Introduction and Background
to
Risky Business: Invasive species management on National Forests -
A review and summary of needed changes in current plans, policies and programs
www.kettlerange.org/weeds/

February, 2001
by George Wooten and Marlene Renwyck


Abstract

Invasive species management on public lands is a complex issue which is currently being approached in a variety of ways. Recent efforts to eradicate weeds on National Forests have been costly and sometimes ineffective. Controversy has erupted over the use of herbicides and their potential for harm to health and the environment. This study critically examines the basis of current plans, policies and programs for managing invasive species on federal public lands, along with a presentation of alternative solutions.

To successfully control invasive species, sound policies must be in place, which require clearly stated, measurable goals and objectives based on an understanding of the biology and ecology of invading species. In responding to invasions on public lands, managers need to shift their approach from short-term reduction efforts to flexible approaches that treat the causes of invasions rather than the symptoms, while placing more emphasis on prevention and monitoring.


Document Conventions

This document provides the background and rationale for recommended changes and improved implementation of objectives, policies and programs dealing with the management of invasive species. Topics are described in detail along with illustrative case examples. Emphasis is placed on describing the effects of herbicides on lands administered by the Forest Service, although in many instances, discussions also apply to pesticides in general and other land ownerships.

In the terminology used here, “invasive species” refer to those species, which are rapidly increasing in an ecosystem without controls on their growth and spread. When invasive species originate from outside the area of invasion, they may also be termed non-indigenous, exotic, or alien. When referring to legally regulated invasive plant species, the term “noxious weeds” is used. The use of the term “weeds” or “weedy species” is interpreted loosely to refer to a situation where any unwanted plants may occur, e.g., as used in common parlance, “a plant growing where it is not wanted”.

This document is divided into sections for convenience. Chapter 1, on policies, deals primarily with national and regional plans and policies, and how they interact with programs at all levels. Chapter 2, on disclosure, pertains to required program and project documentation, with particular emphasis on Forest-level projects. Chapter 3, on effects, details specific disclosure and analysis requirements for human and environmental impacts. Chapter 4, on monitoring, deals with accountability and the collection and reporting of information on project outcomes and effects. Chapter 5, on prevention, gives more details of the particular requirements of prevention management approaches. Chapter 6, on education and research, contains a brief discussion of opportunities to improve the future of invasive species management.


Introduction & Background

Plant invasions remain one of the most serious threats to the long-term maintenance of regional biodiversity (Johnson et al., 1994; Clary and Medin, 1990). In the United States, non-native species are suspected of being the highest cause after habitat loss for the listing of all threatened and endangered species (Flather et al., 1994; Wilcove et al., 1998).

Used in this report, invasive species refer to those plant species which are rapidly increasing in an ecosystem without controls on their population growth. The generic term “weeds” is used more loosely for any “undesirable” plants, or “unwanted” vegetation. Invasive plant species may also be referred to here as “noxious weeds” in the legal sense, as species designated for control. The terms “non-indigenous”, “exotic”, or “alien” plants are also used occasionally for species originating outside the area of invasion.

Noxious weeds are spreading on BLM lands at over 2,300 acres per day and on all western public lands at approximately 4,600 acres per day (BLM, 1996). As of 1997, throughout the Pacific Northwest, over 860 exotic plant species have invaded arid and semi-arid lands (Hann et al., 1997). Despite efforts by federal, state, and local activities to combat the spread of invading species, weed epidemics on federal lands continue at alarming rates. Land management agencies are failing to control biological invasions (Bureau of Land Management, 1996) and actions taken by federal management agencies have been ineffective, inappropriate, and lacking in accountability.

Studies in 1940 showed that severe costs, degradation and even destruction of resources have resulted from policies of both non-action and inappropriate action (Cottam and Stewart, 1940). Sixty years later, we continue to deal with the same consequences on increasingly larger areas with invading species. A synopsis of recent conflicts over the management of invasive species on National Forests in the Pacific Northwest is provided in Table 1, below.

Table 1. History of U.S. Forest Service policy with regard to noxious weeds. (Source: Journal of Pesticide Reform. 1992. Beyond Herbicide Wars: Trees, Weeds, and the U.S. Forest Service in the Pacific Northwest. Vol. 12, No. 2 (A publication of Northwest Citizens for Alternatives to Pesticides).
 

March 1984

Northwest Citizens Against Pesticides, Oregon Environmental Council, and Portland Audubon Society win a sweeping legal victory (NCAP v. Block) that stops all herbicide programs on federal forestlands (Region 6 Forest Service and Bureau of Land Management) in Oregon and Washington. Judge James Burns retains jurisdiction in the case, meaning he must approve any EIS written to comply with the law. Soon thereafter, the Forest Service voluntarily curtails all aerial herbicide spraying nationwide on its forestlands. 
June 1986 Forest Service decides to ignore its inadequate 1981 Environmental Impact Statement (EIS) and rewrite its entire policy. Over the next 2½ years, many groups and citizens provided extensive input to the development of the new forest vegetation management policy. 

December 1988

Northwest Regional Forester James Torrence signs the Record of Decision for the Final EIS, Managing Competing and Unwanted Vegetation. This program sets the vegetation management policy in Oregon and Washington; all site-specific programs proposed in the Northwest will tier to this regional policy. Any proposed action in Region 6 that has the potential for vegetation management activity must comply with the new EIS after this date, including all timber sales. 

January 1989

Forest Service petitions the court to lift the spray injunction. The petition is opposed by NCAP. Judge Burns orders the parties (plus Coast Range resident Paul Merrell) to attempt a mediated settlement. Unresolved issues focus on implementation procedures and specific points of fact that were never addressed in the final EIS. 

May 1989

All parties to the suit sign a mediated agreement that specifies steps the Forest Service will take in implementing the regional policy. The Forest Service agrees to produce a regional guide for implementing the EIS within six months that includes profiles on 13 herbicides. The court-imposed spray injunction is lifted. Nine other parties file administrative appeals challenging the Regional Forester’s decision to adopt the programmatic EIS. The agency issues its own administrative stay on all herbicide use pending agency review of the appeals. 

February 1990

Forest Service issues its “Guide to Conducting Vegetation Management Projects in the Pacific Northwest Region”, a document required by the mediated agreement. 

June 1990

Forest Service dismisses all administrative appeals and lifts its administrative stay on herbicide use. 

January 1992

Forest Service issues the first herbicide profile for glyphosate, clearing the way for its use in northwest forests. Thirteen profiles are required by the mediated agreement. 

Many of the problems wrought by invasive plant species are a symptom of a larger problem of poor health of the land, brought about by excessive soil disturbance, overgrazing and excessive roads (Belsky and Gelbard, 2000). Models of the spread of invading species resemble that of infectious diseases. For an ecosystem, invading species are the equivalent of disease agents (Mack et al., 2000; Vale, 1982; Hengeveld, 1989; Grime, 1977). Consideration of disease etiology has strong implications for invasive species management, particularly in addressing causes and prevention.

To be effective, policies should be based on an understanding of the biology and ecology of invading species and must place higher priorities on prevention of new introductions and stopping the further spread of invaders (Campbell, 1993). Policies should account for the causes of plant invasions and should take a hard look at curtailing nonessential activities that contribute to invasions.

Successful invasive species management programs must function effectively without compromising the health of soil, water and native species. Policies must be based on sound science and programs must adhere to policy guidelines. Planning documents should provide reasoned analyses of environmental costs and benefits. In the absence of a distinct program aimed at preventing noxious weed spread, inappropriate management may increase the spread of noxious weeds (O’Brien, 1997).

Accountability continues to plague federal land management. The General Accounting Office (2000) recently cited the lack of clearly stated goals and objectives as a significant obstacle for the Forest Service:

In addition, the Congress could help to expedite the Forest Service becoming more accountable for its performance by requiring the Agency to replace 13 years of promises and false starts with a strategy that includes clear goals and objectives, firm deadlines, and measurable indicators of progress.
Without clearly defined and mandatory objectives to force accountability, federal land managers have no means to assess the effectiveness or appropriateness of the actions they take. When policies provide sufficient direction for programs to operate under, assurances must be given that policy guidelines and regulations will be followed.

This study critically examines the basis of current policies, plans and programs for managing invasive species, along with a presentation of viable alternatives. Policy-makers should consider the formulation of a set of rules to guide invasive species management based on some of these principles.

Discussion topics are divided into chapters and sections in the main document, followed by operating principles and recommended solutions at the end of each section. Throughout the main document, case examples are taken from current programs to illustrate specific points.