Camas flowers and the west vista of the Teton Range from Caribou–Targhee National Forest (Wikipedia)

Introduction 

The USDA Forest Service has proposed an action in an attempt to reduce existing and future invasive plant species within the Caribou-Targhee National Forest and Curlew National Grassland. The proposed action includes treating invasive species utilizing biological/chemical control and mechanical techniques. Below are comments on the EIS for this proposed action.

Comments 

Heidi Heyrend, Team Leader

USDA Forest Service

Caribou-Targhee National Forest

1405 Hollipark Drive

Idaho Falls, Idaho 83401

Re: Caribou- Targhee National Forest and Curlew National Grassland Integrated Weed Management Analysis, Environmental Impact Statement

Environmental Review, Inc. has reviewed the Caribou- Targhee National Forest and Curlew National Grassland Integrated Weed Management Analysis Environmental Impact Statement (EIS) for the open comment period ending February 8, 2021 and has the following comments:

1.     Page 50, 3.2.3.3 Alternative 2- Proposed Action, states that “invasive plants and noxious weeds species would be eradicated, controlled, or contained using a variety of methods. Following treatment, sites would be restored to native vegetation”. However, the removal of invasive plants from highly degraded areas can have unintended consequences. For instance, one undesirable species can be replaced by an equally undesirable species. In these cases, revegetation with desirable and competitive plant species is often necessary. Page 195, 3.5.3.2.1.8 Rehabilitation and Restoration Practices, considers intervention and revegetation efforts to ensure the success of native species. However, when assisted restoration must be used and sourced native seeds are acquired, additional criteria for the selection of native seeds should be considered. While restored plant communities provide a multitude of benefits for wildlife and diversity, ensuring that the revegetation efforts are not wasted is essential. Therefore, determining which native species are not only most beneficial, but are also most the competitive of the native plant species is necessary to ensure a successful re-establishment of native communities and the prevention of re-infestation of invasive species. Depending upon plant species, viable invasive seeds can remain in the soil for years after treatment. Thus, restoration and rehabilitation management need to account for the potential of plant populations to persist even after multiple herbicide treatments. If the native species are not competitive enough to out compete invasive plant species (new and old), are the risks associated with herbicide applications warranted?

2.     Page 61, 3.2.3.3.1.6 Glyphosate- Terrestrial Formulations, states that “field studies in mammalian wildlife have failed to note adverse effects on reproduction. Sullivan (1990) stated that, based on a number of parameters in populations of small mammals, no adverse effects in small mammals could be associated with Roundup spray.” However, since this was published 30 years ago, there are recent studies that suggest that there are adverse effects on mammals from glyphosate herbicides. Kubsad, Deepika, et al. (2019) gathered data that determined that glyphosate could induce transgenerational inheritance of disease, as well as germline epimutations. While there was negligible pathology detected in the F0 and F1 generations, there was a significant increase in pathology and disease observed in the F2 and F3 generations. In addition, Yahfoufi, Zeina A., et al. (2020) established that glyphosate exposure affects metaphase II in mouse oocytes through various mechanisms, clarifying the impacts of glyphosate exposure on female fertility. Therefore, though there appears to be negligible risks for direct exposure of glyphosate on mammals, should these transgenerational and fertility effects be taken into consideration during the risk assessments of glyphosate?

3.     Page 62, section 3.2.3.3.1.7 “Aquatic formulations of Glyphosate” describes sensitivity of amphibians to aquatic formulations of glyphosate as extremely low compared to fish (HQ of 0.05 for amphibians’ vs HQ of 36 for fish). However, for many of the other herbicides listed in section 3.2.3.3.1, where data on amphibians is unavailable, “…fish were used as surrogates to predict risk to amphibians.” Given the discrepancy in sensitivity toward glyphosate identified in section 3.2.3.3.1.7, are fish an appropriate surrogate when predicting amphibian risk to various herbicides?

4.     Page 140, 3.4.3.2.2 Effects of Herbicides on Surface and Ground Water Quality, does not incorporate resolutions or mitigation practices involving training programs. Herbicide applications can have unintended, indirect impacts to groundwater, native plants, animals, and humans. Therefore, it is imperative that herbicide applications are executed in a manner that reduces drift, spills, leeching, and overland flow. Due to the various environmental factors to consider during herbicide applications, it is necessitous that a thorough and tightly regulated operative training program be enacted prior to launching invasive species mitigation efforts utilizing herbicides. If operatives gain herbicide background knowledge, as well as a comprehensive understanding of application practices and consequences, improper herbicide applications can be avoided. This will further lessen indirect herbicide consequences. Should a certification program be offered through the USDA Forest Service as an effective addition to the proposed action?

5.     Page 170-172, 3.5.3.1.10, 3.5.3.1.12, & 3.5.3.113, discuss the sulfonylurea class of herbicides used for non-selective weed control. In the examination of tolerance or susceptibility of plant species to this class of herbicide, it must be noted that there are indications that some sulfonylurea herbicides inhibit processes involved in N-cycling. This would reduce the amount of nitrogen available for plants and would further hinder the restoration of native plant species. Soils that are at most risk for these impacts are those that are alkaline, where sulfonylurea degradation is slower or where sulfonylurea is frequently applied, resulting in excess herbicide buildup. Should special attention be given to this type of herbicide when used recurrently or with high clay soils?

Sincerely,

Devon Van Demark, M.S. 

Environmental Reviewer (Associate in Maine)

Environmental Review, Inc.

1792 Rogers Ave, San Jose, California 95112

 www.envreview.org, (a 501(c)(3) Nonprofit Public Benefit Corporation)

Stefanie Aschmann, Ph.D.

Senior Environmental Reviewer (Associate in Oregon)

Environmental Review, Inc.

1792 Rogers Ave, San Jose, California 95112

 www.envreview.org, (a 501(c)(3) Nonprofit Public Benefit Corporation)

Sources

·      Ericson, U. (2009, February). Impacts of Chemical Methods - Chemical Methods: Management Methods - Managing Invasive Plants. Retrieved January 26, 2021, from https://www.fws.gov/invasives/staffTrainingModule/methods/chemical/impacts.html

·      Kubsad, Deepika, et al. “Assessment of Glyphosate Induced Epigenetic Transgenerational Inheritance of Pathologies and Sperm Epimutations: Generational Toxicology.” Nature News, Nature Publishing Group, 23 Apr. 2019, www.nature.com/articles/s41598-019-42860-0.

·      Rose, M., Cavagnaro, T., Scanlan, C., Rose, T., Vancov, T., Kimber, S., . . . Zwieten, L. (2016, January 06). Impact of Herbicides on Soil Biology and Function. Retrieved January 26, 2021, from https://www.sciencedirect.com/science/article/pii/S0065211315001492

·      Yahfoufi, Zeina A., et al. “Glyphosate Induces Metaphase II Oocyte Deterioration and Embryo Damage by Zinc Depletion and Overproduction of Reactive Oxygen Species.” Toxicology, Elsevier, 19 Apr. 2020, http://www.sciencedirect.com/science/article/abs/pii/S0300483X20301050.