USFWS-VHDR-08

Herbicide Application Reporting

The licensed applicator will keep a record of all plants/areas treated; amounts and types of herbicides used; and dates of application as well as other monitoring elements prescribed by the PCA in VHDR-007; pesticide application reports must be completed within 24 hours of application and submitted to the applicable agencies for review. Wind and other weather data will be monitored and reported for all application reports.

Below is a description of the known toxicity of herbicides proposed for use under this programmatic. If other herbicides are proposed for use by a Project Proponent, a complete effects analysis must be submitted along with the ESA Section 7(a)(2) Review Form to allow USFWS to determine if application of the herbicide(s) can be covered under the PBO.

– 2,4-D amine. 2,4-D amine acts as a growth-regulating hormone on broad-leaf plants, being absorbed by leaves, stems and roots, and accumulating in a plant’s growing tips. If a Project Proponent uses 2,4 D amine, this action requires a 15-foot buffer when hand applied, and a 50-foot buffer when it is applied using a backpack sprayer.

– Aminopyralid. This is a relatively new selective herbicide first registered for use in 2005. It is used to control broadleaf weeds and is from the same family of herbicides as clopyralid, picloram and triclpyr. Aminopyralid is proposed to be used for the selective control of broadleaf weeds. Acute toxicity tests show aminopyralid to be practically nontoxic, with aquatic invertebrates showing more sensitivity. Thus, if aminopyralid does end up in surface waters, the most likely pathway of effect for fish is through loss of prey.

– Chlorsulfuron. This herbicide is used to control broadleaf weeds and some annual grasses. Chlorsulfuron is readily absorbed from the soil by plants. This herbicide does not bioaccumulate in fish. The buffers and application methods greatly minimize the risk of exposure to listed fish and their prey species.

– Clethodim. Clethodim is a post emergence herbicide for control of annual and perennial grasses and is applied as a ground broadcast spray or as a spot or localized spray. This Program is not allowing it for broadcast application; it is allowed for hand application and backpack sprayer, both with a 50-foot buffer.

– Clopyralid. Clopyralid is a relatively new and very selective herbicide. It is toxic to some members of only three plant families. It is very effective against knapweeds, hawkweeds, and Canada thistle. Clopyralid does not bind tightly to soil, and thus would seem to have a high potential for leaching. That potential is functionally
reduced by the relatively rapid degradation of clopyralid in soil. It is one of the few herbicides that this Proposed Restoration Effort program proposes to allow up to the waterline (for hand application) but requires a 100-foot buffer for broadcast application. The Proposed Restoration Effort only allows for one treatment per year.

– Dicamba. Dicamba is proposed to control broadleaf weeds, brush, and vines. Broadcast application of Dicamba will not be allowed for any project because of issues associated with drift. Leaves and roots absorb dicamba and it moves through the plant. It should be applied during active plant growth periods, with spot and basal bark periodic application during dormancy. It does not bind to soil particles and microbes appear to be the primary source of chemical breakdown in soil.

– Glyphosate 1 (aquatic). Glyphosate is a nonselective herbicide used to control grasses and herbaceous plants; it is the most commonly used herbicide in the world. It is moderately persistent in soil, with an estimated average half-life of 47 days (range of 1 to 174 days). Glyphosate is relatively nontoxic for fish. There is a low potential for the compound to build up in the tissues of aquatic invertebrates. The buffers and application methods greatly minimize the risk of exposure to fish and their prey
species.

– Imazapic. Imazapic is used to control grasses, broadleaves, vines, and for turf height suppression in noncropland areas. Imazapic is proposed to be used for noxious weed control and rights-of-way management. Its use is proposed to be allowed up to the waterline with hand injection methods, 15-foot buffers for backpack sprayer application, and 100-foot buffers for broadcast application.

– Imazapyr. Imazapyr is used to control a variety of grasses, broadleaf weeds, vines and brush species. The buffers and application methods greatly minimize the risk of exposure to fish and their prey species.

– Metsulfuron-methyl. The Escort formulation is proposed. It is used to control brush and certain woody plants, broadleaf weeds, and annual grasses. It is active in soil and is absorbed from the soil by plants.

– Picloram. This is a restricted-use pesticide labeled for noncropland forestry, rangeland, right-of-way, and roadside weed control. It is a growth inhibitor and is used to control a variety of broadleaf weed species. It is absorbed through the leaves and roots and accumulates in new growth. The use of this herbicide is restricted to hand applications only (no broadcast applications) with a 25+-foot buffer and no use on sandy or riverwash soils. The buffers and application methods greatly minimize the risk of exposure to fish and their prey species.

– Sethoxydim. This herbicide is a selective post-emergence pesticide for control of annual and perennial grasses. Its mode of action is lipid biosynthesis inhibition. Project design criteria and conservation measures sharply reduce the risk of exposure. A 50-foot no-application buffer is proposed for both spot spraying and hand application, and a 100-foot buffer for broadcast application. Other factors such as wind speed and weather also reduce the risk of exposure. Thus, the risk of acute or chronic exposure to sethoxydim is low.

– Sulfometuron-methyl. At proposed application rates, sulfometuron-methyl is highly toxic to seedlings of several broadleaves and grasses. No chronic exposure is anticipated to occur because the herbicide degrades relatively rapidly. Based on the proposed conservation measures, the risk of exposure to concentrations that result in acute lethal effects or chronic effects is low.

– Triclopyr (TEA). The environmental fate of triclopyr has been studied extensively. This formulation of triclopyr is not highly mobile, although soil adsorption decreases with decreasing organic matter and increasing pH. With the exception of aquatic plants, substantial risks to nontarget species (including humans) associated with the contamination of surface water are low relative to risks associated with contaminated vegetation. The buffers and application methods greatly minimize the risk of exposure to fish and their prey species.