United States FINAL Environmental Impact Statement Agriulture …a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/... · our weed control efforts and maximize

FINAL Environmental Impact Statement

Integrated We e dM a n a g e m e n tON THE LOLO NATIONAL FOREST

United StatesDepartment ofAgriulture

Forest Service

LoloNationalForest

December, 2007

Lolo National Forest

Final Environmental Impact Statement

Integrated Weed Management

Missoula, Mineral, Sanders, Granite, Powell, Lewis and Clark, Flathead, Ravalli and Lake Counties,

Montana

Responsible Agency:

USDA Forest Service

Responsible Official:

Deborah L. R. Austin Forest Supervisor Lolo National Forest

For Further Information Contact:

Andy Kulla, Project Team Leader Lolo National Forest Building 24A, Fort Missoula Missoula, Montana 59804 (406) 329-3962

Abstract: This Environmental Impact Statement (EIS) documents the consideration of seven alternatives for improving weed management on the Lolo National Forest (Lolo NF). Two alternatives were given detailed study and five alternatives were considered but not given detailed study. The Forest is proposing to treat up to 15,000 acres of weeds per year using an integrated weed management approach as described in this EIS as Alternative 2. Alternative 2 would add sheep and goat grazing to the Lolo NF weed management “tool box”, allow weed managers to more promptly control new weed species and new infestations of weeds already found on the Forest, and would allow us to better prioritize our weed control efforts. The integrated weed management tools included in Alternative 2 would include education and awareness, prevention, ground and aerially applied herbicides, goat and sheep grazing, biological control agents, mowing, pulling, seeding and fertilizing. The purpose of this project is to establish beneficial vegetation and weed resistant plant communities by:

• Preventing potential invaders from establishing • Eradicating small new infestations and reducing larger infestations of new invaders • Containing or reducing widespread weeds within infested areas • Allowing rapid, timely response to new, small or recently discovered infestations before

they spread and become well established • Preventing or limiting the spread of established weeds to protect weed-free areas; and • Implementing the 2004 Forest Service National Strategy and Implementation Plan for

Invasive Species Management

Alternative 1 would take no action to change the current weed management on the Lolo NF. Only sites with existing weed management decisions could be treated and about 5,000 to 6,000 acres would be treated each year. Under Alternative two 78,443 weed infested acres were analyzed. Alternative 2 would allow treatment of a maximum of 15,000 of these 78,443 acres in any one year. This broad “menu” of infested sites would allow managers to better prioritize our weed control efforts and maximize our effectiveness. Alternative 2 would also allow treatment of more new and small infestations before they grew to unmanageable proportions. Five other alternatives; Prevention Only, No Herbicides, Low Herbicides, Concentrated Eradication Cells and No Aerial Herbicide Application, were considered but not given detailed study for the reasons described in Chapter 2. Alternative 2 is the Agency’s preferred alternative.

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD).

To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800) 795-3272 (voice) or (202)720-6382 (TDD). USDA is an equal opportunity provider and employer.

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Table of Contents

Summary.......................................................................................................................... 1 Chapter 1 Purpose of and Need for Action................................................................... 1 Introduction...................................................................................................................................... 1 Purpose and Need for Action........................................................................................................... 3 Weed Law and Policy ...................................................................................................................... 8 Relationship to the Forest Plan ........................................................................................................ 9 Supporting Documents and Analysis............................................................................................... 9 Types of Actions Analyzed............................................................................................................ 12 Type of Impacts Analyzed ............................................................................................................. 13 Decision to be Made ...................................................................................................................... 14 Chapter 2 Public Participation, Issues and Alternatives........................................... 15 Introduction.................................................................................................................................... 15 Developing Alternatives ................................................................................................................ 16 Issues.............................................................................................................................................. 16 Alternatives Considered But Not Studied in Detail ....................................................................... 18 Alternatives Considered In Detail.................................................................................................. 21 Mitigation Measures ...................................................................................................................... 28 Environmental Justice.................................................................................................................... 31 Native American Treaty Rights ..................................................................................................... 31 Reasonable Foreseeable Actions.................................................................................................... 32 Monitoring ..................................................................................................................................... 32 Chapter 3 Affected Environment and Environmental Consequences ..................... 35 Introduction.................................................................................................................................... 35 Resources ....................................................................................................................................... 41 Weeds............................................................................................................................................. 41 Range ............................................................................................................................................. 62 Forest Vegetation ........................................................................................................................... 64 Threatened, Endangered, and Sensitive Plants and Native Plant Communities ............................ 70 Fish............................................................................................................................................... 103 Soils and Water ............................................................................................................................ 113 Recreation .................................................................................................................................... 125 Human Health and Herbicide Drift.............................................................................................. 127 Wilderness and Inventoried Roadless Areas................................................................................ 148 Wild and Scenic Rivers................................................................................................................ 152 Heritage Resources ...................................................................................................................... 154 Roads ........................................................................................................................................... 158 Wildlife ........................................................................................................................................ 160 Economics.................................................................................................................................... 196 Chapter 4 Consultation and Coordination................................................................ 201 Preparers ...................................................................................................................................... 201 Agencies, Organizations, Businesses and People Notified.......................................................... 202 Literature Cited ............................................................................................................................ 203

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Glossary ....................................................................................................................................... 232

Table of Contents

Chapter 5 DEIS Comments and FS Responses ....................................................... 235 Comment 1 - Dick Artley ............................................................................................................ 235 Forest Service Response.............................................................................................................. 236 Comment 2 - Jim Brown ............................................................................................................. 238 Forest Service Response.............................................................................................................. 238 Comment 3 – Phil Edholm Lookout Pass Ski and Recreation Area............................................ 238 Forest Service Response.............................................................................................................. 238 Comment 4 – Ed Childers ........................................................................................................... 238 Forest Service Response.............................................................................................................. 238 Comment 5 – Charles Miller and Family .................................................................................... 238 Forest Service Response.............................................................................................................. 238 Comment 6 – Gloria Wegener and Michael Wegener ................................................................ 238 Forest Service Response.............................................................................................................. 239 Comment 7 - Robert F. Stewart / Office of Environmental Policy and Compliance US Department of Interior................................................................................................................. 239 Forest Service Response.............................................................................................................. 240 Comment 8 - Bert Lindler ........................................................................................................... 240 Forest Service Response.............................................................................................................. 240 Comment 9 - Janie Canton-Thompson........................................................................................ 240 Forest Service Response.............................................................................................................. 241 Comment 10 – Jeff Juel, WildWest Institute and Alliance for the Wild Rockies ....................... 241 Forest Service Response.............................................................................................................. 265 Comment 11 – Dwayne Garner................................................................................................... 285 Forest Service Response.............................................................................................................. 285 Comment #12 – Mack Long, Montana Fish Wildlife and Parks................................................. 285 Forest Service Response.............................................................................................................. 287 Comment 13 - John F. Wardell, US Environmental Protection Agency..................................... 288 Forest Service Response.............................................................................................................. 299 Comment 14 – Meggan Ryan...................................................................................................... 303 Forest Service Response.............................................................................................................. 303

Appendices A Project Area Maps By District ......................................................................................................1-5 B Screening/Adaptive Strategy Procedures.........................................................................................6 C Emergency Spill Plan .................................................................................................................. 7-14 D Weed Characteristics ............................................................................................................... 15-24 E Riparian Mitigation Measure Certification................................................................................... 25 F Fisheries Level 1 Team Recommendations .............................................................................. 26-31 G Best Management Practices for Weed Control....................................................................... 32-47 H Cost Estimate by Alternative .......................................................................................................... 48

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I Herbicide and Target Weed Species ............................................................................................... 49

List of Tables and Figures

Figures Figure 1-1 Vicinity Map ....................................................................................................................................2 Figure 2-1 Weed treatment decision tree .........................................................................................................24 Figure 3-1 Relationships between cover of spotted knapweed and richness and cover of native species, overall and by functional group, at knapweed invasion sites in western Montana, as determined by mixed models analysis. Functional group information is given............................................77 Figure 3-2 Average percent similarity between the experimental plots and reference stands defining potential natural communities (Rice & Toney 1998).......................................................................................85 Figure 3-3 Average percent biomass (of total biomass) for grasses, spotted knapweed, and other forbs for eight Sawmill RNA double sampled test plots sprayed (1 pt/ac picloram) in fall of 1996 and fall 2004 (2/3 pt/ac clopyralid); as well as absolute canopy cover. * Values for cheatgrass are calculated from percent absolute canopy cover estimates, not biomass estimates..........................................................87 Figure 3-4 Average percent of lifeform total biomass after herbicide application Lolo National Forest winter range sites one time with a pint or less of herbicide (n = 3 to 4 sites depending on sample year) (Rice and Gauer 2007). ............................................................................................................................88 Figure 3-5 Average percent of life-form total biomass after herbicide application Lolo National Forest winter range one time with a quart or more of herbicide (n = 2 to 4 sites depending on sample year) (Rice and Gauer 2006). ............................................................................................................................89 Figure 3-6 Gibbons Pass plots in 2004 (G4), 2005 (G5), and 2006 (G6) compared to Mueggler & Stewart Idaho fescue/bluebunch wheatgrass habitat type definition plots (not labeled) (relative % canopy cover; NMS two dimensional ordination stress=15) (Rice and Gauer 2006)..................................91

Tables Table 1-1 Weeds on the Lolo NF.....................................................................................................................4 Table 1-2 Acres of Herbicide Treatment Allowed Under Existing NEPA .........................................................7 Table 1-3 Acres of Weed Treatment Since 1997...........................................................................................13 Table 2-1 Acres proposed for treatment by Ranger District...........................................................................23 Table 2-2 Herbicides included in Alternatives 1 and 2...................................................................................25 Table 2-3 Comparing Alternatives .................................................................................................................27 Table 2-4 Comparing How the Alternatives Address the Purpose and Issues in This Analysis.....................27 Table 3-1 Disturbance Levels by Site Type*..................................................................................................36 Table 3-2 Acres by County ............................................................................................................................37 Table 3-3 Public Knowledge about Weeds....................................................................................................40 Table 3-4 Seriousness of Weed Problem ......................................................................................................40 Table 3-5 Number of Weeds Known .............................................................................................................40 Table 3-6 Ability to Name a Weed .................................................................................................................41 Table 3-7 2005 Estimated Infested Acres on the Lolo NF .............................................................................43 Table 3-8 1998 NRIS Weed Inventory for the Lolo NF (Acres/ percent of Lolo NF) ......................................44 Table 3-9 Estimated Acres at Risk on the Lolo NF ........................................................................................45 Table 3-10 Estimated Infested Acres Compared to Acres at Risk on the Lolo NF ........................................46 Table 3-11 Broad Scale Cover Types in the Project Area and their Susceptibility to Invasion for 24 Weed Species................................................................................................................................................47 Table 3-12 Mormon Ridge Four Year Post Treatment Weed Canopy Cover ................................................49 Table 3-13 Status and Effects of Spotted Knapweed Biological Control Agents ...........................................55 Table 3-14 Potential Vegetation Type Groups on the Lolo NF ......................................................................66 Table 3-15 Forest Dominance Types ............................................................................................................67 Table 3-16 G1-G3 Sensitive Species Known or Suspected to Occur on the Lolo NF ...................................70 Table 3-17 G4-G5 Sensitive Species Known or Suspected to Occur on the Lolo NF ...................................71 Table 3-18 Species of Concern Known or Suspected to Occur on Lolo National Forest...............................74 Table 3-19 Species of Interest Known or Suspected to Occur on Lolo National Forest. ...............................74 Table 3-20 TES Plant Species Biological Evaluation Summary ....................................................................96 Table 3-21 Species of Concern Biological Evaluation Summary...................................................................99 Table 3-22 Species of Interest Biological Evaluation Summary ..................................................................100 Table 3-23 Ecotoxicological Risks for Aquatic Species. ..............................................................................109 Table 3-24 Characteristics of the Herbicides Proposed for Use Relative to Salmonid Fishes.....................109

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Table 3-25 Determination of Effects for Bull Trout and Westslope Cutthroat Trout .....................................110

Tables Table 3-26 Biological Evaluation of Alternatives..........................................................................................111 Table 3-27 Water Characteristics ................................................................................................................115 Table 3-28 Representative Stream Flows ...................................................................................................115 Table 3-29 Margin of Safety on maximum Acute and short-term Chronic Exposure to Picloram ................122 Table 3-30 Montana Water Quality Human Health Standards for Herbicides..............................................124 Table 3-31 Herbicides Included in Alternative 1 and 2 ................................................................................132 Table 3-32 Recommended Minimal Buffer Zones Associated with Different Herbicide Spray Applications in the Missoula Valley to Achieve a Reasonable Certainty of No Harm to Children (Felsot 2001)............................................................................................................................................................144 Table 3-33 Summary of land in Wilderness, National Recreation Area and Inventoried Roadless Designation. .................................................................................................................................................149 Table 3-34 Annual Miles of projected/actual Construction and Reconstruction ...........................................158 Table 3-35 Management Indicator Species for the Lolo NF ........................................................................162 Table 3-36 Federally Listed Species Present on the Lolo National Forest ..................................................167 Table 3-37 Treatment of Risk Factors as Outlined in LCAS ........................................................................181 Table 3-38 Sensitive Wildlife Species that are either suspected or known to occur on the Lolo NF* ..........184 Table 3-39 Estimated Economic Impacts ....................................................................................................198

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Summary

Integrated Weed Management on the Lolo National Forest

Proposed Action The Lolo National Forest (NF) proposes to implement an adaptive integrated weed management strategy to address the weed problem on the NF by:

• Encouraging beneficial vegetation and weed resistant plant communities • Improving public awareness of the issues surrounding weeds • Use of weed prevention practices

This integrated weed management strategy would use knowledge gained from each treatment and education program to improve on subsequent projects. It would allow managers to control new and small weed infestations before they expand, cause resource damage and become less manageable. This strategy includes:

• Weed prevention and education • Combination of ground and aerially applied herbicides • Biological agents • Revegetation • Mechanical and cultural treatments • Sheep and goat grazing

The weeds that would be addressed are displayed in Chapter 1 in Table 1-1. A maximum of 15,000 acres could be treated annually. This is less than 1 percent of the approximately 2.1 million acres administered by the Lolo NF. A total of 78,443 acres needing weed treatment have been identified in this analysis. Annual treatment may be less if weed budgets do not increase. Since weeds are often not continuous within a project area, actual treated acres would typically be less than the total area within any given project area. All of these weed management practices would be considered for each weed infestation. Acres proposed for treatment by Ranger District are shown in Table S-1.

Managers would select the maximum of 15,000 acres/year for treatment based on:

• Funding • Invasiveness of the weed species • Size of the infestation • Potential for the seeds to move off-site • Ecological importance or rarity of a certain site

The treatment priorities for this EIS include the priorities from the 1991 Lolo NF Plan Amendment 11 for noxious weed management and add others as follows:

• Bunchgrass big-game winter ranges • Weed-free areas, and the roads, trails and trailheads that lead into them • Areas of concentrated public use (since people spread weeds)

Final Integrated Weed Management EIS Summary-1

• Administrative sites

Summary

• National Forest lands bordering private lands with active weed-controlling programs

• Disturbed areas (as described in Chapter 2)

The purpose of treatments would be not only to kill the standing crop of weeds, but also to deplete the number of viable weed seeds in the soil, and encourage beneficial vegetation and weed resistant plant communities. Sites may need follow-up treatments until the viable weed seeds are depleted, regardless of what control method used. Eight to ten years is a typical viability period for the seeds of many weeds found on the Lolo NF. Treatments may not occur every year, depending on the control method used.

If herbicides were used, treatment return intervals would depend on the weed species, the size of the infestation, the soils and the persistence of the herbicide. If mechanical control or grazing was used the return period would be annually or even twice a year.

Treatment sites range in size from a few plants to infestations with a gross exterior boundary of 16,380 acres. In most areas, weeds do not cover all or even most of the project area. For example, on an infested area of two acres, only a half acre of ground might actually be occupied by scattered clumps of weeds.

Implementation could begin in calendar year 2008 and would continue until new information indicates the need for additional analysis.

Efforts would be made to coordinate treatments with private landowners managing weeds adjacent to national forest lands.

Purpose and Need for Action The overall purpose of this proposal is to raise public and agency awareness of weeds, increase both public and agency use of weed prevention practices, reduce and control existing weeds, prevent new weeds from establishing on the Lolo NF, and encourage beneficial vegetation and weed resistant plant communities. The purpose of direct weed control on the Lolo NF is to:

• Prevent potential invaders from establishing • Eradicate small new infestations and reduce larger infestations of new invaders • Contain and reduce widespread weeds within infested areas • Allow rapid, timely response to new, small or recently discovered infestations before

they become well established • Prevent or limit the spread of established weeds to protect weed-free areas • Implement the 2004 Forest Service National Strategy and Implementation Plan for

Invasive Species Management

The need for this project is: 1) Noxious weeds are present and spreading.

Summary-2 Final Integrated Weed Management EIS

Populations of widespread invaders, such as spotted knapweed, sulfur cinquefoil, houndstongue and Canada thistle, are widespread and continue to expand. Since they became established, in some cases decades ago, they have increased on the Lolo NF. These weeds have also invaded both disturbed and undisturbed areas.

Summary

New invaders such as the hawkweeds and common toadflax have become established relatively recently. Some of these infestations were first seen on the Lolo NF in the last few years, while others have been here longer but have only recently been discovered. Most new invaders have limited distribution.

Potential invaders such as yellow starthistle, purple loosestrife, salt cedar and dyer’s woad have not been found on the Lolo NF yet, but do occur nearby. Based on the extent of the infestations in adjacent areas and states, these weeds have the potential to become established and impact other resources.

2) While prevention is an important weed management tool, we need to address existing weed populations on the Lolo NF.

Weed prevention and mitigation practices are used on the Lolo NF in association with direct control measures. Prevention efforts include practices such as washing off-road machinery to prevent the further spread of weeds, the 1995 Special Order requiring the use of certified weed-seed-free feed on the Lolo NF lands and the Northern Region weed prevention “Best Management Practices” (Appendix G).

Education is another prevention practice used on the Lolo NF and includes such activities as distributing posters and brochures, and the “Leave No Weeds” education program the Lolo NF developed for use in schools. These efforts need to continue to increase awareness of the weed problem and to help build a sense of personal responsibility to minimize the spread of weeds.

3) We are already doing a lot of weed management but weeds are still damaging forest resources, so we need to do more.

Forest resources are negatively impacted by existing and expanding populations of weeds. Because their naturally adapted competitors and native biological control agents are absent, weeds can out-compete and crowd out native plants.

Noxious weeds diminish the productivity, bio-diversity and appearance of Lolo NF lands. Weeds can cause habitat loss and adversely affect diversity and habitat function in plant communities.

4) We need to be able to respond quickly to new infestations and disturbances such as wildfire.

At present, we cannot respond rapidly to new infestations and disturbances. The Lolo NF is receiving more and more requests from the public to control weeds and is not able to respond to those requests.

We want to focus our weed control efforts on the infestations with the greatest potential impacts if left unchecked, those with the highest risk of further spread and those where we have the best likelihood of success. These areas are described in more detail in the Purpose and Need for Action section in Chapter 1.


5) We want to have an active weed program so we can implement and follow Federal, State and Forest Service law, regulation, policy and initiatives relating to weed management.

Summary

Forest plan and agency objectives for biodiversity, our responsibility to health and safety, cooperation with neighboring land owners and consistency with Federal and State laws require an aggressive weed program. The weed laws and policy described in Chapter 1 also direct us to have an aggressive program.

The Northern Region Overview, the Chief of the Forest Service and Montana Governor Brian Schweitzer have all identified weeds as high priority risks to National Forest lands. While we recognize that we will never eradicate all the weeds on the Lolo NF, we want to do a better job than we are doing now. We feel that this desire to do better is an integral part of responsible land management.

Issues Issues were categorized into three groups:

1) Issues outside the scope of the Proposed Action 2) Issues considered but not given further analysis 3) Issues that need further analysis – these are the issues that drive alternatives

Issue outside the scope of the Proposed Action One commenter questioned the adequacy of the process used by the Environmental Protection Agency (EPA) to review and register herbicides for weed control. The EPA has regulatory responsibility regarding the evaluation, disclosure and registration of herbicides in the United States. This issue is beyond the legal authority of this analysis and the Forest Service and, as such, is outside the scope of the Proposed Action. For these reasons, this issue was not considered in this analysis.

Issue considered, but not given further analysis Why are we proposing a 15,000-acre cap on the area we could treat each year? This seems too small to address the weed infestations found on the 2.1 million acre Lolo NF.

While we recognize a biological need to treat more acres each year, this figure was proposed to provide an upper limit for effects analysis and it reflects our estimated maximum capacity to implement weed management activities on the Lolo NF.

Issues needing further analysis

Why don’t we analyze a Prevention Alternative?


This issue was used to formulate an alternative, but since it wouldn’t address existing weed infestations, this alternative was not given detailed analysis. Refer to Chapter 2, Alternatives Considered, but Not Studied in Detail for more discussion. Prevention however, is included as one weed management tool in Alternative 2.

Summary

Why don’t we consider a Low Herbicide Alternative?

We developed a Low Herbicide alternative to respond to this issue and it was considered, but not studied in detail. Refer to Chapter 2, Alternatives Considered, but Not Studied in Detail for more discussion.

What are the effects of weeds on wildlife and other natural resources?

Many people feel that weeds are a very big problem because they’ve seen the impacts of these invasive non-native plants on vast areas. The effects of weeds on resources are discussed in Chapter 3.

How would actions taken to control weeds, especially herbicides, affect wildlife and other resources?

Some people expressed concern about the effects of herbicides on wildlife and other natural resources. To respond to this issue, in Chapter 2, a No Herbicide Alternative is discussed, a Low Herbicide Alternative is considered, but not studied in detail and the No Action Alternative, which holds herbicide use at current levels, is analyzed. The effects of herbicides on natural resources, as well as models and past experience with herbicide drift from aerial application, are disclosed in Chapter 3.

What are the potential effects of herbicides on human health?

Some people expressed concern about the effects of herbicides on human health. To respond to this issue, a No Herbicide Alternative is discussed in Chapter 2, Alternatives Considered, but Not in Detail. In addition, the potential human health effects of herbicides named in this proposal are disclosed in Chapter 3.

Alternatives Considered in Detail

Alternative 1, No Action

Under the No Action Alternative, no new actions would be taken to respond to the Purpose and Need. Some weed control would continue to take place at current levels, namely, actions authorized in past site-specific decisions. This amounts to about 5,000 to 6,000 acres annually.

There would be no forest-wide plan to take action on new weed species or new infestations. Actions to control or eradicate new infestations not covered in existing decisions would require further NEPA analysis and documentation. These analyses would take from one to three years to complete and only if funding becomes available.

Alternative 2, Proposed Action


Under this alternative, the Lolo NF would implement an adaptive integrated weed management strategy to control weeds at current levels. Adaptive Management, as used in this analysis, is defined as a dynamic approach to resource management in which the effects of treatments and decisions are continually monitored and used, along with research

Summary

results, to modify management on a continuing basis to ensure that objectives are being met. It would also allow managers to control new and small weed infestations before they can expand, have a greater impact on other resources and become less manageable.

This strategy includes a prevention and education component, together with a combination of ground and aerially applied herbicides, biological agents, revegetation, mechanical and cultural treatments, and sheep and goat grazing on a maximum of 15,000 acres/year. Managers will be able to prioritize annual weed treatments to where we can have the greatest benefit.

Annual treatment priorities are described above under the Proposed Action heading in this summary. Most weed treatments would require re-treatments until the weed seed is depleted in the soil seed bank (for direct controls) and until public prevention measures are commonly used (for education measures). Re-treatment would be least frequent for herbicides (1 to 3 growing seasons). Re-treatment would be most frequent for grazing, mowing or pulling (1 to 2 times per growing season).

Table S-1 Acres proposed for treatment by Ranger District Ranger District Acres

Missoula 7,082 Ninemile 31,351 Plains/Thompson Falls 35,949 Seeley Lake 2,292 Superior 1,769

TOTAL 78,443

When new weed infestations are found, they would be screened to determine priorities and what kind of treatment to use. A Decision Tree (Figure 2-1 page 24 in Chapter 2) would be used to determine the most appropriate method(s) to use to maximize weed control and minimize the risk of adverse environmental effects. Mitigation measures would be used to minimize any adverse effects on human health and other resources.

• Herbicides would be used at or below the rates specified on the label or in the Lolo NF Plan, whichever is more restrictive.

• Aerial application would be considered and used according to the mitigation measures and subject to the criteria described in Chapter 2.

• This alternative includes an adaptive approach that would allow managers to learn from the past and improve treatments in the future.

Alternatives Considered but Not Given Detailed Study

Additional alternatives were considered but not given detailed study. These alternatives were:

• Prevention only • No herbicides • Low herbicide use • Concentrated eradication cells • No aerial herbicide application


The reasons these alternatives were not given detailed study are discussed in Chapter 2.

Summary

Affected Environment

The analysis area occurs across the Lolo NF. The Lolo NF stretches for 120 miles in a northwest to southeast direction and lies in west-central Montana. The forest extends from the Idaho border east. The forest is 40 to 80 miles wide in a southwest and northeast direction. The Clark Fork of the Columbia River is the major drainage. Interstate 90 bisects the forest. Chapter 3 describes which and how resources may be affected.

Environmental Consequences Chapter 3 discloses the potential environmental consequences of the alternatives. Direct effects are caused by the action and occur at the same time or place. Indirect effects are caused by the action and are later in time or farther removed in distance, but still reasonable foreseeable. Cumulative effects are the impacts which result from the action when added to other past, present, and reasonable foreseeable future actions regardless of which agency or person undertakes such actions.

Comparison of the Alternatives The main differences between Alternative 1 and Alternative 2 are that in Alternative 2:

• We could add sheep and goat grazing in our weed management “tool box” • We would be able to better prioritize which weed infestations we treated each year,

our intention being to get the greatest benefit for our weed management dollar • We would be able to treat new and recently discovered weed infestations • We could treat up to 15,000 acres/year if funding allowed. Otherwise we would

treat our historical level of about 5,000 to 6,000 acres/year • Alternative 2 would put an increased emphasis on encouraging beneficial

vegetation and weed resistant plant communities, and establishing native and desirable vegetation rather than just killing weeds


The following table briefly summarizes how each alternative relates to the Purpose for this analysis and the effects of the alternatives by issue. More information on the issues is available in Chapter 2. A detailed disclosure of environmental consequences is presented in Chapter 3.

Summary

Table S-2 Comparison of how the alternatives address the Purpose and Issues in this analysis.

Alternative 1, No Action Alternative 2, Proposed Action

Purpose: Prevent potential invaders from establishing.Includes full range of prevention measures and BMPs, but limits ability to treat new invaders

Same as Alternative 1 but allows for treatment of new invaders as funded.

Purpose: Eradicate small new infestations and reduce larger infestations of new invaders. Minimally meets purpose, because it does not allow rapid response to small new infestations without additional NEPA analysis.

Best meets purpose, because it allows rapid treatment of both small and large new infestations.

Purpose: Contain and reduce widespread weeds within infested areas. Moderately meets purpose on sites with existing NEPA decisions, but does not allow containment or reduction of widespread weeds unless they are covered by an existing NEPA decision.

Best meets purpose, because it allows rapid containment and reduction of more widespread weeds that are not covered by an existing NEPA decision.

Purpose: Allow rapid, timely response to new, small or recently discovered infestations before they become well established. Minimally meets purpose, because it does not allow rapid response without additional NEPA analysis, which usually takes from 1 to 3 years.

Best meets purpose, by allowing rapid, timely response to widest range of situations.

Purpose: Prevent or limit the spread of established weeds in weed free areas. Meets purpose only in places where there is an existing NEPA decision.

Best meets purpose, by allowing rapid response to the widest range of situations.

Purpose: Implement the 2004 Forest Service National Strategy and Implementation Plan for Invasive Species Management. Implements the strategy for sites with existing NEPA decisions. Does not implement the strategy on new infestations or after disturbances such as wildfire.

Implements the strategy by providing flexible and rapid response while ensuring other resource protection.

Issue: What are the effects of weeds on wildlife and natural resources? Impacts of weeds include:

• Changes in plant community composition and structure. • Loss of sensitive plant populations. • Effects on water and soil quality. • Effects to people allergic to weeds

Provides lower level of protection for native plants from weeds. No reduction of weed-caused impacts to soil and water on sites without existing NEPA decisions.

Provides higher level of protection for native plants from weeds. Reduces weed-caused impacts to soil and water and people.

Issue: How would actions taken to control weeds, especially herbicides, affect wildlife and natural resources? Impacts of herbicides include effects to: Fish and terrestrial animals, Non-target plants, and soil and water quality.

On average, treatment would occur on less than ¼ of 1% of the acres on the Lolo NF. Effects would be extremely low due to limited acres treated and mitigation measures applied.

Annual maximum treatment would occur on less than ¾ of 1% of the acres on the Lolo NF. Low effect due to limited acres treated. Mitigation measures would further minimize effects.

Issue: What are the potential effects of herbicides on human health (chemically sensitive individuals, people allergic to herbicides and general public)?

On average, treatment would occur annually on less than ¼ of 1% of the acres on the Lolo NF. Effects would be below established toxicological thresholds due to limited acres treated and mitigation measures applied. Mitigation would help sensitive people avoid treatment sites.

Annual average treatment would occur on less than ¾ of 1% of the acres on the Lolo NF. Effects would be below established toxicological thresholds due to limited acres treated and mitigation measures. Mitigation would help sensitive people avoid treatment sites.
