08/07/2024
PLEASE SEND IN YOUR PUBLIC COMMENT BY TOMORROW, Aug 7, 5 pm! &SHARE FAR&WIDE! This is our National forest, open to all. Link in previous post.
Comment on Siulsaw invasive w**d mngt plan amendment to include more herbicide& drone use. Feel free to reuse parts or all of this thorough comment: (Also, see Carol Van Strum's very thorough comment in previous post.) Great comment to use & share!
Katie Isacksen
Siuslaw National Forest
3200 Jefferson Way
Corvallis OR 97331
Dear Ms. Isacksen,
I would like to submit a written comment regarding invasive w**d management plans for the Siuslaw National Forest.
Developing a comprehensive approach to treating invasive w**ds is a good idea; however, given the variety of w**ds,
landscapes, and topographies, I imagine that each project site will still need specific strategies.
Identifying and prioritizing which plant species should be managed is critically important. “Once an invasive species
becomes established, it is rarely possible to eradicate.” (https://www.doi.gov/blog/invasive-species-finding-solutions-
stop-their-spread). For example, Himalayan blackberry seeds are spread by birds, which is why they are commonly found
under perching sites, such as along fence rows and under power lines. Many people pick blackberries to eat and make
preserves out of them. If they’re sprayed with an herbicide, these individuals will be poisoned. This alert is posted on
https://solvepestproblems.oregonstate.edu/w**ds/himalayan-blackberry:
If swaths of land are sprayed with herbicides via backpack sprayers and drones, other edible food sources (e.g., salmon
berries, mushrooms) will undoubtedly also become contaminated. “Proposed activities may occur in all management
areas including Wilderness, Wild and Scenic River corridors, Research Natural Areas and National Recreation.” The
herbicides listed are known to leach into groundwater and/or can contaminate surface waters (see attached comments
from Carol VanStrum). Indeed, “… the actions clearly [must] outweigh the potential harm caused by invasive species.” It
seems that, if herbicides are used, the objective “to reduce adverse impacts from invasive and native species, pests, and
diseases” is diametrically opposed to the objective: “to restore and maintain healthy watersheds and diverse habitats”
(US Forest Service National Strategic Plan, USDA 2007).
The current proposal would amend the existing Siuslaw Forest Plan to add 4 additional chemicals to herbicide
formulation options, bringing the total number of chemicals that could be applied to forested lands to 14. I am strongly
opposed to this. Instead, I encourage the Forest Service to work with local communities and organizations on
implementing the other methods listed (e.g., manual, biological, mechanical) to control invasive w**ds.
The proposed action plan states, “Fluazifop targets grasses which makes it a valuable tool in treating butterfly habitat.”
This is ironic, because Mallick et al. (2023) found that herbicides adversely affect butterfly species – specifically fluzifop-
pbutyl, along with sethoxydim, glyphosate, and imazapyr, which are all on the plan’s herbicide list. Additionally, triclopyr
is “very toxic to aquatic life with long lasting effects” and aminopyralid methyl has “a biodegradation half-life of 462 to
990 days in sediment-water systems”. Herbicide sprays can have devastating consequences on both the local wildlife and
the surrounding environment. A recent study detected pesticides (e.g., hexazinone and atrazine) used in forestry
management practices in 38% of the bivalves samples along the Oregon Coast (Scully-Engelmeyer et al. 2021). Pesticides
used in forestry practices have been linked to behavioral abnormalities in salmon (e.g., swimming performance, seaward
migration, adult returns), compromised immune systems, endocrine disruption (Ewing, 1999).
The first proposed action described in the plan is prevention: “Prevention is, by far, the most effective means of
controlling invasive plant species.” Similarly, it would be so much easier to prevent contamination of Siuslaw Forest lands
with herbicides! The State of Oregon Pesticide Management Plan for Water Quality Protection states “Prevention of
water contamination is a major component of effective resource management.” Many of the herbicides proposed for use
in the control of invasive w**ds are listed in the plan’s appendix B listing “Oregon Pesticides of Interest: potential to
occur at concentrations approaching or exceeding a Federal, State, or Tribal human health or environmental reference
point.” Moreover, it is very challenging to monitor water quality, yet based on the research cited above, it is clear that
herbicides HAVE contaminated our forests and water systems.
I urge you to severely restrict the use of, or ideally avoid using, herbicides in the management of invasive w**ds. Creating
new, more insidious problems in an effort to eliminate an existing problem does not make sense. Thank you for your
consideration.
Sincerely,
Ursula Bechert, DVM, PhD
See letter Submitted by Carol Van Strum
Five Rivers, Oregon 97390
The Forest Service asks for “Preliminary public feedback on invasive w**d management options” for preparation of its
NEPA and NFMA documents:
Siuslaw Integrated Invasive Species Project.pdf....
Yes on 21-177 Artfarm Barn Coast Range Association STOP the SPRAY at Beaver Creek, Oregon North Coast Ecology Network
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