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.


[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

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). 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].

  • (BE, 1999) Biological Evaluations and Noxious Weeds Date: July 12 1999, by Jennifer Molesworth.
  • (EA & DN, 1997) 1997 ONF Integrated Weed Management Environmental Assessment and Decision Notice.
  • (EA, 1999) Integrated Weed Management Environmental Assessment April 1999, Okanogan National Forest.
  • McDougle, J.H., Mar. 3, 1999 letter providing guidance on pesticide references provided during scoping comments, for Natural Resources Staff, R-5, Ecosystem Management Coordination Staff and the Office of General Counsel.
  • (Mediated Agreement) Northwest Coalition for Alternatives to Pesticides, et. al. v. Clayton Yeutter, et. al. Civil Case No. 83-6272-E-BU, (U.S.D.C. Oregon) Stipulated Order of May 24, 1989.
  • Rieman, Bruce, and John McIntyre. 1993. Demographic and Habitat Requirements for Conservation of Bull Trout. USDA-FS GTR INT-302, Ogden, UT.
  • (ROD, 1988), Managing Competing and Unwanted Vegetation, Final Environmental Impact Statement Record of Decision, Region 6: United States Department of Agriculture, Forest Service, Pacific Northwest Region, November 1988.
  • (SERA, 1996) Syracuse Environmental Research Associates, Inc., Risk Assessment Final Report, Prepared for: USDA, Forest Service, for Selected Commercial Formulations of Glyphosate -Accord, Rodeo, Roundup And Roundup Pro.
  • Wooten, G.F., letter dated Aug 25, 1999, requesting review.
  • Wooten, G.F., damage survey dated Sept 23, 1999, with accompanying photographs.
  • (WSDA Case File 051C-99). Washington Department of Agriculture, Pesticide Management Division, Investigation Summary, Case File 051C-99, Jan 28, 2000.