Boulder Creek on the Okanogan National Forest

Case study of a weed management action gone wrong

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.

[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.

[Signature of Methow Ranger District Fisheries Biologist]