on the
Rogue River National Forest
P.O. Box 520
Medford, OR 97501
1998/1999
20 Sept. 98
Prepared by:
Joel E. Pagel; USDA FS Region 6 Peregrine Falcon Specialist and ROR TES Specialist/Forest Biologist
Reviewed for project consistency by:
Stephen Bulkin; Forest Silviculturist
* Hard copy signed on 20 Sept. 98 (JEP)
Introduction: Purpose and Need
Per FSM 2672.4, the USDA Forest Service is directed to complete a biological evaluation (BE) to examine effects of proposed projects on Proposed, Endangered, Threatened (USDI Fish and Wildlife Service, endangered species list) and Sensitive species (USDA Forest Service Regional Forester sensitive species list) (PETS) prior to the implementation of projects. BE’s are used to examine proposed actions and ensure that projects will not adversely affect the existence or cause adverse modification of habitat for PETS species. FSM 2672.41 and 2672.42 objectives and standards (respectively) were used to prepare this evaluation.
This BE addresses the proposed Control and prevention of noxious weeds on the Rogue River National Forest project.
The following documents (in addition to literature cited) were used as part of the analysis process for guidance and reference;
Rogue River Land and Resource Management Plan
Record of Decision for Amendments to Forest Service and Bureau of Land Management planning Documents within the range of the Northern Spotted Owl
Forest Service Manual, Section 2670
Mediated agreement between the Northwest Coalition for Alternatives to Pesticides, Secretary of Agriculture, and Oregonians for Food and Shelter, 24 May 1989
Proposed Action
The proposed action is described in the attached plan of work and Table 1. Briefly, this project entails the prevention and control of non-native vegetation (a.k.a. weeds) infestations using manual, mechanical, biological, and in severe instances, chemical herbicides. The objectives of this project are to:
Long term elimination and short term control/reduction of current infestations of noxious weeds.
Prevent further spread of noxious weeds to other remote or roaded areas of the National Forest.
Coordinate with other agencies and adjacent landowners for the prevention and control of noxious weeds, and to reduce their invasion onto federal lands.
Develop an integrated pest management scenario and plan for noxious weed management.
Develop preventative practices and rigorous monitoring techniques for noxious weed control actions.
Noxious weed species have become widespread and in some areas ubiquitous over portions of the southern Oregon landscape. Plant species to be controlled do not have current economic or ecological value to the native landscape, and endanger endemic floral communities, and ecological integrity of wildlife habitat.
The species addressed for control by this proposal and subsequent BE include; spotted and spotted knapweed, purple loosestrife, St. John’s wort, Scotch broom, Tansy ragwort, yellow toadflax, Canadian thistle, hound’s tongue, yellow star thistle, dalmation toadflax, and puncture vine. Noxious weeds are defined in 7 USC 61:2802 as plants that are "of foreign origin, and can directly or indirectly injure ... other useful plants..." Further information on these invasive weed species may be reviewed in the attached proposal.
The four alternatives of this proposal include
1) no-action
2) mechanical and manual
3) chemical
4) combined methods including mechanical, manual, and chemical
Species Information
Species addressed per this BE are listed below.
Proposed, endangered or threatened species (per 1998 programmatic consultation BA and BO with USDI Fish and Wildlife Service)
peregrine falcon Falco peregrinus anatum northern bald eagle Haleatus leucocephalis northern spotted owl Strix occendatalis marbled murrelet Brachyramphus marmoratus
FS Sensitive (FSM 2670 supplement)
Siskiyou mountain salamander Plethodon stormi red-legged frog Rana auroa common kingsnake Lampropeltis getulus California mountain kingsnake Lampropeltis zonata northwestern pond turtle Clemmys marmorata marmorata ferruginous hawk Buteo regalis greater sandhill crane Grus canadensis tabida Pacific western big eared bat Plecotus townsendii townsendii white-footed vole Arborimus albipes California wolverine Gulo gulo luteus Dennings agapetus Agepetus denningi Schuh’s homoplectran Homoplectra schuhi Klamath limnephilan Limnephilus alcoaura Fisher’s caddisfly Lepistoma fischeri Green Springs Mountain caddisfly Farula davisi Siskiyou caddisfly Tinodes siskiyou
Effects of Proposed Action
The landscape effects of the proposed action using alternatives 2, 3 and 4 will be beneficial to all species. Restoration of endemic plant life, and a reduction of introduced weeds will return disturbed habitat to some semblance of native vegetation. However, short term difficulties and effects to individuals (red-legged frogs and Siskiyou salamanders) with several species could be realized via the chemical alternative if accidental release via transportation spills or misapplication of herbicides occurs. Adequate after-action monitoring programs are important to conduct adaptive management on proposed actions.
The no-action alternative may have long-term detrimental landscape level effects. Noxious weeds often become established in disturbed areas where endemic plants are unable to compete effectively. The noxious weed situation on the Rogue River National Forest is of extreme concern, however time for well-considered planning and prevention actions should not be given less attention because of a perceived "crisis" (see Cox 1998).
Proposed, endangered and sensitive species on the Rogue River National Forest include:
Species Determination Proposal 1 2 3 4 peregrine falcon NE NE NE NE northern bald eagle NE NE NE NE northern spotted owl NE NE NE NE marbled murrelet NE NE NE NE
NE = No Effect
The four federally listed species addressed via this BE will not be affected; either directly or indirectly via disturbance, reduction and/or contamination of their prey, or nesting, roosting or foraging habitat. The following rationale was used to make this determination.
American peregrine falcon
Peregrine falcon nest sites on the ROR are not proximal to the action areas.
Northern bald eagle
Northern bald eagle nest sites on the ROR are not proximal to the action areas.
northern spotted owl
Spotted owl activity centers are not proximal to the action areas.
Marbled murrelet
No marbled murrelet nest sites, or anecdotal or surveyed observations have been found on the Rogue River National Forest.
Manual and mechanical methods, including gas and diesel powered equipment, used to prevent and control noxious weeds would not cause disturbance, habitat removal or take of PETS individuals or species.
Bioaccumulation is not likely with the application of the chemical herbicides slated for use, and would not affect the species viability, or individuals (Anon 1994 a, b & c, Anon 1997 a & b). Further, endocrine disruption has not been shown or tested with the proposed herbicides (contaminants) (see O’Brien 1987); the dose of the contaminant to be used would suggest endocrine disruption would be localized and short-lived IF it were to enter the food chain of any of these species. However, it is reasonable to assume that peregrine falcons, red-legged frogs, and Siskiyou salamanders are the only PETS species which could be remotely affected by chemical contamination by herbicides due to bioaccumulatory pathways through the food chain (peregrine falcon), or direct contact with moist skin (anurans and salamanders). Bioaccumulation and potential for endocrine disruption caused by the proposed chemicals is unlikely for the peregrine falcon, even under worse-case scenarios (Pagel notes).
Herptiles; specifically salamanders and anurans, are sensitive to chemical contaminants, and can be adversely affected by quantities which seem minuscule (McComb et al. 1990, Bidwell and Corria 1995). All of the area proposed to be chemically treated is xeric and disturbed by previous anthropogenic activities. The action area is considerably drier than the specific habitat requirements of these two species; however precautions prescribed legally and by Forest Service direction for chemical treatment should be strictly adhered to. Herptile species habitats are not immediately proximal to the disturbed xeric habitat and would not be affected by the chemical treatments.
Species Determination Proposal 1 2 3 4 Siskiyou Mountain Salamander
NI NI NI NI Red-legged frog NI NI NI NI common kingsnake NI NI NI NI California mountain kingsnake NI NI NI NI Northwestern pond turtle NI NI NI NI Ferruginous hawk NI NI NI NI greater sandhill crane NI NI NI NI Pacific western big eared bat NI NI NI NI white-footed vole NI NI NI NI California wolverine NI NI NI NI Dennings agapetus NI NI NI NI Schuh’s homoplectran NI NI NI NI Klamath limnephilan NI NI NI NI Fisher’s caddisfly NI NI NI NI Green Springs Mountain caddisfly NI NI NI NI Siskiyou caddisfly NI NI NI NI
NI = No Impact
Determination
This project; all alternatives, will have a no-effect determination on all federally listed species; specifically American peregrine falcons, northern spotted owl, bald eagle, and marbled murrelet. Consultation with the USDI Fish and Wildlife Service is not necessary regarding this project.
This project, all alternatives, will have a no-impact determination on all Regional Forester sensitive species because habitat is not available for critical life functions within the areas to be treated.
Recommendations
Forest Service projects which attempt to restore habitat and conserve indigenous species are important to landscapes and local ecosystems. Indeed, much of this project is non-controversial. However, introducing human produced contaminants into an ecosystem can be fraught with potential hazards; known and unknown (O’Brien 1997, 1998). One only needs to examine the instance of the peregrine (Pagel 1995) or other situations (Pagel and O’Brien 1996) to realize that often we are not completely sure of the final outcome of many of our management actions.
I offer the following mitigation recommendations to alleviate and eliminate potential long term resource damage caused by restoration activities, and to reduce the potential for non-productive release of herbicides.
- Evaluate efficacy of proposed herbicide release (if this alternative is selected) through rigorous monitoring with adequate baseline established prior to action.
- Provide (long term funding and staffing) for efficacious short and long term statistically and ecologically sound monitoring of treatment. Product should be publication in peer-reviewed journal.
- Provide for preventative actions to identify and eliminate the source of weed dispersal to and from nearby habitat.
- Use appropriate techniques for each site and plant (see Cox 1998).
Literature Cited
Anon. 1997a. Glyphosate; herbicide information profile. USDA Forest Service, Pacific Northwest Region, Portland.
Anon. 1997b. Triclophyr; herbicide information profile. USDA Forest Service, Pacific Northwest Region, Portland.
Anon. 1994a. Hexazinone; herbicide information profile. USDA Forest Service, Pacific Northwest Region, Portland.
Anon. 1994b Dicambra; herbicide information profile. USDA Forest Service, Pacific Northwest Region, Portland.
Anon. 1997c. Clopyralid. DowElanco, Indianapolis.
Bidwell, J.R. and J.R. Corria. 1995. Acute toxicity of a herbicide to selected frog species. Final Report, Tech. Ser. 79. Dept. Env. Protection, Perth.
Cox, C. 1998. Lessons from leafy spurge and yellow starthistle. J. Pesticide Reform. 18:2-6.
McComb, W.C., L.R. Curtis, K.Bentson, M. Newton, and C.L. Chambers. 1990.
Toxicity of glyphosate herbicide to terrestrial mammals and amphibians of the Oregon Coast Range. Draft Rept. for USDA NAPIAP Project # PNW 89-456.
Northwest Coalition for Alternatives to Pesticides V Richard Lyng, USDA. 1989. Civil No. 83-6772-E-BU. Oregon District, US District Court.
O’Brien, M. 1997. Some of the problems with herbicide treatments for noxious weeds. Presentation at Noxious Weed Workshop, USDA FS Pacific Northwest Region, Portland.
O’Brien, M. 1998b. 04 July letter to Karyn Wood, Wallowa-Whitman National Forest.
Pagel, J.E. 1995. Quandaries and complexities of ecological risk assessment: Viable options to reduce humanistic arrogance. Human and Ecol. Risk Assessment 1:376-391.
Pagel, J.E. and M. O’Brien. 1996. The use of ecological risk assessment to undermine implementation of good public policy. Human and Ecol. Risk Assessment 2:238-242.