4/21/99
TO: Boulder County Commissioners
FROM: Tim Seastedt
RE: Suggested changes to Boulder County Noxious Weed Management Plan (for public hearing 4/29/99)
Please consider the enclosed proposed changes to the weed management plan. My purpose is to address the need for scientific credibility in the document, as well as address the need for a more open public participation process. I attempt to put the goals of the program in the context of state-of-the-art IPM management, nested within the conceptual framework of ecosystem management. Boulder County citizens recognize the value of County Open Space. This is a world-class commodity. The plans and procedures for the management of these lands should be of equivalent quality. Please note that much of the material for the County Wide Goals was taken from information provided by George Wooten.
Additions to draft document are indicated by insertion of word or phase in Italics. My rationale for the modifications are included below each proposed change.
1) Pg 6, section 3-101
"since certain undesirable plants constitute a potential threat to the....
Rationale: You have no data on the economic or ecological impacts of some of these species in Boulder County.
2) Pg 14, section 5-101
Replace all of sections A, B, and C with the following:
5-101 County Wide Goals
1. Public involvement will be open and welcome during the planning, preparation, and implementation of weed management projects. Education will be an integral part of weed management projects.
2. Goals of proposed projects will be realistic and objectives will be measurable.
3. Proposed projects will provide clear and concise definitions and terms.
4. Weed management projects will be designed in the interests of the general public, without favor to special interests. (For example, weed management's goal on public lands is not to generate cattle forage, unless agreed upon via the hearing process.)
5. Proposed projects will include integration of cultural values with resources.
6. Proposed projects involving the use of pesticides or herbicides will include risk analyses for public health and safety, and thresholds for health and safety tolerance will be publicly available.
7. Proposed projects will describe and analyze the economics of control methods, and projects will describe and analyze costs/benefit ratios.
8. Monitoring will be incorporated in all weed management programs.
B. Integration with Ecosystem Management
1.Managers will describe weed control measures within an ecosystem management framework involving an understanding of the biology, demographics and etiology of weed. The different functional attributes of invading species versus those present in the current or desired system will be identified.
2. Criteria for "damage thresholds" will be established for invading species that activate a process of strategic weed management.
3. Areas in which eradication of certain species may not be feasible will be identified, and goals will be directed toward control strategies rather than eradication in these areas.
4. Areas in which control or containment may not be feasible will be identified, and management will not use funds in these situations until control mechanisms have been established.
5. Use of native species for recovery will be encouraged. However, non-native vegetation in and around non-native habitat (e.g., disturbance corridors such as roads and trails) may be considered.
6. Monitoring will be incorporated in all weed management programs and document responses of the plant community as well as weed response to treatments..
7. (same as proposed B (5)) Work with municipalities and state and federal agencies and other local governments to develop and coordinate integrated management efforts preferably through the use of intergovernmental agreements.
C. Management Criteria for Projects Using Herbicides
1. Decision documents will provide analyses of health and safety risks associated with pesticides, and will do so openly and without bias. Descriptions of potential hazards will be available to the public, and will include discussion and analysis of potential effects (or lack of data) on sensitive individuals and children.
2. Decision documents will describe the affects of proposed treatments on the environment, and will include discussion and analysis of potential effects of herbicides including above- and below-ground transport, breakdown factors, food-web incorporation, nature of targets, synergistic effects, and aquatic effects. If the balance of such effects is completely unknown, herbicide use will be restricted to emergency cases where weed eradication is attainable, and for which other documentation has been completed.
3. Decision documents will include worst-case scenarios including a discussion of potential effects resulting from chemical spills, herbicide drift, off-target contamination, and accidental over-application.
4. Herbicide use on public lands will be rejected for chemicals containing so-called "inert ingredients". Manufactured products containing trade secrets for ingredients have no place on public lands.
5. All areas treated with herbicides will be posted for the duration of pesticide residuals on the site.
6. Monitoring will involve studies of cumulative effects, including the potential for development of herbicide tolerance, chemical buildup, and selective changes in vegetation structure.
D. Preferred Alternatives
1. Preferred alternatives will have clearly stated goals
2. Preferred alternatives will substantially involve the public.
3. Preferred alternatives will be long-term solutions.
4. Preferred alternatives will be economically cost-effective and have clearly stated costs.
5. Preferred alternatives will be specific about dates and times.
6. Preferred alternatives will be site-specific.
7. Preferred alternatives will incorporate effectiveness monitoring.
Rationale: A more comprehensive set of goals are needed that incorporate adequate scientific documentation and public involvement in these public land decisions. The above guidelines are a minimum requirement to assuage public concerns that human health and environmental health issues receive the same weighting in management decisions as do other concerns. Note that these are goals, not absolutes.
Page 15, section B (2)
Delete (2, 3)
Item (4) now becomes (2)
Rationale: The wording, as written, assumes chemical use will be applied in all cases. This is unacceptable.
Suggested new sections:
(G) Pesticide-free transportation corridors will be maintained to city centers and to major medical facilities. Exceptions will require public hearings.
(H) No herbicides will be used within posted school zones.
Rationale: These actions are warranted based on community health needs and concerns.