Storrie and Rich Fire Areas Invasive Plant Treatment Project

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1 United States Department of Agriculture Forest Service Storrie and Rich Fire Areas Invasive Plant Treatment Project Environmental Assessment Mt. Hough Ranger District, Plumas National Forest, Plumas County, California February 2013 Yellow starthistle (Centaurea solstitialis) found at the end of a spur road off of Caribou Road (NFS road 27N26E) (Jim Belsher-Howe, July 2003).

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3 For More Information Contact: Michael Donald, Mt. Hough District Ranger c/o Katherine Carpenter, Project Leader Mt. Hough Ranger District Plumas National Forest Highway 70 Quincy, CA Phone: Fax: Information is also available on the project website:

4 The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual's income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA's TARGET Center at (202) (voice and TDD). To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, S.W., Washington, D.C , or call (800) (voice) or (202) (TDD). USDA is an equal opportunity provider and employer. ii

5 Contents Contents... iii Introduction... 1 Background... 1 Management Direction... 1 Proposed Project Location... 3 Need for the Proposal... 5 Purpose of Project... 5 Need for Action... 5 Desired Condition... 6 Public Involvement and Tribal Consultation... 7 Issues... 7 Category A Issues... 8 Category B Issues Proposed Action and Alternatives Alternative A Proposed Action (Multi-treatment) Alternative B No Action Alternatives Considered but Eliminated from Detailed Study Alternative C Aerial Application of Herbicides Alternative D Herbicide Treatment Alone Alternative E No Additional Buffers over Label Directions Alternative F Use of Alternative Substances to Registered Pesticides Alternative G Use of Prescribed Fire Alternative H Use of Grazing Proposed Action Herbicides Proposed Project design features Annual Implementation Review Process Project design features and Mitigations Environmental Impacts of the Proposed Action and Alternatives Past, Present and Reasonably Foreseeable Future Actions Botanical Resources Introduction Environmental Consequences Compliance with the Forest Plan and Other Direction Invasive Plants Introduction Environmental Consequences Compliance with the Forest Plan and Other Direction Recreation, Lands, and Scenic Resources Introduction Environmental Consequences Compliance with the Forest Plan and Other Direction Hydrology and Soils Introduction Environmental Consequences Compliance with the Forest Plan and Other Direction Wildlife Terrestrial and Aquatic Species Introduction iii

6 Environmental Consequences Compliance with Forest Plan and Other Direction Cultural Resources Introduction Affected Environment Environmental Consequences Compliance with the Forest Plan and Other Direction Consultation and Coordination References List of Tables Table 1. Management authority for infestations in the Storrie and Rich Fire Watersheds Table 2. Prioritization for treating invasive plant infestations Table 3. Current management goals and proposed initial treatment methods for known invasive plant infestations on NFS lands within Storrie IPT Project area Table 4. Proposed methods for the treatment of invasive plants in the Storrie IPT Project Table 5. Herbicide Application Rate limits Table 6. Project design features Table 7. Stream buffers for herbicide application Table 8. Chemical Treatment Acreage Caps for Each Stream Reach Table 9. Threatened, Endangered, Candidate, and R5 Forest Service Sensitive plant species known in analysis area Table 10. Definitions of terms used to distinguish herbicides and application methods. Adapted from Gover (1997) Table 11. Comparison of the herbicides proposed for controlling invasive plant species in the Storrie IPT Project area Table 12. Chemical Treatment Annual Acreage Caps for Each Stream Reach Table 13. Determinations for Threatened, Endangered, Proposed, Candidate and Sensitive Animal Species that potentially occur within the Storrie IPT Project area Table 14. Analysis of Management Indicator Species (MIS) habitat in or adjacent to the Storrie IPT Project area Table 15. Category for analysis of effects of Storrie IPT Project on Migratory Birds List of Figures Figure 1. Vicinity map... 4 Figure 2. Treatment selection process Figure 3. Map of sub-watersheds associated with project Figure 4. Current proposed treatment polygons near the confluence of the NFFR and the EBNFFR; a few scattered occurrences except along Caribou Road where they are more contiguous Figure 5. Example area showing the cumulative effects analysis area buffers at the confluence of the NFFR and EBNFFR iv

7 Mt. Hough Ranger District, Plumas National Forest Introduction We are proposing to treat priority invasive plant infestations on up to 200 acres annually, using a combination of manual, mechanical, cultural, and chemical methods. These actions are proposed to be implemented across on the Mt. Hough Ranger District of the Plumas National Forest. We prepared this environmental assessment (EA) to determine whether implementation of the invasive plant treatments may significantly affect the quality of the human environment and thereby require the preparation of an environmental impact statement. By preparing this EA, we are fulfilling agency policy and direction to comply with the National Environmental Policy Act (NEPA). For more details of the proposed action, see the Proposed Action and Alternatives section of this document. Background The Storrie Fire burned approximately 50,000 acres in 2000 and the Rich Fire burned approximately 6,500 acres in Both of these fires occurred in the Feather River Canyon northwest of Quincy, California. In July of 2008, the U.S. Forest Service received a 102 million dollar settlement for the Storrie Fire and in August of 2010, the U.S. Forest Service received a 17.3 million dollar settlement for the Rich Fire. Fire settlement funds received by the Forest Service for restoration of the affected areas provide a unique opportunity to restore ecosystem health, function, and resilience. Invasive plants (also known as noxious weeds) can have strong negative effects on wildland values. The location, severity, and management of the Storrie and Rich Fires have created a very high risk for invasive plant introduction and spread within the watersheds affected by the fires. The Storrie and Rich Fire Areas Invasive Plant Treatment Project (hereafter, Storrie IPT Project), is proposed to address these concerns. In 2012, after initiation of the planning of this project, the Chips Fire burned approximately 77,000 acres, overlapping the project area. The location, severity, and management of the Chips Fire, as well as the impacts associated with post-fire management activities, contribute to the risk for invasive plant introduction and spread within the Storrie IPT Project area. Management Direction Invasive species were identified by the Chief of the Forest Service as one of the four greatest threats to forest health (for more information, see Invasive plants can have strong negative effects on wildland values. They reduce the quality and quantity of habitat for wildlife and fish by reducing forage, shelter, and cover. Rare native plants can be directly displaced by spreading invasive plant infestations. Invasive plants can also reduce an ecosystem s capacity to provide clean water, productive soils, and defensible space for fire management. They can also degrade recreational opportunities by impeding access and impacting scenic qualities. The proposed action and alternatives are guided by the Plumas National Forest Land and Resource Management Plan (PNF LRMP) (USDA 1988) as amended by the Sierra Nevada Forest Plan Amendment Final Environmental Impact Statement and Record of Decision (SNFPA FEIS and ROD)(USDA 2004a, 2004b). 1

8 Storrie and Rich Fire Areas Invasive Plant Treatment Project The SNFPA ROD directs the Forest Service to undertake invasive plant management and to prioritize activities in the following order: 1) prevent new introductions of invasive species; 2) conduct early treatment of new infestations; and 3) contain or control established infestations (USDA 2004b, page 36). Forest Service Manual 2900 (2011) directs the Forest Service to use an integrated pest management (IPM) approach for invasive species control, to develop and utilize site-based and species-based risk assessments to prioritize the management of invasive species infestations, and to use a structured decision-making process and adaptive management to help identify and prioritize invasive species management approaches and actions. IPM requires integration of multiple program components (prevention, early detection/rapid response, mapping, control, re-vegetation and monitoring) with site-specific selection of treatment methods (mechanical, chemical, biological and cultural) based on factors including effectiveness, feasibility, ecological impact, and safety. This project focuses on treatment because the Forest Service has existing procedures in place for invasive plant prevention, inventory, and monitoring. When prioritizing infestations for treatment, the management goal and treatment strategy for each infestation would vary according to the target species biology, the size of infestation, the values at risk from the infestation, and treatment effectiveness. Land allocations within the Plumas National Forest have been allocated to certain primary uses through two planning processes: the original PNF LRMP (USDA 1988) development process and the SNFPA ROD (USDA 2004a, 2004b). Each of these plan components includes standards and guidelines for land and resource management unique to each land allocation. Many of these allocations overlap. Certain allocations (called prescriptions) in the PNF LRMP are still applicable in whole or in part, because they were not superseded by the SNFPA ROD. Those allocations still in effect for the Storrie IPT Project area are discussed further below. The PNF LRMP (USDA 1988) displays management areas, which include descriptions, standards and guidelines, prescription allocations, and management objectives specific to each management area (pages ). A list of management areas and associated criteria that overlap with the Storrie IPT Project is available in the project record at the Mt. Hough Ranger District, Quincy, California. There are no management objectives or standards and guidelines included in the PNF LRMP specific to the treatment of invasive plants. The SNFPA ROD includes management goals and are found in the SNFPA ROD, Appendix A: Management Direction, A. Management Goals and Strategies, pages These management goals and strategies include Noxious Weed Management. Old Forest Ecosystems and Associated Species; Aquatic, Riparian, and Meadow Ecosystems and Associated Species; Fire and Fuels Management; and Lower Westside Hardwood Ecosystems are management goals and strategies that do not apply to the Storrie IPT Project. Land allocations from the SNFPA ROD that overlap with the Storrie IPT Project area include: Proposed Wild and Scenic River, Proposed Special Interest Areas, Recreation Areas, Wildland Urban Interface, Northern Goshawk Protected Activity Centers (PACs), Spotted Owl PACs and Home Ranger Core Areas (HRCAs), range allotments, bald eagle territory, and critical aquatic refuges. Congressionally designated land allocations that overlap with the project area include the Bucks Lake Wilderness Area and the Chips Creek Inventoried Roadless Area. 2

9 Mt. Hough Ranger District, Plumas National Forest Proposed Project Location The project area is located on National Forest System (NFS) lands administered by the Plumas National Forest in the watersheds affected by the Storrie (2000) and Rich (2008) wildfires. The Storrie and Rich Fires both occurred within the North Fork Feather River watershed, approximately 20 miles northwest of Quincy, California (Figure 1). The project area includes approximately 90,000 acres, of which up to 200 acres would be treated annually. The Storrie Fire of 2000 burned on both the Plumas and Lassen National Forests; this project does not include lands administered by the Lassen National Forest. In order to address adjacent invasive plant infestations that are at high risk of infesting the Storrie and Rich Fire areas, the proposed project area was selected using hydrological boundaries; it consists of the lands administered by the Mt. Hough Ranger District (MHRD) on the Plumas National Forest that occur within the 7th field sub-watersheds that were affected by the Storrie and Rich Fires. Watershed boundaries were set using hydrological units designated by the United States Geological Survey (USGS); the 7th field sub-watershed is one of the smallest recognized by USGS (5,000 to 8,000 acres). The Queen Lily, North Fork, and Gansner Campgrounds, portions of the Bucks Lake Wilderness, the Pacific Crest Trail, and the proposed Red Hill Special Interest Area (SIA) are located within the project area. The project area intersects Highway 70, Caribou Road (NFS road 27N26), and NFS road 26N22 and 26N26. Portions of the following township, ranges, and sections occur within the project area: T23N, R5E, sections 1 and 12; T23N R6E sections 5 and 6; T24N R5E sections 24 and 25; T24N R5E section 36; T24N R6E sections 1-5, 8-17, 19-22, 28-30, 32, 33, and tracts 37-41; T24N R7E sections 1-8, 10-12, 17, and 18; T25N R6E sections 1, 2, 10-16, 21-28, and 33-36; T25N R7E sections 1-36; T25N R8E sections 2-11, 15-23, and 25-36; T26N R6E sections 35 and 36; T26N R7E sections 1, 3, 4, 7-10, and 12-36; T26N R8E sections 2,6-11, 14-23, and [Mount Diablo Base Meridian (MDBM)]. 3

10 Storrie and Rich Fire Areas Invasive Plant Treatment Project Figure 1. Vicinity map 4

11 Mt. Hough Ranger District, Plumas National Forest Need for the Proposal Purpose of Project The purpose of this project is to reduce the spread of infestations that threaten wildland values in a timely and cost-effective manner, while protecting human health and critical ecosystem functions. The proposed project would also create the ability to rapidly respond to new (currently nonexistent or undocumented) invasive plant infestations and new species and adaptively manage existing invasive plant infestations. This action responds to the goals and objectives outlined in the Plumas National Forest Land and Resource Management Plan (PNF LRMP), as amended by the Sierra Nevada Forest Plan Amendment (SNFPA) Record of Decision (ROD), and helps move the project area towards desired conditions described in that plan (USDA 2004b, pg 36). Need for Action This proposal is needed because invasive plants are known at approximately 776 locations and are adversely impacting at least 213 acres within the watersheds affected by the Storrie and Rich Fires 1. The location, severity, and management of the Storrie and Rich Fires have created a very high risk for invasive plant introduction and spread within the watersheds affected by the fires. During both fires and during the subsequent Chips Fire, fire suppression and very high burn severity resulted in considerable ground disturbance, leaving favorable conditions for the establishment and spread of invasive plants. Furthermore, all three of these fires occurred near high traffic areas, such as roads, trailheads, campgrounds, and facilities, which were heavily infested with invasive plants. Approximately 85 percent of known invasive plant infestations within the project area occur within 500 feet of high traffic areas. These infested areas can act as source populations for invasive plant introduction and spread into adjacent uninfested areas, including the nearby Bucks Lake Wilderness and the proposed Red Hill Special Interest Area (SIA). Invasive plants do not recognize land ownership boundaries and can spread indiscriminately between National Forest System (NFS) lands and neighboring areas. Effective invasive plant management requires cooperation with adjacent public land managers and private land owners. Within the project area, there are invasive plant infestations that occur partially or entirely on private lands. Management of infestations on private land are not proposed in this project. Nonetheless, member organizations of the Plumas Sierra Weed Management Area (PSWMA) have been using manual, chemical, and biological methods to eradicate invasive plant on nearby non-nfs lands for the past several years. In addition, Pacific Gas and Electric Company (PG&E) is actively treating invasive plants on a combination of private and NFS lands within the Rock Creek Cresta and Bucks hydropower license area and is planning additional treatments under the PG&E Vegetation Management Project (Appendix E). Lack of comparable, appropriate, and effective invasive plant treatment by the Forest Service could reduce the effectiveness of nearby efforts of other land managers, while a lack of coordination could result in undesired cumulative effects to NFS resources. 1 This includes known infestations on private property. 5

12 Storrie and Rich Fire Areas Invasive Plant Treatment Project Invasive plants migrate, establish, and spread rapidly and unpredictably. Some species spread at rates of eight to twelve percent per year (USDA 1999). New invasive plant species and new infestations of known species are discovered every year on NFS lands. Timeliness of action is important because the cost, difficulty, and potential adverse effects of invasive control increases with the scale of infestation. Treatment is more likely to be effective if infestations are treated when they are still small. Flexibility in treatment strategy is important because infestations may not respond predictably to treatment, they may shift or grow rapidly, and new invasive plant species and infestations can represent currently unforeseen threats to wildland values. Therefore, the Forest Service desires the flexibility to adapt to changing conditions and respond rapidly to invasive plant threats that may be currently unknown. Desired Condition New introductions of invasive plants are prevented, new infestations are rapidly treated, and established infestations are contained and controlled where they threaten wildland values or pose a high risk of spread to uninfested areas. The Forest Service is able to maintain a treatment capacity of at least 100 acres annually at an annual operating cost of less than $50,000. Human health and critical ecosystem functions, such as water quality and threatened, endangered, and sensitive species are protected during invasive plant treatment. 6

13 Mt. Hough Ranger District, Plumas National Forest Public Involvement and Tribal Consultation The project proposal was listed in the Schedule of Proposed Actions on April 9, The scoping period was held from April 9 to May Over 200 individuals, organizations, groups, or tribes were contacted with project information initiating the scoping period. Project proposal information was sent to mining claimants; mining organizations, companies, and groups; local agency officials such as Plumas County Board of Supervisors and California Department of Water Resources; organizations including Back County Horseman s Association and Californians for Alternatives to Toxics; Native American Tribes; special use permitees; and adjacent land owners. The Forest Service consulted with individuals, Federal, State, tribal, and local agencies during the development of this EA. A list of those consulted is available in the Coordination and Consultation section and further details are provided in the project record at the Mt. Hough Ranger District in Quincy, California. The project specific internet website and instructions for submitting comments in an effort to reduce paper were included in the mailed scoping materials. Two comments were received-one from an adjacent land owner and the other from the Pacific Crest Trail Association. Using the comments from the public (see Issues section), the interdisciplinary team developed a list of issues to address and a response to each individual comment. These issues and responses are listed in the Issue section below. Issues Issues (cause-effect relationships) serve to highlight effects or unintended consequences that may occur from the proposed action, providing opportunities during the analysis to reduce adverse effects and compare trade-offs for the responsible official and public to understand. Issues are best identified during scoping early in the process to identify the environmental effects to consider and develop proposals that minimize environmental impacts. However, due to the iterative nature of the NEPA process, additional issues may come to light at any time. An issue should be phrased as a cause-effect statement relating actions under consideration to effects. An issue statement should describe a specific action and the environmental effect(s) expected to result from that action. Cause-effect statements provide a way to understand and focus on the issues relevant to a particular decision. There is no set of standard issues applicable to every proposal, so it is important for the Responsible Official to consider a variety of laws, regulations, executive orders, and input, with the help of the interdisciplinary team. The Responsible Official approves issues to analyze in depth by the interdisciplinary team in the environmental analysis (FSM ). It is often helpful to group similar issues by common resources, cause-effect relationship, common geographical area, or those linked to the same action. The Forest Service separated the scoping comments into two groups: Category A and Category B issues. Category A issues were defined as those directly or indirectly caused by implementing the proposed action. Category B issues included those: 1) outside the scope of the proposed action; 2) already decided by law, regulation, Forest Plan, or other higher level decision; 3) irrelevant to the decision to be made; 4) conjectural and not supported by scientific or factual evidence; or 5) the comment could not be phrased as a cause-effect relationship. 7

14 Storrie and Rich Fire Areas Invasive Plant Treatment Project Category A Issues Issue 1. Recreational experience on the Pacific Crest Trail (PCT) is not protected. Currently, there are no herbicide applications proposed for the PCT. However, the Forest Service is concerned that the yellow starthistle on the private property at the Pacific Crest Trail Association (PCTA) trailheads would eventually spread to NFS lands and may require treatment. The Forest Service welcomes the PCTA s suggestion to use PCTA volunteers to attempt to control these infestations through manual or mechanical methods; we would work with the PCTA to coordinate such efforts. However, should these methods not prove effective or feasible, then herbicide treatment may be the only alternative to prevent further spread on the PCT. The Forest Service would like to retain the flexibility to use herbicides in these circumstances. Removal of invasive plants along the PCT would likely improve the recreational experience. A target species near the PCT is yellow starthistle which is a menace to hikers and pack stock; its sharp spines irritate hikers, reduce camping and hiking opportunities, and make the plants unpalatable--sometime even toxic--to pack stock. Additionally, as native plants species recolonize trailside areas currently occupied by invasive plants, the area's ecological integrity would likely increase, creating a more aesthetic trail experience. While chemical treatment would include signage to notify trail users of treatments and dyes to mark treated areas, these impacts would be very short-term, lasting less than a few weeks annually. Controlling invasive plants would reduce the likelihood of spread of invasive plants to uninfested areas by way of hikers and pack stock, which would also improve the recreational experience. Vectors, such as trails, roads, and utility corridors, present a high risk of spread and as such are considered high priority for treatment; within the project, trails are prioritized second only to treatment of new species, species with very few isolated infestations, and infestations that occur in a Wilderness or Special Interest Areas. Issue 2. Concern over the use of herbicides Chemical treatment is an important tool in the Forest Service s integrated pest management approach and critical for meeting the purpose and need for this project. With over 90 acres of priority weed infestations many of which are adjacent to roads it would likely be infeasible and substantially less effective and less safe for workers to treat all infestations by manual or mechanical treatment alone. FEASIBILITY For many annual invasive plants with short lifespans, effective manual or mechanical treatment is limited to a few weeks. With over 90 acres of priority weed infestations, it would likely be infeasible to conduct all manual and mechanical treatments during the short seasonal window. For a comparison, manual treatment of yellow starthistle averages 10 to 20 hours per acre of manpower (from past treatment records of the project area), whereas directed spray or broadcast treatment only requires less than one hour per acre. So, a 10-person crew working all day long for one month would not likely complete initial manual treatment during the seasonal window and completion of follow-up treatments would be highly unlikely. SAFETY Along busy roadside areas, the risk of injury from motor vehicles to workers presents a serious workplace safety concern. Manual or mechanical treatment would require workers to spend extended periods of time on busy roads, as these treatment methods are labor-intensive. 8

15 Mt. Hough Ranger District, Plumas National Forest The risk of workers conducting broadcast or directed spray chemical treatment via truckmounted spray vehicles or hose reels would likely be much lower, because these treatments require exponentially less time. EFFECTIVENESS For certain species, manual and mechanical treatment has been shown to be ineffective. For example, at several infestations on the Plumas and Lassen National Forests, Canada thistle has been pulled manually 2-6 times per season for multiple years; manual treatment has produced little discernible control. Several studies support our experience that repeat pulling exhibits variable effectiveness and is often prohibitively time consuming (Nuzzo 1997; Zouhar 2001; Bond and Turner 2004). For many weed species, herbicide is the most effective tool. Consideration of treatment effectiveness while not the sole criteria for treatment selection is an important component of integrated pest management. Conducting ineffective treatments wastes time and money, puts workers at risk unnecessarily, and can still result in negative impacts to resources. The Plumas National Forest is committed to an integrated pest management approach that utilizes the least impactful methods than can achieve effective control. Control would only occur when careful consideration indicates that leaving an invasive plant infestation unchecked would result in more damage than controlling it with available methods. Generally, chemical treatment is considered after other methods are deemed ineffective or infeasible. For all chemical treatment, project design features, such as stream buffers and limited operating periods, would be employed to protect resources and human safety (Table 6 and Appendices C and D). Furthermore, assuming that initial chemical treatment is effective, the volume of herbicide used per acre is expected to decrease over time and follow-up non-chemical treatment will become more feasible. Issue 3. Herbicide application may negatively affect honeybees because the herbicides selected are not non-toxic to bees and the eradication of invasive plants may reduce pollen available for bee forage. The Forest Service has created project design features (Table 6, PDFs #1-4 and #24) targeted at minimize exposure to non-target organisms, including honey bees. There are drift restrictions, such as applying only during relatively calm conditions, using large droplets, using only groundbased equipment, applying within two feet of target plants, to minimize drift onto water or nontarget areas. We will avoid spraying while an invasive plant is in bloom or during the middle of the day, when pollinators are the most active. Furthermore, the Forest Service has considered toxicity to non-target organisms as the selection of the five proposed herbicides. The Forest Service has conducted extensive risk assessments on the ecological toxicology of the herbicides selected. Many herbicides were not selected because of a lack of information regarding ecological toxicology. In addition, several herbicides for which the Forest Service does have extensive risk assessments including 24-D, Triclopyr BEE, and certain formulations of glyphosate were also deliberately excluded from the project because of concerns over potential effects to non-target species. Although direct exposure to pesticides can kill queen or worker bumble bees, and cause minor to lethal effects to larvae that feed on pesticide-contaminated food, this project will utilize herbicides and not insecticides. Most herbicides probably do not harm bees directly, though their use can reduce nectar supplies, which in turn limit bumble bee colony success (Schweitzer et al. 2012). Insecticides, especially microencapsulated formulations that can be transported back to the hive, are generally of greater concern than herbicides. 9

16 Storrie and Rich Fire Areas Invasive Plant Treatment Project Category B Issues Issue 4. PCT users would not be notified of proposed treatments. The proposed action includes an annual public notification. While there would not be a formal comment period for the public notification, there would be time between the notification and treatment for coordination with the public. Issue 5. Oak and manzanita are marked with "Noxious Weed" flagging. Oak and manzanita are not considered invasive plants by the Plumas National Forest. No treatment of oak or manzanita is proposed. Sometimes, flagging is hung on adjacent trees and shrubs because the target invasive plants die back completely during the winter. Issue 6. Aerial herbicide application will damage recovering trees. Aerial herbicide application is not proposed. Proposed Action and Alternatives The Proposed Action and the No Action alternatives were studied in detail. More details and information are provided for each alternative below. Alternative A Proposed Action (Multi-treatment) Treat currently identified priority invasive plant infestations at approximately 274 locations (94 acres); establish a prioritization and treatment protocol that would allow for adaptive management of known infestations and evaluation of expanding and newly arising invasive plant occurrences for treatment; and, treat currently unidentified invasive plant infestations up to 200 acres annually. Invasive plants proposed for treatment include barbed goatgrass, hoary cress, spotted knapweed, yellow starthistle, squarrose knapweed, Canada thistle, Scotch broom, Dyer s woad, tall whitetop, Himalayan blackberry, and medusahead. Alternative A Proposed Action (Multi-treatment) is described in more detail in Proposed Action section below. Alternative B No Action Under the No Action alternative, current management plans would continue to guide management of the project area. Primarily manual control efforts would occur under this alternative. No mechanical, chemical, or cultural treatment activities would be implemented, except those for which there is existing environmental analysis. Alternatives Considered but Eliminated from Detailed Study Federal agencies are required to rigorously explore and objectively evaluate all reasonable alternatives and to briefly discuss the reasons for eliminating any alternatives that were not developed in detail (40 CFR ). Public comments received in response to the Proposed Action provided suggestions for alternative methods for achieving the purpose and need. Some of these alternatives may have been outside the scope of the need for the proposal, duplicative of the alternatives considered in detail, or determined to be components that would cause 10

17 Mt. Hough Ranger District, Plumas National Forest unnecessary environmental harm. Therefore, a number of alternatives were considered, but eliminated from detailed study for the reasons summarized below. Alternative C Aerial Application of Herbicides Aerial application of herbicides was not considered in detail because the potential risks to human health and resources outweigh the potential habitat improvements that might be gained through treatment. The prioritized infestations are small enough to allow for cost-effective ground-based herbicide treatments, eliminating the need to consider the less targeted approach of aerial application. Alternative D Herbicide Treatment Alone The use of herbicides alone (i.e. without any other control methods) was not considered because it does not meet the Forest Service s need to pursue an integrated pest management approach (IPM). IPM requires the consideration of a variety of treatment methods and selection of a treatment method based on effectiveness, feasibility, ecological impact, and safety. Use of other methods will allow for minimizing the amount of herbicide use on the Forest. Alternative E No Additional Buffers over Label Directions The use of herbicides according to label direction with no additional buffers was not considered in detail because it does not conform to USFS Best Management Practices for Water Quality (BMPs). BMPs require buffers for all herbicide applications near perennial streams. The Proposed Action includes application of certain herbicides using specific application methods (Table 6) with no additional buffers for areas away from live water. Alternative F Use of Alternative Substances to Registered Pesticides The use of alternatives to registered pesticides as advocated by some environmentallyconcerned groups was not considered in detail because of a lack of risk assessments and inconsistent efficacy results for these substances. Many alternative substances (e.g. hot foam, hot water, Burn-out, corn gluten, sugar, etc.) are not registered by the Environmental Protection Agency as herbicides; therefore, assessments of their risks to resources that have been subjected to the same testing and disclosure requirements as the proposed herbicides do not exist. Available information on alternative substances indicates limited or unknown effectiveness on perennial species. For example, corn gluten is considered effective on seedlings that are just starting to grow (i.e. prior to much root elongation), so it would not be effective in controlling established, aggressive perennials or many larger annuals. The ineffectiveness of manual and mechanical treatments on deep-rooted sprouting perennials (e.g. Canada thistle, hoard cress) is the primary reason that the Forest Service is considering the use of herbicides for these types of invasive plants. In addition, compared to manual treatment via hand-pulling or select or directed spray herbicide application, the application of alterative substances tends to be less targeted due to their modes of action or application method. Therefore, they represent a higher risk to nontarget species, particularly native vegetation. 11

18 Storrie and Rich Fire Areas Invasive Plant Treatment Project Alternative G Use of Prescribed Fire The use of prescribed fire was not considered in detail because of concerns with wildland fire risk and potential difficulties in implementing effective treatment. Terrain and fire weather conditions in the Feather River Canyon, as well as location of infestations in high traffic areas or low-flammability fuels types, severely restrict the feasibility of prescribed burning within the project area. Furthermore, the effectiveness of treatment depends on the season of the burn, with most effective invasive plant control often obtained through summer or fall burns; lateseason burning is frequently rendered infeasible by fire weather conditions or concerns for adjacent resources (e.g. private land, structures, timber stands). In addition, certain invasive plants considered in this proposal, particularly deep-rooted perennial species, respond favorably or unpredictably to burning; prescribed burning could result in the spread of invasive plants. If prescribed burning is considered the only effective and feasible treatment for a particular infestation, then an additional environmental analysis would be undertaken to allow for such treatment. Within existing NFS facilities, pile burning may be used to consume invasive plant materials that have been manually or mechanically removed. Alternative H Use of Grazing The use of grazing was not considered in detail because safety concerns and the lack of grazing allotments containing invasive plants severely restrict the feasibility of grazing within the project area. Most infestations do not occur in designated grazing allotments. Many occur in high traffic areas where grazing animals would be at risk of collision with vehicles. Additionally, most occurrences are small enough that there would not be sufficient forage to warrant the use of grazing animals. Grazing will continue to be considered as an invasive plant control tool on the Plumas National Forest. If grazing is considered the only effective and feasible treatment for a particular infestation, then an additional environmental analysis would be undertaken to allow for such treatment. 12

19 Mt. Hough Ranger District, Plumas National Forest Proposed Action The Forest Service proposes to: 1) treat currently identified priority invasive plant infestations at approximately 274 locations (94 acres); 2) establish a prioritization and treatment protocol that would allow for adaptive management of known infestations and evaluation of expanding and newly arising invasive plant occurrences for treatment; 3) treat currently unidentified invasive plant infestations up to 200 acres annually. Treatment would consist of manual, mechanical, chemical, or cultural methods, or a combination of these methods (described below). The project s total annual treatment area would be capped at 200 acres; chemical treatment would be capped at 100 acres total annually, by individual stream reach, and by maximum volume (described below). If additional species are added to the Plumas National Forest (PNF) Invasive Plant List (USDA 2012), infestations of these species would also be considered for treatment. Treatment methods for new infestations would be limited to those analyzed in the proposed action and all project design features would apply to all new treatments. Project operations would begin in 2014 and continue until weed management goals are met or until such time as new information warrants additional environmental analysis. This project would occur in addition to the treatment of approximately 112 infestations (56 acre) currently undertaken by PG&E on NFS lands within its Rock Creek Cresta license area. In the watersheds affected by the Storrie and Rich Fires, there are 336 invasive plant infestations (60 acres) entirely on private land and are not under consideration for treatment (Table 1). Table 1. Management authority for infestations in the Storrie and Rich Fire Watersheds Land Status Weed Management Authority Number of infestations Privately owned Managed by PG&E Managed by other private owners 40 5 NFS Lands Managed by PG&E Managed by Forest Service Treatment proposed No treatment proposed 35 3 Acres currently identified Total Because not all invasive plant infestations are equally threatening to wildland values, infestations would be prioritized based on their size, their threat to wildland values, and their likelihood to spread into uninfested areas (Table 2). Prioritization would be conducted by the project manager, with input from an interdisciplinary team. The goal of prioritization would be to concentrate treatment resources on the highest priority infestations and to minimize the total long-term workload, cost, and resource impact of invasive plant control. Control would occur only when careful consideration indicates that leaving an invasive plant infestation unchecked would result in more damage than controlling it with available methods. In general, the Forest Service would act to prevent new infestations and assign highest priority to existing infestations that are the fastest growing, most disruptive, and affect the most highly valued resources. As 13

20 Storrie and Rich Fire Areas Invasive Plant Treatment Project such, there are 35 currently identified invasive plant infestations (3 acres) where treatment is not proposed (Table 1). Table 2. Prioritization for treating invasive plant infestations Priority Description Eradicate: Newly discovered species Species with very few isolated infestations forest-wide Any infestations that occur in a Wilderness, Special Interest Area, or Research Natural Area Control or eradicate: Fast-growing species that: Impact high value resources Are relatively isolated from other infestations; OR Occur along spread vectors, such as roads, campgrounds, trailheads, administrative facilities, gravel pits, parking lots Eradicate: Small, isolated infestations of slow-growing species Control: Fast-growing species that are rapidly expanding Control: Large infestations that: Are adjacent to other large infestations Occur in highly disturbed areas Do not occur along spread vectors Are not rapidly spreading Species for which available technology has not proven effective Contain: Species of very wide distribution where control or eradication is not deemed feasible For most species encountered in the project area, infestations are both small and isolated, so eradication would be the management goal (Table 3). However, for species with large or widespread infestations, the management goal would depend upon the threat and spread risk. A few species (i.e. Himalayan blackberry, Canada thistle) are so widespread that eradication is not a feasible goal. Attempts would be made to contain spread through prevention measures; however, treatment would only be considered when infestations of these species threaten high value resources. For example, in 2011, the first ever Himalayan blackberry infestation was recorded in the Bucks Lake Wilderness; manual treatment would be undertaken to eradicate this infestation as it presents a great risk to the otherwise uninfested Wilderness. The Forest Service proposes to use the following treatments for any known invasive plant infestations within the project area and for new infestations. For a full description of treatment methods refer to Table 4. Manual treatment Techniques include digging, hand pulling, clipping, mulching, or tarping. Mechanical treatment Techniques include pulling with tools, mowing, cutting, brushing, trimming, or digging with heavy equipment. Acreage treated by heavy equipment is expected to be small estimated at less than 10 acres annually. Chemical treatment Herbicides would be considered where manual or mechanical treatment is infeasible or ineffective. Up to 100 acres may be treated annually using 14

21 Mt. Hough Ranger District, Plumas National Forest herbicide. 2 No aerial application of herbicides is proposed in this project. Application methods would include select, directed spray, or broadcast spray. Cultural treatment Cultural treatment would be limited to thermal methods in which plants are heated and killed through desiccation. Prescribed burning and grazing are not considered feasible within the project area. Acreage treated by cultural methods are expected to be very small estimated at less than 5 acres annually. Selection of treatment method would follow the process outlined below in Figure 2. It would be conducted by the project manager, with input from an interdisciplinary team. Initial treatment methods were selected based on analysis conducted as a part of the Storrie Fire Noxious Weed Management Strategy (USDA 2010). Generally, chemical treatment is considered after other methods are deemed ineffective or infeasible. Currently, chemical treatment is being considered as an option for treatment of 3 of the 11 species known from within the project area; the remaining 8 species currently occupy such a small area that it is expected that they can be treated entirely by manual methods (Table 3). There are an additional 14 invasive plant species listed on the PNF Invasive Plant List (USDA 2012) that are not currently found in the project area; any species on the PNF Invasive Plant List may be prioritized for treatment. Treatment methods for new infestations would be limited to those analyzed in the proposed action and all project design features would apply to all new treatments. Table 3. Current management goals and proposed initial treatment methods for known invasive plant infestations on NFS lands within Storrie IPT Project area3 Species (common name) Aegilops triuncialis (barbed goatgrass) Cardaria pubescens (hoary cress) Centaurea maculosa (spotted knapweed) Centaurea solstitialis (Yellow starthistle) Centaurea virgata ssp. squarrosa (squarrose knapweed) Proposed Initial Treatment Method Number of Acres currently Management Goal infestations identified Eradicate Imazapyr - directed spray Mechanical + Glyphosate Eradicate directed spray Manual treatment Eradicate Manual treatment Eradicate Eradicate Manual treatment Eradicate Aminopyralid - directed spray Eradicate Glyphosate - select Aminopyralid or glyphosate - Control directed spray Aminopyralid - broadcast Control spray Manual treatment Eradicate 1 <0.1 No treatment currently planned; Monitor for future Contain treatment needs 2 <0.1 Cirsium arvense (Canada thistle) Cytisus scoparius Eradicate Mechanical + cultural Annual acreage cap for chemical treatment was based on proposed treatment of known infestations (~90 acres) plus additional acreage for a) expanding known infestations and b) new (currently nonexistent or undocumented) infestations. It does not include chemical treatments currently underway by PG&E. 3 This excludes known infestations on private property. 15

22 Storrie and Rich Fire Areas Invasive Plant Treatment Project Species (common name) (Scotch broom) Isatis tinctoria (Dyer s woad) Lepidium latifolium (tall whitetop) Rubus discolor (Himalayan blackberry) Taeniatherum caput-medusae (medusahead) Proposed Initial Treatment Method Number of infestations Acres currently identified Management Goal treatment Manual treatment Eradicate Manual treatment Eradicate No treatment currently planned; Monitor for future Contain treatment needs Eradicate Manual treatment 1 <0.1 Cultural + Imazapyr - directed Control spray Managed by PG&E Eradicate, Contain, and Control various known infestations on NFS land Total The project area intersects the 23,958 acre Bucks Lake Wilderness. Currently, there is only one invasive plant infestation in the Bucks Lake Wilderness. The use of herbicides, motorized equipment, or mechanical transport in Bucks Lake Wilderness is not anticipated and would not be undertaken without Regional Forester approval. Herbicides Proposed Herbicides are already in use within the administrative boundary of the Plumas National Forest by private landholders, PG&E, and county and state agencies. However, federal agencies, such as the Forest Service, must first go through an environmental review process before using specific herbicides in order to comply with the National Environmental Policy Act (NEPA). The following herbicides are proposed: Aminopyralid (trade names include Milestone ): This herbicide provides mainly postemergence control of many annual, biennial, and perennial invasive plant species, including brooms and yellow starthistle. It is selective and it does not injure grasses and many broadleaf species, though it can injure legumes (Fabaceae) and members of the sunflower family (Asteraceae). For some species, aminopyralid can provide residual (preemergence) control, thereby reducing the need for retreatment. Within the soil, aminopyralid does not persist for long (less than 2 weeks) and is relatively immobile. Chlorsulfuron (trade names include Telar ): This herbicide provides pre- and postemergence control of many broadleaf invasive plants and some annual grasses. It is selective and does not injure most perennial grasses. It is absorbed by the leaves and roots. It is generally active in the soil and tends to leach in permeable soils. It can remain is soil for 1-3 months. Broadcast application is not proposed. Glyphosate (trade names include Accord, Aquamaster ): This is one of the most widely used herbicides available. It is non-selective (broad spectrum), so it may injure non-target plants. It provides only post-emergent control and is not absorbed through roots. It is nonpersistent and relatively immobile in soil. Plants treated with glyphosate can take several 16

23 Mt. Hough Ranger District, Plumas National Forest weeks to die; repeat application is often necessary to remove plants that were missed during the first application. Broadcast application is not proposed. Imazapyr (trade names include Habitat ): This herbicide provides mainly post-emergence control of annual and perennial grasses, some broadleaf species, and woody species. It is non-selective (broad spectrum), so it may injure non-target plants. For some species, imazapyr can provide residual (pre-emergence) control, thereby reducing the need for retreatment. Broadcast treatment is not proposed. Triclopyr (trade names include Garlon TM 3A, Milestone VM Plus): This herbicide provides pre- and post-emergence control of woody and broadleaf plants and resprout control as stump treatment on woody plants. It is selective and has little impact on grasses. It can reside in soils for up to 6 months. Formulations containing triclopyr butoxyethyl ester (BEE) are not being considered. Triclopyr can be used in combination with aminopyralid in a premixed formulation (e.g. Milestone VM Plus). Herbicides would be applied in accordance with 1) product label directions; 2) California Department of Pesticide Regulation requirements; 3) Forest Service best management practices for water quality (USDA Forest Service 2011); and 4) Forest Service direction (FSM 2080, 2150 and 2200) and Handbook (FSH ). This project would include a Pesticide Use Spill Plan. Prior to any herbicide use, a Pesticide Use Proposal (PUP) (FS ) and safety plan (FS ) would be completed by the project lead and approved by the Forest Supervisor. The Forest Supervisor has delegated authority to District Rangers to approved projects proposing groundbased applications of non-restricted use chemicals. The Storrie IPT Project is only proposing ground-based applications of non-restricted use chemicals. The annual acreage cap for chemical treatment is 100 acres and was based on initial proposed treatment of known infestations (~90 acres) plus additional acreage for expanding known infestations and new (currently nonexistent or undocumented) infestations. Assuming that initial treatment is effective, over time, the volume of herbicide used per acre is anticipated to decrease at each treatment site and for the entire project. The acres infested, however, may remain static for an extended time, as infestations are controlled and reduced in density, but not eradicated. A maximum volume per acre is set for each herbicide (Table 5). Project design features contain additional resource-specific restrictions on chemical treatment (Table 6), including setting stream buffers for each herbicide and application method (Table 7) and capping treatment in the aquatic influence zone (150 feet from water s edge) for each stream reach (Table 8). Proposed herbicide treatments would be implemented during the time of the year when application would be most effective for each species and its phenology. If new or resurgent target plants emerge, then the infestation may be promptly retreated to ensure effective control. The project includes a strategy to monitor whether treatments are effective and implemented as designed. Surfactants and marker dyes may be added to any herbicide application, unless limited by specific project design features. Surfactants and marker dyes are adjuvants compounds that improve mixing, application, or effectiveness of an herbicide. Surfactants enhance absorbing, spreading, sticking, and other properties of herbicides, allowing for use of lower application rates. Marker dyes are used to visually confirm the location of the herbicide application; this assists applicators in limiting application to target plants and reduces the risk of application to non-target organisms and areas. 17

24 Storrie and Rich Fire Areas Invasive Plant Treatment Project Project design features Under certain conditions, some of the proposed methods may present a risk to human health or critical ecosystem functions, such as water quality and threatened, endangered, and sensitive species. In order to ensure that human health and critical ecosystem functions are protected during treatment, an interdisciplinary team developed project design features that would a) set safety guidelines, including safe handling of chemicals and public notification prior to treatment; and b) limit the scope of certain treatments near certain resources. For a full list of project design features refer to Table 6). Project design features are critical to the project s goal of rapidly responding to changing conditions. They provide clear direction for protecting resources, while still allowing enough flexibility that new and expanding infestations can be effectively and rapidly treated. Project design features would apply to any treatment undertaken as part of this project, including new infestations, expanding infestations, and new species. Annual Implementation Review Process Changes in infestation conditions, treatment effectiveness, and resource conditions may result in the need to adapt treatment prescriptions and treat different locations. Accordingly, the project s annual program of work may vary spatially and proportionally by treatment method; this is a critical component of an IPM approach. Each year, prior to implementation, an annual treatment plan would be developed and it would be reviewed by resource specialists to ensure that the proposed treatment is within the scope of the Decision Notice. Notification on the Forest website would occur to ensure that landowners, partners, regulatory agencies, and Tribes are aware of the proposed treatments. This annual implementation review process is described in Appendix C. 18

25 Mt. Hough Ranger District, Plumas National Forest Yes Is infestation in RNA? No Station Director approval needed. Conditions of approval may dictate treatment method. Yes Apply appropriate design features and conduct manual treatment. Is manual treatment effective and feasible? Yes No Is infestation in Wilderness? No Regional Forester approval needed for mechanical, chemical, or thermal treatment. No Is mechanical or thermal treatment effective and feasible? Yes Yes Is select treatment feasible? Yes No Is chemical treatment effective and feasible? No Apply appropriate design features and conduct treatment. Yes Is directed spray treatment feasible? No No Are there resource concerns that would restrict use of this method? Yes Yes Is infestation within acreage limit for using broadcast spray? No Apply appropriate design features and conduct treatment. Yes Could another chemical be used? No Figure 2. Treatment selection process Do not treat or start over at the beginning of decision tree, assuming full control or eradication may not be possible. 19

26 Storrie and Rich Fire Areas Invasive Plant Treatment Project Table 4. Proposed methods for the treatment of invasive plants in the Storrie IPT Project Treatment Method MANUAL Hand Pulling Clipping Digging Mulching Tarping MECHANICAL Toolassisted pulling Mowing, cutting, brushing, trimming Heavy equipment CHEMICAL Select Directed spray Broadcast spray Description Pulling or uprooting plants by hand. It can be effective against certain shrubs, tree saplings, and herbaceous invasive plants, particularly annuals and tap-rooted plants. It is not effective against perennial invasive plants with deep underground stems and roots that are often left behind to resprout. Cutting or removing seed heads and/or fruiting bodies to prevent germination. This method is labor-intensive and feasible only for very small infestations. Using hand tools such as shovels and sharp shooters (shovels with a narrow blade). Covering with certified weed-free mulch such as rice straw, grass clippings, wood chips, or newspaper. Mulching is a non-selective treatment and may injure non-target plants. Placing tarps (visqueen, geocloth, or similar material) to shade out or solarize injure by long exposure to heat of the sun plants. Tarping is most effective when the soil is damp. Tarping is a non-selective treatment and may injure non-target plants. Using plant-pulling tools that are designed to grip the plant stem and provide the leverage necessary to pull out its roots (e.g. Root Talon, Weed Wrench). Tools vary in size, weight, and target plant size. Tools can be cumbersome and difficult to carry to remote sites. Mowing, cutting, brushing, or trimming plants to remove above-ground vegetation. It can reduce seed production and restrict target plant growth, especially in annuals cut before they flower and set seed; however, some species resprout vigorously when cut. These methods are non-selective and may injure non-target plants. These methods are often used in combination with herbicide treatments to decrease the amount of herbicide needed or increase herbicide effectiveness by allowing application to actively growing plant material, freshly cut stems, or new growth promoted by remove above-ground vegetation. Using heavy equipment (e.g. skid steer, excavator) to dig up or rip out shrubs or trees. Removal with heavy equipment is limited to dense stands and is not used on isolated plants, as it can injure non-target plants and cause considerable ground disturbance; this method is limited to trees and shrubs. These methods are often used in combination with herbicide treatments to decrease the amount of herbicide needed or increase herbicide effectiveness by allowing application to actively growing plant material, freshly cut stems, or new growth promoted by remove above-ground vegetation. Touching individual target plants with applicators containing herbicide. Because these methods involve direct application, there is a very low likelihood of drift or delivery of herbicides away from treatment sites. Select applications are used in sensitive areas, such as near water, to avoid applying herbicide on the soil, in the water, or to non-target plants. These methods can be used in more variable conditions than directed or broadcast spraying. Specific methods include: Dip & clip Cutting tool is first dipped in concentrated herbicide, then used to cut target plant; this may be used on individual or groups of target plants Hack & squirt, cut stump Herbicide is applied to cut surfaces, such as tree or shrub stumps, to eliminate or greatly reduce re-sprouts; this is used on individual target plants Wick, wipe, drizzle Target plants by touched with a wipe or wick containing herbicide; this may be used on individual or groups of target plants Spraying herbicide on individual target plants using a regulated nozzle. A regulator nozzle helps to concentrate application towards target plants. This method uses a backpack-mounted wand sprayer or a truck-mounted hose sprayer. Spraying herbicide to an entire infested area, rather than to individual target plants, using a regulated nozzle. This method uses a truck- or ATV-mounted boom sprayer and is limited to areas adjacent to roads and motorized trails. Broadcast methods are used for denser infestations where application to individual plants would not be feasible. No aerial applications of herbicides are included in this project. Herbicides will be applied according to label directions. Chemical treatments may include use of adjuvants such as surfactants and dyes. Adjuvants are materials that facilitate the activity of herbicides, such as the emulsifying, dispersing, spreading, wetting, or other surface modifying properties of liquids; and dyes assist the applicator in efficiently treating target plants as well as avoiding contact with herbicide-treated plants by showing which plants have been treated already. Herbicide use is timed to the growth stage and physiology of the target species. CULTURAL 20

27 Mt. Hough Ranger District, Plumas National Forest Treatment Description Method Using heat to desiccate and kill plants. Methods include steaming, flaming, torching, infrared, or microwave. While some equipment uses an open flame, this method does not include prescribed burning. Thermal treatment is only Thermal executed when weather and fuel conditions permit and requires certain fire safety precautions. This method is most effective for seedlings and plants in the rosette stage. It can be used in combination with other methods to treat seedlings that germinate after mature plants are removed. Although prescribed burning and grazing can be effective invasive plant treatment methods, they have been excluded from this project. Terrain, location of infestations in high traffic areas, and fire weather conditions severely restrict the feasibility of prescribed burning within the project area. Likewise, animal safety and the location of grazing allotments severely restrict where grazing could be considered. If either prescribed burning or grazing are considered the only effective and feasible treatment for a particular infestation, then additional environmental analysis would be undertaken to allow for such treatment. Within MHRD facilities, pile burning may be used to consume invasive plant materials that have been manually or mechanically removed. Table 5. Herbicide Application Rate limits Herbicide Active Ingredient measured as active ingredient (a.i.) or acid equivalent (a.e.) Aminopyralid (a.e.) Lowest Application Rate pounds (lb) active ingredient (a.i.) or acid equivalent (a.e.) per acre Expected Application Rate pounds a.i. or a.e. per acre Maximum Annual Application Rate pounds a.i.or a.e. per acre per year Maximum Annual Treatment number of treatments per site per year broadcast--1 directed/select--2 Chlorsulfuron (a.i.) Glyphosate (a.i.) Imazapyr (a.e.) Triclopyr-TEA (a.e.) broadcast directed/select broadcast--1 directed/select--2 Application rate ranges are those analyzed in SERA risk assessments, which considers likely USFS application methods and label recommended rates. Project design features and Mitigations In response to internal and external scoping on the proposal, mitigation measures were developed to ease some of the potential impacts the proposed action may cause. The project design features and mitigation measures are described below. These project design features are critical during implementation and will be included in the Annual Implementation Review Process (Appendix C). Table 6. Project design features ID Project design feature (PDF) PDF Purpose 1 Herbicide application will comply with product label directions and applicable legal requirements. To avoid or minimize the risk of soil, surface water, or groundwater contamination. To minimize risk to Special Status plants and wildlife as well as other biological resources. To ensure compliance with legal requirements. Compliance with BMP

28 Storrie and Rich Fire Areas Invasive Plant Treatment Project ID Project design feature (PDF) PDF Purpose 2 Herbicide formulations would be limited to those containing one or more of the following 5 active ingredients: aminopyralid, chlorsulfuron, glyphosate, imazapyr, and triclopyr. Herbicide applications would only treat the minimum area necessary to meet site objectives. 3 Herbicide application methods are limited to select (e.g. wicking, wiping, stem injection), directed spray (use of backpack sprayer or hand held nozzle to aim application at specific target species), and broadcast spray (truck or ATV mounted boom sprayers), as permitted by the product label and project design features. No aerial herbicide applications will occur. 4 Spray application drift control measures: 1) Only ground based equipment will be used 2) All applications will cease when weather conditions exceed those on the label 3) Applications will not be performed when the National Weather Service forecasts a greater than 70 percent probability of measurable precipitation (greater than 0.1") within the next 24 hour period 4) Applications will cease when wind speed exceeds 10 mph 5) Spray nozzles will produce a relatively large droplet size ( microns) 6) Low nozzle pressures will be used (15 psi) 7) Spray nozzles will be kept within 24 inches of target vegetation during spraying 8) A pressure gauge or pressure regulator will be required on each backpack sprayer 5 Herbicides will be applied by trained and/or certified applicators in accordance will label instructions and applicable federal and state pesticide laws. Mixing of herbicides will be supervised onsite by, at a minimum, a Qualified Applicator (QAC) certified by the State of California. 6 Personal Protective Equipment (PPE) will be used in accordance with the product label and California Department of Pesticide Regulation requirements. 7 Chemicals will be stored in designated storage facilities consistent with FSM , Chapter 40. Unused herbicides will be disposed of in accordance with the product label and FSM , Chapter 40. If the product label and FSM differ, the more restrictive storage and disposal guidelines will be followed. 8 Local Native American Tribes will be consulted on the entire project area to allow tribal members an opportunity to provide input. Individual plants identified by tribes will be protected in the same manner as Special Status Plant Species (see below). 9 No directed spray or broadcast herbicide application will occur on weekend days between Memorial Day and Labor Day in recreation sites (campgrounds, trailheads, dispersed camping areas, and known blackberry picking sites). To minimize potential adverse effects on workers, forest users, and resources. To minimize potential adverse effects on workers, forest users, and resources. To minimize the risk of pesticide drift onto water or non-target areas, in order to minimize impacts to water quality, Special Status plants and wildlife, nontarget vegetation, and other biological resources (e.g. pollinators, aquatic organisms). Compliance with BMP To establish the level of trained / certified personnel for herbicide applications. To minimize potential adverse effects to workers. To minimize potential adverse effects on workers, forest users, and resources. Compliance with BMP To ensure that plants in traditional gathering areas are protected. To inform and to minimize potential adverse effects on forest users. 22

29 Mt. Hough Ranger District, Plumas National Forest ID Project design feature (PDF) PDF Purpose 10 Herbicide treatments would not occur on the PCT during peak hiker season from July 15th through August 15th. To maintain recreation experiences along the Pacific Crest Trail. 11 For herbicide treatment within 100 ft of recreation sites (campgrounds, trails (including the PCT), trailheads, dispersed camping areas, and known blackberry picking sites), cautionary notice signs will be posted at the recreation site prior to herbicide treatments. The Pacific Crest Trail Association will be contacted prior to any herbicide treatments or closures of the PCT so users could be notified through their public website. 12 No directed spray or broadcast herbicide application will occur within known blackberry picking sites when blackberries are ripe, generally for two weeks in late August. 13 Use of herbicide, motorized equipment, or mechanized transport in Bucks Lakes Wilderness would be allowed only when authorized by the Regional Forester. 14 Ground disturbing actions (e.g. weed wrenching, grubbing with a shovel, use of skid-steer) will not be used in known cultural resource sites, unless there is on-site monitoring by a staff archeologist or the technique has been agreed to by a staff archeologist who has determined that the technique will have no effect on cultural resources. 15 If cultural resources are discovered during project implementation where none are known, the Mt. Hough RD Heritage Resources Staff will be contacted immediately and the discovery will be dealt with as appropriate. 16 No broadcast herbicide application will occur within 100 feet of Special Status Plant Species (SSPS). No directed spray or select application will occur within 25 ft of SSPS. Buffers may be waived if plants are covered by a protective barrier. Under saturated/wet soil conditions, the only herbicide application is permitted within 100 feet of SSPS is select application. Modifications may be made with consultation with a staff botanist. 17 When Special Status Plant Species are within 25 feet of mechanical, digging, covering, or flaming treatments, plants will be clearly identified and care taken to avoid direct impacts to individuals. No buffers are required for hand pulling. 18 If an American Marten, Pacific Fisher, Sierra red fox, or Wolverine den site is located, then the following buffers and limited operating periods (LOP) apply: No treatment (including manual) will occur within 1/4 mile of a known forest carnivore den site from: American marten--may 1-July 31 Pacific fisher--march 1-June 30 Wolverine--Jan 1-June 30 Sierra red fox--jan 1-June 30 Any treatment within a 100-foot buffer of existing roads, trails, and facilities would be allowed during the LOP. Existing seasonal wildlife closures of trails will be observed. To inform and to minimize potential adverse effects on forest users and maintain recreation experiences along the Pacific Crest Trail. To minimize potential adverse effects on forest users. To ensure that wilderness character is maintained and to exclude the sight, sound, and other tangible evidence of motorized equipment. To ensure that cultural resources are protected. To ensure that cultural resources are protected. To ensure that Special Status Plant Species are protected. To ensure that Special Status Plant Species are protected. To ensure that Special Status Forest Carnivores are protected. 23

30 Storrie and Rich Fire Areas Invasive Plant Treatment Project ID Project design feature (PDF) PDF Purpose 19 Northern goshawk: Use of mechanical equipment (e.g. weed whacker, ATV, chainsaw) will be prohibited within approximately ¼ mile of a nest site during the breeding season (February 15 - September 15), unless surveys by a staff biologist confirm that northern goshawks are not nesting. If the nest stand is unknown, either survey to determine the nest stand location or apply the Limited Operating Period (LOP) to a ¼- mile area surrounding the Protected Activity Center (PAC). Use of mechanical equipment would be allowed during the LOP if it is: a) within a 100-foot buffer of existing roads, trails, and facilities or b) creates noise less than a standard truck engine for less than 4 hours duration. Existing seasonal wildlife closures of trails will be observed. 20 Bald Eagles: Use of mechanical equipment (e.g. weed whacker, ATV, chainsaw) will be prohibited within 1/4 mile of occupied nest sites from November 1 - August 31st. Use of mechanical equipment would be allowed during the Limited Operating Period (LOP) if it is: a) within a 100-foot buffer of existing roads, trails, and facilities or b) creates noise less than a standard truck engine for less than 4 hours duration. Existing seasonal wildlife closures of trails will be observed. 21 California Spotted Owls: Use of mechanical equipment (e.g. weed whacker, ATV, chainsaw) will be prohibited within approximately ¼ mile of nest sites during the breeding season (March 1 - August 31), unless surveys by a staff biologist confirm that California spotted owls are not nesting. If the nest stand is unknown, either survey to determine the nest stand location or apply the Limited Operating Period (LOP) to a ¼- mile area surrounding the Protected Activity Center (PAC). Use of mechanical equipment would be allowed during the LOP if it is: a) within a 100-foot buffer of existing roads, trails, and facilities or b) creates noise less than a standard truck engine for less than 4 hours duration. Existing seasonal wildlife closures of trails will be observed. 22 Willow flycatcher: Use of mechanical equipment (e.g. weed whacker, ATV, chainsaw) will be prohibited within occupied emphasis sites and unoccupied known sites from June 1 - August 31, unless surveys by a staff biologist determine confirm that the site is unoccupied. Use of mechanical equipment would be allowed during the LOP if it is: a) within a 100-foot buffer of existing roads, trails, and facilities or b) creates noise less than a standard truck engine for less than 4 hours duration. Existing seasonal wildlife closures of trails will be observed. 23 Within 500 feet of known occupied sites for the California redlegged frog, Cascades frog, Yosemite toad, foothill yellow-legged frog, Sierra Nevada yellow-legged frog, and northern leopard frog, precautions will be issued to and care will be taken by workers to avoid crushing or trampling amphibians. To ensure that Northern Goshawks are protected from noise that may cause goshawks to abandon nests or young to fall out of nest. To ensure that Bald Eagles are protected from noise that may cause bald eagles to abandon nests or young to fall out of nest. To ensure that California spotted owls are protect from disturbance that may cause owls to abandon nests or young to fall out of nest. To ensure that the Willow flycatcher is protected from disturbance including noise from humans and equipment that may cause willow flycatcher to abandon nests or young to fall out of nest. To meet Sierra Nevada Forest Plan Amendment (SNFPA) Riparian Conservation Objectives. 24

31 Mt. Hough Ranger District, Plumas National Forest ID Project design feature (PDF) PDF Purpose 24 Within 500 feet of known occupied sites of California red-legged frog, Cascades frog, Yosemite toad, foothill yellow-legged frog, Sierra Nevada yellow-legged frog, and northern leopard frog, treatment will be limited to manual treatment or select herbicide application. In areas where Special Status amphibian tadpoles or metamorphs are present, treatment will be seasonally delayed until metamorphs disperse. 25 POEA surfactants will not be used within 150 feet of surface waters. 26 All wells, ponds, and springs used for domestic water supplies will be protected with a 200 foot buffer for herbicide treatment and mixing. At annual planning meeting water rights will be checked with the state and potential affected parties contacted. State website: 27 Perennial streams used for domestic water supply (e.g. Jackass Gulch) will be protected with a 15 feet buffer for 0.5 miles upstream of the diversion point for herbicide treatment and a 200-foot buffer around the diversion intake. Directed spray can occur within this buffer if a) use near a domestic water source is directed on the product label; AND b) water quality is monitored. 28 Fueling of gas-powered equipment with gas tanks larger than 5 gallons would not occur within 150 feet of surface waters, except at existing facilities. Fueling of gas-powered equipment less than 5 gallons would not occur within 25 feet of surface waters, except at existing facilities. 29 Herbicide mixing will not occur within 150 feet of surface waters, except at existing facilities. 30 Within 50 feet of perennial or seasonal streams, if treatment reduces groundcover to less than 75 percent for a contiguous area of greater than 0.25 acres, then mulching and/or revegetation may be required to minimize erosion and reestablish native vegetation. Only native plant species will be used in revegetation. All mulch and seed material will be certified weedfree. 31 Herbicide use buffers have been established for streams and other water bodies (listed below in Table 7). Buffers vary by herbicide and application method. Tank mixtures would apply the largest buffer as indicated for any of the herbicides in the mixture. 32 Roadside ditches will be treated the same as the water body type they resemble. 33 An annual cap is set on chemical treatment within 150 ft of perennial and seasonal streams. This cap varies by stream reach (listed below in Table 8). 34 Chlorsulfuron use will be restricted on soils with high clay content. These are the ultramafic soils in the vicinity of Red Hill. If this chemical is used, application methods will be limited to select treatment. Soil restrictions will be finalized during annual implementation review process (Appendix C). To meet SNFPA Riparian Conservation Objectives. To protect aquatic organisms. To protect water quality and insure protection of beneficial uses. To protect water quality and insure protection of beneficial uses. To protect water quality and aquatic organisms. To protect water quality and aquatic organisms. To protect water quality and riparian habitat for aquatic organisms. To minimize risk of surface water contamination in order to protect water quality and aquatic organisms. Compliance with BMP To protect water quality and meet SNFPA Riparian Management Objectives To limit cumulative effects of treatment within floodplains. To minimize risk of surface water contamination in order to protect water quality and aquatic organisms. 25

32 Storrie and Rich Fire Areas Invasive Plant Treatment Project ID Project design feature (PDF) PDF Purpose 35 Soils above 4,000 feet in elevation: application of Aminopyralid, Chlorsulfuron, and Triclopyr (including equipment rinsing) will not occur on deep, coarse textured, saturated soils. For elevations above 4,000 feet, district hydrologist or soil scientist will be consulted about the proper timing of herbicide application in the spring prior to treatments. 36 Avoid spraying while an invasive plant is in bloom or during the middle of the day, when pollinators are the most active. 37 When working in and adjacent to conifer plantations shield or cover conifer or desired woody vegetation (black oak, dogwood, alder, etc.) seedlings when spraying nearby. 38 Use directed versus broadcast spray whenever and wherever possible around conifer or desired woody vegetation seedlings. 39 Do not use herbicides that target broadleaf or woody species when possible, if working near desired woody vegetation seedlings. 40 Grazing permitees would be informed of any herbicide use within allotments and timing of treatments would be coordinated as necessary. To minimize risk of surface water contamination in order to protect water quality and aquatic organisms. To prevent direct spray to honey bees or bumble bees or other pollinating species. To minimize the potential for mortality to conifer seedlings and/or desired woody vegetation. To minimize the potential for mortality to conifer seedlings and/or desired woody vegetation. To minimize the potential for mortality to desired woody vegetation. Maintain efficacy of treatments and minimize potential effects to cattle. 26

33 Herbicide Active Ingredient Mt. Hough Ranger District, Plumas National Forest Table 7. Stream buffers for herbicide application LIVE WATER (Perennial streams, lakes, ponds, springs, seeps, fens, bogs) Stream Class Herbicide Application Method NO LIVE WATER (Seasonal wetlands when dry; seasonally flowing / intermittent channels that support a continual strip of riparian vegetation) Dry washes without riparian vegetation Broadcast spray Directed spray Broadcast spray Directed spray Select Select No buffer Aminopyralid 100 ft 25 ft 10 ft 50 ft 10 ft required Treatment Treatment Chlorsulfuron not proposed 100 ft 25 ft not proposed 50 ft 25 ft Treatment Treatment No buffer Glyphosate not proposed 25 ft 10 ft not proposed 10 ft required Treatment Treatment No buffer Imazapyr not proposed 25 ft 10 ft not proposed 25 ft required No buffer required, unless otherwise specified by project design features. Triclopyr-TEA 200 ft 100 ft 25 ft 100 ft 50 ft 25 ft Buffer distances are measured from the water's edge. Roadside ditches will be treated the same as the water body type they resemble. Buffers for domestic water sources are specified in PDF 25 & 26. Toxicity, soil mobility, and runoff potential were considered in selecting buffer distances and application methods allowed. In some instances, buffer distances are greater than those provided in the product label, in order to comply with USFS Best Management Practices for Water Quality. Table 8. Chemical Treatment Acreage Caps for Each Stream Reach Reach Description Miles Maximum acres of chemical treatment w/in 150 ft water's edge 1 North Fork Feather River--Project Boundary to Caribou Dam North Fork Feather River--Caribou Dam to Mosquito Creek North Fork Feather River--Mosquito Creek to Mouth East Branch North Fork Feather River--Mill Creek to North Fork Feather River Confluence 5 North Fork Feather River--Confluence to Belden North Fork Feather River--Belden to Rock Creek Dam North Fork Feather River--Rock Creek Dam to Rock Creek Powerhouse 8 North Fork Feather River--Rock Creek Power House to Cresta Dam Caps are based on SERA risk assessment modeling scenarios and ensure that herbicide concentration will be equal to or less than modeled amounts. The SERA risk assessment scenarios assume 100 percent treatment of 10 acres of treatment along any 1.6 miles of stream. No more than 17 percent (10 for every 58 acres) of the aquatic influence zone in any 1.6 mile stretch will be treated annually, resulting in far less herbicide applied within the aquatic influence zone than modeled in the SERA risk assessments (Dresser 2008). Because much of the treatment is along the main stem of the North Fork Feather River, a consistent 1.6 mile reach size was not logical. The river was segmented into reaches based on tributaries and the hydropower infrastructure. Then, the caps were scaled to maintain less than 17 percent treated acres within the aquatic influence zone. This project design feature, coupled with no broadcast buffers, provides strong assurance that herbicide use would not result in herbicides reaching streams in concentrations likely to harm fish and other beneficial uses of surface water. 27

34 Storrie and Rich Fire Areas Invasive Plant Treatment Project Environmental Impacts of the Proposed Action and Alternatives This section summarizes the physical, biological, and social environments of the affected project area and the potential changes to those environments due to implementation of the alternatives. It also presents the scientific and analytical basis for comparison of alternatives. Affected environment and environmental consequences sections have been divided by resource areas and then by alternative. Further, effects analyses that are required by law are discussed per alternative. This chapter describes aspects of the environment likely to be affected by the proposed action and alternatives. Also described are the environmental effects (direct, indirect, and cumulative) that would result from undertaking the proposed action or alternative. The following resource specialist analyses are incorporated by reference: Biological Evaluation for Terrestrial and Aquatic Wildlife Species for the Storrie and Rich Fire Areas Invasive Plant Treatment Project (Colin Dillingham and Kristina Van Stone Hopkins)(USDA 2013a), Terrestrial Wildlife Management Indicator Species Report and Migratory Bird Species Report for the Storrie and Rich Fire Areas Invasive Plant Treatment Project (Colin Dillingham)(USDA 2013b), Storrie- Rich Fire Area Invasive Plant Treatment Project: Biological Evaluation of Potential Effects to Threatened, Endangered, and Sensitive Plant Species (Jim Belsher-Howe)(USDA 2013d), Recreation, Lands, and Scenic Resources Report for the Storrie and Rich Fire Areas Invasive Plant Treatment Project (Erika Brenzovich)(USDA 2013e). Past, Present and Reasonably Foreseeable Future Actions According to the Council on Environmental Quality (CEQ) National Environmental Policy Act (NEPA) regulations, cumulative impact is the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-federal) or person undertakes such actions (40 CFR ). In order to understand the contribution of past actions to the cumulative effects of the proposed action and alternatives, this analysis relies on current environmental conditions as a proxy for the impacts of past actions. This is because existing conditions reflect the aggregate impact of all prior human actions and natural events that have affected the environment and might contribute to cumulative effects. This cumulative effects analysis does not attempt to quantify the effects of past human actions by adding up all prior actions on an action-by-action basis. There are several reasons for not taking this approach. First, a catalog and analysis of all past actions would be impractical to compile and unduly costly to obtain. Current conditions have been impacted by innumerable actions over the last century (and beyond), and trying to isolate the individual actions that continue to have residual impacts would be nearly impossible. Second, providing the details of past actions on an individual basis would not be useful to predict the cumulative effects of the proposed action or alternatives. In fact, focusing on individual actions would be less accurate than looking at existing conditions, because there is limited information on the environmental impacts of individual past actions, and one cannot reasonably identify each and every action over the last century that has contributed to current conditions. Additionally, focusing on the 28

35 Mt. Hough Ranger District, Plumas National Forest impacts of past human actions risks ignoring the important residual effects of past natural events, which may contribute to cumulative effects just as much as human actions. By looking at current conditions, we are sure to capture all the residual effects of past human actions and natural events, regardless of which particular action or event contributed those effects. Third, public scoping for this project did not identify any public interest or need for detailed information on individual past actions. Finally, the Council on Environmental Quality issued an interpretive memorandum on June 24, 2005 regarding analysis of past actions, which states, agencies can conduct an adequate cumulative effects analysis by focusing on the current aggregate effects of past actions without delving into the historical details of individual past actions. The cumulative effects analysis in this EA is also consistent with Forest Service National Environmental Policy Act (NEPA) Regulations (36 CFR 220.4(f)) (July 24, 2008), which state, in part: CEQ regulations do not require the consideration of the individual effects of all past actions to determine the present effects of past actions. Once the agency has identified those present effects of past actions that warrant consideration, the agency assesses the extent that the effects of the proposal for agency action or its alternatives will add to, modify, or mitigate those effects. The final analysis documents an agency assessment of the cumulative effects of the actions considered (including past, present, and reasonable foreseeable future actions) on the affected environment. With respect to past actions, during the scoping process and subsequent preparation of the analysis, the agency must determine what information regarding past actions is useful and relevant to the required analysis of cumulative effects. Cataloging past actions and specific information about the direct and indirect effects of their design and implementation could in some contexts be useful to predict the cumulative effects of the proposal. The CEQ regulations, however, do not require agencies to catalogue or exhaustively list and analyze all individual past actions. Simply because information about past actions may be available or obtained with reasonable effort does not mean that it is relevant and necessary to inform decision making (40 CFR ). In determining cumulative effects, the past, present, and future actions displayed in Appendix E were added to the direct and indirect effects of the proposed action and alternatives. Botanical Resources Introduction The purpose of this section is to present a summary of the effects of the proposed project on botanically sensitive resources within the Botany analysis area. Throughout this section, the term rare species or plants is used to refer to federally Endangered, Threatened, and Candidate plant species and Forest Service Region 5 Sensitive species. A complete discussion of effects to these species, as well as to Plumas National Forest special interest species, is provided in the Storrie-Rich Fire Area Invasive Plant Treatment Project: Biological Evaluation of Potential Effects to Threatened, Endangered, and Sensitive Plant Species (USDA 2013d), which is located in the project record and incorporated by reference. The area analyzed in this document is referred to as the Botany analysis area ; it encompasses approximately 142,600 acres and consists of the project area and the area within one mile of project area. This area was chosen to capture all rare plants that occur (a) within the proposed 29

36 Storrie and Rich Fire Areas Invasive Plant Treatment Project project area or (b) have suitable habitat within the Project Area as well as a source population (i.e. potential for seed dispersal) located within close proximity to the proposed activities. The analysis area contains a high diversity of rare plants including fifteen Forest Service sensitive plant species. The temporal scale of the analysis is one year more than the live span of the project. The persistence of the proposed herbicides in the environment is relatively short, measured in the scale of days to months. The other proposed treatment methods also have impacts to nontarget vegetation of less than one year. To date, only a small portion of the Storrie IPT Project area has been has been formally surveyed for rare plants, approximately 6,715 acres of the 90,000 acre project area, which includes all proposed treatment units. Between 2000 and 2012 approximately 5,270 acres were surveyed in the current project area for various vegetation management projects (Buck and Clifton 2000, Garcia and Associates 2001b, E Corp Consulting 2002, USDA 2002, Dittes and Guardino 2010, USDA 2009a, USDA 2012b). In 2001, approximately 975 acres of the Plumas NF were surveyed as part of the Storrie Fire Salvage project (Garcia and Associates 2001a). Approximately 460 acres of the Rich Fire were surveyed for the Rich Fire Recovery Project (USDA 2009b). In 2007 and 2008 several proposed OHV routes were surveyed as part of the Plumas NF Travel Management Project (Vollmar Consulting 2007, USDA 2008). For those areas outside of the surveyed areas, but within the Botany analysis area, species occurrence information was compiled using the California Natural Diversity Database (2013), Plumas NF rare plant records, and past survey reports. Those species present within one hundred feet of proposed treatments were considered to have the highest potential to be impacted by the proposed project activities. Conversely, species further away were not considered to have a high likelihood of being impacted by the currently proposed treatments either directly, indirectly, or cumulatively. Table 9 lists the rare species analyzed in this document (i.e. those that fall within 100 feet of proposed treatments). Table 9. Threatened, Endangered, Candidate, and R5 Forest Service Sensitive plant species known in analysis area. Species Common Name Listing Status Occurs within 100ft/25ft/Rx unit Astragalus webberi Webber's milkvetch Sensitive X X Clarkia mildrediae ssp. mildrediae Mildred s clarkia Sensitive X X Frangula purshiana ssp. ultramafica Caribou coffeeberry Sensitive X X Lewisia cantelovii Cantelow's lewisia Sensitive X X Monardella follettii Follett s monardella Sensitive X Monardella stebbinsii Stebbin's monardella Sensitive X X Packera eurycephalus var. lewisrosei cut-leaved ragwort Sensitive X X X Sedum albomarginatum Feather River stonecrop Sensitive X X X 30

37 Mt. Hough Ranger District, Plumas National Forest Environmental Consequences Botanical Resources Alternative A Proposed Action The ecological effects of aminopyralid, chlorsulfuron, glyphosate, imazapyr, and triclopyr-tea are discussed in detail in the SERA Risk Assessments (2003, 2004a, 2004b, 2007, and 2011) and the HFQLG final supplemental EIS (USDA 2003); this analysis tiers to these documents. In general, information regarding the direct effects of the five proposed herbicides, surfactant, and marker dye on rare plant species is almost nonexistent (USDA 2003). Direct Effects of Herbicide Application All of the proposed herbicides are highly effective at killing plants as reflected by the extremely high hazard quotients in the SERA risk assessments. By the nature of their action herbicide can be non-selective or selective. Non-selective herbicides can kill all types of plants whereas selective herbicides kill certain groups of plants while not impacting other groups of plants. There are several ways to prevent herbicides from getting on plants of concern. Spatial separation, physical barriers, and method of herbicide application are the most practical. As the distance between application site and plants of concern increases, the likelihood of harming the plants of concern decreases. Physical barriers such as buckets, tarps, or plastic sheeting can be utilized to prevent herbicides from reaching plants of concern. Drift can be reduced by controlling droplet size, spray pressure and ceasing application in high winds (PDF #4). Application methods can reduce or eliminate drift. Directed spray at target plants greatly reduces the amount of herbicide drift. Rare plants would be protected from herbicide spray by being covered when treatments occur within 25 feet of individual rare plants (PDF #13). Select applications (wiping and wicking) eliminate drift altogether since the herbicide is directly applied to plants rather than sprayed. Aminopyralid provides mainly post-emergence control of many annual, biennial, and perennial invasive plant species, including brooms and yellow starthistle. It is selective and it does not injure grasses and many broadleaf species, though it can injure legumes (Fabaceae) and members of the sunflower family (Asteraceae). For some species, aminopyralid can provide residual (preemergence) control, thereby reducing the need for retreatment. Within the soil, aminopyralid does not persist for long (less than 2 weeks) and is relatively immobile. Chlorsulfuron provides pre- and post-emergence control of many broadleaf invasive plants and some annual grasses. It is selective and does not injure most perennial grasses. It is absorbed by the leaves and roots. It is generally active in the soil and tends to leach in permeable soils. It can remain is soil for 1-3 months. Broadcast application is not proposed. Glyphosate is one of the most widely used herbicides available. It is non-selective (broad spectrum), so it may injure non-target plants. It provides only post-emergent control and is not absorbed through roots. It is non-persistent and relatively immobile in soil. Plants treated with glyphosate can take several weeks to die; repeat application is often necessary to remove plants that were missed during the first application. Broadcast application is not proposed. Imazapyr provides mainly post-emergence control of annual and perennial grasses, some broadleaf species, and woody species. It is non-selective (broad spectrum), so it may injure nontarget plants. For some species, imazapyr can provide residual (pre-emergence) control, thereby reducing the need for retreatment. Broadcast treatment is not proposed. 31

38 Storrie and Rich Fire Areas Invasive Plant Treatment Project Triclopyr provides pre- and post-emergence control of woody and broadleaf plants and resprout control as stump treatment on woody plants. It is selective and has little impact on grasses. It can reside in soils for up to 6 months. Formulations containing triclopyr butoxyethyl ester (BEE) are not being considered. Triclopyr can be used in combination with aminopyralid in a pre-mixed formulation. The proposed surfactant (i.e. Competitor or an equivalent formulation) is a modified vegetable oil, which is very unlikely to produce secondary breakdown products that would act as toxins to rare plant species. In addition, the proposed marker dye (i.e. Hi-light Blue or an equivalent formulation) is a water-soluble dye that contains no listed hazardous substances (SERA 1997) and is unlikely to cause adverse effects on rare plant species (Bakke 2007). For the remainder of this analysis, the discussion of effects resulting from herbicide application takes into consideration the effects of the herbicide s active and inert ingredients (the latter of which is water), metabolites, surfactant, and marker dye. Direct Effects of Manual, Mechanical, and Cultural Treatments Direct effects from these treatments occur when plants are physically impacted. Examples include crushing by vehicles or equipment, trampling, thermal treatments and cutting, clipping or mowing. These actions can result in death, altered growth, or reduced seed set through physically breaking, crushing, burning, scorching, or uprooting plants. Project design feature #14 protects rare plants from potential negative impacts from manual, mechanical, and cultural treatments. Indirect Effects of Treatments Indirect effects are separated from an action in either time or space. These effects, which can be beneficial or detrimental to rare species, may include changes in vegetation composition, successional patterns, or fire regimes. Indirect beneficial effects are likely based on the control or eradication of invasive plants from suitable habitat in close proximity to existing populations of rare plants. This would make more area available to rare plant population expansion. The indirect effects of herbicides on rare plant species can include accidental spills, spray drift, surface runoff, or a combination of these factors. In general, the primary hazard to non-target terrestrial plant species is herbicide drift, which are minimized by project design features including: (1) avoidance through buffers e.g. PDF #11, 15, 16, 24, 30, 31 (2) spraying in a manner to limit the potential for pesticide drift e.g. PDF #4 and/or (3) using an application method other than spraying (USDA 2003). The complete set of project design features are included in Table 6, Table 7, and Table 8 in the proposed action section of this document. Applications of glyphosate in 0 to 5 mile per hour (mph) winds using a backpack sprayer have demonstrated that droplets can drift as far as 23 feet; applications made in a 15 mph wind have the potential to drift up to 68 feet (SERA 2011). Similarly, Marrs et al. (1989) found buffers on the order of 5 to 10 meters adequate for ground based sprayers to minimize the risk of herbicide impacts. Based on these calculations, the project design features (PDF #13) are sufficient to significantly reduce the risk of indirect effects due to drift. Another potential indirect effect on rare plant species would be if an herbicide treatment were to negatively impact pollinator species. To quantify the potential impact on pollinator species, a 32

39 Mt. Hough Ranger District, Plumas National Forest scenario was analyzed to examine the effect of directly spraying a honey bee (assuming 100 percent absorption and over 50 percent of the body surface) with the proposed herbicides (SERA 2003, 2004a, 2004b, 2007, 2011). The results of this analysis indicate that there would be a low risk to honey bees using the chemicals, expected application rates, and volumes proposed. There has also been some concern regarding the toxicity of surfactants on terrestrial insects. This is primarily due to the effective spreading ability of these surfactants, which may amount to the physical effect of drowning (rather than any toxicological effects). Studies have indicated that the effect on terrestrial insects is highly dependent upon the dose (Bakke 2007). Surfactants are usually applied at very low rates and, because they are very effective, are usually not applied at high spray volumes (Bakke 2007); therefore, it is unlikely that insects would be exposed to the rates and doses of concern presented in the literature. There would be a low risk that the proposed herbicides or surfactant would cause widespread effects on terrestrial insects due to (1) the need for a relatively high dose for a lethal effect, and (2) the fact that individual insects, rather than entire colonies or nests, would most likely be impacted (Bakke 2007). There is a low risk for negative indirect effects to habitat for rare plants because habitat requirements are not fully understood. Thus, potential impacts cannot be fully avoided and may inadvertently occur. The potential short term negative impacts are out-weighed by the positive long term effects of removing invasive species from rare plant habitat. Alternative A Cumulative Effects The effects of past activities on rare plant species in the Botany analysis area are largely unknown. On the Plumas NF, rare plant surveys did not begin until the early 1980s. In many cases, even when project-level surveys were conducted, there is very little documentation that describes whether past projects avoided or protected rare plant species during project implementation. In addition to these unknowns, changes have been made to the Plumas NF Sensitive species list. Therefore, in order to incorporate the contribution of past activities into the cumulative effects of the proposed Project, this analysis uses the current abundance and distribution of rare plant species as a proxy for the impacts of past actions. Over the past 30 years, the landscape in the Botany analysis area has experienced high levels of past activity and, consequently, high levels of past disturbance. For those species that occupy open habitats and are tolerant of some level of disturbance, it is possible that past activities in the Botany analysis area have had a beneficial effect by creating openings and areas of suitable habitat across the landscape. However, these activities have also created a highly disturbed landscape, which has increased the susceptibility to Invasive plant introduction and spread and increased the overall risk to native plant communities and rare species. There would be no negative cumulative effects as a result of the proposed project because there are no biologically significant negative direct or indirect effects. Furthermore, negative cumulative effects would be unlikely because of the annual implementation review process established by this project. This review would not only document the on-going treatments of this project but also similar actions (whether conducted by the USFS or other agencies or organizations such as Caltrans, Plumas County Department of Agriculture, PG&E, or Plumas County Road Department) that have the potential to impact these same populations. 33

40 Storrie and Rich Fire Areas Invasive Plant Treatment Project If existing management guidelines (such as field surveys, protection of known rare plant locations, and implementation of invasive plant mitigations) remain in place, the effects of future projects are likely to be minimal or similar to those described in this analysis. Ongoing activities, such as woodcutting, hunting, and dispersed recreation activities, are not likely to make a significant impact on rare plant species; however, these activities may act as vectors for invasive plant spread. Rare plant species in the project area may be minimally affected by the proposed action. This conclusion is based on the negligible potential impacts to individuals and potential impacts to habitat due to the design of proposed treatments near rare plants including the project design features. Overall the benefits of removing invasive species from rare plant habitat far outweigh the potential negative impacts from incomplete knowledge of species life history and habitat requirements. Alternative B No Action Direct Effects No direct effects are anticipated because no project-related activities would be implemented. Indirect Effects Under this alternative, the existing invasive plant infestations would continue to expand along roadsides, in forest openings, along riparian corridors, into meadows, and within other areas of suitable habitat. Invasive plant species pose a serious threat to ecosystem function because of their ability to displace native species, alter nutrient and fire cycles, decrease the availability of forage for wildlife, and degrade soil structure (Bossard et al. 2000). Invasive plant establishment and spread in the Botany analysis area has the potential to negatively affect suitable habitat, not only for rare species, but also for all native plant species. The 27 occurrences of rare plants near known infestations would have increased competition for essential resources. Cumulative Effects Under the No Action Alternative the Plumas National Forest would continue limited invasive plant treatments along with Plumas-Sierra Weed Management Area partners. The PNF would continue limited manual, mechanical, and cultural treatments of small infestations similar to past and on-going treatments. PG&E would continue invasive plant treatments required under FERC relicensing projects and as proposed under the current PG&E Herbicide Vegetation Management Program. Invasive plant prevention measures would continue to be incorporated into new project design feature and serve as a critical means of limiting spread of existing infestations and introductions of new invaders. Given the open nature of the project area including State Highway 70 as a primary access to Plumas County, prevention measures while effective are unlikely to prevent all new introductions. The on-going actions under the no action alternative are not likely to control the spread of invasive plant species. Rare plant populations would be increasingly impacted by new introductions of invasive plants and the spread of existing infestations. The no action alternative is likely to negatively affect rare plant species and their habitat in the project area through the continued spread of invasive species that would occupy potential habitat of rare species and directly compete with rare species for resources. 34

41 Mt. Hough Ranger District, Plumas National Forest Compliance with the Forest Plan and Other Direction Federal Laws Endangered Species Act (16 USC 1531 et seq.): Under this act, federal agencies must ensure that any action authorized, funded, or carried out by the agency is not likely to (a) jeopardize the continued existence of any listed species or (b) result in the destruction or adverse modification of a listed species designated critical habitat. Section 7 of the act requires federal agencies to consult the U.S. Fish and Wildlife Service concerning listed (i.e. threatened or endangered) plant species that fall under their jurisdiction. Forest Service Manual (FSM) Direction FSM Section 2670 (USDA 2005b): provides policy for the protection of sensitive species and calls for the development and implementation of management practices to ensure that species do not become threatened or endangered because of Forest Service actions. It requires a review of all activities or programs that are planned, funded, executed, or permitted for possible effects on federally listed or U.S. Forest Service sensitive species (FSM , USDA 2005b). Forest Plan Plumas NF Land Management Plan (USDA 1988a, 2004b): provides management direction for all Plumas NF Sensitive plants; that direction is to maintain viable populations of sensitive plant species (USDA 1988). The 1988 Forest Plan also provides forest-wide standards and guidelines to: protect Sensitive and Special Interest plant species as needed to maintain viability; inventory and monitor Sensitive plant populations on an individual project basis; and develop species management guidelines to identify population goals and compatible management activities / prescriptions that will maintain viability. Management direction for sensitive plant species on the Plumas NF is also provided in the Sierra Nevada Forest Plan Amendment (SNFPA) Final Supplemental Environmental Impact Statement (USDA 2004a). The standards and guidelines provided in the SNFPA include conducting field surveys, minimizing or eliminating direct and indirect impacts from management activities, and adhering to the Regional Native Plant Policy (USDA 2004a). Interim Management Prescriptions Individual species conservation strategies, or species management guidelines, for the Plumas NF have not been completed for most of the Forest s Sensitive species. Until these conservation strategies have been completed, the Plumas NF has developed Interim Management Prescriptions (USDA 2007) that will be followed to ensure compliance with the Plumas LRMP. Invasive Plants Introduction Invasive plant species are oftentimes classified as pioneer species or invaders; therefore, disturbance, whether it is natural (such as a wildfire) or associated with management activities (e.g. road construction, timber harvest), often creates ideal conditions for the introduction and establishment of invasive plants. Colonization of invasive plant species into disturbed sites can 35

42 Storrie and Rich Fire Areas Invasive Plant Treatment Project be due to the removal of natural barriers that keep invasive species in check, such as unfavorable light, soil, or moisture conditions (Parendes and Jones 2000). The susceptibility of a burned landscape to invasive species colonization is dependent upon a number of factors that include: (a) site specific properties of the ecosystem itself, such as resource availability and disturbance regime; (b) properties of both the native and non native plant populations (i.e. response to fire, morphology, and competitive ability); and (c) availability of invasive species propagules for dispersal (Zouhar et al. 2008). The location, severity, suppression activities and post-fire management of the Storrie, Rich, and Chips fires have created a very high risk for invasive plant introduction and spread within the project area. During all three fires, fire suppression and very high burn severity resulted in considerable ground disturbance, near existing invasive plant infestations, leaving favorable conditions for the establishment and spread of invasive plants. Subsequent timber harvesting and associated activities further increased the level of ground disturbance near established and new invasive plant infestations. At present, a large portion of the project area is considered relatively free of invasive plants. Most invasive plant infestations are associated with areas of past or present disturbance, including skid trails, power lines, penstocks, and permanent or temporary roads. These infestations often provide seed sources for invasive species moving into the less invaded areas. Approximately 85 percent of the project area infestations occur along roads. Roads contribute to weed dispersal and create suitable habitat for invasion by altering environmental conditions, stressing or removing native species, and allowing for easier movement by wild or human vectors (Trombulak and Frissell 2000). Although the project area has relatively few roads, habitats that intersect roads are at the greatest risk for invasive plant invasion and spread. Severe wildfires, such as the Storrie, Rich, and Chips fires, can expose soil surfaces, reduce shade, decrease competition from native species, and contribute to soil nutrient pulses; all of these factors create conditions favorable to the establishment and spread of invasive plants (Sheley 2002). In a comparison of low severity and high severity burns, Turner et al. (1997) found that the density of invasive Canada thistle after severe surface and crown fires was two to four times greater than the density of Canada thistle after a light surface fire. In addition, Jacobs and Sheley (2003) determined that seed production in invasive Dalmatian toadflax increased by tenfold following fire. The area analyzed in this document the same as the project area described in the proposed action which encompasses approximately 90,000 acres. This area was chosen because it captures all the invasive plant infestations impacted by the fires, introduced or spread during fire suppression activities, or introduced or spread during post fire restoration activities. Furthermore, the project area captures infestations near the fires with the potential to spread into the fire areas if infestations are not controlled. To date, only a small portion of the Storrie-Rich project area has been has been formally surveyed for invasive plants, approximately 6,715 acres of the 90,000 acre project area. Between 2000 and 2012 approximately 5,270 acres were surveyed in the current project area for various vegetation management projects (Buck and Clifton 2000, Garcia and Associates 2001b, E Corp Consulting 2002, USDA 2002, Dittes and Guardino 2010, USDA 2009a, USDA 2012b). In 2001, approximately 975 acres of the Plumas NF were surveyed as part of the Storrie Fire Salvage project (Garcia and Associates 2001a). Approximately 460 acres of the Rich Fire were surveyed for the Rich Fire Recovery Project (USDA 2009b). The most extensive invasive plant species surveys were conducted in 2003 by PG&E along the North Fork of the Feather River as 36

43 Mt. Hough Ranger District, Plumas National Forest part of the Federal Energy Regulatory Commission s (FERC) relicensing process for the Rock Creek Cresta project. These surveys documented 445 invasive plant locations or 92 percent of all known invasive plant species in the Storrie Fire area. In 2007 and 2008 several proposed OHV routes were surveyed as part of the Plumas NF Travel Management Project (Vollmar Consulting 2007, USDA 2008). Environmental Consequences Invasive Plants Alternative A Proposed Action Under the proposed action up to 200 acres of invasive plant infestations could be treated per year including up to 100 acres of herbicide treatment. Treatments would be performed on currently documented infestations or new infestations found over the life of the project. Treatments for new infestations would be determined by the protocol outlined in the proposed action. A yearly implementation plan review would ensure resources are protected and appropriate project design features incorporated (Appendix C). Small isolated infestations would be eradicated by the proposed manual and mechanical treatments. These treatments may be effectively combined with herbicide treatments. Repeated treatments would likely be necessary because established infestations have built up an on-site seed bank that may take several years to deplete. For instance, recent research indicates that it takes two to four years to deplete yellow starthistle s seed bank (DiTomaso et al. 2006). Manual and mechanical control methods are most effective for control of annual species and tap rooted plants; they are considered less effective against invasive plant species with deep underground stems and roots, which have the ability to resprout following treatment (Tu et al. 2001). Cultural treatments using propane torches have been tested at sites on the Plumas NF. Small infestations of medusahead have been reduced (Coppoletta 2006) and seedlings of French broom killed. While cultural treatments can be effective their practical use is limited by fire restrictions, the number of specialized personnel required, and the method is extremely time intensive. Herbicide treatments would be used to control larger infestations and in conjunction with manual, mechanical, or cultural treatments to eradicate smaller infestations of some species. Herbicide treatments are generally considered to be the most economic and effective method of invasive plant species control (DiTomaso 2009). However, their effectiveness is highly dependent upon the biology of the target species, herbicide formulation, application method, and sitespecific variables such as climatic and environmental conditions (Bossard et al. 2000). Herbicides are categorized based on their degree of selectivity, method of application, and application timing (i.e. pre-emergent vs. post-emergent). Some of the definitions used to distinguish the herbicides proposed for use are defined in Table 10. It is important to note that many herbicides fall into several categories. 37

44 Storrie and Rich Fire Areas Invasive Plant Treatment Project Table 10. Definitions of terms used to distinguish herbicides and application methods. Adapted from Gover (1997). Term Definition Pre-emergent Post-emergent Selective Non-selective Herbicides applied to the soil prior to emergence and act on target invasive plant species as they germinate. Herbicides applied to the leaves and stem of target invasive plant species after emergence. Herbicides effective at controlling target plants or classes of plants. Herbicides effective at controlling most plant species. Contact Systemic Broadcast Herbicides that injure only the portion of the plant it contacts Herbicides that move throughout the plant; can cause injury in areas away from the point of contact. An application that is made to an entire area. Spot treatment An application made to localized targets (i.e. scattered plants) within a management area. While herbicide treatment can be a highly effective method of control, it also presents several potential risks. Improper herbicide use can lead to damage to non-target species, chemical persistence in the environment, toxicity to humans and wildlife, contamination of ground and surface water, and selection for herbicide resistance in invasive plant species (DiTomaso 2009). Potential risks can be minimized by adhering to all applicable pesticide laws and carefully following herbicide label instructions (PDF #1). Environmental risks can be further minimized by choosing herbicides that are selective; rapidly degraded; immobilized in the soil and unlikely to reach groundwater; non-toxic to animals; and not easily volatilized (Bossard et al. 2000). Different methods of application (PDF #3), operating period restrictions (PDF #4, 9, 10, 11, 12, 18), and use of dye markers (to identify treated plant material) can also be utilized to minimize impacts to applicators and non-target species. A considerable body of information describing the hazards and risks associated with using each of the proposed herbicides is contained in the Human Health and Ecological Risk Assessments (HERAs) completed by Syracuse Environmental Research Associates, Inc. (SERA) under contract to the Forest Service (SERA 1997, 2004a, 2007, 2011a,b,c), and in the HFQLG Act final supplemental EIS (USDA 2003). Table 11 provides an overview of the herbicides that are most commonly used for control of the invasive plant species found in the project area. The information provided was obtained from the scientific literature, herbicide product labels, and from environmental analyses conducted by the Forest Service and other government agencies. It is important to note that the information presented in Table 10 is not static; ongoing research and testing will likely result in new application rates, target species, and products. When choosing a specific herbicide for treatment, it is important to take into consideration species-specific and site-specific factors such 38

45 Mt. Hough Ranger District, Plumas National Forest as habitat type, invasive plant species, infestation size, and climatic conditions. Always read and follow the directions provided in the product label. 39

46 Storrie and Rich Fire Areas Invasive Plant Treatment Project Table 11. Comparison of the herbicides proposed for controlling invasive plant species in the Storrie IPT Project area. Chemical 1 Advantages Disadvantages Target Species Surfactant Needed? Aminopyralid (i.e. Milestone ) Chlorsulfuron (i.e. Telar XP ) Selective; will not injure grasses and many broadleaf species Pre and post-emergence activity No grazing restrictions Low toxicity Selective; will not injure most grasses Pre and post-emergence activity No grazing restrictions with applications up to 1 1/3 ounces per acre of Telar XP Can injure legumes (Fabaceae) and other desirable members of the sunflower family (Asteraceae) Possible damage to non-target terrestrial and some aquatic plants at peak concentrations. Potential for off-site movement up to 900 feet Some soil residual Centaurea maculosa Spotted knapweed Cardaria pubescens Hairy whitetop Centaurea solstitialis Yellow starthistle Cirsium arvense Canada thistle Cardaria pubescens Hairy whitetop Centaurea solstitialis Yellow starthistle Cirsium arvense Canada thistle Lepidium latifolium Tall whitetop Linaria dalmatica var. dalmatica Dalmatian toadflax Yes. Add non-ionic surfactant Yes. Add surfactant Aquatic area restrictions Permissible to treat non-irrigation ditch banks, seasonally dry wetlands and transitional areas between upland and lowland sites. Can be used to the water s edge. Do not apply directly to water and take precautions to minimize spray drift onto water. Terrestrial applications only Permissible to treat intermittent drainage, intermittently flooded low lying sites, seasonably dry flood plains, and transitional areas between upland and lowland sites when no water is present. Do not make applications to natural or man-made bodies of water such as lakes, ponds, or streams. Isatis tinctoria Dyer s Woad 40

47 Mt. Hough Ranger District, Plumas National Forest Chemical 1 Advantages Disadvantages Target Species Surfactant Needed? Glyphosate (i.e. Accord, Aquamaster ) Post-emergent activity No grazing restrictions (except for lactating dairy animals) Adheres to soil which lessens leaching or uptake by nontarget species Non-selective; can injure desirable non-target broadleaf or grass species Off site drift possible up to 100 feet Aegilops triuncialis Barbed goatgrass Cardaria pubescens Hairy whitetop Centaurea maculosa Spotted knapweed Yes. Add non-ionic surfactant to most formulations Aquatic area restrictions Terrestrial and aquatic use Aquatic formulations (i.e. Aquamaster) are available that can be applied directly to water. Centaurea solstitialis Yellow starthistle Cirsium arvense Canada thistle Cytisus scoparius Scotch broom Lepidium latifolium Tall whitetop Linaria dalmatica var. dalmatica Dalmatian toadflax Rubus discolor Himalayan blackberry 41

48 Storrie and Rich Fire Areas Invasive Plant Treatment Project Chemical 1 Advantages Disadvantages Target Species Surfactant Needed? Aquatic area restrictions Imazapyr (i.e. Habitat ) Will control most annual and perennial grasses and broadleaf invasive species in addition to many brush and vine species Non-selective; can injure desirable non-target broadleaf or grass species Centaurea sp. knapweeds Centaurea solstitialis Yellow starthistle No Terrestrial and aquatic use Aquatic formulations (i.e. Habitat ) are available. Triclopyr (Garlon 3A) Selective for woody and broadleaf perennial species. Little or no impact on grasses. Pre and post-emergence activity. No grazing restrictions. Cirsium arvense Canada thistle Centaurea solstitialis Yellow starthistle Cirsium arvense Canada thistle Cytisus scoparius Scotch broom Rubus discolor Himalayan blackberry 1 Common chemical trade names are included in parentheses 2 Application rates may vary according to label suggestions. Rates of product are given in active ingredient (a.i.) or acid equivalent (a.e.) No Use in upland sites, on banks of nonirrigation ditches, seasonally dry wetlands, floodplains, and transition areas between uplands and wetlands. Do not apply directly to water. 42

49 Mt. Hough Ranger District, Plumas National Forest Restoration or re-vegetation of a site following invasive species treatment is an important component of the long-term strategy to reduce noxious infestations (PDF #27). Removal of invasive plant species often creates gaps or patches of bare soil and can promote further invasion by the same species or other undesirable plants (USDA Forest Service 2005c). Passive re-vegetation (i.e. allowing re-vegetation to occur from the native vegetation already present at the site) may be appropriate if the bare patches are small. However, if the treatment site is severely degraded and native plants are absent or in low abundance, active re-vegetation efforts may be required to promote recovery of the native plant community (USDA Forest Service 2005c). The selection of appropriate species for re-vegetation is dependent upon a number of different factors, including site-specific management objectives, physical characteristics of the site, seed availability and cost, genetic makeup, and species morphology and ecology (USDA Forest Service 2005). For re-vegetation activities that require seeding or planting, locally collected native seed sources should be used whenever possible. Plant and seed material will be collected from as close to the project area as possible, from within the same watershed, and at a similar elevation whenever feasible. Persistent non-natives such as Phleum pretense (cultivated timothy), Dactylis glomerata (orchard grass), or Lolium spp. (ryegrass) will not be used. This requirement is consistent with USFS Region 5 policy which directs the use of native plant material for revegetation and restoration for maintaining the overall national goal of conserving the biodiversity, health, productivity, and sustainable use of forest, rangeland, and aquatic ecosystems. The invasive plant treatments proposed would be effective in eradicating, controlling, or containing invasive plant populations as outlined in the proposed action section of this EA. The project design features would greatly reduce the risk of inadvertent impacts to humans and other resources in the area. The proposed action would increase the coordination and effectiveness of on-going invasive plant treatments across land ownerships. The coordinated effort across land ownerships would reduce the future need for invasive plant treatments. Alternative B No Action Under the No Action Alternative the Plumas National Forest would continue limited invasive plant treatments along with Plumas-Sierra Weed Management Area partners. The PNF would continue limited manual, mechanical, and cultural treatments of small infestations similar to past and on-going treatments. PG&E would continue invasive plant treatments required under FERC relicensing projects and as proposed under the current PG&E Herbicide Vegetation Management Program. Invasive plant prevention measures would continue to be incorporated into new project design feature and serve as a critical means of limiting spread of existing infestations and introductions of new invaders. Given the open nature of the project area including State Highway 70 as a primary access to Plumas County, prevention measures while effective are unlikely to prevent all new introductions. Infestations with on-going treatments would be further reduced or eradicated. Infestations outside of currently authorized project areas or too large to be treated by available methods (i.e. without herbicides) would continue to increase in size and serve as potential seed sources for spread and establishment of new infestations. Continued spread of invasive plants would increasingly threaten and compromise wildland and recreational resources in the project area. The following list, adapted from the Pacific Northwest Region s Invasive Plant Program; 43

50 Storrie and Rich Fire Areas Invasive Plant Treatment Project Preventing and Managing Invasive Plants (USDA 2005), documents some of the impacts of invasive plants on native ecosystems. Reduce biological diversity Impact populations of native species, including those that are threatened or endangered Decrease the quality and abundance of forage for wildlife Disrupt relationships between plants and associated herbivores, insects, mycorrhizae, and pollinators Alter fire behavior; affect the intensity, duration, and frequency of fires Alter soil stability through loss of plant cover, debris, and litter Change soil ph and chemistry; negatively impact soil biota Cause direct and indirect changes in water availability and moisture regimes Increase soil erosion and stream sedimentation Increase fragmentation of habitats and edge effects Alter ecological processes such as nutrient and water cycling Degrade ecological integrity and disrupt ecosystem structure/function Reduce the recreational value of public lands Create large economic losses Compliance with the Forest Plan and Other Direction Federal Acts and Orders Executive Order (1999)- directs federal agencies to prevent the introduction of invasive species; detect and respond rapidly to control such species; and to minimize the economic, ecological, and human health impacts from invasive species on NFS lands. Forest Service Manual (FSM) Direction FSM Section directs the U.S. Forest Service to prevent the introduction and establishment of noxious weeds; contain and suppress existing weed infestations; and to educate and cooperate with agencies, land owners, land managers, and members of the public to control weeds. Forest Plan Plumas NF Land Management Plan (USDA 1988, 2004b): The 2004 Record of Decision on the Sierra Nevada Forest Plan Amendment (SNFPA) Final Supplemental EIS (USDA 2004b) amended the management direction in the Forest Plan to address management of noxious weeds and invasive exotic (nonnative) species. The Record of Decision (ROD) for the 2004 SNFPA established goals for noxious weed management using an integrated weed management approach according to the priority set forth in Forest Service Manual The three priorities include: 1. Prevent the introduction of new invaders. 2. Conduct early treatment of new infestations. 3. Contain and control established infestations. 44

51 Mt. Hough Ranger District, Plumas National Forest Provisions for implementing these goals are embodied in the noxious weed management standards and guidelines of the SNFPA 2004 Record of Decision. Recreation, Lands, and Scenic Resources Introduction The Storrie and Rich Fire Areas Invasive Plant Treatment Project (Storrie IPT Project) analysis boundary for recreation, lands, and scenic resources encompasses a variety of recreation and scenic resources on the Plumas NF including portions of the Bucks Lake Wilderness, the Upper North Fork of the Feather River (UNFFR), portions of a National Forest Scenic Byway along Highway 70, developed recreation sites, the North Fork Recreation Area, portions of the Pacific Crest Trail and other Plumas NF trails, dispersed camping sites, and dispersed berry picking areas along portions of NFS roads 26N26 and 27N26, hereafter referred to as Caribou Road. This analysis includes the effects of the proposed action on recreation, lands, and scenic resources. A Recreation, Lands, and Scenic Resources report for the Storrie IPT Project was completed for recreation, lands, and scenic resources by Erika Brenzovich in November This report is incorporated by reference and is available in the project record (USDA 2013e). Recreation There are four developed recreation sites on the PNF within the analysis boundary (three developed campgrounds and one developed trailhead) and numerous dispersed recreation sites. There are three undeveloped trailheads within the analysis boundary and one trailhead (Belden Rest Area) on private land. The majority of recreational activities that occur within the project area are concentrated along the UNFFR. The main recreational activities within the analysis boundary include white water and flat water boating, berry picking along Caribou Road, offhighway vehicle riding, fishing, camping, driving for pleasure, swimming, dredging and panning for gold, picnicking, rock climbing, bike riding, hiking, and backpacking. A campground concessionaire operates three developed campgrounds within the analysis area. There are three resorts and two RV (recreation vehicle) parks which are privately owned on or adjacent to the Plumas NF. The former James Lee Campground is a popular staging area for white water boaters and dispersed camping area for many recreation users. Caribou Road, a stretch of approximately 6 miles along the UNNFR lies predominantly within the North Fork Feather River Recreation Area (280 acres in size). There are three developed campgrounds along Caribou Road (Gansner Bar, North Fork, and Queen Lily) and numerous dispersed camping sites along the river. Blackberry bushes are very common along pullouts and shoulders of Caribou Road nearly the entire stretch of the road to the Belden Forebay. Blackberry picking is extremely popular along Caribou Road, typically from mid-august to mid- September each year. Wilderness The Storrie IPT Project area contains portions of the Bucks Lake Wilderness, a congressionally designated wilderness area approximately 23,958 acres in size. Approximately half of the Bucks Lake Wilderness lies within the Storrie IPT project boundary. The Bucks Lake Wilderness is managed to maintain and protect wilderness characteristics and values in accordance with the Wilderness Act of Five wilderness characteristics must be 45

52 Storrie and Rich Fire Areas Invasive Plant Treatment Project considered when management activities have the potential to affect wilderness character in a proposed project. Four of these wilderness characteristics are from Section 2 (c) of the Wilderness Act of 1964: untrammeled, natural, undeveloped, and outstanding opportunities for solitude or a primitive and unconfined type of recreation. There is a fifth quality; the unique qualities of a particular wilderness area, which is used to monitor wilderness character although it is not derived from the Wilderness Act of The use of herbicides, motorized equipment, or mechanical transport in Bucks Lake Wilderness is not included in the proposed action and would not be undertaken without Regional Forester approval. Approximately 19 miles of the Pacific Crest Trail spans the Bucks Lake Wilderness. The Bucks Lake Wilderness is a relatively small wilderness area and is predominantly used for day use; there is some overnight use of this area. Wild and Scenic The Upper North Fork of the Feather River (UNFFR) has five sections which were deemed to have potential for inclusion in the Wild and Scenic River System including the area from Belden to Caribou in the vicinity of Caribou Road. In accordance with management direction outlined in a memorandum to District Rangers dated May 8, 2001, all planned Forest Service management activities within 1/4 mile of both sides of the river's bank need to be consistent with management direction for Wild and Scenic Rivers until a suitability determination is made through the land management planning process. Therefore, this area is currently managed in accordance with direction for Wild and Scenic Rivers. Inventoried Roadless There is one Inventoried Roadless Area within the project area The Chips Creek Inventoried Roadless Area. This area is approximately 12,700 acres in size. Forest Service direction for management of Inventoried Roadless Areas (IRA) is to provide lasting protection for IRAs and to maintain the roadless characteristics which consist of: 1) high quality or undisturbed soil, water, and air; 2) sources of public drinking water; 3) diversity of plant and animal communities; 4) habitat for threatened, endangered, proposed, candidate, and sensitive species and for those species dependent on large, undisturbed areas of land; 5) primitive, semi-primitive nonmotorized and semi-primitive motorized classes of dispersed recreation; 6) reference landscapes; 7) natural appearing landscapes with high scenic quality; 8) traditional cultural properties and sacred sites; and 9) other locally identified unique characteristics. A Ninth Circuit Court decision (Lands Council v Martin, 2008), also directs the Forest Service to consider the effects of activities within these areas on the potential for designation as wilderness areas. Pacific Crest Trail There are 24.5 miles of NFS non-motorized trails within the project area; which includes approximately 15.4 miles of the Pacific Crest Trail (PCT), a national scenic trail. The Pacific Crest Trail is frequented by hikers and equestrians; the use of mountain bikes or motorized vehicles is not allowed on the PCT. Much of use on the Plumas NF section of the PCT occurs between mid- July and mid-august by thru-hikers (hikers who are hiking from Mexico to Canada, or doing long sections of the PCT). Approximately 1000 thru-hikers each year traverse the 15.4 miles of the PCT through the Storrie IPT Project area. There are 40.3 miles of motorized trails within the analysis area and no developed motorized trailheads. 46

53 Mt. Hough Ranger District, Plumas National Forest Lands Numerous outfitters and guides conduct guided fishing tours along UNFFR and guided hunting tours within the project area. These outfitters and guides operate under special use permits with the Plumas NF. There are numerous recreation events under special use permit with the Plumas NF that take place in the project area including music festivals near Belden Resort and a river festival at the former James Lee Campground. There is a special use permit for a school (Indian Jim School) issued to Plumas Unified School District. There is one communication site within the analysis boundary with four leases under special use authorization with the Plumas NF. Other types of special use permits within the analysis area include improvements such as roads, water lines, a hotel/motel, and powerlines. There are two Federal Energy Regulatory Commission (FERC) licenses issued to Pacific Gas & Electric (PG&E) within the project area --Upper North Fork Project (FERC 2105) and Rock Creek Cresta Project (FERC 1962) which have license conditions identified for recreation. Scenic Resources There are four Visual Quality Objectives (VQOs) outlined in the Plumas National Forest Land and Resource Management Plan (PNF LRMP, USDA 1988a) within the Storrie IPT Project area: Preservation: Only ecological change is allowed. Retention: People s activities are not to be evident to the casual forest visitor. Partial Retention: People s activities may be evident but must remain subordinate to the characteristic landscape. Modification: Activities may dominate the characteristic landscape but must, at the same time, utilize naturally established form, line, color, and texture. The Highway 70 corridor, a National Forest Scenic Byway, bisects the Storrie IPT Project area. Visual resources for the North Fork and Rich Management Areas under the PNF LRMP standards and guidelines provide for applying Rx-10 (Visual Retention Prescription) and Rx-14 (Visual Partial Retention Prescription) to the Highway 70 viewsheds (USDA 1988a). The California Department of Transportation currently maintains the right-of-way within 100 feet of the centerline of Highway 70. The Bucks Lake Wilderness has a VQO of Preservation where only ecological change is allowed. The PCT has a VQO of partial retention. Effects Analysis Methodology Potential impacts of project actions to recreation based activities, recreation infrastructure, lands, and scenic resources are described below. This analysis focuses on the recreation opportunity spectrum, visual quality objectives, recreation facilities, roads, motorized and nonmotorized trails, Caribou Road, wilderness, and wild and scenic rivers. Direct and indirect impacts are described for these resources. The geographic extent of this analysis is the project boundary. This extent is appropriate because direct, indirect, and cumulative impacts will be contained within this perimeter. The following GIS data were used to complete this analysis: Plumas National Forest Roads and Trails layers, Plumas National Forest Recreation Opportunity Spectrum, Wilderness, and Inventoried Roadless layers. The Storrie IPT Project is designed to fulfill the management direction specified in the 1988 Plumas National Forest Land and Resource Management Plan (PNF LRMP) (USDA 1988), as 47

54 Storrie and Rich Fire Areas Invasive Plant Treatment Project amended by the Sierra Nevada Forest Plan Amendment (SNFPA) FSEIS and ROD (USDA 2004a,b, c). The Storrie IPT Project encompasses two Management Areas outlined in the PNF LRMP, North Fork Management Area 19 and the Rich Management Area 20. General direction outlined for these management areas from the PNF LRMP is listed in the Recreation, Lands, and Scenic Resources report (USDA 2013e). The Recreation Opportunity Spectrum (ROS) is used as an indicator in the recreation analysis to measure beneficial or adverse effects on recreation. The Recreation Opportunity Spectrum (ROS) is a system used to divide the Forest into recreational opportunity areas based on area size, distance from roads, and the degree of development. Existing and potential recreation activities are identified within each category to guide future management. Categories within this analysis range from Primitive in the Bucks Lake Wilderness to Roaded Natural in areas along Highway 70. There are four ROS classifications identified in the PNF LRMP that apply to this project area: Primitive, Semi-Primitive Non-Motorized, Roaded Modified, and Roaded Natural (USDA 1988a). Environmental Consequences Proposed Action Direct, Indirect, and Cumulative Effects of Invasive Plant Treatments Recreation Mechanical, manual, chemical, and cultural treatments under the proposed action alternative would have minor short term direct impacts on developed recreation sites, trailheads, trails, and the Pacific Crest Trail by causing a minor inconvenience to visitors if workers are present. It is not likely that recreation sites, trails, or trailheads would be closed during manual, mechanical, or cultural treatments. Project Design Features 9 through 13 listed in Table 6 would minimize any potential negative impacts to forest visitors from herbicide treatments in two ways: 1) scheduling treatments to avoid high visitor use periods, and 2)providing signs prior to and during treatments to assist visitors in avoiding herbicide treatment areas. Project design features would ensure that chemical treatments would occur outside of peak use periods. It is possible that recreation sites would be closed during herbicide treatments. The Human Health and Risk Assessment (Appendix D) addresses potential for chemical exposure by Forest visitors engaged in recreation and other user activities. It is not anticipated that any impacts to human health would occur as a result of herbicide treatments because project design features are designed to minimize human health impacts to recreation users. Cautionary signs would be posted at recreation sites, trails, and trailheads warning visitors if any herbicide treatments would occur within a recreation site or trail. In the area of Caribou Road, blackberry picking areas would be protected from herbicide treatments proposed on adjacent invasive plants through project design features #9 and #12 listed in Table 6. These design features ensure that no directed spray or broadcast herbicide application would occur within known blackberry picking sites when blackberries are ripe. Recreation opportunities under the Recreation Opportunity Spectrum would be maintained or improved under manual, mechanical, chemical, and cultural treatments in the proposed action because treatments would promote the control or eradication of invasive plants at recreation sites, trailheads, and trails. Invasive plants such as yellow starthistle can be a nuisance to visitors at recreation sites, campgrounds, and trails. Treatments would likely result in a minor inconvenience to visitors if workers are conducting manual, mechanical, or cultural treatments at recreation sites, trailheads, or trails. A visitor may choose to select an alternate recreation site to 48

55 Mt. Hough Ranger District, Plumas National Forest avoid an area where herbicide treatment has been used. This impact is short-term in nature since proposed chemical treatments would only occur until the invasive plant is controlled or eliminated. Project design features identified in Table 6 would minimize any risk to human health at recreation sites and along trails because treatments would not occur during peak use periods. There are no known past, present or reasonably foreseeable future projects within recreation sites or other recreation areas that when considered with manual, mechanical, chemical, or cultural treatments under the proposed action would have any significant cumulative effects on recreation sites or opportunities in the project boundary (Appendix E). Although Himalayan blackberry is considered an invasive plant species on the Plumas NF, blackberry picking areas along Caribou Road would be not be impacted by manual, mechanical, chemical, or cultural treatments since they are not being targeted for eradication or control. Treatment activities from the proposed action would maintain blackberry picking opportunities along Caribou Road because the Plumas NF recognizes this is a popular recreation activity. There are, however, infestations of Himalayan blackberry outside of the Caribou Road vicinity that could be eliminated or controlled in the future through a combination of manual, mechanical, and or chemical treatments. An impact to these sites in the future is considered minimal since the focus of blackberry picking in the project area is along Caribou Road. There are no known past, present or reasonably foreseeable future projects within the blackberry picking sites that when considered with the proposed action would have any significant cumulative effects on blackberry picking opportunities in the project boundary (Appendix E). Wilderness There is one known invasive plant infestation (Himalayan blackberry) located in the Bucks Lake Wilderness that is proposed to receive manual treatments under the proposed action. Proposed manual treatments at that location would not be visible from designated trails in the wilderness. Since no motorized or mechanized equipment would be used to remove the infestation, manual treatment activities would maintain wilderness character and values of the Bucks Lake Wilderness. There may be a short-term visual impact to the natural setting at the infestation site after treatment for a short-term duration until management activities are no longer evident. However, this impact is considered minimal since the proposed treatment site is located away from designated trails and the site is already part of a larger historic mining site where evidence of man is already present. There are no proposed chemical treatments in the Bucks Lake Wilderness at this time, and since use of herbicide in wilderness areas would be allowed only when authorized by the Regional Forester, it is not likely that chemical treatments would be used to control or eradicate future infestations in the Bucks Lake Wilderness. Manual treatments would be the preferred treatment method in the wilderness to protect the natural setting and other wilderness characteristics. It is not anticipated that any of the five wilderness characteristics (opportunities for solitude, untrammeled, natural, undeveloped, or unique qualities of the Bucks Lake Wilderness) would be negatively impacted from manual, mechanical, chemical, or cultural treatments. There would be beneficial effects from allowing proposed and any future necessary manual treatments in the wilderness because it would enable control of any future infestations of invasive plants. Wilderness values and characteristics would thereby be protected and would outweigh shortterm negative impacts from manual treatments. There are no known past, present or reasonably foreseeable future projects within the Bucks Lake Wilderness that when considered with the manual, mechanical, chemical, or cultural treatment under the proposed action, would have any 49

56 Storrie and Rich Fire Areas Invasive Plant Treatment Project significant cumulative effects on the five wilderness characteristics of the Bucks Lake Wilderness (Appendix E). Wild and Scenic Manual, mechanical, and chemical, and cultural treatments under the proposed action would not have adverse effects on the outstandingly remarkable values or the free flowing condition of areas along the UNFFR, managed as a Wild and Scenic River. Controlling invasive plant infestations would have a beneficial effect by protecting and preserving the outstandingly remarkable values of this river and providing for ongoing public use and enjoyment. There are no known past, present or reasonably foreseeable future projects within these areas that when considered with the proposed action would contribute to adverse cumulative impacts (Appendix E). Inventoried Roadless Manual, mechanical, chemical, and cultural treatments under the proposed action alternative would likely have beneficial impacts on the Chips Creek Inventoried Roadless Area (IRA) by providing effective control or eradication of any future infestations to protect roadless characteristics and protect wilderness values for potential future designation under the Wilderness Act. Control or eradication of invasive plant infestations on other areas of NFS lands outside the IRA would reduce the likelihood of expansion into the IRA. There would be no direct or indirect adverse effects from the proposed action. There are no known past, present or reasonably foreseeable future projects within the Chips IRA that when considered with manual, mechanical, or cultural treatments in the proposed action would contribute to adverse cumulative impacts (Appendix E). Pacific Crest Trail Since there are no known invasive plant locations located on the Pacific Crest Trail, impacts from manual, mechanical, chemical, and cultural treatments would not exist unless an invasive plant infestation occurred in the future. If a future infestation is small enough along the PCT, it is possible that manual or mechanical treatment methods could be utilized before invasive plant managers decide to use chemical treatments. Short-term impacts to trail users from chemical treatments would only impact the four-mile stretch of PCT from Belden to the Lassen NF boundary, since it is not anticipated that herbicide would be used along the PCT section within the Bucks Lake Wilderness (approximately 12 miles). In the event chemical treatments would occur (outside wilderness) on the Pacific Crest Trail in the future, the impacts to trail users would be the inconvenience on a trail closure, however this impact would be short-term in nature, and would not exist once chemical treatments were completed. Project design features #9-13 listed in Table 6 would ensure any impacts to PCT users would be minimized, including any risks to human health. If future removal of invasive plants along the PCT and other trails would occur, it would have beneficial direct impacts to trails by ensuring that invasive plants would not infest trails within the project area, thus having beneficial indirect benefit to the recreational experience along trails. A focal target species near the PCT is yellow starthistle which is a menace to hikers and pack stock; its sharp spines irritate hikers, it reduces camping and hiking opportunities, and the plants can be unpalatable--sometime even toxic--to pack stock. Additionally, as native plants species recolonize trailside areas currently occupied by invasive plants, the area's ecological integrity would likely increase, creating a more aesthetic trail experience. There are no known past, present or reasonably foreseeable future projects that when considered with manual, 50

57 Mt. Hough Ranger District, Plumas National Forest mechanical, chemical, or cultural treatments under the proposed action, would have any significant cumulative effects on trails, including the Pacific Crest Trail, within the project boundary (Appendix E). Lands There would not be any negative impacts to land uses under special use authorization from mechanical, manual, chemical, or cultural treatments under the proposed action. There would likely be beneficial impacts to some of these land uses such as outfitter and guide permits that use recreation sites and frequent areas along the UNFFR because invasive plants would be controlled and or eradicated and provide a better recreation experience for their clients. Scenic Resources The proposed action alternative would meet the VQOs identified in the PNF LRMP (USDA 1988a). Proposed manual, mechanical, chemical, and cultural treatments would likely have an overall beneficial effect on visual resources by controlling, reducing, or eradicating existing invasive species infestations and restoring areas currently degraded and not meeting VQOs to the appropriate desired conditions identified in the PNF LRMP (USDA 1988a). There could be short term negative impacts to visual quality in treatment areas. Short term impacts from chemical treatments could include indictor dye and browning vegetation that could be visible for the season. The short term impact from indicator dye or browning vegetation would be replaced by the long term beneficial effect of enhancing and restoring the diversity of texture and color from native plants. Control or eradication of existing infestations and new infestations would reduce the likelihood that infestations would increase in size or number and adversely impact visual resource in areas that currently meet the VQOs. There are no known past, present or reasonably foreseeable future projects that when considered with the proposed action would contribute to adverse cumulative impacts to scenic resources. No Action Alternative Direct, Indirect, and Cumulative Effects Recreation Under the no action alternative, invasive plant infestations would not be controlled and would have negative impacts to recreation sites and trails where invasive plants are a nuisance to recreation users. Under the no action alternative, invasive plant infestations would continue to expand into areas of concentrated public use such as along roads, trails, and campgrounds, thereby negatively impacting recreation experiences. Known invasive plant infestations at recreation sites and trails would not be eliminated or controlled and would likely spread to other recreation sites and areas. Invasive plants such as yellow starthistle would continue to be a nuisance to recreation users and have negative indirect impacts on recreation experiences. Under the no action alternative, future invasive plant infestations at recreation sites and trails could have an adverse effect on native vegetation and other resources that contribute to the natural character of recreation sites and visitor experiences. In some instances, there could be negative cumulative impacts because invasive plant infestations have the potential to displace desired native plant species. Wilderness Under the no action alternative, the known infestation of Himalayan blackberry would not be eradicated. This infestation, along with future infestations, would have the potential to spread and increase in population size. If existing and future invasive plant infestations are not controlled or eradicated, there would be adverse impacts to wilderness values under direction 51

58 Storrie and Rich Fire Areas Invasive Plant Treatment Project from the Wilderness Act of The no action alternative has the potential to put wilderness values at risk that are protected under the Wilderness Act of 1964 if existing or future invasive plant species were to spread and increase in population size in the future, thereby having negative cumulative impacts on two of the five qualities of wilderness character (untrammeled and natural qualities). Wild and Scenic Under the no action alternative invasive plant infestations would not be substantially controlled. Invasive plant infestations would continue to expand on the Forest, increasing the probability of infestations within areas managed as Wild and Scenic Rivers, and adversely affecting the outstandingly remarkable values identified including scenery and recreation. There would also be a risk of expanding infestations having an adverse effect on fisheries, historical and cultural values. Implementation of the no action alternative would not negatively affect the free flowing condition of these rivers. Inventoried Roadless Areas (IRA) Under the no action alternative invasive plant infestations would not be substantially controlled within the Chips Creek IRA and other areas of the Forest, so would continue to expand, increasing the probability of infestations within the IRA. With this alternative there would be an increased likelihood that multiple IRA characteristics listed on page 44 that the Forest Service is responsible to manage, would be compromised. The potential to be designated as wilderness in the future could be at risk if IRA characteristics were compromised. There would likely be direct and indirect adverse impacts to characteristics and purposes of IRAs. Pacific Crest Trail (PCT) Under the no action alternative, negative direct impacts to the PCT and other trails would occur if future infestations of invasive plants along trails would not be controlled or eradicated. The known infestation of yellow starthistle adjacent to the PCT Equestrian Trailhead would be allowed to persist and have high potential to spread into areas along the PCT. An absence of treatments under the no action alternative would cause negative indirect impacts to the recreational experience along trails if invasive species like yellow starthistle spread and cause a menace to hikers and pack stock. There is potential for negative cumulative impacts to the PCT and other trails if invasive plants begin to outcompete native species because the area's ecological integrity would likely decrease, degrading the scenic quality along the Pacific Crest Trail and contributing to a negative recreation experience. Lands Under the no action alternative, there would likely be negative impacts to some of these land uses such as outfitters and guides that are permitted to use recreation sites and frequent areas along the UNFFR because invasive plants would not be controlled or eradicated. This could have a negative effect on the recreation experience of the clients of these outfitters and guides. There would be no cumulative impacts to Lands resources under the no action alternative. Compliance with the Forest Plan and Other Direction Wilderness The Bucks Lake Wilderness is managed to maintain and protect wilderness characteristics and values in accordance with the Wilderness Act of Five wilderness characteristics must be considered when management activities have the potential to affect wilderness character in a 52

59 Mt. Hough Ranger District, Plumas National Forest proposed project. Four of these wilderness characteristics are from Section 2 (c) of the Wilderness Act of 1964: untrammeled, natural, undeveloped, and outstanding opportunities for solitude or a primitive and unconfined type of recreation. There is a fifth quality; the unique qualities of a particular wilderness area, which is used to monitor wilderness character although it is not derived from the Wilderness Act of It is not anticipated that any of the five wilderness characteristics (opportunities for solitude, untrammeled, natural, undeveloped, or unique qualities of the Bucks Lake Wilderness) would be negatively impacted from manual, mechanical, chemical, or cultural treatments under the proposed action. Wild and Scenic The Upper North Fork of the Feather River (UNFFR) has five sections which were deemed to have potential for inclusion in the Wild and Scenic River System including the area from Belden to Caribou in the vicinity of Caribou Road. In accordance with management direction outlined in a memorandum to District Rangers dated May 8, 2001, all planned Forest Service Management activities within 1/4 mile of both sides of the river's bank need to be consistent with management direction for Wild and Scenic Rivers until a suitability determination is made through the land management planning process. Inventoried Roadless There is one Inventoried Roadless Area within the project area The Chips Creek Inventoried Roadless Area. This area is approximately 12,700 acres in size. Forest Service direction for management of Inventoried Roadless Areas (IRA) is to provide lasting protection for IRAs and to maintain the roadless characteristics which consist of 1) high quality or undisturbed soil, water, and air; 2) sources of public drinking water; 3) diversity of plant and animal communities; 4) habitat for threatened, endangered, proposed, candidate, and sensitive species and for those species dependent on large, undisturbed areas of land; 5) primitive, semi-primitive nonmotorized and semi-primitive motorized classes of dispersed recreation; 6) reference landscapes; 7) natural appearing landscapes with high scenic quality; 8) traditional cultural properties and sacred sites; and 9) other locally identified unique characteristics. A Ninth Circuit Court decision (Lands Council v Martin, 2008), also directs the Forest Service to consider the effects of activities within these areas on the potential for designation as wilderness areas. Hydrology and Soils Introduction The purpose of this document is to analyze, interpret, and discuss potential effects of the Storrie and Rich Fire Areas Invasive Plant Treatment Project (Storrie IPT Project) on soil and water resources located within the project area. Invasive plant treatments proposed include mechanical, manual, cultural, and chemical. Most of the known infestations are along roads in the project area. Setting The project area is located at the northern end of the Sierra Nevada physiographic provenance. It is located in the North Fork Feather River (NFFR) watershed. The area is generally mountainous and steep, with the NFFR Canyon and its major tributaries dominating much of the region. Total precipitation in the project area varies from 40 inches in the lower elevations of the canyon, to over 90 inches near Bucks Lake. Precipitation falls primarily as snow above 6,500 feet, 53

60 Storrie and Rich Fire Areas Invasive Plant Treatment Project and a combination of snow and rain below that elevation. Rain-on- snow events during the winter produce the largest flows and most destructive floods. Temperatures in the Storrie assessment area range from 68 degrees (all degrees are reported in Fahrenheit) in July to 35 degrees in January, with extremes ranging from summer highs of 108 degrees to minus 6 degrees in the winter. The NFFR is the largest tributary to Oroville Reservoir, which in turn is the main reservoir for the California State Water Project and the second largest reservoir in the state. In the project area, the NFFR is highly modified by hydropower development. Three separate Federal Energy Regulatory Commission (FERC) licenses cover the area. Many metrics for water quality and riparian conditions have been collected over the years, triggered by the licensing processes, so there is abundant data for evaluating existing conditions. The NFFR and its large mostly free flowing tributary the East Branch (EBNFFR) and other smaller tributaries in the project area can be mostly characterized as steep mountain streams and rivers. Smaller tributaries are extremely steep and their beds consist of boulders and/or bedrock. More sensitive meadow and wide, low- gradient, riparian habitat is very limited in this area. The geologic formations underlying the Storrie IPT Project area predominantly occur in northwest-southeast bands. The northeastern portion of the project area is primarily comprised of ultramafic metavolcanic rocks, the southwestern, granitic rocks. There are also portions of the project area that consist of marine derived Triassic and Paleozoic sedimentary and metasedimentary rocks. Most of the soils within the project are gravelly to sandy loams that are moderately to well drained (water passes through them easily). This includes soils that are derived from the metavolcanic and granitic rock types. More anomalous clayey and poorly drained soils occur in the Red Hill and Caribou Road area. These reddish soils develop on serpentine rock types. Affected Environment Soil Condition Weathered granodiorite is prevalent throughout the south part of the project area and is responsible for the abundant, well-drained, sandy loams. The serpentine belt generates shallow cobbly clayey soil in the vicinity of Red Hill. These soils are poorly drained in some areas. Parent material in the rest of the project area consists of metamorphic schist and slate, and volcanic andesite and basalt. Soils are generally coarse and shallow. Ground cover is below guidelines in some areas due to the consumption of vegetation by recent wildfires including the Storrie Fire (2000), the Canyon Complex (2008), the Rich Fire (2008), and the Chips Fire (2012). Much recovery has already occurred from the older fires, but the recent Chips Fire burned at moderate to high severity in the lower Chips, Mosquito, and North Fork Muggins sub-watersheds. Additional areas have reduced soil cover due to the impacts of roads and hydropower development. The Storrie IPT Project proposed action includes project design features (PDF #30) to mitigate ground cover where the removal of invasive plants creates bare soil. Treatment areas are relatively small and are not likely to affect soil condition or productivity. Watershed Condition The topography of the Storrie IPT Project area is generally steep and mountainous. The NFFR and EBNFFR are particularly impacted by infrastructure; they are followed by California State 54

61 Mt. Hough Ranger District, Plumas National Forest Highway 70 and the Union Pacific Railroad. Numerous dams impound water and divert it into a system of tunnels and penstocks to generate power. Management activities impacting conditions in the tributary watersheds are typical of the Cascade-Sierra region. They include roads (and especially roads in poor locations or that are poorly maintained), timber harvest, mining, and recreational use. There are a few small residential developments as well. Tributaries to the NFFR and EBNFFR are typical of steep Sierran streams, characterized by boulder and cobble beds. These sub-watershed areas have been affected by numerous wildfires in the area. The Storrie, Canyon Complex, Rich, and most recently, Chips Fire have all likely had detrimental effects to the existing watershed condition. Detrimental effects from wildfires typically include accelerated runoff and erosion, and possible increases to water temperature from the removal of riparian cover by fire. Water quality is the focus of this analysis because water is the resource most at risk when using herbicides. Extensive testing has been conducted as part of FERC relicensing in this project area. With a few minor exceptions, water quality has shown to be within the limits set by the state (FERC 1997; FERC 2005). Notable exceptions include a rating of impaired under the Clean Water Act (303d listed) for temperature and for polychlorinated biphenyl PCB which is a toxic substance once used to cool electric transformers. PCB s were released when a landslide damaged a PG&E switching station near Caribou in Much of this point source pollution has been remediated by PG&E and is documented in the 2105 Final Environmental Impact Statement for the Upper North Fork Hydropower Project (2005). Existing temperature issues have been determined to be caused by the reservoir system including the very large and shallow Lake Almanor. Specific water quality sampling for herbicides has been conducted by PG&E and their contractors as a requirement of their invasive plant treatments associated with Rock Creek Cresta and Bucks projects (Garcia and Associates 2009, 2011, 2012). During three years of sampling in the areas where herbicide treatments have occurred, there have been no detections of herbicides in the water. Effects Analysis Methodology The analysis methodology is designed to examine potential direct, indirect, and cumulative effects from proposed manual, mechanical, cultural, and chemical treatments to soil and water resources from the Storrie IPT Project. This analysis takes into account the setting, existing conditions, and past, present and future activities that may lead to cumulative effects. The proposed manual, mechanical, and cultural treatments are small in scale and pose negligible risk to soil and water resources. Chemical treatments would have more potential for risk and are more complicated to quantify, so these treatments are the focus of our analysis. Direct application to water is not proposed, so special attention is paid to direct effects to soils and the possibility of herbicide moving to water bodies from treatment sites. The Forest Service has a contract with Syracuse Environmental Research Associates, Inc. (SERA) to conduct human health and ecological risk assessments. These assessments are for herbicides that may be proposed for use on National Forest System lands. The information contained in this analysis relies on these risk assessments. Herbicide effects to relevant resources were analyzed in risk assessments for each of the five herbicides included in the proposed action (SERA 2003, 2007, 2011a,b,c). The risk assessments considered worst-case scenarios including accidental exposures and application at maximum reported rates. Although the risk assessments have limitations, they represent the best science available. 55

62 Storrie and Rich Fire Areas Invasive Plant Treatment Project The GLEAMS (Groundwater Loading Effects of Agricultural Management Systems) model examines the fate of herbicides in various soils under a variety of environmental conditions (SERA 2013). This model was used for all the Forest Service SERA risk assessments. This is a wellvalidated model for herbicide transport and is the best available at this time. The GLEAMS model was run with weather, soils, chemicals, and soils relevant to the project area. The GLEAMS model results, along with soil and landscape characteristics, helped guide the development of project design features (Table 6). These PDFs will reduce the risk of any detrimental effects and ensure compliance with management direction. Geographic and Temporal Bounds The Hydrologic Unit Code (HUC) 7 sub-watersheds affected by the Storrie and Rich Fires define the project boundary and this area also serves as the soil and hydrology analysis area (Figure 3). The project area does not include the upper portion of several sub-watersheds that lie on the Lassen National Forest. These headwater areas are mostly remote and are not actively managed. 56

63 Mt. Hough Ranger District, Plumas National Forest Sub-watershed # Sub-watershed HUC 7 Name 1 North Fork Feather River-Swamp Creek 2 Lower Rock Creek 3 Mill Creek-East Branch NF Feather River 4 North Fork Feather River-Chambers Creek 5 North Fork Feather River-Milk Ranch Creek 6 Mosquito Creek 7 Yellow Creek-Squirrel Creek 8 Lower Chips CreekTable Cell 9 East Branch NF Feather River-Serpentine Canyon 10 North Fork Feather River-Belden Forebay 11 North Fork Feather River-Gansner Bar Forebay 13 East Branch North Fork Feather River-Mill Creek 14 Lower Rush Creek 15 North Fork Feather River-Muggins Creek Figure 3. Map of sub-watersheds associated with project. Although the entire sub-watersheds are considered in this analysis, the main area of focus will be the geographic area where treatment is most likely to occur and where soil and water resources are at the highest risk. 57

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