APPENDIX N GOSPEL-HUMP WILDERNESS INVASIVE PLANT MANAGEMENT PROJECT COMMENTS AND RESPONSES TO COMMENTS

Transcription

1 APPENDIX N GOSPEL-HUMP WILDERNESS INVASIVE PLANT MANAGEMENT PROJECT COMMENTS AND RESPONSES TO COMMENTS

2 Gospel-Hump Wilderness Invasive Plant Management Project Appendix N Gospel-Hump Wilderness Invasive Plant Management Project Comments and Responses to Comments A 30-day public comment period for the Gospel-Hump Wilderness Invasive Plant Management Project began on December 22, 2014, with publication of the Legal Notice announcing the 30-day comment period in The Lewiston Tribune. The Gospel-Hump Wilderness Invasive Plant Management Project Assessment (EA) is now available on the Nez Perce- Clearwater National Forests website at A scoping letter was sent to approximately 300 individuals, organizations, and government and tribal agencies summarizing the Proposed Action, and included directions to the Forest s website for more information. Summary of Public Comments One hundred sixty-nine individuals and organizations responded during the 30-day scoping period. The majority of the comments were included in three letters from the following organizations: Friends of the Clearwater, Wilderness Watch, and Idaho Conservation League. Most of the remaining comments, were similar to, or the same as, the comments in these three letters. Over 160 letters were form letters or a variation of a form letter. Comments were received from both individuals and organizations. Comment letters was assigned a reference number (Letter Number, Author Initials, Comment Number - see Table 1). Specific Written Comments The following section contains specific written comments, how they were categorized according to relevance to the purpose and need and the Forest Service s response to those comments. To minimize duplication, comments addressing essentially the same topic or concern have been consolidated among the various letters. Each comment contains a citation to the comment letter(s) where contained. Specific written comments are defined by 36 CFR 218.2: Written comments are those submitted to the responsible official or designee during a designated opportunity for public participation ( 218.5(a)) provided for a proposed project. Written comments can include submission of transcriptions or other notes from oral statements or presentation. For the purposes of this rule, specific written comments should be within the scope of the proposed action, have a direct relationship to the proposed action, and must include supporting reasons for the responsible official to consider. Issues serve to highlight effects or unintended consequences that may occur from the proposed action and alternatives, giving opportunities during the analysis to reduce adverse impacts and compare trade-offs for the decision maker and public to understand. An issue should be phrased as a cause-effect statement relating action under consideration to effects. An issue statement should describe a specific actin and the environmental effect(s) expected to result from that action (FSH , section 12.4). Since this is an EA, the term significant is not used (FSH , section 12.41). Issues may be addressed through: 1

3 Appendix N Purpose and Need Alternative development Design criteria Analysis and documentation in effects Gospel-Hump Wilderness Invasive Plant Management Project When a concern is not identified as an issue, the rationale for not identifying it as an issue can be categorized as follows: Previously decided by law, policy, or Forest Plan Outside the scope of the project Not affected by proposal Conjectural, not supported by science Irrelevant to the decision being made Duplication of previous scoping comments No comment/issue could be identified relevant to the proposal Table 1. Gospel-Hump Wilderness Invasive Plant Management Project Comments and Responses Herbicide Use 1, DA, 1 11, Lor, 2 These letters asked that glyphosate-containing herbicides be limited to only Rodeo or Accord formulations because others can have adverse effects on people, wildlife, and aquatic species. Herbicide Use 1, DA, 1 This letter requested that Selway- Bitterroot Invasive Weeds (SBW) EIS/ROD be amended to restrict glyphosate-containing herbicides to Rodeo or Accord formulations. Herbicide Use 2, ICL, 5 This letter asked that only biodegradable herbicides be used, and that only herbicides that do not enter into the food chain and cause mortality be used in lakes or other waters or in riparian areas. Design criteria: The Proposed Action (PA) identifies Rodeo and Accord formulations and specifically not Roundup - as approved for use. See the Human Health section and Table 27 in the EA. Outside the scope of the project: This comment is outside the scope of this project, although the SBW ROD (and the draft decision on the Gospel-Hump EA) does limit glyphosate use to Rodeo and Accord formulations. Design criteria and carried through analysis: Design criteria have been developed that mitigate herbicides that cause mortality from entering into waterbodies or into the food chain and into water. The effects of these herbicides is addressed in the EA as well as the biological evaluation/biological assessment (BE/BA). See discussion in Chapters 2 and 3 and Appendix L (BE/BA). 2

4 Gospel-Hump Wilderness Invasive Plant Management Project Appendix N Herbicide Use 2, ICL, 6 This letter asked that herbicides be stored in durable containers and mixed carefully so as not to contaminate water or riparian areas and that their label instructions be followed. Herbicide Use 4, WW, 3 This letter suggests that herbicides rarely work and that weeds become resistant to herbicides so that herbicide concentrations have to perpetually be increased. They state that herbicide use must be limited and their use ended after a period of time. Minimum Tool 2, ICL, 1; 3, FOC, 6 Assessment (EA) vs. Impact Statement (EIS) 2, ICL, 2; 3, FOC, 3 This letter asked that the minimum tool method of control and treatment be analyzed for each strategy, as well as how the minimum tool process will be consistent with the Forest Plan. These letters suggest that the impact for the SBW and Frank Church weeds projects are similar to the effects for this project and, therefore, an EIS should be completed rather than an EA. Design criteria and Decided by law, policy, or Forest Plan: Design criteria have been developed and Best Management Practices (BMPs) are in place to ensure that herbicides do not contaminate water, riparian areas, or other areas. Federal law requires herbicides to be mixed and handled according to the label s instructions. See Chapters 1 and 2 for design criteria, Appendix F for BMPs, and Appendix G for the Herbicide Safety and Spill Prevention Plan. Alternative Development: Unlike in agriculture, where herbicide resistance has been reported in association with large-scale industrial herbicide use, the limited and focused use of herbicides in the project area would make plant resistance an unlikely factor. Nonetheless, to respond to this concern the adaptive management strategy in the PA calls for monitoring for herbicide resistance and adjusting use if needed. See EA Chapter 2 and section A, Herbicide Resistance, of the SBW EIS. See Chapter 3 and Appendix L (BE/BA). Decided by law, policy, or Forest Plan: As a matter of Forest Service policy, a minimum tool analysis was completed for the Proposed Action and is available for public review on our website. The environmental assessment (EA) documents how the minimum tool process would be used during the analysis and throughout implementation of the Proposed Action. See Chapter 1; Chapter 2; Chapter 3; and Appendix A (Wilderness Minimum Tool Guidelines). Decided by law, policy, or Forest Plan: Council on Quality (CEQ) and Forest Service policy is to utilize an EA to determine if significant effects from a project exist and, if so, then complete an EIS. The SBW and Frank Church weeds project EISs have similar proposed actions to this EA and did not identify any significant effects. Therefore, starting this project with an EA to determine if an EIS is necessary seemed appropriate. If a Finding of No Significant Impact cannot be issued, an EIS will be developed. See Chapter 1 of the EA. 3

5 Appendix N Gospel-Hump Wilderness Invasive Plant Management Project Prevention 2, ICL, 3 and 8; 3, FOC, 7; 4, WW, 1; 11, Lor, 1; 14, Krause, 1; 23,Britton, 1: 22, Kov, 2; Noxious Weed and Invasive Plant List These letters suggested that a prevention strategy should be the major emphasis or the only strategy utilized and should be fully considered as a treatment type. 2, ICL, 7 This letter asked that a single list be developed for both noxious weed and invasive plants with a single name. 2, ICL, 9; 22, Kov, 1; 27, Gas, 1 This letter asked that impacts from commercial livestock grazing be assessed. Alternative development: The Forest agrees that prevention, as a strategy, is the most important and first strategy to be used in any weeds management program. A Gospel- Hump Prevention Plan and a Gospel- Hump Education Plan are part of the overall strategy and are included in the Proposed Action. However, prevention alone does not meet the Purpose and Need for this project. A prevention-only alternative was considered in this EA; however, it was dropped from further analysis because it did not meet the Purpose and Need (EA, Chapter 2). Nonetheless, we have tried to emphasize the importance of education and prevention in this analysis and in the draft decision. See discussion under Chapter 1; Chapter 2; Appendix B, Gospel- Hump Weed Prevention Strategy Plan; Appendix C, Wilderness Education Plan; and Appendix F, Best Management Practices. Also see Appendix R of the SBW EIS, which addresses many prevention comments and is applicable here. Outside the scope of the project: Often times, people use the terms invasive plants and noxious weeds interchangeably. These terms are identified differently by various agencies and policy, both State and federal. Nonetheless, we have tried to clarify these differences and similarities at the very beginning of the EA. And while there is no formal invasive plant list, all state noxious weeds are identified in Appendix H of the EA. Design criteria and carried through analysis: The effects of commercial livestock grazing on invasive plants and their spread, as well as the effects of invasive plants on livestock grazing, have been assessed and the analysis is included in the EA. Design criteria related to grazing have been added to the EA in Table 3 (as G1 and G2). 4

6 Gospel-Hump Wilderness Invasive Plant Management Project Appendix N 4, WW, 1 4 This letter suggest that commercial livestock grazing be halted to reduce the spread of weeds 2, ICL, 10; This letter asked that other vectors of weed dispersal, including livestock management, be identified in this analysis and recommendations made for items in a prevention plan. 2, ICL, 10; 3, FOC,8 These letters suggested the strategy for the Gospel-Hump should look at the Selway-Bitterroot and Frank Church wilderness weed strategies to assist this project. Outside the scope of the project: Commercial livestock grazing, including grazing impacts on invasive weeds, is covered under each allotment management plan and National Policy Act decision. The decision to graze or not to graze is not duplicated here. The scope of the Gospel-Hump Invasive Plant Management Project, which excludes a decision on whether or not to graze livestock, is outlined in Chapter 1. However, as described above, a design criteria intended to reduce possible impacts from grazing has been added to the EA in Table 3. Alternative development: The Proposed Action and analysis in the EA consider vectors for weed dispersal. These vectors are well defined (see EA, Chapter 3). Prevention of weed spread through various vectors is included in the Proposed Action (see Chapter 2, Proposed Action and Table 3, and Appendices B and C). Purpose and Need: Part of the Purpose and Need is to have a weed strategy similar to the Selway- Bitterroot s weeds strategy. The Frank Church wilderness weeds strategy is also being looked at for assistance with this project. See description in Chapters 1 and 2. The success in the Frank Church Wilderness has been documented, based on monitoring results in the 2008 Supplemental EIS, Appendix I. 5

7 Appendix N Gospel-Hump Wilderness Invasive Plant Management Project 3, FOC, 9 This letter suggests that invasive plant/noxious weed programs, including the SBW plan, have failed and, therefore, should not be used in this wilderness. Purpose and Need: The Purpose and Need of this project is not the eradication of all weed species but the management of weeds in an adaptive integrated strategy. It recognizes that some weeds cannot be eradicated at this time. It is understood that weed management is complicated and has not been successful in some instances, but a strategy to minimize impact is still necessary. Rice s (2016) 5-year SBW monitoring results mirror the expected effects displayed in the EIS; that is, monitoring shows a strong reduction in spotted knapweed after herbicide treatment as well as a short-term loss of native vegetation associated with spray areas. Monitoring continues and is expected to document an increase in native vegetation over time. Biological Control Strategy 3, FOC, 10 This letter suggests that reducing one weed may benefit another that has greater ecological risks. It goes on to state that focusing on knapweed may be counterproductive. 3, FOC, 12 This letter suggested that weeds may be a result rather than a cause of ecosystem functioning and nutrient cycling. 2, ICL, 4; 3, FOC, 4; 4, WW, 2; 15, Wal., 1 These letters expressed concern that the release of biological agents may have unintended consequences upon the environment and may not be in accordance with the Wilderness Act. Weed treatments similar to those proposed have been effective on the Nez Perce Clearwater NF. J. Doyle, NPCNF Bio. Tech. (Pers. Comm. 2017) reports The amount of herbicide (sprayed) has decreased in the last couple years as we ve been successful in controlling the (priority) weeds. Recent monitoring in nearby watersheds have shown a reduction in the acres treated over the last 10 years (J. Doyle, Pers. Comm.). Conjectural, not supported by science: Neither the Purpose and Need nor the Proposed Action strategy focuses on knapweed. This statement is speculative and not supported by science. Conjectural, not supported by science: This statement is speculative and not supported by science. Analyzed and documented in effects: The effects of a biological control strategy are analyzed in the EA. An Issue statement was developed that includes this issue. See Chapters 2 and 3. 6

8 Gospel-Hump Wilderness Invasive Plant Management Project Appendix N Biological Control Strategy 3, FOC, 11 This letter suggested that unintended consequences can result from releasing biological agents and cited a study concerning deer mice that ate insects introduced to control knapweed; consumption of the insects altered the deer mice population. Wilderness 3, FOC, 1 These letters suggested that using herbicides and biological control may violate the Wilderness Act. Analyzed and documented in effects: The effects of a biological control strategy will be analyzed in the EA. An Issue statement was developed that includes this issue. See Chapters 2 and 3. The SBW EIS (pp through ) discusses the effects of biocontrol, including this deer mice study, and is referenced in Chapter 3 of the EA. Decided by law, policy, or Forest Plan: The regulatory framework within which this project was developed was discussed in the Purpose and Need statement in the scoping documents and is documented in Chapter 1 of the EA. The current Noxious Weed Control Program for the Nez Perce National Forest (May 1988) approved the use of biological control in Wilderness. Wilderness 3, FOC, 2 These letters are concerned that the wilderness character needs to be protected as outlined in the Wilderness Act. Wildlife 3, FOC, 5 This letter refers to FSM a, concerning the introduction of wildlife species. Monitoring 3, FOC, 5; This letter suggested that monitoring from the Selway- Bitterroot and Frank Church-River of No Return Wildernesses should be evaluated as part of this analysis. This legal framework was also addressed in the SBW EIS (Chapter 1, pp. 1-5 through 1-7) and in response to similar comments to the SBW DEIS, (Appendix R, p. R-12). Analyzed and documented in effects: The effects of biological control and herbicide use is analyzed in the EA. An Issue statement was developed that includes this issue. See Chapters 2 and 3. Irrelevant to the decision being made: FSM a refers to the reintroduction of wildlife species: this is not a reintroduction project. Alternative development: Recent Selway-Bitterroot monitoring results are discussed in Chapter 2 under Monitoring-Reporting. The monitoring results from both projects have been considered in the development of this proposal. 7

9 Appendix N Gospel-Hump Wilderness Invasive Plant Management Project Monitoring 3, FOC,14 4, WW, 4 This letter suggested that annual monitoring and a 5-year effectiveness review should be part of the decision and changes should be made to management based on monitoring. Other 3, FOC, 13 This letter asked if impacts of exotic weeds are greater than the harm from aquatic habitat (fish stocking), agency fire suppression, or livestock grazing. Other 3, FOC, 16 This letter requested that an alternative that does not engage in widespread ecological manipulation of wilderness be evaluated. Other 11, LOI, 3 This letter suggested the agency should not interfere and should let nature take its course and eventually the weeds will be replaced by plants and foliage. Other 19, Bockino, 1 Duplication 6; 8; 9; 11; 13; 17; 18, 19; 20, 25; 26; 28; 29; 30; This letter suggested using goats to control weeds. These letters are form letters generated from Wilderness Watch s alert (4, WW, 1 4). All of these letters are duplicates of the comments in that letter, which have been addressed above. These letters produced no additional information concerning the scope of this EA, issues, or alternatives. Alternative development: Monitoring, including effectiveness monitoring is part of the Proposed Action for this project (Tables 7 and 8 and Monitoring section in Chapter 2). The proposed adaptive management strategy (Chapter 2 and Appendix D) allows for the flexibility the commenter suggests. Adaptive management allows the Forest Service to activate the adaptive response options shown in Tables 7 and 8, if the resource monitoring results/triggers displayed in those tables are met. Monitoring results on a very similar proposal in the very similar Selway-Bitterroot Wilderness Area will also continue to inform the actions in this area. So long as SBW and Gospel-Hump monitoring demonstrate success, monitoring in the Gospel-Hump will be periodic but may not occur on an annual basis. Annual reporting to NOAA-NMFS will occur. Outside the scope of the project: This question is outside the scope of this project s analysis. However, impacts of other actions and activities are considered and discussed in the analysis. Alternative development: A prevention (and manual/cultural treatment) alternative was considered; however, it was dropped from further analysis because it did not meet the Purpose and Need (EA, Chapter 2). The No Action alternative may best address the effects of not engaging in ecological manipulation. See Chapter 2. Conjectural, not supported by science: This statement is speculative and not supported by science. Outside the scope of the project: The scope of this project does not include the use of animals to control weeds. Goats would conflict with bighorn sheep in the area and, therefore, are not a viable option. Duplication of previous scoping comments 8

10 Gospel-Hump Wilderness Invasive Plant Management Project Appendix N No Recordable Comment No Recordable Comment 5, Schmidt This letter only produced a list of environmental groups, agencies, and other organizations. No comments/issues could be developed from this letter. 7, Sowder; 12, Fish; 21, Fran, 24, Cook These letters only made statement. No comments/issues could be developed from these letters. No comment/issue could be identified relevant to the proposal No comment/issue could be identified relevant to the proposal 9