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USDA FOREST SERVICEENVIRONMENTAL STATEMENT

1972 SISKIYOU NATIONAL FORESTHERBICIDE PROGRAM

U.S.D.A. FOREST SERVICE ENVIRONMENTAL STATEMENT1972 SISKIYOU NATIONAL FOREST HERBICIDE PROGRAM

Prepared in Accordance with Section 102(2)(c)of Public Law 91-190

SUMMARY SHEET

I. Final Statement

II. Administrative

III. This action concerns the application of 2,4-D, 2,4,5-T or atrazine on11,358 acres in 204 separate tracts on the Siskiyou National Forest

itr to control certain types of vegetation. The action will reduce vege-tative competition to conifer crop trees which will result in fastergrowth and better survival of the crop trees. Treatment areas are inCoos, Curry, and Josephine Counties of southwest Oregon and in DelNorte County, California.

IV. A reduction of grasses, forbs and shrubs is anticipated, increasinggrowth rates on conifer trees and improving survival of newly plantedtree seedlings. Wildlife forage may increase or decrease dependingon the vegetative composition of the treated area. Temporary estheticdeterioration will occur on parts of the project area. No significantadverse effect on soil organisms, water quality, wildlife, or aquaticlife is expected.

V. Manual and mechanical means of adjusting vegetative composition havebeen considered.

VI. Comments on the Draft Environmental Statement on herbicide use on theSiskiyou National Forest have been received from the following Federal,State and local agencies:

1. Federal Agencies

Department of Agriculture, Agricultural Research ServiceEnvironmental Protection AgencyDepartment of Commerce, National Oceanic and Atmospheric Administration

2. State Agencies

Oregon State University, School of ForestryOregon Pesticide Use Clearing HouseCalifornia Department of Fish and Game

3. Local Agencies

Del Norte County. California, Agricultural CommissionerJosephine County, Oregon, Board of County Commissioners

4. Groups

MazamasOregon Environmental CouncilRogue Group Sierra ClubFederation of Western Outdoor Clubs

5. Individuals

None

VII. The Draft Statement was made available for CEQ and the public onJanuary 28, 1972.

The Final Statement was made available for CEQ and the public on

I. DESCRIPTION

The selective herbicides 2,4-D, 2,4,5-T, or atrazine will be applied to 204separate tracts totalling 11,358 acres during one of two application seasonsas shown in Table 1.

TABLE 1

APRIL 1 - MAY 20 SPRAY PERIOD AUG. 20 - SEPT. 20 TOTAL

2,4-D 2,4,5-T 2,4-D and atrazine 2,4-D 2,4,5-T

No. No. No. No. No. No. No.AREAS ACRES AREAS ACRES AREAS ACRES AREAS ACRES AREAS ACRES AREAS ACRES AREAS ACRES

134 8360 33 1286 6 96 6 198 5 307 20 1111 204 11,358

LARGEST AREA: 399 ACRES AVERAGE AREA SIZE: 5t ACRES

Reduction of vegetative competition to increase survival of newly plantedconifer seedlings is the treatment objective on 24 areas comprising 1308 acres.Release of young conifer trees from suppressing vegetation will be carried outon the remaining tracts. Of the total land area on the Siskiyou Forest, 0.9

percent will be sprayed.

The Siskiyou National Forest is located in southwest Oregon and northern Calif-ornia, as shown in Illustration 1. All herbicide application will be in Josephine,

Curry amd Coos counties of Oregon, and in Del Norte County, California.

ILLUSTRATION 1

KEY MAP

SISKIYOUNATIONALFOREST -)

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Conventional helicopter spray techniques will be used consisting of agri-culture spray booms equipped with #6508 flat jet spray tips for the phenoxyherbicides and D-lO discs with #45 cores for atrazine application. Flyingheights will be 50-70 feet above the vegetation at speeds of 40-50 milesper hour. Boom pressure will be 25-35 p.s.i. Spraying will be prohibitedwhen any 6ne of the following conditions exist on the spray area: Wind inexcess of 6 MPH; temperature in excess of 750F; snow or ice on vegetation;raining; relative humidity less than 50 percent or air turbulence adequateto seriously affect normal spray pattern. Unsprayed buffer strips of 100feet minimum width will be left along designated water courses. ForestService personnel are present during spray operations. They monitor themixing of herbicide formulations and application for compliance with mixingand application instructions and the project safety plan.

A number of factors influence spray drift and should be considered when eitherplanning or reviewing a spray program. Klingman (36) listed size of spraydroplet, amount of wind, and height of droplet release above the ground asbeing factors which affect the amount of drift. Other factors reported byU.S.D.A. (37) which influence drift are specific gravity of spray droplet,evaporation rate, type of air movement (vertical or horizontal), temperature,humidity, and aerodynamic forces created by the aircraft. Additional factorswhich will influence drift of 2,4-D is the type of 2,4-D that is used, whetherit is an amine, a high volatile ester, or a low volatile ester (38).

The U.S.D.A. (37) reported that spray application flight height may varyfrom a few feet, for low growing crops, to 100 feet or more over mountainousforests depending upon the height required for effective laterial distribution.Isler and Maksymink (38) found a greater lateral movement of spray dropletsat a helicopter spray height of 25 feet above the ground than at a sprayheight of 50 feet above the ground.

The particle size median volume diameter in microns for the 6508 flat jetspray tip for the pressure range of 25 to 35 p.s.i. is 660 to 680 microns.Scotton (39) reported that a droplet of 400 microns diameter falling 10 feetin a 3 mph wind will be carried 8.5 feet. Klingnan (36) reported that a drop-let of 500 microns diameter falling 10 feet in a 3 mph wind will be carriedseven feet. The flat jet 6508 spray tips provide controlled spray particlesize and minimum driftage. No problems involving drift are anticipated instreams, campgrounds or in other special classified areas such as the Kalmiop-sis Wilderness and botannical areas.

The prohibition to discontinue spraying when air turbulence is such as toseriously affect normal spray pattern is included to cover unforeseen conditionsthat may develop and is monitored by a trained observer watching the sprayingoperation. Radio communications are maintained during the spray operation. Incase of equipment malfunction, pilots are instructed not to dump herbicide insensitive areas.

At this time, consideration is being given to the use of a foaming spray systemto reduce spray drift along streamsides. Use of the system on portions of theproject area hinges on technicalities to be resolved prior to April 1, 1972.

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The phenoxy herbicides to be applied are low volatile esters of 2,4-D and2,4,5-T. Formulations consist of 2 to 3 pounds of active ingredients peracre to be applied with 1/2 gallon of number 2 diesel oil and enough waterto make eight gallons or a straight oil carrier, also applied eight gallonsper acre. Atrazine spray rates will be five pounds of 80 percent activeingredients per acre in 10 gallons of water.

A water monitoring program will be carried out in conjunction with the sprayproject. Water samples will be taken from streams before, during, and afterspraying. Samples will be analyzed for herbicide content by the State ofOregon, Department of Agriculture. Results of the water analysis are reviewed.Those with above average herbicide levels are investigated to determine thecause and corrective action is taken to keep herbicide levels well withintolerable limits.

The primary purpose of water monitoring is to detect and correct developingproblems before they become serious. These may be due to equipment, applicationtechniques, personnel, or sampling techniques. An example would be a laboratoryanalysis report showing 7 ppb of 2,4-D in a sample when other samples showed nodetectable amount or less than 1 ppb. This pinpoints the time and place ofprobable contamination. A subsequent follow-up investigation is made to deter-mine cause so that corrective action can be taken.

The U. S. Department of Interior (40) lists 0.1 ppm (100 ppb) of 2,4-D and2,4,5-T as permissable in surface water for public use. Most of the watersamples taken on the Siskiyou contained less than 1 ppb of herbicide. Nosamples have contained 100 ppb or more of 2,4-D or 2,4,5-T.

The emperical data obtained from water monitoring is used to measure the hazardof the use of herbicides on the Forest to users and inhabitants of the water.

Tolerable limits are those which an organism can endure with little adverseeffect.

The cost of aerial herbicide application on the Siskiyou Forest to reduce vege-tation competing with conifer trees averaged $19.20 per acre in F.Y. 1971. Theonly known alternative method suitable to the rough topography of southwestOregon is hand cutting and piling. This was recently attempted on two separateone-acre tracts. The first attempt cost $400.00 and the second cost $148.50.On a large scale program, these costs would probably be lower but unlikely tofall below $100.00 per acre. In many cases, the mass of shrub material to becontrolled is so great as to make manual or mechanical efforts physicallyimpossible.

II. ENVIRONMENTAL IMPACTS

Effects on Soil Organisms. An herbicide application of three pounds per acrewill result in approximately nine ppm herbicide in the top inch of -soil (1).Whiteside and Alexander (2) measured oxygen consumption of soil organisms inHoneoye silt loam as an indication of the effect of herbicides on the micro-flora. The study shows that 2,4-D and 2,4,5-T concentrations up to 10 ppm didnot affect respiration.

Whiteside and Alexander (2) reported that 2,4-D is metabolized by soil organismsin ten days. Pimental (42) in his review of the literature concerning persis-tence in soil, reported that atrazine may persist in soil for 17 months, 2,4-Dhad a persistence range of 7 days to 126 days, and 2,4,5-T had a persistencerange of 14 days to 190 days.

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Norris and Greiner (49) reported that 2,4-D is rapidly degraded in forestlitter and that the rate of degradation varies with the type of litter andherbicide formulation used. Norris (50) reported that 2,4-D and 2,4,5-T aredegraded in forest litter at markedly different rates. At 35 days, 2,4-Drecovery had fallen to six percent. In contrast, 2,4,5-T required 120 daysto reach a recovery level of 13 percent.

Studies by Kratochvil (3) show no significant effect on micro-organisms ina silt loam soil when 2,4-D was applied at rates of one to four pounds peracre and 2,4,5-T was applied up to 16 pounds per acre.

Baldacci and Amici (4) measured the effect of 2,4-D on actinomycete soilorganisms and found that some strains were adversely affected by a 400 ppmconcentration. Additional work by Stephenson and Mitchell (5) shows thatfungi are more resistant to phenoxy herbicides than bacteria. The herbicidesto be used on this project are rapidly decomposed in the soil.

Microbe activity utilizing atrazine as a source of energy and nitrogen appearsto be the main cause of its decomposition in soil (6). The effect of atrazineon soil microflora is small (7).

If. ect on Terrestrial Vegetation. Newton (25) discussed the relationship ofmoisture consumption, soil and air temperatures near the surface, light inter-ception, and phenology and growth habit of plants in a plant association andthe effects on tree seedling survival. He reported that decreasing vegetationcover with herbicides reduced moisture loss from the top three feet of soil ina linear manner, reduced temperature stress to conifer seedlings, and increasedthe light reaching seedlings. The use of herbicides can provide desirablecommunity balances when the beneficial components are preserved, while removingthose species which create drought or cast extreme shade.

Over 1000 plant species occur on the Siskiyou National Forest, although few ofthese will be found on any one tract treated with herbicides. Although treat-ment is done to manipulate plant composition, only a portion of the speciesare significantly affected by 2,4-D, 2,4,5-T or atrazine.

In the manner applied on the Siskiyou, 2,4-D and 2,4,5-T adversely affect someof the broadleaved forbs and a portion of the shrub species. Gratkowski andPhilbrick (8) found the shrub species and their frequency of occurrence on atypical Siskiyou National Forest site as shown on the left side of Table 2.In another study, Gratkowski (9) determined the effect of 2,4-D and 2,4,5-Ton some of these species. His results are shown on the right side of Table 2.

Of the forbs susceptible to phenoxy herbicides, those not shielded by over-topping shrubs will receive spray application. Degree of susceptibility byspecies of forbs common to the Siskiyou has not been published. It is knownthat large groups of plants such as grasses, ferns, and mosses are unaffected.In the shrub category, elderberry (species) and big leaf maple (Acer macro-phyllum) are notably resistant to the phanoxies.

Atrazine is also a selective herbicide and will be used to reduce annualgrasses where newly planted conifers would succumb from moisture competition.Atrazine is also detrimental to horsetails, Indian hemp, prickly lettuce,yellow nutgrass, rush, sedge, and Canada thistle (10).

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TABLE 2

BRUSH SPECIES, FREQUENCIES AND EFFECT OF 2,4-D AND 2,4,5-T ON ATYPICAL SISKIYOU SITE

Percent of KillCommon Name Botanical % of Plots Aerial Portion Entire Plant

Name Occupied 2,4-D 2,4,5-T 2,4-D 2,4,5-T

Greenleafmanzanita

Canyonlive oak

Arc tos taphylospatula

Quercuschrysolepis

92 91 84 20

0

0

068 44 37

Mountainwhite thorn

Ceanothuscordulatus

20 100 100 0 20

Goldeneve rgre enchinkapin

Castanopsischrysophylla

12 58 67 0 0

Gai._K:rniabuckthorn

Baldhiprose

GrapeleafCaliforniapewberry

Rhamnu scal iforn ic a

Rosagymnoc arpa

RubusVitifolius

10

5

5

Bittercherry

Prunusemargina ta

5

Sc rubtanoak

Lithocarpusdensiflorus

2 66 63 0 0

Buckbrushceanothus

Ceanothuscuneatus

2

Hoarymanzanita

Acrtostaphyloscanescens

2 100 100 100 100

Osobe rry Osmaroniac eras if orm is

2

Effect on Terrestial Wildlife. Norris and others have reported that 2,4-Dand 2,4,5-T ingested by mammals, including black-tail deer, is rapidly excretedand does not accumulate in the body tissue. One hundred cattle drenched 10times and 100 sheep drenched 481 times with 2,4-D showed no ill effect (11).

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Black (12) is studying the effect of herbicide-caused vegetation changes onwildlife. He reports fewer small animals on treated areas after vegetationwas decreased by herbicides. Mice were most affected. Deer used sprayedareas more than unsprayed areas the summer following a spring treatment.

Rudd and Genelly (48) discussed the alterations of the chemical constitutionof plants treated with 2,4-D. The chemical alterations of concern are therendering of toxic plants palatable and rendering normally acceptable plantstoxic. They had no knowledge of complaints concerning wildlife species.

Klingman (36) mentions two types of poisoning hazards which should be consideredwhen livestock graze on plants treated with 2,4-D and 2,4,5-T. These are hydro-cyanic acid poisoning and nitrate poisoning in ruminants. He concluded thatthe use of phenoxy herbicides evidently does not change the usual precautionsnecessary to prevent hydrocyanic acid poisoning. Klingman (36) discussednitrate poisoning by livestock and concluded that many weeds contain enoughnitrate to cause poisoning whether treated with herbicides or not.

Klingsbury (45) listed plants with cyanogenetic potential. Of the plantslisted, mountain mahogany, velvet grass, cherries, apple and white clover occuror the Siskiyou. None of these plants are abundant on the areas scheduled fortreatment. The species of mountain mahogany incriminated in the loss oflivestock do not occur on the Siskiyou. Although velvet grass has been listedas potentially dangerous, Klingsbury (45) reported that no cases of livestockpoisoning caused by it are on record in the United States. Both species ofwild cherry on the Siskiyou are potentially dangerous. Grigsby and Ball (47)reported that 2,4-D and 2,4,5-T reduced the hydrocyanic acid present in blackcherry leaves by 88 percent and 85 percent respectively. The occurrence ofapple on the Forest is rare. White clover is an introduced weed of limitedoccurrence on the Siskiyou.

Kingsbury (45) discussed nitrate poisoning from plants. He reported thatplant growth under drought conditions and lessened light tends to increasethe nitrate content in the plants. A number of unpalatable weeds become pala-table when treated with 2,4-D and 2,4-D can upset the nitrogen metabolism inplants and may cause accumulation of nitrate to toxic levels. He lists manyplants in which toxic concentrations of nitrates have been measured, some ofwhich are abundant on the Siskiyou. Wort (46) mentions the work of Berg andMcElroy which indicated that the danger of nitrate poisoning to animals eat-ing forage crops and weeds sprayed with 2,4-D was very unlikely. (Despite thepresence of a nitrate poisoning hazard, no case of nitrate poisoning causedby plants has been reported for livestock or wildlife on the Siskiyou NationalForest.)

The reaction of wild birds common to the Siskiyou when exposed to 2,4-D and2,4,5-T is not known. The acute oral toxicity to domestic chicks is quite low.When fed 2,4-D daily at a dosage of 280 mg./kg. for 28 days, no effects couldbe detected (13). Both 2,4-D and 2,4,5-T, at relatively high dosages, depressedreproduction in chickens as did 2,4-D in mallard ducks (42). No such dosagesare expected to occur in connection with the Siskiyou spray projects.

The relationship of 2,4-D and 2,4,5-T to native insects is unstudied. Palmer-Jones (14) applied 2,4-D dust directly to bees and at the hive entrance, forcingthe insects to crawl through it. Neither adults nor young were adversely affected.

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Toxicology studies with upland game birds and mallard ducks show atrazine tohave very low toxicity to those species (15). Norris and others (16) foundatrazine residues in deer up to 76 ppb in portions normally consumed by man.

Swanson (30) stated that the spraying of brush to release Douglas-fir createstemporary openings where growth of forbs is stimulated for a few years beforethe canopy again closes; increased use of this practice should have a pronouncedeffect by extending the optimum forage-producing period of the rotation.Lawrence (31) stated that intensive forest management practices raise thecarrying capacity of Douglas-fir stands for black-tailed deer. Harper (32)reported that black-tailed deer and Roosevelt elk have responded to loggingand now occupy areas that for many years they avoided due to old-growth timberand its absence of forage plants. Hooven (33) reported changes in vegetationsuccession favor an increase in abundance and number of species of animals.He further stated that succession of important species of small mammals andseed-eating birds is related to vegetative succession and other changes inhabitat. Hungerford (34) reported that dew accumulations in clearcut areasin Idaho maintained succulent vegetation during summer where none would other-wise be expected and that this was important in extending the range of ruffedgrouse. The reports by Rungerford (34) and Newton (25) have important impli-cations for the extension of the range of ruffed grouse. Mitchell (35) statedmaxi-mum forage is present 3 to 5 years following clearcutting and burning andgood forage is available for 12 to 20 years: "In the future it is quiteevident that the good big-game range in the heavy forest type on the west side(of the Cascade range) will be in direct proportion to the area of lands cutover in the immediate past 20 years."

The effect of vegetation control on wildlife food and cover depends upon thespecies of wildlife present and the status and species of vegetation beingtreated. Areas scheduled for treatment vary and effects of treatment will varyalso. A varied composition of wildlife species depends primarily on a varietyin species and status of vegetation. Successful reforestation is a prerequisiteto continued cutting and vegetation variety. Cutover areas will be treated andreforested, thereby allowing for cutting in other areas. The Siskiyou sprayprogram is expected to create such a condition.

Effect on Aquatic Life. Tarrant and Norris (17) sampled streamwater after2,4-D and 2,4,5-T had been applied to adjacent brush stands. Herbicide wasdetected at rates of 0.5 ppb to 70 ppb and fell below detectable levels a fewdays after spraying. In 1963, 600 acres were sprayed in the Wilson River water-shed in western Oregon with one pound of 2,4-D and one pound of 2,4,5-T per acre.Salmon fry and streambottom organisms in live cages were unaffected. Pimental(42) stated that 2,4-D appears to degrade rapidly in water.

Thofern (18) applied diesel oil to a forest area at rates up to 20 gallons peracre. The oil could not be detected in streamwater. Suss and others (19)placed 600 gallons of diesel oil per acre. Depth of soil penetration waseight inches. Total decomposition of the oil took six months.

Walter (20) applied atrazine to water at rates of 0.2 to 6.0 ppm. No fishkill was observed. Bottom fauna decreased by 50 percent. Those exposed in-cluded mayfly and caddis fly larvae, leeches, and gastrapods.

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Mullison (41) reviewed the literature on the herbicide effects on aquaticorganisms and concluded that, from the evidence at hand, there are few signsof either a contamination problem or an accumulation in water of presentlyavailable herbicides when used according to label directions.

Effect on Man. Local observers of previous Siskiyou herbicide projects havefound the aesthetic impact to range from undesirable to undetectable. Noobjective data is available. Proper selection of spray areas can minimizevisual impact. The fact that only part of the greenery is defoliated may behelpful.

The herbicide 2,4-D is slightly toxic to man with lethal dosage estimated at50 to 100 mg/kg. The lethal dose for 2,4,5-T has not been accurately established.An extensive health survey of 126 manufacturing plant workers showed no illnesscaused by 2,4,5-T (21). Employees had inhaled 1.6 to 8.1 mg per day per personfor periods up to three years and with total exposures over 10,000 mg.

Kearney et al. (43) reported that the dioxin TCDD (2,3,7,8-tetrachlorodibenzo-p-dioxin) is not bro-synthesized in the environment, is not a photo product of2,4,5-trichlorophenol, does not leach into the soil profile, is not taken upby plants from the soil, and is not translocated in plants from foliar appli-cations but is washed off the plants. At herbicide treatment rates approxi-mateiy 40,000 times those planned on the Siskiyou National Forest, they couldnot detect TCDD in the soil. They concluded that environmental contaminationwith dioxinhas produced no measurable effects.

There appears to be little chance for the release of dioxins through burningof the sprayed areas. High pressures and high temperatures are necessary forthe formulation of dioxins when 1,2,4,5-tetrachlorobenzene is reacted withmenthanol and sodium hydroxide to give the sodium salt of 2,4,5-trichlorophenol(44). The 2,4,5-trichlorophenol is reacted with acetic acid under mildlyalkaline conditions and the product is then acidified with H2S04 to produce2,4,5-T (44). Since high pressures are absent, it is highly unlikely thatdioxin could be produced by the heat from fires on areas sprayed with 2,4,5-Tor 2,4-D.

The Advisory Committee on 2,4,5-T to the Administrator of the EnvironmentalProtection Agency (21) concluded that, as presently produced and as appliedaccording to regulations in force prior to April 1970, 2,4,5-T represents nohazard to human reproduction. The Committee found no evidence of adverseeffects on human reproduction in Vietnam, and Globe, Arizona. They also con-cluded that current patterns of usage of 2,4,5-T are such that any accumula-tion that might constitute a hazard to any aspect of human health is highlyunlikely. The Committee found no evidence to suggest that TCDD, as a contam-inant in 2,4,5-T, is likely to be encountered by animal or man in sufficientdosage to cause toxic reactions. The Committee also concluded that the herbi-cide 2,4,5-T does not accumulate in any component of the biosphere.

No case of human poisoning from atrazine has been reported (15). Feedingtests with rats over a two-year period showed no adverse effects due toatrazine.

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III. FAVORABLE ENVIRONMENTAL EFFECTS

The temporary reduction of plant volume on a sprayed site increases availablelight, moisture and soil nutrients. Lauterbach (22) reported the effect onDouglas-fir after herbicide application at several locations in western Oregon.Height growth of the conifers increased 61 percent to 178 percent. In allcases, diameter growth increase was comparable.

On a 73-acre tract in the Siskiyou National Forest, diameter growth ofconifers increased 329 percent for a seven-year period following chemicalrelease from overtopping hardwoods (24). This probably represents an extremedegree of response with average growth improvement from herbicide treatmentbeing somewhat less.

Decrease in annual grasses and forbs through application of atrazine has beenshown to increase survival of newly planted seedlings. Newton (23) statesthat under very rare circumstances can a planted seedling evade drought con-ditions in fully stocked herb communities.

A common vegetative condition on the Siskiyou Forest is one in which tanoak(Lithocarpus densifloras), Pacific Madrone (Arbutus menziesii) or CeonothusfCeonothus species) form a dense canopy ten or more feet above the ground.Grasses and forbs are quite scarce under this dense canopy and wildlife forageis practically nonexistent on these areas. Einorsen (27) found that the nut-ritive value of plants was much lower beneath a closed canopy than in a youngsuccessional stage. Herbicide treatment to increase growing room for conifersalso increases growing room for grasses and forbs and frequently causes basalsprouting of the hardwoods with subsequent game browsing in evidence. Thereduction in the density of the hardwood canopy usually results in more pro-ductive and enjoyable hunting. Several minor benefits have also been observed.Plants which serve as alternate hosts for common rust diseases of forest trees(such as the genus Ribes) are decreased in number on sprayed tracts. View-points of the forest scene have been opened along public travel routes pre-viously shrouded in dense vegetation. Animals are also more readily observedon areas where the hardwood vegetation has been treated.

A number of flowering forbs are resistant to phenoxy herbicides at the appli-cation rates and times used on the Siskiyou National Forest. The number andvigor of these forbs increases after treatment with these herbicides. Theformation of dense brushfields very difficult to walk through is prevented bythe p'ienoxy herbicide treatments. Access for fire control and forest recreationis greatly improved by the treatments.

IV. ADVERSE ENVIRONMENTAL EFFECTS WHICH CANNOT BE AVOIDED

The visual impact of some of the treated tracts will be undesirable to manypeople for several years. Some non-target flowering forbs which are consideredesthetically desirable may be killed or temporarily damaged. Atrazine has agreated impact on grasses and forbs than the phenoxy herbicides but does littledamage to woody plants at the application rates used on the Forest.

Changes will occur in wildlife habitat which will be detrimental to some situa-tions and beneficial to others. The climax vegetation on most of the SiskiyouNational Forest is coniferous forest. A shrub stage precedes the conifers inthe succession of plants. Application of herbicides will accelerate the changefrom shrub to forest. Big game browse is less in the forest stage than in thelow shrub stage.

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Some of the vegetative communities to be treated consist of low shrubs andforbs containing preferred wildlife browse species. Table 3 shows the twentymost preferred plants for black-tailed deer (25) as determined for westernWashington, their occurrence in the Siskiyou National Forest with suscepti-bility to phenoxy herbicides is shown in Table 3.

TABLE 3COMMON TO

STOMACH SAMPLE ANALYSIS SISKIYOU N.F. SUSCEPTIBILITY TORating Species (Peck) PHENOXY HERBICIDES

1 Trailing Blackberry X High2 Salal X Low3 Grasses X Low4 Red Alder X Medium5 Vine Maple X Medium6 Western Hemlock X Low7 Douglas-fir X Low8 Huckleberry X Medium9 Fireweed X High

10 Western Red Cedar X Low11 Annual Agoseris X Medium12 Deerfern X Low13 Hosetail X Low14 Plantain X High15 Common Pearly Everlasting X High16 Apple17 Oxalis X Low18 Clover X Low19 Willow X Low20 Salmonberry X Medium

Actual browse reduction measurements as a result of herbicide treatment havenot been made. Any reduction should be temporary, since the species with lowsusceptibility benefit from the application of phenoxy herbicides with increasedvigor and the woody species having medium susceptibility will usually producean abundance of sprouts.

Any harmful effects on fish, plankton, and other water inhabitants, if theyexist at all, from the controlled application of herbicides on the Siskiyou,are expected to be temporary. Results from water monitoring conducted onprevious herbicide application programs on the Siskiyou show that herbicidecontamination of water, when it occurred, was well below the levels quoted byPimental (42) as being injurious to plankton, benthic organisms, fish, tadpoles,frogs, turtles, and water snakes.

V. ALTERNATIVES TO THE PROPOSED ACTION

The impact of no brush control is discussed in Section VII, Page 12 as anirretrievable commitment of resources. The current annual sustained yield onthe Siskiyou National Forest is 190.9 million board feet. It is estimatedthat this annual harvest would decrease more than 50 percent with no vegetationcontrol.

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The alternative of growing and harvesting the brush for wood fiber on a shortrotation of five to ten years is not economically or environmentally desirable.Markets do not exist for this type of material, the short rotations wouldaccelerate erosion, the large expanses of brushfields would be detrimental toforest recreation, and potential gains in productivity through intensive forestmanagement, including genetics, would not be realized.

Control of the vegetation by mechnaical methods is considered undesirable onthe steep topography of the Siskiyou National Forest. Soil disturbance on thesteep slopes by heavy equipment will increase sheet erosion, reduce waterquality, reduce productivity of the trout and anadromous fish streams, andhave a negative visual impact.

Control of the vegetation by manual cutting is possible provided that thenecessary manpower and financing is made available. Practical limitations onmanpower would eliminate the possibility of treating the large acreage involved.The cost of manual cutting versus aerial application of herbicides is discussedin Paragraph 6, Page 3.

Using thickened solutions is an alternate method of formulating the herbicidesprays. This would reduce spray drift at an added cost and result in lesseffective vegetation control, requiring follow-up treatments. Mechanicalinverting systems and Amchem's Microfoil boom have the same disadvantages.References cited elsewhere in this statement indicate that drift is not aproblem if the herbicide is properly applied using the conventional spraysystem.

Current application technique and formulations have been developed in conjunc-tion with the Pacific Northwest Forest and Range Experiment Station. Theyhave been refined to provide the degree of vegetation control needed to meetour objectives with a minimum amount of herbicide and impact on the environ-ment. New application techniques and formulations are being used on a trialbasis but, so far, lack the predictability of the conventional systems.

Adopting a different timber harvest method will not solve the brush problemon the Siskiyou. The most serious brush problem species are present in theold growth timber stands and are released when timber is harvested despitethe harvest method used.

VI. RELATIONSHIP BETWEEN LOCAL SHORT TERM USES OF MAN'S ENVIRONMENT AND THEMAINTENANCE AND ENHANCEMENT OF LONG TERM PRODUCTIVITY

Forestry has the knowledge and capability of increasing forest yields similarto the growth improvement which has occurred in agriculture. Herbicides areone of the tools necessary to achieve these yields.

All areas scheduled for treatment were at one time covered with forest whichhas subsequently been removed by timber harvesting or forest fires. Herbicideswill allow the next crop to reach usable size a great deal faster and atheavier volumes per acre.

Unless housing starts can reach 2.5 million per year by 1975, adequate livingfacilities will not be available in the United States in 1978 (26). This is

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double the present building rate. The need for softwood timber in the UnitedStates is great. This project will assist in answering the need.

Generally, the fire hazard will increase temporarily following brush sprayingdue to more dead and dry fuels being created; however, the acceleration ofplant succession would convert relatively high hazard brush types to lesshazardous coniferous types sooner than would otherwise occur.

VII. IRREVERSIBLE OR IRRETRIEVABLE COMMITMENTS OF RESOURCES

No brush control on much of the commercial forest land in southwest Oregonafter timber harvest or wildfire could result in a commitment of these landsto brushfields. Gratkowski (28) reports that many of the important brush-fields in southwest Oregon now have histories of 100 years or more. Zinke (29)presents evidence which indicates that it may take Douglas-fir and redwood upto 60 years to gain dominance in a tanoak-madrone-redwood-Douglas-fir community.The rotation age on the Siskiyou National Forest is calculated on a 105-yearbase. The annual sustained allowable harvest on the Siskiyou National Forestwould decrease with no brush control. This loss in timber production poten-tial would have an effect on the local economy, the gross National product,and the U.S. trade balance.

VIII. CONSULTATION WITH OTHERS

The Oregon Pesticide Use Clearing House has been established to assist in thereview of pesticide use proposals. The following signatory agencies to theMemorandum of Understanding have reviewed the Siskiyou National Forest plannedherbicide use program for Fiscal Year 1972 with no adverse comments:

Department of InteriorBureau of Land ManagementBureau of Sport Fisheries and Wildlife

Fish Commission of Oregon

Oregon State Department of Forestry

Oregon State Game Commission

Oregon State Board of Health

Oregon State Department of Environmental Quality

Oregon State University Extension Service

The working groups on pest management of the President's Council of Environ-mental Quality has reviewed and approved the Forest's planned herbicide usefor Fiscal Year 1972.

The Draft Environmental Statement was sent to the following agencies, groups,and individuals:

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1. Federal Agencies

Department of AgricultureAgricultural Research ServiceSoil Conservation ServiceConsumer & Marketing Service

Department of CommerceNational Oceanic and Atmospheric AdministrationNational Marine Fisheries Service

Department of Health, Education and Welfare

Department of InteriorDepartment of Interior Coordinator

Environmental Protection Agency

2. State Agencies

Oregon State Pesticide Use Clearing HouseCalifornia Department of Fish and Game

3. Local Agencies

Board of County Commissioners of Coos, Curry andJosephine Counties, Oregon

Board of Supervisors of Del Norte County, CaliforniaDel Norte County Department of Agriculture

4. Groups

Wildlife Management InstituteFederation of Western Outdoor ClubsSierra ClubOregon Cattlemen's AssociationOregon Sheep Grower's AssociationMazamasOregon Environmental CouncilOregon Wildlife FederationWestern Forestry and Conservation AssociationIzaak Walton League of AmericaDean, School of Forestry, Oregon State UniversityIndustrial Forestry AssociationOregon Forest Protection AssociationWestern Wood Products AssociationNorthwest Timber Association

5. Individuals

Mr. Robert Van Leer, Curry County reporterMr. Vern Garvin, Curry County communicationsMr. Lewis N. Krauss, Jr., Rough & Ready Lumber Company

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Mr. Robert C. ByrdMr. W. W. BalderreeMr. D. G. McGregorMr. T. W. McGillMr. Harlow Merrick, Josephine County Humane Society

The following signatory agencies to the Memorandum of Understanding of theOregon Pesticide Use Clearing House have commented on the U. S. Forest Serviceplanned herbicide use program in Oregon for Fiscal Year 1972. Their commentsare attached.

Oregon State Game Commission, attachment number 1Oregon State Board of Health, attachment number 2Oregon State Department of Environmental Quality,

attachments 2 and 3

Discussion of comments received from the Oregon Pesticide Use Clearing Houseon the Forest Service planned herbicide use program in Oregon for Fiscal Year1972 follows:

The Oregon State Game Commission approved the use of atrazine, 2,4-D,and 2,4,5-T if applied in rates and in the manner prescribed by themanufacturer provided that the dioxin content of 2,4,5-T is 1 ppmor less. They made no adverse comments concerning the effects of thesepesticides on wildlife or wildlife habitat. These pesticides will beapplied in accordance with the manufacturers label and 2,4,5-T havinga dioxin content of 1 ppm or less will be used.

The recommendations for aerial spraying made by the Oregon State Boardof Health and by the Oregon State Department of Environmental Qualityare covered in contract clauses used by the U. S. Forest Service inRegion 6.

Comments on the Draft Environmental Statement were received from the followingagencies and groups. These comments are attached to the final statement.

1. Federal Agencies Attachment No.Department of Agriculture,Agricultural Research Service 4

Environmental Protection Agency 5Department of Commerce, National Oceanic

and Atmospheric Administration 6

2. State AgenciesOregon State University, School of Forestry 7Oregon Clearing House 8California Department of Fish and Game 9

3. Local AgenciesDel Norte County, California,Agricultural Commissioner 10

Josephine County, Oregon,Board of County Commissioners 11

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Attachment No.4. Groups

Mazamas 12Oregon Environmental Council 13Rogue Group, Sierra Club 14Federation of Western Outdoor Clubs 15

5. IndividualsNone

No meetings or hearings were held on the Draft Environmental Statement.

Discussion of reviews and comments received on the Draft Environmental State-ment follows:

Review Summary, Agricultural Research Service, Department of Agriculture

The Agricultural Research Service, Department of Agriculture, had no objec-tions to the proposed use of herbicides on the Siskiyou National Forestfrom the standpoint of soil and water conservation research.

Comment

No reply necessary.

Review Summary, U. S. Environmental Protection Agency

The U. S. Environmental Protection Agency asked if any area treated with2,4,5-T or atrazine will be used for grazing domestic animals.

Comment

None of the areas planned for treatment with 2,4,5-T or atrazine arein a cattle allotment.

Review Summary, U. S. Department of Commerce, National Oceanic and AtmosphericAdministration

The U. S. Department of Commerce, National Oceanic and Atmospheric Administrationmade a recommendation that the section on adverse environmental effects whichcannot be avoided by expanded to include the effects of the project on theaquatic environment.

Comment

Concur - changes made in sections I and IV. Since no application of thepesticides will be made to water and a 100 foot untreated buffer stripwill be left on each side of streams, no adverse environmental effect isanticipated in the aquatic environment.

Review Summary, Oregon State University, School of Forestry

The Oregon State University, School of Forestry response suggested that thefact that big game habitat is usually temporarily enhanced by both grass andbrush should be added.

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Comment

Concur - additional information added to section II.

Review Sumrmary, Oregon State Department of Agriculture

The Oregon State Department of Agriculture supported the controlled use ofherbicides in all forest lands. They asked us to consider adding the require-ments that only pesticides registered with the Oregon State Department ofAgriculture be accepted for use in Oregon and that the applicators be licensedby the Department.

Comment

For aerial spraying projects in Oregon, the Forest Service requires thatthe applicator abides by all State laws. This includes licensed appli-cators and use of registered pesticides.

Review Summary, District Planning Sectionm LGRD (Oregon)

The District Planning Section suggested that a great deal could be done torehabilitate the forest with available unemployed manpower.

Comment

The possibility of using manpower to accomplish this type of forest rehab-ilitation work is discussed on page 3 of the statement. Manual brushremoval is considered to create at least as many environmental impactsas controlled herbicide treatment. Current Forest Service funding isnot adequate to accomplish the needed work by manual methods.

Review Summary, Fish Commission of Oregon

The Fish Commission of Oregon regarded the use of herbicide on forest land tobe generally compatible with maintenance of fish life.

Comment

No reply necessary.

Review Summary, Forest Research Laboratory, Oregon State University

The Forest Research Laboratory, Oregon State University, reported that theimpact on the environment, as described in the statement, is in agreementwith research results conducted by members of their faculty.

Comment

No reply necessary.

Review Summary, Oregon State Game Commission

The Oregon State Came Commission did not consider long-range herbicide programsas being adequately described on a given area. How often will a given area be

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treated? They questioned the effects of removals of shrubs, grasses, andforbs on tree survival plus wildlife food and cover.

Comment

How often a given area will be treated with herbicides on the SiskiyouNational Forest cannot be stated with certainty. Under the presentintensity of management, most areas would not be treated more than twoor three times in one hundred years. The very fact that retreatment isnecessary sometimes in some areas shows treatments are only temporary ineffect. The herbicide treatments planned or the Siskiyou are designedto control vegetation rather than to completely eliminate it.

Review Summary, California Department of Fish and Game

The California Department of Fish and Game found no reason to believe thatthe treatment of 72 acres of National Forest land in Del Norte County, Calif-ornia, would be hazardous to wildlife; however, they were concerned about thepotential indirect effects of habitat changes.

Comment

The effects of habitat changes on wildlife populations have been addedto section II.

Review Summary, Agricultural Commissioner of Del Norte County, California

The Agricultural Commissioner of Del Norte County, California, recommendedthat consideration should be given in the statement regarding impact on wild-life as it is affected by the size of the areas to be sprayed and the availa-bility of nearby unsprayed areas. He noted that loss of mice and rat colonieswould be easily replaced by migration from adjacent unsprayed areas when thehabitat in the sprayed areas again becomes suitable. He also pointed out thatany adverse effects on wildlife habitat is easily offset by nearby unsprayedareas.

Comment

Agree - no reply necessary.

Review Summary, Josephine County Oregon, Board of County Commissioners

The review made by the Josephine County, Oregon, Board of County Commissionersresulted in a comment that they considered that the draft statement seems tobe quite complete. No other comments were made.

Comment

No reply necessary.

Review Summary, Mazamas

The Mazamas approved the use of 2,4-D, atrazine, and 2,4,5-T as outlined inthe draft statement as good forestry practice. They were concerned about the

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use of herbicides near botanical areas and where rare plant species exist.

Comment

Agree - additional information on spray drift added to section I. Three

botanical areas are located on the Siskiyou National Forest. These are

Babyfoot Lake, Big Craggies, and York Creek. The Kalmiopsis Wildernessand a portion of the Rogue River Wild River area are also located on the

Forest. Rare plants such as Kalmiopsis, western leucothoe, Californiapitcher-plant and Brewer spruce are protected in the botanical areas and

the wilderness. Herbicides are not used in these areas and care is used

in the use of herbicides to prevent drift into these areas.

Review Summary, Oregon Environmental Council

The Oregon Environmental Council pointed out two errors in Table 1 of the

draft statement and requested that maps showing the location of the areas

planned for spraying be included in the statement. They questioned drift

from the project and its effect on sensitive areas and in water. More infor-mation on water monitoring was requested. The impact of the herbicides on

humans and other forms of life was considered to be too hazardous to continuewith the program.

Comment

Response to specific questions follow:

Correction has been made in Table 1 concerning the number of areas and

the acreage planned to be sprayed.

No discernable impact is expected to any special classification area asa result of this project. Additional data on application restrictions,

spray drift and its effects have been added to Sections I and II.

Additional information on water monitoring has been entered in thestatement.

Data on herbicide persistence in soil, vegetation, and water has beenadded to Section II.

The use of high concentrations of 2,4,5-T is not proposed in the environ-

mental statement. The proposed herbicide treatments are designed to

improve growth conditions for conifers. It is recognized that the treat-

ments will have an effect on every plant species in the treated areas and

this is discussed in Sections II, III, and IV.

Additional data on the effects of herbicide on terrestrial wildlife has

been included in the statement. Based on analysis of available studiesand reports contained in the appendix, no teratogenic effects on wildlifespecies are expected to occur due to the low application rates to be used.

There appears to be little likelihood of affecting aquatic life when pesti-

cides are used in accordance with label directions. The controls placed on

the Siskiyou spray program provides for compliance with label directions.

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The Globe, Arizona incident was investigated by a panel consisting ofscientists from the Departments of Agriculture, Interior, and Health,Education and Welfare and from the National Academy of sciences, withobservers from the Office of Science and Technology and the ArizonaExtension Service (13). Among the conclusions reached by the panel were:

1. "There is clear evidence of drift of herbicides on a number of plantson some of the nearby properties.

2. "The human illness complaints are those that commonly occur in thenormal population; the eye irritation in one individual may berelated to the spraying.

3. "Reports from the wildlife specialists indicate no significant effectson birds, deer, and other wildlife.

4. "Information obtained from owners of livestock and observation ofanimals did not indicate any illnesses that do not commonly occur inother regions.

5. "Air pollution by sulfur oxides must be seriously considered as asignificant contributor to the plant and animal damage alleged tohave been caused by herbicides.

6. "The deformed goat and duck alleged to have been caused by the herbi-cides used on the spray project were obviously not caused by the herbi-cides used on the project. The deformed goat, born about five yearsprior to the 1969 spraying, was caused by severe nutritional deficiency.The duck, hatched four miles away from the site of herbicide applica-tion, had a slipped tendon which is a condition not uncommon to fowl."

The objective of the herbicide program on the Siskiyou National Forest isto suppress growth of brush species competing with conifers, not to elimin-ate them.

This Environmental Statement is not intended to discuss the clearcuttingcontroversy which is the subject of other statements.

The list of references cited on Page 9 of the Oregon Environmental Council'sletter of March 29, 1972 has been reviewed. Difficulty has been encounteredin obtaining references 1, 3, 5, 7 and 8 due to incomplete or incorrectcitations. The Pacific Northwest Forest and Range Experiment Station couldnot locate them in the PNW Library. The library at Oregon State Universityalso failed to locate them and gave the reason as incorrect citations.

Review Summary, Rogue Group Sierra Club

The Rogue Group Sierra Club questioned the availability of information concern-ing the full impact of herbicides on wildlife. They did not consider thatenvironmental alternatives were adequately covered in the draft statement.They questioned the research of Norris and Newton and urged that the programbe postponed until a true environmental impact statement is forthcoming.

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Comment

The impact of herbicides on wildlife and aquatic organisms are discussedin more detail in the statement. A discussion on alternate cutting methodshas been included in Section V.

Review Summary, Federation of Western Outdoor Clubs

Mr. Brock Evans, Northwest Conservation Representative, urged extreme cautionin the application of 2,4-D and 2,4,5-T due to the great potential adverseimpact on lower life forms. He recommended carefully monitored pilot projectsover a period of years and suggests that modified timber harvest methods willdiscourage brush invasion.

Comment

Additional information has been incorporated into the statement. Thereare areas that need additional attention, but a number of scientists, includ-ing Norris, Newton, Mullison, Kearney and others, consider the hazard to beslight when the herbicides are used with proper controls and in accordancewith label instructions.

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REFERENCES

1. Norris, Logan A. Chemical Brush Control: Assessing the Hazard.Journal of Forestry. October 1971: 715-720.

2. Whiteside, J.S. and Alexander, M. Measurement of MicrobiologicalEffects of Herbicides. Weeds. 8:204-213 1960.

3. Kratochvil, D.E. 1951. Determinations of the Effect of SeveralHerbicides on Soil Microorganisms. Weeds, 1:24-31.

4. Baldacci, E. and Amici, A. 1955. Toxicity of 2-methyl-4-chloro-phenoxyacetic acid (MCPA) and 2,4-D for Actinomycetes.

5. Stephenson, E.C. and Mitchell, J.W. 1945. Science, 101.

6. Weed Society of America. Herbicide Handbook, 2nd Edition. 1970pp. 89.

7. Volk, G.M. and Eno, C.F. The Effect of Simazine and Atrazine onCertain of the Soil Microflora and their Metabolic Processes.

8. Gratkowski, H.J. and Philbrick, J.R. Repeated Aerial Spraying andBurning to Control Sclerophyllous Brush. Journal of Forestry.December 1965; 919-923.

9. Gratkowski, H.J. Effects of Herbicides on Some Important BrushSpecies in Southwestern Oregon. Pacific Northwest Forest andRange Experiment Station Research Paper 31. 1959.

10. Dunham, R.S. 1965. Herbicide Manual for Noncropland Weeds. Agri-culture Research Service, L.S.D.A. Agriculture Handbook No. 269.

11. Palmer, J.S. and Radeleff, R.D. 1969. Production Research ReportNo. 106. U.S.D.A.

12. Annual Report 1970. Forest Research Laboratory. Oregon StateUniversity.

13. Tschirley, F.H. et.al. Investigations of Spray Project near Globe,Arizona. 1970. Report to the U.S.D.A.

14. Palmer-Jones, T. 1964. Effect on Honey Bees of 2,4-D. NewZealand Agriculture Research. 7:339-342.

15. House, William B. et.al. Assessment of Ecological Effects ofExtensive or Repeated Use of Herbicides. Midwest Research Institute.1967.

16. Norris, L.A., Newton, M. and Zabatkovski, J. 1967. Atrazine Residuesin Deer. Western Weed Control Conference, Research Committee-ResearchProgress Report, 30-31.

17. Tarrant, R.F. and Norris, L.A. 1967. Residues of Herbicidesand Diesel Oil Carriers in Forest Waters: A Review SymposiumProceedings: Herbicides and Vegetation Management. OregonState University.

18. Thofern, E. 1962. The Pollution of Soil and Water with Diesel Oil.A11g. Forstzeitschr 17 (13/14):214-217.

19. Suss, A.G. et.al. The Behavior of Carbon 14 Labeled Diesel Oilin Different Soils. Use of Isotopes in Weed Research Symposium.1965.

20. Walker, C.R. 1964. Simazine and Other S-Triazine Compounds asAquatic Herbicides in Fish Habitats. Weeds 12(2), 134-139.

21. Wilson, James G. et.al. Report of the Advisory Committee on 2,4,5-Tto the Administrator of the Environmental Protection Agency, 1971.

22. Lauterbach, P.G. Chemical Weeding and Release of Conifers inWestern Oregon and Washington. Symposium Proceedings:Herbicidesand Vegetation Management. Oregon State University. 1967.

23. Newton, M. Seedling Survival and Vegetative Competition. WesternForestry and Conservation Association. 1964.

24. Unpublished data from field surveys in 1970 and 1971.

25. Brown, E.R. The Black-tailed Deer of Western Washington. WashingtonState Game Department. Biological Bulletin No. 13.

26. The Housing and Urban Development Act of 1968.

27. Einorsen, A.S. Crude Protein Determination.i of Deer Food asApplied Management Technique, Trans.-North American WildlifeConference. 11; 309-312. 1946.

28. Gratkowski, H. Brush Problems in Southwest Oregon. Pacific North-west Forest and Range Experiment Station, U.S.D.A., Forest Service.January 1961.

29. Zinke, P.J. The Soil-Vegetation Survey as a Means of ClassifyingLand for Multiple-Use Forestry. Proc. Fifth World Forestry Congress.1960.

30. Swanson, D.O. 1970. Roosevelt Elk-Forest relationships in theDouglas-fir Region of the Southern Oregon Coast Range. Ph.D.Dissertation, University of Michigan, Ann Arbor. 173pp.

31. Lawrence, William H. 1969. The Impact of Intensive Forest Manage-ment Wildlife Populations. In Wildlife and Reforestation in thePacific Northwest. School of Forestry, Oregon State University.pp. 72-74

32. Harper, James A. 1969. Relations of Elk to Reforestation in thePacific Northwest. In Wildlife and Reforestation in the PacificNorthwest. School of Forestry, Oregon State University. pp. 67-71

33. Hooven, Edward A. 1969. The Influence of Forest Succession onPopulations of Small Animals in Western Oregon. In Wildlife andReforestation in the Pacific Northwest. School of Forestry, OregonState University. pp. 30-34.

34. Hungerford, Kenneth E. Influence of Forest Management on Wildlife.In Wildlife and Reforestation in the Pacific Northwest. School ofForestry, Oregon State University. pp. 39-41. 1969.

35. Mitchell, G. E. 1950. Wildlife-Forest Relationships in the PacificNorthwest Region. J. Forestry. 48(l):26-30

36. Klingman, Glen C. 1961. Weed Control: As a Science. John Wileyand Sons Inc., New York. 421 pp.

37. U.S.D.A. 1965. Aerial Application of Agricultural Chemicals. U.S.Department of Agriculture, Agriculture Handbook No. 97. 48 pp.

38. Isler, D.A. and Bohdan Maksymink. 1961. Some Spray Distribution andAtomization Tests with a Helicopter. U.S.D.A., ARS 42-54. 9 pp.

39. Scotton, John W. 1965. Atmospheric Transport of Pesticide Aerosols.U.S. Department of Health, Education, and Welfare. Public HealthService. 30 pp.

40. U.S. Dept. of Interior. 1968. Report on the Committee on WaterQuality Criterion. Federal Water Pollution Control Administration,Washington, D.C. 234 pp.

41. Mullison, W.R. 1970. Effects of Herbicides on Water and its Inhabi-tants. Weed Science. Vol. 18, No. 6. pp.738-750

42. Pimental, David. 1971. Ecological Effects of Pesticides on Non-TargetSpecies. Executive Office of the President, Office of Science andTechnology. 220 pp.

43. P.C. Kearney, A.I. Isensee, C.S. Halling, E.A. Woolson, and J.R. Plimmer.1972. Environmental Significance of the Chloro-dioxins. ProceedingsWeed Society of America. pp. 29.

44. MacLeod, Colin M. et.al. 1971. Report on 2,4,5-T. A Report of thePanel on Herbicides of the President's Science Advisory Committee. 68 pp.

45. Kin~gsbury, John M. 1964. Poisonous Plants of the United States andCanada. Prentice Hall. 626 pp.

46. Wort, D.J. 1964. Effects of Herbicides on Plant Composition andMetabolism. In the Physiology and Biochemistry of Herbicides.Academic Press. pp. 291

47. Grigsby, B.H. and C.D. Ball. 1952. Some Effects of Herbicidal Sprayson the Hydrocyanic Acid Content of Leaves of Wild Black Cherry. N.E.Weed Control Conference. Proc. 6:327-330

48. Rudd, Robert L. and Richard E. Genelly. 1956. Pesticides: TheirUse and Toxicity in Relation to Wildlife. State of California, Dept.of Fish and Game. Game Bulletin No. 7.

49. Norris, Logan A. and David Greiner. 1967. The Degradation of 2,4-Din Forest Litter. Bulletin of Environmental Contamination & Toxicology,Vol. 2, No. 2, 65-74.

50. Norris, Logan A. 1970. Degradation of Herbicides in the Forest Floor.In Tree Growth and Forest Soils. Oregon State University Press.

0)~* UINITED STATES DEPARTMENT OF AGRICULTURE

AGRICULTURAL RESEARCH SERVICESOIL AND WATER CONSERVATION RESEARCH DIVISION

NORTHWEST BRANCH. P. 0. maX 1 1678015M. IDAHO 83701

REC EIVa jWATERSHEED MC .

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March 29, 1972

Subject: Environmental Statement--Siskiyou National ForestHerbcide ro~rm. 1972

To: Rexford A. ReslerRegional ForesterU. S. Forest ServiceP. 0. Box 3623Portland, Oregon 97208

We have reviewed the above subject statement and see no objectionsto this plan from the standpoint of soil and water conservationresearch.

We appreciate the opportunity to review and comment on thismaterial.

/John C. StephensLIChief of Branch

cc:A. J. Webber, SCS, Portland, Oregon

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1200 SiXYTI AVENUE ~~~~ ~~~ ~SEATTLE, WA S I NG T0X N9I 0 , .1

February 2, 1972

REPLY TOATTN OF: M/S 325

Mr. Lloyd G. GillraorAssistant regional ForesterU. S. Department of AgricultureForestL ServiceP.O. Box 3623Portland, Oregon 97208

Dear Mr. Gillmor:

Thank you for the opportunity to review on draftenvirofldaental -impact statements for he'rbicides SCithe Siuslaw and Siskivo,7u Forcsts.

We have the following comaments:

1.The EIS declares that I-lb per acre of Picloram will -

be used on 581 acres with 2,4-D.COMMENT: Picloraro is not registered with EPA forforest or range land.

2. The EIS declares 2 lbs a.e., Amitrole-T will be usedon 1,600 acres.COMM1ENT: Amitrole-T1 is not regstered for use onforest or range land.

3. The ETS declares 1-lb a.e., Dica-mba with 2,4-D willbe used on 40 acres.COMMENT: Dicamba is notL regiszered for forest manage-ment. !-t is registered for range 'Land management. withrestrictions.

4. The EIS declares 50 acres will be for control of noxiouswoeds on range permit area s.COMMYENT: This stat~eme~nt docs not sneci fy which of theherbicides lse wilbe used on this 50 acres of rangeland.The following limitat-ions must be considered:

a. Atrazine - Do not graze treated area.

sf

2

b. 2,4,5-T - Do not graze da2irY animals within sixweeks OL application. Do no't graze meat animalswithin two weeks of slaughter.

5.. The EIS declares the volatile esters of 2,4-D and2,4,5-T are used.COMIMIE'NT: Are these h~icrh or low volatile esters?

6. -The EIS states 5 per cent of the coastal recreationareas will be t-reated.CO,', ENT: Will 2,4,5-T; be used _n this area? Thisproduct is not registered for use around recreationalareas.

Siskivou National ?orest

Will any area treat:ed wnxith 2,4, J-T or Atrazine beused for grazing doxeszic ani-.als? The liraitation statedin comment number 4 above must be considered.

if you have any auestions recgar-irncg these comments,nlease contact To.;ert 2. ?oss, C;^ie_, Pesticides Branch,Region X, Environmental Proteczion Agency.

Sir.cc rely,

hurlon C. RavAssistant Rcgi-.onal Ad.arcnistrator

for ianagement

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U.S. DEPARTMENT OF COMMERCENational Oceanic and Atmospheric AdministrationNational Marine Fisheries Service6116 Arcade Building RECEIVED |Seattle, Washington 98101 1 WATERSHED MGT.

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Regional ForesterU.S. Forest ServiceRegion 6P.O. Box 3623Portland, Oregon 97208

Dear Sir:

We have reviewed your proposed draft environmental impact statementrelated to the Siskivou National Forest Herbicide F'ogram. Ihesecomments are informal from the field level. In general,--he state-ment appears to be excellent. We do offer the following comments foryour consideration.

On page 10, Item IV, some mention should be made on the effects thisproject will have on the aquatic environment.

On page 11, first paragraph, we suggest it be expanded to point outthe effect of the project on food for trout and anadromous fish aspreviously explained in the report.

We appreciate the opportunity to review your field draft of thisenvironmental impact statement. If we can be of further help, pleasecall on us.

Sincerely,

Director

WM .,A_,X'.U , .i i,-;ey

I

wOLSLCORVALLIS, OREGON 97331

OREGON STATE UNIVERSITYSCHOOL OF FORESTRY

February 25, 1972

J

Mr. Rexford A. ReslerRegional ForesterRegion 6, U. S. Forest Service319 S. W. Pine StreetPortland, Oregon 97208

Dear Rex:

This is in response to your February 4 environmentalpolicy statement covering the proposed Siskivou NationalForest Herbicides Program. I asked Mike Newton to reviewthe impact stateme~nt and-his response was very complimentary.He suggested adding the fact that big-game habitat is usuallytemporarily enhanced by both grass and brush control.

Mike suggests that this outline could be used for mostherbicide environmental statements in the Region with good.advantage.

Sincerely,

Carl H. StoltenbergDean

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TOM MCCALL March 9, 1972_OVICOINOR

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~LSDGT Mr. Rexford A. ReslerRJS Regional Forester

WAP U. S. Department of AgricultureEVI Region 6

At P. 0. Box 3623Portland, Oregon 97208

Re: siskivu N.F. Herbicide ProcaramPNRS #72 o 4 U b U-

Dear Mr. Resler:

We have referred your draft Environmental ImpactStatement to the appropriate state agencies. We have alsopublished and distributed notice to all state agencies andCouncils of Governments.

The responses quoted below suggest points to beconsidered and included in your statement.

State Department of Agriculture -Don McKinnis, Development Specialist"Our response to EIS U.S. Forest Service,Siskiyou N.F. Herbicide Program, PNRS #72024 060 will be based upon the general use ofherbicides for protection of our forest lands.

"Mr. Bill Kosesan, assistant administrator,Plant Division, Oregon Department of Agri-culture, reviewed the request and his remarksare enclosed.

"The continued use of herbicides in forestlands is a necessary part of sound forestrymanagement. By the scientific applicationof herbicides we are able to maintain somecontrol over competitive vegetation on forestland enabling the desired species to maintainvigorous growth without competition from so

V\Ki LibrIaI) MGT-F!LE COPT

Mr. Rexford A. Resler - 2 - March 9, 1972

called pest vegetation. Also the problem ofweed control on certain noxious weeds growingupon our forest lands must be controlled toprevent their spread into other forest lands,or eventually into agriculture lands.

"We support the controlled use of herbicidesin all forest lands."

W. H. Kosesan, Ass't Chief, Plant Division"You supplied us with a copy for our reviewof the statement of the proposed U.S. ForestService project to use herbicides on 213separate tracts on the Siskiyou National Forestand asked for comments.

"The statement, in our view, is well writtenand prepared and indicates that a great deal ofthought has been given to the proposed spraying.We have only one suggestion.

"In our opinion, it would be appropriate if theForest Service would consider adding the require-ments that only pesticides registered with ourDepartment be accepted for use on their controlprojects, and only applicators examined andlicensed by our Department be approved for appli-cation work."

District Planning Section, LGRD'"This project is so technically complicatedthat this Division does not have the particularexpertise to evaluate the project. However,on a hunch, we feel the project will be environ-mentally harmful and will therefore yield toD.E.Q.'s review. It would appear that, with somany peop3e needing work, welfare recipients andyoung people, a great deal could be done torehabilitate the forest with this manpower."

Fish Commission of Oregon:

"Herbicide use in reforested lands is generallyregarded by the Fish Commission as being com-patible with maintenance of fish life. Bufferstrips are required in streamside areas and thisfurther reduces the hazard to fish from toxicityof herbicide and protects streamside vegetationimportant to maintenance of adequate water quality."

Mr. Rexford A. Resler - 3 - March 9, 1972

Forest Research Laboratory, OSUJ. R. Dilworth"The impact on the environment, as described,is in agreement with research results con-ducted by members of our faculty. The temp-orary browning of some of the grass and brushspecies should be more than overcome by thelong-term improvement of the environment bythe establishment of coniferous stands, theecological climax vegetation on these areas.I am inclined to agree with Mr. Ralph Nader'sconclusions that '...good ecology is not alwaysthe same as a pleasing appearance in the shortrun. Ecological rather than aesthetic variablesshould dictate logging and regeneration prac-tices..." As a general rule, I feel that theuse of chemicals mentioned in the proposal areto be preferred over mechanical means becausetheir total impact on the environment is muchless and the effects soon disappear.

"I have confidence that the U.S. Forest Servicewill handle this operation with the minimizationof environmental impacts as a major goal."

Game Commission:"Long-range herbicide programs are not adequatelydescribed on a given logged unit. Will oneapplication of chemical be sufficient or willtreatment be repeated in the future years?What effects does removal of shrubs, grasses andforbs have on soil temperature and moistureaccumulation, factors which will effect treesurvival plus wildlife food and cover?"

You may use this letter as evidence of your com-pliance with Section 102 (2)(C) of the National EnvironmentalPolicy Act of 1969 (83 Stat.853), and OMB A-95 (Revised)

Cordially,.

Kessler R. CannonAssistant to the GovernorNatural Resources

OF CALIFORWJA-RESOURCES AGENCY -,

'ARTMENT OF FISH AND GAME

RONALD REAGAN, Governor

Ma~rch 7, 1972

Mr.* W. P. RonayneU. S. D. A.U. S. Forest ServiceSiskiyou National ForestP. 0. Box 414oGrants Pass, Oregon

1-_Dear Mr. Ronayne,

An examimation of' your proposed use of' herbicides on 72acres of' National Forest land in Del Norte County, Ca~if'-or'na, reveals there is no reason to believe any hazardto wildlife will result from this project.

Sincerely yours,

W. M. _Grdi. ith

cc: Region I

Itifo V/Aclion X

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AXT OF CAUlFORrmi'i. -RESOURCES AGENCY RONALD REAGAN, 3overncr

EPARTMENT OF FISH AND GAME0. Box 1480 AdiA K

adding, California 96001 ib. D

March 27, 1972 Hirsh

voy) MAR 12a19i2g'o' tt1 C

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Mr. W. P. RonayneU. S. D. A.U. S. Forest ServiceSiskiyou National ForestP. 0. Box 440Grants Pass, Oregon

Dear Mr. Ronayne:

Thank you for the opportunity to review your draft environ-mental statement covering the proposed Siskiyou NationalForest herbicide program. On March 7, Mr. Griffith of ourpesticides laboratory submitted comments to you regardingthe direct (toxic) effects of the proposed herbicide use onwildlife. We concur with his conclusions; however, we areconcerned over the potential indirect effects.

Although the use of the described toxicants does not appearto be hazardous to wildlife directly, the basic program ofbrush and hardwood removal outlined in the Siskiyou NationalForest proposal will adversely effect wildlife. The statementunder paragraph IV, page one, of the summary sheet which statesthat no significant adverse effect on wildlife is expected mustrefer only to the use of a particular herbicide and not to themore serious problem of habitat change.

Many species of wildlife require mixed forest types includinghardwoods and brush in order to survive. A diversity of plantforms and habitat types is essential in maintaining wildlifepopulations. If large areas of forest lands are convertedfrom hardwoods and brush to younger, even-age stands of pureconifers the net result will be a loss in wildlife numbers anda reduction in species variety. The capability of the forestto produce and support wildlife will be greatly diminished.

Mr. W. P. Ronayne -2- March 27, 1972

According to the summary, some 11,858 acres of hardwoods andbrush will be treated. This, in itself, constitutes a sig-nificant loss to wildlife. If we consider the loss in previousyears and anticipate that the Forest Service will continue thisprogram at the same rate, the ultimate loss of habitat can beexpected to have serious adverse effects on the wildlife resource.

Under the multiple use concept of Forest Management, wildlifeshould be given equal consideration with other forest uses.The programs outlined in the environmental impact statementdo not appear to reflect true multiple use planning and shouldbe modified accordingly to insure preservation of adequate wild-life habitat to protect the resource.

Very truly yours,

0m e;Re al Manager

cc: Environmental Services BranchWildlife Management Branch

I-. I

L J GRRTTJr WatOFFICES OF mr ,2Ow hlair- Sealer NiL J. GAtItUlT. Jr. AGRI.ULTURAL COMMISSIONERTHOSlent. SeateAr+ SEALER OF WEIGHTS AND MEASURESHOS. O. P; CALIFORNIA PLANT QUARANTINE OFFICER

Do v t ~~~~~~~~~~~~~~~~~~~~~~COUNTY POUNDMASTER

P. O. BOX 159

Plim V707- 464.2716 6CreswCitty, Califomka 95531

February 29, 1972 I , ;

Regional ForesterU.S. Forest ServiceP.O. Box 3623Portland, OR 97208

Dear Sir:

In response to a request of Mr. W.P. Ronayne, Forest Supervisor,Siskiyou National Forest for our comments on the draftedEnvironmental Statement, 1972, Siskiyou National Forest, we arepleased to submit the following:

The environmental statement is excellent and well presented.Consideration should be given, in the statements regarding wild-life impact, that the average size of the areas to be sprayed isapproximately 55 acres and that any adverse effect on wildlifehabitat is easily offset by nearby unsprayed areas. Even on thelargest spray area (399 acres), the area is small enough thatwildlife will be able to move to adjacent areas. The exceptionwould probably be some of the mice or rat colonies. However,their loss would be easily replaced, when the habitat becomessuitable, by migration of animals from adjacent areas of higherpopulation. The maximum travel distance would be in terms offeet since the migration need only be from the perimeter to thecenter of the sprayed area.

Please accept our thanks for the opportunity to comment.

Sincere

Agricultural ;sioner

COUNTY COURTHOUSEGRANTS PASS, OREGO0N 97526

Tel. 476-7733

JOSEPHIN E4' COUNTY OREGONI

. . /A

Office of

BOARD) OF COUNTY CX)MMtSSIlONItRS

Kenneth E. JacksonM. C. LoughridgeGeorge A. Calvert

'Iv o

February 24, 1972

Mr. W. P. RonayneForesit SupervisorSiskiycu National ForestU. S. Department of AgricultureP. 0. Box 440Grants Pass, Or 97526

Dear Mr. Ronayne:

This is in reply to your letter of February 22 withwhich you enclosed a draft environmental statement coveringproposed S~isiou National Forest herbicide pL rm

The report has been read and discussed by the Boardand it seems to be quite complete. We have no other commecntsto make at this time.

Very truly yours,

BOARD OF COUNTY COMMISSIONERS

~~§2'~-~- (Q /

MA. C. Loughri~dgeChairman

unes los

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M A ZA MAS909 N. W. 19TH AVENUE

PORTLAND, OREGON 97209

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WATERSH~ED MGT.

MAR 6 1972F.S. RM40avmmw�

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II , . -March 2, 1972

/( X A

Mr. Rexfordl A.itesler, Regional ForesterU. S. Forest ServiceP, 0. Box 3623Portland, Oregon 97208

Dear Mr. Resler:

Thank you for sendinir. us the enviroml.ental statementcovering the proposed Si4]i'You National ForestHerbicides P~ro-ramn.

Our Corwnittee ai-proves as ffood forestry practicethe use of 2, '4-D, 2,4,5-T, :eal atrazine as outlinedin the environmental stnteiment for nse in theSiskiyou National Herbicides Program. Hlowever,extrem~e care should be used to avoid the use ofherbicides in or near botanical areas in the Forestor where rare plant s- 'ecies exist; t~he SiskiyouNational Forest is distinctive in this respect.

Sincerely,

Eleanor HlellerChairman, Conservation Cornnittee

cc:Forest Supervieor

THE MAZAMAS were organized on the summit of Mount Hood, in 1894. - The purposes of the club are to explore mountains, t ismnt'Iauthoritative and scientific information concerning them, Ind to encoursge the preservation of forests and other features of tonan cnr i hinatural beauty. - Any person who haa climbed to the summit of a snowp'eak on which there sat es n iiggair aondtdieno fwh anor be reached by any other means than on foot. is eligible to membership. - The word "Mazuama is derived from the name of a mouantin goat..

Ktk~tIVtW'WATERSHED MGT.APR 4 13 71

OREGON ENVIRONMENTAL COUNCIL431 5 S W. CORBETT AVENUE. PORTLAND, OREGON 97201 / PHONE: 503/222-5369

March 29, 1972 tI

___AERICAN ASSOCIATION OF UNI YE RS ITYWOMEN, Poolcnd Brur,:lr

.----- AYERIC-AN INSTITUTE OF ARCHITECTSThre Portlond Chroprer

,, Sovithoesteri Otegcn ChopterAMERICAN INSTITUTE OF PLANNERS

- /-., ~~~~~~Oregon Sect InfWt.ISOC ElY OF LANDSCAFE ARCHITECTS

T _;rfs7 ~Oreioo Sect cm, PNqW ChapterANGLERS CLUB OF PORTLAND

-- rMAREA ENVIRONMENTAL COMMITTEECoos Boy, Oregon

CHEMEKEFANS, Solen,, Oregon-7~1TIZEI.S FOR A CLEAN ENVIRONMENT

Ccr,-Iils, OregonCLACKAMAS COUNTY NEW POLITICS

f. A C ATTrOF ENVIRONMENTAL COUNCIL,Gol n; !TFEFOR VOLCANIC CASCADE STUDY

Porticrid, OregonCOMM.ITEE FOR MINAM ACTION. INC

Portland, OregonENVIRONMENTAL ACTIVIST COALITON

Le.,s cod Clark CollegeEUGENE FUTURE POVrER COMMITTEEEUGENE NATURAL HISTORY SOCIETY

4-H CLUB CARROT-TOPPERS, Sccppcose. OregonFRIENDS OF THE EARTH

GARDEN CLUBS of Cedor M.ll. Co-reolr, Geruors.Illinois Volley, McKenrre i&,ce, Scoppoosc

GREENLEAF CLUB OF FIRST UNITARIAN CHURCHFort lond

INSURANCE WOMEN S ASSOCIATIONOF PORTLAND

JUNIOR LEAGUE. E~pone, PortlandMcKENZIE FVIFISHERS, Eugene, Oregon

MCKENZIE GUARDIANS, R,~c Rner, OregonNORTKWEST STEEIHEADERS COUNCIL OF TROUT

UNLI MIT ED. Beeoerrn, Natrl, Portland.Portlond, 1,gord

ORS!DIANS, INC , Ergame, OregonOREGON CITIZENS FOR CLEAN AIR

OREGON COUNCIL FOR IEW POLITICSOREGON COUNCIL OF ROCK AND MINERAL CLUBS

Pcsebvrg, OregonOREGON GUIDES AND PACKEPS Viclo, Oregon

OREGON NURSES ASSOCIATIONOREGON PARK & RECREATION SOCIETY

Coroollrs, OregonOREGON SC IENCE TEACHERS ASSOCIATION

OREGON SOCIETY OF LANDSCAPE AECrIITECTSPortlond, Oregon

OREGON TUBERCULOSIS ANDRESPIRATORY DISEASE ASSOCIATION

O S.U FIN AND ANTLER CLUBCorooIrs, Oregon

O.S.U MOUNTAIN CLUB, Corrollhs, OregonPLANNED PARENTHOOD ASSOCIATION, INC.

Lone Cao-ty, PortllndPORTLAND AUDUBON SOCIETY

P.UB E.. bend, OregonREED COLLEGE OUTING CLUB

Portlan.d, OrcgonROGUE ECOlOGY COUNCIL

Aslrlono, OregonSALEM BEAUTIFICATION COUNCIL

SANTIAM ALFINE CLUBSolern, Oregon

SIERRA CLUBPocif~c Norlhtoest Chopter

Colunrbco Groap, Portlord, OregonSPENCER BUTTE IMPROVEMENT ASSO)CIATION

Eug-ne, OregonTRAILS CLUB OP OREGON

TROUT UNLIMITEDUNIVERSITY OF OREGON OUTDOOP PROGRAM

E,,gcEr, OregonWILLAMET7E RIVER GREEIJWAY ASSOCiATION

WILLAMETTE TUBEPCLILOSIS AND RTPiRATORYDISEASE ASSOCIATION. OrIeI, Oregon

WOMEN S ARCHITECTURAL LEAGUE OF PORTLANDZERO POPULATION GROWTH

Lc." Caotr', Portland

Mr. W. P. RonayneSuper vi sorSiskiyou National ForestP. 0. Box 4B40Grants Pass, Oregon 97526

or ,,

11I I/3 0, ~~~~~a,

Re: Draft Environmental Impact Statement,Sivkivou Naional Forest Herbicide-Piogranm, 1972

Dear Bill:

We are pleased to have the opportunity to reviewand comment upon the above Environmental ImpactStatement.

We have spent considerable time studying yourDraft EIS for your 1972 Herbicide Program andhave some very serious doubts as to the efficacyand safety of your proposed program.

Our primary concern is about the effects on theenvironment of the treatment of large segmentsof the Forest with 2,4-D and 2,,5T and we donot feel that the project would correct thetimber management problems in the SiskiyouNational Forest. Our comments are organized tofollow the basic format of the Impact Statement.

As we informed you in our earlier letter., weare concerned about the very close timing between'the final date to receive statements on thisDEIS and the proposed date to begin the sprayingprogram. We are pleased that you will not beginthe program without the express approval ofthe Council on Environmental Quality. There ishardly any point of this letter, however, if theForest Service is planning to go ahead with theprogram despite the comments that may be received.Even though you may get approval from CEQ toshort-circuit the NEPA process, it does not makeyour actions anymore acceptable to us.

WATERSIIED jjAGT. -- I~

SI

Letter to Mr. W. P. RonayneMarch 29, 1972Page 2

The description of the project (section I) contains mathematicalor typographical errors in the numbers and acreage of tracts to besprayed. On page 3 is a map showing the location of the SiskiyouNational Forest in the state of Oregon, and the areas to be sprayedare identified simply as being "in Josephine, Curry and CoosCounties of Oregon." There is no excuse for not including in thestatement maps showing the exact location of every site to be

-sprayed. We obtained project maps and plotted spray sites on theNF map, along with information from the Game Commission. We weredistressed to find that several of the spray sites are in the winterjranges of blacktail deer and Roosevelt elk, as well as dozens in theheadwaters of such fishing rivers as the Chetco, Sixes, Pistol, andHunter, not to mention tributaries of the Rogue and Illinois.

/ Furthermore, spray Unit 511 is within 1/4 mile of the Coquille River\j ,f Falls Natural Area, and Unit 512 is 1-1/4 miles from the Port Orford

Cedar Natural Area. Units 166 and 167 are within ,/2 mile of theKalmiopsis Wilderness Area and several other sites-are quite closealso. Units 188, 190, and 191 are all within 1/2 mile of ElkoForest Camp; Unit 195 is 1/4 mile from Long Ridge Forest Camp; Unit316 is 1 mile from Agness and from Singing Springs Resort; Unit317 is 1/2 mile from Schnieder Lodge; and Unit 507 is 1 mile fromboth Butler Bar and Panther Creek Forest Camps.

The spraying techniques and conditions as outlined on p. 4 givecause for concern. The Dow Chemical Co.(one of the manufacturersof phenoxy herbicides) recommends aerial spraying from 10 feet abovethe ground, but this project plans spraying from 50-70 feet above

' ,>the vegetation. Drifting of the herbicides is the major technical$i| problem. The U.S.D.A. states that 2,4-D, aerially applied, can

drift to a radius of 4 miles with no wind. With wind of 3 mphU8-; 2,4-D dropped from 10 feet up in one experiment drifted 84 miles.'

,/,Therefore leaving 100 foot unsprayed buffer strips will not eliminatethe possibility of considerable contamination of streams from the

i Jproject. We approve of the conditions set, as far as they go, forprohibiting spraying, but feel that "air turbulence adequate toseriously affect normal spray pattern" is meaningless. What wouldthe limiting criteria be? Exactly when and where will these weathermeasurements be taken? What are the provisions for interruptingsprayin if one of the prohibiting conditions develops while thehelicopter is out? And what instructions will be given to the heli-

¢ copter pilots in case of equipment malfunction? All of these question,\\should have been answered in the impact statement.

The water monitoring system is probably a good idea for obtainingempirical data, but how can "corrective action" be taken after"above average" concentrations of herbicides are found? The damagewill already have occurred. What are "average" levels? Also, whatare "tolerable limits" of herbicides in water? Tolerable to whom or

i to what?

letter to Mr. W. P. RonayneMarch 29, 1972Page 3

The DEIS inadequately discusses, on p.5, the persistence of theherbicides to be used. One study is cited on p.8 which shows that2,4-D was degraded by soil bacteria in 10 days. We have not seen thatstudy, but research by Logan Norris shows that in a typical Oregon

act lforest community, unless interrupted by heavy rainfall, 2,4-D persists,a Efor more than 1 month, and 2,4,5-T for more than 4 months.2 Other

research, using drier, less fertile soil, indicates that under someconditions even 2,4-D can remain active for 1-1/2 years.3 There is

\ (jsome confusion as to whether or not these substances are persistentt,_;in water.

Pages 5 - 8 of the DEIS are concerned with effects of the herbicideson some of the animals and plants in the areas to be sprayed. Thesection on "Terrestrial Vegetation" shcws mainly that the susceptibili) of many of the trees, shrubs, and forbs in the Siskiyous has not beendetermined. The grasses, ferns and mosses may not be killed directly

> by low levels of the herbicides to be used, but 2,4,5-T can kill grass.and affect even Douglas firs at high concentrations, and the changesin soil, sunlight, and moisture no doubt have indirect effects on everplant type in the sprayed areas. Whether or not any of the rareflowers and shrubs native to the Siskiyous would be adversely affectedby the herbicides is unknown or at least notmentioned.

The sections on "Terrestrial Wildlife" and "Aquatic Life" are no morereassuring. The discussion of effects on mammals is totally inadequateoverlooking effects of repeated exposures to 2,4,5-T and not mentionine

[ studies showing acute teratogenic effects of both 2,.4-D and 2)4,5-:T r- on laboratory mammals, or studies showing acute toxicity to livestock

[); from feeding in pastures treated with 2,4,-D which apparently caus sI the build-up of large quantities of nitrates in grasses and weeds.

The finding by Black, to which the DEIS refers, that "deer used sprayerareas more than unsprayed areas the summer following a spring treatmentis cause for great concern. The defoliants cause excessive sproutingin shrubs not immediately killed, which would certainly attract deer,and elk as well. But what is the concentration of the herbicides inthe sprouts, and what are the levels of herbicides and nitrates inother vegetation these animals might utilize? Not only would largequantities of these substances be directly toxic, but even small amount

V might cause serious malnutrition problems. A study by Barber and Nagy'shows that 2,4-D inhibits the ability of mule deer rumen bacteria todigest cellulose.5 This may already be causing problems in some easterOregon deer ranges sprayed to remove sagebrush. Of course there isalso the possibility that 2,4-D will remain in water sources and inplants eaten by the deer on winter ranges in the Siskiyous. In thiscase there would not only be possibilities of toxic effects and mal-nutrition, but also the chance of teratogenic effects on fawns bornthe following spring.

Letter to W. P. RonayneMarch 29, 1972Page 4

Drifting 2,4-D, 2,4,5-T, and 2-4,5-TP from chaparral spraying projectson the Tonto National Forest in Arizona caused extensive sickness,deaths, and birth defects in wild mammals and birds and in domesticlivestock, poultry, and pets on adjacent private land. Illness toanimals and humans was related to direct exposure to drifting spraysand to the use of plants and drinking water still contaminated manymonths after the spraying was completed.6

Effects on birds of the herbicides to be used are almost unknown.Direct toxicity may be quite low, but, as shown above, the majorproblems from the phenoxy herbicides are from delayed and/or indirecteffects. 2,4-D is teratogenic to gamebirds.7 High nitrate levels,as well as changes in the plantcommunities, could severely affectfood supplies directly, or indirectly by changing invertebrate den-sities. Defoliation of trees and shrubs would decrease the number of

Ik available nesting sites and shelter areas.

Amphibians and reptiles are not even mentioned in the DEIS and sopparently effects of herbicides on them are unknown. Affects of the

pherioxy herbicides on invertebrates are not really known, either,(although atrazine is certainly directly toxic to them.

The small amount of research on herbicides and fish indicates probablylow toxicity, although indirect effects from lowered food suppiies.No long exposure studies are reported in the DEIS but there are indi-cations in the scientific literature that the general health of fish

. is damaged by 2,4-D, leading to invasion by internal parasites.8

' Possible side effects of the spraying should have been mentioned.Killing trees and shrubs right along the banks of streams, whether dontby logging, direct spraying, or accidental drifting of sprays, hasknown results: increased water temperature in summer and increasedsiltation in rainy seasons. Both of these spell disater for spawningfish.

There is no attempt in the DEIS to discuss environmental effects of\ \ the diesel oil carrier, except to show that this substance, like the. herbicides, can be degraded in soil. What about its persistence in

water? And what about its effects on plants and animals before it isdegraded?

As in the discussion of effects of herbicides on other forms cf lifeithe section of the DEIS on effects on man minimizes the possible dangeand ignores many scientific studies which should have been reviewed.The lethal toxicity is not really at issue, except in the event ofaccidental exposure of the workers in the project. What is at issueis the long term effects of low level exposures to the sprays. As wementioned above, residents of Globe, Arizona, suffered a variety COtypes and degrees of illness following spraying of 2,4-D, 2,45-T, and

Letter to Mr. W. P. FonayneMarch 29, 1972Page 5

2,4,5-TP on chaparral in the Tonto National Forest. One person (andher property) were d rectly sprayed, but most of the effects werefrom drinking water and eating fruits and vegetables contaminatedby drift from the project. The quotation in the DEIS (p.8) from thereport of the Advisory Committee on 2,4,5-T to the Administrator ofthe EPA contains the qualifying phrase "2,4,5-T of low dioxin content.Several herbicide factories were shut down temporarily due to high

\'N incidence of partic ular diseases among the workers when the 2,4,5-Tas contained large quartities of dioxin (one worker continued suffering

ft at least 6 years after exposure ended).9 This substance is apparentlyan inevitable contamninant of these herbicides and is also producedwhen either 2,4-D or 2,4,5-T is exposed to excessive heat. Indicatiorare that it is per3istent in living tissues, is not degraded by soilorganisms, and is 'I much higher direct toxicity than the herbicides.Studies using 2,4-2 and 2,4,5-T of both low and high dioxin concen-trations found increased incidence of birth defects in laboratoryanimals (our only way of testing for dangers to man) and the fewmedical news items from Vietnam show that herbicide spraying may bethe cause of increases of similar birth defects in humans living inand near the heavily sprayed areas.10

It is, likely that at least a small portion of the herbicides usedin the Siskiyou project would get into streams and be available indrinking water, especially from the units which are near campgroundsand other areas of human use. The amounts would be small and theperiod of contamination brief under normal circumstances. However,

i. ±o' much greater concern is the very real possibility of forest andbrush fires in tne Siskiyou National Forest, particularly on thesprayed sites due to increases in *. amounts of dead and dry brushmaterial. As indicated above, the heat from fires would cause both2,4-D and 2,4,5-T to produce dicxin, which would be released into theatmosphere to further contaminate vegetation, water, wildlife, andhumans. This is a problem which could have unforeseen and extremelyserious consequences.

Some of the comments made in section III of the DEIS represent idealconditions and not necessarily what will happen. Thus, reducing thevolume of plants on a given site may have effects which are advantage

., only temporarily. Particularly in the Siskiyous, summers are very driand hot. Too much direct sunlight can scorch and kill seed!tngs and

't saplings of many desirable plant species. No doubt competition foravailable moisture is severe during the long summer, but herbicideswill compound rather than solve the problem in the long run. Naturalmechanisms for conserving moisture are shade, mulch, and humus.Normal life and death cycles of deciduous and annual plants, as wellas plant community succession are the means by which these mechanismscan work. then severe fires, clearcutting, or other disasters barethe soil, it is at once highly vulnerable to all types of erosion. -Wind, rain, frost, and gravity physically remove it, while nutrients

Letter to W. P. RonayneMarch 29, 1972Page 6

and micro-organisms are further burned by the sun and leached out byrain. It takes but a matter of hours or weeks to sterilize soil orerode it away entirely, byt it takes on the order of 10,000 years tobuild just an inch of it. 1

Pioneer plants invade an area bared of vegetation, and the perfectsymb btic relationship begins again. For the plants cannot livewhere there is no soil with its microorganisms to supply the plantswith nutrients, but neither can the soil live without the plantswhich supply the microorganisms with dead vegetable matter to feed onand decompose. Neither one can live without water, so each partner

Y.\ helps to conserve it, the soil by absorbing and holding it in itshumus sponge, and the plants by providing shade and mulch with itsleaves to keep the sun from evaporating it. And most importantly,neither one can live if erosion continues, so stabilization is a jointventure, too. The plants, of course, brace the soil with their rootsand break the wind with their branches, while the soil humus soaks uprain instead of letting it wash over the surface, and it holds theearth together in a fabric of decayed vegetable fibers instead ofletting the water line up flat particles of silt or clay which canslide easily against each other. Hard as it may be to believe,terrestrial life on this planet depends on this humble relationship.

Many factors determine which types of plants will D'ow on a givensite at a given time, the most important factors being the presentcondition of the soil in relation to the availability of moisture andsunlight. Every stage in the plant community succession has its ownrequirements and its own "purpose," which is to change the micro-environment and prepare the soil for the next stage. The climaxcommunity, be it conifer or brush, has the "purpose" of maintainingequilibrium, by maximum stability from erosion and by continualreplacement of soil nutrients used. In a forest community, undernatural conditions, shade, decay , and frequent small fires keep theamounts of underbrush, dead branches, and fallen needles or leavesto a minimum. In drought periods hot fires will create small openings.but these are often reseeded to trees again right away by surroundingsurvivor trees. If the fires have damaged the soil, the successionstarts again, but with a ready seed source the tree seedlings startto grow before the brush has completely taken over the site. However,in altered circumstances, for instance where fires have been con-trolled for many years, these dry materials accumulate to becometinder in low rainfall years, setting off devastating and repeatedfires which can burn huge areas of trees, destroying humus, nitrogen,and other nutrients in the soil, and allowing winter rains to erodethe area. Then the whole cycle has to start over again, each stagemay last a long time, and even when conditions are again right forgrowing trees it may take long years before chance brings the seedsto the area.

I

Letter to Mr. W. PF RonayneMarch 29, 1972Page 7

Extensive clearcutting of timber has almost identical effects, thesun burning the soil (if indeed the slash is not burned on purpose),and the site eroding in rain and wind. Clearcut areas which have beensuccessfully reforested have been either small, on gentle slopes, onnorth slopes (or in some other way avoiding the full force of the sun),or have had some other ameliorating condition so that the microenviron-ment remains right for growing trees again right away. Vast, steep,

. exposed clearcuts, where replanting is often not attempted until the:' soil has been ruined, and where the slash has been either burned or

removed instead of chipped up and applied as mulch, such sites cannotproperly grow trees again right away. Neither can areas which havebeen burned repeatedly. These last may even become permanent brush-fields. Not even ceanothus or alder can draw nitrogen up from lowersoil layers and supply it to the topsoil if the soil is so badlyeroded and burned that nitrogen no longer exists in it. The perennialgrasses and shrubs are needed to stop the erosion and replenish thesoil. If the site can again be made "ready," and if a seed sourceis available or seedlings planted, trees will grow up underneath thebrush, eventually overtopping and killing it.12 This is not a processwhich should be hurried, except perhaps by the addition of extra,

a (organic fertilizers. Application of herbicides, artificial fertilizers,rodenticides, etc., may succeed in growing trees, but the crop will beless resistent to diseases, and it is possible the wood will be ofpoorer quality as well.

Section V of the DEIS discusses alternatives to the herbicide sprayingprogram. The paragraph on mechanical control methods evinces anenvironmental concern not often displayed by the Forest Service. Italso leaves readers with the question, "they want to use herbicideson those areas for the purpose of later harvesting of conifers, butwhat is the difference between clearcutting those areas and what theyhave described?"

Section VI compares forestry to agriculture, an illfounded desire.Chemical pesticides, artificial fertilizers, and heavy machineryhave indeed increased the quantity of crops yielded per acre, but atthe expense of a very significant loss of quality in the crops har-vested. The failure to restore depleted humus has started a viscious

, circle, with erosion draining fertility further, making crops lessresistent to disease, leading to more artificial pesticides andfertilizers, which kill soil organisms and at times cause increases inpest populations. The harvest, meanwhile, even if it is high in

C quantity, obviously has a defecit of nutritional value. Agricultur'sI example is not one the' forester should try to follow. Instead, heshould learn, from its mistakes, that healthy soil is the key toincreased harvests, since humus, with all its microorganisms, is thefine line of life between sterile, crumbled rock and plant.

Two ideas have become extremely clear to us in preparing these comment.s.One is that the brush fields of the Siskiyous have a function inforest production, namely the rebuilding, stabilization, and protection

Letter to Mr. W. P. RonayneMarch 29, 1972Page 8

of the soil. These "unwanted" species should theifore not beeliminated, because the conifers will either grow up through themor not grow at all, no matter what artificial means are used. Thesecond idea is that clearcutting on a large scale should never beused as a harvesting technique, at least not in the dry areas of theSiskiyou National Forest. Selective logging, shelterwood or con-toured strip logging -- and these only on gentle slopes -- wouldstimulate regeneration of forest trees without allowing fire to becomesuch a dominant influence, and without allowing brush fields to becomeso firmly established.

Herbicides, like artificial fertilizers, should never become necessary.Their use is always prescribed for areas where other misuses havealready occurred, and the chemicals merely prolong, if not compound,the basic problems. The particular substances 2,4-D and 2,4,5-T arelargely unknown in their effects on forest ecosystems, wildlife species,or man, but indications are that they may be extremely dangerous.We do not think there has been proper discussion of these dangersin the Draft Environmental Impact Statement. Furthermore, for thereasons stated above, the Oregon Environmental Council feels that the1972 herbicide program for the Siskiyou National Forest is both unwiseand unnecessary.

Sincerely,

Larry WilliamsExecutive Director

cc: Mr Rexford ReslerMr. L. B. DayEnvironmental Protection AgencyCouncil on Environmental Quality

List of References is AttachedLW:jai

List of References for the Oregon Environmental Council Responseto the Draft Environmental Impact Statement, Siskiyou NationalForest Herbicide Program, 1972.

1. "Controlling Mesquite with 2,,4-D," Folder #98, U.S.D.A.,1962, and "Drift of Pesticides," California Departmentof Agriculture, Jan. 1960.

2. Norris, Logan A., "Degradation of Several Herbicides In RedAlder Forest Floor Material," in "Research Progress Report,"Western Society of Weed Science, 1969.

3. Report #16, Southeastern Forest Expt. Station, U.S.F.S.,Ashville, N. C., 1965.

4. Gordon H. Orians & E. W. Pfeiffer, Science, Vol. 168, #3931,1970 and L. M. Stahler & E. I. Whitehead, Science, Vol. 112,#749, 1950.

5. Thomas A. Barber & Julius G. Nagy, "Effects of Pesticides onMule Deer Rumen Bacteria," in Transactions of the 36th N.American Wildlife & Natural Resources Conf., 1971.

6. Billee Shoecraft, "Sue the Bastards," The Franklin Press,Phoenix, 1971.

7. M. Etienne Wolff et al, "Disastrous Effects of the Herbicide2,4-D on the Embrionic Development and the Gertility of Game-birds," Acad. of Sciences - Ser. D, Title 271, Dec. 1970.

8. Phillip A. Butler, "The Sub-Lethal Effects of Pesticide Pollution,in "The Biological Impact of Pesticides in the Environment,"J. W. Gillett, ed., Envir. Health Sci. Ser. #1, 1969.

9. Thomas Whiteside, Defoliation, Ballentine Books, N.Y., 1970.

10. Id.

11. E. B. Balfour, The Living Soil, The Devin - Adair Co., N. Y.,1950.

12. Jerry F. Franklin & C. T. Dryness, Vegetation of Oregon &Washington, U.S.D.A. F.S. Research Paper #PNW - 80.

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iF5IDERATION OF WESTERN OUTDOOR GLU~bOs~j rw,,,b~lirbI/r d 19'2 for 3I I S the tioon of tIe Proper Uu. Enornnet a,,I

&IJ P~tg~f i nt.pii Scenic, X'ild/rilnis ,,e:d Outdoor Rccreialon Rciourrcei.

' 1971-1972Plerdct BETTY HUGHFSP 0 Bo. 2067, Cr,-nl. Call 93921

V-e Pesdq-,t ROBERT WENKAM1372 Kapoan- Blvd Honolulu, H...,,,96814

I , , _ _ *

Seo,.tan {ELIZABETH HANDIER ,J634 N Cooeercai Ave.. Porflad, Ora, 97217

Tresn e ff, KATHERINE MARTIN410 W.v on St, So. P-sad-ra, C.Ii 91030

Norfwirl Conse-vat,on Repsenttrv:BROCK EVANS4534'7 U.v--rsty Way NE, Seati, Wash 9H105

MEMBER CLUBS -

A N

State Vic. Presidents

DIXIE BAADE, Alaska

ANNA LAURA MYERS, LARRY GIACOMINI. CalIfornR

CYRIL M SLANSKY, Idaho

DR. LOREN L KRECK, Montana

CLAIR SIDDALt, Oregon

JACK E McCLELLAN. UtahLILLIAN KELLER. RAY KRESEK, Washington

Ed toe

HASSE BUNNELLE943 Milb To-er, San Francisco, C.lIf. 94104

April 6, 1972AlPINF ROAMERS

W.atchee, Wash ngtonANGORA HIKING CLUB

Aslc,.a, OregovbOEiNG EMPLOYEES ALPINE SOCIETY

Seattle W.Sh-ronCAL.FORNIA ALPINE CLUB

San Frano oo, CalilornaCASCADE WILDERNESS CLUB

Bell nghorm. Washi,,tonCASCADANS

YaLka., WoshingtonCHEMEKETANS

Salen,. OregonCONTRA COSTA HILLS CLUB

Oak ind, Cllforn-aCRAG RATS

Hood REver, OregonDESOMOUNT CLUE

Los Angeres. CallfornlaHOBNAIlFERS

Spokane, WasrhngtonIDAHO A0EINE CLUB

IoaI. fail,, IdahoINTER MOUNTAIN ALPINE CLUB

REchl-nd, W.shlhglonKLAHrHANE CLUB

Por Aneles., WashingtonMcKENZIE GUARDIANS

Blue Ever, OregonMONTANA WILDERNESS ASSOCIATION

Bsozenan Mo -t.,,.MOUNTAINEERS

Seaftle, Wash,vgtonMT BAKER CLJB

BeIngham, WashlnglonMT, ST HELENS CLUB

LOvgvem. WWahingtonOBSIDIANS, INC

Fugen OregonOLYMPIANS. INC

Hogriam, Wash ngtonO SU MOUNTAIN CLUB

Corvallis, OregonPTARMIGANS

V .coj .. r. WshlngtonREEO COLIEGE OUTING CLUB

Porravd OregonREGIONAl PARKS ASSOCIATION

Rerkelny. Callforn.RIMROCK MOUNTAINEERS

CoOlee Dev WashinglonROAMER HIKING CLUB

lnglewood, CalltorniROCKY MOUNTAINEERS

M--sol. MorranaSANTIAM ALPINE CLUB. INC

Sale,- OregonSEATTLE AUDUBON SOCIETY

Seattle WashingtonSIERRA CLUB

S-n FrInvsco, Calilorn,.*SKAGIT ALPINE CLUB

MO-t Vernon. WiaslhvgronSOU'HEASTERN ALASKAMOUNTAINEERING ASSOCIATION

Kvc~hk -a Alask aSPC'A'AE MOUNTAINEERS, INC

Spokane W-shnyrooSUMMIT ALPINE CLUB

T.coma, WashIngtonTAMAIPAIS CONSERVATION CLUB

S-n F-ancoco, CallorniaTRAUIS CiUB OF OREGON

Porland, OregonWANDERERS

Oly.,pia. W.1h ngtonWASATCH MOUNTAIN CLUB

Sri, 1 ̂ .e Coty, UIalhWASHINGTON ALPINE CLUB

Sca0rr, Wah.ncr-o.WASFI.'iGTON KAYAK CLUB

S-:. ti WashingtonWY EAST CLIMBERS

POrt!a.,J Orweo ,

Mr. egslerU.S. Forest ServiceRegion--V-rP.O. Box 3623Portland, Oregon 97208

RECEIVEDWATERSHED MGT.

APR 6 1972F.Si R-6

Dear Rext

The attached book review from the publication "Arizonansfor a Quality Environment" came to my attention after I hadmailed you our comments on the draft environmental statementfor the proposed Siskiyou National Forest herbicides program.

I think it is quite relevant, and it points up some ofthe dangers of 2,4-D and 2,4,5-T, which we also referred toin our comments. Could you please attach the review to ourcomments and incorporate them by reference into it?

Best regards,

Brock

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*^r. ,tnt.2 1 .s' :wnolr dying. C: :.. o ',in;t: anoe b -,avitr :f' tn: livesto, .

' ' i. 6- .. '. li ,. i: : i ,!' fin indil ; ifru-trats ;i. ;th ,1u.r-:.i - .-erntent of1', -ti. . in the lb:yrinth.: I o;areaucrao:_cs,reanain eithOI :rcsioly ignorant of ' :v ' re dsing or choose (,it of desire tokeepn. thsir p. .'.. ._ .% i.rd tho.ir p. r to disxre,.a! : the evidns~.

harly in the gan. h discovered that tsa:e ezt Servv-o hai been cpoaying 2,4-D ad2,4,5-T for s. years without -,ny to-dc. 'Lie Fore;3t .: tie was oblivious To thedanigvro; in a- -, ij~ty herb5icide t:lvl't deadLy ov~n ihough em;r,ty,were painted igseeni and plaac' Jr. rdcnic areai. nL. a'.ir.dful of re . ie had bven officially in-fono I of th.c , por.n. A: ter il. thlre's no t ;w against it. For' examp1e,she obtained a p f a lettcr date , .uul:, 19o5,, s Lnt iy the For'.a Service inGlobe to four are ranehlert. One miehtr ' ricxi that all iour leased land from thegovernment and ne '.ia then an empr.]vyoc ,'V IIV Forest d rvioe. Thu .etter atatedthat the Globe orea would be the sito o: t: ge Chap3rrai s 3pray proJt '., with thepurpose of e -rit. rome 14.v - 2- .J c:es t>.very c ohaparral stands to orebategreater forag: ai,- water yield. like l- t.j'* le used Wt., 2-41D and L,4,5-T. from whichthey did not antcc-;ste any aiverse ei 3'ct.. Ccnsi&draticn was to be given surrcundc-..-areaj, but aL was ,elt that they wv.jud -. !tlt from the program throuvh the prodtctir:2of r.,ore cow feed, rioro wildlife, bettsr wot r vield.

With such offi vli assurances, who wcuud .:int -o rock th2s toat? Today. 3 inumber of

years later, nrvns-i of the regisn -prayeji lS iarrically barren. Grasts wll nut grow.

Lut it te pointed *ut that the Globe i not an isvlated cne. ih nerbicides have-bean sprayed over every natiLr.sl forest in .Ilfornin. A documented ea"e reveala tnat

- cne helicopter fis i over a reservoir v:in it ,pray bt-l-.in6 behind. Ai an Arizona,Mrs. 2hoecraft IIozdfom a state e-:-loyve tinst a 5e-cet Jtjdy Ios on: iciway in a s3roelyjrh.hbited part *: r state ti 2.ocover th, ' r.-rsngo effeots on hl.-'ns. The gilinea pogsdon't know abo-: it. When the aire cocus icr 'them to bt. txazrdned thoy will be told t.eir.vestig3tors ar2 otidying th" ffectz of 'I.-L

Mienuihile, bac -. n rtobe the p;ople we- b ocang upset, and Mrs. Cno- rzaft, sick her-ssl ' and w3tchim, her pets di-, was at . hpat. Tr- :<rest Service, De-artrent aIAgri-ulture, E';- 'ier Pro,,ers, ERcreau cr ,an3 ' sna';':: . rtncners, chenmnal companies,h-i ,, stte and r:et1, rl3 officials as wel] i.i lcal o~ff a-'s also had :heir chance todisp'ay their ability to pull tosether in i interest of rmaintaining t';e status qCo. t

So far the sit'nati-n, includir: ;Irs. mhor.ft's multiritilion-dollar zuit, ha? not beenres-l-iwd, but : a f3r 3S is kn %%n, 2,4-D mid ",-,WT corktn au- 2n us-:. As to the mr.ti- ,r

vat-on for her o~.-rsivc and ,otly t'I;''t, I't'. Shoecraft'3 statement iz a classical r.nefcr those conce r.-:d with the environ-rent in whiob they l:v.:

V-aL -T am doing, cshat T hive n r~e, or wlhct I wtll do, is rotf-rc ha amnity. ft ts for rne--tcr mnvalcf-f7r .!iis person i rererto wh'n I say "I". ' at for y. ., not for t- rin acroos thestrest, not for a easar.t in *annam, not -v-n for unbrongenerationr, but for re. For i--ly when 1 c:3re "nough abaut whathapFFrn- to ce, so r'vc.Ž so t!.-at I -fuse to nave , riC;hbtviolased, my lass braken, ^y mountains destrayed, wheth-x theyare the Pinals in Arizna, or th" Cmokie. in T-nnessee--Oniythrn. will I care about w-at hai.i.'.ns to J mu. a::d the re-t

of hu:tarity.

At times the boo:k is prolix, and one mtiho woim for a n:re orderly sec irt. Put, verymuch in the r3anutr-asn of American tradit or., it daes rc:'resent a graa-r Ats fi:htagainst big tu _nese and big goveruzent. nue the hast3ads i. available at the hosixk Stop,2504 N. Carpoel 1 A.vernuejTtLcs; se- A r'c -nd.

0

N .-' BROCK EVANS

BRO; 1 i,913tCK E'VNS i Aph 3 1972

- ~NGORTMIIVEST C01 K NA`i,' DEP.E MITIVE'-~ Conservatio s Center------ *- 46341/i UNIVERSITY WAY NE ME 2-6157 SEATTLE WASHINGTON 98105-- t~March 29, 1972

~C _ Pr. R{exford Resler, Regional Forester_ Region VI

_,--A.0. ',ox 3623 Re: File # 1940, Draft,,'Portland, Oregon 97208 Environmental Statement,

Siskou iierbici.des Pr-o.ran

Dear Nr. Resler:

-1 , Thank you for the opportunity to comwment upon the Draft Environmental'Statemtnnt above noted.

The program, planned for this year, would consist of application ofherbicides 2,4-D, 2,4,5-T, or atraziinc on 213 different areas, weith atotal acrea-c of ll,3SJ acres. Usir'r! application rate and acreagospiven i.n tihe renort, this vi'l.1 amrount to 23-35,000 pounds of 2,94-D and2,4t5-T 1in.,sed, and 990 Do.inds of atrazine. Using the FYs 1971applicati.on coct pixr acre of r.19. (20 t ch -ttal estimated project costwill be about $22%O'0. Reduction of vr-otative comipetition to increasesuILrIv.-vA of newly-planted so-lin~s (-L3(3 acres) and release of youngconifer trc:es from suppressive vegetation (10,550 acres) are two reasonsgiven for the program.

In our view, this is a prograa of extremely large scope and isfrau-1ht with possibly -- e osr seriotus consequences for the environmentof the 'Siskiyou National For-.ct. Therefore, we wrill direct our commentsto the potential. impacts as We see t-em.

T7%rirt (f e ::) , u. A goracixa d -al has been written about theadlver.-e oncvironr..eni-;al e-i-ectc oL 2,4-L and 2,4,5-T already. The NationalParkc Sc-rvice f'elt that its `.tZenial -. zards to other forms of life wereso [,,i2,-'t that it banned a proposed pviag program along park roads.This is just one examnie o:U- wnat anoth-r federal arency has done toprotect the environment from oadverse cfCLfects of those chemicals.

On November 12, 1970, thc Daily 'Missoulian carried an article onthe mrIthi.y meetin- of h1%`ontarna EnvirorL..cntal Cocirdinating Council. Inii: wore comments by a 1%r-. 1ThU, ourOng1fu a chemist wi1 th the Universityof voratolna Dcoartmnent of 3OtlnY* ,' To '. -arn-eau advised the environ-merit).li: Sto question coontinued use of such h-ierbicides as 2,4-D and2,4, 5-T when it is known that they hv..c hA'irmful effects on low1er lifeforms hut not human beings. };e stated, "Since .966 it has been knownthat thesc chemicals can cause birth'l e-ects and they are still beingspread into the environment. Just becLuse p:oplc don't drop over deadiinmneliately doesn't mean that therc. :cn t any serious cffects." Mr.Touranl-lgyflU W3S citing evidene.e g;•.cthci.c by the Deopartment Rf lHealth,Education and lWclfare, publi..shedc in a bD2ceimlber 3.969 report titlcd"Secreary's Commission on Pcsticides and their Relation to EnvironmentalHealth".

It seemed plain to us from the cvidence accumulated in these reportsand clsewhorc that those herbicides have great potential. danger, and canhave adverse impact on other forms of life, despite the comments to thecontrary in the proposed Environmental Statement. We would urge extreme

R% .. pe~eJil . the Sierrok Ctil, naid Iv , 1e4rntiQPn of Webtern (utdoor Clubs,

a

- Mm

1ir. Reoxford iResler, Rcgionral ForesterPage Two I'March 29, 1972

caution in application of any such herlicides, and recommend that,if it is done, it be done on a ;-uch smaLller scale as a pilot demon-stration projectt with t:he results careiully monitered over a periodof years.

Forestry practioes. We feel this is a relevant subject in the contextof the question of wxhether or not mrsasisve applications of herbicideswoul1. be used in the Siskivou National Forest. Th is so, because we feelthat there is evidence to inidicace that, if cutting methods were modified,there would be less competiti-on for b-_r;ush, and correspondingly lessneed to reduce the brush to permit youn.,ag seedlings to rmnature at thedesired rate.

Our consulting forester, . r. W illiam Conway, has examined theproposed B3oulder Creek sale and also thle planninrg near \Wi.ldhorse Lookoutas examplces of wihat is currentlly in pror-,ress on the Sisiiyou NationalForest. Although the areas in ue-stioil in the draft statement are nowcut anl plantted, ;'r. Conway f (,se S tA:-);C thihe prop'oosed Boulder Creek salewill 6ive some idca of the staond coniJ.it 'ons ex sting before timbercuttin,- i.n an averige stand or, -thc! S.S;ou. The uni.t to be cut herewould b)e no IbOe:,ttcr th.n a site PV for .KugaS fir. Site III is consideredaverane for the B3roo.'ingis D) is.:-iciS 'Lbut: ziany other current sales observedwere on site IV and V Dou-las fir land * The common denominator for thesesites is Aidely scatteredi tr.es of pDO:- quality, a great deal of taperto the logs, -and he!avy brush c1w;vcr, wi.th, rhododendron thel main brushspecie'S. ',-d:hen coupledi with thre foreos:; 3oil survey, it is questionablewhether many of these sites should be ' loged in the first place.

The planted areas in the vicinity of Wildhorse Lookout were mainlylocated on site III and TV. T-e avera-gc age of the planted trees wasabout ten years. The avera-e h. i-ht o-0 t.he seedlings and saplings wasabout three feet; normally Nrieldc tab)leS show that the height of thesesaplings should be aboutl five feet. In i-many stands, the practice ofclearcuuting has encouraged 'brut!sh inva.i.sion, and has led to a greaterd(ensity of brush cover. 1anY stands a.e just competing with the rhodo-dendron, and some are losin3 the batrc3.<- Growfth reduction is signifi-cant, and it will be interest 5i, to sec the economic impact of the brushon thinning crow performance at the time of t:Jue first pro-commerc.althinning.

Thle conclusions drawn by us frori3 tchiss situation, which may be theaxvera,-e situation on the Sishiy.n, is rnot thlat w.e should enter intomassive applic:ations of horh.i.cidcs t-o reoiove the: bru-sh. It is ratherthat IeC should quickly -,move to another iechod of cutting, distinct fromthe clearcuttinag which is apparently now being practiced in such largemeasure.

X'r . Conway recommends first, that some sites be considered for notimber Cuttingn whatsoeverC evcen if th(1C:Y -re presently included in theinvencory for i:the allow,-,.n)lo cu:. * eccct;ly, i) p)Oi.nts outi that on themore productive sites, the on-i ngCs Cr tCd by timiber cuttings ;hould beheld (1;ui in order to allow !..;-oC hadc in t.hc cutover area.;. pointsout that control of overhea6 Ji-.l;t is onc! of th.>e best i-meithods to dis-courafge br-ush invasion* Dcn!se r1e _-,enorac ion o. natural sedlingLs wlichthen rCsults w.Ti11 helm insure control, Of the site. The effect of theho~t, dry sumnmers in the Sis]:,.you rc.1-.i (i on sedclinr survival, in clearcutshas alrctrey been well deouonstrzit-ed, and is a furthe-r argument in favorof srn])leu- clearcuts and r.nuci-. rA:re si..ic.. This will have Cthe ilonact of

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.. - Pa--e ThreeU� I -1

a Tarch 29, 1972

invasion, and thus will elininate any alleged nced to engage in massiveherbicide spraying programs such as the one proposed here.

In slhort, we reconmend as a mearziinful alternative to a massiveherbicide srrayin,, program, an imm.cdi.ate reevaluation of the entiretiiiiber program of the Sts1kiyou iational Forest, with an aim to doingmuch more Ili1:ht selection and grounl seLection of cutting. This maycost the timber companies a li.ttlc 1).t more money hbut it will vastlybetter protect the public forcvt resource, which belongs to all of us.

Thank you for this opportunity to comment.

Very truly yours,

Brock Evanslscc: Holly Jones

Diane ',.cyerDave CorkranLarry .?Will iams

Wk (.Acrs t7

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