, eliminating the need to consider the less targeted approach of aerial application.

Alternative 4 — Use of Grazing

The use of grazing (including goats) was not considered in detail because of the lack of active grazing allotments containing invasive plants within the project area. Most infestations do not occur in active grazing allotments, which restricts the feasibility for the use of grazing as an invasive plant control method. Additionally, most occurrences are small enough that there would not be sufficient forage to warrant the use of grazing animal as a treatment method. However, grazing would continue to be considered as an invasive plant control method in other areas of the Lassen National Forest. If grazing were considered the only effective and feasible treatment for a particular infestation, then an additional environmental analysis would be undertaken to allow for such treatment.

Decision Framework

Given the purpose and need, the Responsible Official reviews the proposed action and the other alternatives in order to make the following decision:

1) Whether to implement the Proposed Action as described above 2) Whether to implement an alternative which better responds to the Purpose and Need for Action 3) Whether the No Action Alternative should be implemented.


Environmental Consequences This section describes the environmental impacts of the alternatives in relation to whether there may be significant environmental effects as described at 40 CFR 1508.27. Further analysis and conclusions about the potential effects are available in resource specialist reports and other supporting documentation located in the project record. These reports are available upon request.

The cumulative effects boundaries for each resource unless otherwise noted were defined as the project area. A summary of the activities considered during cumulative effects analysis can be found in the Diamond Area PORFFA Report (Past, Ongoing, and Reasonably Foreseeable Future Actions), hereby incorporated by reference.

The following documents are summarized in this EA are available upon request, and are hereby incorporated by reference into this assessment:

Pioneer Invasive Plant Treatment Project, Report for Fire and Fuels; Lewis, December 11, 2014 (Fire and Fuels Report).

Management Indicator Species Report, Pioneer Invasive Plant Treatment Project; Rickman and Vandersall, January 8, 2015 (MIS Report).

Biological Evaluation for the Pioneer Invasive Plant Treatment Project; Rickman and Vandersall, February 25, 2015 (BE).

Pioneer Invasive Plant Treatment Project, Range Allotment Input; Pasero, December 9, 2014 (Range Report).

Biological Evaluation and Assessment for R5 Forest Service Sensitive and Federally Listed Plant Species, Pioneer Invasive Plant Treatment Project; Bovee and Sanger, February 25, 2015 (Botany BE/BA).

Pioneer Invasive Plant Treatment Project, Hydrology Report; Blaschak, April 14, 2015 (Hydrology Report).

Pioneer Invasive Plant Treatment Project Soil Report; Peters, December 17, 2014 (Soils Report).

Cultural Resources Report, Pioneer Invasive Plant Treatment Project; Gudiño, January 8, 2015. (Cultural Report)

Pioneer Invasive Plant Treatment Project, Recreation and Visual Resources Report; Pasero, December 9, 2014 (Recreation and Visual Resources Report).

Invasive Plants Effects Analysis Report, Pioneer Invasive Plant Treatment Project; Sanger, February 26,2015 (Invasive Plants Report).


Additional documents used for the Pioneer project are also available upon request and are hereby incorporated by reference into this assessment, including the following:

Migratory Landbird Conservation on the Lassen National Forest, Pioneer Invasive Plant Treatment Project; Rickman, October 31, 2014 (Migratory Landbird Assessment).

Silviculture Report for the Pioneer Invasive Plant Treatment Project; Wilcox, November 7, 2014 (Silviculture Report).

Pioneer Invasive Plant Treatment Project, Invasive Species Risk Assessment; Sanger, December 19, 2015 (Invasive Species Risk Assessment).

Risk Assessment Worksheets for Milestone, Fusilade, Rodeo and Roundup for the Pioneer Invasive Plant Treatment Project, Created on October 15 and 21, 2014.

Human Health and Ecological Risk Assessments for Aminopyralid, Fluazifop-P-butyl, and Glyphosate.

Invasive plants

Invasive plant species pose a serious threat to biological diversity because of their ability to displace native species, decrease the availability of forage for wildlife, and degrade soil structure (Bossard et al. 2000). They can also alter physical ecological processes such as hydrology, and increase soil erosion, siltation in streams, fire intervals, and fire severity (Bossard et. al. 2000). Disturbance, whether it is natural (such as the Moonlight Fire) or associated with management activities, often creates ideal conditions for the introduction and establishment of invasive species. Colonization into disturbed sites is often facilitated by the removal of natural barriers that frequently keep invasive species in check, such as unsuitable light, soil, or moisture conditions (Parendes and Jones 2000). In addition, wildfires can increase resource availability by reducing resource use by resident vegetation (through mortality or injury) or by altering the form of availability of nutrients (Zouhar et al. 2008).

At present, a large portion of the project area is considered relatively free of invasive plants. Surveys for invasive plants have been ongoing within the project area for over 20 years as part of project based rare plant surveys (USDA Forest Service 2014b). In addition, project specific surveys in 2013 and 2014 were conducted in certain riparian areas to map potential invasive plant species locations for this project. These surveys documented approximately 135 invasive plant locations throughout the project area. As a result, of the 26,600 acres of Lassen NF lands within the project area, currently only 274 acres or approximately 1 percent of the these lands are infested.

Most invasive plant infestations are associated with vectors such as riparian corridors and roads. These infestations often provide seed sources for invasive species moving into the less invaded areas throughout the project area. Roads contribute to weed dispersal and create suitable habitat for invasion by altering environmental conditions, stressing or removing native species, and allowing for easier movement by wild or human vectors (Trombulak and Frissell 2000). Habitats that intersect roads and riparian areas


are at the greatest risk for invasive plant invasion and spread.

Hand-pulling and grubbing efforts within the project area over the last 10+ years have proven ineffective in reducing or eradicating most of the infestations within the project area. Many species have creeping root systems and hand pulling and grubbing does little to reduce or eliminate these infestations (DiTomaso, Kyser et al. 2013). Herbicides are needed for these hard-to-control species, and the herbicides proposed for use were selected specifically for their effectiveness against invasive species within the project area (DiTomaso, Keyser et al. 2013; Tu et al. 2001). Timing of application and retreatment may be needed to achieve desired results throughout the life of the project.

Alternative 1 Direct and Indirect Effects

Under the Proposed Action up to 80 acres of invasive plant infestations would be treated annually using a variety of methods including herbicides. Treatments would utilize an IPM approach on currently documented infestations or new infestations found over the life of the project. As a result, with implementation of the Proposed Action, small isolated infestations are expected to be eradicated and an initial reduction in size would be expected for the larger infestations with eventual control and/or eradication within the life of the document. New sites, expanded sites, and new species discovered within the project area would be treated with this alternative using methods determined by the protocol outlined in the Proposed Action. Repeated treatments would likely be necessary at many sites because established infestations have built up an on-site seed bank that may take several years to deplete. The annual implementation review process plan would ensure resources are protected and appropriate project Integrated Design Features are incorporated into all new treatment areas (Appendix B), and efficacy monitoring would be reviewed on a regular basis to ensure treatment methods are successful in controlling infestations (Appendix D).

Overall, manual control methods are most effective for control of annual species and tap-rooted plants; they are considered less effective against invasive plant species with deep underground stems and roots, which have the ability to resprout following treatment (Tu et al. 2001). Herbicide treatments would be used to control larger infestations and those species with creeping rootstalks in conjunction with manual or cultural treatments where needed throughout the project area. Many times herbicide treatments are considered to be the most economic and effective method of invasive plant species control (DiTomaso et al. 2006). However, their effectiveness is highly dependent upon the biology of the target species, herbicide formulation, application method, and site-specific variables such as climatic and environmental conditions (Bossard et al. 2000).

Implementation of the Proposed Action would result in the eradication of high priority invasive species (forbs) where herbicide treatment is proposed, and the control or containment of annual grasses where treatments are proposed for restoration of native habitats and rare plant occurrences. As a result, of the seven invasive plant species proposed for treatment within the Pioneer Project area only cheatgrass and medusahead are not expected to be eradicated within the life of the project (Table 2). While these species


are not expected to be eradicated, benefits would come from treating medusahead and cheatgrass to improve habitat for wildlife and rare plants that occur in the areas proposed for treatment. These areas have been degraded by invasion and site-specific treatments would improve habitats and reduce seed sources within the project. In addition, cultural methods including post treatment seeding with natives would help with the long-term restoration of these sites.

Overall, the invasive plant treatments proposed for the Pioneer project would be effective in eradicating, controlling, or containing invasive plant populations throughout the project area, as well as help restore degraded habitats and rare plant species. In addition, integrated design features would greatly reduce the risk of inadvertent impacts to humans and other resources in the area. As a result, it is expected that five of the seven species proposed for treatment within the project area could be eradicated within the boundaries of the Pioneer project. Implementation of the proposed project would also have low potential to spread weeds within the project area, due to the overall goal of eradicating, containing, and controlling weed infestation within the project area (Invasive Species Risk Assessment, project record).

Cumulative Effects

The cumulative effects analysis area for invasive plants is the Pioneer project area. This area captures all the invasive plant infestations impacted by the Moonlight Fire on the Lassen National Forest lands and introduced or spread during fire suppression and restoration activities. Furthermore, the project area captures infestations near the fire and along vector corridors with the potential to spread into burned areas if infestations are not controlled.

Vectors, including vehicles, hikers, water, roads and wildlife, as well as projects and activities with the potential for ground disturbance such as road maintenance, are ongoing and would continue to be present within the project area. These factors have contributed in the past, and continue to contribute currently to the establishment of invasive species within the project area. All ongoing and future projects have project specific Integrated Design Features included as part of the proposed action to insure that invasive species are not spread by project implementation activities.

Ongoing or future vegetation treatments on private lands may have cumulative impacts to the species under consideration within the project area, and could have contributed to spread, but since treatment of invasive species by the various landowners is unknown, the nature and extent of the impacts from these activities cannot be quantified. However, if new introductions are discovered moving into the project from private lands, the Pioneer project has been designed to treat new infestations early while small, and potentially eradicate these new infestations over time from Lassen NF lands.


With the implementation of the No Action Alternative, herbicides and cultural treatments would not be a tool for eradication of invasive species infestations within the Pioneer project area. The Lassen NF would still attempt to conducted limited treatment by manual methods on those species without a creeping root


system, but eradication would be impossible. In addition, invasive plant prevention measures would continue to be incorporated into new projects as Integrated Design Features and would serve as a critical means of limiting spread of existing infestations and introductions of new invaders.

Without the implementation of the Proposed Action, many infestations would continue to spread and increase, eventually becoming well established and potentially impossible to eradicate without intensive and expensive treatments. Seeds would continue to be transported and infest new sites throughout the area particularly within riparian areas and adjacent meadow habitats, and existing infestations would be expected to increase in spatial extent and density over time. As a result, invasive species would increasingly affect native ecosystems, as well as Sensitive species. Native plant diversity and wildlife habitat quality would be reduced over time due to increasing dominance by invasive species. Few, if any infestations or invasive species would be eradicated or contained under this alternative. Acreage of existing populations would most likely increase as manual control methods have proven inadequate in the past.

Cumulative Effects

The scope of analysis and the effects of past, ongoing and future foreseeable actions under No Action Alternative would be identical to those discussed for Alternative 1. Vectors would continue to spread invasive species throughout the project area, and Integrated Design Features would continue to be incorporated into proposed projects. Invasive species infestations; however, would only be treated on a limited basis and the impacts associated with them would compound over time.

Threatened Endangered and Sensitive Plant (TES) Species

Ten Forest Service Region 5 Sensitive plant species are either known to occur or contain potential habitat within the Pioneer Invasive Plant Treatment Project boundary. Of these, five are known to occur within the Pioneer Project area: Botrychium minganense (Mingan moonwort), Botrychium montanum (western goblin), Lomatium roseanum (adobe parsley), Penstemon sudans (Susanville beardtongue), and Pyrrocoma lucida (sticky goldenweed). An additional five species are not known to the project area, but contain potential habitat within the project area: Botrychium ascendens (upswept moonwort), Botrychium crenulatum (scalloped moonwort), Botrychium pedunculosum (stalked moonwort), Botrychium pinnatum (northwestern moonwort), and Bruchia bolanderi (Bolander’s bruchia). No other currently listed Region 5 Sensitive plant species or federally listed plant species are known to occur or have potential habitat within the project area. Effects to Sensitive plant species are discussed in detail in the Biological Evaluation and Assessment for R5 Sensitive and Federally Listed Plant Species, Pioneer Invasive Plant Treatment Project.

Alternative 1

This section will discuss both the environmental effects of high priority invasive plant treatments that are currently identified within the Pioneer Project area to Region 5 Sensitive plant species, and the effects of invasive plant treatments that may be proposed in future years as additional infestations are identified for


treatment. The ecological effects of fluazifop-b-butyl, aminopyralid, and glyphosate are discussed in detail in Human Health and Ecological Risk Assessments produced by Syracuse Environmental Research Associates (SERA) for each herbicide (SERA 2007; 2011; 2014a). These Risk Assessments take into account applications rates and methods to quantify potential risks to non-target plant species from direct spray, off-target drift, and off-site movement of these herbicides. While information specific to adjuvants used in commercial formulations of glyphosate is incorporated into Risk Assessments (SERA 2014b), risks from adjuvants that may be added to fluazifop-p-butyl and aminopyralid are discussed only in general terms within the risk assessments for these herbicides. Adjuvants would be approved for aquatic use by the Washington State Department of Ecology (2013), and also registered for use in California. Surfactants such as Competitor® are modified vegetable oils, which would be very unlikely to produce secondary breakdown products that would act as toxins to rare plant species. In addition, marker dyes such as Hi-light® Blue are water-soluble, contain no listed hazardous substances (SERA 1997; USDA Forest Service 2007b), and would be unlikely to cause adverse effects on rare plant species.

Although species-specific information regarding the direct effects of the three proposed herbicides on Region 5 Sensitive plant species is unknown, Risk Assessment hazard quotients that quantify the potential risks to non-target plant species from the proposed action will be used to discuss project effects to Sensitive plant species with known occurrences or potential habitat within the Pioneer Project area. This analysis includes species that are either known to occur or have potential habitat within the Pioneer Project area. There would be no effect to other Region 5 Sensitive plant species.

Direct Effects

Direct effects involve physical damage to plants or their habitat. Manual and cultural treatments have the potential to directly affect plant species, resulting in death, altered growth, or reduced seed set through physically breaking, crushing, burning, scorching, or uprooting plants. Herbicides, formulated to kill plants, have the potential to injure or kill plant species upon contact, depending upon the selectivity of the herbicide and sensitivity of the plant species. Direct effects of herbicides vary according to the chemical composition and application rate of the herbicide and are discussed in detail below.

Direct Effects of Manual and Cultural Treatments

The direct effects of manual (handpulling, clipping, digging, mulching, tarping) and cultural treatments, (thermal treatments, prescribed fire, seeding activities) would be restricted to the area of treatment and area immediately surrounding the infestation that may experience foot or equipment traffic during implementation. There are no known occurrences of Botrychium minganense, Botrychium montanum, Lomatium roseanum, or Pyrrocoma lucida within 25 feet of manual or cultural treatments currently proposed for high priority infestations. There are portions of five suboccurrences of Penstemon sudans (totaling 1.0 acres) that are within 25 feet of digging or flaming treatments. These suboccurrences would be identified to avoid direct impacts to individuals (IDF #27). Although hand pulling is not excluded from Sensitive plant occurrences, the effects of this action on Penstemon sudans would be minimal due to the low potential for ground disturbance from this action. In addition, contractors would be trained in the


identification of Sensitive plant species, further minimizing the potential for direct effects from these treatments (IDF #30). The area within 25 ft. of future proposed manual and cultural treatments would be surveyed for Sensitive species so that these same protective measures could be applied (IDF #31). These design features would minimize or remove the risk of direct effects to Sensitive species from manual and cultural treatments.

Direct Effects of Chemical Treatments

The direct effects of herbicide application would vary by herbicide and depend upon whether the herbicide is non-selective (killing all plant species), or selective (killing certain groups of plants, specified below). Chemicals identified for use within the Pioneer Project include aminopyralid, fluazifop-p-butyl and glyphosate.

The effects of aminopyralid, fluazifop-p-butyl, and glysophate on non-target plant species are quantified in the SERA Risk Assessments for these herbicides, which report risk in terms of a Hazard Quotient (HQ). A Hazard Quotient value of 1 represents a threshold of concern (SERA 2007; 2009; 2011; 2014a). Hazard Quotient values greater than 1 exceed this threshold of concern; values less than one represent an acceptable level of risk without further mitigation. If sprayed directly on non-target plant species, both aminopyralid and glyphosate have very high probabilities of directly affecting susceptible species, with modelled HQ values of 390 (aminopyralid) and 1,538 (glyphosate). The modelled risk from direct spray with fluazifop-p-butyl, by contrast, returned an HQ value of 0.5, representing a relatively low risk of damaging non-grass species.

No broadcast application of aminopyralid or glyphosate would occur within 100 ft. of Sensitive plant species, and no directed spray or select application of these herbicides would occur within 25 ft. of Sensitive plant species unless plants were covered by a protective barrier (IDF #26). Because the area within 500 ft. of future proposed treatments would be surveyed for Sensitive species prior to treatment (IDF #31), these same protective measures would be applied to future infestations prioritized for treatment. With buffers implemented as described, the chemical application of glyphosate or aminopyralid would not directly affect Sensitive plant species.

The application of fluazifop-p-butyl would be excluded from within 25 ft. of all Sensitive plant occurrences except for occurrences of Penstemon sudans identified for cheatgrass treatment (IDF #26). The direct application of an herbicide within a Sensitive plant occurrence could occur only in occurrences of Penstemon sudans identified for treatment with fluazifop-p-butyl due to high levels of cheatgrass. There are five suboccurrences of Penstemon sudans containing infestations of cheatgrass that are currently prioritized for treatment with fluazifop-p-butyl. Of the 16.45 acres of Penstemon sudans within these suboccurrences, 2.65 acres (16%) are proposed for treatment. Cheatgrass co-occurs with plants of Penstemon sudans at these sites, and so plants of P. sudans on these 2.65 acres would likely experience direct spray from fluazifop-p-butyl. Because, however, fluazifop-p-butyl is selective on true grasses, the risk of adverse direct effects to Penstemon sudans, a dicot, would be low, with a reported hazard quotient of 0.5 (SERA 2014a). As a result, the chemical application of fluazifop-p-butyl would have a very low


risk of causing adverse direct effects to Penstemon sudans, and would not directly affect other Sensitive plant species.

Indirect Effects

Indirect effects are separated from an action in either time or space. These effects, which can be beneficial or detrimental to rare species, may include changes in plant community composition once invasive plant species are removed, or the indirect effects of herbicide application, including off-target drift, surface runoff, soil percolation, or wind erosion.

Plant Community Composition

Invasive plant treatments may alter plant community composition by decreasing invasive plant cover and increasing the habitat available to other plant species. Indirect beneficial effects are likely as a result of the control or eradication of invasive plants from suitable habitat that is in close proximity to existing occurrences of rare plants. This beneficial effect would be most likely to occur within Penstemon sudans occurrences where cheatgrass is proposed for treatment (2.65 acres). There are also 15 suboccurrences of P. sudans within 25 ft. of Canada thistle, medusahead and spotted knapweed infestations that are currently prioritized for treatment. Although buffers would prevent manual, cultural, or herbicide treatments from occurring within P. sudans occurrences (except for hand-pulling), treatments adjacent to these occurrences may open up additional habitat for P. sudans to colonize.

Herbicide Application

The indirect effects of herbicide application may include off-target drift, surface runoff, soil percolation, wind erosion, or a combination of these factors. The indirect effects of herbicide application are quantified using models included in SERA Risk Assessments for each herbicide. Each exposure scenarios is described in further detail below:

Off-target drift

When using targeted spray applications, there is some potential for impact from drift down-wind of the application area. These impacts can range from reduced plant vigor, abnormal growth, or necrosis, to death depending on both the exposure (dose) and the sensitivity of the affected plant. Herbicide drift is influenced by a number of factors including site topography and surrounding vegetation, spray droplet size, wind speed and direction, and height of spray nozzle. This analysis of off-target drift uses SERA Risk Assessment exposure assessment and risk characterization models for each herbicide (SERA 2007, 2011, 2014a) to provide an estimate of the maximum projected risk to non-target plant species. Because herbicide drift is influenced by a number of factors, drift estimates are intended to be used only as generic estimates (SERA 2007). Risk is again characterized using hazard quotient (HQ) values, with hazard quotient values >1 representing a level of concern. Model assumptions included boom (broadcast) application using a medium-coarse droplet spray at 20 inches above the target vegetation, wind speeds of 10 mph, and report hazard quotients for no observable effect concentration (NOEC) thresholds. It is


important to note that these model assumptions are substantially different from the application of herbicide as proposed under the Pioneer Project; however, these model results would be utilized to provide a general assessment of the relative risks to non-target plants represented by each herbicide.

Fluazifop-p-butyl is proposed for treatment within and adjacent to five suboccurrences of Penstemon sudans (Table 5) but greater than 500 ft. from any other occurrences of Sensitive plant species. Because fluazifop-p-butyl targets true grasses, it has a low HQ for risk to non-grass species. The risk of indirect effects to Penstemon sudans or any of the other Sensitive plant species analyzed within this document from the off-target drift of fluazifop-p-butyl would therefore be low to none.

For aminopyralid and glyphosate, SERA Risk Assessment models report HQ values for off-target drift below the threshold of concern at a distance of 100 ft. from the application of aminopyralid, at a distance of 500 ft. from the application of glyphosate (SERA 2007; 2011). There are no occurrences of Botrychium minganense, Botrychium montanum, Lomatium roseanum, or Pyrrocoma lucida within 500 ft. of infestations currently prioritized for treatment with herbicides. The potential for indirect effects from off-target drift to known occurrences of these species is therefore low to none.

There are 27 suboccurrences of Penstemon sudans within 500 ft. of proposed treatments that would utilize either glyphosate or aminopyralid. The risk of off-target drift to Penstemon sudans would decrease significantly with increasing distance from the spray area, and so the 100 ft. buffers on broadcast application and 25 ft. buffers on directed spray or select application (IDF #26) would reduce this risk to non-target plants. Taking into account application buffers for glyphosate and aminopyralid and application method, there are 17.2 acres of P.sudans within areas where the maximum risk of adverse effects to non-target vegetation from off-target drift is modelled as HQ > 1.

The actual number of acres of P. sudans at risk of adverse effects from off-site drift is, however, expected to be substantially lower than 17.2 acres. The assumptions used to model these off-target drift HQ values differ substantially from the application of glyphosate and aminopyralid as proposed in the Pioneer Project. While model inputs include low boom ground application (broadcast) using fine to medium/coarse drop size distributions, the application of herbicides proposed in the Pioneer Project would differ in several important respects. Herbicides would be applied with backpack sprayers for all but two infestations, spray nozzles would produce a relatively large droplet size, and low nozzle pressures (15 psi) would be used (IDF #4). In addition, glyphosate or aminopyralid spray applications would not occur when the wind velocity is greater than five miles per hour when working within 200 ft. of rare plant occurrences (IDF #29). According to the Risk Assessment for glyphosate, offsite drift from backpack applications should be reduced substantially compared to broadcast spraying from even a low boom ground application, although the extent of this reduction cannot be quantified (SERA 2007). Based upon the inclusion of project design features to reduce the risk of offsite effects from drift (wind restrictions, coarse droplet size, low nozzle height), it is reasonable to conclude that adverse effects to Penstemon sudans from off-site drift are unlikely to occur or would have only scattered, incidental effects to this species. Monitoring of Sensitive plant occurrences where the modelled hazard quotient for herbicide drift


is greater than 1 would be used to validate these assumptions, and would be conducted for three years following herbicide application (Appendix D). Monitoring results would trigger modifications to future invasive plant treatments if reduced plant vigor or abnormal growth were observed, or if occurrence densities decreased significantly more than control sites.

An additional consideration is that 19 weed infestations near these Penstemon sudans occurrences are proposed for treatment with either glyphosate or aminopyralid. Of these, glyphosate presents a much higher risk of off-target drift effects than does aminopyralid. As specified in the proposed action, aminopyralid is the preferred product for use when possible, and so the actual application of glyphosate is expected to be lower than the maximum proposed application, further reducing the risk to Penstemon sudans from the off-target drift of glyphosate application.

If additional surveys detect new Sensitive plant occurrences within 500 ft. of proposed future treatment activities, the same IDFs that limit off-site drift would be applied, and minimal effects to other Sensitive plant species would result.

Other off-target movement (surface runoff, soil percolation, wind erosion)

Adverse effects to non-target plant species such as Sensitive species may also occur if surface runoff moves an herbicide outside the treatment area, if an herbicide leaches through the soil, or if wind erosion results in the translocation of contaminated soil. This would primarily be a concern for aminopyralid, which remains active within the soil following application. The potential for off-target movement is greatest for spot applications where the herbicide is applied directly to the soil, a method that is proposed only for the application of aminopyralid. Other targeted herbicide applications (directed foliar spray, wicking and wiping, drizzle, dipping and clipping) proposed under Alternative 1 are expected to have limited risk of movement from runoff since herbicides would not be applied directly to the soil.

Off-target movement from runoff and soil percolation was also modelled in the SERA Risk Assessments for each proposed herbicide (see the Soils and Hydrology sections for more details). Review of exposure scenarios and risk characterizations for aminopyralid, fluazifop-p-butyl, and glyphosate indicated that hazard quotients for surface runoff and groundwater contamination were below the threshold of concern in all probable application. These risks would be further reduced by the prohibition of aminopyralid application on deep, coarse-textured soils (IDF #25), and the prohibition of herbicide application when there is a high chance that precipitation > 0.1” would occur within the subsequent 24 hours (IDF #4). Although the reduction of risk represented by these protection measures cannot be quantified, they would further reduce the possibility that off-site herbicide movement via surface water or percolation through the soil would result in adverse effects to Sensitive plant species.

Wind erosion leading to off-site contamination of pesticides that may affect non-target plant species is also likely to be highly site-specific. The amount of herbicide that might be transported by wind erosion depends upon several factors, including the application method, the depth of incorporation into the soil, wind speed, and topographic and surface conditions. In the SERA Risk Assessments, risks


associated with wind erosion are calculated by modelling the amount of herbicide that might be transported off-site based upon estimates of annual soil loss associated with wind erosion and the assumption that the herbicide is incorporated into the top 1 cm of soil. Review of exposure scenarios and risk characterizations for aminopyralid, fluazifop-p-butyl, and glyphosate indicated that hazard quotients are below the threshold of concern for the effects of wind erosion to plant species that are sensitive to these herbicides in all scenarios (Soils Report, project record).

If additional surveys detect new Sensitive plant occurrences within 500 ft. of proposed future treatment activities, the same IDFs that limit off-target movement would be applied, and minimal effects to Sensitive plant species would result. Overall, the expected risk of indirect effects from surface runoff, soil percolation, or wind erosion to Sensitive plant species is expected to be low to none.

Cumulative Effects

Current inventories of Sensitive plant species capture the aggregate impact of past human actions and natural events that have led to the current inventory of these species within the project area (CEQ 2005). Past human actions and natural events are therefore implicit within existing conditions and are addressed within the Existing Environment section above. These include the effects of ongoing manual invasive plant treatments, as well as timber harvest activities on NFS lands within the project area. Past effects may also include timber harvest activities and herbicide use on private lands within the project area. Cumulative effects for all species analyzed within this document are spatially bounded by the Pioneer Project area and temporally bounded by a 20-year period. Cumulative effects would result when the direct and/or indirect effects of Alternative 1 on a given species add incrementally to the effects of past, present, and reasonably foreseeable future actions.

Ongoing actions have similar effects to these species as the Pioneer Project, since all projects either have been surveyed to similar standards as the Pioneer Project or would be prior to project implementation. In addition, future projects would incorporate similar design features to flag and avoid known occurrences of Sensitive plant species unless the project is intended to restore or enhance the species or its habitat or potential impacts are believed minor. Ongoing activities with the potential for the impact to Sensitive plant species include those associated with road maintenance. These actions would affect a maximum of 0.09 acres of Pyrrocoma lucida within the project area (6%) and 1.1 acres of Penstemon sudans within the project area (< 1%) that are adjacent to roads. In addition, there are two active allotments within the cumulative effects analysis area. Three occurrences of Sensitive plant species are known to these active allotments (BOMI-024, PESU10-003, PYLU-001). Effects of livestock grazing can include grazing of plants, or impacts to habitat through hoof action. Of these occurrences, grazing has been noted only within the occurrence of Pyrrocoma lucida (PYLU-001), where impacts were noted as very minor. Ongoing grazing effects would contribute only incidentally to the low risk of indirect effects to Pyrrocoma lucida from project-related off-target drift or off-target movement of herbicides as described above. Other ongoing activities, such as general recreational use within the project area, may be contributing only incidental effects on these species, if any (PORFFA, Project Record). Ongoing


activities with the potential for the highest impact to Sensitive plant species include those associated with road maintenance. As with ongoing actions, future actions on NFS lands such as plantation maintenance would be surveyed to similar standards to ensure that any impacts to Sensitive plant species are either beneficial or mitigated so that the long-term viability of each Sensitive plant species on the forest is maintained.

Ongoing and future actions on adjacent private lands may also add cumulatively to effects from the implementation of Alternative 1. There is a known occurrence of Penstemon sudans on private lands within the project area where timber harvest activities and herbicide use may occur, but since mitigations that would be applied to this occurrence are not known, impacts to the occurrence or potential habitat for this species cannot be quantified. Given the number of occurrences within the project area, any potential impacts to Penstemon sudans on adjacent private lands would not be expected to contribute to a loss of viability for this species within the project area.

Past, ongoing and foreseeable future actions would add cumulatively to the direct and indirect effects of Alternative 1 as described above. The implementation of Alternative 1 may result in direct effects to Penstemon sudans that are within management direction, as well as minor, short-term potential adverse indirect effects of herbicide drift to Penstemon sudans, and longer-term beneficial effects to Penstemon sudans from invasive weed treatments. Because known occurrences of other Sensitive plant species are greater than 500 ft. from currently proposed treatments, no direct or indirect effects to these species are currently anticipated. There is, however, the potential that surveys around new infestations identified for treatment in subsequent years may detect new Sensitive plant occurrences in the vicinity of proposed treatment areas. Direct and indirect effects to new occurrences would be comparable to those described for Penstemon sudans.

Although project effects would add cumulatively to the effects of past, ongoing and future actions on Botrychium ascendens, Botrychium crenulatum, Botrychium minganense, Botrychium montanum, Botrychium pedunculosum, Botrychium pinnatum, Bruchia bolanderi, Lomatium roseanum, Penstemon sudans, and Pyrrocoma lucida, these effects would not lead to a loss of viability for these species within the Pioneer Project area or across the Lassen NF.

Alternative 2 Direct Effects

There would be no direct effects to Botrychium ascendens, Botrychium crenulatum, Botrychium minganense, Botrychium montanum, Botrychium pedunculosum, Botrychium pinnatum, Bruchia bolanderi, Lomatium roseanum, Penstemon sudans, and Pyrrocoma lucida other than those associated with ongoing activities.

Indirect Effects

The indirect effects of Alternative 2 would be those associated with the continued persistence and spread of high priority invasive plant species. Manual treatments of high priority invasive species within the


Pioneer project area have been ongoing, yet weed populations have continued to spread. Many of the species prioritized for treatment have the ability to resprout from rhizomes or lateral stems, rendering ongoing manual control insufficient to curb the persistence and spread of these infestations. Cheatgrass, in the absence of Alternative 1, would continue to degrade habitat for Penstemon sudans on the 2.6 acres where it occurs at high densities. In addition, infestations of Canada thistle and medusahead that are adjacent to occurrences of Penstemon sudans would continue to spread, and may eventually degrade habitat within these Sensitive plant occurrences.

Cumulative Effects

The scope of analysis and the effects of past, ongoing and future foreseeable actions under Alternative 2 would be identical to those discussed for Alternative 1. The implementation Alternative 2 would not result in direct effects to any of the Sensitive plant species analyzed within this document. Past, ongoing and foreseeable future actions would therefore add cumulatively only to the indirect effects of Alternative 2, as described above. These include the adverse indirect effects of continuing invasive plant invasion on Penstemon sudans in areas where invasive plant species are within or adjacent of Penstemon sudans habitat.

The implementation of Alternative 2 is not, however, expected to affect the viability of Botrychium ascendens, Botrychium crenulatum, Botrychium minganense, Botrychium montanum, Botrychium pedunculosum, Botrychium pinnatum, Bruchia bolanderi, Lomatium roseanum, Penstemon sudans, or Pyrrocoma lucida within the Pioneer Project area or across the Lassen NF for at least the next 20 years.

Determination: With the incorporation of project Integrated Design Features, the implementation of Alternative 1 of the Pioneer Project may affect individuals of Botrychium minganense, Botrychium montanum, Lomatium roseanum, Penstemon sudans, or Pyrrocoma lucida (known occurrences within the project area) and Botrychium ascendens, Botrychium crenulatum, Botrychium pedunculosum, Botrychium pinnatum, or Bruchia bolanderi (potential habitat but no known occurrences within the project area) but is not likely to result in a trend toward Federal listing as Threatened or Endangered or a loss of viability for these species. There would be no effect to other Sensitive plant species from implementation of the Pioneer Project because no occurrences and no potential habitat for these species occur within the Pioneer Project area.

Cultural Resources Alternative 1

Direct Effects

Proposed manual and cultural treatments such as digging, hand pulling, prescribed fire and thermal methods have the potential to adversely affect cultural resources. Two sites would be affected by manual treatments. These treatments would result in the displacement of both surface and subsurface artifacts while digging out or handing pulling the invasive plants. In order to minimize the impacts to the cultural


resources, ground disturbing actions (e.g. grubbing with a shovel) would not be used in known cultural resource sites, unless there is on-site monitoring by a staff archeologist or the technique has been agreed to by a staff archeologist who has determined that the technique would have no effect on cultural resources.

Cultural treatments consisting of prescribed fire and thermal methods may adversely affect destroy cultural resources with flammable and fragile characteristics. Fire lines constructed for prescribed operations could also adversely impact cultural resources by either displacing them or fracturing them. One site is located thirty feet outside of a treatment area proposed for prescribed fire and thermo use. The site would be identified by flagging in order to keep fire and fire lines offsite.

Chemical treatments will not adversely affect cultural resources and is permitted under the Regional PA under the following stipulation: “Applications of pesticides or herbicides that do not have the potential to affect access to or use of resources by Indians based on the nature of the undertaking or prior or current consultation with Indian tribes”. Four sites are located in areas proposed for chemical treatments. Consultation was conducted with the tribes and no concerns were raised in regards with to impacts of resources used by the tribe.

Indirect Effects

Some of the treatments could enhance cultural resource values, even if they do not directly affect the landscape within the site boundary. Removal of invasive plants within historic sites could enhance the historic character of the resource by restoring its original landscape context. Proposed treatments adjacent to prehistoric sites would enhance cultural resource values and the prehistoric context of these resources.

Cumulative Effects

The cumulative effects analysis boundary for cultural resources is the treatment areas with a 50-meter buffer around them. The geographic scope of the cumulative effects analysis boundary was selected because impacts to cultural resources accumulate at the specific location of cultural resources, irrespective of actions in surrounding areas. Archaeological sites are stationary resources, which are protected from all project (current or future) related activities until eligibility to the National Register of Historic Places has been determined. Generally, archaeological sites are not influenced by actions taken outside their boundary since this is addressed and mitigated during project planning and integrated design features. A temporal scope was also selected in determining cumulative effects, because impacts to cultural resources at a given location can accumulate over time from different activities or events.

The cumulative effects analysis for cultural resources considers impacts of the alternatives when combined with the past, present, and foreseeable future actions and events prior to the 1974 Forest and Rangeland Renewable Resources Planning Act and the archaeological protection laws of the mid 1970s, effects to cultural resources were not considered during project planning or implementation. Consequently, cumulative impacts of varying degrees occurred within the project area from various land management activities including primarily logging, fuel reduction efforts, road construction, and grazing.


Natural environmental processes and unrestricted land uses have also contributed to effects to cultural resources within the Pioneer Project area. These include dispersed recreation, off highway vehicle (OHV) uses, user created roads and trails, wildfires, erosion, and exposure to the elements. The burning and hand pulling/ digging associated with this alternative could cause additional adverse impacts on cultural resources located in the project area.

Determination: Activities associated with this alternative would comply with the National Historic Preservation Act (NHPA) of 1966, as amended and implementing regulations 36 CFR 800. Tribal communities would continue to be consulted for any concerns regarding this project. Protection of cultural resources would also comply with the Regional Programmatic Agreement as referenced above. SRPM as outlined in the Regional PA would be followed throughout the duration of project activities. Provided that SRPMs are applied, all project impacts would avoid historic properties. Following such protective measures, no adverse effects to the known sites are anticipated.

The proposed action would enhance the historic character of the resource by restoring its original landscape context.

Alternative 2

Under the No Action alternative, current management plans would continue to guide management of the project area. Primarily manual control efforts would occur under this alternative. No chemical or cultural treatment activities would be implemented within the project area, except those for which there is existing environmental analysis.

Direct and Indirect Effects

No adverse effects from project related activities would occur to cultural resource sites as a result of implementing this alternative. The risk of historic character loss would be greater should the “No Action” alternative be selected due to invasive plants replacing the native plants. This option would not provide opportunities for study and interpretation.

Cumulative Effects

Without management intervention there is a concern that growth of invasive plants in and around historic properties would lead to a loss of historic integrity of the site. While the loss of historic integrity may not be great, it still is important to mitigate issues that may affect the site’s eligibility to the NRHP.

Fuels

Fuels input focuses on two cultural methods used for treating medusahead, prescribed fire and flaming, and the effects of those treatments on the invasive plant. The manual and chemical methods of treatments proposed in the Pioneer project have very little effect on the fire and fuels resource area. Therefore, the discussion concerning those methods of treatments, if any, will be brief.


Alternative 1

Direct and Indirect Effects of Prescribed Fire

Fire kills mature medusahead plants. Immature plants may be only top-killed by early-season fire. Fire also destroys many viable medusahead seeds, but sufficient numbers can remain uninjured that reduction in plant density is usually temporary. Prescribed fire would reduce the Medusahead cover of thatch and dry matter, and would reduce the density of medusahead stands (FEIS 2014). The flaming treatment kills individual plants and reduces the percent of cover within a site (Coppoletta 2005; 2008).

Medusahead plants can regenerate by tillering. The reduction of thatch due to fire increases light penetration and temperature fluctuations on the soil surface, which can stimulate germination in some native and invasive species. Fire can also place any remaining seeds in contact with mineral soil, where it can germinate and subsequently be destroyed by future treatments such as tillage and herbicide use. In cheatgrass and medusahead wildfires, accumulation of litter and the rapidity at which the litter combusts lead to soil heating of such short duration that nitrate levels may increase. Wildfire-induced increases in soil nitrate in cheatgrass and medusahead-dominated areas are undesirable. Medusahead is nitrophilic and readily germinates in seedbeds with high nitrate levels (FEIS 2014).

Removing the litter layer could also improve the effectiveness of mechanical and chemical treatment (Zimmerman 2002). The flaming treatment does not result in ground disturbance that usually favors invasive species colonization (Coppoletta 2005).

Within the larger medusahead sites where prescribed burning in proposed, there are other tree, brush and grass species present that would be affected by fire. Prescribed fire would reduce surface fuel loading by reducing duff, litter, and down woody debris. This treatment would likely induce some scorch in the lower canopy of trees and could cause limited mortality in the small diameter trees.

Cumulative Effects

The fire and fuels cumulative effects analysis area for the Pioneer project includes the area within the project boundary. The existing conditions are the result of past management practices that include mechanical thinning, site preparation, prescribed burning, and salvage cuts. Several wildfires have impacted portions of project area, including the 2007 Moonlight Fire. Several grazing allotments are also active and ongoing. Past treatments of invasive plants have been conducted by manual or physical means only. These activities have resulted in a range of fuel loadings and have created the existing fire and fuel conditions within the project area.

Any cumulative effects to the fire and fuels resource area from the proposed manual, chemical, and cultural treatments on invasive plants are not expected due to the small acreage of the dispersed treatment sites and the fuel loading from the invasive species in these sites does not contribute much to the fire behavior in the project area, especially when compared to the surrounding vegetation. When these factors are considered and combined with the past, present, and future actions within the project area, any risk of cumulative effects to the fire and fuels resource from the proposed action are negligible.



The Pioneer Invasive Plant Treatment Project would not be implemented under Alternative 2. Current management plans would continue to guide management of the project area. No new invasive plant treatments would occur outside of ongoing manual treatments. There would not be any prescribed fire treatments to help control existing medusahead populations and reduce the risk of further establishment of the noxious weed. No chemical or cultural treatment activities would be implemented within the project area, except those for which there is existing environmental analysis. The agencies goal of effectively treating invasive species would not be met under this alternative.

Invasive plants would continue to grow and spread in areas where manual treatments have been ineffective. Medusahead litter layer would continue to dominate the groundcover and inhibit the growth of desirable native vegetation. Medusahead would continue to be the dominate vegetation in the area, and overall biodiversity and habitat quality would continue to decrease. Medusahead could continue to spread onto areas of bare soil and current populations could spread out in the event of a wildland fire. If the medusahead continued to spread, fire hazard could be increased due to the increase thatch layer and dry vegetation that ignites easily and spreads rapidly during wildfires. Once established, these invasive weeds are very expensive and difficult to control or eliminate. Few, if any, infestations or invasive species would be eradicated or contained under this alternative. Acreage of existing populations would most likely increase throughout the project area.

Cumulative Effects

The scope of analysis and the effects of past, ongoing and future foreseeable actions under Alternative 2 would be identical to those discussed for Alternative 1. Vectors would continue to spread invasive species throughout the project area. Invasive species infestations would only be treated on a limited basis and the impacts associated with them would compound over time. There would be an increase in the Medusahead thatch layer and stand density throughout the project area over time, which could increase the fire hazard at some of the larger sites. Property and natural resources in and around the Pioneer project area would continue to be at risk from invasive weeds and the potential damage they cause to the ecosystem.

Air Quality


There would be no direct or indirect effects to air quality due to the limited scope and duration of the prescribed fire and flaming activities.

Cumulative Effects

The cumulative effects analysis for Air Quality considers ongoing, proposed, and reasonably foreseeable future actions. Impacts to air quality from prescribed underburning and machine pile burning in the project and adjacent areas, during the last five years have been minimal and no Notice of Violation of air


quality standards has been issued on the Lassen National Forest during this period. Alternative 1 would not increase the amount of prescribed fire activities in the area above what has been implemented for the last five years and would not impact the air quality of the area, when combined with ongoing and reasonably foreseeable future actions, beyond what has occurred during this time.

Alternative 2 Direct, Indirect, and Cumulative Effects

This alternative would not implement any prescribed fire treatments, so there would not be any impacts from smoke.

Hydrology

Application of chemical treatments to live water is not a proposed action in this project, and proposed manual and cultural treatments pose a very low risk of negative effects to waters within the project area, so the analysis in this report primarily focuses on the potential for herbicide treatments to reach water bodies from application sites.


Up to 80 acres of treatment annually, including manual, chemical, or cultural means, could take place in the project area. In reality, most of these areas have only discontinuous infestations of invasive plants but as acres of infestations change year to year; the analysis was done as if all the land within a treatment area is infested.

Manual and Cultural Treatments

In general, proposed treatment areas along riparian corridors are small, with most less than one acre, and many less than 0.01 acre. 21 acres of manual treatment are proposed within RCAs for spotted knapweed and medusahead, and one 0.4 acre area for dyer’s woad. Manual treatments would include hand pulling and/or digging. Treatment would be discontinuous and limited to individual sites. Removal of invasive plants would not have effects to stream temperature, as these species do not provide shade, nor would they have effects to stream flow.

Where manual methods remove invasive plants near streams, there could be minor loss of ground cover and soil disturbance, which can have the potential to create minor localized increases in erosion and fine sediments where vegetation is removed from stream banks; however, this increase would be so small that it would be immeasurable, as there are very few manual treatments within proximity to stream banks, and native vegetation should quickly reestablish, typically within one-to-two growing seasons. The vast majority of treatment sites are small and existing native vegetation would reseed naturally. Manual treatments would not have negative effects to channel morphology, as these invasive plant species do not provide root structures sufficient to significantly influence stream bank stability if removed.


Cultural treatments include prescribed fire and thermal methods of up to 24 acres annually. Prescribed fire would be used for medusahead sites using an integrated approach with follow-up chemical treatment and reseeding of native vegetation. An IDF would be implemented so that hand lines would not be constructed in RCAs, fire may be allowed to back into the site, and wet line would be used if needed. The medusahead areas would be revegetated with native species using broadcast and/or a rangeland drill methods. Plugs of live locally adapted plants could also be used if an appropriate source is available. In addition, mulch may be used to ensure germination and seedling survival. While prescribed fire would remove vegetation, this would be a temporary effect as native vegetation should reestablish with assistance, and the mulch that may be used for seedling survival would provide ground cover. No effects to stream flow, reduced bank stability, or decreased water quality would be expected with use of prescribed burning.

Chemical Treatments

The routes for herbicide to contaminate water are direct application, drift into water bodies from spraying, runoff from a large rainstorm soon after application, and leaching through soil into shallow ground water or into a stream. This section addresses each of these delivery routes.

No direct application of herbicide to water is intended with this project. Chemical treatments would primarily be spot with a backpack sprayer. Glyphosate and aminopyralid are proposed for use in RCAs. Fluazifop-p-butyl would be utilized at cheatgrass sites, and would not be applied in riparian areas. Buffers would be used for herbicide near streams, based on stream characteristics (Table 7). Glyphosate tends to bind strongly to soils and would move only if the soil particle was carried into water. The primary chemical treatment methods used would be select application or directed spray of herbicides to the target plants. Drift would be minimal under these circumstances and risk to native riparian vegetation is very small. Glyphosate is the only chemical that would remove all vegetation but this would be short-term. Aminopyralid is the preferred chemical for treatment, which is selective and would not remove riparian graminoid species. Spot treatments would also remove far less vegetation than broadcast treatments so there is less potential for erosion. Given the rate, frequency, and method of application, degradation and dilution, and the implementation of IDFs, the risk of groundwater contamination from the use of aminopyralid in this project is extremely low. While aminopyralid has recently been added to the 6800 groundwater protection list under the California Code of Regulations’ Pesticide and Pest Control Operations as having the potential to pollute groundwater (3CCR section 6800[a]), the very low application rates and frequency make groundwater contamination unlikely, and aminopyralid would not be used in a Groundwater Protection Area (GPA), as there are no GPAs within or hydrologically down gradient of the project area.

Chemicals can be transported through soil as subsurface or groundwater flow and have the potential to reach surface water bodies. Dispersal of groundwater through soil would increase chances of herbicide chemicals adsorbing into soil. The implementation of BMPs (Appendix C) and IDFs also minimize the chance of herbicides reaching live water through drift, runoff, or groundwater movement.


There are 103 miles of road within the project area. Of these, 31 miles (30 percent) are within RCAs. Roads and their associated ditch lines are often connected to streams and during storm events can carry herbicide to streams. However, as the vast majority of sites would use direct spray or select application, with the exception of the broadcast spray sites for medusahead, very little herbicide applied to the soil would be available for transport to streams.

The targeted spray and select application treatments proposed with this project are inherently far less likely to deliver herbicide to water than larger broadcast or aerial treatments because the herbicide would be applied to individual plants, so drift, runoff, and leaching are greatly minimized. Small amounts of some herbicides can trans-locate from the plant to the soil or an adjacent plant, but the concentrations of herbicide that may be delivered to streams from this mechanism is much less than GLEAMS predictions, which model broadcast spraying of herbicide next to a stream with live water using no stream buffers. Modeling runs using SERA worksheets were conducted for assumed application rates for the herbicides proposed in the project. Despite the conservative assumptions of the GLEAMS model, very few significant scenarios with elevated hazard quotients were predicted, and none of these were probable scenarios related to water quality. None of the treatments are extensive enough under this alternative to measurably affect stream flows or water yield. Chemical methods used for treatment would have not have effects on water infiltration into soil and associated surface runoff.

GLEAMS model runs from the risk assessments and results of several monitoring studies reviewed by Bakke (2001) showed amounts of herbicides in streams to be below levels of concern for human or aquatic health, and primarily from drift during broadcast or aerial application. One project had several glyphosate detections, but it was used directly in a stream channel to control aquatic invasive species. While broadcast methods would be applied on a limited basis with glyphosate, they would have larger 25-50 foot buffers, depending on stream class (Table 7), and aerial application is not proposed under this alternative.

Cumulative Effects

The cumulative effects analysis area is comprised of the 7th field subwatersheds that are either totally or partially located within the project boundary that have identified invasive plant sites. Subwatersheds with currently identified invasive plant treatment sites include Baxter Creek, Coppervale, East Fork Willard Creek, Elysian Valley, Lassen Creek, Lower Willard Creek, Middle Willard Creek, Mountain Meadows Creek, Upper Gold Run, Upper Willard Creek, and West Fork Willard Creek.

When proposed chemical, manual, and cultural treatments are combined, none of the treatments exceed one percent of each subwatershed watershed area, and most are well under one percent (Table 2). There is also an annual cap of 80 acres of chemical treatments within the project area. This amount is much too small an area to show measurable effects to flows from treatment. BMPs (Appendix C) and integrated design features would also be in place to minimize impacts to riparian areas.


Given application rates, methods, and number of acres proposed for treatment, concentration of herbicides approaching levels of concern for water quality is unlikely. Half-life period, solubility, or adsorption of each herbicide determines how readily each would transport off site. Because herbicides degrade, their half-life period impedes cumulative effects to water resources from multiple chemical treatments at a single site. The risk of cumulative effects to water quality from manual treatments of invasive plants is insignificant, even if all mapped acreage were treated by using this method, which would not occur.

Cumulative effects to water quality are not expected because of the following factors: the small, dispersed treatment sites, the minimal ground disturbance caused by removal of individual plants using manual/physical methods, the site-specific application of chemicals that degrade within a matter of days to months, the use of buffers along streams and hydrologic features with live water, and the implementation of relevant IDFs and BMPs (Appendix C). When these factors are considered with the combined with past, present and reasonably foreseeable actions within the project subwatersheds, risk of cumulative watershed effects from the proposed action is negligible.


Under this alternative, the proposed action would not be implemented. Invasive plants would continue to grow and spread in sites where manual treatments have been ineffective, including riparian areas. There would be no direct or indirect effects to channel morphology, stream flow, or water quality from this alternative.

Cumulative Effects

No new invasive plant treatments would occur outside of ongoing manual treatments. While lack of effective treatments would allow the continued spread of invasive plants and the associated changes in ecosystems, there would be no cumulative watershed effects under the no action alternative.

Management Indicator Species (MIS), terrestrial and aquatic

The MIS whose habitat would be either directly or indirectly affected by the Pioneer Project and that were analyzed in the Management Indicator Species Report, hereby incorporated by reference were aquatic macro-invertebrates and Pacific tree (chorus) frog. Summaries of these analyses are provided below.


Macro-invertebrates: As there would be no measurable change in flow, sedimentation, and very low to no risk of shade changes on limited acres due to implementation of Alternative 1, Alternative 1 would not alter the existing trend in the habitat or aquatic macroinvertebrates across the Sierra Nevada bioregion. Given the limited area, integrated design features and slight potential for small localized effects, flow and


sedimentation risks for this alternative is low and would not be expected to be measurable. Most of the invasive plants including all identified for treatment are generally below six feet in height and therefore contribute little to stream shading. Treatment areas would fill in with other native vegetation over time, contributing to a more natural water surface shade regime. Given the above water surface shade change risk is very low.

Pacific tree (chorus) frog: Considering the approximately 61,000 acres of wet meadow on USFS lands and small changes to habitat factors on limited acres, Alternative 1 would not alter the existing trend in the habitat, nor would it lead to a change in the distribution of Pacific tree frogs across the Sierra Nevada bioregion. There would be no change in acres of wet meadow nor changes to wet meadow hydrology or ground cover class on the approximately 57 acres of wet meadow in the Pioneer project. The short-term impact to herbaceous cover class could affect up to 0.2 acres of cover class and 0.7 acres of height class of wet meadow project wide as identified currently with recovery on all acreage and possible increase in herbaceous height and cover class on 0.2 acres in the long term.

Cumulative Effects

Macro-invertebrates: The portions of subwatersheds that feed streams within the project area were selected as the cumulative effects area. Perennial waters within the project receive waters only from this area; therefore, this area covers the flow element, which has the largest area contributing to cumulative effects. There should not be any measurable cumulative effects from the Pioneer Project related to flow, sedimentation, and stream shade.

Pacific tree (chorus) frog: The cumulative effects analysis area for wet meadow habitat in the Pioneer project is the portions of subwatersheds that feed the project area since all wetlands within the project are fully contained in the project area and hydrology of the wet meadows is controlled by these areas. This alternative may help restore herbaceous height and ground cover class in in small acreages of wet meadow but would not affect other habitat elements.


Macro-invertebrates and Pacific tree (chorus) frog: There would be no direct effects to habitat elements and nor anticipated indirect effects large enough to affect habitat elements, since no activities related to the project would take place. Since there are no direct or indirect effects to habitat elements, there would be no cumulative effects to habitat elements. Therefore, Alternative 2 would not alter the existing trend in the analyzed habitats nor would it lead to a change in the distribution across the Sierra Nevada bioregion for any of the analyzed MIS species.


Threatened, Endangered and Sensitive Species, terrestrial and aquatic

The following discussion of effects on TES terrestrial and aquatic species are summaries from the analysis in the Biological Evaluation for the Pioneer Invasive Plant treatment Project (BE), hereby incorporated by reference.

1) Due to the project area being outside the range of the species, or due to the lack of suitable habitat or habitat components in the project area, it is my determination that the action alternatives would have no effect on the following Federally Listed threatened or endangered species or their critical habitat:

Gray wolf, northern spotted owl, valley elderberry beetle, Central Valley steelhead DPS, Central Valley chinook salmon ESU, Delta smelt, Winter-run chinook salmon ESU, California red-legged frog, Shasta crayfish, conservancy fairy shrimp, vernal pool fairy shrimp, vernal pool tadpole shrimp, giant garter snake, and the Sierra Nevada yellow-legged frog,

2) Due to the project area being outside the range of the species, or due to the lack of suitable habitat or habitat components in the project area, it is my determination that the action alternatives would have no effect on the following Forest Service Sensitive species:

Northern bald eagle, California wolverine, American marten, Pacific fisher, Sierra Nevada red fox, Townsend’s big-eared bat, great gray owl, willow flycatcher, greater sandhill crane, yellow rail, Shasta hesperian snail, foothill yellow-legged frog, Cascade frog, northwestern pond turtle, California floater, Great Basin rams-horn, scalloped juga, topaz juga, montane peaclam, nugget pebblesnail, black juga, kneecap lanx, Goose Lake redband trout, hardhead, Pacific lamprey, and Eagle Lake rainbow trout.

Sensitive species analyzed in detail for the Pioneer Project were California spotted owl, northern goshawk, pallid bat, fringed myotis, and western bumble bee. Summaries of the analyses of effects for these species follow.

Alternative 1 Northern goshawk


Potential effects due to disturbance to known nest sites during project implementation is avoided due to the integrated design feature for this project that restricts actions during the nesting period of goshawks when within 0.25 miles of known nest sites. Also, because invasive plants rarely occur within non-disturbed, high-canopy forested stands, it is unlikely invasive plant locations and treatments would occur within goshawk nesting habitat. Since most invasive plants would be in disturbed locations, especially along roads, goshawks and other wildlife would tend to be habituated to noise from these areas due to on-going human use.

There would be no alteration to forest structure as a result of this project. Proposed treatments could temporarily increase bare ground within the treated areas by reducing total plant cover. However,


due to the small and patchy nature of the invasive plant populations, as well as the annual cap on treatment acres, there would not be a substantial loss of cover within the project area in any given year. The proposed area for prescribed fire would cause the largest temporary loss of plant cover, however this location is adjacent to Highway 36 and thus not likely of high habitat capability for goshawks or their prey, and distant from goshawk nesting habitat.

The SERA Risk Assessments (2007; 2011; 2014a) and worksheets for the herbicides proposed for use within this project indicate there are no acute or chronic exposure scenarios of direct concern to goshawks at application rates described in the Proposed Action. The Risk Assessments further indicate that there is no risk of toxicity to a raptor consuming either mammalian or avian prey that had been contaminated directly by herbicide spray. Therefore, the herbicides proposed for use would not be expected to represent a direct or indirect risk of toxicity to northern goshawks.

While SERA Risk Assessments and worksheets indicate an increased level of concern regarding birds or small mammals that consume contaminated broadleaf foliage or grasses, the scenarios in which these would occur are not plausible or expected within the project area. Chronic exposures to prey species are also unlikely because goshawk prey are not known to prefer foraging on invasive plant species.

In addition, the SERA Risk Assessments do not indicate that toxicity to small mammals or birds directly consuming sprayed vegetation would be sufficient to result in mortality to the individual bird or small mammal (2007; 2011; 2014a). Therefore, there would be no expectation of any mortality to or a decrease in prey species for northern goshawks as a result of this project.

Therefore, given the invasive plant species to be sprayed and the types of herbicides being proposed, the very small patches in which the invasive plants are known to exist, the very small proportion of the project area that would be treated, and the general low-toxicity of the herbicides at the rate proposed to be applied, there does not appear to be a plausible risk of toxicity to northern goshawks or their prey. Because this project would not affect forest structure, would target non-native, invasive plants in small discrete patches, and would not cause disturbance to known nest sites, and would not pose an unreasonable risk of toxicity to goshawks or their prey, potential for direct and indirect effects to northern goshawks are negligible throughout the project area.

Cumulative Effects

The Pioneer goshawk cumulative effects analysis area was retained at the project level. The cumulative effects analysis area was not extended beyond this due to negligible direct and indirect effects of the Proposed Action.

This project would prevent further expansion of the targeted non-native invasive plant populations that have become established within the project area, and in time should greatly reduce or eliminate these populations. Also, populations of non-native plants that become newly established in the future would be controlled and not allowed to spread. No non-native, invasive plant species on the Lassen NF are known to provide essential habitat for native wildlife. Reducing the presence of invasive plants


would benefit wildlife species that are adapted to and depend upon healthy plant communities, including prey species for goshawks.

Within the project area timber harvest on private timber lands would occur, including approximately 154 acres of clearcut harvests that may include the use of herbicides post-harvest . However, because the Pioneer project would not affect the forest structure of goshawk nesting or foraging habitat on FS lands, and would have extremely negligible direct or indirect effects to foraging habitat of prey, the potential alteration of habitat on private lands would not serve to create negative cumulative effects when combined with the Pioneer project. Due to negligible potential for direct and indirect effects to goshawk habitat, and that no on-going or reasonably foreseeable future projects within the Pioneer project area would affect goshawk nesting or foraging habitat on USFS administered lands, the other past, ongoing and reasonably foreseeable future projects identified in the PORFFA document (project record), would not combine with this project to create substantial effects to northern goshawks or their habitats. Due to negligible potential for direct and indirect effects, and due to positive cumulative effects, other past, ongoing and reasonably foreseeable future projects identified in the PORFFA document (project record), would not combine with this project to create substantial effects to northern goshawks or their habitats.

California Spotted Owl


Potential effects due to disturbance to known spotted owl nest sites during project implementation is avoided due to the integrated design feature for this project that restricts actions during the spotted owl nesting period when within 0.25 miles of known nest sites. Also, because invasive plants rarely occur within non-disturbed, high-canopy forested stands, it is unlikely invasive plant locations and treatments would occur within spotted owl nesting habitat. Since most invasive plants would be in non-forested openings along riparian areas or in disturbed locations, with many found along roads, spotted owls and other wildlife would tend to be habituated to noise from these areas due to on-going human use.

There would be no alteration in forest structure as a result of this project. Proposed treatments could temporarily increase bare ground within the treated areas by reducing total plant cover. However, due to the small and patchy nature of the invasive plant populations, as well as the annual cap on treatment acres, there would not be a substantial loss of cover within the project area in any given year. The proposed area for prescribed fire would cause the largest temporary loss of plant cover, however this location is adjacent to Highway 36 adjacent to young, pure pine stands, and the area does not represent spotted owl nesting or foraging habitat.

The SERA Risk Assessments and worksheets for the herbicides proposed for use within this project indicate there are no acute or chronic exposure scenarios of concern to raptors at application rates described in the Proposed Action (2007; 2011; 2014a). The Risk Assessments further indicate that there is no risk of toxicity to a raptor consuming either mammalian or avian prey that had been ‘contaminated’


directly by herbicide spray. Therefore, the herbicides proposed for use would not be expected to represent a direct or indirect risk of toxicity to spotted owls.

While SERA Risk Assessments and worksheets indicate an increased level of concern regarding birds or small mammals that consume contaminated broadleaf foliage or grasses, the scenarios in which these would occur are not plausible or expected within the project area (2007; 2011; 2014a). Chronic exposures are also unlikely because spotted owl prey are not known to prefer foraging on invasive plant species. The primary prey species for spotted owls in this area is northern flying squirrels, which are largely fungivores, and thus would not be expected to consume the invasive plants, which are the target of this proposed project.

In addition, the SERA Risk Assessments do not indicate that toxicity to small mammals or birds directly consuming sprayed vegetation would be sufficient to result in mortality to the individual bird or small mammal (2007; 2011; 2014a). Therefore, there would be no expectation of any mortality to or a decrease in prey species for spotted owls as a result of this project.

Therefore, given the invasive plant species to be sprayed and the types of herbicides being proposed, the very small patches in which the invasive plants are known to exist, the very small proportion of the project area that would be treated, and the low-toxicity of the herbicides at the rate proposed to be applied, there does not appear to be a plausible risk of toxicity to California spotted owls or their prey. Because this project would not affect forest structure, would target non-native, invasive plants in small discrete patches, and would not cause disturbance to known nest sites, and would not pose an plausible risk of toxicity to goshawks or their prey, potential for direct and indirect effects to California spotted owls are negligible throughout the project area.

Cumulative Effects

The cumulative effects analysis area for spotted owls was retained at the project level due to negligible potential for direct and indirect effects of the Proposed Action.

This project would prevent further expansion of these non-native invasive plant populations that have become established within the project area, and in time should greatly reduce or eliminate these populations. In addition, non-native plant populations that become established in the future would be controlled and not allowed to spread. No non-native, invasive plant species on the Lassen NF are known to provide essential habitat for native wildlife. Reducing the presence of invasive plants would benefit wildlife species that are adapted to and depend upon healthy plant communities, including prey species for spotted owls. However, given the extremely small proportion of the project area in which treatments would be applied, the potential for substantial positive or negative direct, indirect, or cumulative effects is negligible.

Within the project area timber harvest on private timber lands would occur, including approximately 154 acres of clearcut harvests that may include the use of herbicides post-harvest. However, because the Pioneer project would not affect the forest structure of spotted owl habitat on FS


lands, and would have extremely negligible direct or indirect effects to foraging habitat of prey, the potential alteration of habitat on private lands would not serve to create negative cumulative effects when combined with the Pioneer project. Due to negligible potential for direct and indirect effects to spotted owl habitat, and that no on-going or reasonably foreseeable future projects within the Pioneer project area would affect spotted owl nesting or foraging habitat on USFS administered lands, the other past, ongoing and reasonably foreseeable future projects identified in the PORFFA document (project record), would not combine with this project to create substantial effects to California spotted owls or their habitats.

Given the above analysis, it was determined that the proposed activities within Alternative 1 of the Pioneer Project may affect individuals of California spotted owls, but was not likely to result in a trend towards federal listing or loss of species viability.

Pallid Bat


Potential for disturbance during project implementation to this species is low in that spraying would occur during daylight hours when this species is within diurnal roosts, which would typically be high in trees within cavities. Also, the majority of treatment areas are within disturbed sites or along roads, which are locations subject to on-going human use, so that if bats are roosting near these areas they would be habituated to vehicular and other noise. The area proposed for prescribed burning, along Highway 36, would not include potential roost trees due to this site being an open meadow with only a few young trees within it, thus there would be no risk of the prescribed fire causing mortality or damage to roost trees.

No invasive plants on the Lassen NF are known to provide essential habitat for native vertebrate wildlife or insect species. Due to this, and due to the small, discreet patches of the known invasive plant species identified for treatment within this project, the removal or control of these populations would not represent a substantial decrease in habitat for the invertebrate prey for this species. Control of these invasive plant species would serve to maintain healthy and diverse native plant communities, which should benefit insect communities in the area, and thus in time this project should promote potential prey species for pallid bats.

However, the small scale of treatments within the project area would limit the positive or negative aspects of this project to this species. Approximately 26,600 acres of land administered by the US Forest Service occurs within the project boundaries. Within this area, invasive plants are known from about 135 known sites, of which 110 sites may be treated with this project. These 110 sites total about 274 acres, or about 1% of the USFS acreage within the project area. The project would place a cap on annual treatment at 80 acres, or 0.3% of the USFS acreage. Given this extremely small spatial extent within the project area, there would be negligible potential for substantial negative or positive effects of this project to this species.

None of the herbicides proposed for application are considered toxic to invertebrates, thus there should be no direct impact to the abundance of pallid bat prey. SERA risk assessments and worksheets


were reviewed, and there are no acute or chronic exposure scenarios at application rates described in the Proposed Action that would result in a HQ >1 for a small mammal consuming contaminated insects (2007; 2011; 2014a). The likelihood of a chronic exposure to contaminated insects is remote, given the small acreages treated and the relatively large areas in which bats forage. The bats are not likely to forage exclusively within treated areas over a 90- day period (the chronic exposure time-frame) so there does not appear to be a plausible risk from chronic exposure. Cumulative Effects

The established Pioneer project area boundary was considered sufficient as a cumulative effects analysis area for pallid bats because 1) no spatially-oriented standards and guidelines or LOPs are associated with this species, 2) individuals do not have defined spatial territories that can be mapped or assessed, 3) there are no areas within or adjacent to the analysis area that represent unique habitat opportunities for these species that would warrant expanding the project area to include, and, 4) the negligible direct and indirect effects of the Proposed Action.

Within the project area timber harvest on private timber lands would occur, including approximately 154 acres of clearcut harvests that may include the use of herbicides post-harvest However, because the Pioneer project would not affect the forest structure of pallid bat habitat on FS lands, nor would it have the potential to decrease potential pallid bat roosting habitat within the project area, and would have extremely negligible direct or indirect effects to foraging habitat of prey, the potential alteration of habitat on private lands would not serve to create negative cumulative effects when combined with the Pioneer Project. Due to negligible potential for direct and indirect effects to pallid bat habitat, and that no on-going or reasonably foreseeable future projects within the Pioneer project area would affect pallid bat roosting habitat on USFS administered lands, the other past, ongoing and reasonably foreseeable future projects identified in the PORFFA document (project record), would not combine with this project to create substantial effects to pallid bats or their habitats.

Fringed Myotis


Potential for disturbance during project implementation to this species is low in that spraying would occur during daylight hours when this species is within diurnal roosts, which would typically be high in trees within cavities. Also, the majority of treatment areas are within disturbed sites or along roads, sites subject to on-going human use, so that if bats are roosting near these areas they would be habituated to vehicular and other noise. The area proposed for prescribed burning, along Highway 36, would not include potential roost trees due to this site being an open meadow with no large snags within it.

No invasive plants on the Lassen NF are known to provide essential habitat for native vertebrate wildlife or insect species. Due to this, and due to the small, discreet patches of the known invasive plant species identified for treatment within this project, the removal or control of these populations would not


represent a substantial decrease in habitat for the invertebrate prey for this species. Control of these invasive plant species would serve to maintain healthy and diverse native plant communities, which should benefit insect communities in the area, and thus potential prey species for pallid bats.

However, the small scale of treatments within the project area would limit the positive or negative aspects of this project to this species. Approximately 26,600 acres of land administered by the US Forest Service occurs within the project boundaries. Within this area, invasive plants are known from about 135 known sites, of which 110 sites may be treated with this project. These 110 sites total about 274 acres, or about 1% of the USFS acreage within the project area. The project would place a cap on annual treatment at 80 acres, or 0.3% of the USFS acreage. Given this extremely small spatial extent within the project area, there would be negligible potential for substantial negative or positive effects of this project to this species.

None of the herbicides proposed for application are considered toxic to invertebrates, thus there should be no direct impact to the abundance of fringed myotis prey. SERA risk assessments and worksheets were reviewed, and there are no acute exposure scenarios at application rates described in the Proposed Action that would result in a HQ >1 for a small mammal consuming contaminated insects (2007; 2011; 2014a). The likelihood of a chronic exposure to contaminated insects is remote, given the small acreages treated and the relatively large areas in which bats forage. The bats are not likely to forage exclusively within treated areas over a 90- day period (the chronic exposure time-frame) so there does not appear to be a plausible risk from chronic exposure.

Cumulative Effects

The Pioneer project area boundary was considered sufficient as a cumulative effects analysis area for this species because, 1) no spatially-oriented standards and guidelines or LOPs are associated with this species, 2) individuals do not have defined spatial territories that can be mapped or assessed, and, 3) there are no areas within or adjacent to the analysis area that represent unique habitat opportunities for these species that would warrant expanding the project area to include, and, 4) the negligible direct and indirect effects of the Proposed Action.

Within the project area timber harvest on private timber lands would occur, including approximately 154 acres of clearcut harvests that may include the use of herbicides post-harvest. However, because the Pioneer Project would not affect the forest structure of fringed myotis habitat on FS lands, nor would it have the potential to decrease potential fringed myotis roosting habitat within the project area, and would have extremely negligible direct or indirect effects to foraging habitat of prey, the potential alteration of habitat on private lands would not serve to create negative cumulative effects when combined with the Pioneer project. Due to negligible potential for direct and indirect effects to fringed myotis habitat, and that no on-going or reasonably foreseeable future projects within the Pioneer project area would affect fringed myotis roosting habitat on USFS administered lands, the other past, ongoing and reasonably foreseeable future projects identified in the PORFFA document (project record), would not combine with this project to create substantial effects to fringed myotis or their habitats.


Western Bumble Bee


Western bumble bees are known to visit three of the genera to which invasive plants proposed for treatment belong: Cirsium, Centaurea and Hypericum. Of these genera, western bumble bees on the ELRD have been observed on a native species of Hypericum. While they have not been observed on the other two genera of plants, they would presumably visit both C. arvense (Canada thistle) and C. stoebbe ssp. micranthos (spotted knapweed). Both of these plants occur in small patches within the project area. For instance, spotted knapweed is known from either sites totaling about 12 acres, or about 1.5 acres per site, and Canada thistle is known from 75 sites totaling about 33.4 acres, or less than 0.5 acres per site. The three other species of flowering plants proposed for treatment are known from single sites that, combined, total less than an acre in size. Given the small patch size of these plant species, and their scattered nature throughout a project area totaling about 26,600 acres of FS administered lands, eradication or reduction of these invasive plants would likely have little effect to the foraging abilities of western bumble bees which can forage for up to several miles from a nest, especially since the treatments would be phased in over more than a single year. Therefore, there should be negligible potential for indirect effects related to short-term reductions in floral resources.

Herbicides, as opposed to pesticides, have yet to be implicated as a concern regarding the decline of bumble bee species (R. Thorp, UCD, personal communication). As reviewed in the SERA risk assessments (2007; 2011; 2014a), potential risks to insects are studied using toxicity data on the honeybee as a surrogate species. Aminopyralid would be the preferred herbicide on Canada thistle, spotted knapweed and Klamathweed. This herbicide is very non-toxic, and the effective timing for use of this herbicide is when target plants are from the rosette to beginning of bolt stages, which are prior to flowering. Given the non-toxic nature of this herbicide, and the effective timing being prior to flowering, there would be no concern of toxic effects to western bumble bees. Based on this, as well as the lack of apparent risk associated with the other proposed herbicides, no risks to bumble bees would be anticipated due to the use of the herbicides and their rate of application as proposed within this project.

The use of fluazifop-p-butyl within Penstemon sudans populations is desired in order to reduce completion of this USFS Sensitive plant species with cheatgrass. P. sudans is often visited by bumble bees, and western bumble bees are known to forage on Penstemon species. Therefore, the objective of promoting the health of P. sudans populations would benefit pollinators in the project area, and possibly western bumble bees. This is consistent with published field studies, which indicate that applications of fluazifop-p-butyl used to enhance the growth of wildflowers can be beneficial to both bees and butterflies (SERA 2014a). However, given the extremely small spatial extent of potentially treated areas within the project area, and an annual cap of treatment at 80 acres, there would be negligible potential for substantial negative or positive effects of this project to this species.


Cumulative Effects

The Pioneer project area boundary was considered sufficient as a cumulative effects analysis area for this species because, 1) no spatially-oriented standards and guidelines or LOPs are associated with this species, 2) individuals do not have defined spatial territories that can be mapped or assessed, 3) there are no areas within or adjacent to the analysis area that represent unique habitat opportunities for these species that would warrant expanding the project area to include, and, 4) the negligible direct and indirect effects of the Proposed Action.

Within the Pioneer project area approximately 93 acres of existing pine plantations will be precommercially thinned and masticated. Long-term, this project by opening densely planted pine plantations would create growing space for a more abundant shrub and forb layer underneath the planted trees, may help benefit this species by enhancing floral resources within the plantation areas. Other past, ongoing and reasonably foreseeable future projects identified in the PORFFA document (project record) that would occur on USFS administered lands within the project area would have no substantial effects on western bumble bees or their habitats. Within the project area timber harvest on private timber lands would occur, including approximately 154 acres of clearcut harvests that may include the use of herbicides post-harvest, a relatively small amount of acreage within this project area of almost 31,000 acres. Given the negligible potential for direct, indirect and cumulative effects on USFS lands, and some potential for the Pioneer to improve floral resources of native plants on USFS lands, this private timber harvest would not combine with the Pioneer project to create substantive negative effects to western bumble bees or their habitats.

Other past, ongoing and reasonably foreseeable future projects identified in the PORFFA document (project record), would have no substantial effects on western bumble bees or their habitats.

Determination: Alternative 1 may affect individuals of the following FS Sensitive species, but is not likely to result in a trend towards federal listing or loss of species viability: California spotted owl, northern goshawk, pallid bat, fringed myotis, and western bumble bee.

Alternative 2 Northern Goshawk and California Spotted Owl

Direct, Indirect, and Cumulative Effects

There would be no direct effects to northern goshawks and their current habitat conditions as a result of this alternative. Indirect effects include a continuation of current vegetative trends across the analysis area. Manual control methods would continue to be applied to known invasive plant infestations. Acreage of existing populations would most likely increase as manual control methods have proven inadequate in the past. As a result, infestations would be expected to slowly increase in spatial extent and density, and these infestations could be the seed source resulting in new infestations within the project area. Over time, this could result in a reduction in native plant species and healthy, native plant communities in the affected areas, possibly reducing or negatively impacting habitat for small mammals and birds that


represent prey species. However, due to the very small spatial extent of the existing invasive plant populations within the project area, substantive negative impacts to prey habitat throughout the project areas as a whole are not likely in any reasonable planning horizon.

Pallid Bat and Fringed Myotis


There would be no direct effects to fringed myotis or their current habitat conditions as a result of this alternative. Indirect effects include a continuation of current vegetative trends across the analysis area. As part of these trends, the identified invasive plant infestations would remain untreated and uncontrolled. Acreage of existing infestations would most likely increase as manual control methods have proven inadequate in the past. As a result, the infestations would be expected to slowly increase in spatial extent and density of the invasive plants, and these infestations could be the seed source resulting in new infestations within the project area. Over time, this could result in a reduction in native plant species and healthy, native plant communities in the affected areas, possibly reducing or negatively impacting habitat native insects that represent prey species. However, due to the very small spatial extent of the existing non-native plant populations within the project area, substantive negative impacts to prey habitat throughout the project areas as a whole are not likely in any reasonable planning horizon.

Western Bumble Bee


There would be no direct effects to western bumble bees or their current habitat conditions as a result of this alternative. Indirect effects include a continuation of current vegetative trends across the analysis area. The observed recent declines in western bumble bee are thought to be a result of factors that unrelated to the vegetative trends within the project boundaries of the Pioneer Project, and include factors such as disease from imported bumble bees, urban and agricultural development, and exposure to pesticides. Thus, long-term vegetative trends within the project area, or within the ELRD as a whole, were likely not a large contributing factor in the observed population declines.

Manual control methods would continue to be applied to known invasive plant infestations. Acreage of existing infestations would most likely increase as manual control methods have proven inadequate in the past. As a result, infestations would be expected to slowly increase in spatial extent and density, and these infestations could be the seed source resulting in new infestations within the project area. Over time, this could result in a reduction in native plant species and healthy, native plant communities in the affected areas, possibly reducing or negatively impacting habitat for native insects. This may be especially the case in cheatgrass-affected P. sudans populations. However, due to the very small spatial extent of the existing invasive plant populations within the project area, substantive negative impacts to floral resources throughout the project areas as a whole are not likely in any reasonable planning horizon.


Range Alternative 1 and 2


Integrated design features are included in the project to notify permittees of timing and location of treatment. It is likely that treatments would occur when livestock are least likely to be in the vicinity of treatment areas with little chance of livestock ingesting treated plants or coming into contact with herbicides.

It is expected that there would be no effects to livestock or rangeland with or without implementation of this project, and because there is less than one acre of treated areas proposed within active allotments,

Recreation/Visuals Alternative 1


Proposed treatments would have minor short-term direct impacts to the use of developed and dispersed recreation sites, by causing a minor inconvenience to visitors if workers are present. It is not likely that recreation sites would be closed during manual, mechanical, or cultural treatments.

Project IDFs that include timing restrictions of herbicide application during special event use periods and signing of treatment areas prior to application would minimize any potential negative impacts to forest visitors from herbicide treatments. This displacement effect would be very limited in duration.

There would be no direct effects to roads or recreation sites within the project area. Indirectly sites may be enhanced by the removal of invasive species. There would be no change to recreational opportunities as defined under ROS.

The proposed action alternative would meet the Visual Quality Objectives (VQOs) identified in the LRMP. Proposed manual, mechanical, chemical, and cultural treatments would likely have an overall beneficial effect on visual resources by controlling, reducing, or eradicating existing invasive species infestations and restoring those areas. There could be short-term negative impacts to visual quality in treatment areas. Short-term impacts from chemical treatments could include indicator dye and browning vegetation that could be visible for the season. The short-term impact from indicator dye or browning vegetation would be replaced by the long-term beneficial effect of enhancing and restoring the diversity of texture and color from native plants. Control or eradication of existing infestations and new infestations would reduce the likelihood that infestations would increase in size or number and adversely impact visual resource in areas that currently meet the VQOs.


Cumulative Effects

There are no known past, present or reasonably foreseeable future projects within the project area that when considered with manual, mechanical, chemical, or cultural treatments under the proposed action would have any significant cumulative effects on recreation sites or opportunities in the project boundary; or that would contribute to adverse cumulative impacts to scenic resources.


Under the No Action alternative, invasive plant infestations would have the potential to continue to expand into areas of concentrated public use such as along roads and campgrounds. Known invasive plant infestations would not be eliminated or controlled and would likely spread to other areas. Under the no action alternative, future invasive plant infestations at recreation sites could have an adverse effect on native vegetation and other resources that contribute to the natural character of recreation sites and visitor experiences. In some instances, there could be negative cumulative impacts because invasive plant infestations have the potential to displace desired native plant species that are desired for collection or other purposes.

Under the No Action alternative, the visual character in areas of existing invasive plant occurrences would remain degraded. There would not be the opportunity to rehabilitate and restore the visual character of these areas. Infestations that are small and not currently impacting the visual quality would continue to expand and over time would become more pronounced on the landscape. Expanding and new occurrences of invasive plants would change the form, texture, line, color, and overall characteristic landscape. The No Action alternative would likely contribute to additional adverse impacts to visual resources in the future if invasive plant populations would increase in size and remain untreated.

Soils

Soils in the Pioneer Project area formed from sedimentary, granitic, and volcanic parent materials. Surface textures are predominantly sandy loams and loams with small areas of loamy sands and clay loams. The soils are well-drained with the exception of less than 1% of the project area having moderately well-drained, poorly drained, or excessively drained soils (USDA NRCS 2014).

Soil cover is within guidelines throughout the project area, even within the footprint of the Moonlight fire. Soil cover was estimated in 2013 at 395 points within the high and moderate burn severity area of the Lassen NF portion of the Moonlight fire, with 91% of the points having greater than 50% cover.

Direct and Indirect Effect

Manual Treatments

The overall impacts of these activities are very low. Some of these activities would temporarily decrease ground cover in patches but potential erosion hazard from such small areas would be low, possibly


causing some very localized erosion, on the order of a few square feet per occurrence. Monitoring of ground disturbing activities would occur to ensure the compliance with BMPs.

Cultural Treatments

Cultural methods include seeding, prescribed fire, and thermal methods involving flame, steam, microwave, or infrared application. These methods do not disrupt the soil surface. Thermal methods are applied to individual plants causing a temporary, spotty reduction in soil cover and would not appreciably increase the risk of soil erosion.

A total of 21 acres in three plots would be broadcast burned. These small prescribed burns would be conducted using methods that would prevent high soil burn severity and the resulting detrimental impacts such as soil organic matter consumption. There would be a temporary reduction in soil cover but the low slope gradients and high infiltration rates would help prevent soil erosion in these well-drained soils. Burned areas would be seeded following the burn, which would facilitate rapid recovery of vegetative soil cover.

Chemical Treatments

Depending on the chemical used herbicide treatments may affect soils directly by having short-term adverse impacts on certain soil microbes and impacts from losses in vegetative cover. The effect of a chemical treatment on the soil depends on the particular characteristics of the chemical used, how it is applied, and the physical, chemical, and biological characteristics of the soil.

Indirect effects resulting from herbicide application to soil can be offsite transport of the herbicide attached to soil particles via wind or water erosion. Also, movement of the herbicide down through the soil profile can result in groundwater contamination. In general, primary herbicide processes in soil are leaching, hydrolysis, and adsorption/desorption onto soil particles, and biological degradation. Rapidly drained soils have greater propensity to transfer herbicides to groundwater. Organic rich soils and finer texture soils have higher adsorption potential for holding herbicides. Herbicides would vary in the degradation rates based on their chemical structure and site-specific soil characteristics.

All of the herbicide application planned in the Pioneer Project is either directed spray, select methods (dip and clip, hack and squirt, wick, wipe and drizzle), or broadcast spray. No chemicals would be incorporated into the soil or aerially sprayed.

Some chemical would land on the soil surface where it could be transported off site via wind or water erosion. Factors controlling these processes include amount of soil cover, degradation rate of chemical when exposed to sun and air, soil infiltration rate, soil texture, slope, and weather events such and wind and rain following application. Due to the patchy, discontinuous nature of directed spray and select application methods soil cover would largely remain intact with a combination of live and dead plants. The only broadcast application would be with glyphosate following prescribed fire on gentle slopes. The risk of offsite movement is low due to residual soil cover with directed spray and select application, design features that preclude spraying when storms are approaching, high infiltration rates,


gentle slopes where broadcast spray occurs, and reseeding for rapid vegetative recovery where broadcast spraying takes place.

Below is a brief summary for each chemical proposed for use detailing each chemical’s behavior in soils, including persistence, leaching potential, and movement offsite:

Glyphosate: Glyphosate rapidly and tightly binds to soil. There is little potential for leaching or offsite movement due to its very strong adsorption to soil. Similarly, glyphosate has a low risk of impacting soil microorganisms (SERA 2011). Glyphosate becomes inactive as an herbicide upon contact with the soil. Glyphosate is degraded via microbial activity and has a half-life of 47 days (DiTomaso et al. 2013).

Aminopyralid: Aminopyralid has been shown to be practically non-toxic to most soil organisms (SERA 2007). It has an average half-life of 35 days and can be considered highly mobile in most permeable soils (DiTomaso et al. 2013). The Pioneer Project proposed action is to only spray aminopyralid directly onto plant surfaces and adjacent soil, or wick and wipe it on rather than broadcast spray or incorporate into the soil.

Even with its low toxicity the high mobility and hence, high leachability of aminopyralid warrants special consideration in zones of high water table. Because of this leachability there is a project IDF that states that the application of aminopyralid would not occur on deep, coarse textured, saturated soils. Also, spraying would not occur when rain is forecast to be greater than 50% chance. The appropriate FS specialists would be consulted about the proper timing of herbicide application in the spring prior to treatments. With a half-life of 35 days, any aminopyralid that was able to move into the soil would be expected to be reduced by half about every 35 days. The low application rates, the method of application, and the IDFs mentioned above would prevent significant leaching of aminopyralid.

Fluazifop-P-butyl: This herbicide binds strongly with soils, is not highly mobile, and has low persistence, with an average half-life of 15 days (DiTomaso et al. 2013). Though data is minimal at this time, fluazifop-p-butyl does not appear to impact most soil organisms when applied at the proper rate (SERA 2014a).

Overall, the proposed herbicide types and application rates are expected to facilitate decay by soil microbes. Risk to soil microorganisms is low. Where plants are killed, the residue would continue to provide some soil cover until new plants establish. The treatment areas are small and discontinuous, reducing the possibility of transport via wind or water erosion. The potential for adverse effects of herbicide residues in soil would be minimized or eliminated by incorporating the project design features and applying BMPs for herbicide application.

Cumulative Effects

A soil cumulative impact can be defined as the total impact, positive or negative, on soil biota, erosion, water infiltration rate, and/or cover that result from the incremental impact of a proposed action, when added to other past, present and reasonably foreseeable future actions occurring within the same area.


As stated above, treatment areas are small and some are associated with roads that already have impacted soils associated with them. The invasive plant treatments do not represent a significant additional disturbance. These factors would keep the risk of cumulative effects to a minimum.

The soil effects from cultural treatments are temporary and small and would not measurably contribute to cumulative effects. In addition, based on the half-lives of these chemicals, application rates, and project design features, there is very little risk of any cumulative effects to soils.


The overall impacts of these activities are very low. Some of these activities would temporarily decrease ground cover in patches but potential erosion hazard from such small areas would be low, possibly causing some very localized erosion, on the order of a few square feet per occurrence. Monitoring of ground disturbing activities would occur to ensure the compliance with BMPs.

Cumulative Effects

As stated above, treatment areas are small and some are associated with roads that already have impacted soils associated with them. The invasive plant treatments do not represent a significant additional disturbance. These factors would keep the risk of cumulative effects to a minimum.


References:

Bakke, D. 2001. Unpublished. A Review and Assessment of the Results of Water Monitoring for Herbicide Residues for the Years 1991 to 1999, USFS Region 5 (Pacific Southwest). Accessed 12 December 2014 from website: http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5416107.doc

Bossard et al. 2000. Invasive Plants of California’s Wildlands. University of California Press, Berkeley, CA 360 p.

California Department of Pesticide Regulation (CDPR). 2013. California Product/Label Database Queries & Lists. Sacramento, CA. http://www.cdpr.ca.gov/docs/label/labelque.htm

Colorado Department of Natural Resources (CDNR). 2000. Appendix 11: Susceptibility of some Colorado noxious weeds to control by 2,4-D, dicamba, picloram, and glyphosate herbicides. In: Caring for the land series publications volume IV - creating an integrated weed management plan: a handbook for owners and managers of lands with natural values. http://cpw.state.co.us/Documents/CNAP/App11.pdf

Coppoletta, M. 2005. Testing the Effects of Flaming as a Method of Medusahead Control on the Plumas National Forest. USDA Forest Service, Plumas National Forest.

Coppoletta, M. 2008. Medusahead Flaming Project: Revisit Notes. USDA Forest Service, Plumas National Forest.

DiTomaso, J.M., G. B. Kyser et al. 2013. Weed Control in Natural Areas in the Western United States. Weed Research and Information Center, University of California. 544 pp.

DiTomaso, J.M., G. B. Kyser and M.J. Pitcairn. 2006. Yellow Starthistle Management Guide. Cal-IPC Publication 2006-3. California Invasive Plant Council: Berkeley, CA. 78 pp.

Fire Effects Information System (FEIS). 2014. Taeniatherum caput-medusae; Pinus ponderosa; Juniperus occidentalis; Purshia tridentata; Bromus tectorum; Juncus balticus; Elymus elymoides; Poa bulbosa. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory.

Parendes, L. A. and Jones, J. A. (2000). Role of Light Availability and Dispersal in Exotic Plant Invasion along Roads and Streams in the H. J. Andrews Experimental Forest, Oregon. Conservation Biology, 14: 64–75.

Syracuse Environmental Research Associates (SERA). 1997. Use and assessment of marker dyes used with herbicides. December 21, 1997. SERA TR 96-21-07-03b. 30 pp. Fayetteville, NC.

Syracuse Environmental Research Associates (SERA). 2007. Aminopyralid: Human Health and Ecological Risk Assessment - Final Report. June 28, 2007. SERA TR-052-04-04a. Fayetteville, New York. 153 pp.


http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5416107.doc

http://www.cdpr.ca.gov/docs/label/labelque.htm

http://cpw.state.co.us/Documents/CNAP/App11.pdf

Syracuse Environmental Research Associates (SERA). 2009. Technical Comparison of EPA, BLM and Forest Service Pesticide Risk Assessments - Final Report. July 29, 2009. SERA TR-052-19-02. Fayetteville, New York. 39 pp.

Syracuse Environmental Research Associates (SERA). 2011. Glyphosate: Human Health and Ecological Risk Assessment -Final Report. March 11, 2011. SERA TR-052-22-03b. Manlius, New York. 313 pp.

Syracuse Environmental Research Associates (SERA). 2014a. Scoping/Screening Level Risk Assessment on Fluazifop-P-butyl, Final Report. July 21, 2014. SERA TR-056-07-02a. Manlius, New York. 275 pp.

Syracuse Environmental Research Associates (SERA). 2014b. Preparation of Environmental Documentation and Risk Assessments for the USDA/Forest Service. May 1, 2014. SERA MD-2014-02a. Manlius, New York. 159 pp.

Trombulak S.C. and C. Frissell. 2000. Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities. Conservation Biology 14(1), pp.18-30.

Tu, M., Hurd, C. and J.M. Randall. 2001. Weed Control Methods Handbook, The Nature Conservancy, http://tncweeds.ucdavis.edu. version: April 2001

USDA Forest Service. 1993. (LRMP) Lassen National Forest Land and Resource Management Plan Record of Decision (1993) and Final Environmental Impact Statement (1992). Lassen National Forest, Pacific Southwest Region, USDA Forest Service.

USDA Forest Service 1998. Stemming the Invasive Tide: Forest Service Strategy for Noxious and Nonnative Invasive Plant Management. USDA Forest Service. Washington D.C. 29 pp.

USDA Forest Service 2000. Noxious Weed Management Strategy, USDA Forest Service, Pacific Southwest Region, Region 5, Vallejo CA.12 p.

USDA Forest Service. 2004. Sierra Nevada Forest Plan Amendment, Final Supplemental Environmental Impact Statement and Record of Decision. Pacific Southwest Region, Forest Service, Vallejo, CA. Online at http://www.fs.fed.us/r5/snfpa/final-seis/index.html

USDA Forest Service. 2007a. Record of Decision (ROD: Final Environmental Impact Statement (FEIS): Sierra Nevada Forests Management Indicator Species Amendment. Pacific Southwest Region, Vellejo, CA.

USDA Forest Service. 2007b. Bakke, D. Ed. Analysis of Issues Surrounding the Use of Spray Adjuvants with Herbicides. Region 5, Pacific Southwest Region, USDA Forest Service. January 2007.

USDA Forest Service 2011. Chapter 2900. Invasive Species Management. Washington D.C.

USDA Forest Service 2013. W. Boes. Ed. Draft Lassen National Forest Invasive Plant Management Plan. August 18, 2013. Lassen National Forest, Region 5. Susanville, CA.

USDA Forest Service 2014a. Lassen National Forest Invasive Plant Species List. Lassen National Forest, Region 5, Susanville, CA.


http://tncweeds.ucdavis.edu/

http://www.fs.fed.us/r5/snfpa/final-seis/index.html

USDA Forest Service. 2014b. Lassen National Forest rare plant occurrence forms, Forest atlases, project documentation and GIS databases. Lassen National Forest, Supervisor’s Office, Susanville, CA.

USDA Soil Survey Staff, Natural Resources Conservation Service (USDA NRCS). 2014. United States Department of Agriculture. Web Soil Survey. Available online at http://websoilsurvey.nrcs.usda.gov/ Accessed Oct 28, 2014.

Washington State Department of Ecology (WSDE). 2013. Adjuvants and Surfactants Allowed for Use Under a Permit in Washington Waters. Olympia, WA. http://www.ecy.wa.gov/programs/wq/pesticides/regpesticides.html#adjuvant

Zimmerman, J. R., W. S. Johnson and M. E. Eiswerth. 2002. Medusahead: Economic Impact and Control in Nevada. Cooperative Extension, Nevada Agriculture Experiment Station. Fact Sheet FS-02-37.

Zouhar, Kris. 2003. Bromus tectorum. In: Fire Effects Information System, [Online]. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory (Producer). Available: http://www.fs.fed.us/database/feis/ [2014, September 5].

Zouhar, K. S., J. Kapler, S. Southerland, and M. L. Brooks. 2008. Wildland fire in ecosystems: fire and nonnative invasive plants. Gen. Tech. Rep. RMRS-GTR-42-vol. 6. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 335 p.


http://websoilsurvey.nrcs.usda.gov/

http://www.ecy.wa.gov/programs/wq/pesticides/regpesticides.html%23adjuvant

http://www.fs.fed.us/database/feis/

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Appendix A - Pioneer Invasive Plant Treatment Project

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CA 36

29N03A

29N49

29N0

9Y

29N20Y

29N03

29N0

9YC

Highway 36 Inset

Highway 36 Inset

Pioneer Invasive Plant Treatment ProjectPioneer Treatments!. Bromus tectorum!5 Centaurea stoebe ssp. micranthos!. Cirsium arvense!. Elymus caput-medusae!. Hypericum perforatum ssp. perforatum!. Isatis tinctoria!. Lepidium latifolium

RoadsMoonlight Fire 2007 0 1 2 Miles

0 0.25 Miles

¯

²(cheatgrass)

(spotted knapweed)(Canada thistle)

(medusahead)(Klamathweed)

(Dyer's woad)(perennial pepperweed)

Appendix B Annual Implementation Review

Process

Lassen National Forest


Pioneer Invasive Plant Treatment Project Appendix B

The following process will be used to ensure that the selected treatment alternative is properly implemented and meets the Forest’s intent to implement Integrated Pest Management and Best Management Practices. It applies to invasive plant sites known and identified for treatment in the EA, as well as new sites found during inventory (early detection/rapid response). An invasive plant implementation review team (Review Team) will be assembled annually to ensure consistent and effective treatment is applied, appropriate Integrated Design Features (IDFs) are implemented, and necessary monitoring and reporting are completed. The Review Team will be led by botanists designing the treatments but will also include the following subject matter specialists: hydrology, soils, range management, recreation, heritage resources, wildlife and aquatic biology. This annual review process will include the following tasks:

Map and characterize invasive plant infestations to be treated (responsibility botany)

Add or refine target species mapping and infestation information each year.

Develop Annual Proposed Implementation Prescriptions (responsibility botany)

Document each detailed proposed prescription on an Invasive Plant Treatment Record (Exhibit 1). This will be done for each treatment site or logical grouping of sites.

Use Integrated Weed Management principles to identify preferred treatment method(s) for each treatment site.

Send treatment proposals to the review team.

Annual Implementation Review (responsibility all specialists) Review team reviews resource checklist and proposed Invasive Plant Treatment Records for proper implementation of the NEPA decision and associated IDFs. This review would identify any new information or conditions outside of those analyzed that may require additional analysis prior to implementation.

• Revise Invasive Plant Treatment strategy with any new information • Check for inclusion of all applicable IDFs • Identify pre-treatment fieldwork necessary to implement integrated design features (e.g.

flagging of sensitive sites). • Ensure that no extraordinary conditions exist that were not considered in the EA.

Annual Implementation Review Documentation: Treatment Selection Process (Figure 2 in EA, page 12) Invasive Plant Treatment Record (Exhibit 1, two pages) completed for each infestation Integrated Design Features (Exhibit 2, two pages) Complete FS 2100-2- Pesticide Use Proposals for all chemicals.

Annual Implementation Plan 2


Coordination and Notification (responsibility botany) • Coordinate with adjacent landowners and partners when appropriate. • Complete County Pesticide use Report monthly (contractor responsibility). • Notify landowners, partners, regulatory agencies and Tribes about proposed treatments and

treatment areas via Forest website.

Treatment, Post-Treatment Monitoring and Adaptive Management (responsibility all specialists) Post-treatment reviews will occur to evaluate monitoring results and determine whether prescriptions and project design features were effective.

• Monitoring would occur during implementation to ensure IDFs and BMPs are implemented as planned.

• Post-treatment reviews would occur to determine whether treatments were effective and whether or not passive/active restoration has occurred as expected (Appendix D). Post- treatment monitoring would also be used to detect whether IDF’s were appropriately applied.

• Contract administration and other existing mechanisms would be used to correct deficiencies. Herbicide use and certified applicator information would be documented in the National pesticide use database, via the Forest Service Activity Tracking System (FACTS), and other forms.

• Post-treatment monitoring would assess re-treatment needs. For example, as the size of an infestation is reduced, treatment method may change from spot spray to hand pulling (Appendix D).

• Post-treatment monitoring would also be used to refine restoration prescriptions and determine if additional sites should be treated.

• Post-treatment monitoring reports for Penstemon sudans cheatgrass treatment sites would be review to determine if treatments were effect, and/or if additional sites should be added.

Monitoring D ocumentation:

Post-treatment records, pesticide use reports, and monitoring reports, including recommendations for changes in water feature buffer widths (Table 1).



Exhibit 1. Invasive Plant Treatment Record (page 1)

USDA Forest Service Invasive Plant Treatment Record NRIS site ID: General Location:

Map

Target species:

Field Crew / applicator: Treatment Date:

Application Area: Percent cover of target species:

Number of plants: Active ingredient:

Brand or Product name: EPA registration #: Total Amount of Product:

% solution: Application rate:

Surfactants used:

Legal Location: TRS:

UTM NAD 83: Easting:

Northing:

Treatment Prescription:

Treatment Notes:

DETAILED DIRECTIONS TO SITE



Exhibit 1. Invasive Plant Treatment Record (page 2)

Wildlife / Aquatics -.(LOPs)

Hydrology – (stream buffers, reach acreage cap)

Recreation-

Soils – (sensitive soils)

Range -

Heritage – (sites to protect)

Botany (rare plants within 100ft or 25ft?)

Annusl Im Annual Implementation Plan 5

Pioneer Invasive Plant Treatment Project Appendix B Exhibit 2. Integrated Design Features


Herbicide Application ☐ 4 Spray application drift control measures:

1) Only ground based equipment would be used 2) All applications would cease when weather conditions exceed those on the label 3) Applications would not be performed when the National Weather Service forecasts a greater than 70 percent probability of measurable precipitation (greater than 0.1") within the next 24 hour period 4) Applications would cease when wind speed exceeds 10 mph or 5 mph when spraying near Rare plants (IDF# 29) 5) Spray nozzles would produce a relatively large droplet size (500- 800 microns) 6) Low nozzle pressures would be used (15 psi) 7) Spray nozzles would be kept within 20 inches of target vegetation during spraying 8) A pressure gauge or pressure regulator would be required on each backpack sprayer

☐ 5 Herbicides would be applied under the direction of a certified applicator in accordance to label instructions and applicable federal and state pesticide laws.

☐ 6 Personal Protective Equipment (PPE) would be used in accordance with the product label and California Department of Pesticide Regulation requirements.

☐ 7 Chemicals would be stored in designated storage facilities consistent with FSM 2109.14, Chapter 40. Unused herbicides would be disposed of in accordance with the product label and FSM 2109.14, Chapter 40. If the product label and FSM differ, the more restrictive storage and disposal guidelines would be followed.

Cultural Resources ☐ 8 Local Native American Tribes would be consulted on the entire project area to allow tribal members an

opportunity to provide input. Species identified by tribes would be protected in the same manner as Rare Plant Species (see below).

☐ 9 Ground disturbing actions (e.g. grubbing with a shovel) would not be used in known cultural resource sites, unless there is on-site monitoring by a staff archeologist or the technique has been agreed to by a staff archeologist who has determined that the technique would have no effect on cultural resources.

☐ 10 If cultural resources are discovered during project implementation where none are known, the Eagle Lake RD Heritage Resources Staff would be contacted immediately and the discovery would be dealt with as appropriate.

☐ 11 No herbicide application would take place in the Roxie Peconom campground 7 days before and 7 days after the annual Bear Dance, traditionally held in June.

Fire and Fuels ☐ 12 Fire lines would be constructed for prescribed fire operations, except where existing roads, skid trails, or natural

barriers would serve as control lines. Hand lines would not be constructed within Riparian Conservation Areas, but fire would be allowed to back into the site. If needed, wet line would be used. Hand lines would also not be constructed in cultural resource sites.

☐ 13 Fueling of drip torches would not occur within 25 feet of surface waters, except at existing facilities.

☐ 14 Vehicles and/or equipment that are driven and/or come in contact with medusahead sites should be carefully inspected prior to leaving the site. When appropriate, vehicles and equipment will be washed and cleaned to prevent seed or plant fragment movement.

☐ 15 Vehicle and equipment wash stations would be designated by a botanist prior to project implementation. These areas would be surveyed for weeds and treated accordingly if needed.

Hydrology ☐ 16 All surfactants used near water will be approved for aquatic applications (WSDE 2013 and CPRD 2013).

☐ 17 All wells, ponds, and springs used for domestic water supplies would be protected with a 200 foot buffer for herbicide treatment and mixing. These will be reviewed each year during the annual implementation process.

☐ 18 Streams used for domestic water supply (e.g. West Fork of Willard Creek) would be protected with a 15 feet buffer for 0.5 miles upstream of the diversion point for herbicide treatment and a 200-foot buffer around the diversion intake. Within this buffer only select methods would be used.

☐ 19 Herbicide mixing would not occur within 150 feet of live surface waters.




Hydrology- continued ☐ 20 Herbicide use buffers have been established for streams and other water bodies (listed in Table 7). Buffers vary

by herbicide and application method. Tank mixtures would apply the largest buffer as indicated for any of the herbicides in the mixture.

Range ☐ 21 Grazing permitees would be informed of any herbicide use within allotments and timing of treatments would be

coordinated as necessary.

Recreation ☐ 22 For herbicide treatment within 100 feet of roads, Roxie Peconom campground, and established dispersed

camping sites, cautionary notice signs would be in the treatment area prior to herbicide treatments.

Silviculture ☐ 23 When using glyphosate, avoid or shield plantation conifers seedlings and desired woody vegetation (black oak,

aspen, cottonwood, willow, etc.) seedlings when spraying nearby.

☐ 24 Do not use herbicides that target broadleaf or woody species when possible, if working near desired woody vegetation seedlings.

Soils ☐ 25 Application of Aminopyralid (including equipment rinsing) would not occur on deep, coarse textured, saturated

soils. The appropriate FS specialists would be consulted about the proper timing of herbicide application in the spring prior to treatments.

Botany ☐ 26 No broadcast herbicide application would occur within 100 feet of Sensitive or Special Interest plant species (Rare

plants). No directed spray or select application would occur within 25 feet of Rare plant species, with the exception of Penstemon sudans located within cheatgrass treatment areas, where the application of fluazifop-p-butyl may occur. Buffers may be waived if plants are covered by a protective barrier. Under saturated/wet soil conditions, select is the only herbicide application permitted within 100 feet of Rare Plant species. Modifications may be made with consultation with a staff botanist.

☐ 27 When Rare plant species are within 25 feet of digging, covering, or flaming treatments, plants would be clearly identified and care taken to avoid direct impacts to individuals. No buffers are required for hand pulling.

☐ 28 Only locally adapted native plant species would be used for revegetation. All mulch and seed material would be certified weed- free.

☐ 29 Glyphosate or aminopyralid spray applications would not occur when the wind velocity is greater than five miles per hour when working within 200 feet of rare plant occurrences.

☐ 30 All contractors will be instructed on the proper identification of rare plant species prior to project implementation activities.

☐ 31 Rare plant surveys would be conducted within 500 ft. of new infestations identified for chemical treatment, and within 25 ft. of new infestations identified for manual treatments prior to implementation.

Wildlife ☐ 32 Northern goshawk: Use of mechanical equipment (e.g. weed whacker, ATV, chainsaw) would be prohibited

within approximately ¼ mile of a nest site during the breeding season (February 15 - September 15), unless surveys confirm that northern goshawks are not nesting.

☐ 33 California Spotted Owls: Use of mechanical equipment (e.g. weed whacker, ATV, chainsaw) would be prohibited within approximately ¼ mile of nest sites during the breeding season (March 1 - August 31), unless surveys confirm that California spotted owls are not nesting.



Table 1. Water feature buffers for herbicide application Water Feature

Her

bici

de A

ctiv

e In

gred

ient

LIVE WATER (Perennial/intermittent streams. ponds, springs, seeps, seasonal wetlands and wet meadows)

NO LIVE WATER (seasonally flowing / intermittent channels that support a continual strip of riparian vegetation)

Dry washes without riparian vegetation

Herbicide Application Method

Broadcast spray

Directed spray

Select

Broadcast spray

Directed spray

Select

No buffer required,

unless otherwise

specified by project design

features.

Aminopyralid

Treatment not proposed 10 ft. Water’s edge

Treatment not proposed 10 ft. No buffer

required

Fluazifop-p-butyl Treatment not proposed 50 ft. Treatment not

proposed Treatment not proposed 25 ft. Treatment not

proposed Glyphosate 50 ft. 10 ft. Water’s edge 25 ft. 10 ft. No buffer

required Buffer distances are measured from the edge of scoured continuous channel or water’s edge. Dry seasonal wetlands and meadows- no buffer required for direct spray or select treatments for glyphosate and aminopyralid. Fluazifop-p- butyl would not be used within 25 ft. of dry seasonal wetlands and meadows. Buffers for domestic water sources are specified in IDF 17 & 18. Select methods near live water will use an aquatic formulation of Glyphosate.


Appendix C Applicable Best Management

Practices



Pioneer Invasive Plant Treatment Project Appendix C

Region 5 FSH 2509.22, Chapter 10 and National Best Management Practices (USDA 2011) Section 12.51, Exhibit 07

BMP 5.7 - Pesticide Use Planning Process Objective: To introduce water quality and hydrologic considerations into the pesticide use planning process.

Explanation: The pesticide use planning process is the framework for incorporating water-quality protection requirements contained in BMPs 5.8 through 5.14 into project design and management. The project environmental document will incorporate these considerations in discussion of environmental effects and mitigation measures.

Implementation: The interdisciplinary team will evaluate the project in terms of site response, social and environmental impacts, and the intensity of monitoring if needed.

The responsible line officer will prepare environmental documentation, project plan, and the safety plan. Project plans and safety plans will specify management direction.

Approval for proposed pesticide projects will proceed according to direction established in Pacific Southwest Region supplement No. 2100-95.1 to 2150.

Section 12.51, Exhibit 08

BMP 5.8 - Pesticide Application According to Label Directions and Applicable Legal Requirements Objective: To avoid water contamination by complying with all label instructions and restrictions for use.

Explanation: Directions on the label of each pesticide are detailed and specific, and include legal requirements for use.

Implementation: Constraints identified on the label and other legal requirements of application must be incorporated into project plans and contracts.

For force account projects, the Forest Service project supervisor (who will have a Qualified Applicator Certificate) is responsible for ensuring that label directions and other applicable legal requirements are followed.

For contracted projects, the contracting officer, or the contracting officer’s representative will be responsible for ensuring that label directions and other applicable legal requirements are followed.

Best Management Practices 2



BMP 5.9 - Pesticide Application Monitoring and Evaluation 1. Objective:

a. To determine whether pesticides have been applied safely, were restricted to intended target areas, and have not resulted in unexpected non-target effects.

b. To document and provide early warning of hazardous conditions resulting from possible pesticide contamination of water or other non-target areas.

c. To determine the extent, severity, and duration of any potential hazard that might exist. Explanation: This practice documents the accuracy of application, amount applied, and any water- quality effects so as to reduce, or eliminate hazards to non-target species. Monitoring methods include spray cards, dye tracing (fluorometry), and direct measurement of particles in, or near water. Type of pesticide, type of equipment, application difficulty, public concern, beneficial uses, monitoring difficulty, availability of laboratory analysis, and applicable Federal, State, and local laws and regulations are all factors considered if it becomes necessary to develop a monitoring plan.

Implementation: If there is a need to develop a monitoring plan, it will be identified during the pesticide use planning process as part of the project environmental evaluation and documentation.

2. The water-quality monitoring plan would specify:

a. Who will be involved and their roles and responsibilities;

b. What parameters will be monitored and analyzed;

c. When and where monitoring will take place;

d. What methodologies will be used for sampling and analysis, and the rationale behind each of the preceding specifications.

A water-quality specialist and the project leader will evaluate and interpret the water-quality monitoring results in terms of compliance with and adequacy of project specifications.


BMP 5.10 - Pesticide Spill Contingency Planning Objective: To prevent water contamination resulting from cleaning, or disposal of pesticide containers.

Implementation: Pesticide spill contingency planning will be incorporated into the project safety plan. The pesticide spill contingency plan prepared by each forest consists of predetermined actions to be implemented in the event of a pesticide spill. The plan lists who will notify whom and how, time requirements for the notification, guidelines for spill containment, and who will be responsible for cleanup.

The site-specific environmental evaluation and resulting documentation will include public and other agency involvement in plan preparation. The plan will list the responsible authorities.




BMP 5.11 - Cleaning and Disposal of Pesticide Containers and Equipment Objective: To prevent water contamination resulting from cleaning, or disposal of pesticide containers.

Explanation: The cleaning and disposal of pesticide containers must be done in accordance with Federal, State, and local laws, regulations, and directives. Specific procedures for the cleaning and disposal of pesticide containers are documented in the Forest Service Pesticide Use Management and Coordination Handbook (FSH 2109.114), and State and local laws.

Implementation: The forest, or district Pesticide Use Coordinator (Qualified Applicator) will approve proper rinsing procedures in accordance with State and local laws and regulations, and arrange for disposal of pesticide containers when Forest Service personnel apply the pesticide.

When a contractor applies the pesticide, the contractor will be responsible for proper container rinsing and disposal in accordance with label directions and Federal, State, and local laws.


BMP 5.12 - Streamside Wet Area Protection during Pesticide Spraying Objective: To minimize the risk of pesticides inadvertently entering waters, or unintentionally altering the riparian area or wetland.

Implementation: Appropriate width buffers will be established for spraying pesticides near water bodies. Factors considered in establishing buffer strip widths are beneficial water uses, adjacent land uses, rainfall, wind speed, wind direction, terrain, slope, soils, and geology. The persistence, mobility, acute toxicity, bio-accumulation, and formulation of the pesticide are also considered. Equipment used, spray pattern, droplet size, and application height and past experience are other important factors.

Perennial and intermittent surface waters, wetlands, and Riparian Conservation Areas (RCAs) will be identified from onsite observation, and mapped during project planning.

When included as part of the environmental evaluation and documentation, the project work plan, the protection of surface waters, wetlands, or RCAs will be the responsibility of the project supervisor for force account projects, and the COR will be responsible on contracted projects.




BMP 5.13 - Controlling Pesticide Drift during Spray Application Objective: To minimize the risk of pesticide falling directly into water, or non-target areas. Implementation: The spray application of pesticide is accomplished according to prescription which accounts for terrain and specifies the following: spray exclusion areas; buffer areas; and factors such as formulation, equipment, droplet size, spray height, application pattern, and flow rate; and the limiting factors of wind speed and direction, temperature, and relative humidity.

An interdisciplinary team will prepare the prescription, working with the Forest or District Pesticide Use Coordinator during project planning.

For force account projects, the Forest Service project supervisor will be responsible for ensuring that the prescription is followed during application and for closing down application when specifications are exceeded.

On contracted projects, the contracting officer, or the contracting officer’s representative will be responsible for ensuring that the prescription is followed during application and for closing down application when specifications are exceeded.


Appendix D Monitoring Plan



Pioneer Invasive Plant Treatment Project Appendix D

Monitoring of Non-target Impacts to Sensitive Plants As a part of the Eradication and Control of invasive plants project it may be necessary to implement targeted invasive plant control within and near Sensitive plant occurrences. If invasive plant treatments occur within and around Sensitive plant occurrences, the forest would implement monitoring designed to detect non-target impacts to these species. Non-target impact monitoring would be required for Sensitive plant occurrences when the modelled hazard quotient (HQ) from herbicide drift for sensitive plant occurrences is greater than 1.

When monitoring for impacts to sensitive plants is required, site-specific monitoring plans would be developed during the annual implementation assessment process. Site-specific monitoring plans would include details regarding the proposed monitoring methods (scope and sampling protocol), targeted species and/or community types, and duration; and would be tracked as a part of the infestation treatment record. Monitoring for Sensitive plant occurrences would be designed to detect impacts to populations from herbicide treatments only.

For known Sensitive plant occurrences, the only currently proposed herbicide applications with a HQ >1 would be the proposed spray application of glyphosate within 500 feet of Penstemon sudans (Susanville beardtongue), and the proposed application of aminopyralid within 100 feet of P. sudans. Where glyphosate or aminopyralid are applied within these distances of P. sudans, post-treatment monitoring would be required to validate the assumption that proposed treatments would have negligible impacts to Sensitive plant species. Plant density and growth characteristics (e.g. reduced vigor or abnormal growth) of Sensitive plant occurrences would be monitored post-treatment for three years. Observations of reduced plant vigor or abnormal growth would result in modification of future invasive plant treatments. Decreased plant density would result in modification only if there was not a similar trend in Penstemon sudans control plots (described below). Monitoring results would be documented within the project record. The same method would use for any new Sensitive plant species found within the designated buffer distances described above.

For restoration treatments of degraded areas, vegetation monitoring would be designed to detect changes in plant species composition and cover during and following proposed invasive plant treatments. If undesirable shifts in species composition (e.g. increasing trends in exotic plant species cover) are detected that cannot be addressed through revegetation practices, future invasive plant treatments in degraded areas will be modified.

Cheatgrass Treatment Effectiveness Monitoring within Penstemon sudans Cheatgrass is currently identified for treatment where it occurs at high densities within occurrences of the Sensitive plant Penstemon sudans. Monitoring would occur within three occurrences of Penstemon sudans that are proposed for treatment with fluazifop-p-butyl. Permanent plots would be established within infested areas that would be sprayed, within infested areas that would not be sprayed, and within an adjacent intact native plant community. Control plots would be established to account for background variation in population densities. Within each plot, data would be collected on cheatgrass cover, Penstemon sudans cover and density, cover of other species present within the plot, Penstemon sudans flowering rates, and any indicators of sub-lethal but adverse effects to P. sudans growth (e.g. abnormal growth or reduced vigor).

Monitoring Plan 2


Cheatgrass treatment efficacy would be evaluated by using the Treatment Efficacy Ratings described below (Table C-1). If after three years of treatment cheatgrass treatment efficacy were rated a minimum of fair, with neutral or beneficial effects to Penstemon sudans, then additional acres would be considered for treatment.

Invasive Species Treatment Efficacy Monitoring Monitoring of treatment efficacy is an essential part of an invasive species treatment program. Forest Service Policy (FSH 2109.14-53) requires that post-treatment evaluations be conducted to validate treatment priorities, adapt future treatment techniques, determine the effect of treatments on non-target organisms, and complete project implementation. In addition, a standard and guideline established under the Sierra Nevada Forest Plan Amendment (2004) also requires the forest to routinely monitor noxious weed control projects to determine success and evaluate the need for follow-up treatments or different control methods. Monitoring of treatment efficacy allows program managers to identify changes in the extent, distribution and density of the invasive species populations and changes to the environment, non-target organisms and other biotic and abiotic factors in the affected ecosystem.

Treated sites would be monitored each year using standard procedures described in the National Forest System Data Recording Protocols and Requirements for Invasive Species (Inventory and Treatment) (http://fsweb.wo.fs.fed.us/invasivespecies/data/documents/InvSpp-SurveyInventoryTreatment-NatProtocols-Integration_v2014-Final.pdf). In accordance with these protocols, data on the location and size of each infestation, as well as the percentage of the targeted invasive species infestation that was controlled by the treatment activity would be recorded and assigned a treatment efficacy rating (Table C-1).

Table C-1. Treatment Efficacy Ratings.

The effectiveness of each treatment would be evaluated by reviewing the annual treatment efficacy ratings and adjusting methods (within the parameters of the Project Decision) to improve effectiveness. For example, annual monitoring may show a need to adjust treatment timing to increase efficacy or to revise use of a particular method. The length of time required for treatments to kill plants varies with treatment method and plant species, and the schedule of when to evaluate treatments for effectiveness would not be the same for all treatments. The effectiveness of treatments would be evaluated a minimum of once every three years for each infestation based upon a review of data in the FACTS and NRIS databases. Adjustments would be recommended where annual efficacy ratings are less than “Fair” over a period of three years.

PERCENT EFFICACY

RATING DESCRIPTION

0 No effect No effect can be detected on the target species population 1-5 Failure Little to no effect can be detected on the target species population.

6-25 Poor Treatment killed less than a quarter of the target species population. 26-50 Marginal Less than half of the target species population was controlled 51-75 Fair Over half of the target species population was controlled. 76-90 Good Treatment was successful in killing most of the target species population 91-99 Excellent Over 95% of the target species population has been killed with the treatment. 100 Complete Not a single individual of the target species population was found after a

complete survey of the site. Infestation was eradicated on the site. UNK Unknown Treatment efficacy/success can not be determined.

Monitoring Plan 3

http://fsweb.wo.fs.fed.us/invasivespecies/data/documents/InvSpp-SurveyInventoryTreatment-NatProtocols-Integration_v2014-Final.pdf

http://fsweb.wo.fs.fed.us/invasivespecies/data/documents/InvSpp-SurveyInventoryTreatment-NatProtocols-Integration_v2014-Final.pdf


Monitoring would continue at treated sites for three years after a target species infestation has been determined eradicated on the site. This is important because seeds of many invasive plants can remain viable for several years, leaving sites vulnerable to reinfestation.

Monitoring Plan 4