The USFS is coordinating with several electric utility providers to allow the spraying of approximately 900 miles of powerline right of ways across National Forests in Arkansas and Missouri with herbicides. The Utility Right of Way (ROW) Herbicide project raises many concerns, especially for those who live near, within, or, adjacent to our National Forests. This project is also of great concern to the general public who use and enjoy our National Forests for recreation, hunting, and, for gathering edible and medicinal plants and herbs.

1. General Concerns regarding the scoping letter and available documentation:
   The scoping letters were late in being distributed. The scoping letter misleads the public by stating that EPA “approved” herbicides will be used. EPA does NOT approve any herbicides but merely registers them based on manufacturer’s data. The scoping letter estimates that the total coverage area would be around 700 acres, but offers no explanation. Our calculations indicate a total coverage area of over 5000 acres.

2. Herbicide and Mixture Concerns: The only current risk assessments (RA) we are aware of are the 2003 studies for glyphosate and triclopyr. We must therefore assume these are the only current Forest Service approved herbicides and only in the formulations mentioned in this study. There is no risk assessment for the two FS approved herbicides used in a tank mix. The utility plans on using a tank mix of all five herbicides. This is not discussed or covered in either the RA or EIS.
3. Responsible and Ethical Stewardship of Public Lands: The utility’s proposed use of herbicides exhibits a flagrant disregard for the biological sensitivity of species found on our public lands, and, an ignorance of the physiological sensitivity of human health and the environment.
4. Alternatives: No mechanical or hand tool control alternative is proposed. Putting public and environmental health at risk for the sake of allowing utilities to cut costs on line maintenance is irresponsible and unacceptable.
5. Drinking Water: Many residents living in or near the National Forest use shallow drinking wells or springs. Trace levels of herbicides could end up in drinking water for some sensitive individuals, thus causing irreparable harm and damage to human health. The USFS cannot approve a project where this may occur.
6. Caves and Karst: The Ozark National Forest has a significant amount of Karst terrain. Karst areas contain numerous sinkholes, springs and streams that drain into subterranean caverns (i.e., caves). Water (and thus the pollutants carried by water) can enter these groundwater systems rapidly as it passes through cracks and crevices in the ground surface, such as fractures in stream beds (i.e., losing streams), sinkholes, or fractured limestone under thin layers of permeable soils. Groundwater in karst areas can travel as quickly as a few thousand feet to over a mile per day. Degradation of sensitive, underground habitats and the associated groundwater can, therefore, occur rapidly in areas of karst topography. These and other characteristics of karst ecosystems make the underground environment relatively fragile and highly susceptible to human induced perturbation. Many highly specialized and sensitive fish and wildlife species such as bats, amphibians, fish, and crustaceans (e.g., cave crayfish, isopods, amphipods) spend all or a part of their life in these unique and sensitive karst habitats. Federally-listed species that occur in karst habitats of northeastern Oklahoma are the endangered Ozark big-eared bat, gray bat, and Indiana bat, and the threatened Ozark cavefish. The measures most important to conserve listed cave species include 1) obtaining and utilizing knowledge of the cave locations used by the species, 2) limiting human disturbance to occupied caves, and 3) protecting known caves and surrounding foraging areas from habitat loss due to development. Essential information, such as the location of caves used by listed species, is often incomplete, and the extent of karst features in the vicinity of the proposed project may be larger than what is currently known. Undiscovered karst features, such as a cave opening and underground passages, may occur on or near project sites, even in previously developed areas. The US Fish and Wildlife Service recommends the following precautionary measures be taken to avoid impacts to federally-listed and sensitive karst species:
   
   1. Survey the project right-of-way for karst features such as cave openings and sinkholes.
   2. Establish a buffer area of about 300 feet around any caves or sinkholes found during the survey (or during any aspect of project implementation). USFW Service should be contacted for further evaluation to determine if the cave is used by federally-listed or sensitive cave species.
   3. If a cave is used by federally-listed or sensitive species, USFWS may require the cave to be mapped when bats are not present to determine if any additional openings or passages may be affected by the project. In addition, USFWS may recommend modifications of the proposed project to allow additional buffer areas to be established. Incorporation of additional buffer areas may be necessary to avoid impacts to federally-listed or sensitive species.
   4. In the event that holes or other openings are encountered during project activities, no herbicides should be applied near the opening until USFWS or USFS approved personnel have the opportunity to investigate the site thoroughly.
7. Herbicide Drift: Herbicides are known to drift and may harm or kill non target plants or other species that are sensitive, threatened, or endangered.
8. Fragmentation: Killing and or harming plant and animal populations living under or near utility line ROW’s will unnecessarily fragment the forest habitat and may cause irreversible stress to sensitive, threatened, or endangered species.
9. Invasive Species: Killing native species using herbicides will open up large opportunities for invasive, non-native species to proliferate under power line ROW corridors.
10. Maps: The maps associated with the scoping documents are useless for showing what is intended where. There are several different colored lines and symbols, but no map key to explain what anything means. The maps also have virtually no reference points, including labeled roads, counties, towns, or any other useful information to determine accurately where herbicides might be used.
11. Jobs: Power line ROW vegetation can be easily controlled by manual methods. Manual vegetation control requires more labor and thus provides opportunities for local employment in economically challenged communities within the National Forests. The Forest Service needs to look at the economic impacts on communities (particularly the amount of jobs lost) by allowing herbicides to be used in utility ROWs.

SUMMARY

The Forest Service operates under the Forest Service Organic Administration Act of 1897 (among other statutes and laws). The Act provides that “no national forest may be established except to improve and protect the forest, or to secure favorable conditions of water flows”.

Many of the national forest lands being considered for inclusion in this project are part of National Wild and Scenic River watersheds. Section 1271 of the National Wild & Scenic River Act is the Congressional declaration of policy that “certain elected rivers of the Nation which, with their immediate environments shall be protected for the benefit and enjoyment of present and future generations.”, and that a formal policy was needed to, “protect the water quality of such rivers and to fulfill other vital national conservation purposes.”

Since the USFS is officially charged with protecting the water flow and quality on Ozark/St Francis/Mark Twain/Ouachita National Forest lands, this project appears to run contrary to these important conservation practices.
These are just a few of the numerous issues regarding the inherent dangers surrounding herbicide use on our public forests. Given the risk of this project and the number of people and extent of the resource subject to adverse impacts from the project, this project proposal should be withdrawn immediately. The national forest lands in question should be managed specifically to protect water quality, wildlife habitats and dispersed recreational opportunities.