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Environmental Assessment
Superior National Forest Non-Native Invasive Plant Management Project
Superior National Forest St. Louis, Lake, and Cook Counties
April, 2006
Responsible Official: Jim Sanders Forest Supervisor Superior National Forest 8901 Grand Ave. Place Duluth, MN 55808 For Further Information Contact: Jack Greenlee Laurentian Ranger District 318 Forestry Rd. Aurora, MN 55705 (218) 229-8817
Spotted Knapweed
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Table of Contents
1.0 Purpose and Need and Proposed Action ................................................................................... 3
1.1 Introduction ........................................................................................................................... 3
1.2 Purpose and Need for Action ................................................................................................ 5
1.3 Modified Proposed Action ................................................................................................... 6
1.4 Decisions To Be Made .......................................................................................................... 8
1.5 Scoping / Public Involvement ............................................................................................... 8
1.6 Issues ..................................................................................................................................... 9
1.7 Analysis of Significance Factors ......................................................................................... 9
2.0 Alternatives ............................................................................................................................. 11
2.1 Introduction ......................................................................................................................... 11
2.2 Development of a Range of Alternatives ............................................................................ 11
2.3 Alternatives Considered But Not Analyzed In Detail......................................................... 11
2.4 Alternatives Considered in Detail ....................................................................................... 12
2.4.1 Alternative 1 – No Action ............................................................................................ 12
2.4.2 Alternative 2 – Modified Proposed Action .................................................................. 12
2.5 Monitoring and Evaluation ................................................................................................. 22
2.6 Comparison of the Alternatives .................................................................................... 22
3.0 Affected Environment and Environmental Consequences ..................................................... 24
3.1 Description of Project Area ................................................................................................ 24
3.2 Threatened and Endangered Species .................................................................................. 24
3.2.1 Analysis Area ............................................................................................................... 24
3.2.2 Affected Environment .................................................................................................. 24
3.2.3 Environmental Consequences ...................................................................................... 24
3.3 Regional Forester’s Sensitive Species ................................................................................ 26
3.3.1 Analysis Area ............................................................................................................... 26
3.3.2 Affected Environment .................................................................................................. 26
3.3.3 Environmental Consequences ...................................................................................... 26
3.4 Significance Factors ............................................................................................................ 30
4.0 References ............................................................................................................................... 37
Appendix A – maps ...................................................................................................................... 41
Appendix B – site table ................................................................................................................. 42
Appendix C – Scoping/Public Comment Summary ..................................................................... 43
Appendix D – herbicide environmental characteristic and mammal toxicicty summary ............. 53
Appendix E – Design Features ..................................................................................................... 57
Appendix F - Past, present, and reasonably foreseeable projects ................................................. 61
Appendix G – List of Preparers and Contributors ........................................................................ 62
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SUPERIOR NATIONAL FOREST NON-NATIVE INVASIVE PLANT MANAGEMENT PROJECT
1.0 Purpose and Need and Proposed Action
1.1 Introduction
The Superior National Forest has a unique opportunity to prevent some of the widespread
ecological, social, and economic impacts caused by non-native invasive plants that
plague other parts of the United States. In order to maintain and improve aquatic and
terrestrial wildlife habitat and to maintain healthy, resilient native plant communities, the
Forest Service proposes to implement a Forest-wide non-native invasive plant
management program, beginning with treatments on approximately 146 acres and
possibly expanding up to 219 acres over the next 10 years.
The purpose of the proposed action is to eradicate or control existing non-native invasive
plant (NNIP) populations and to respond rapidly to new infestations in order to prevent
the further spread of NNIP. This project proposes an integrated approach to NNIP
control to achieve results, including use of manual, mechanical, herbicide, and biological
control methods. Only manual treatments would be implemented in the Boundary
Waters Canoe Area Wilderness.
The project area consists of 1686 NNIP sites spread throughout the Superior National
Forest, which stretches 130 miles across northeastern Minnesota from the Lake Superior
shore to the international border just east of Voyageurs National Park and Rainy Lake. It
encompasses parts of Cook, Lake, and St. Louis Counties. The one million acre
wilderness area along the Canadian border is the Boundary Waters Canoe Area
Wilderness (BWCAW). The Superior NF contains a diversity of vegetation types, soils,
and landforms. It lies in a transition area between the northern boreal forest,
characteristic of much of Ontario, Canada, and the temperate deciduous forest found in
the eastern United States. Much of the terrain is rolling hills or rugged ridges
interspersed with swamps and numerous lakes and streams. The area is underlain with
bedrock that is part of the Canadian Shield. The Superior NF is home to a variety of
animals and plants ranging from common to rare. Together the flora, fauna, soil and
water of the SNF form a resilient ecosystem that provides a variety of habitats,
recreational opportunities and forest products.
Infestations of non-native plants increasingly threaten the integrity of the forest
ecosystem and native plant communities on the Superior National Forest. Approximately
1800 species of non-native plants have established in the wild in the United States
(Westbrooks 1998). Of particular concern are those non-native plants, termed non-native
invasive plants, which are successful at invading natural habitats. Invasive plants can
alter natural ecosystems in several ways, including replacing native species with exotic
species, causing changes in water or fire regimes, causing changes in soil characteristics,
adding a new or displacing an existing wildlife food source, and altering erosion and
sedimentation processes (Westbrooks 1998). NNIP pose social and economic threats as
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well. NNIP can impact recreational activities such as boating or fishing, and by some
estimates they cost the U.S. economy $35 billion annually (Pimentel et al. 2005).
The scope of the NNIP problem on the Superior National Forest is dramatically different
than that found on other National Forests in the U.S. For example, many western
National Forests have infestations totaling in the hundreds of thousands of acres, while
the Superior National Forest currently has less than 2000 acres known to be infested.
Northeast Minnesota and the Superior NF are fortunate because many of the NNIP that
are causing problems in the upper Midwest have not arrived or have not yet spread
extensively (Table 1.1) on the Forest. For example, common buckthorn is largely
restricted to rural communities like Aurora or Grand Marais or urban areas such as
Duluth; it has not moved extensively into the Arrowhead Region’s forests. Species like
purple loosestrife and leafy spurge have also not spread extensively yet, while others like
Canada thistle, spotted knapweed, and common tansy are beginning to rapidly expand
their reach. Three NNIP, orange hawkweed, yellow hawkweed, and oxeye daisy, have
already become ubiquitous and infest over 1800 acres altogether outside the BWCAW,
yet within the BWCAW they still only occupy less than 10 acres total; manual control of
these species in the BWCAW is still feasible. If only BWCAW occurrences of these last
three species are counted, the Superior NF has only 146 acres infested by NNIP, and we
therefore have an outstanding opportunity to prevent the ecological, social, and economic
impacts caused by NNIP that plague other parts of the U.S.
Table 1.1. Known abundance of non-native invasive plants on the Superior National Forest
Species Common Name
Species Scientific Name
Number of known sites
Total known infested acres
Canada thistle Cirsium arvense 409 13.6
Common buckthorn Rhamnus cathartica 1 0.25
Cypress spurge Euphorbia cyparissias 8 0.2
Goutweed Aegopodium podagraria 3 0.5
Leafy spurge Euphorbia esula 14 1.7
Orange hawkweed* Hieracium auranticum 67 1.3
Oxeye daisy* Leucanthemum vulgare 100 0.6
Plumeless thistle Carduus acanthoides 1 0.0003
Purple loosestrife Lythrum salicaria 14 4.6
Siberian peabush Caragana arborescens 1 0.25
Spotted knapweed Centaurea biebersteinii 291 68.3
St. Johnswort Hypericum perforatum 55 3.8
Tansy Tanacetum vulgare 578 49.5
Tatarian honeysuckle
Lonicera tatarica 1 0.005
Yellow hawkweeds*
Hieracium floribundum, H. piloselloides, H. pilosella
143 1.3
TOTALS 1686 145.9
* Acres and number of occurrences for orange hawkweed, oxeye daisy, and yellow hawkweed are only for occurrences found within the BWCAW (there are over 600 acres for each of these species outside of the BWCAW).
In the past five years, the Superior NF has begun to actively manage NNIP, working
within the framework established by the USDA Forest Service National Non-native
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Invasive Species (NNIS) Strategy (USDA Forest Service 2004d) and the Region 9 NNIS
Strategy (USDA Forest Service 2003a). Accomplishments on the Superior NF include:
Prevention
o Cleaning of road maintenance equipment
o Avoidance mitigations in timber sales
o Prevention signs at BWCAW entry points
Early detection and rapid response
o Early detections of plumeless thistle, meadow knapweed, and Japanese
knotweed
o Inventory for NNIP completed outside BWCAW
Control and management
o From 3-12 acres of treatments annually, via pulling, mowing, or
herbicides
Education and awareness
o Annual NNIP workshops for public, Forest staff, garden clubs, & partner
groups such as Friends of the BWCAW
o St. Louis County Fair display
Rehabilitation and restoration
o Development of native grass and wildflower seed mix from local seed
sources
The NNIP program on Superior National Forest is 5 years old and still growing. In order
to effectively combat NNIP, the Superior National Forest will continue working on all the
elements listed above. This Environmental Assessment focuses on one element, control
and management of non-native invasive plants.
1.2 Purpose and Need for Action
In order to maintain and improve aquatic and terrestrial wildlife habitat and to maintain
healthy, resilient native plant communities, there is a need to implement an integrated
approach to NNIP control that eradicates or controls existing infestations and provides for
a rapid response to new infestations. We propose to implement NNIP management
activities, including manual/mechanical treatments, herbicide treatments, and biological
controls, over a ten-year period across the Superior NF. Only manual treatments would
be implemented in the BWCAW.
The Forest Plan (USDA Forest Service 2004 [see D-VG-1, D-VG-3, D-WL-1, D-WL-6,
D-WL-9, O-WL-37, O-WL-38]) directs us to work to establish native vegetation
communities and aquatic and terrestrial wildlife habitats that are diverse, productive,
healthy, and resilient. Native plants should dominate all terrestrial and aquatic
ecosystems, with non-native plants forming at most a minor component. The Forest Plan
directs us to reduce the spread of terrestrial or aquatic non-native invasive species that
pose a risk to native ecosystems. In the BWCAW, the plan directs us to work toward the
removal of non-indigenous species. Specifically, the Plan’s objective is to use integrated
pest management to:
1. Eradicate any populations of new invaders
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2. Contain or eradicate populations of recent invaders that have not
become widespread yet
3. Limit the spread of widespread, established invaders.
Given the current distribution of NNIP on the Superior National Forest, the need for
action is to:
Rapidly respond to new infestations in the future
Use an integrated approach to control NNIP
The purpose is to:
Maintain and enhance the integrity of native plant communities that have been or
may be infested with NNIP on the Superior NF. This includes:
o Ensuring that aquatic and terrestrial wildlife habitats continue to be
diverse, healthy, productive, and resilient
o Protecting and restoring native plant communities and wildlife habitat
o Reducing the spread of NNIP
The objective of this project is to:
Contain and eradicate both existing populations of NNIP as well as new
infestations
1.3 Modified Proposed Action
To capitalize on the unique opportunity we have to prevent widespread degradation of
terrestrial and aquatic ecosystems on the Superior National Forest, the Forest Service
proposes to manage NNIP populations using an integrated combination of control
methods based on the species and site. These control methods would include ground-
based herbicide application, manual/mechanical control methods, and biological controls.
The sites proposed for treatment are shown on site maps in Appendix A and in a
corresponding table of sites in Appendix B. Table 1.2 summarizes the proposed
treatments.
Table 1.2 Treatment summary for modified proposed action Species Name
Total acres Acres manual/mechanical
Acres using herbicide
Herbicide Acres biocontrol
Canada thistle 13.6 0.2 13.4 Clopyralid aminopyralid, or glyphosate
Common buckthorn
0.25 .25 0.25 Triclopyr or glyphosate
Cypress spurge 0.2 .1 .1 Imazapic
Goutweed 0.5 0.5 0 None
Leafy spurge 1.7 0.02 1.68 Imazapic
Orange hawkweed
1.3 1.3 0 None
Oxeye daisy 0.6 0.6 0 None
Plumeless thistle
0.0003 0.0003 0.0003 Clopyralid aminopyralid, or glyphosate
Purple loosestrife
4.6 3.1 2.0 Glyphosate 2
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Siberian peabush
0.25 .25 .25 Clopyralid or glyphosate
Spotted knapweed
68.3 3.6 64.7 Clopyralid aminopyralid, or glyphosate
St. Johnswort 3.8 0 3.8 Metsulfuron methyl or glyphosate
Tansy 49.5 0.5 49 Metsulfuron methyl or glyphosate
Tatarian honeysuckle
0.005 0.005 .005 Triclopyr or glyphosate
Yellow hawkweeds
1.3 1.3 0 None
TOTALS (known infestations)
145.9 11.2 136 2
Note: Up to 73 additional acres (50% of the 145.9 known infested acres) could be treated over the next ten years, for a total of 219 acres
Experience has shown that the greatest success in NNIP management comes when an
integrated combination of appropriate treatment methods are used (Tu et al. 2001,
Czarapata 2005) such as is being proposed here. For some species, manual/mechanical
methods would be preferred over herbicide treatment for very small occurrences
(generally for less than 0.0002 acres or about the size of a kitchen table) for species with
shallow fibrous roots or tap roots, or at sites where manual/mechanical methods are
needed to avoid impacts to non-target vegetation (for example, TES plant site) or other
resources.
The sites listed in Appendix B would be targeted for treatment initially, but in order to
respond rapidly to new infestations detected in the next ten years, up to 50% more acres
than what is currently infested may be treated. In other words, there are approximately
146 infested acres currently known, and up to 73 additional acres may be treated as new
infestations are found.
Only manual methods would be used in BWCAW. In 2005, high priority sites with good
potential for NNIP (e.g. former resorts, heavily used campsites) were inventoried in the
east half of the BWCAW. Inventory efforts will continue in the west half of the
BWCAW in 2006. An analysis of priority species for treatment as well as possible
treatment methods would occur in the future after inventory efforts in the BWCAW are
more complete. In the meantime, only manual methods would be used. Herbicides
would be considered for any site outside the BWCAW if monitoring demonstrates that
manual/mechanical methods are ineffective.
These treatments would occur over the next ten years. A ten year treatment period is
needed because many of the species listed in Table 1.2 produce seed that remains viable
in the soil for 7-10 years or more (Czarapata 2005). Implementation would begin in
summer 2006. Of the 1686 known NNIP occurrences, most occur on roadsides (65%), at
recreation sites (12%), gravel pits (6%), or in the BWCAW (18%). Approximately 4% of
known NNIP acreage is in the BWCAW and 96% outside of the BWCAW.
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Additional details on the proposed action are described in: section 2.2.1 – treatment
methods, section 2.2.2 – how each NNIP species would be treated, section 2.2.3 – how
sites would be prioritized for treatment, and Appendix E – design features to minimize
negative environmental impacts.
1.4 Decisions To Be Made
The Responsible Official for this decision will be the Forest Supervisor. The decisions to
be made are:
Whether the project will have a significant impact and trigger the need to prepare
an EIS
Whether to select the proposed NNIP control actions as proposed or modified, or
as described in an alternative
What mitigation measures are needed, if any
What monitoring is required.
1.5 Scoping / Public Involvement
The purpose of scoping is to identify significant environmental issues deserving of
further study and to de-emphasize the non-significant issues (40 CFR 1500.4g).
General Public
A legal notice including a brief description of the proposed action was published in the
Duluth News Tribune on January 31, 2006. The legal notice provided an address, phone
number, and email address for those who wished to request a copy of the more detailed
comment package. A detailed package requesting comments was mailed to over 300
individuals, groups, and agencies who have expressed interest in these types of projects
by placing their name on a mailing list maintained in the Forest Supervisor’s Office in
Duluth. Over 150 additional letters were sent to adjacent landowners notifying them
about the project and about the availability of the comment package. The comment
package was also available online at http://www.fs.fed.us/r9/superior. People had 30
days after publication of the legal notice to submit comments.
Nineteen responses were received. A summary of the comments received and our
responses to them are in Appendix C.
Agencies
Comments on the comment package were requested from Voyageurs National Park,
United States Geological Survey, Quetico Provincial Park, Minnesota Pollution Control
Agency, the Minnesota Department of Natural Resources, Cook County, Lake County,
St. Louis County, and Carlton County.
Tribes
Comments on the comment package were requested from the 1854 Authority,
representing the Grand Portage and Bois Fort Bands of the Lake Superior Chippewa.
Comments were also requested directly from the Grand Portage, Fon du Lac, and Bois
Fort Bands. We received a response from the 1854 Authority.
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1.6 Issues
Issues are points of disagreement, debate, or dispute about the potential effects of a
proposed activity and are based on some anticipated outcome. Significant issues are
issues that are within the scope of the proposed action, are relevant to the decision to be
made, are not already decided by law, regulation, or policy, and are not conjectural or
unsupported by scientific evidence. The interdisciplinary team reviewed comments and
determined whether issues were significant or not.
There were few comments from the public that debated the effects of the proposed
activities (see Appendix C). None of the issues raised during scoping were considered
significant because they could all be addressed by slight modifications or clarification of
the proposed action or by making adjustments to the design features.
Although no significant issues were identified, Threatened and Endangered species and
Regional Forester’s Sensitive Species will be analyzed in a BA/BE and summarized in
Chapter 3. It is Forest Service policy to analyze effects to Regional Forester’s Sensitive
Species (FSM 2670.32).
Non-significant issues are analyzed briefly in Appendix C or the project record.
Appendix C contains a summary of the comments received during the public scoping as
well as responses to issues and concerns that will not be further analyzed.
1.7 Analysis of Significance Factors
The Council on Environmental Quality regulations (40 CFR Parts 1500-1508) define
“significance” in relation to environmental effects. The eleven elements of this definition
are critical to reducing paperwork through use of a finding of no significant impact when
an action will not have a significant effect on the human environment and is therefore
exempt from requirements to prepare an environmental impact statement. The following
eleven significance factors are analyzed for the NNIP Management Project alternatives.
Context. The significance of an action must be analyzed in several contexts such
as society as a whole (human, national), the affected region, the affected interests,
and the locality. Significance varies with the setting...in the case of a site-specific
action, significance would usually depend upon the effects in the locale rather
than in the world as a whole. Both short and long term effects are relevant.
Intensity - the severity of impact. The following should be considerd in
evaluating intensity:
o Impacts may be both beneficial and adverse. A significant effect may
exist even if, on balance, effects are believed to be beneficial.
o The degree of effects on public health or safety.
o Unique characteristics of the geographic area such as proximity to historic
or cultural resources, park lands, prime farmlands, wetlands, wild and
scenic rivers, or ecologically critical areas.
o The degree of controversy over environmental effects.
o The degree to which the possible effects on the human environment are
highly uncertain or involve unique or unknown risks.
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o The degree to which the action may establish a precedent for future
actions with significant effects or represents a decision in principle about a
future consideration.
o Whether the action is related to other actions with individually
insignificant but cumulatively significant impacts. Significance exists if it
is reasonable to anticipate a cumulatively significant impact on the
environment. Significance cannot be avoided by terming an action
temporary or by breaking it down into small component parts.
o The degree to which the action may adversely affect districts, sites,
highways, structures, or objects listed in or eligible for listing in the
National Register of Historic Places or may cause loss or destruction of
significant scientific, cultural, or historical resources.
o The degree to which the action may adversely affect an endangered or
threatened species or its habitat that has been determined to be critical
under the Endangered Species Act of 1973 (ESA).
o Whether the action threatens a violation of Federal, State, or local law or
requirements imposed for the protection of the environment.
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2.0 Alternatives
2.1 Introduction
This chapter describes:
how the range of alternatives was developed,
alternatives analyzed in detail, including monitoring,
alternatives considered but not analyzed in detail, and
summary of effects.
In accordance with the National Environmental Policy Act, a No Action Alternative
(Alternative 1) is included in this analysis. This alternative is intended to serve as a
control showing the environmental and social effects of taking no action, as well as to
provide the deciding officer the option of taking no action at this time.
If there are unresolved issues about effects, alternatives are developed. Alternatives are
used to provide the responsible official with choices for avoiding or minimizing effects.
The purpose and need for action sets the range of alternatives since all alternatives must
in some way meet the purpose and need.
2.2 Development of a Range of Alternatives
The implementation guidelines (40 CFR 1500) developed by the Council on
Environmental Quality require that an environmental review must “...rigorously explore
and objectively evaluate all reasonable alternatives.’ The courts have established that this
direction does not mean that every conceivable alternative must be considered, but that
selection and discussion of alternatives must permit a reasoned choice and foster
informed public participation and decision-making.
To meet the purpose and need for the NNIP Management project, the interdisciplinary
team developed a proposed action, which was included in the Comment Package. Public
comments received during the 30 day comment period are used to identify significant
issues, which are used to develop alternatives. However, for the NNIP Management
project, no significant issues arose during scoping, and therefore only two alternatives
will be analyzed, the No Action and Modified Proposed Action.
When developing alternatives, the interdisciplinary team also identified specific design
features to minimize impacts on resources from the management activities proposed in
the action alternatives. Design features are derived from Forest Service policies, Forest
Plan Standards and Guidelines, Minnesota Forest Resource Council Forest Management
Guidelines, and site-specific analysis. Design features are described in detail in
Appendix E.
2.3 Alternatives Considered But Not Analyzed In Detail
Alternative 3. Proposed Action of January 2006.
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One alternative, the Proposed Action of January 2006, was considered but not in detail.
This alternative does not meet the purpose and need as completely as the alternatives
analyzed in detail for the following reasons:
Aminopyralid was identified during the comment period as an additional
herbicide to use for controlling spotted knapweed, Siberian peabush, and exotic
thistles. It is related to clopyralid and has similar effects as clopyralid, except that
aminopyralid use rates are much lower and therefore less chemical winds up in
the environment. Aminopyralid was selected because it may further reduce the
already low risk of impacts associated with clopyralid.
Herbicide application was eliminated as a secondary treatment approach for 3
purple loosestrife sites that are located on lakes or rivers (as opposed to in
roadside ditches) in response to comments from the 1854 Authority. These 3
purple loosestrife sites are small, and to ease concerns over herbicide use on lakes
and rivers, these sites will be managed with hand pulling alone, and no herbicide
would be applied to NNIP in lakes, rivers, or adjacent wetlands. Because these
sites are small, it is very likely that the NNIP control objectives would be met by
handpulling alone.
2.4 Alternatives Considered in Detail
2.4.1 Alternative 1 – No Action
The No Action alternative represents the current condition and serves as a baseline to
compare the proposed action. With No Action, we would not implement an integrated
approach of manual/mechanical, herbicide, and biological control treatments to control
NNIP on the Superior National Forest. Limited NNIP treatments may still take place
through other decisions. However, many weed sites would continue to grow in size and
provide a seed source for other infestations.
2.4.2 Alternative 2 – Modified Proposed Action
Alternative 2 is a proposal to manage NNIP populations using an integrated combination
of control methods based on the species and site. Experience has shown that the greatest
success in NNIP management comes when an integrated combination of appropriate
treatment methods are used (Tu et al. 2001, Czarapata 2005) such as is being proposed
here. These control methods would include ground-based herbicide application,
manual/mechanical control methods, and biological controls. Treatments would occur
annually across the Superior National Forest over the next decade. Table 1.2 summarizes
the proposed treatments. The sites proposed for treatment are shown on site maps in
Appendix A and in a corresponding table of sites in Appendix B.
Management activities would occur over the next ten years. A ten year treatment period
is needed because many of the species listed in Table 1.2 produce seed that remains
viable in the soil for 7-10 years or more (Czarapata 2005). Implementation would begin
in June 2006.
The sites listed in Appendix B would be targeted for treatment initially, but in order to
respond rapidly to new infestations detected in the next ten years, up to 50% more acres
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than what is currently infested may be treated. In other words, there are approximately
146 infested acres currently known, and up to 73 additional acres may be treated as new
infestations are found. Most known infestations are along roads (65%), at recreation sites
(12%), or gravel pits (6%); it is likely that future infestation sites would look very similar
to these. Prior to treatment, information about new infestations would be reviewed by
appropriate resource specialists to determine whether surveys for sensitive resources are
needed. When recommended by resource specialists, pre-treatment site specific surveys
for sensitive resources would be conducted.
2.4.2.1 Treatment Methods
Manual and Mechanical Control Methods
Manual methods like pulling would generally be used with small infestations (generally
less than 0.0002 acres or about the size of a kitchen table) of species with shallow tap
roots. For many rhizomatous species, manual methods are ineffective for eradication
because root fragments remain in the soil after pulling and allow the plants to resprout.
Furthermore, pulling causes disturbance of the upper layers of soil which encourages
sprouting of weeds seeds from the soil seed bank, and pulling usually involves trampling
of any desirable native vegetation nearby. Repeated annual visits to pulling sites would
be needed for long term control.
Manual/mechanical methods would also be used at sites where needed to avoid effects to
non-target vegetation (e.g. TES plants) or other resource. Manual methods would be
used in the BWCAW. Table 2.1 describes the manual/mechanical methods proposed for
use.
Table 2.1 Proposed Manual/Mechanical Treatment Methods
Method Description of action Pull Hand-pull entire plant including roots – usually herbaceous plants or shrubs less
than 5mm in diameter. Leave plant on site or bag and remove if it has mature flowers or fruit. Used for individuals or small patches of plants. Can be effective for tap-rooted species but not rhizomatous species.
Cut Clip with lopping shears; cut with saw, brush cutter, axe, weed whip, or mower; girdle the bark. This action can be used alone or followed by cut stump application of herbicide. Cutting alone does not kill plant but can prevent seed set.
Dig Excavate plant with narrow spade, shovel, weed wrench, or tractor with disking blade. Plants are usually left on site. Used for individuals and small patches of plants. Can be effective for tap-rooted species but not rhizomatous species.
Scorch (flame)
Use the flame of a propane weed torch to scorch or wilt green leaves. This is done either very early or late in the growing season when exotics are green and native perennials are mostly below ground. It does not start a ground fire. Scorching will kill one year’s growth of annual and biennial weeds. Especially useful for sprouts of buckthorn.
NNIP in the BWCAW would only be treated by pulling, cutting, or digging plants
manually. No other types of treatments are proposed in the BWCAW, primarily because
NNIP inventory efforts have not been completed in the BWCAW. In 2005, high priority
sites with good potential for NNIP (e.g. former resorts, heavily used campsites) were
inventoried in the east half of the BWCAW. Inventory efforts will continue in the west
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half of the BWCAW in 2006. An analysis of priority species for treatment as well as
possible treatment methods would occur in the future after inventory efforts in the
BWCAW are more complete. In the meantime, only manual methods would be used.
After hand pulling, noxious weed roots and seeds will be disposed of in such a way as to
prevent them from starting a new infestation elsewhere. Some combination of the
following methods would be used; specifically which are used would depend on the
situation.
Placing in a sturdy plastic bag and securely closing bag
Burning, either on site or after being safely transported in a bag
Disposal in a landfill
Placing plants on shrubs or branches, so that they don’t contact ground and will
dry out without a chance to resprout
Such factors as: ripeness or unripeness of the seeds, seed dispersal mechanism
(windborne vs. waterborne), whether the weed is a wetland or upland species, whether
vegetative fragments can start new plants, and ease of transporting the plants would be
considered when making decisions about NNIP disposal.
To help prevent re-infestation of sites that have been treated, areas where
manual/mechanical treatments have taken place may be seeded with native or desirable
non-native grasses or forbs. Establishing competing vegetation may help prevent or slow
down the reinfestation of sites by NNIP.
Herbicide Treatment
Herbicides would be used for large brushy species or for herbaceous species for which
manual/mechanical controls are ineffective. Herbicides were selected based on their
effectiveness and low toxicity. All herbicides proposed for use are approved by the
Environmental Protection Agency and available without special permit (anyone can buy
them at a garden supply store). Table 2.2 summarizes the chemicals proposed for use in
this alternative and their targeted use.
All herbicides would be used according to manufacturer label direction (e.g., regarding
rates, concentrations, and application methods). All herbicides would be applied using a
ground-based method; no aerial application would be used. Spot application of herbicide
would occur at nearly all sites. Spot application directs herbicides to target plants with
minimal exposure to humans, desirable vegetation, or other non-target organisms. By
using spot application rather than broadcast application, herbicide drift would be
minimized. Techniques that could be used for spot application include spraying foliage
using hand held wands mounted to backpack tanks or pick-up or ATV mounted tanks, or
cut stump treatments (spraying or wiping) in which a shrub is cut and herbicide is applied
to the stump. Broadcast application would be considered for the two largest sites, the old
Isabella ELC and Sawbill Landing. For broadcast application, an arm with multiple
nozzles mounted to it is attached to a vehicle which drives back and forth across a site.
The timing of treatments varies by species. Generally there would be one herbicide
application per site per year with follow-up monitoring and possible treatment in
subsequent years.
15
To help prevent re-infestation of sites that have been treated, areas where herbicide
treatments have taken place may be seeded with native or desirable non-native grasses or
forbs. Establishing competing vegetation may help prevent or slow down the
reinfestation of sites by NNIP.
Table 2.2 Proposed Herbicide Treatment Methods
Common chemical name
Examples of trade names
Targeted Use Weeds targeted
Triclopyr
Garlon3A®; Brush-
B-Gone®, Garlon4
®,
Vine-X®
Stump and/or basal bark treatment, foliar spot spray; broadleaf-selective
Buckthorn, Tatarian honeysuckle
Glyphosate
Roundup Pro®;
Roundup® Original,
Accord®,
many others
Stump treatment, foliar spray; non-selective
Tatarian honeysuckle, Canada thistle, Buckthorn, Plumeless thistle, Spotted knapweed, St. Johnswort, Tansy, Siberian peabush
Glyphosate for near water
Rodeo® , Glyfos
Aquatic®,
Aquamaster®,
many others
Foliar treatment, weeds near open water, non-selective
Purple loosestrife or any species listed for glyphosate (above) that occurs near open water
Imazapic Plateau
®; Plateau
Eco-Pak®;
Foliar treatment, non-selective
Leafy spurge, Cypress spurge
Clopyralid Transline®
Foliar spray; broadleaf selective- especially composites and legumes
Canada thistle, Plumeless thistle, Spotted knapweed, Siberian peabush
Aminopyralid Milestone®
Foliar spray; broadleaf selective- especially composites and legumes
Canada thistle, Plumeless thistle, Spotted knapweed
Metsulfuron methyl
Escort®,
Metsulfuron methyl DF
®
Foliar spray; broadleaf selective
Tansy, St. Johnswort
Specific herbicides that could be used as appropriate are the following:
Glyphosate (N-[phosphonomethyl] glycine) is a non-selective, broad spectrum,
systemic herbicide that is used to control many annual and perennial plants.
Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, but
the surfactants in some formulations are highly toxic to aquatic organisms (Tu et
al. 2001). Therefore, only formulations labeled for aquatic use would be used
near water.
Triclopyr ([{3,5,6-trichloro-2-pyridinyl}oxy] acetic acid) is a selective herbicide
that controls broadleaf herbaceous and woody plants, but has little impact on
grasses. It is particularly effective at controlling woody species with cut-stump or
basal bark treatments. Triclopyr is effective against buckthorn (MN DNR 2005a),
Siberian peabush (MN DNR 2005b), and tatarian honeysuckle (MN DNR 2005c).
16
Clopyralid (3,6-dichloro-2-pyridinecarboxylic acid) is a selective herbicide that
controls many annual and perennial broadleaf weeds. It is particularly effective
against members of the sunflower, nightshade, pea, violet, and knotweed families
(Tu et al. 2001). Clopyralid may be used against spotted knapweed, thistles, and
St. Johnswort (Czarapata 2005, Nuzzo 1997). Clopyralid is a pre-emergent and
post-emergent herbicide, and so can be effective not only on the plants to which it
is applied, but can also prevent germination from seeds in the seed bank.
Aminopyralid (4-amino-3,6-dichloro-2-pyridinecarboxylic acid) is a selective
herbicide that controls many annual and perennial broadleaf weeds. It is related
to clopyralid and is effective against members of the sunflower family, among
others (Dow AgroSciences 2005). It was released in October 2005.
Imazapic ((±)-2-[4,5-dihydro-4-methyl-4-(1-methylethlyl)-5-oxo-1H-imidazol-2-
yl]-5-methyl-3-pyridinecarboxylic acid) is a selective herbicide for both the pre-
and post-emergent control of some annual and perennial grasses and some
broadleaf weeds (Tu et al. 2001). Imazapic is one of the more effective herbicides
used against leafy spurge (Czarapata 2005) and cypress spurge.
Metsulfuron methyl (methyl 2-[[[[(4-methoxy-6-methyl-1,3,5-triazin-2yl)-
amino]carbonyl]-amino]-sulfonyl]benzoate) is a selective herbicide that is
effective for brush and some woody plants as well as annual and perennial
broadleaf weeds and some grasses (Information Ventures 1995). Metsulfuron
methyl has been used with good success against common tansy on the Superior
National Forest (Greenlee pers. obs.)
For most NNIP infestations outside the BWCAW where manual/mechanical control
methods are initially tried, if monitoring shows that such methods are ineffective,
herbicides would then be tried. The only exception to this is for purple loosestrife that
occurs in lakes and rivers; these infestations would only be treated with
manual/mechanical methods.
Biological Control Methods
When a plant from one continent is moved to another, it usually leaves behind the natural
enemies that help prevent population explosions where it normally grows. The purpose
of biological control is to reunite invasive plant species with their natural enemies. This
involves releasing specific non-native insects that feed on specific target plant species.
The United States Department of Agriculture, Animal and Plant Health Inspection
Service (APHIS) has permitted the insects listed in Table 2.3 for release in the United
States, under the Plant Protection Act of 2000 (7 USC 7701 et seq.). Before permitting
the release of non-native biological control agents, APHIS thoroughly evaluates the
potential risk of adverse impacts to non-target plants and animals (USDA APHIS 2005,
Driesche et al. 2002).
The first purple loosestrife biological control insects were released in Minnesota in 1992
by the MN DNR. To date they have been released at over 800 sites across Minnesota,
including sites in St. Louis and Lake Counties, and are well established at many purple
loosestrife infestations in Minnesota (MN DNR 2006). Our proposed action would be to
17
move them from an established location to the purple loosestrife infestation at Clear
Lake.
Table 2.3. Biological Control Insects Proposed Biocontrol insect Scientific name Target plant # of potential
sites Black-margined loosestrife beetle
Galerucella calmariensis Purple loosestrife leaf eating beetle
1
Golden loosestrife beetle Galerucella pusilla Purple loosestrife leaf eating beetle
1(same as above)
Loosestrife root weevil Hylobius transversovittatus
Purple loosestrife root boring weevil
1(same as above)
Loosestrife flower weevil Nanophyes marmoratus Purple loosestrife flower feeding weevil
1(same as above)
We are considering the use of biological controls at Clear Lake rather than other methods
for the following reasons. The Clear Lake purple loosestrife site is the largest known
such site on the Superior National Forest at approximately 2 acres. Herbicide control
with glyphosate was considered but rejected because glyphosate is non-selective, and
with 2 acres to spray, many non-target native plant species would be affected. The site is
too large to effectively control with pulling. The next lake downstream, Dark Lake, has a
0.5 acre infestation, and no purple loosestrife has been found in surveys of Dark River
downstream from Dark Lake. By controlling purple loosestrife in Dark Lake with hand-
pulling, and containing the purple loosestrife in Clear Lake with biological controls, we
hope to prevent the Dark River downstream from becoming infested.
Orange and yellow hawkweed and oxeye daisy, which each infest over 600 acres of
Superior NF lands outside the BWCAW, are good candidates for biological control
measures. Efforts are underway to develop biological controls for the exotic hawkweeds
(CABI 2005). However, at present none exist for these three species, so none is
proposed.
Most of the other NNIP sites are too small to support a population of biocontrol insects.
Biological control insects can be effective on plant infestations that have a sufficient
supply of the target plant and that meet other needs of the biocontrol insect such as
moisture, windbreaks, and hiding places (Tu et al. 2001). None of these insects will
completely eliminate the target plants (Tu et al. 2001). However, monitoring of purple
loosestrife biological controls by the MN DNR has shown that biological controls can
reduce the abundance of this plant, making it a small component of wetlands rather than a
large one (MN DNR 2006).
2.4.2.2 Treatment Summary by Species
Detailed descriptions of treatment protocols are given below for each species and
summarized in Table 1.2.
Common Buckthorn MANUAL/MECHANICAL CONTROL: Common buckthorn has a shallow root system,
and seedlings and small plants are easily pulled (GLIFWC 2005, Czarapata 2005). For
18
small infestations (generally less than 0.0002 acres or about the size of a kitchen table),
seedlings and small plants would be pulled. Large shrubs resprout vigorously after
cutting alone (GLIFWC 2005). Therefore, large plants would be cut and herbicide would
be applied to the stump. For larger infestations, a combination of cutting and herbicide
treatment would be used. Alternatively, in large infestations, small buckthorn plants
could be burned with a weed torch.
CHEMICAL CONTROL: Medium and large shrubs would be cut and the stump treated
with glyphosate or triclopyr. Herbicide would be applied with a sponge-type applicator
to avoid contacting non-target plants. An alternative method is to paint triclopyr on the
basal bark and leave the shrub intact. Thick patches of young seedlings may be spot-
sprayed with triclopyr or glyphosate. Herbicide treatment can be applied almost any time
of the year. The optimal time would be September through November.
Tatarian Honeysuckle MANUAL/MECHANICAL CONTROL: Tatarian honeysuckle has a shallow root
system, and seedlings and small plants are easily pulled (GLIFWC 2005, Czarapata
2005). For small infestations (generally less than 0.0002 acres or about the size of a
kitchen table), seedlings and small plants would be pulled. Large shrubs resprout
vigorously after cutting alone (GLIFWC 2005). Therefore, large plants would be cut and
herbicide would be applied to the stump. For larger infestations, a combination of cutting
and herbicide treatment would be used. Alternatively, in large infestations, small
honeysuckle plants could be burned with a weed torch
CHEMICAL CONTROL: Medium and large shrubs would be cut and the stump treated
with glyphosate or triclopyr. Herbicide will be applied with a sponge-type applicator to
avoid contacting non-target plants. An alternative method is to paint triclopyr on the
basal bark and leave the shrub intact. Thick patches of young seedlings may be spot-
sprayed with triclopyr or glyphosate. Herbicide treatment can be applied almost any time
of the year. The optimal time would be September through November.
Siberian Pea shrub
MANUAL/MECHANICAL CONTROL: For small infestations (generally less than
0.0002 acres or about the size of a kitchen table), small plants would be pulled, but
medium and large plants have an extensive root system. Large shrubs resprout
vigorously after cutting alone (Saskatchewan Purple Loosestrife and Invasive Species
Project 2005). Therefore, large plants would be cut and herbicide would be applied to the
stump. For larger infestations, a combination of cutting and herbicide treatment would be
used.
CHEMICAL CONTROL: Medium and large shrubs would be cut and the stump treated
with glyphosate or clopyralid. Herbicide will be applied with a sponge-type applicator to
avoid contacting non-target plants. An alternative method is to paint clopyralid on the
basal bark and leave the shrub intact. Thick patches of young seedlings may be spot-
sprayed with clopyralid or glyphosate. Plants can be treated any time of year
(Saskatchewan Purple Loosestrife and Invasive Species Project 2005).
19
Spotted knapweed MANUAL/MECHANICAL: Populations in the BWCAW would be treated by pulling
prior to seed set. This will require repeat visits for several years to deplete the seed bank
and pull plants that resprout. Manual control actions will be repeated, if possible, two or
more times during the growing season. Outside the BWCAW, very small populations
(generally less than 0.0002 acres or about the size of a kitchen table) would be pulled.
Spotted knapweed has a woody taproot which, if pulled, kills the plant (Duncan et al.
2001).
CHEMICAL CONTROL: Outside the BWCAW, spotted knapweed populations larger
than 0.0002 acres would be treated with clopyralid or aminopyralid, broadleaf weed
killers. Alternatively, if impacts to adjacent non-target vegetation, such as in a gravel pit,
are not a concern, glyphosate may be used. At sites less than 150 feet from water, with a
high water table, or with rapid permeability throughout the soil profile, glyphosate would
be used. Knapweed can be successfully treated with herbicide in the rosette stage
through the bolting stage, but is less susceptible to herbicides during the flowering stage.
Canada thistle MANUAL/MECHANICAL CONTROL: Populations in the BWCAW would be treated
by pulling, cutting, or digging up the plant prior to seed set. Manual control actions will
be repeated, if possible, two or more times during the growing season. These manual
methods will require repeat visits for several years to deplete the seed bank. This thistle
has creeping rhizomes that break easily when pulled, and remaining root fragments can
sprout and make new plants, thus making it difficult to kill Canada thistle by pulling
(Czarapata 2005, Lym and Zollinger 1995, Nuzzo 1997). Therefore, outside the
BWCAW, populations of Canada thistle would be treated with herbicide.
CHEMICAL CONTROL: Outside the BWCAW, Canada thistle populations would be
treated with clopyralid or aminopyralid, broadleaf weed killers. Alternatively, if impacts
to adjacent non-target vegetation, such as in a gravel pit, are not a concern, glyphosate
may be used. At sites less than 150 feet from water, with a high water table, or with rapid
permeability throughout the soil profile, glyphosate would be used. Thistles can be
successfully treated with herbicide in the rosette stage through the bolting stage, but are
less susceptible to herbicides during the flowering stage.
Plumeless thistle MANUAL/MECHANICAL CONTROL: The one known population is outside the
BWCAW and would be hand pulled or dug with a shovel prior to seed set. This species
has a single taproot so plants can be successfully killed by pulling/digging (Czarapata
2005). If this method proves unsuccessful, herbicide would be used. Manual control
actions will be repeated, if possible, two or more times during the growing season. These
manual methods will require repeat visits for several years to deplete the seed bank.
CHEMICAL CONTROL: The plumeless thistle population would be treated with
clopyralid or aminopyralid, broadleaf weed killers, if manual eradication is not
20
successful. If new sites are found that are less than 150 feet from water, have a high
water table, or have rapid permeability throughout the soil profile, glyphosate would be
used. Thistles can be successfully treated with herbicide in the rosette stage through the
bolting stage, but are less susceptible to herbicides during the flowering stage.
Leafy spurge/Cypress spurge
MANUAL/MECHANICAL CONTROL: Populations in the BWCAW would be treated
by pulling prior to seed set. These control actions would be repeated, if possible, more
than once during the growing season. Hand pulling will require repeat visits to infested
sites for the foreseeable future. Leafy spurge and cypress spurge have an extensive
network of creeping rhizomes that break easily when pulled, and remaining root
fragments can sprout and make new plants, thus making it very difficult to kill these
plants by pulling (Czarapata 2005, Biesboer 1996). Therefore, outside the BWCAW,
populations of leafy spurge and cypress spurge would be treated with herbicide.
CHEMICAL CONTROL: Outside the BWCAW, leafy spurge or cypress spurge
populations would be treated with imazapic, a broadleaf weed killer that is particularly
effective on plants in the spurge family.
Purple loosestrife
MANUAL/MECHANICAL CONTROL: For all the purple loosestrife sites except the
Clear Lake infestation, plants will be carefully pulled or dug out with a shovel prior to
seed set, taking care to leave as few roots as possible. It may take 7-10 annual visits to
eliminate a site because seeds in the soil seed bank can sprout when the ground is
disturbed, and plants that get partially pulled resprout. For purple loosestrife infestations
that are not on lakes or rivers, if monitoring proves manual/mechanical methods to be
ineffective at eradicating the population, we will spot spray glyphosate on individual
plants, if the population is outside the BWCAW (see below).
BIOLOGICAL CONTROL: This method will be used at the largest purple loosestrife
infestation which is on Clear Lake on the Laurentian Ranger District, where the plant
occurs in patches along the majority of the lakeshore.
CHEMICAL CONTROL: For purple loosestrife infestations outside the BWCAW and
that are not on lakes and rivers, if manual/mechanical methods prove unsuccessful at
eradicating the population, the plants will be spot-treated with an aquatic labeled
formulation of glyphosate. Plants will be individually sprayed. Application need only
cover 25% -50% of the foliage of each plant (Bender and Rendall 1987). Where feasible,
we will apply glyphosate to cut stems with a wiping technique. This technique is
designed to minimize the impact to adjacent, non-target plants. Plants can be treated
anytime during the growing season but before they set seed in August. The ideal time
would be in July when root reserves are low. We would make a single chemical
treatment per year per site. This will be followed by monitoring in subsequent years and
treatment of missed plants and re-sprouts with hand-pulling or using herbicide.
Common tansy
21
MANUAL/MECHANICAL: Populations in the BWCAW would be treated by pulling,
cutting, or digging up the plant prior to seed set. Manual control actions will be repeated,
if possible, two or more times during the growing season. These manual methods will
require repeat visits for several years to deplete the seed bank and pull plants that
resprout.
CHEMICAL CONTROL: Common tansy has a large rootstock that is difficult to
eradicate by pulling or digging (Greenlee, pers. obs.). Therefore, outside the BWCAW,
common tansy populations would be treated with metsulfuron methyl, a broadleaf weed
killer that is particularly effective on tansy. Alternatively, if impacts to adjacent non-
target vegetation, such as in a gravel pit, are not a concern, glyphosate may be used. At
sites less than 150 feet from water, with a high water table, or with rapid permeability
throughout the soil profile, glyphosate would be used.
St. Johnswort
MANUAL/MECHANICAL: No St. Johnswort would be treated by manual/mechanical
methods. There are no known populations in the BWCAW.
CHEMICAL CONTROL: Manual/mechanical methods have generally been ineffective
at controlling this plant (Czarapata 2005). Therefore, outside the BWCAW, St.
Johnswort populations would be treated with metsulfuron methyl, a broadleaf weed
killer. Alternatively, if impacts to adjacent non-target vegetation, such as in a gravel pit,
are not a concern, glyphosate may be used. At sites less than 150 feet from water, with a
high water table, or with rapid permeability throughout the soil profile, glyphosate would
be used.
Yellow and Orange Hawkweeds, Oxeye daisy, Goutweed (also called snow on the
mountain)
MANUAL/MECHANICAL: BWCAW – Populations in the BWCAW would be treated
by pulling, cutting, or digging up the plant prior to seed set. Manual control actions
would be repeated, if possible, two or more times during the growing season. These
manual methods would require repeat visits for several years to deplete the seed bank and
pull plants that resprout. Only non-native hawkweeds would be treated.
CHEMICAL CONTROL – Yellow and orange hawkweeds and oxeye daisy are nearly
ubiquitous along roadsides outside the BWCAW, and chemical control at this scale is not
practical. Since chemical control of these species is not practical, and no biological
controls exist, no treatments will be applied to non-native hawkweeds or oxeye daisy
outside the BWCAW. No goutweed is known on SNF lands outside the BWCAW.
2.4.2.3 Prioritization of Sites for Treatment
Some NNIP sites are a higher priority for treatment than others. The species, location,
and infestation size largely determine whether a site is a critical, high, or moderate
priority for treatment. See Appendix C for a complete description of treatment priorities.
22
2.5 Monitoring and Evaluation
Monitoring assesses if the project was implemented as designed and if the design features
are effective in protecting natural resources. The Forest Service would monitor treated
areas to ensure that control actions and site protection measures meet objectives (Table
2.4). If control actions are not meeting objectives, alternative control actions would be
implemented as described in the proposed action.
Table 2.4. Monitoring of treatments
NNIP Treatments
Objective Eradicate or contain NNIP at treatment sites
Methods Visual inspection of representative sample of treatment sites, photomonitoring
Frequency 1-3 weeks post treatment, 1, 2, and 3 years post treatment
Responsibility Plant Ecologist, Biological Science Technician, District Biologist
Measure of
Success
Year 1: 80% decrease of NNIP cover at site; Year 3: 95% decrease of NNIP
cover; Year 10: 100% decrease of NNIP cover.
Design Features
Objective Ensure that the design features and provisions in contracts are implemented.
Methods COR pre-work with contractors to go over design features and contract
provisions; COR/Inspector visits to representative sample of treatment sites
during treatment.
Frequency Daily or weekly during time period when treatments are being implemented
Responsibility Plant Ecologist, Biological Science Technician (plants), District Biologist
Measure of
Success
Compliance with design features (e.g. amount of non-target plant damage at
site, amount of rutting)
Revegetation
Objective Native and desirable non-native plants occupy site and help prevent
reinfestation
Methods Visual inspection of treatment sites, photomonitoring
Frequency Between year one and year three following treatment
Responsibility Plant Ecologist, Biological Science Technician, District Biologist, Soil Scientist
Measure of
Success
30%-70% canopy cover of target species by year 3 post treatment; 0% cover of
NNIP
2.6 Comparison of the Alternatives
This section summarizes the major conclusions of Chapter 3 and presents them in a
comparative format. Table 2.5 summarizes the proposed activities.
Table 2.5 Comparison of proposed activities by alternative.
Activity Alternative 1 Alternative 2
23
Acres of manual/mechanical
treatment
0 16.8
Acres of herbicide treatment 0 204
Acres of biocontrol 0 3
Note: Table displays maximum possible treatment acres by activity. As noted in description of modified proposed
action, up to 50% more acres may be treated than what is currently known; this figure is displayed above. The total is
greater than 219 acres because some infestations are proposed to be treated by more than one method.
24
3.0 Affected Environment and Environmental Consequences This chapter presents the aspects of the environment that could be affected by treatment
activities. The “Affected Environment” section describes the existing condition for each
resource that could be affected by the proposed action. The “Environmental Effects”
section describes the direct, indirect, and cumulative effects of the alternatives.
Resources for which there was no debate about environmental effects are not addressed
here.
3.1 Description of Project Area
The project area encompasses NNIP infestations found across the entire Superior
National Forest. In addition to these site specific locations, up to 73 additional acres of
infestations could be treated as they are found over the next 10 years. These additional
sites could occur anywhere on the Superior, and they are likely to be in similar types of
settings as the currently known sites. Of the 1686 known NNIP occurrences, most occur
on roadsides (65%), at recreation sites (12%), gravel pits (6%), or in the BWCAW (18%).
Approximately 4% of known NNIP acreage is in the BWCAW and 96% outside of the
BWCAW. Additional details of the physical and social characteristics of this forest-wide
project area can be found in the FEIS for the Forest Plan (USDA Forest Service 2004e).
3.2 Threatened and Endangered Species
This section summarizes key findings and determinations of the NNIP Biological
Assessment (BA – see planning record for complete BA).
3.2.1 Analysis Area
The analysis area is the same for each of the Superior National Forest’s three Threatened
or Endangered species: grey wolf, Canada lynx, or bald eagle. The area covered by the
analysis of direct and indirect effects includes all lands administered by the Superior
National Forest. The area covered by the cumulative effects analysis includes lands of all
ownerships within Superior National Forest boundaries. The NNIP Management Project
BA describes the time scales, rationale, and analysis areas in more detail.
3.2.2 Affected Environment
No site specific surveys were conducted for grey wolf, Canada lynx, or bald eagle.
However, potential suitable habitat exists in the project area and a Biological Assessment
has evaluated the potential risks of the project to these threatened species. The BA can be
found in the planning record.
3.2.3 Environmental Consequences
3.2.3.1 Alternative 1 – No Action
Direct and Indirect Effects
Under this alternative, no NNIP treatments would take place. Therefore, there would be
no consequences to grey wolf, Canada lynx, or bald eagle from any treatment activities.
25
NNIP would continue to spread under Alternative 1 and impact native plant communities.
However, this continued NNIP spread would not impact grey wolf, Canada lynx, or bald
eagle. Continued NNIP spread would not impact habitat for any wolf, lynx, or bald eagle
prey, nor would it cause any changes in prey availability or distribution for these species.
The potential increase in NNIP abundance within the time frame of the analysis would
not reach such a level as to impact habitat for prey species. NNIP abundance is currently
quite limited relative to the areas over which these wide-ranging predators forage.
Continued NNIP spread would also not affect Canada lynx denning or foraging habitat.
The potential increase in NNIP abundance within the time frame of the analysis would
not reach such a level as to impact lynx denning or foraging habitat, particularly since
most of the NNIP infestations currently occur along roads, at recreation sites, or in gravel
pits.
Lastly, continued NNIP spread would not impact bald eagle nesting, perching, or roosting
sites. The potential increase in NNIP abundance within the time frame of the analysis
would not reach such a level as to begin impacting trees used by bald eagles.
3.2.3.2 Alternative 2 – Modified Proposed Action
Direct and Indirect Effects
Analysis conducted in the Biological Assessment for threatened and endangered species
concludes that there would be no effect to the Canada lynx, gray wolf or bald eagle; the
BA is contained in the project file. No trees would be cut and no new roads would be
constructed under Alternative 2, and thus there would be no changes to habitat for
wolves, Canada lynx, or bald eagles, or for animals that these species prey upon.
Alternative 2 would cause no changes in prey availability for wolves, Canada lynx, or
bald eagle.
Wolf, Canada lynx, and bald eagle exposure to herbicides, either directly or indirectly,
would be negligible, and thus there would be no effects of herbicide use on these species.
Direct exposure to herbicide spray streams of individuals of any of these species or their
prey is very unlikely. Indirect dietary exposure to the proposed herbicides through prey
that had been exposed is very unlikely because none of the proposed herbicides
bioaccumulate, and all proposed herbicides would be excreted rapidly from prey animals’
bodies. Grey wolf, lynx, and bald eagle all forage over a wide area relative to the average
area of any given treatment site, which is 0.09 acres.
Disturbance to wolves or Canada lynx caused by manual/mechanical treatments or
herbicide treatments would have no effect on them because it would be very temporary
and dispersed over a wide area and would occur primarily along roads, at gravel pits, or
at recreation sites. Alternative 2 would cause no disturbance to nesting eagles because
treatments near active eagle nests would not be conducted in the nesting season.
Alternative 2 would cause no effects to abundance of woody debris and no trees would be
cut, so there would be no effects to lynx denning or foraging habitat.
26
Release of purple loosestrife biological control insects would not impact wolves, bald
eagle, or lynx. None of these insects are biting or stinging insects, and the impacts they
cause to purple loosestrife would not impact forage for wolf or Canada lynx prey.
Cumulative effects
There would be no cumulative effects of either alternative to grey wolf, Canada lynx, or
bald eagle since there are no direct or indirect effects to these species.
Determination
Both Alternative 1 and Alternative 2 would have no effect on grey wolf, Canada lynx, or
bald eagle.
3.3 Regional Forester’s Sensitive Species
This section summarizes key findings and determinations of the NNIP Biological
Evaluation (BE – see planning record for complete BE).
3.3.1 Analysis Area
The analysis area is the same for each of the Superior National Forest’s 58 RFSS plants
and 28 RFSS animals. The area covered by the analysis of direct and indirect effects
includes all lands administered by the Superior National Forest. The area covered by the
cumulative effects analysis includes lands of all ownerships within Superior National
Forest boundaries. The NNIP Management Project BE describes the time scales,
rationale, and analysis areas in more detail.
3.3.2 Affected Environment
No site specific surveys were conducted for RFSS plants or animals. It is assumed that
potential suitable habitat for all of the 28 RFSS animals and 57 of the 58 RFSS plants
exists within the project area. However, most of the NNIP sites are poor habitat for many
of the RFSS plants and animals since 65% of sites occur on roadsides, 12% occur at
recreation sites, and 6% occur at gravel pits. Prior to treatment of NNIP occurring in
gravel pits, in forest stands, in wetlands, or other suitable RFSS plant habitats, a TES
plant survey would be performed. The Biological Evaluation has evaluated the potential
risks of the project to these RFSS plants and animals. The BE can be found in the
planning record.
For the one RFSS plant, false asphodel, with no suitable habitat in the project area, the
proposed alternatives are expected to have no impact.
3.3.3 Environmental Consequences
3.3.3.1 Alternative 1 – No Action
Direct and Indirect Effects
Under this alternative, no NNIP treatments would take place. Therefore, there would be
no consequences to RFSS plants or animals from any treatment activities.
27
NNIP would continue to spread under Alternative 1 and impact native plant communities.
This continued NNIP spread would not impact the majority of RFSS animals. However,
for LeConte’s sparrow, black tern, yellow rail, or Wilson’s phalarope, and for all of the
RFSS plants, continued NNIP spread would degrade suitable habitat thus cause some
potential indirect negative impacts to these species.
3.3.3.2 Alternative 2 – Modified Proposed Action
Direct and Indirect Effects
For the majority of RFSS plants and animals, the modified proposed action would have
no impacts. For many species, the reason for no impact is simply that suitable habitat for
the RFSS does not overlap with where the weed infestations are; most NNIP infestations
are along roads, in gravel pits, at recreation sites or other areas that are not suitable
habitat. Design features also help to prevent impacts, for example by changing the timing
of treatments for some species or by minimizing the risk that herbicides would move off-
site and have non-target impacts, such as by using spot application of herbicides rather
than broadcast application. A few known occurrences of RFSS plants occur at the same
site as a weed infestation. In these cases the least impactful treatment method would be
chosen, such as handpulling or wick application of herbicide, to ensure no impact to the
RFSS plants. Some short term impacts from trampling of suitable RFSS plant habitat is
possible. However, over the long term Alternative 2 would help improve or maintain
suitable habitat for many of these species.
For the RFSS plants pointed moonwort, common moonwort, Michigan moonwort, pale
moonwort, ternate grapefern, and least moonwort, and for the RFSS animals LeConte’s
sparrow, olive sided fly catcher, yellow rail, black throated blue warbler, bay breasted
warbler, Connecticut warbler, Wilson’s phalarope, sharp tailed grouse, Laurentian tiger
beetle, lake sturgeon, northern brook lamprey, creek heelsplitter, and black sandshell,
Alternative 2 could cause some impacts to these species or their suitable habitat. For this
group of RFSS plants, there is a chance that individuals could be missed during surveys
and thus get directly sprayed by herbicide. However, sufficient suitable habitat at any
given site would remain untreated such that only individuals would probably get
impacted, not entire populations.
For these RFSS animals, some (e.g. LeConte’s sparrow, yellow rail, Wilson’s phalarope,
or Laurentian tiger beetle) occupy habitats where NNIP are frequently found, and thus
they may accidentally be directly sprayed; this is much less likely for the birds in this
group than the tiger beetle. LeConte’s sparrow, olive sided fly catcher, yellow rail, black
throated blue warbler, bay breasted warbler, Connecticut warbler, Wilson’s phalarope,
sharp tailed grouse, and Laurentian tiger beetle also all eat (at least for part of their diet)
insects or berries/seeds and could thus potentially experience dietary exposure to
herbicide, if they eat food that had been sprayed. The risk of negative effects is low
because none of the proposed herbicides is highly toxic to birds (Appendix D, table D-4).
Ecological risk assessments conducted for the proposed herbicides suggest that use of
these herbicides at rates commonly used by the Forest Service poses little or no risk to
birds (see BA/BE Table 2.1). However, the risk assessments for glyphosate and triclopyr
conclude that small birds who consume insects from areas treated with the maximum
28
application rate for an extended period of time could potentially experience adverse
effects (see BA/BE Table 2.1). Therefore, although negative effects are unlikely for
these species, it is conservative to conclude that some individuals could be impacted.
For lake sturgeon, northern brook lamprey, creek heelsplitter, and black sandshell,
herbicide exposure is unlikely because of project design features. However, in a worst
case scenario, some individuals of these species could be exposed to herbicide, for
example through aerial drift of herbicide spray. There could potentially be minor impacts
to individuals, but the risk of negative effects is low because none of the proposed
herbicides is highly toxic to fish (Appendix D, table D-4). Ecological risk assessments
conducted for the proposed herbicides suggest that use of these herbicides at rates
commonly used by the Forest Service poses little or no risk to fish (see BA/BE Table
2.1).
No impacts to RFSS plants or animals are expected from release of purple loosestrife
biocontrol insects.
Cumulative effects
This cumulative effects analysis considers past, present, and reasonably foreseeable
projects that have affected NNIP spread on the Superior National Forest. They are listed
in Appendix F.
There would be minor negative cumulative effects of Alternative 1 to the RFSS plants
and animals discussed above. Under Alternative 1, NNIP would continue to spread and
could reduce and degrade the acres of suitable habitat for these species. Some NNIP
treatment activities would occur on Forest Service lands under a 2003 Categorical
Exclusion, and some NNIP treatment activities would probably occur on other publicly
(e.g. county, state) or privately owned lands. These actions would help offset some of the
NNIP spread, but the net effect would still be a gradual increase in NNIP infestations and
subsequent degradation of suitable habitat for these species. NNIP prevention measures
incorporated in recent and future vegetation and transportation management EA’s would
also help to limit the cumulative effects of Alternative 1, but there would still be a net
increase in NNIP infestations.
There would probably be a minor net beneficial effect of Alternative 2 on the RFSS
species discussed above. The design features would ensure that the cumulative negative
impacts of manual/mechanical, herbicide, and biocontrol treatments to these species are
quite small. Similar design features apply to NNIP treatments that have been carried out
under a 2003 Categorical Exclusion on Forest Service lands, and herbicide use on other
publicly and privately owned land in the project area would likely be implemented using
voluntary site-level forest management guidelines (MFRC 2005), which would minimize
non-target effects. There would be beneficial effects to suitable habitat for these species
under Alternative 2 as NNIP are contained and eradicated, both as a result of this project,
and as a result of NNIP treatment activities occurring under the 2003 Categorical
Exclusion referred to above, and NNIP treatment activities occurring on other publicly or
privately owned lands. These beneficial effects would probably slightly exceed the
29
minor negative effects mentioned above, creating a minor net benefical cumulative effect
of Alternative 2 to these RFSS.
Determination
Terrestrial Animals: Alternative 1 would have no impact on heather vole, northern
goshawk, boreal owl, olive sided flycatcher, black throated blue warbler, bay breasted
warbler, peregrine falcon, Connecticut warbler, three toed woodpecker, great grey owl,
sharp tailed grouse, wood turtle, Laurentian tiger beetle, Mancinus alpine, red disked
alpine, Jutta arctic, Nabokov’s blue, or Freija’s grizzled skipper.
Alternative 2 would have no impact on heather vole, northern goshawk, boreal owl, black
tern, peregrine falcon, three toed woodpecker, great grey owl, wood turtle, Mancinus
alpine, red disked alpine, Jutta arctic, Nabokov’s blue, or Freija’s grizzled skipper.
Alternative 1 may impact individuals of LeConte’s sparrow, black tern, yellow rail, or
Wilson’s phalarope but is not likely to result in a trend towards federal listing or a loss if
viability.
Alternative 2 may impact individuals of LeConte’s sparrow, olive sided fly catcher,
yellow rail, black throated blue warbler, bay breasted warbler, Connecticut warbler,
Wilson’s phalarope, sharp tailed grouse, or Laurentian tiger beetle, but is not likely to
result in a trend towards federal listing or a loss of viability.
Aquatic Animals: For Alternative 1, the proposed activities would have no impact on
lake sturgeon, shortjaw cisco, northern brook lamprey, creek heelsplitter, and black
sandshell.
Alternative 2 would have no impact on shortjaw cisco.
Alternative 2 may impact individuals of lake sturgeon, northern brook lamprey, creek
heelsplitter, and black sandshell but is not likely to result in a trend towards federal listing
or a loss if viability.
Plants: For Alternative 1, the proposed activities may impact individuals of alpine
milkvetch, creeping rush, swamp beggar-ticks, floating marsh-marigold, Katahdin sedge,
linear-leaved sundew, neat spike rush, moor rush, Vasey’s rush, auricled twayblade, fall
dropseed muhly, American shoregrass, dwarf water lily, club-spur orchid, northern bur-
reed, awlwort, lance-leaved violet, Cladonia wainoi, large-leaved sandwort, long leaved
arnica, maidenhair spleenwort, Ross’ sedge, sticky locoweed, nodding saxifrage,
encrusted saxifrage, smooth woodsia, Arctoparmelia centrifuga, Arctoparmelia
subcentrifuga, pointed moonwort, common moonwort, Michigan moonwort, pale
moonwort, ternate grapefern, least moonwort, Douglas hawthorne, small shinleaf,
cloudberry, fairy slipper, ram’s head ladyslipper, western Jacob’s ladder, Caloplaca
parvula, Certraria aurescens, Menegazzia terebrata, Ramalina thrausta, Sticta
fuliginosa, Usnea longissima, Pseudocyphellaria crocata, moschatel, triangle grapefern,
goblin fern, New England sedge, Chilean sweet cicely, Braun’s holly fern, Canada yew,
barren strawberry, Canada ricegrass, rough fruited fairy bells, or Peltigera venosa, but are
not likely to cause a trend to federal listing or loss of viability.
30
The proposed activities in Alternative 2 may impact individuals of pointed moonwort,
common moonwort, Michigan moonwort, pale moonwort, ternate grapefern, and least
moonwort but are not likely to cause a trend to federal listing or loss of viability.
For Alternative 2, the proposed activities would have no impact on alpine milkvetch,
creeping rush, swamp beggar-ticks, floating marsh-marigold, Katahdin sedge, linear-
leaved sundew, neat spike rush, moor rush, Vasey’s rush, auricled twayblade, fall
dropseed muhly, American shoregrass, dwarf water lily, club-spur orchid, northern bur-
reed, awlwort, lance-leaved violet, Cladonia wainoi, large-leaved sandwort, long leaved
arnica, maidenhair spleenwort, Ross’ sedge, sticky locoweed, nodding saxifrage,
encrusted saxifrage, smooth woodsia, Arctoparmelia centrifuga, Arctoparmelia
subcentrifuga, pointed moonwort, common moonwort, Michigan moonwort, pale
moonwort, ternate grapefern, least moonwort, Douglas hawthorne, small shinleaf,
cloudberry, fairy slipper, ram’s head ladyslipper, western Jacob’s ladder, Caloplaca
parvula, Certraria aurescens, Menegazzia terebrata, Ramalina thrausta, Sticta
fuliginosa, Usnea longissima, Pseudocyphellaria crocata, moschatel, triangle grapefern,
goblin fern, New England sedge, Chilean sweet cicely, Braun’s holly fern, Canada yew,
barren strawberry, Canada ricegrass, rough fruited fairy bells, or Peltigera venosa.
3.4 Significance Factors
Context. ...the significance of an action must be analyzed in several contexts such as
society as a whole (human, national), the affected region, the affected interests, and
the locality. Significance varies with the setting...in the case of a site-specific action,
significance would usually depend upon the effects in the locale rather than in the
world as a whole. Both short and long term effects are relevant.
The context of this project is limited to the locale of the Superior National Forest because
teatments would occur Forest-wide. The potential physical and biological effects of this
project are analyzed at appropriate scales, such as across all ownerships Forestwide for
the cumulative effects analysis for TES plants and animals. Short and long term effects
are both considered.
Even in a local context, this project would not pose significant short or long term effects.
The 219 acres proposed for treatment are a small proportion of the total area of the
Superior National Forest (2.2 million acres). This relatively small scale of treatment
would limit the proposal’s effects on other resource values to a very minor level. The
projects design features would also help minimize and avoid adverse impacts.
Intensity - the severity of impact. The following should be considered in evaluating
intensity:
Impacts may be both beneficial and adverse. A significant effect may exist even if,
on balance, effects are believed to be beneficial.
Both adverse and beneficial impacts of the alternatives are analyzed and disclosed.
Beneficial effects were not used to compensate for or offset adverse effects. Even when
considered separately, adverse effects are small and not significant (see BA/BE for
further description of effects).
31
The degree of effects on public health or safety.
This project would have a very low risk of significant effects to human health and safety.
The manual and mechanical control methods would pose little safety risk to workers or
the public because routine safety practices would be observed. These safety practices
address hazards related to operating mechanical equipment such as brush saws in remote
settings as well as exposure of workers to natural hazards such as poison ivy, stinging
insects, or falling branches. The public would be excluded from treatment sites while
work is in progress so they will not be affected by these methods.
The herbicide treatment methods also pose a low risk of impacts to human health and
safety. The risk to human health depends on the toxicity of the herbicides used and the
dose of herbicide to which an individual may be exposed. This project was designed to
minimize risk to human health by 1) choosing herbicides with low toxicity to humans
(see Table 3.1), and 2) implementing safety measures to reduce the chances that herbicide
applicators or the general public would be exposed to herbicide.
Appendix E describes design features which reduce the risk that applicators or the
general public would be exposed to herbicide. All herbicides proposed for use are
approved by the Environmental Protection Agency and available without special permit
(anyone can buy them at a garden supply store). The design features include measures to
reduce the risk of: off-site herbicide drift, run-off of herbicide into groundwater or
surface water, being directly sprayed by herbicide, consuming wild fruit that that have a
herbicide residue on them, and walking through a recently sprayed area.
The human health risks of the proposed herbicides were evaluated agency-wide by a risk
assessment procedure. Table 3.1 shows the risk assessment results – all of the herbicides
have a low risk of effects to human health. The risk assessment for each herbicide
includes assessments of the hazards of acute and chronic exposure to the herbicide, an
exposure assessment, and a dose-response assessment.
The risk assessments are very quantitative. They include a variety of exposure scenarios
for applicators and the general public, such as chronic consumption of sprayed fruit, or
direct spray of exposed legs. Many fairly conservative assumptions go into each
exposure scenario. Each exposure scenario generates a dose or exposure for the public or
applicators, and this dose is compared to the dose at which no adverse effects are
expected (this is established by the EPA and is based on animal research). The human
health risk is characterized for each exposure scenario, and while these risk assessments
cannot prove the safety of any herbicide, they can indicate whether there is a plausible
level of concern and where that concern should be directed.
No Forest Service risk assessment has been performed for aminopyralid; it is a new
product that was released in October 2005. It is closely related in its chemical structure
and activity to clopyralid. EPA registered this herbicide under its Reduced Risk Pesticide
Initiative. Based on its similarity to clopyralid, which has low risk to human health, and
32
on the studies EPA analyzed during aminopyralid’s registration process (USEPA 2005),
aminopyralid has a low risk for human health effects.
Table 3.1. Environmental characteristics, toxicity, and human health risk of proposed herbicides
Herbicide Application rate
Soil mobility
Average Soil half-life
Water half-life
Toxicity to Mammals
Human Health Risk Summary
Glyphosate 2 lb a.e./acre (typical rate)
low 47 days 12 days to 10 weeks
low Very little potential risk to
applicators or general public
Triclopyr 1 lb a.e./acre (typical rate)
moderate-high
30 days 4 days (but only hours in sunlight)
low
Very little potential risk to applicators or general public at typical application rates.
For maximum use rates, risk assessment suggests
prolonged exposure for workers and general public
may lead to health risks.
Imazapic
0.1 lb a.e./acre (typical rate)
low 106 days 1-2 days low Very little potential risk to
applicators or general public
Clopyralid
0.35 lb a.e./acre (typical rate)
moderate-high
40 days 8-40 days low Very little potential risk to
applicators or general public
Aminopyr- alid
0.08 lb a.e./acre (typical rate)
moderate-high
104 days (lab study); 32 days in field study
½ day low
No Forest Service risk assessment available for this new product. EPA pesticide fact sheet for aminopyralid suggests acute and chronic
exposures pose low potential risk to workers and general
public
Metsulfur- on methyl
0.03 lb a.i./acre (typical rate)
Moderate-high
120-180 days 1-8 days low Very little potential risk to
applicators or general public
SOURCES: Environmental characteristics and toxicity come from Appendix D. For human health risk information: Glyphosate - USDA Forest Service 2003b, p. 3-47 to 3-61; Triclopyr – USDA Forest Service 2003c, p. 3-29 to 3-51; Imazapic - USDA Forest Service 2004c, p. 3-22 – 3-25; Clopyralid - USDA Forest Service 2004a, p. 3-33 – 3-38; Aminopyralid – USEPA 2005; Metsulfuron methyl - USDA Forest Service 2004b, p. 3-23 – 3-25.
Unique characteristics of the geographic area such as proximity to historic or
cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or
ecologically critical areas.
Historic or cultural resources: Potential effects to these are described below.
Park lands: Portions of four Minnesota state parks are immediately adjacent to Superior
National Forest lands. The status of NNIP within these state parks is not known, but
there are 5 known roadside NNIP infestations within 500-2,640 feet of state park
boundaries. Two of these infestations are on Forest Service land and would be treated
with herbicide in Alternative 2 of this project; the other three are on non-Forest Service
ownership. This would potentially have benefical effects to the nearby state park lands
by limiting the risk of spread to these parks, but there would be very little risk of negative
effects to the parks because they are all over 500 feet away. The NNIP on non-Forest
Service land would not be treated as part of this project, but may be treated as part of
future cooperative projects with adjacent landowners. The non-Forest Service NNIP
33
could spread to State Park lands, but would probably not pose a risk to unique resources
because they would probably be roadside infestations that could be easily detected and
treated before causing significant impacts.
Prime farmlands: There are no known prime farmlands within the project area. This
project will not result in significant impacts to this resource.
Wetlands: Maps of wetlands from the National Wetlands Inventory show 827,640 acres
of wetlands occur forest-wide within Superior National Forest boundaries. The modified
proposed action proposes NNIP treatments on approximately 14 acres of mapped NWI
wetlands. There would be limited impacts to wetlands because of design features that
protect groundwater and surface water resources. For example, no soil mobile herbicides
would be applied to soils with rapid permeability throughout the soil profile or areas with
a high water table, nor within 150 feet of streams, lakes, and open water wetlands.
Additional design features include measures such as prohibiting fueling or herbicide
mixing within wetlands. This project would have limited impacts to wetlands.
Wild and scenic rivers: There are approximately 4 acres of NNIP infestations proposed
for treatment within the five eligible Wild, Scenic, and Recreational River Management
Areas (MA). These infestations are primarily on roads within this MA, with a few
infestations in gravel pits and one in a wildlife opening. Proposed treatments could have
some benefical effects to these rivers by preventing degradation of vegetation
communities by NNIP. Negative impacts from proposed treatments would be very
limited because of the design features that protect groundwater and surface water, as
described above for wetlands. This project would have minimal impacts to eligible Wild,
Scenic, and Recreational Rivers.
Ecologically critical areas: Little Isabella River Unique Biological Area (UBA), and
Dragon Lake and Blueberry Lake Candidate Research Natural Areas (cRNA) are the only
such areas within the project area with known infestations of NNIP. There are
approximately 0.1 acres total in all three areas. All of the infestations are along
roadsides. Proposed treatments would eradicate the NNIP in these areas and help protect
their ecological integrity. Negative impacts from proposed treatments would be very
limited because of the design features that protect other important natural and social
resources – see Appendix E for the design features. This project would have minimal
impacts to ecologically critical areas.
The degree of controversy over environmental effects.
The members of the public and other government entities that reviewed the comment
package had a chance to review the preliminary effects of the NNIP Management Project.
The Interdisciplinary Team and the Forest Supervisor carefully reviewed public
comments and determined that there were no highly controversial effects of this project.
Most commenters supported the proposed action, some asked for clarification or
expressed concern with aspects of the proposed action, and a few recommended new or
different actions. However, no scientific evidence was presented that displayed
controversy about effects. There is no scientific controversy over any of the potential
34
effects (USDA Forest Service 2003b, USDA Forest Service 2003c, USDA Forest Service
2004a, USDA Forest Service 2004b, USDA Forest Service 2004c, USEPA 2005).
The degree to which the possible effects on the human environment are highly
uncertain or involve unique or unknown risks.
Proposed activities, such as mowing or handpulling NNIP, herbicide treatment of NNIP,
or release of biological control insects, are similar to those that have occurred in the past
on the Superior National Forest and in northeast Minnesota. The effects of the NNIP
Management project will be similar to the effects of a 2003 Categorical Exclusion for
NNIP control at recreation and administrative sites, and to other NNIP handpulling
projects that have occurred in recent years. These past actions have been monitored and
taken into account during development of the NNIP Management project. All actions
included in this project are consistent with the 2004 Forest Plan, and all environmental
effects are within the range disclosed in the Final Environmental Impact Statement for
the 2004 Forest Plan. Based on the effects of past decisions and the effects that are
disclosed in this environmental analysis, there will not be any highly uncertain effects or
effects that involve unique or unknown risks.
The degree to which the action may establish a precedent for future actions with
significant effects or represents a decision in principle about a future consideration.
Implementing specific activities within this project area would not commit the Forest
Service to actions on other lands either within or outside the project area. This project
will not establish a precedent for future actions nor does it represent a decision in
principle about a future consideration. All actions that are connected have been included
in this analysis.
The reasonably foreseeable future projects disclosed under cumulative effects are those
that are in the development phase. Environmental analyses will be completed on all of
these projects and site specific decisions will be made on whether or not to implement
these other projects.
Whether the action is related to other actions with individually insignificant but
cumulatively significant impacts. Significance exists if it is reasonable to anticipate
a cumulatively significant impact on the environment. Significance cannot be
avoided by terming an action temporary or by breaking it down into small
component parts.
Cumulative effects to Threatened, Endangered, and Sensitive Species were analyzed
earlier in this Chapter. For this issue the relevant cumulative effects analysis boundary
was determined and all known actions on all ownerships, including past, on-going, and
reasonably foreseeable future projects were considered. Appendix F describes potential
cumulative actions. There are no known significant cumulative effects between this
project and other projects that have occurred in the past, or currently being implemented,
or planned in the project area or adjacent areas.
The degree to which the action may adversely affect districts, sites, highways,
structures, or objects listed in or eligible for listing in the National Register of
35
Historic Places or may cause loss or destruction of significant scientific, cultural, or
historical resources.
No significant project-related impacts are foreseen on any historic properties listed on or
considered eligible for listing in the National Register of Historic Places. The Project
Area has been reviewed by Heritage Resource staff. As a result, they have identified the
known heritage sites within and adjacent to treatment units and all known heritage
resources will be avoided during implementation of the project. Any previously
unrecorded heritage resources discovered during project implementation shall be avoided
and reported.
Appendix E contains mitigations for treatment units that have the potential for containing
unrecorded heritage resources. A reasonable and good faith effort shall be made to
identify heritage resources in those locations. All land within 400 feet of lakes and
streams that is within treatment unit boundaries shall be reviewed. The review would
consider the potential for unrecorded archeological sites. Field survey would be
conducted as deemed appropriate by the Heritage Resource Program Manager.
Based on the review of past surveys and recorded heritage resources, planned review of
areas of higher potential prior to action, and the mitigation measures and monitoring
associated with the actions, the Superior National Forest Heritage Program Manager
concluded that there shall be no direct, indirect or cumulative effects to heritage resources
under any of the alternatives.
The degree to which the action may adversely affect an endangered or threatened
species or its habitat that has been determined to be critical under the Endangered
Species Act of 1973 (ESA).
The NNIP Management Project would have no adverse effects to threatened or
endangered species. The BA/BE (see project file) for this project documents that both
Alternatives 1 and 2 will have no effect to wolves, Canada lynx, or bald eagle. This
analysis is summarized in Section 3.2 of this Environmental Assessment.
Consultation with USDI Fish and Wildlife Service
As per Forest Service Manual 2671.45 no consultation has been initiated by the Forest
Service for this project because the BA concludes that the modified proposed action
(Alternative 2) would have No Effect on listed species or their designated critical habitat.
Whether the action threatens a violation of Federal, State, or local law or
requirements imposed for the protection of the environment.
The National Forest Management Act, National Environmental Policy Act, Endangered
Species Act and the Clean Water Act were considered during this analysis. These actions
would not threaten a violation of any Federal, State, or local law or requirement for the
protection of the environment. The NNIP Management Project would protect the
environment to the extent practical and would enhance terrestrial and aquatic wildlife
habitat and native plant communities through vegetation management activities to meet
Forest Plan desired conditions and objectives.
36
Civil Rights and Environmental Justice:
The phrase "Civil Rights" implies fair and equal treatment under the law, both within the
agency and in its relations with the public (FSH 1909.17, 33.26). It is Forest Service
policy that Forest Service employees conduct official business so that: "1) the Forest
Service eradicates all forms of discrimination from its programs and activities; 2) all
levels of the organization are supportive of affirmative action; 3) there are no economic
or social barriers which limit program participation; and 4) all programs and services are
equally available to all persons, without exceptions" (Forest Service Manual 1703).
Executive Order (EO) 12898 of February 11, 1994, requires each federal agency to
"make achieving environmental justice part of its mission by identifying and addressing,
as appropriate, disproportionately high and adverse human health or environmental
effects of its programs, policies, and activities on minority populations and low-income
populations".
Under all alternatives, there would be no direct, indirect, or cumulative effects of the
Project on environmental justice.
37
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Minnesota Department of Natural Resources. 2005b. Siberian peashrub (Caragana
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Nuzzo, V. 1997. Element stewardship abstract for Cirsium arvense. The Nature
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Relyea, R.A. 2005a. The lethal impact of Roundup® on aquatic and terrestrial
amphibians. Ecological Applications 15:1118-1124.
Relyea, R.A., N.M. Schoeppner, and J.T. Hoverman. 2005b. Pesticides and amphibians:
The importance of community context. Ecological Applications 15:1125-1134.
Relyea, R.A. 2005c. The lethal impacts of Roundup and predatory stress on six species
of North American tadpoles. Arch. Environ. Contam. Toxicol. 48:351-357.
Saskatchewan Purple Loosestrife and Invasive Species Project. 2005. Caragana or
Siberian peashrub. 2 p. Available internet:
http://www.sfn.saskatoon.sk.ca/science/splep/caragana.html
Tu, Mandy, C. Hurd, and J.M. Randall. 2001. Weed Control methods Handbook: Tools
and Techniques for Use in Natural Areas. The Nature Conservancy, Wildland
Species Team. Version April 2001. Available on Internet:
http://tncweeds.ucdavis.edu/handbook.html
39
U.S. Department of Agriculture, Forest Service. 2002. Biological control of invasive
plants in the eastern United States.
U.S. Department of Agriculture, Forest Service. 2003a. Non-native invasive species
framework for plants and animals in the U.S. Forest Service, Eastern Region. On
file with Forest Supervisor, Superior National Forest, 8901 Grand Ave. Place,
Duluth, Minnesota 55808. 20 p. Available internet:
http://www.fs.fed.us/r9/wildlife/nnis/r9-nnis-program.shtml
USDA Forest Service. 2003b. Glyphosate - Human Health and Ecological Risk
Assessment Final Report. Submitted by Patrick R. Durkin, Syracuse Environmental
Research Associates, Inc. SERA TR 02-43-09-04a.
http://www.fs.fed.us/foresthealth/pesticide/risk.shtml
USDA Forest Service. 2003c. Triclopyr - Revised Human Health and Ecological Risk
Assessments Final Report. Submitted by Patrick R. Durkin, Syracuse Environmental
Research Associates, Inc. SERA TR 02-43-13-03b.
http://www.fs.fed.us/foresthealth/pesticide/risk.shtml
USDA Forest Service. 2004a. Clopyralid - Human Health and Ecological Risk
Assessments Final Report. Submitted by Patrick R. Durkin and Mark Follansbee,
Syracuse Environmental Research Associates, Inc. SERA 43-1387-3-0716.
http://www.fs.fed.us/foresthealth/pesticide/risk.shtml
USDA Forest Service. 2004b. Metsulfuron methyl - Human Health and Ecological Risk
Assessments Peer Review Draft. Submitted by Julie Klotzbach and Patrick R.
Durkin, Syracuse Environmental Research Associates, Inc. SERA 43-1387-3-0716.
http://www.fs.fed.us/foresthealth/pesticide/risk.shtml
USDA Forest Service. 2004c. Imazapic - Human Health and Ecological Risk
Assessments Final Report. Submitted by Patrick R. Durkin and Mark Follansbee,
Syracuse Environmental Research Associates, Inc. SERA 43-1387-3-0716.
http://www.fs.fed.us/foresthealth/pesticide/risk.shtml
U.S. Department of Agriculture, Forest Service. 2004d. National strategy and
implementation plan for invasive species management. FS-805. 17 p. Available
internet:
http://www.fs.fed.us/rangelands/ftp/invasives/documents/Final_National_Strategy
_100804.pdf.
USDA Forest Service 2004e. Superior National Forest Land and Resource Management
Plan. On file with Forest Supervisor, Superior National Forest, 8901 Grand Ave.
Place, Duluth, Minnesota 55808. P. 2-22 – 2-36, 2-54.
40
USDA Forest Service. 2004f. Final environmental impact statement, forest plan
revision, volume 1. On file with Forest Supervisor, Superior National Forest,
8901 Grand Ave. Place, Duluth, Minnesota 55808. Pp. 3.1-1 – 3.1-21.
U.S. Department of Agriculture, Animal and Plant Health Inspection Service. 2005.
Technical Advisory Group for biological control agents of weeds. 4 p. Available
internet: http://www.aphis.usda.gov/ppq/permits/tag/
USDA Forest Service. 2006. Biological Assessment/Biological Evaluation of the non-
native invasive plant management project on Threatened, Endangered, and
Regional Foresters Sensitive Species. On file with Forest Supervisor, Superior
National Forest, 8901 Grand Ave. Place, Duluth, Minnesota 55808. 119 pp.
USDA Forest Service. 2006. Draft fiscal year 2005 monitoring and evaluation report.
On file with Forest Supervisor, Superior National Forest, 8901 Grand Ave. Place,
Duluth, Minnesota 55808. Pages unnumbered.
US Environmental Protection Agency. 2005. Pesticide fact sheet: aminopyralid. 56 pp.
Westbrooks, R. 1998. Invasive plants, changing the landscape of America: Fact book.
Federal Interagency Committee for the Management of Noxious and Exotic
Weeds (FICMNEW), Washington, D.C. 109 pages. Available on Internet:
https://www.denix.osd.mil/denix/Public/ES-
Programs/Conservation/Invasive/intro.html. Pp. 1-8.
41
Appendix A – maps
42
Appendix B – site table
43
Appendix C – Scoping/Public Comment Summary This document is a summary of how public comments were categorized into significant issues,
non-significant issues, and non-issues by the interdisciplinary team. It includes analysis of non-
significant issues where needed, answers to questions, or further clarification. Not all comments
are listed. Where similar comments were given, the comment is listed only once.
An issue is a point of debate with a proposed action based on some anticipated effects. A
significant issue is based on extent of geographic distribution, duration of effect, and intensity of
interest or conflict generated. According to CEQ regulations, significant issues are neither
correlated to nor the same thing as significant effects. Significant issues would receive analysis
in the Environmental Assessment.
Non-significant issues are issues that are 1) not within the scope of the proposed action, 2) not
relevant to the decision to be made, 3) are already decided by law, regulation, or policy, or 4) are
conjectural or unsupported by the scientific evidence. Issues about effects that can be mitigated
through further clarification of the proposed action, design features and mitigation measures also
are not significant issues. Non-significant issues are analyzed briefly in this document and in the
project record. They are not analyzed further in the Environmental Asssesment.
Non-issues are comments that do not debate an effect. They can be statements of opinion,
preferences, or questions about the proposed actions.
1. Significant Issues
No significant issues were identified by the interdisciplinary team during analysis of comments.
2. Non Significant Issues
Effects to reptiles and amphibians
Comment: We suggest the USFS give consideration to whether the timing of treatments
in wood turtle habitat should be revised to ensure nesting success. Specifically, should
riparian habitats known to be occupied by wood turtles be completely avoided from the
beginning of their nesting period to the point at which the young turtles disperse? Could
effective treatment be conducted prior to or after this period to avoid any disturbance to
buried eggs or young turtles? Kenneth Westlake for EPA
Response: This issue was addressed by modifying the design feature for wood turtle. In
known wood turtle habitat, NNIP treatments will not be conducted during the nesting
period or during the dispersal period for young turtles.
Comment: We think the plan should give more attention to recent work by Relyea
(Relyea 2005a, Relyea et al. 2005b, Relyea 2005c) that demonstrates the high level of
mortality of amphibian species when subject to Roundup in both aquatic and terrestrial
habitats… Recent work by Relyea may suggest to simply avoid glyphosphate in or near
aquatic habitats and to minimize its use in terrestrial habitats. Nick Danz and Gerald
Niemi, NRRI
44
Response: Relyea’s research is specific to Roundup, not glyphosate in general, and it
suggests that Roundup causes fairly high levels of mortality in tadpoles (when applied to
aquatic habitats) and in adult frogs (when applied in terrestrial habitats). As Relyea
(2005a) states, other research suggests that the ethoxylated tallowamine surfactant
(POEA) in Roundup is the cause for toxicity in fish and perhaps in amphibians.
Roundup is not labeled for use in aquatic habitats, and we do not propose to use Roundup
in such settings. In this way we would avoid impacts to amphibian larvae and to other
aquatic animals such as fish, which are very sensitive to exposure to Roundup. Only
formulations of glyphosate approved for aquatic use (e.g. the Rodeo™ formulation of
glyphosate) or imazapic would be applied in terrestrial habitats within 150 feet of
streams, lakes, and open water wetlands. Also note that, in response to comments from
the 1854 Authority, we will not be applying any herbicides, even those labeled safe for
aquatic use, to lakes and rivers – see response to comments about effects on water
resources. Also see response to comments from the Minnesota DNR requesting
clarification of glyphosate use.
To avoid potential impacts to adult amphibians in terrestrial habitats, we modified the
proposed action. The Roundup formulation of glyphosate will not be used anywhere in
the project area. Only glyphosate formulations that do not contain ethoxylated
tallowamine surfactants would be used.
Effects of herbicide on water resources
Comment: We do have some concern with chemical control, especially in or near water
resources. Although it was difficult to assess every potential treatment area, some
specific locations include Big Rice and Moose Lakes. Big Rice Lake is of extreme
importance to the bands, and any chemical applications (potentially near the public
landing) adjacent to or affecting the water should be avoided. Supporting maps indicate
purple loosestrife in Moose Lake. The plan states that purple loosestrife plants will be
spot treated with herbicide if manual/mechanical methods are unsuccessful. Moose Lake
is a high quality wild rice lake, and we believe that chemical applications should be
avoided there. Darren Vogt, 1854 Authority
Response: We share the 1854 Authority’s concern with herbicide effects on surface
water and groundwater. To alleviate these concerns, we modified the proposed action.
Herbicide application was eliminated as a secondary treatment approach for 3 purple
loosestrife sites (Dark Lake, Moose Lake, and Little John Lake) that are located on lakes
or rivers. These sites will be managed with hand pulling alone, and no herbicide would
be applied to NNIP in lakes, rivers, or adjacent wetlands anywhere in the project area.
Because there are only three such sites and they are small, it is very likely that the NNIP
control objectives would be met by handpulling alone. Furthermore, we would
coordinate with the 1854 Authority for any NNIP management in wild rice lakes.
For NNIP treatments that are at terrestrial sites (i.e. in the uplands) but near water, such
as at boat launches (for example at Big Rice Lake) or along roads near creek crossings,
45
the design features in the modified proposed action would protect water resources so that
there is very little risk of herbicide treatments to water resources. Some design features
limit application to times when wind speed is less than 10 m.p.h. to minimize offsite
herbicide drift. Others prevent herbicide treatment if weather forecasts call for rain that
could lead to runoff of herbicides in surface water. Herbicides that could leach through
the soil and impact ground water would not be used on sites with shallow soils or rapidly
drained soil, or at sites with shallow water tables, or within 150 feet of lakes, streams, or
open water wetlands. Only herbicides that bind tightly to soil particles (glyphosate and
imazapic) would be used at such sites; there would be very little risk of herbicides
leaching off-site and entering ground or surface water. Mixing and loading of herbicides
would not occur in wetlands or near water. These design features are conservative and
will prevent movement of herbicides from terrestrial sites into aquatic sites.
There are several other reasons that the proposed herbicide treatments pose a low risk to
water resources. First, herbicides would be applied only by Minnesota-licensed
applicators or under the supervision of licensed pesticide applicators. Licensed pesticide
applicators are trained to properly maintain application equipment to prevent leaks and to
apply herbicide in a manner that minimizes drift, such as by using spray nozzles that put
out larger, heavier droplets that fall to the ground quickly. Second, the infestation sites
are generally quite small – the average size is only 0.09 acre – so on average very little
herbicide would be used at a site. Lastly, modern herbicides are broken down by
microbes and sunlight into inactive products in the soil fairly rapidly; depending on the
soils and weather, this could take from 4 to 26 weeks (see Table D-1 in Appendix D). In
the unlikely event that they do enter the surface water, their concentration would quickly
decline because of volatilization and degradation by sunlight and microorganisms, which
occurs even more rapidly in water (see Table D-2 in Appendix D).
Effects of non-native hawkweeds and oxeye daisy to native
plants
Comment: But I personally would like to see the orange hawkweed, oxeye daisy, and
yellow hawkweed remain in the National Forest, including the BWCAW. They add a
great deal of color to open spaces and do not appear to affect the health or survival of the
native species. Bob Barnabee
Response: While they may not be our most pernicious invasives, a number of studies
have documented the negative impacts of these species on native plants. For example,
see the chapter titled “Meadow and Orange Hawkweed” by L.M. Wilson and R.H.
Callihan and “Oxeye Daisy” by B.E. Olson and R.T. Wallander in Biology and
Management of Noxious Rangeland Weeds published by Oregon State University Press in
1999. They are also on noxious weed lists in a number of states. We propose to control
oxeye daisy and yellow and orange hawkweed in the BWCAW, but they are so
widespread outside the BWCAW that there is no chance to control them there, so forest
visitors will still be able to see them in abundance along roads.
Effectiveness of manual treatments
46
Comment: From my experience, trying to eliminate tansy and other invasive species
manually, though well intended, will result in failure. Gordon Hommes
Response: Some species are very difficult to kill by pulling (like leafy spurge), while
others can successfully be controlled manually (like spotted knapweed), at least for small
infestations. The proposed action takes these species differences into account. We
acknowledge the shortcomings of manual control where it is proposed but is not the most
effective treatment method (for example, pulling tansy or Canada thistle in the
BWCAW). However, at this time we do not have a complete NNIP inventory for the
BWCAW. An analysis of priority species for treatment as well as possible treatment
methods would occur in the future after inventory efforts in the BWCAW are more
complete. In the meantime, only manual methods would be used
Appropriateness of glyphosate, a non-selective herbicide
Comment: I would recommend not using glyphosate when other herbicides are available.
Glyphosate is a non-selective herbicide, this opens up the treatment areas to other plants,
in many cases undesired vegetation. Lee Shambeau, 4-Control
Response: We acknowledge these potential effects of glyphosate. However, glyphosate
binds soil tightly and is less likely to leach into ground water or run off sites like some
soil mobile herbicides. The Superior National Forest has many sites with shallow to
bedrock soils or very gravelly well-drained soils where soil mobile chemicals pose a risk
for leaching. To mitigate the effects of using glyphosate, we are proposing only spot
application with this herbicide, which would not create large areas of bare ground. Also,
we have a design feature for seeding treated areas where necessary to provide more
competition for weeds that may try to reinvade a site.
Response to Questions and Non-issues
Clarify glyphosate use
Comment: We also ask that the NNIP Management Project clarify the conditions under
which the use of the aquatic labeled version of glyphosate is required. Lynden Gerdes,
Jim Weseloh, Minnesota DNR
Response: We have attempted to clarify the use of aquatic labeled formulations of
glyphosate in the Design Features for this project, in response to these comments and in
response to comments from the 1854 Authority expressing concern over use of herbicides
in or near water resources. During implementation of the NNIP Management Project, no
herbicides (even those labeled for aquatic use) would be applied to NNIP (like purple
loosestrife) in lakes or rivers or wetlands adjacent to lakes and rivers. Only glyphosate
formulations approved for aquatic use or imazapic will be applied within 150 feet of
streams, lakes, and open water wetlands, on rapidly drained soils, or on sites with a high
water table. Aquatic labeled glyphosate is required because of concern for effects on fish
and amphibians. Imazapic does not have to be aquatic labeled as long as use is not in
aquatic habitats because it does not have the same risk for effects on fish and amphibians
as some glyphosate products.
47
Encourage coordination with other landowners
Comment: Would like to see the Forest Service coordinate with the city of Ely to get
weeds in their city gravel pit treated. Bob Koschak
Comment: We encourage the development of cooperative partnerships with local
landowners and government entities to create awareness and a sense of urgency, which
can lead to treatment of areas with imminent risk to USFS land. Kenneth Westlake, EPA
Comment: We did not see any indication that your agency will be cooperating with the
Minnesota Department of Natural Resources or private landowners to destroy the weeds
in question. This may leave large areas that will serve as a source of re-infestation. It
might be profitable to work with local landowners to decrease the number of weeds that
would serve as a base for re-infestation. Rebecca Milanese
Response: Thank you for your suggestion. We share your desire to coordinate with other
agencies and landowners and recognize it as a key aspect of successful NNIP
management. We have begun coordinating with the MN DNR, MN DOT, and St. Louis,
Lake, and Cook Counties. As we move forward with implementing this proposal,
coordination efforts will expand to encompass more landowners and agencies.
Organic farm certification
Comment: Our certifying agency, The Organic Crop Improvement Association, requires
that we maintain at least an eight meter buffer zone between our crops and any land
treated with herbicides. We have additional concerns over any drift from the spraying
and from the possibility of run-off of the herbicide residue. As we understand your maps
the nearest non-native invasive plant occurrences are over a mile from our property. We
would like you to notify us if any sites are located nearer to our property and we hope
you will work with us to prevent any possible contamination of our crops.
Response: We share your concern about herbicide drift and run-off from treatment sites,
and we will certainly work with you to make sure there are no threats to your organic
certification. As you correctly note, there are no plans for any treatments within a mile of
your property at present, and we will notify you if any closer infestations are found.
We developed the NNIP Management Project with the intent of minimizing non-target
effects of all treatment methods. If NNIP infestations are found that are close enough to
your property to be of concern, manual/mechanical treatment options could be considered
that would not threaten your organic certification.
Measures of success
Comment: Lastly, we recommend the USFS outline measures of success for this project.
Kenneth Westlake, EPA
Response: We added measures of success in the monitoring section of the EA, Chapter
2.5.
48
Adequacy of proposed treatment acres
Comment: The plan does not, however, describe the sampling methodology used to
characterize the current distribution of NNIP on the Forest. Thus, we cannot be sure that
the current infestation is in fact restricted to only 146 acres. Additionally, did the survey
include aquatic habitats? The plan gives no mention to aquatic invaders other than Purple
Loosestrife, which is more of a wetland invader than a lake invader. Were lakes
surveyed? A lack of detail in the explanation of the current distribution of NNIP makes it
unclear whether the plan should allow for a greater number of additional acres to be
treated pending new discoveries. Was there a rationale for picking 50% of 146 (73 acres)
for new treatments? Why not choose a greater number of total acres? Nick Danz, Gerald
Niemi, NRRI
Response: Thanks for your question. NNIP surveys began on the Superior in 2001 and
continued district by district through 2004, when all the districts were completed. NNIP
surveys focused on sites where NNIP are most frequently found: roads, gravel pits,
recreation sites, BWCAW entry points, administrative sites, log landings, trails, harvest
units, etc. Nearly all such sites have been surveyed now. In 2005, surveys in the
BWCAW at campsites, portages, old resorts, old logging trails, and similar locations
began; the publication Dickens et al. 2005 informed survey methodology for BWCAW
surveys. Thus far, all the BWCAW infestations have been quite small.
Casual observation suggests that NNIP on the Superior are not as abundant (yet) in areas
with intact forest overstory, or lakes and wetlands. No systematic inventory has been
completed for such areas. However, surveys of 85 lakes on the Superior in 2003-2004 by
the MN DNR County Biological Survey did not turn up any purple loosestrife
infestations, nor have stream and lake surveys performed by Forest Service fisheries
crews. On the other hand, last summer 3 new, small (<0.5 acre) purple loosestrife
infestations were found. So, while there clearly are some NNIP infestations on the
Superior that are yet to be found, the pattern seems clear: the majority of NNIP
infestation are small (average = 0.09 acre) and located on roads or other corridors where
ground disturbance occurred or that are frequently impacted by people. New infestations
will certainly be found in the BWCAW and outside of it, but based on observation made
during weed inventories on the Superior to date, we think that allowing for treatment of
up to 50% more acres than what is currently known will be adequate to allow for
treatment of new infestations that appear over the next ten years.
Add scientific names
Comment: Crosswalk the common names of plants to complete scientific names. Jim
Weseloh, MN DNR, Lynden Gerdes
Response: We added these in the Environmental Assessment.
Disposal of NNIP
Comment: The Project proposal states “NNIP parts capable of starting new plants (seeds,
rhizomes, etc.) will be disposed of properly”. However, proper disposal is not described.
49
We recommend that procedures for handling, transporting and identifying the final
location for disposal of NNIP be fully described, for instance, controlled and monitored
burn piles at stated locations, or closed vehicle transfer to county landfill with specific
vehicle cleanout procedures. These details need to be clear up front so that when an
action begins all the necessary personnel and resources are in place to effectively and
responsibly transport and manage NNIP material to a controlled end point. Jim Weseloh,
MN DNR, Lynden Gerdes
Response: There are too many NNIP sites and too many different NNIP settings to
prescribe a disposal method for each NNIP site in this Environmental Assessment.
However, we did add some general considerations for NNIP disposal in the
Environmental Assessment and they are summarized here. Some combination of the
following methods would be used, and specifically which are used would depend on the
situation.
Placing in a sturdy plastic bag and securely closing bag
Burning, either on site or after being safely transported in a bag
Disposal in a landfill
Placing plants on shrubs or branches, so that they don’t contact ground and will
dry out without a chance to resprout
Other factors like: ripeness or unripeness of the seeds, time of year weeds are pulled,
seed dispersal mechanism (windborne vs. waterborne), whether the weed is a wetland or
upland species, whether vegetative fragments can start new plants, and ease of
transporting the plants would be considered when making decisions about NNIP disposal.
Prevention, rehabilitation, and restoration
Comment: Success of the NNIP Management Project and the greater goal of maintaining
native plant communities across the SNF will require a focus on prevention,
rehabilitation and restoration within all management activities. We recommend the
Project address these critical components more comprehensively in the following areas:
timber management areas…, recreation…, gravel pits…, transportation… Jim Weseloh,
MN DNR, Lynden Gerdes
Response: We agree that prevention, rehabilitation, and restoration are all key
components for successful NNIP management. As noted in Chapter 1.1, these are two of
five components of weed management that the Superior has been addressing over the last
several years. Although prevention, rehabilitation, and restoration with respect to timber
management, recreation, gravel pits, and transportation are beyond the scope of this
NNIP Management Project, we will continue to address these issues within the greater
framework of NNIP management on the Superior National Forest.
Comment: We recommend adding language stating that follow-up seeding of sites
disturbed by hand-pulling activities may require returning to the site at another time or
season to re-establish native species. Jim Weseloh, MN DNR, Lynden Gerdes
Response: This is now addressed in the design features.
50
Recommendations to add herbicide
Comment: Recommendations for Herbicides to add to list: Imazapyr, Aminopyralid,
Chlorsulfuron. Lee Shambeau, 4-Control
Response: Thank you for your information. We considered your suggestions, and
decided to add aminopyralid to the proposed action, but not imazapyr or chlorsulfuron.
There were enough advantages of aminopyralid, such as lower use rates compared to
clopyralid, that we decided to add it to the proposed action. For the other two herbicides,
we either do not currently have a need for controlling the species that they provide
control for (in the case of imazapyr), or feel that a herbicide we currently propose to use
(metsulfuron methyl) will meet our needs sufficiently that we do not need to add the
proposed herbicide (chlorsulfuron).
Statements of support
Comment: I would like to recognize your efforts in the area as needed and long overdue.
Tavis Westbrook, Minnesota State Parks
Comment: The 1854 Authority is in support to the Superior National Forest NNIP
Management Project and its objective to contain and eradicate invasive plant species.
Darin Vogt, 1854 Authority
Comment: This letter is to commend you on your comprehensive approach insofar as
removing invasive species from USDA Forest Service managed lands. Al Goodman,
Lake County
Comment: Having seen the results of many invasive plants in other parts of Minnesota
and the southeast, I applaud you recognition of the danger while there is time for
effective management intervention. Joseph Caulfield
Comment: We do, however, support the concept that you have presented…targeting
known areas of plant invasion and treating with as minimal danger to other plants as
possible. Robert and Carolyn Morrow
Comment: If we need to cross his lands, we may. Walter Sweeney
Comment: We strongly agree with the “Design Features” included in Section 2.3: “All
control treatments will be designed so that they are effective, based on the weed species’
phenology and life history, yet have the fewest impacts on non-target plants, wildlife,
water, recreation, and other resources” and; “Retain native vegetation and limit soil
disturbance as much as possible. If exposed soil results from NNIP control actions, re-
vegetate exposed soils promptly to avoid re-colonization by NNIP. Use only approved
seed mixtures and weed seed-free mulch.” An emphasis and priority on choosing the best
phenology (by species) is critical to effective control and eradication. Jim Weseloh, MN
DNR, Lynden Gerdes
51
Response: Thank you, comment noted.
Chemical sensitivity
Comment: One other consideration that should be held in mind is that some individuals
are extremely allergic to various chemicals. It would be important for your staff to make
individuals in the areas (campgrounds, road workers, etc.) aware that they are applying
chemicals especially on days when there might be wind drift or if chemicals are applied
in highly traveled areas. Rebecca Milanese
Response: For weed infestations in highly traveled areas, such as recreation sites or
campgrounds, access to the weed infestation would be restricted during herbicide
application, and a notice of the herbicide treatment would be posted once the treatment
was done. These and other design features should ensure that the public is aware of
recently treated sites and can avoid them if they choose.
Comment period and mailing list
Comment: I have noticed that the proposals are coming without dates for the end of the
comment period. If one does not have ready access to the Duluth News Tribune
mentioned in the proposal and does not know the date of publication o f the notice o fthis
proposed action, it is extremely difficult to know if comments fall within the comment
period and whether they are being considered. The effect of this dating system could be
considered an attempt to obscure the end date for comments, whether this is its true intent
or not. Rebecca Milanese
Response: We appreciate your concern. Forest Service regulation and policy establish
that the agency needs to be exact with respect to the publication date of the legal notice.
However, we cannot always rely on the print media to be 100% accurate when it comes
to publishing the legal notice on a given day. A newspaper may say they will publish the
legal notice on a given day, but sometimes that deadline is missed. If the Forest Service
either waited to send out a comment package or Decision Notice until the exact date of
the legal notice were known, the public would be shortchanged in terms of having the
entire length of the comment period to comment. Similarly, if the agency sent out an
inaccurate legal notice date, the public might miss the end of the comment period.
However, you do have a valid concern. To address it, we have begun placing the date of
the legal notice publication on our website after the legal notice is published. In this way,
commenters who do not receive the newpaper of record for a project can still easily
access the date of the legal notice and determine when the comment period ends.
Comment: Replace Bob Dale’s name on mailing list with Forrest Fleischman’s. Forrest
Fleischman, Forest Service Employees for Environmental Ethics
Response: We will do this.
Hand pulling
52
Comment: You mentioned in a few places that the size of the infested area was about the
size of the kitchen table. Why weren’t the people who were doing the field inspections
given a hand scythe to do the work right then and there? Gerald Olsen
Response: We did pull some of the sites as they were inventoried – they’ll be re-treated
in this project.
Transportation Management
Comment: Your paper states that “most known infestations are along roads”. This tells
me that closing roads would be a good place to start… Lawrence Morgan
…I can only imagine the illegal trails being blazed everywhere and with the trails come
more invasive species… Lawrence Morgan
Response: Roads and trails do serve as corridors for invasive plants. However, your
suggestions to close roads and trails are beyond the scope of this analysis, which does not
address transportation management. Also, this project includes design feature that will
minimize erosion as a result of project activities (see Appendix E).
Timber Management
Comment: …closing roads would be a good place to start, because not only would the
forest evolve away from 65% aspen thickets cut on short rotations…
Response: Aspen management is beyond the scope of the NNIP Management Project.
53
Appendix D – herbicide environmental characteristic and mammal toxicicty summary
Table D-1 - Mobility and Persistence of Herbicides in Soil
Herbicide Characteristics
Mechanisms of degradation Half-life
in soil
Mobility
Glyphosate Degradation is primarily due
to soil microbes
Average of 47
days
Low
Triclopyr Triclopyr is rapidly degraded
to triclopyr acid by sunlight
and microbes in the soil
30 days Ester formulation binds readily with
the soil, giving it low mobility. The
salt formulation binds only weakly
in soil, giving it higher mobility.
However, both formulations are
rapidly degraded to triclopyr acid,
which has an intermediate
adsorption capacity, thus limiting
mobility.
Clopyralid Clopyralid is degraded by soil
microbes.
40 days Does not bind strongly to soils, and
has moderate-high mobility
Aminopyralid Degradation by soil microbes
and sunlight
104 days (lab
study); 32
days in field
study
Does not bind strongly to soils, and
has moderate-high mobility
(USEPA 2005)
Imazapic Degradation primarily due to
soil microbes
106 days
(USDA Forest
Service
2004c)
Limited
Metsulfuron
methyl
Degraded by soil microbes
and chemical hydrolysis
120-180 days Moderate-high (Information
Ventures 1995)
Note: Unless otherwise noted, data is from Tu et al. 2001.
Table D-2 - Herbicide Solubility, Half Life, and Aquatic Toxicity Data. Herbicide Solubility Half-life Aquatic Toxicity and Bioconcentration
Glyphosate Soluble in water 12 days to 10 weeks Glyphosate is moderately toxic to fish. The Roundup®
formulation is highly toxic to fish and amphibians
because of the surfactant. Rodeo® is much less toxic
to aquatic organisms and is registered for aquatic use.
Relatively low potential for bioconcentration (USDA
Forest Service 2003b, p. 3-36).
Triclopyr Salt formulation is
water-soluble. The
ester formulation is
insoluble in water
Salt formulation can degrade
in sunlight with a half-life of
several hours. The ester
formulation takes longer to
degrade .
Ester formulation is extremely toxic to fish and aquatic
invertebrates. Acid and salt formulation is slightly
toxic to fish and aquatic invertebrates. Triclopyr acid
and triclopyr ester have relatively low potential for
bioconcentration (USDA Forest Service 2003c, p. 3-
24).
Clopyralid Highly soluble in
water and will not
bind with particles
in water column
8 to 40 days. Low toxicity to aquatic animals. No evidence of
bioconcentration in fish tissues (USDA Forest Service
2004a, p 3-18).
Aminopyralid Soluble in water About half a day – degraded
by sunlight
Aminopyralid is practically non toxic to fish and
aquatic invertebrates (USEPA 2005). Not expected to
bioconcentrate in fish.
54
Imazapic Soluble in water 1-2 days – degraded by
sunlight
Low toxicity to fish, and rapidly degraded in water
(USDA Forest Service 2004, p. 4-4). Very low level
of bioconcentration in fish tissue (USDA Forest
Service 2004c, p. 3-17).
Metsulfuron
methyl
Soluble in water 1 to 8 days (Information
Ventures 1995)
Practically non-toxic to fish and aquatic invertebrates
(Information Ventures 1995). Studies suggest low
potential for bioconcentration (USDA Forest Service
2004b, p. 3-19).
Note: Unless otherwise noted, data is from Tu et al. 2001.
55
Table D-3 Herbicide Toxicity Data for Mammals Herbicide Acute Toxicity Chronic Toxicity
(Technical product unless
specific formulation noted)
Oral
LD50
(rat)
Dermal
LD50
(rabbit)
4-Hour
Inhalation
LC50
(rat)
Skin
Irritation
(rabbit)
Skin
Sensitization
(guinea pig)
Eye
Irritation
(rabbit)
24-Month
Dietary
NOEL
(mouse)
24-Month
Dietary
NOEL
(rat)
12-Month
Dietary
NOEL
(dog)
mg/kg BW mg/L mg/kg BW/day
Glyphosate
Glyphosate acid >5000 >5000 NA Mild No Severe 750 362 >500
ROUNDUP >5000 >5000 2.6 None No Moderate Chronic toxicity data available
only for technical glyphosate acid RODEO >5000 >5000 >6.37 None No Slight
Triclopyr
Triclopyr acid 630 >2000 >2.6 Slight Positive Mild NA 12 0.5
GARLON 3A 2574 >2000
>2.6
None NA Severe
Chronic toxicity data available
only for technical triclopyr acid
GARLON 4 803 >2000
>4.8
None
Positive
Slight
Clopyralid
Clopyralid acid >5000
>2000
>1.2
(unspec.)
V. Slight
No
Severe
2000
15
100
(NOAEL)
Aminopyralid
Aminopyralid acid >5000 >5000 >5.5 No No Severe 50
(NOAEL)
250
(NOAEL)
93
(NOAEL)
Milestone >5000 >5000 >5.79 Slight No None Chronic toxicity data available only for
technical aminopyralid acid
Imazapic
Imazapic >5000
>5000 >4.83 None
No
Slight
>1288 >1133 150
(LOAEL)
Metsulfuron methyl
Metsulfuron methyl >5000 >2000 >5 Slight None Slight 5000 ppm
(18mo)
25 500 ppm
From: Glyphosate - USDA Forest Service 2003b, Appendix 3a, & chapters 3.1.4, 3.1.5, 3.1.11-3.1.13; Triclopyr - USDA Forest Service 2003c, Appendices 4, 5, & chapters
3.1.4, 3.1.5, 3.1.11-3.1.13; Clopyralid - USDA Forest Service 2004a, Appendix 1, & chapters 3.1.4, 3.1.5, 3.1.11-3.1.13; Aminoclopyralid – USEPA 2005; Imazapic - USDA
Forest Service 2004c, Appendix 1, & chapters 3.1.4, 3.1.5, 3.1.11-3.1.13; Metsulfuron methyl - USDA Forest Service 2004b, Appendix 1, & Chapters 3.1.4, 3.1.5, 3.1.11-3.1.13.
NA = Not Available
56
Table D-4 – Herbicide Toxicity Data for Birds, Fish, and Insects
Herbicide Formulation Avian Receptors Terrestrial Invertebrates Aquatic Receptors
(Technical product unless
specific formulation noted)
Bobwhite Quail Mallard Duck Earth-
worm
Honeybee Daphnia Bluegill Rainbow Trout
Oral LD50 8-day dietary
LC50
Oral LD50 8-day dietary
LC50
LC50 Topical LD50 48-hour
LC50
96-hour
LC50
96-hour
LC50
mg/kg BW ppm
(in food)
mg/kg BW ppm
(in food)
ppm
(in soil)
ug/bee Mg/L (in water)
Glyphosate
Glyphosate acid >6300mg/kg >6300mg/kg >100 780 120 86
ROUNDUP >5620mg/kg >5620mg/kg >5000mg/k
g
>100 12.9 5.8 8.2
RODEO >2000 >1000mg/k
g
>1000
(TL50)
>1000
(TL50)
Triclopyr
Triclopyr acid 2934 1698 5620 >100 133 148ppm 117ppm
Triclopyr butoxyethyl ester 849 5401 >5401 >100 2.2 0.36ppm 0.65ppm
Triclopyr triethylamine salt 11,622 2055 >10000 >100 1110ppm 893ppm 613ppm
Clopyralid
Monoethanolamine salt of
clopyralid
>4640 1465 >4640 >1000 >100 350 1645 700
Aminopyralid
Aminopyralid acid >2250 >5556 mg/kg
diet
>5496 mg/kg
diet
>100 >98.6 >100 >100
Imazapic
Imazapic >2150 >5000 >2150 >5000 >100 100 >100 >100
Metsulfuron methyl
Metsulfuron methyl >5620ppm >5620 >5620ppm >5620 >25 >150 >150 >150
LD50 - Lethal Dose 50; LC50 - Lethal Concentration 50; TL50 - Threshold Level 50. From: Glyphosate - USDA Forest Service 2003b, Appendices 9, 10, & chapters
4.1.2.2 and 4.1.3; Triclopyr - USDA Forest Service 2003c, Appendices 9, 12, 13; Clopyralid - USDA Forest Service 2004a, Appendices 2, 3, 5; Aminopyralid – USEPA 2005;
Imazapic - USDA Forest Service 2004c, Appendices 2, 3; Metsulfuron methyl - USDA Forest Service 2004b, Appendices 2, 3, 5, 6.
57
Appendix E – Design Features The project is designed to reduce or eliminate potential adverse effects of our actions.
All NNIP management will adhere to the following design features:
All guidelines presented in Forest Service Manual 2150, Pesticide Use
Management and Coordination, in Forest Service Handbook 2109.14, Pesticide
Use Management and Coordination Handbook, and in the Forest Service Health
and Safety Code Handbook chapter 22.1 would be observed. Also, compliance
with all federal, state, and local regulations regarding herbicide use would be
ensured.
All treatments will be designed to ensure that they do not negatively impact
Threatened, Endangered, or Sensitive species.
All control treatments will be designed so that they are effective, based on the
weed species’ phenology and life history, yet have the fewest impacts on non-
target plants, wildlife, water, recreation, and other resources.
All treatments will be planned to minimize the undesired impacts on native
vegetation.
Retain native vegetation and limit soil disturbance as much as possible. If
exposed soil results from NNIP control actions, revegetate exposed soils
promptly to avoid re-colonization by NNIP. Emphasize native species in
seed mixtures, and use only noxious weed seed free seed mixes and
mulch. Revegetation activities may require multiple visits to site to
maximize the chance for success of revegetation activities.
Field personnel involved in NNIP treatment actions must be able to
visually distinguish target NNIP plants from non-target native plants,
particularly native and non-native hawkweeds.
Prior to treatment of any new infestations not known at the time of this EA,
information about new infestations would be reviewed by appropriate resource
specialists to determine whether surveys for sensitive resources are needed.
Motor vehicles associated with NNIP treatment (e.g., ORVs, passenger vehicles,
tractors, riding mowers, etc.) would not be operated in wetlands while the ground
surface is inundated or saturated, or in forested areas where the equipment is not
capable of passage without damage to overstory (canopy) trees.
Motor vehicles associated with NNIP treatments that operate in infestations would
be cleaned before leaving the site.
Equipment refueling will not be done in wetlands, poorly drained soil, filter strips,
or riparian management zones.
Mechanical or manual control:
Mowing will be limited to roadsides or disturbed areas and timed to avoid
spreading seeds.
Use of the weed torch will be limited to times of low fire danger and when native
vegetation is dormant, or only in areas which are already heavily disturbed.
Wildland firefighters will be on site.
Equipment, boots, and clothing will be cleaned thoroughly before moving from
treatment site to ensure that seeds or other propagules are not transported to other
sites.
58
NNIP parts capable of starting new plants (seeds, rhizomes, etc.) will be disposed
of properly.
All earth disturbing NNIP eradication projects will be reviewed by heritage staff.
Appropriate heritage inventory and heritage site protection measures will be in
place prior to project implementation.
Herbicide Use:
Herbicide label directions will be carefully followed. This could include
temporary closure of treatment areas for public health and safety.
Notices will be posted near all areas which have been recently treated with
herbicides.
Herbicide application will only occur when wind speeds are less than 10 mph, or
according to label direction, to minimize herbicide drift.
Weather forecasts will be obtained prior to herbicide treatment. Treatment
activities will be halted, if necessary, to prevent runoff during heavy rain events.
Appropriate protective gear will be worn by herbicide applicators per label
direction.
Herbicide containers will be disposed of following label specifications, state and
federal laws, and Forest Service guidelines.
Herbicides stored on-site will have Material Safety Data Sheets per Forest Service
guidelines
All individuals working with herbicide will review corresponding Material Safety
Data Sheets.
Rinse water for cleaning or rinsing actions in conjunction with herbicide
treatment will be disposed of according to label instructions.
No herbicides, even those labeled for aquatic use, would be applied to NNIP (like
purple loosestrife) in lakes or rivers or wetlands adjacent to lakes and rivers.
Coordinate with the 1854 Authority for management of NNIP in wild rice lakes.
Use of clopyralid, aminopyralid, or metsulfuron methyl is not permitted in areas
with a high water table (ELT 1, 2, 3, 4, 5, or 6) or rapid to very rapid permeability
throughout the soil profile (ELT 7, 9, 11, 16, 17, 18). Use of triclopyr on such
sites is permitted only via cut stump applications. Aquatic labeled glyphosate and
imazapic may be used on such sites.
Use of clopyralid, aminopyralid, or metsulfuron methyl is not permitted within
150 feet of streams, lakes, and open-water wetlands. Use of triclopyr within 150
feet of streams, lakes, and open water wetlands is permitted only via cut stump
applications. Aquatic labeled glyphosate and imazapic may be used within this
buffer distance.
To protect terrestrial adult frogs and toads, Roundup and other formulations of
glyphosate containing ethoxylated tallowamine surfactants will not be used.
Mix and load herbicides outside of wetlands, areas with poorly drained soil, filter
strips, and riparian management zones.
Except for the old Isabella ELC site and Sawbill Landing, herbicides would be
applied only manually (e.g., using hand-held sprayers or painted on stumps or cut
surfaces). Broadcast spraying may be used at these two sites.
Wildlife and TES Species
59
If any TES species are observed during implementation of NNIP control activities
(other than raptors flying by overhead or a wolf passing by), work will stop until
the District Wildlife Biologist is consulted. Treatments will be revised as
necessary to avoid impacts to the subject species.
No treatments should be conducted within 860 feet of known nests occupied by
the northern goshawk or bald eagle during the breeding season (March 1 to
August 30). This distance represents a nest area of roughly 50 acres, centered at
the nest.
Do not conduct management activities within 300 feet of known nest sites of
boreal and great gray owls during the breeding season (March 1- June 1).
Prior to initiating treatments in non-forested wetlands and lakes, check for the
presence of black terns, yellow rails, and Wilson’s phalarope. Alert the District
wildlife biologist and do not proceed with treatment if birds are discovered.
At known occurrences of Nabokov’s Blue or Freija’s Grizzled Skipper, treat
NNIP by hand pulling or spot application of herbicide using a wick applicator.
Except for herbicides labeled for aquatic use, herbicide use in wetlands with
suitable amphibian breeding habitat will be avoided.
Riparian habitats known to be occupied by the wood turtle will be inspected for
wood turtles before physical or chemical treatments. Personnel working in
riparian habitats should be trained to recognize the wood turtles and their nests
and avoid trampling either. Do not conduct any NNIP treatments between May
20 and June 20 or from August 20 to September 30 in riparian habitats known to
be occupied by wood turtle.
Potential habitat for the sensitive plants pointed moonwort, common moonwort,
Michigan moonwort, pale moonwort, ternate grapefern, and least moonwort
would be surveyed prior to treatment if sites had never been surveyed for these
plants in the past.
When work is conducted in areas containing rare or sensitive plant species, those
plants would be flagged or marked, and operators would be trained to visually
recognize the protected plants.
Aquatic areas should be inspected for the possible presence of rare aquatic plant
species before treatments are initiated in those areas.
Site Specific
Do not treat NNIP occurrences 2328, 2365, and 2366 from March 1 to August 30
to protect nearby bald eagle nests.
Do not treat NNIP occurrences 5266 and 5493 from March 1 to August 30 to
protect nearby goshawk nests.
Do not treat NNIP occurrence 2148 from March 1 to June 1 to protect nearby
boreal owl nests.
For tansy infestation 5572, survey for Vasey’s rush before treatment. If Vasey’s
rush is found in immediate vicinity of tansy, either dig tansy or use wick
application herbicide treatment.
For Canada thistle infestation 5638, survey for neat spike rush before treatment.
If neat spike rush is found in immediate vicinity of Canada thistle, either pull or
dig Canada thistle or use wick application herbicide treatment.
60
For tansy infestation 5201, survey for large leaved sandwort before treatment. If
large-leaved sandwort is found in immediate vicinity of tansy, either dig tansy or
use wick application herbicide treatment.
For spotted knapweed infestation 2036, survey for least moonwort before
handpulling spotted knapweed.
For spotted knapweed infestation 7117, survey for least moonwort before
treatment. If least moonwort is found in immediate vicinity of spotted knapweed,
either dig or pull knapweed or use wick application herbicide treatment.
61
Appendix F - Past, present, and reasonably foreseeable projects Past projects influencing NNIP in project area:
Federal Vegetation management projects - Junction EA, Crescent Lake EA, Silver Island
EA, Red Pine and White Spruce Thinning EA, Red Pine Thinning Project – 1998, Behind
the Ridge EA, Northern Lights EA, and the Plantation EA (including transportation
management associated with selected alternative).
NNIP management projects – 2003 NNIP Management CE – 3-8 acres NNIP treatment per
year since 2003
Past county, DNR, and private industry timber sales in Lake, Cook, and St. Louis Counties
Releases of purple loosestrife biocontrol insects by MN DNR in St. Louis, Lake, and Cook
Counties
NNIP control conducted by MNDOT: Angora plumeless thistle, Biwabik Japanese
knotweed, Cascade State Park musk thistle
Tower Gypsy Moth EA
Current projects influencing NNIP in project area
Federal Vegetation Management Projects - Holmes-Chipmunk EIS, Echo Trail EIS,
Kadunce Hunter Walking Trail, Inga South EA, Upper Caribou CE, and East Side Thinning
Environmental Assessments (including transportation management associated with selected
alternative)
Highway 53 and Highway 1 reconstruction
Current county, DNR, and private industry timber sales in Lake, Cook, and St. Louis
Counties
Prescribed burning associated with BWCAW Fuels Management EIS
Reasonably foreseeable projects influencing NNIP in project area
Federal Vegetation Management Projects - Whyte, Twins, Two Island, Mid-Temperance,
Glacier, and Clara (including transportation management associated with selected
alternative)
Denley Road reconstruction
Future county, DNR, and private industry timber sales in Lake, Cook, and St. Louis
Counties
2006 Cook County Slow the Spread Gypsy Moth Project
Herbicide applications to NNIP by other public and private landowners
NOTE: Vegetation management and transportation management projects were included above
because they are probably the two types of projects that contribute most to NNIP spread on the
Superior, and thus are a connected action for the NNIP Management Project. EA’s for such
projects completed in the last four years considered the effects of each project on NNIP spread
and included mitigations to limit spread. Recent monitoring (USDA Forest Service 2006) shows
that the NNIP mitigations appear to be working and the contribution of any given project to NNIP
spread is quite small.
62
Appendix G – List of Preparers and Contributors
Susan Alexander – Public Service Specialist
Bill Clayton – Archaeologist
Erica Hahn – Forest Environmental Coordinator
Ken Gebhardt – Forest Fisheries Biologist
Jack Greenlee – Forest Plant Ecologist
Barbara Leuelling – Forest Soil Scientist
Kris Reichenbach – Public Affairs Specialist
Dan Ryan – Wildlife Biologist
Ann Schwaller – Natural Resources Recreation Manager
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