This web page follows a series of letters to various government agencies as a case study of a noxious weed management action--Boulder Creek on the Okanogan National Forest--and what went wrong with plans. Preferred and recommended actions available to managers were ignored, in preference for more harmful actions, which impacted treated areas beyond acceptable limits.
Start here to follow the trail of information relating to the 1999 chemical applications along Boulder Creek on the Okanogan National Forest.
Chemicals were broadcast sprayed into weed-free riparian areas |
Trees providing shade and cover were killed |
Native plants were killed, weakening road stability |
Noxious weeds survived next to killed native plants |
Erosion and sedimentation was increased in this at-risk stream |
Spraying was done directly into T&E fish habitat |
[Letter of Aug 25, 1999, to agencies, requesting a review of serious problems caused by improper actions.]
August 25, 1999
George Wooten, Jr.
23 Aspen Lane
Winthrop, WA 98862
509-996-3835, gwooten@methow.com
To: All interested parties
Re: Herbicide spraying on Okanogan National Forest, 1999.
Sirs / Mmes:
I would like to request a site visit with representatives from the National Marine Fisheries Service (NMFS) and US Forest Service (USFS) to investigate the way in which riparian herbicide spraying is affecting riparian habitat along Boulder Creek and other Forest Service Roads. The 1999 spraying of Boulder Creek has resulted in apparent riparian tree mortality, foliage removal and unsightly browning along Boulder Creek road and in the Creek itself. I believe that the Okanogan National Forest (ONF) has not adequately analyzed the effects caused by this chemical application, including: (1) loss of habitat for T & E fish species, including Upper Columbia River steelhead and bull trout; (2) direct effect to T & E species; (3) indirect effects to T & E species, including grizzly bear and gray wolf; (4) direct and indirect effects to fish (including proposed westslope cutthroat), wildlife, riparian vegetation, and sensitive plants. The Methow Valley Ranger District (MVRD) is required to analyze these effects under the Endangered Species Act (ESA) and the National Environmental Policy Act (NEPA). This document refers to the following decision documents: Biological Evaluations and Noxious Weeds Date: July 12 1999, (BE) by Jennifer Molesworth, and the 1997 ONF Integrated Weed Management Environmental Assessment (EA) and Decision Notice (DN). The BE has not corrected the earlier inadequate analysis presented in the out- of date and inaccurate EA, as detailed below.
My experience in this matter stems from visits I made to Boulder Creek in July 1999, and from my training as a biochemist, botanist and wetland scientist. During my visits I noticed that both sides of the roadsides had been sprayed in a continuous stripe for miles up Boulder Creek (Treatment site #27, Bromas Creek / First Butte), going through several riparian areas that come within 50 feet of the road edge. The stripe consisted of a completely killed zone of vegetation, primarily native plants and including shrubs and trees.
My site visit indicates that treated roadsides have been denuded of their prior vegetative cover, which was primarily native species, thus increasing the amount of sediment delivered into the riparian system. This is contrary to the claims made in the EA, justifying the need for the spraying program. Rather than improving the habitat for fish and wildlife, the increased sedimentation impairs the quality of the riparian system, increases the amount of fine sediments into the channel and contributes to the embeddedness that plagues downstream fish redds. If siltation and embedding of redds is detrimental to listed fish species, then quite possibly the no effect determination of the BE is in error, and a take or harm may occur.
The herbicide treatment on Boulder Creek has caused the removal of beneficial native shrubs and trees along the road and within the adjacent riparian zone. This will result in a lowered recruitment of large woody debris (LWD) into the stream channel. Forest Service biologists are critically aware of the necessity of adequate stream side buffers that provide shade, cover and structural habitat for fish and maintain the continuous input of allochtonous material necessary to keep streams productive. Forest Service regulations (36 CFR §219.27 (e)) require that special attention be given to land and vegetation approximately 100 feet from the edge of all perennial streams, lakes, and other bodies of water. In a conversation I had on on August 23 with Christina Bauman, noxious weed specialist on the MVRD, I mentioned that the road appeared to have been continuously striped with herbicide along both sides clear up to the First Butte Lookout (Bromus Creek) Road, killing all vegetation within the striped zone, even across riparian areas. She replied that, on the contrary, hand wicking and spot spraying were used in riparian areas, but that in any case, the incidental killing of non-target species was an intended consequence of the spraying program. Such a management goal is arguably suboptimal on merit alone, however the BE specified hand wicking and spot spraying would occur in riparian areas as a mitigation measure for surfactant, and presumably, herbicide, entry into the water, not loss of vegetation. The loss and degradation of riparian habitat that occurred as a result of the spraying went unacknowledged in the BE, leading once again to the conclusion that the no effect determination is in error, and a take may occur.
Due to its phytotoxicity, the Environmental Protection Agency (EPA) compiled a list of over 70 species jeopardized by the use of glyphosate (US EPA, 1986). The BE did not disclose whether the herbicide removal of vegetation would affect any listed species, or if a survey for listed species occurred along the riparian corridor. In prior visits to the area, however, I have collected specimens from unusual species of willows (Salicaceae) which do not appear on list of species known from the ONF, but which should have been identified in any surveys for threatened, endangered or sensitive (TES) plants. This indicates TES surveys were not done prior to the application as specified in the EA. During my visit to the area in 1999, I noticed several of these willows in the riparian zone had been killed or defoliated by broadcast herbicide treatment, again in apparent violation of specifications in the EA and BE. I would like an independent botanist from an agency outside the USFS to review this issue with MVRD personnel to determine if any listed plant or other species were harmed. As a broad spectrum herbicide, glyphosate has documented phytotoxicity to a wide array of organisms, including lichens (Brown, 1995), nitrogen-fixing bacteria (Tu, 1994, Carlisle et al, 1986, Moorman et al, 1992, Martensson, 1992), beneficial mycorrhizal fungi (Estok et al, 1989, Chakravarty and Chatarpaul, 1990, Chakravarty and Chatarpaul, 1990, Sidhu and Chakravarty, 1990, and Chakravarty and Sidhy, 1987). These species are all integral components of the ecosystem which has been affected by spraying on Boulder Creek. The Carlisle study found that the rate of glyphosate degradation correlates with the soil respiration rate, an estimate of microbial activity. Glyphosate has been found to inhibit growth (at 50ppm) of 59% of randomly selected soil bacterial, fungal, actinomycete, and yeast isolates; of nine herbicides tested, glyphosate was the second most toxic. The no effect determination of the BE is likely in error, and a take or harm may have already occurred.
The EA and BE state that "herbicide label specifications will be followed". The label on Monsanto glyphosate formulation Rodeo© requires that it be applied in combination with an approved surfactant such as Ortho X-77 Spreader© (alkylarylpolyoxyethylene [AAPOE, a substance related to POEA, or polyethoxylated tallow amine, described below], isopropanol, water, and fatty acids). If the label requirements were followed then the BE is incorrect in stating that surfactants, "will not be used within the riparian buffers". In my August 23 conversation with Christina Bauman, she informed me that the Monsanto glyphosate formulation Rodeo© was used within 100 feet of riparian areas, without a surfactant. Either the BE is incorrect about following label requirements, or the BE is incorrect about the use of surfactants within the riparian buffer. It obviously can't be both. Either way, this is a serious matter. The ambivalence of official decision documents indicate to me that the effects analysis is flawed and the DN should not have been approved without consultation by a qualified chemist or biochemist. The gravity of this violation is that the Okanogan NF and Wenatchee NF weed control programs denied well-informed public comments raised about these points and sprayed vast tracts of land this year, willfully ignorant about the environmental effects. Such actions could be construed as arbitrary and capricious if this were reviewed by the courts.
At the time of this writing, I haven't determined whether or not the surfactant was used with the Rodeo© application. I am asking that your agency meet with the Forest Service staff and myself about this project, get the facts straight, and consider if there has been a taking. If the label directions to use a surfactant were ignored by the applicator, then there would be less chemical entry into the riparian ecosystem, assuming this is a one-time application, and the weed problem would be solved. But without the surfactant, the effectiveness of Rodeo© is lessened and the application becomes a waste of money.
According to a September 7, 1998, memo to acting director of the Washington State Noxious Weed Board, Lisa Lance, from the Ad Hoc Coalitioin for Willapa Bay, Nahcotta, WA 98637, a similar story of the failure of agencies to knowledgably use glyphosate has played out in attempting to control Spartina alternifolia (cordgrass) in Willapa Bay in Pacific County. In order to appease environmental pressure, The Nature Conservancy, in concert with some zealous Washington Congressmen, authored an EIS to control Spartina through hand-wicking with glyphosate. When this treatment didn't work, the 6-inch thick EIS was essentially ingored, and the chemical rewicked, and when this didn't work the chemical was sprayed from helicopters, and when this didn't work the helicopters returned, ad infinitum. I worked for the Forest Service when the EIS for Spartina control was released, and I remember the elation of the staff upon hearing that a safe herbicide was finally discovered that could be used in riparian ecosystems. Perhaps I have some of the details wrong, after all, nobody wants to admit failure, but the damage is that the program has since become institutionalized by a Forest Service all too anxious for a quick-fix which doesn't exist.
Weeds are not directly causing fish mortality, but indirectly through habitat loss. In fact, weeds are a symptom of poor forest health brought on by years of roading, logging and livestock grazing on the ONF. Because of the rugged terrain, most MVRD roads are located along streams and rivers, where they have become festering sores in the fragile glacial soils. The ONF has been largely unsuccessful at establishing beneficial vegetation along roadsides, and relies primarily on forage grass plantings for road maintenance. Orchard grass, Kentucky bluegrass, timothy and intermediate and crested wheat are planted in riparian sites, replacing shrub-dominated communities with grasses amenable to management. These grasses then attract cattle to preferentially graze along the roadsides, converting them into linear pastures. The increased disturbance provides a seedbed for weed seeds travelling on and in cattle and cars, and the trampling scarifies and plants the seeds, even providing hoof-prints to hold water and aid the weeds during spring germination. The problem of sedimentation and erosion affecting T & E fish in Boulder Creek has not been improved by the MVRD's weed treatment program-it is worse. The damage wrought by management to riparian habitats is amply documented by scientists on the Wenatchee and Okanogan National Forests (Everett, 1994, Johnson, 1994, Wissmar, 1994). What is lacking is resolve on the part of the agencies to deal with the causes of the problem, and change the way cattle grazing occurs along streams and rivers.
The inescapable conclusion is that the cause of weed spread and the damage to riparian ecosystems are both being caused by uncontrolled cattle trampling and grazing. NMFS and the USFS need to reconcile conflicting goals and assign a fair percentage of damage to riparian habitat where it belongs-livestock grazing along forest roads. But while it is the duty of the USFS to examine and correct the cause of the weed problem, it is the duty of NMFS to attend to the problem of T & E species impacts, which is why I am writing this letter, asking for an investigation into the damage caused on the MVRD through the weed management program. It is unfair that NMFS expects one hundred percent assurance that fish are not harmed through delivery of water through the Skyline irrigation canal, when the USFS is allowing far more damage to occur through its weed management program, with only a nod and a wink to the cattlemen.
Returning to the subject of the spraying incident on Boulder Creek, for the moment let's assume that the applicator had the common sense to follow the label directions, since label violations could result in license forfeiture. In that case, the action to go ahead with the spraying plan appears to be an arbitrary and capricious decision, as the Forest Service did not avail itself of recent documented effects from the chemical threats posed to ecosystems by glyphosate, Rodeo©, or X-77 Spreader©. The EA listed as references for glyphosate toxicity were Folmar et al (1979) and Newton et al (1984), yet these appear not to have been read, for the BE to have garnered a no effect.
The first reference found that in fish exposed to 2.0 mg/L of Roundup (another glyphosate formulation) the fillets contained 80 mg/kg of glyphosate and the eggs contained 60 ug/kg. Roundup is four times more toxic to rainbow trout fry and fingerlings than to larger fish. Also, significant increases in stream drift of midge larvae was observed after the 2.0 mg/L of Roundup treatment. The toxicity of Roundup to rainbow trout and bluegill increased with increasing temperature. Roundup was about twice as toxic to rainbow trout at 17 degrees C than at 7 degrees C. It is also more toxic to bluegills at 27 degrees C than at 17 degrees C. Roundup was more toxic to rainbow trout and bluegills at pH7.5 than at pH6.5. Technical glyphosate was less toxic to fish at a higher pH, but the surfactant appeared to be more toxic at the higher pH. Solutions of Roundup aged for up to 7 days in reconstituted water at 12 and 22 degrees C did not change in toxicity to midge larvae, rainbow trout, or bluegills. Applications of Roundup to ditchbanks near aquatic ecosystems may be hazardous to resident fauna, particularly if the water temperatures are elevated or the pH exceeds 7.5. This is important because glyphosate causes water temperatures to increase for several years following treatment (Holtby and Baillie, 1987).
In the 1984 report by Newton, glyphosate residues and metabolites were evaluated in forest brush field in Oregon coast range. Concentrations were higher in sediment than in water and persisted longer. Early stream-bottom samples reflected concentratrions found in the streamwater, but later samples showed that even the water concentrations occurring below the detection limit may contain enough glyphosate to contribute to adsorption by sediments. Of particular interest was the author's finding that residues (of glyphosate) in animals may remain detectable for several months. Concentrations in viscera were always higher than those in the remainder of the animal. This indicates that the BE did not even consider the one available reference they had that indicated measurable levels of herbicide can and do become detectable in fish:
"Hand application of glyphosate within the buffers, the spill plan and mixing requirements, the small amount of herbicide near water at any given time, the rapid dilution of chemicals if they do enter the water all keep the potential effect to listed fish at a non measurable level. Any herbicide that does enter the water should be an insignificant amount."
Since the publication of Newton in 1984, reports of the toxicity of glyphosate formulations on fish and wildlife have become widespread in the scientific literature. The Forest Service was given ample information through scoping on the EA to avail themselves of this literature, yet they chose to ignore it through the implementation of the project, in violation of National Environmental Policy Act (NEPA) procedures, and Endangered Species Act (ESA) consultation procedures.
Glyphosate is acutely toxic to fish (Servizi et al, 1987). This report summarizes the acute lethality of Garlon 4, Roundup and a surfactant (MON 0818) contained in the formulation of the latter to sockeye salmon, rainbow trout and coho salmon. This study is important because it establishes the evidence that the combined effect of glyphosate and the surfactant POEA is more than additive (synergism). MON0818 (surfactant) was tested separately from glyphosate and found to be much more toxic than the latter. Further testing showed that the combined effect of glyphosate and MON0818 were "more than additive and raises doubt that the LC50's reported for Roundup in reconstituted water are applicable to natural waters.
Acute toxicities of Rodeo©, with X-77 Spreader© per label recommendations, vary from 120 to 290 ppm (Mitchell et al, 1987). Effects on pink and chum salmon are more serious than on coho and chinook (Wan et al, 1989).
Sublethal effects of glyphosate on fish include erratic swimming, labored breathing, altered feeding, migration and reproduction, and increased likelihood of being eaten (Morgan, J.D., et al, 1991, Liong et al, 1988).
Clearly the "no effect" determination of the BE occurred without substantial review. I would like to request NMFS review of this oversight so that the correct assignment of effects be given to the herbicide program, including incidental takings or harm to listed fish species.
The effects of glyphosate are not limited to fish and plants. Connor and McMillan (1990) compared moose forage resources on control and on herbicided cutovers near Thunder Bay, Ontario. Available moose browse, on control areas, was four times greater, and browse utilized was 32 times greater, than in treated areas after one growing season post-spray. Winter moose presence was almost two times greater on untreated than treated areas after one growing season and similar at two growing seasons post-spray. An important issue that needs to be considered is the effect of spraying sizable contiguous areas, substantially affecting food supplies within the home ranges of a number of moose, and the eventual effect on moose populations. The Chewuch watershed is just beginning to show a comeback in moose, and the effect of this ill-conceived herbicide spray program needs to be assessed. Other species besides moose, for example lynx and grizzly bear, use the Boulder Creek area. A possibly grizzly bear and cub sighting was made by Charlie Dewberry in 1998 on the sprayed section of Boulder Creek, however the BE did not analyse the effects of herbicide on listed mammals, and should not have been approved, for this omission.
Martinez and Brown (1991) found that the surfactant POEA (in doses of 1.03g/kg ) has serious pulmonary toxicity, but not quite as serious as the full formulation, Roundup which produced 100% death in rat subjects within 24 hours. Recent cases of poisoning in suicide attempts using a 41% glyphosate concentration have produced life-threatening symptoms (in humans) and a DEATH RATE of 10-20%, in spite of animal studies which show that the active ingredient, glyphosate, has a toxicity of approximately 5g/kg. This is important because gilled species are also more susceptible to surfactants (Rankin et al, 1982).
A number of studies show detrimental effects from glyphosate on birds (Cox, 1991, 1995a, 1995b). A study by MacKinnon and Freedman (1993) examined the effects of silvicultural glyphosate use on breeding birds near Stewiacke, Nova Scotia. Densities of most common breeding species decreased on all treatment plots, including the reference plot. The White-throated sparrow and the common yellow decreased significantly, as did also the alder flycatcher, especially on the spray plots. The BE did not analyse the effects of herbicide on birds, and should not have been approved.
Glyphosate causes a magnitude of untoward effects to the entire aquatic food chain. Austin et al (1991) found that glyphosate could potentially act as a phosphorus source and thus could stimulate undesirable eutrophication of waterways, especially those used by salmon or trout. The paucity of published research on the action of glyphosate on aquatic species composition, bioaccummulation, food chain relationships, further recommends caution in the application of this herbicide, which unfortunately has gone unheeded by the ONF and WNF. Buhl and Faerber (1989) found that Roundup treatment of a Maine clearcut caused an 89 percent decline in the numbers of the midge Chironomas riparius. This species is an important food resource in the food chain.
In studies commissioned by the Department of Environmental Protection in Southwest Australia, Bidwell and Gorrie (1995) showed that tadpoles (which respire with gills) were many more times sensitive to the full formulation than adult frogs, and were considerably more sensitive to the formulation (Roundup 360) than to technical grade glyphosate. Some surfactants affect aquatic organisms by damaging the gill membrane. LC50 values for adult frogs indicate there may be very little safety margin between concentrations in shallow water and concentrations lethal to frogs. Frogs are exposed to herbicides through runoff or overspray from treated areas adjacent to permanent or temporary wetlands.
Goldsborough and Brown (1988) assesses the effects of the Roundup formulation of glyphosate on short term carbon assimilation by periphytic (growing in fresh water) algal communities collected from six small forest ponds. The six study ponds were located in boreal forest near Lake Winnepeg in Manitoba. The short term photosynthetic rates of intact periphyton communities were significantly impacted by glyphosate additions. Glyphosate concentrations less than .89mg/L had no effect on short term algal photosynthesis, while the EC-50 value (glyphosate level resulting in 50% inhibition of carbon fixation) lies between 8.9 and 89mg/L.
Also there has been no description of the effect from the carriers so-called "inert ingredients" in the herbicide forumulations used, nor on the cumulative effects of combining the herbicide glyphosate with picloram. In a chapter from their book, Colborn and Clement (1992) examine the issue of increased exposure to pesticides (including herbicides and fungicides) and the difficulties encountered in obtaining any meaningful measurements of these exposures for women, children, even embryos in vivo. (Most standards of exposure are geared to the adult male.) Exposure (to active and so-called "inert" ingredients) through treated food and contaminated water are now combined with exposures through rainwater, snow, household dust, yard soil and indoor air. The timing of exposure, even to a small amount, can have a profound effect on an embryo. No studies showing cumulative exposure from all pathways could be found. There are many reproductive and endocrinological effects associated with herbicides and fungicides. The reassessment and reregistration of many older pesticides (using new techniques) mandated by law in 1988 had not been conducted in 1990. False claims about the safety of pesticides, combined with flaws in the federal registration process, raise serious concerns about increased exposure to environmental chemicals, when there is lack of information on their reproductive and endocrinological effects, synergy, bioaccumulation, and continual low-dose exposure.
Certain chemicals in the environment are estrogenic Arnold et al (1996). Low potencies of these compounds when studied singly may indicate little effect on biological systems. However, combinations of two weak estrogen-mimicking chemicals were 1000 (!) times as potent as any chemical alone. This synergistic interaction of chemical mixtures with the estrogen receptor has profound environmental implications for the ONF, which hasn't considered the synergistic or cumulative effects of their project on listed species.
The ONF does not have the means to carry out such complicated analyses in its EAs and BEs, let alone even read the recent literature. It is not reasonable to expect that the ONF or WNF produce a reasonable description of the effects of weed control on the National Forests. Both documents should be withdrawn and the real job of protecting salmon through control of mismanagement begun.
Unfortunately the detrimental effects on the aquatic food chain have already occurred. It is unfortunate that the job of documenting these effects should fall on citizens rather than paid agency personnel. I have neither the time nor financial resources to document the extent of harm to T & E species which has been caused by the MVRD on Boulder Creek, and throughout the ONF and WNF by this unfortunate circumstance. I would appreciate the assistance of NMFS in helping to resolve my concerns about fish, and USFS about wildlife.
It was dismaying to visit Boulder, Wolf and McFarland Creeks only to find out that the MVRD had sprayed them without public notice. After spending countless hours commenting on the scoping and EA documents, the MVRD apparently owes nothing to the public. The BE was not distributed, no warning signs were posted along the road side, and the promise to contact sensitive individuals (of which I am one) made in the EA was not kept. The herbicides sprayed in McFarland Creek caused me to have intense headaches all day long. The herbicide formulations used there appear to have been dispersed in a solvent carrier, which was highly irritating to work in. Part of my income comes from sales of natural scents and oils, however the sprays used by the MVRD in McFarland Creek impair my ability to sense smells. Obviously if I can smell these chemicals, then fish, with their highly developed sensory organs, can sense, and possibly avoid, them and the entire Methow River system. Avoidance of pesticide polluted rivers by anadromous fish has been documented (Ewing, 1999).
Almost every road in McFarland Creek was completely saturated with herbicide, from the ridge tops to the Methow River. In private talks with people in the area, it appears that the Okanogan National Forest is not acting under a Federal Program, but rather under pressure from the Okanogan County Noxious Weed Control Board. Almost to confirm this, at the bottom of the McFarland road, I photographed the Okanogan County spray truck spraying herbicide directly into the Methow River. Although the sprayed cover many miles, but the infestations are not being controlled, only hidden.
To address the native tree and shrub mortality caused by the herbicide spraying, the following quote from Karen Ripley, DNR Resource Protection Division, upon discovering the extent of ponderosa pine mortality caused by the Department of Transportation (DOT) roadside spray program in fall, 1998, is relevant:
"Such damage must be prevented in the future. Noxious weeds, road surface integrity, visibility, ditch maintenance and vegetation control are all very critical and consequential road management issues. As manager of DNR's Forest Health program, I am interested in solutions to these issues which also are compatible with healthy roadside forest trees.
If a roadside chemical is being applied which is damaging to the trees, a substitute chemical or practice must be located. There is an especially critical need to find suitable ways of managing roadsides that are adjacent to major waterways such as Peshastin Creek and the Okanogan and Methow Rivers.
Next Steps: It. is important to pursue the larger goal that such tree injuries not be repeated."
My hope is that NMFS will also take such impacts to their resource to heart when they contact the Forest Service about these issues and concerns.
Sincerely yours,
George Wooten
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Tu, C.M. 1994. Effects of herbicides and fumigants on microbial activities in soil. Bull. Environ. Contam. Toxicol. 53:12-17
USDI-Bureau of Land Management. 1994. Noxious Weed Strategy for Oregon/Washington. USDI-BLM Lakeview District Office, Lakeview, OR.
Wan MT, Watts RG, Moul D.J. 1989. Effects of different dilution water types on the acute toxicity to juvenile Pacific salmonids and rainbow trout of glyphosate and its formulated products. Bull Environ Contam Toxicol 43:378-385.
Wissmar, Robert C., J.E. Smith, B.A. McIntosh, H.W. Li, G.H. Reeves, J.R. Sedell. 1994. Ecological Health of River Basins in Forested Regions of Eastern Washington and Oregon. USDA-FS Gen. Tech. Rep. PNW-GTR-326, PNW Region, Portland, OR. 66 p.
CASE STUDY:
[Damage survey on Boulder Creek of Sept 23, 1999. Click
here to view some of the photographs accompanying this report.]
BOULDER CREEK MONITORING SURVEY to assess herbicide impacts - George Wooten, 9/23/99
KEY: Mileposts begin at the Okanogan NF sign on the Chewuch Road, just before crossing Boulder Creek. Numbers refer to roll of photo numbers. All plants described are natives except planted sheep fescue, spotted knapweed and diffuse knapweed. Used here, erosion refers to soil movement; sedimentation refers to movement of soils into the streams, wetlands and other aquatic areas.
0.0 ONF sign on E. Chewuch Road.
0.1 (#1-7) Boulder Bridge - killed bitterbrush inside bank; spotted knapweed, not diffuse knapweed; 90% kill.
0.2 (#1-18,19) Begin Boulder road grade - strip of dead bitterbrush and ponderosa pine.
0.3 (#1-20) Ditto; green, live bitterbrush in background of photo.
0.7 (#1-21) Looking into gorge - bitterbrush 30% cover killed >50%. Summary: 10/20 bitterbrush killed and 0/3 knapweed within the bank are killed. The buffers on this bank are too wide to be glyphosate; Tordon?
1.4 (#1-22, 23) Herbicide-burned ponderosa, Douglas fir along road within 50' of bank with dead dogbane and 1 dead knapweed plant. Culvert shows delivery of contaminants to other side of road. Second photo shows close-up of vegetation removal (bitterbrush and dogbane), denuding soil.
1.6 (#1-24, 25) Ponderosa, bitterbrush, buckbrush brown and killed, causing increased sedimentation and susceptibility to weed infestation.
1.8 (#1-26) Riparian vegetation (Nootka rose, Pacific willow, red-osier dogwood, mountain alder) leaves brown and killed in riparian channel. Sedimentation extreme. Knapweed not all killed. Amount of native vegetation killed is approximately 100 times that of the percent knapweed killed.
1.9 Calcareous seep coming in possible TES plant site.
2.1 (#1-27,28) Road bank eroding into river. 10% cover of existing vegetation (diffuse knapweed, fireweed) all killed or heavily damaged leaving no vegetation to stabilize bank. Douglas fir on left, willow on right killed in a 50' strip; knapweed less than 10 plants. Roadside grasses are non-native sheep fescue at approximately 50% cover.
2.4 (#1-29) Ponderosa pine is browned inside a sandy floodplain.
2.5 (#1-30) Overgrazed road pullout and unmarked road are left untreated leaving knapweed to reinfest. No controls on cattle.
3.0 (#1-31) Eroding knapweed infestation left alone on bank side while bitterbrush is killed on the uphill side.
3.2 (#1-32) Sprayed knapweed left fully viable.
3.5 (#1-33) Killed alder is 15' from road leaving banks denuded and eroding.
3.8 (#1-34) Damaged ponderosa, willow in stream channel 10' below road; knapweed proliferates and 2 plants of sheep fescue are grazed; sedimentation increased.
4.0 (#2-1) Cattle browsing in riparian landing.
4.3 (#2-2) Damaged road corridor both sides - impacted vegetation is mostly native; spotted knapweed is viable beyond prism; esthetically unattractive.
4.6 (#2-3,4,5,6) Damaged riparian vegetation (alder, maple, rose, dogwood) both sides of road, while spotted knapweed is unaffected and is seeding out. Sheep fescue is ineffective at stopping erosion. Pool vegetation is directly affected (treatment directly into water).
4.7 (#2-7) Fireweed killed, knapweed seeding increased; sedimentation increased.
4.8 (#2-8) Killed alder along road in riparian areas.
5.0 (#2-9, 10) Roadside vegetation (buckbrush, Scouler willow) killed; knapweed flowering and goint to seed; sedimentation increased.
5.1 (#2-11) Cottonwood and fireweed killed; potential halted for large woody debris contribution; sedimentation increased.
5.2 (#2-12, 13) Ponderosa damaged, spotted and diffuse knapweed flourishing; sheep fescue overgrazed, erosion increasing. Photo #13 is close-up of cattle use of road prism.
5.3 (#2-14) Typical cattle trail through killed dogbane and browned ponderosa to access sheep fescue while increasing erosion.
5.4 (#2-15) Killed bearberry and Douglas fir where no knapweed previously occurred.
5.5 (#2-16) Untreated landing with killed native plants along road.
5.6 (#2-17, 18, 19) Killed 30' tall Douglas fir along road and 70% killed buckbrush along roadside ditch. Number of dead knapweed seen in 100' stretch equals one plant. A half-killed Douglas fir and about ten killed alder are along the road in a riparian area. Black-cap raspberry is killed; sedimentation is increasing; 10' tall Douglas fir seedlings are killed or half-killed above the road.
5.7 (#2-21) Sedimentation is increased as a direct result of loss of structural stability in the soil above the riparian area.
CONCLUSIONS (*'d items result in direct loss of habitat and taking of T & E fish.):
*1. Native upland, riparian and wetland vegetation killed along road and within riparian areas; loss of shading and habitat degradation results.
2. Erosion from vegetation removal generally increased throughout the area, degrading wildlife habitat.
*3. Sedimentation into the stream is increased wherever roads are adjacent to riparian areas, due to vevetation removal, thus resulting in decreased wildlife and fish habitat and degradation of fish spawning gravels through embedding of stream gravels.
4. Mitigation of sedimentation through roadside planting did not occur, leaving roadsides in worse condition than before treatment.
5. Existing sheep fescue planted along road is attracting cattle preferentially into the road prism due to higher protein content of fescue, and resistance to herbicide treatment. Erosion and sedimentation are increased due to cattle trampling; no mitigation of cattle movement is occurring.
*6. Potential for large woody debris input into riparian areas is decreased, reversing the potential for long-term recovery of the riparian ecosystem by 20 to 30 years in some cases.
7. Targeted noxious weeds infestations were not targeted for site-specific removal, leading to existing infestations seeding and increasing chances for spread of seed from infested roadsides.
8. Targeted noxious weeds preferentially survived, preferentially leaving resistant patches of noxious weeds to reinfest the roadside.
9. Noxious weeds occurring along the road were incorrectly identified as diffuse knapweed, when spotted knapweed was prevalent. Spotted knapweed is longer-lived, and has a more extensive root system, therefore treatments were ineffective.
ADDITIONAL NOTES:
1. No notification of sensitive individuals was given during treatment as required by state law (confirmed by George Wooten, registered sensitive individual)
2. No signage of treated areas was provided as specified in the EA.
3. Label requirements for herbicide formulation were not followed.
4. The Biological Evaluation was not reviewed publicly, nor was it prepared with proper authority to judge chemical effects; the BE was too brief to yield reasonable assessment of impacts; the BE was incorrect in its assumption of impacts; the BE was incorrect in its finding of "no effect".
CASE STUDY
[Letter of Februray 22, 2000, notifying responsible agencies
of the problem, their responsibilities, and suggesting a resolution.]
Feb 22, 2000
George Wooten, Jr.
23 Aspen Lane
Winthrop, WA 98862
509-996-3835, gwooten@methow.com
To: All interested parties
Re: Herbicide spraying on Okanogan National Forest, 1999.
Hello,
This letter summarizes some of the information gathered related to the 1999 chemical applications along Boulder Creek, a Chewuch River tributary, and other areas on the Okanogan National Forest. The main points in this letter follow on prior correspondence already mailed out to Keith Rowland, Okanogan National Forest (ONF), Stuart Cory, National Marine Fisheries Service (NMFS), Bill Noble, US Fish and Wildlife Service (USFWS), Ed Von Grey, Washington State Department of Agriculture (WSDA), Cristina Bauman, Methow Valley Ranger District (MVRD), as well as others (Wooten letter, Aug 1999).
This letter also responds to a notification from Gary Smith, R-6, RO, that for the Forest Service to review recent references on pesticides, a detailed reply was required of why the referenced studies would significantly change or alter any of the consequences that the Forest Service has or will disclose to the public. So, with due respect, here goes.
The following points should have been taken into consideration during the design and implementation of the the 1997 EA for the ONF chemical program. Subsequent to the chemical application, most of these unplanned impacts have not been disclosed, leaving the public and and agency personnel with unrealistic beliefs about the success of the program, which is now being ushered forward without heed.
1. The 1999 chemical application resulted in significant damage and killing of native vegetation along Boulder Creek. A ten-foot-wide swath of roadside vegetation, including trees over 30 feet in height, was damaged or killed along five miles of riparian habitat. This riparian habitat degradation occurred in waters occupied by listed species, including Upper Columbia River steelhead, bull trout and potentially, west-slope cutthroat. Photographs and monitoring of the vegetation and soil damages are available on request (Wooten, Sept 23, 1999 survey). Some photographs and documentation are on the Web at (http://www.methow.com/~gwooten/ecology/bould.htm). Habitat and resource damage includes loss of shade, raised stream temperatures, loss of detrital and organic contributions to the system, and loss of large woody debris. These factors are widely agreed upon by biologists as critical components of the aquatic habitat.
2. The 1999 chemical application resulted in increased erosion and destabilization of streambank integrity. Actively eroding banks were further devegetated, resulting in increased sedimentation and erosion during fall 1999. Soil exposure was increased, brought on by damage and removal of beneficial native vegetation along five miles of habitat. Photographs and monitoring of the erosion and sedimentation damage is available on request (Wooten, Sept 23, 1999 survey). Damage to aquatic habitat from increased sedimentation, siltation and erosion are widely agreed upon by biologists as contributing to the decline of listed species.
According to Rieman and McIntyre (1993), ". . .any increase in the proportion of fines in substrates should be considered a risk to. . .the persistence of associated bull trout populations."; "cover is important in winter and is thought to limit many fish populations."; ". . .we must conclude that temperature represents a critical habitat characteristic."; "managers must consider any disruption in important habitat characteristics a threat to the persistence of a bull trout population."
3. Results of Sensitive plant surveys to identify potential impacts were not included in the 1997 EA, as required by the National Environmental Policy Act (NEPA). Several unique species occur in the Boulder Creek drainage, yet the documentation does not indicate that any Sensitive plant surveys were completed prior to the application. The document from SERA indicated harm to sensitive plants was possible.
4. The 1999 date on the BE indicates it was written two years after the 1997 Environmental Assessment (EA), and 3 years after the 1996 SERA paper which were to have disclosed the effects of glyphosate application, under NEPA and the National Forest Management Act (NFMA). The BE did not incorporate a review of biochemical effects and environmental fate sufficient to inform the decision-maker of the impacts that occurred as a result of that application, except by reference to the above outdated reviews. The damage that resulted can thus be attributed to an inadequate decision document, yet impacts to off-target plants were acknowledged as a problem in SERA ("If plants are accidentally sprayed at the application rates used by the Forest Service, they are likely to be damaged, particularly in the upper ranges of anticipated application rates. This kind of exposure may be regarded as an accidental scenario, which is relatively easy to control with proper management and application."). To further ignore these predicted environmental impacts amounts to negligence by management.
5. The 1999 applicator was issued a Notice of Correction by the Washington Department of Agriculture Pesticide Management Division, and the Forest Service was issued a Letter of Review as a public record for label violation (WSDA Case File 051C-99).
6. Health measures were not incorporated into the project, e.g., some sensitive individuals were not contacted by the FS, and no roadside spray warnings were posted.
7. The application was apparently broadcast sprayed, thus affecting mostly native species. The BE specified hand wicking and spot spraying would occur in riparian areas, yet photographs clearly show a ten-foot-wide or greater band of spraying occurred for most of the length of the Boulder Creek area treated.
8. The 1999 application on Boulder Creek occurred in a drainage used by T & E species, including grizzly bear, gray wolf, lynx and bald eagle, yet no documentation was provided for potential effects from this application or on the 74 other treated sites.
9. The 1999 application resulted in loss of the visual quality resource, and production of a strip of brown or dead vegetation along a major Forest road, which lessens the value of the ONF to recreational visitors. This was not documented in the EA.
10. The ONF is proposing to continue this chemical application program in the year 2000 (EA, 1999) using the same chemicals, and without providing reviewers with monitoring information on the damage and impacts caused by the 1999 application, which may now be in need of restorative efforts. Public review of monitoring information and discussion of problems arising from the 1999 program should occur before the year 2000 program begins. An appeal of the 1999 EA was denied because of assurances by the Regional Office and ONF that all impacts had been discussed and analysed, and that a scenario such as this would not happen, even after it already had. The above points regarding the 1999 application leave serious doubt about the ability of the next project to perform as planned. According to the FS, no riparian spraying will occur in year 2000, which seems to be an admission that the 1999 spraying in riparian corridors was a mistake. Appellants also contend that the FS has not correctly identified riparian buffers or identified sources of chemical transport.
11. The recent actions taken by NMFS in closing federal water diversions to protect Methow Valley anadromous fish habitat has not taken account of the affects on listed fish due to damage to the above habitat components--shade, cover, detritus and organic contributions, stream temperatures, large woody debris, and effects from erosion and siltation. USFWS also responsibility to insure that the high quality habitat requirements necessary for bull trout to persist, which is already at risk along this grazed and roaded stretch of stream, has not further declined as a result of this action. The inescapable conclusion from this survey indicates that indeed, habitat was degraded as a result of this application.
12. The application was ineffective in controlling noxious weeds. Monitoring surveys (Wooten, Sept 1999) indicate that frequently, patches of noxious weeds remained growing at more than 50% of their original cover. Due to the removal of competition, further weed spread has been facilitated, exceeding the action threshold for vegetation control more than before the spray program (Region 6 ROD, 1988.
13. Methods of weed prevention available to the ONF were not used in this area as claimed in the 1997 EA, and required by the Mediated Agreement and Region 6 ROD (1988). In particular, stream bank vegetation is degraded along Boulder Creek, aggravated by years of uncontrolled cattle and road disturbances. The goal of management should be stabilizing streambank soils and restoring the vegetative condition to a healthy, diverse cover, and the methods should include discouraging livestock and vehicle disturbances and planting beneficial plants that can stabilize soils without attracting livestock. These prevention measures will be harder to perform now that native species have been removed and noxious weeds benefitted by the application.
14. The Forest Service Washington Office (WO), in a letter from Janice McDougle, indicates that the Forest Service regularly reviews their risk assessments and pays particular attention to monitoring EPA chemical registration notices. If that were so, then why wasn't anyone paying attention when the ONF proposed it would intentionally violate the label as a mitigation measure for the 1999 chemical application project? According to the BE, the reasons for violating the label were ostensibly to protect listed fish species, but in ignoring the proper application method, the operation may have been rendered ineffective. But, according to the Washington Pesticide Control Act, RCW 15.58.150(2)(c) states "It shall be unlawful for any person to use. . .any pesticide contrary to label directions. . ."
The WO letter was written to suggest that under NEPA, the Forest Service has no requirement to review all recent herbicide references submitted by an individual, unless the submitter explains, in detail, why the studies referenced would significantly change or alter any of the consequences that the Forest Service has or will disclose to the public. I submit that the failure of a weed control program to effectively meet its stated goal to control noxious weeds, while simultaneously killing predominantly native, roadside, riparian vegetation and degrading habitat for listed species along a five-mile wide swath, is a significant lack of disclosure. In addition, another 75 sites treated in 1999 may have similar undisclosed impacts or unrealized goals. The undocumented environmental impacts, combined with the revenue lost during this program, indicate it is ill-conceived.
SERA made numerous notes about the risks to off-target vegetation, and the outcome indicates that these risks weren't understood or heeded in the 1997 or 1999 EAs. Quotes from SERA are included attached to the the bottom of this letter.
I would like to further submit that regardless of the Forest Service's NEPA requirments, the EPA under FIFRA, NMFS and USFWS under the Endangered Species Act (ESA), and all of the reviewers of a project, need to review and understand recent information and citations, and know about and disclose what impacts could foreseeably occur as a result of the proposals. Unfortunately, there is not a large body of literature about the effects of these chemicals on the dry, sandy, glacial soils being treated, that can be used to guide management. As in any experiment, monitoring should have alerted managers here that something was gravely wrong. Looking at the effects at the Boulder Creek site, it is apparent that the 1999 program failed to control weeds and contributed to a decline in forest health.
The lack of disclosure of impacts to riparian habitat described here is tantamount to arbitrary and capricious management, and the failure of chemical applications to benefit riparian vegetation or control weeds in an effective manner should be serious enough of a charge for the FS WO to consider the need for additional reviews. Yet the persistence of the ONF and R-6 RO in forging blindly ahead with this program indicates that any documentation of the 1999 impacts, if they exist, were not considered nor disclosed.
Having spent quite a few years studying the management, biology and ecology of invasive species, I previously commented to the Forest Service that such quick fixes can be expected to fail. Public comments to the EAs indicated a strong opposition to the chemical alternatives used. In addition, suggested preventive measures which could have been undertaken were not considered. Managers of public lands can no longer afford to make such costly failures, particularly when modern methods of restoration and ecosystem management are available.
At this point, it is very important to me and to other members of the
public to receive assurances from my government that these impacts and
costs will not be swept under the rug. This survey indicates that it would
be a blunder to continue with the next phase of this program, which blindly
proposes new treatment sites separate from any context of the failure of
the 1999 program. This situation needs attention and correction from the
responsible agencies, EPA, NMFS, USFWS, and FS. I am anxious to hear from
one of your staff about these matters so that we may begin an open dialogue
about how to solve the problems.
Thank you very much.
Respectfully,
George Wooten, Botanist, Biochemist
Referenced documents as cited [hyperlinks added during development of this web site].
Attachment: Quotes from the SERA regarding off-target plant impacts.
. . .4.2.2. Terrestrial Plants. The primary hazard to non-target terrestrial plants is from unintended direct deposition or spray drift. Unintended direct spray will result in exposure equivalent to the application rate. As discussed in the dose-response assessment for terrestrial plants (section 4.3.3), such exposures are likely to result in adverse effects to a number of plant species.
. . .Direct deposition, either through unintentional direct spraying or spray drift does present a plausible hazard. If plants are accidentally sprayed at the application rates used by the Forest Service, they are likely to be damaged, particularly in the upper ranges of anticipated application rates. This kind of exposure may be regarded as an accidental scenario, which is relatively easy to control with proper management and application. The extent and duration of damage will depend on the time of application and plant species.
. . .(1992), this could damage some sensitive plant species.
. . .Glyphosate can reduce the emergence and weights of progeny seedlings on crops such as corn, soybeans, and johnson grass (Jeffery et al. 1981). It is not clear whether this effect is caused by direct toxic action on the seeds or simply reduced vigor in the parent plant as the seeds develop.
. . .Gross signs of toxicity, which may not be apparent for 2-4 days in annuals or for more than 7 days in perennials, include wilting and yellowing of the vegetation, followed by browning, breakdown of plant tissue, and, ultimately, root decomposition.
. . .In addition to these laboratory bioassays, there are several field studies that have assessed the effects of glyphosate on terrestrial organisms (Appendix 2-2). . . In most cases, the effects noted were changes in population density that reflected changes in food availability or suitable habitat.
. . .Glyphosate residues or perhaps residues of adjuvants used with
glyphosate have been shown to affect grazing preference in cattle (Jones
and Forbes 1984) but not sheep (Kisseberth et al. 1986).
[The flawed July 12, 1999 Biological Evaluation by Okanogan National Forest - scanned document.]
File Code: Biological Evaluations and Noxious Weeds Date: July 12 1999
Route To: Laurie Thorpe, Frank Hanford, Christina Bauman, Keith Rowland, Bill Baer
Subject: Methow Basin Fish listings and Integrated Weed Management EA
Recent fish listings have brought about a need to review and update the August 1997 Integrated Weed Management EA and DN with effects determinations for the new listings. The original DN made a 'No Impact" effects determination for proposed Upper Columbia River steelhead and bull trout. The DN was prepared prior to steelhead listing but was signed after steelhead were listed but was not modified to reflect the change in listing status. The Decision Notice was signed on August 26, 1997. On August 11, 1997 Upper Columbia River (UCR) steelhead were listed as endangered. Since the DN was signed UCR bull trout were listed as threatened in June 1998; UCR spring chinook were proposed for listing in early 1998 and listed as endangered on March 29,1999. West slope cutthroat were recently proposed for listing and are found in the Twisp River, Chewuch River, Goat Creek and in higher elevation areas of Boulder Creek.
After reviewing the EA and DN the effects determination for ESA listed UCR steelhead, spring chinook and bull trout is "no effect"; the project will not jeopardize the continued existence of westslope cutthroat trout. If westslopes are "listed" the effects determination would be the same as the other species. I reached these determinations after reviewing the original effects determinations for steelhead and bull trout, the EA and DN, and after conversations with Christina Bauman and Frank Hanford, Dennis Carlson from NMFS, and Dan Rife from the Wenatchee National Forest, and after revie wing the Biological Assessment for a similar project on the Wenatchee National Forest. These determinations are based on mitigation measures listed in the EA and DN, the spill plan, and the effects analysis in the EA and site specific information provided in the EA.
In addition to the mitigation measures listed in the EA, DN the following modifications/clarifications are recommended:
1. Modify the mitigation item #14 on page 68 and Appendix E Spill/Release plan by adding a statement saying that mixing of herbicides and cleaning of equipment will occur outside of riparian reserves (300' from fish bearing streams, 150' from perennial non fish bearing, and 100' from intermittent streams).
2. According to the Appendix E spill plan mixing will be done within carefully chosen areas away from water and within secondary containment. Mixing will be conducted away from riparian sources. Some examples include the FS Compounds in Twisp or Winthrop, one of the campgrounds with well water, or gravel pits with water transported to the site. The contractor and Forest service inspector will have spill kits in their vehicles. Herbicide containers will be kept securely on the contractors vehicle. Containers of unmixed concentrated herbicide will be sealed in the original containers and held on the contractors vehicle. The amount of mixed herbicide carried on a vehicle will be 250 gallons or less.
3. There will be specific herbicide buffers used along bull trout, steelhead and spring chinnook migration, holding, rearing, and spawning areas. Broadcast spraying of roadside will retain a 100' buffer, hand spaying will be permitted up to 50' buffer and hand wicking within 50'. These areas can be found along sites 22 (Goat Creek), 25 (Brevicomas Chewuch River), 28 South Fork Gold, 30 Buttermilk Rd. Twisp River Sno Park, 32 Twisp River Road, and 33 Black Canyon 4010 road crossing. Buffer width is increased for Site 22 to 100' from fish bearing streams.
in summary, the non chemical weed control measures specified will not cause enough soil disturbance to affect fish habitat. The mitigation measures for herbicide use include 100' buffer widths along steelhead, bull trout, spring chinook, and westslope cutthroat habitat where no picloram. will be applied and require that a Forest Service inspector work with the contractor at all times. Within this buffer and within 50' of all other streams glyphosate will be hand applied. Surfactants, are often more toxic than the herbicide and will not be used within the riparian buffers. Stream crossings will be marked with flags that are visible to vehicle operators where roadside spraying will be conducted. The EA specifies that herbicide label specifications will be followed and specifies that weather and soil conditions that will be met before herbicides are used. Hand application of glyphosate within the buffers, the spill plan and mixing requirements, the small amount of herbicide near water at any given time, the rapid dilution of chemicals if they do enter the water all keep the potential effect to listed fish at a non measurable level. Any herbicide that does enter the water should be an insignificant amount.
JENNIFER A. MOLESWORTH
Fisheries Biologist