Control of Invasive Species (2006)

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The first line of defense and the most cost-effective strategy against invasive species is preventing them from invading and becoming established in the first place. Once an infesta- tion becomes well-established, management is expensive and eradication is difficult and unlikely. One of the most important components of prevention is the detection of indi- vidual plants or small groups of plants after seed germina- tion. The second is eradication before they produce seed or develop an established root system. Early detection, as applied to invasive species, is a com- prehensive, integrated system of active or passive surveil- lance to find and verify the identity of new invasive species as early after entry as possible, when eradication and control are still feasible and less costly. It may be targeted at areas where introductions are likely, such as near path- ways of introduction and sensitive ecosystems where impacts are likely to be great or invasion is likely to be rapid (18). After invasive species become established, they often grow deeper root systems and may reproduce by rhi- zomes as well. Control after weeds have gone to seed may begin a long process, because many seeds are viable for years. Control of non-plant species requires equally atten- tive action and may reach out to law enforcement, recre- ational users, and travelers, especially users of aquatic vehicles that may carry infested water from one location to another. Focusing resources on preventing and detecting new invasions, to the extent possible, can be far more cost- effective than containing existing populations. As the National Invasive Species Action Plan notes, “[e]ven the best prevention efforts cannot stop all introductions. Early detection of incipient invasions and quick, coordinated responses are needed to eradicate or contain invasive species before they become too widespread and control becomes technically and/or financially impossible. Popu- lations that are not addressed early may require costly ongoing control efforts.” The remainder of this chapter focuses on Early Detec- tion and Rapid Response (EDRR), planning for invasives control, identification of aspects of operations that spread invasive species, roadside inventory, risk assessment, pri- ority setting, and information management. 12 ASSESSMENT AND MANAGEMENT Management of invasive alien species generally includes: • Initial assessment of the situation; • A process of identifying the species of highest priority for a management program; • Detailed information on methods for eradication, con- tainment, control, and mitigation; • An introduction to monitoring approaches; • Identification of principal approaches to the project; • Activities to secure resources; • Stakeholder commitment and involvement; and • Training in control methods. The first step of a management program is to assess the current situation by determining the management goal, the extent and quality of the area being managed, the invasive tar- get species affecting the area, and the native species threat- ened. The management goal should be the conservation or restoration of intact ecosystems that support the delivery of ecosystem services and cost-effective maintenance of the area. Eradication and control options need to be evaluated on the basis of the likelihood of success, cost-effectiveness, and any potential detrimental impacts. Prioritization of invasive species control projects takes into consideration the extent of the area infested by the species, its impact, the ecological value of habitats invaded, the difficulty of control, and management costs. Species with the highest priority would be those known or suspected to be invasive but still in small numbers, species that can alter ecosystem processes, species that occur in areas of high con- servation value, those imposing or with the potential to impose high costs on the DOT, and those that are likely to be controlled successfully. Eradication, containment, and control are all approaches to management of populations of invasive species. When prevention measures have failed, an eradication program is considered to be the most effective action, because of the opportunity for complete rehabilitation of the site and long- term minimization of costs. Because eradication programs can initially be costly and require full commitment until completion, the feasibility of this approach requires care- ful consideration. Eradication has been achieved using CHAPTER THREE PREVENTION OF ROADSIDE INFESTATIONS

13 mechanical, chemical, and biological control, as well as habitat management. These methods are discussed in detail in chapter four. Identifying Major Pathways and Managing Risk The most common approach for prevention of invasive organisms is to target individual species. A comprehensive approach also targets major pathways that lead to harmful invasions and manages the risks associated with these path- ways. Although some have argued that certain pathways, such as ship ballast water, have already been used for cen- turies, current attention to control is still important. Estab- lishment rates can vary over time. For example, with faster transport times, some invasive species can establish in new environments more easily. Climatic changes and changes in disturbance in the area of introduction (e.g., construction opening new areas of land or salinity and nutrient changes in bays) also affect an area’s susceptibility. Pathways for introduction of invasive species are both intentional and accidental. Most plant and vertebrate species introductions have been intentional; for example, using plants as ornamentals or for erosion control, mam- mals as game, birds for enjoyment, fish for sport fishing. In contrast, most invertebrates (including marine organisms) and microbe introductions have been accidental, frequently attached to other species introduced intentionally. Often agricultural weeds have been introduced as contaminants of crop seeds, whereas most of the environmental weeds were purposefully planted as ornamentals, for soil stabilization, or for firewood. Education is a key component of success- ful prevention and management methods. DOTs, WMAs, and federal agencies have roles in informing the public why prevention measures are taken and what impact failure can cause (19). Identifying Aspects of Department of Transportation Operations That Promote Invasives E.O. 13112 mandates a risk-based approach, including con- sideration of the likelihood that an invasive species will establish and spread, as well as the degree of harm it could cause. To do this, it helps to start with a master list of the DOT’s work activities that may inadvertently promote the spread of an invasive. A risk assessment identifies the most significant issues and helps decide where to focus. A few DOTs are currently identifying infestations on-site for treat- ment before ground disturbance, over multiple years if nec- essary. Increasingly, measures are being taken to conserve valuable topsoil, instead of having it collected and sold by contractors, which leaves deficient soils that are more vul- nerable to infestation by invasive species. DOTs are check- ing and treating permanent water control for West Nile Virus and considering inadvertent creation of such environments as part of current planning processes. Identification of aspects of operations that may affect the environment is a step in the development of a system to man- age environmental impacts, often called an environmental management system (EMS). In an EMS, the transportation agency identifies environmental aspects of its activities, products, or services that it can control and over which it can be expected to have influence to determine those that have had or can have significant impacts on the environment. With respect to invasive species and other environmental impacts, the DOT can then prioritize pathways and controls according to significance, available funding, risk, or any other factors the DOT deems important. Although research has indicated that off-road vehicles are among the largest offenders in the transport of seeds of inva- sive species, construction projects, transportation systems, and roadside maintenance operations can inadvertently spread invasives as well. The following are just a few com- mon mechanisms: • Use of forage mulches that have not been certified weed seed-free mulches and other erosion-control products. • Planting of species now controlled as invasive for erosion- control purposes, including aggressive sweet clovers, alfalfa, smooth brome, trefoil, and perennial rye. • Placement of spoil or importation of topsoil contami- nated with invasives, such as ragweed, thistles, and sweet clovers. • Ill-timed maintenance disturbances such as blading, mowing, ditch dredging, and bare-grounding, which have been known to increase invasives. • Indirect mechanisms such as drainage flows, wind, vehicles, people, and wildlife. • Movement of construction equipment from a weedy site to a non-weedy site, which can transport undesirable seeds (9). DOT earthmoving, erosion control, water quality, wetland restoration, endangered species protection activities, land- scaping, NEPA processes, snow storage, utility line and sign- age placement, volunteers, recovery zone maintenance, and other maintenance and operations activities all affect inva- sive species and native habitats. BMPs are used to reduce the introduction or spread of invasive species. The spread of invasive species caused by substandard vegetation or revegetation and the transport of weed seeds by vehicles are particularly well-documented (2). An Australian study found that approximately half of all cars examined were carrying seeds (3). Exotic species cover and the num- ber of exotic forb species decreased as the distance from roads increased, particularly on certain soil types (nonser- pentine soils in particular) (20).

Most DOTs (26 states, 65% of respondents) are not for- mally identifying aspects of activities that may affect or pro- mote invasive species. Some DOTs reported that they were already “very cognizant of some of the detrimental activities and need to incorporate steps to minimize spread through BMPs.” Nine DOTs (23% of respondents) are explicitly iden- tifying aspects or risk areas. At Arizona and New York State DOTs, at the district level, engineers and supervisors are iden- tifying activities such as mowing, blading, and cut cleaning that will promote or spread invasive species, and devising BMPs to reduce these impacts. New South Wales Roads and Traffic Authority Assessment of Construction, Operation, and Maintenance Activities: Example of Environmental Aspect and Risk Identification The New South Wales, Australia, Roads and Traffic Author- ity (RTA) undertakes environmental impact assessments for its construction, operation, and maintenance activities, in addition to project development. The RTA has committed to addressing environmental aspects in all of its activities and to continuously improving the authority’s environmental performance. The RTA-wide EMS has been a primary vehi- cle for accomplishing this commitment. It “provides a struc- tured management system to achieve and demonstrate our environmental performance” (21). The RTA prepares a Review of Environmental Factors to identify and consider environmental impacts, which may prompt development and/or implementation measures to address them. Standard maintenance activities are assessed on a regular basis, usually annually (22). Other maintenance activities are assessed in a way similar to that of construction activities (23). For maintenance by contract, requirements for environmental impact assessment are incorporated in contract requirements and reviewed by the RTA (24). The New South Wales RTA uses tables to summarize construction and maintenance activ- ities and associated environmental aspects and impacts. Activities entailing ground disturbance or use of vehicles and equipment off the roadway have been particularly identified as potentially causing the spread of invasive species. Risk Assessment A risk assessment process assesses species based on their per- ceived risk and potential impact. The objective of the assess- ment is to predict whether or not a species is likely to become established and be invasive and to generate a relative ranking of risk. Entire pathways may also be analyzed for risk. This may be a more efficient procedure where many possible species and vectors are involved. Although the lack of knowl- edge and ability to predict consequences may lead to sub- stantial reliance on assumptions, risk assessment provides a logical process for gathering, analyzing, synthesizing, com- paring, and communicating information, which can improve the quality of decision making (25). 14 Processes for setting priorities often incorporate risk assessment. One such process is reviewed later in this chap- ter. Other risk assessment resources include: • Committee on Environment and Natural Resources, National Science and Technology Council, Ecological Risk Assessment in the Federal Government (26). • Commission of the European Communities, Communi- cation on the Precautionary Principle (27). • National Research Council, Risk Assessment in the Fed- eral Government: Managing the Process (28). PLANNING FOR INVASIVES CONTROL Once a DOT maintenance staff has determined the problem, it can more easily identify priorities in addressing target species. Such priorities may be determined through a risk assessment, as discussed earlier, after which action plans may be devel- oped. After locating and recording undesirable vegetation on a map, prioritizing sites, and making a realistic assessment of resources to address invasives, a DOT can more readily develop plans, policies, and standards to execute the work. Fourteen DOTs (35% of respondents) are linking identi- fied locations of invasive species infestation to treatment plans. This occurs in a variety of ways, from highly informal to formal plans. Florida DOT (FDOT) is identifying loca- tions of its two top priority invasive species for treatment planning. At the Arkansas State Highway and Transportation Department (Arkansas Highways), maintenance area per- sonnel identified Johnsongrass for spot control efforts in the course of its other work. Kansas DOT also identifies loca- tions for spot treatment, although on a limited basis. MoDOT tracks and treats sites at the district level, whereas Nevada DOT (NDOT) tracks infestations in stormwater drainage basins and wetland mitigation sites only. At the Wisconsin DOT (WisDOT), district maintenance supervisors work with the county maintenance patrolmen, who are familiar with locations, to develop the annual treatment program, based on county personnel knowledge and experience rather than mapping. In general, these informal systems are handled by DOT regions, districts, or maintenance shops. Continuous improvement can be accomplished through a variety of means. An EMS encourages a cycle of goal-setting (PLAN), implementing actions (DO), and reevaluation (CHECK and ACT) to achieve continuous improvement with regard to environmental objectives. Although an EMS or EMS-style IVM program explicitly seeks to evaluate pro- cedures, strategies, and implementation for continuous im- provement, DOTs use other mechanisms as well. General quality assurance reviews on each district and one of the main- tenance areas that FDOT and many DOTs employ, document findings and areas for improvement, which may include inva- sive species control. Texas DOT (TxDOT) is among those DOTs that are documenting all treatment procedures, but still

15 working on including feedback and effectiveness information. The statewide consistent pesticide application recordkeeping system that Minnesota DOT (Mn/DOT) and the University of Minnesota are developing for pesticide use and that target species and situations (Canada thistle, guardrails, etc.) is expected to provide data for decision support for continuous improvement, as well. The Adirondack Park Invasive Plant Program (APIPP) and Washington State DOT (WSDOT) have information management and decision support components of their system, as treatment areas are tracked and effectiveness information is gathered. Further information on decision sup- port systems can be found later in this chapter. Ten DOTs (25% of respondents) revise treatment plans and reallocate resources if necessary and develop systems to doc- ument treatment and continually improve coverage. An EMS can help agencies document effectiveness and make the case for additional resources. Because Wyoming DOT (WYDOT) contracts out invasive species control to the state DOA, the state maintenance engineer receives annual reports showing treated areas, cost overruns and underruns, and percentage of ROWs reviewed. It also indicates any problems that were encountered in the program for that year. If there are issues or concerns, these are discussed and addressed with the Wyoming DOA. Wyoming DOA will reallocate statewide funding for the WYDOT noxious weed program if needed. Other states may modify allocations based on district feedback (MoDOT) or on a district-by-district or district-maintenance- area basis (Mn/DOT). Greater flexibility for reallocation is available with a statewide program, with centrally responsible personnel and dedicated funding specifically for control of invasive species (Arkansas Highways). In some cases, treat- ment procedures may be refined on a central level, with real- location of resources continuing on the district level (TxDOT). Oregon DOT indicated that it attempts to direct any remaining maintenance dollars at the end of budget bienniums to supple- mental herbicide purchases. INTEGRATED ROADSIDE VEGETATION MANAGEMENT IVM or IRVM can be considered an outgrowth and subset of Integrated Pest Management (IPM) that has evolved from pest management in agriculture and forestry over the past 30 to 40 years. During that period, pest management evolved from the use of a single control method targeted at a specific pest or group of pests on a crop to an increasingly holistic approach. The development of the concept of IPM was likely the first and largest step, when it was recognized that different pest control methods could be used in combination to achieve the desired pest control and that this desired level of control was within acceptable thresholds, not simply the lowest pest population that could be achieved. Subsequently, workers in the field went on to recognize that pest management should deal with all of the pests affecting a crop in an integrated manner; that is, solv- ing the problem of one pest may simply generate new and often worse problems with other pests. Finally, awareness has been increasing of the costs of chemical pesticides to people and the environment. The conventional wisdom of IPM in agriculture has been that although the broad outline of an IPM system can be prescribed, the local variation in these factors means that the detailed program will end up being location- specific, evolving over time. IVM or IRVM parallels IPM. IVM or IRVM encourage sta- ble self-sustaining vegetation with limited use of mowing, her- bicides, tree removal, and other methods as necessary. Because no single tactic can solve a current weed problem or prevent future infestations, IVM encourages managers to combine several treatment methods into an integrated weed management program tailored to the site and resources avail- able. In addition, an invasive species management program benefits from communication and cooperation among the many individuals and agencies involved in management of the problem. These integrated methods focus on the ultimate goal, which for DOTs may be preservation or the increase of indige- nous biodiversity in the conservation area being managed, as well as management of overall maintenance costs. Planning helps achieve these ends and considers the range of control options. The process of control can be compli- cated, involving several different tactics in combination or in sequence, or it may be that at its simplest just one method applied using a simple decision rule can suffice to achieve the objective required. For example, for woody invaders, cut- ting is frequently combined with chemical control to the stump. Control of purple loosestrife may involve biological control, mechanical removal, and other methods. Considera- tion of the environmental impacts of control actions requires that environmentally sound methods be available and judi- ciously deployed, especially in highly vulnerable areas. IVM has been described as a decision-making and management process that uses knowledge from a broad base of expertise, a combination of treatment methods, and a monitoring and evaluation system to achieve vegetation management goals. An overview of common IRVM or IVM steps is included as Appendix D. Model DOT IVM or IRVM planning efforts are described in the following section. Iowa Department of Transportation’s Integrated Roadside Vegetation Management Iowa DOT was an early leader in the implementation of IRVM, which the agency understood as simply using the most cost-effective and ecologically sound method of man- agement on a site-by-site basis. The approach was based on the following principles (9). • Nature does not allow bare soils to exist. • Bare soils are revegetated by successions of plant groups until a most-fit community of plants develops. • Disturbance of the vegetative cover reverses the suc- cession of revegetation back to the bare soil starting point and therefore allows more invasions.

Iowa DOT defines IRVM as a long-term approach to veg- etation management that (29): • Systematically evaluates each area to be managed; • Determines which plant communities best fit the area; • Develops procedures that will encourage, enhance, or reestablish desirable plant communities; • Provides self-sustaining, diversified, visually interesting vegetation; • Keeps safety and an improved environment as priori- ties; and • Utilizes the most beneficial methods to prevent or cor- rect undesirable situations caused by disturbance or less than optimum vegetative ground cover. The Iowa DOT’s IRVM plan is brief and general, allow- ing for adaptation by counties. The agency defines the prime purpose of roadside vegetation as holding soil in place with- out creating hazards. At the same time, it would like to address other desirable uses for roadside vegetation (aes- thetic, economic, and environmental) once safety and func- tional requirements are met. The goals of the Iowa DOT’s Integrated Roadside Management Plan are to: • Preserve and provide safe, functional, and environ- mentally improved corridors of travel throughout the state. • Utilize a long-term integrated management program that promotes desirable self-sustaining plant communi- ties and encourage those plant communities that are native to Iowa through preservation and reestablish- ment whenever practical. • Bring about considerable reduction and possible elimi- nation of the use of chemicals as a control method of undesirable plants. • Enhance the scenic qualities of the roadsides and their value as wildlife habitat. To achieve these goals, Iowa DOT outlined the following procedures, which follow a PLAN-DO-CHECK-ACT (EMS- type) process as follows: • Inventory the sites to be managed. • List the existing areas of desirable vegetation, as well as those that need improvement. • Determine the appropriate management methods needed. • Determine the best time to implement management procedures and ensure that they are accomplished at that time. Temporary procedures may be needed to preserve an area before permanent procedures can be used. • Evaluate the results periodically. • Take further measures if necessary. The emphasis on weed eradication rather than weed prevention has led to increased mapping of vegetation, 16 statewide planning, and new maintenance and construction practices. Iowa DOT and the Iowa State Legislature have supported establishment of an IRVM center at the Univer- sity of Northern Iowa, which has produced resources of value to several state DOTs. Minnesota Department of Transportation Process for Integrated Roadside Vegetation Management Planning Mn/DOT’s process for IRVM planning is detailed in the Minnesota Best Practices on Roadside Vegetation Manage- ment and summarized here (30). Preliminary Planning, Categorization, and Goals • A local plan adapted to fit local culture, political con- cerns, and climate and environmental conditions is best. • Plan development should be a team effort, with input from those people having expertise in landscape archi- tecture, maintenance, design, construction, biology, horticulture, utilities, and public relations, as well as from general citizens. A steering committee responsi- ble for developing the plan, providing guidance on how it is run, and reviewing the annual work plan and progress may also be created. – Before plan development, the agency should identify the roadways it is responsible for maintaining and prioritize them according to the level of management they will receive. – When developing the plan and considering mainte- nance strategies, keep the following guidelines in mind: (1) timing is an important factor for all control and maintenance methods, (2) programs should be kept flexible to allow for changes as needed, (3) a combination of several control methods is usually more effective than any single treatment, and (4) maintenance costs are lowest when programs are planned and completed on schedule. • Also identify the desired outcome for a given feature. For example, is the objective to have low maintenance, return the roadside to prairie grasses, maintain golf- course-like sod, or reestablish a wetland? Assessing Existing Conditions Assess existing conditions to assign and prioritize manage- ment strategies for an area. Three factors that will direct man- agement techniques are soil, topography, and vegetation. • Soil—Understanding the types of soils present and their physical characteristics is important when outlining a plan for roadside vegetation management. Soil type and texture determine vegetation selection, herbicide appli- cation rates, fertilization needs, and erosion potential.

17 Once known, management techniques should be tar- geted to those conditions. The ideal surface soil is com- posed of 5% organic matter, 25% air, 45% mineral material, and 25% water. The organic material provides fertility and water-holding capacity and supports micro- bial life. Oxygen is required for all root growth. Along roadsides, soil is typically stripped of its nutrients and compacted such that little air remains in the soil, leaving a very hostile environment for vegetation to flourish. When trouble shooting to determine causes of vegetation problems, assessing the soils in an area, especially for excess nitrogen, may explain excessive weed growth or resistance to chemical control methods. • Soil health—Healthy soil is a critical element for estab- lishing a healthy roadside environment. Even the most appropriate and useful tools for managing roadside vege- tation may not work if the soil lacks nutrients to support the targeted vegetation. To improve unhealthy soil, try fertilizer, compost, aeration, or deep scarification to incor- porate oxygen into the soil. If improving soil health is not possible, choose appropriate vegetation of a type that does not need high nutrient soils to flourish for establishment in that area. One way to assess the health of the soil is to send a sample to the state Extension Service Office for analysis and recommendations on the appropriate type and application rate for any necessary fertilizer. • Soil considerations for herbicide use—Use lower appli- cation rates for coarse-grained soils and higher rates for fine-grained soils or soils high in organic material. Before application, learn the potential for herbicide runoff. • Native vegetation—There are three main reasons for preserving native plants: – Environmental—There are no substitutes for the orig- inal wild species of individual states. Once lost, their genetic material can never be recreated. In addition, native wildlife often depends on native vegetation for survival. – Economic—Native plant communities are relatively stable and require little maintenance. Natural com- munities provide good erosion control and are less susceptible to weed invasions. – Aesthetic—Native wildflowers and grasses provide seasonal color changes along roadsides, a natural beautification. They also screen undesirable views and objects if planted strategically. Developing a Plan After the steering committee or appropriate personnel have been assembled and roadside areas have been categorized, Mn/DOT suggests that an IRVM plan be written, following these steps (30): • Develop a vision or mission statement—Such a vision statement is a picture of a road 10 to 20 years in the future. It includes the highest aspirations for what the roadside can become and serves as a source of motiva- tion for all those involved in the process. A mission statement is broad and outlines the ultimate reason for the program’s existence. • Collect pertinent data, such as costs, vegetation (exist- ing and desired), available personnel, and resources— This step includes reviewing records of current mainte- nance operations and taking an inventory of current roadside vegetation conditions. • Establish goals and objectives—When doing so, con- sider the following basic principles: – Safety for the traveling public and maintenance staff, – Maintenance of the infrastructure and highway integrity, – Cost-effective use of public resources, – Environmentally sound decision making, and – Needs and concerns of adjacent landowners and the traveling public. • Analyze and prioritize goals and objectives—Identify which goals are most important. This allows problem areas to be dealt with first, making other goals and objectives easier to reach. • Assign duties and responsibilities for each program participant—With input from those staff members who will be responsible for plan implementation, assign duties and responsibilities. • Plan for budget considerations—Identify costs con- nected with implementing each plan element, as well as ways to deal with budget constraints. This may include planning for equipment purchases and staff needs and increasing the efficiency of existing operations. • Provide an opportunity for research and innovation— Note research opportunities that may result in innova- tions for improving quality, reducing costs, and improving working conditions for maintenance staff. • Provide evaluation criteria—This may be the most important element of the IRVM plan. It is critical that some benchmark be developed to measure program success. Meet and document short-term goals and objectives. Maintain records of implementation activi- ties over time to evaluate overall direction and accom- plishments. Periodically evaluate the plan to determine if it is advancing and if it has reasonable and attainable goals and objectives. Make changes as needed. Implementing the Plan Mn/DOT recommends the following steps to implement the IRVM plan (30). • Identify appropriate methods and applications for con- trol. This could include mechanical methods, such as mowing and aeration; biological or natural processes; cultural methods, such as appropriate seed selection, planting and mulching, or burning; chemical methods, such as the use of herbicides and pesticides; a hands-off approach; or preservation and conservation.

• Train all staff responsible for implementing each ele- ment of the IRVM plan with regard to the plan compo- nents and responsibilities. This is especially important for those staff members who will be completing the actual maintenance. • Keep records of maintenance activities. This includes information about the type of control used, conditions under which it was applied, and general management information. Information about the control method in- cludes weather, application area limits, time of appli- cation, concentration, and quantity of any chemicals applied. For general management purposes, hours, per- sonnel, equipment, and costs are needed to set priorities, evaluate cost-effectiveness, and budget time and money for future activities. A complete and continuously up- dated location map, indicating control activities and dates of application, is recommended. This can be integrated with a GIS to automate the record-keeping process. • Regularly evaluate the program to measure the success of an IRVM plan. This may include tracking the num- ber of citizen complaints received before and after plan implementation, cost reductions for certain mainte- nance activities, and allocation of staff time. Evaluate the effectiveness and success of plan elements and make changes as necessary. New York State’s Six-Step Approach to Integrated Vegetation Management Planning and Implementation In New York State, IVM has been used on powerline corridors for more than 20 years, where a focus on culturing desirable plant communities that minimize the presence of undesirable plants has reduced treatment needs and herbicide use by more than half during that period (31, p. v). Nowak and Ballard’s work with the utility industry and NYSDOT has involved a six-step approach to IVM that provides a framework for com- municating, organizing, and conducting an IVM program (32). The following step-wise system is summarized and adapted from Nowak and Ballard’s work for the utility industry and U.S. Environmental Protection Agency (EPA) (32). It closely parallels that of the Integrated Pest Management Practitioners Association, described earlier. Step 1: Understand pest and ecosystem dynamics—A first step to conducting IVM is to develop a working knowledge of the organisms in the managed system and how they inter- act with each other and the environment, with or without veg- etation management, to produce ecosystem conditions. It is important to identify and understand: • Species life histories (reproduction, growth, and lon- gevity), plant strategies, and responses to disturbance. • Plant succession, changes in distribution, and abun- dance of plants through time and space. • How plants and communities can be manipulated to control the rate and direction of plant succession through interference, grazing, and other mechanisms. 18 Step 2: Set management objectives and tolerance levels— Tolerance levels are specific descriptions of vegetation conditions—individual plant and plant community size, abun- dance, and composition—that, if exceeded, trigger a need to intervene. Undesirable species are not treated unless they exceed the critical threshold. Well-defined thresholds are a critical element of IVM (33,34) that can be useful in com- municating management needs to various stakeholders; for example, thresholds and tolerance levels can be used to demonstrate the cyclic nature of vegetation dynamics, which supports a need to control vegetation on a regular basis. Stakeholders include vegetation management professionals responsible for management decisions on a particular ROW, landowners of the ROW or adjacent properties, governmen- tal regulators responsible for administering state and federal policies and laws, and nongovernmental organizations with a general concern for the environment. Step 3: Compile treatment options—Different treatment options may be needed to match variable environmental and site conditions, concerns, and interests on a ROW. Vegeta- tion treatments can be grouped into categories, such as mechanical, chemical, cultural, physical, biological, and ecological; however, IVM does focus on integrating biolog- ical and ecological control into all treatment schemes. Creation of stable, low-growing plant communities is the long-term objective, and biological and ecological control produces a long-term reduction in treatment efforts and a reduction in herbicide use (35,36). Step 4: Account for economic and environmental effects of treatments—Economic and environmental considera- tions factor into the choice of treatment. Cost-effectiveness may be used as a measure of the success of a treatment in terms of economics, plant community dynamics, and related environmental considerations (37,38). Direct costs include labor, equipment, and materials to treat ROW vegetation, whereas indirect costs include the loss of values or services that can result from a treatment. The latter are often associ- ated with water quality, pollution, wildlife habitat, and aes- thetics, or other ways that the environment can be degraded. Effectiveness pertains to production of desired vegetation conditions and associated benefits and values with operation and management of the transportation corridor in the public interest, taking environmental interests and values into account. Cost-effectiveness timeframes may be short or long term, and often efforts must be made to balance short-term savings with long-term costs. For example, it may be mon- etarily less costly to mow an ROW today when compared with the use of herbicides, but mowing may produce higher costs over the long-term, because of short-term control of vegetation conditions and shorter treatment cycles than can be achieved with other treatments (39,40). IVM is used to maximize cost-effectiveness of management efforts, mini- mizing costs while creating the desired vegetation condi- tions and associated positive values associated with these conditions over the long term.

19 Step 5: Develop site-specific treatment plans—After developing a suite of treatment options (Steps 2, 3, and 4), and weighing the effects of those treatments on long-term production of vegetation conditions and associated benefits and values, a treatment is chosen by the professional vegeta- tion manager. Prescriptions should not be written for entire ROWs, but should instead be developed for specific sections of any one ROW and the constraints therein. It is important to base treatment choices on inventory and analysis of exist- ing site and vegetation conditions (41), particularly because these data will be critical in monitoring outcomes of treat- ments, as outlined in Step 6. Prescriptions for different areas and circumstances of vegetation management should include: • Desired future conditions of the ROW area to be treated and • Description of the treatment as a function of current vegetation conditions and justification of treatments, considering ecological, socioeconomic, and adminis- trative or fiscal factors (42,43). Treatment recommen- dations are the crucial part of the prescription. Step 6: Monitor outcomes and revise and adapt manage- ment plans—Adaptive management incorporates learning from experience (44). Monitoring of the effects and perfor- mance of various treatments may include: • Amount of materials used in treatment, • Treatment costs, and • Vegetation conditions before and after treatment (e.g., quantification of changes in noxious weed cover). In addition to vegetative community changes, herbicide residuals with chemical treatments, water quality, and wildlife populations can also be monitored and fed into the next round of treatment planning and decision making. Vegetation conditions are compared with the desired con- dition set during Step 2, and described in prescriptions during Step 5. Any disparities between “desired” and “achieved” results are investigated, and future treatment options adjusted accordingly. Monitoring ensures that treatment effects are gauged and shortfalls corrected by improving management schemes to better accomplish management objectives. To What Extent Are You Implementing IVM: A Self-Evaluation Nowak and Ballard pose a series of questions that mainte- nance managers may use to self-evaluate their current approach to vegetation management and identify gaps between current systems and the integrated approach pre- sented earlier. Numbers correspond to the steps presented previously (32). 1. Do you have a detailed, basic knowledge of the man- aged ecosystems? 2a. Do you actively involve stakeholders in vegetation management decisions? 2b. Do you consider tolerance levels when determining the need to treat vegetation (positive approach) or do you take a rote approach and treat vegetation only routinely (negative approach)? 2c. Are you proactive in vegetation management (e.g., treat vegetation in concert with tolerance levels, with decisions based on inventory and planning) or reactive (e.g., “hot spotting,” where vegetation is treated after thresholds are soon to be, or already, exceeded)? 3a. Do you maintain a broad range of vegetation treatments—mechanical, chemical, cultural, and biological—in your “toolbox,” and apply a variety of treatments depending on the site and vegetation conditions? 3b. Do you foster the use of biological and ecological controls to prevent pest populations from building past economic thresholds? 4. Do you use broad considerations of cost-effectiveness in selecting a treatment for a specific site? 5. Do you prescribe treatments in a site-specific man- ner, based on a contemporary inventory of ROW resources? 6. Do you monitor the results of treatments to com- pare actual conditions with desired future condi- tions and look to improve the system based on that comparison? In 2003, NYSDOT developed the following 10-point invasive transportation vegetation management plan: 1. Develop a prioritized list of threatening flora or fauna based on regional environments. 2. Use field and GIS mapping of existing invasive populations. 3. Integrate invasive species identification and analysis as part of the department’s normal NEPA/SEQR (State Environmental Quality Review Act) processing. 4. Evaluate potential impacts caused by construction or maintenance activities. 5. Develop preventive BMPs. 6. Test, execute, and evaluate eradication measures. 7. Review and update annually the vegetation manage- ment plans. 8. As innovative design solutions progress, opportuni- ties for the introduction or spread of invasive species are reduced. 9. Promote a climate of interagency cooperation and sharing of coordinated research with public and private sectors. 10. Increase employee and public knowledge through outreach training of the effects of invasive species to the users (45).

NYSDOT’s Draft “Metric for Assessing Performance of Integrated Vegetation Management on Rights-of-Way” As part of NYSDOT’s evaluation of their current vegeta- tion management program and the agency’s Alternatives to Herbicide program, NYSDOT is developing a system- atic framework and research protocol for identification, evaluation, and implementation of environmentally sensi- tive, lower maintenance, and cost-effective vegetation management techniques that can be integrated into the overall vegetation management program (L. Greninger, personal communication, June 1, 2004). To assist NYS- DOT in this effort the State University of New York developed the draft “Metric for Assessing Performance of Integrated Vegetation Management on Rights-of-Way” (46). Assessments include interdisciplinary field meetings and interviews with staff; visits to a representative sample of roadsides; and review of standard operating practices, vegetation conditions, field performances, site challenges, and vegetation management innovations. A report was developed that presents findings and recommendations associated with each principle and criteria. Each principle will have highlighted strengths and weaknesses and sets of commendations for successes and recommendations for program improvement. RESOURCES FOR INTEGRATED VEGETATION MANAGEMENT PLANNING Appendix D includes detailed information on Integrated Vegetation Management Planning. The interagency gateway to invasive species control programs and tools, on the Inter- net, has a list of management plans that have been developed in each state and by each species. Decision support tools are also available. Readers can reach each of these sites at www.invasivespecies.gov. Other resources for IVM planning can be found in refer- ences 47–52. SETTING PRIORITIES DOTs set priorities in an attempt to minimize the total, long- term workload, and hence the cost of an operation in terms of money, resources, and opportunities. Therefore, invasive species control activities may be focused on the prevention of new infestations and on existing infestations that are the fastest growing, most disruptive, and affect the most highly valued or costly to maintain areas. Also considered is the dif- ficulty of achieving satisfactory control; giving higher prior- ity to infestations the DOT believes to be the most amenable to control with available technology and resources. A detailed priority-setting system for weeds is presented in the Handbook for Ranking Exotic Plants for Management and Control (53). 20 The priority-setting process can be difficult, owing to the need to consider multiple factors. It may be helpful to group these factors into four categories as a filter to identify the worst invasives. This process is recommended by the Global Invasive Species Programme (54): 1. Current and potential extent of the species on or near the site (primary consideration). Priorities are assigned to species to first, prevent the establishment of new invasive species; second, eliminate small, rapidly growing infestations; third, prevent large infestations from expanding; and fourth, reduce or eliminate large infestations. Priorities should be assigned in the fol- lowing sequence: – Species not yet on the site but which are present nearby. Pay special attention to species known to be pests elsewhere in the region. – Species present on the site as new populations or outliers of larger infestations, especially if they are expanding rapidly. – Species present on the site in large infestations that continue to expand. – Species present on the site in large infestations that are not expanding. 2. Current and potential impacts of the species. The order of priorities under this category is based on the man- agement goals for your site; however, the following order of consideration may be helpful: – Species that alter ecosystem processes such as fire fre- quency, sedimentation, nutrient cycling, or other ecosystem processes. These are species that “change the rules of the game,” often altering conditions so rad- ically that few native plants and animals can persist. – Species that kill, parasitize, hybridize, or out- compete natives and dominate otherwise undis- turbed native communities. – Species that do not out-compete dominant natives but prevent or depress recruitment or regeneration of native species, reduce or eliminate resources (e.g., food, cover, and nesting sites) used by native animals, promote populations of invasive non- native animals by providing them with resources otherwise unavailable in the area, or significantly increase seed distribution of non-native plants or enhance non-native plants in some other way. – Species that overtake and exclude native species fol- lowing natural disturbances such as fires, floods, or hurricanes, thereby altering natural succession, or creating situations that hinder restoration of natural communities. In areas of repeated disturbances, DOTs may want to elevate the importance of this category. 3. Value of the habitats/areas that the species infests or may infest. Priorities may be assigned in the following order: – Infestations that occur in the most highly valued habitats or areas, especially areas that contain rare

21 or highly valued species or communities and areas that provide vital resources. – Infestations that occur in less highly valued areas. Areas already badly infested with other pests may be given low priority unless the species in question will make the situation significantly worse. 4. Difficulty of control and establishing replacement species. Priorities may be assigned in the following order: – Species likely to be controlled or eradicated with avail- able technology and resources and which desirable native species will replace with little further input. – Species likely to be controlled but that will not be replaced by desirable natives without an active restoration program requiring substantial resources. – Species difficult to control with available technology and resources and/or whose control will likely result in substantial damage to other, desirable species and/or enhance other nonindigenous species. – Species unlikely to be controlled with available technology and resources. Species can be ranked numerically (1, 2, 3, . . ., n) or by classifying invasive groups by worst, moderate, and minor. Invasive species whose populations are decreasing or those that colonize only disturbed areas and do not move into (relatively) undisturbed habitats or affect recovery from the disturbance can be assigned the lowest priorities. Other tools and organizations are readily available to assist DOTs in prioritizing invasive species to target. NatureServe is an independent, nonprofit organization providing scientific information and technology, affiliated with the state Natural Heritage Programs (NHPs). NHPs are often located at state universities and provide support to other government agencies as well as The Nature Conservancy. NatureServe developed an Invasive Species Assessment Protocol, in cooperation with The Nature Conservancy and the National Park Service. The criteria develop Invasive Species Impact Ranks (I-Ranks) at the national and state level. Assessment criteria include Eco- logical Impact, Current Distribution and Abundance, Trends in Distribution and Abundance, and Management Difficulty. Species ranked high present a severe threat to native species and ecological communities. Using this new assessment methodology, NatureServe plans to evaluate at the U.S. national level all of the estimated 3,500 non-native vascular plant species established outside cultivation in the United States. That work is expected to assist land managers in prioritizing their work and to support decision making related to prevention, monitoring, manage- ment, research, and identifying conservation and preserva- tion areas. FHWA and other federal agencies contributed to the development of this system. Ultimately, the system will: • Allow management of data through the NHPs’ network, using its software, Biotics, and providing access to data through a website. • Link non-native species to ecological systems. • Develop more invasive species management information. • Encourage growth of an EDRR pilot project. • Model potential sites for non-native invasions. • Identify invasions that are critical to regional biodiver- sity resources. PREVENTION Prevention involves attention to the most common vectors of transmission, including contaminated seed, mulch, or soils; movement of unlearned equipment or machinery from an invasive weed-contaminated area to a noncontaminated area; and a lack of restoration or revegetation after construction. Prevention depends on limiting the introduction of new weeds through: • Minimizing the disturbance of desirable plants and soils. • Maintaining desired plant communities through good management. • Monitoring high-risk areas such as transportation corri- dors and bare ground. • Revegetating disturbed sites with desired plants. • Evaluating the effectiveness of prevention efforts and adapting plans for the following year. • Early detection and eradication of small patches of weeds through regulatory inventory and corrective action. Early detection consists of identifying and documenting the newly introduced invasive weed species in an area. Then, rapid response may be employed to eradicate new infesta- tions and methods may be taken to prevent movement to non- infested areas. Some prevention practices are presented in greater detail in the section of this document on Cultural Control Methods. Early detection of incipient invasions and quick coordi- nated responses are needed to eradicate or contain invasive species before they become too widespread and control becomes technically and/or financially impossible. Popu- lations that are not addressed early may require costly ongoing control efforts. For example, spotted knapweed (Centaurea biebersteinii) was introduced to Montana in the 1920s, and by 1988 had infested more than 4.7 million acres. The economic impact is approximately $42 million annually (55). Eradication Eradication is the elimination of the entire population of an alien species, including any resting stages, in the managed area. Efforts at eradication often follow failure to prevent introduction

of invasive species on construction and other vulnerable sites. Eradication as a rapid response to an early detection of a nonindigenous species is often the key to a successful and cost- effective solution. Once invasive species have spread, eradica- tion becomes much more difficult and costly, to the point of being infeasible in many circumstances. Feasibility should be assessed before attempting eradication. Successful eradication programs in the past have been based on: • Mechanical control—for example, hand-picking of snails and hand-pulling of weeds. Plants are often best eradicated by a combination of mechanical and chemi- cal treatments. • Chemical control—for example, using toxic baits against vertebrates and spraying insecticides against insect pests. • Biopesticides—for example, Bacillus thuringiensis sprayed against insect pests. • Sterile male releases—usually combined with chemical control. • Physical habitat management controls—for example, grazing and prescribed burning. • Hunting of invasive vertebrates. If an eradication program is feasible, it is the preferred choice for action against an invasive nonindigenous species. Eradication has the advantage of long-term con- trol; no long-term costs outside of follow-up monitoring and prevention measures and the opportunity for restoration of pre-invasion conditions. However, eradication requires adequate funding and commitment from the stakeholders involved. Well-established populations and large areas of infestation may be unsuitable for eradication programs and may have unintended side effects in addition to very high cost. For example, in the case of the attempt to eradicate South American fire ants in southern states, the insecticide initially was ingested by wildlife and cattle. The ant bait subsequently developed also had non-target effects and proved to be more effective against native ant species than the intruder, ultimately enhancing the populations of the nonindigenous species as a result of a decrease of interspe- cific competition with the native ant species (56). Eradication (or control) of well-established, nonindigenous species that have become a major element of the ecosystem will influence the entire ecosystem. Predicting the conse- quences of the successful elimination of such species, includ- ing the synergistic effects of the invasive species to indigenous and nonindigenous species can be difficult, but such efforts are important for avoiding unexpected problems. Cases have been reported where one invasive species replaces another, follow- ing an effort to eradicate the primary target. Successful eradication programs tend to involve: • Small, geographically limited populations of non- indigenous species that are the easiest to eliminate. 22 Therefore, immediate eradication is the preferred option for most species found in early detection sur- veys. It is crucial that the early warning program has funds available for these actions. • Situations where eradication is considered feasible and adequate support from stakeholders must be present. This is easier to achieve on construction sites with exist- ing contracts or on other land over which the DOT has control. • Instances where sufficient funding is secured for an intensive program (allowing for contingencies) to make sure that eradication can be pursued until the last indi- vidual is removed. Expectations must be realistic in terms of the processes required for successful eradica- tion programs; for example, low visible returns for high investments late in the program. • Occasions when immigration of the alien species is zero, something DOTs and contractors can help achieve through vehicle washing and weed seed-free mulch requirements. Potential pathways for the species between infested areas and the management area must be controlled to prevent new invasions. • Situations where all individuals of the species popula- tion are susceptible to the eradication technique. • Effective team management and motivation. Team- work is required to achieve an eradication success, with a core of field and research expertise to maximize effi- ciency and help maintain administrative support. • A technique to monitor the species at very low densi- ties, at the end of the program, to be designed to ensure detection of the last survivors. Organisms that have less obvious stages and that can survive for long peri- ods; for example, seed banks of weeds need a moni- toring period to make sure that eradication has been achieved. • Methods to minimize the chances of reinvasion and early detection of the eradicated species should it reestablish a need to be in place. The development and use of field methods is usually an iterative process because implementation needs to be moni- tored and methods may need to be adapted as conditions change and eradication is approached. Containment Containment of nonindigenous invasive species is a special form of control. The aim is to restrict the spread of an alien species and to contain the population within a defined geo- graphical range. The methods used for containment are the same as those described for prevention, eradication, and con- trol. Containment programs also need to be designed with clearly defined goals: barriers beyond which the invasive species should not spread, habitats that are not to be colo- nized and invaded, etc. To establish these parameters, a clear understanding of why the containment is being done in the

23 first place is necessary; for example, to protect particular areas or habitats from invasion or to allow time to mobilize other control or eradication measures. An important component of a containment program is its ability to rapidly detect new infestations of the invasive species both spreading from the margins of its distribution or in completely new areas, so that control measures can be implemented in as timely a manner as possible. Because these new infestations will initially be at very low densities, early detection can be challenging. The invasive species pop- ulation is suppressed using a variety of methods along the border of the defined area of containment; individuals and colonies spreading beyond this area are eradicated and intro- ductions into areas outside the defined containment area are prevented. A species most likely to be successfully contained in a defined area is one that spreads slowly over short distances. The nearest suitable habitat for the species should preferably be separated by a natural barrier or an effective artificial bar- rier. The most suitable cases for containment are habitat islands without suitable connections that would allow the easy spread of invasive species. The spread of alien fresh- water species between different parts of watersheds is a good example where containment may be possible. If containment of an invasive species in a well-defined area is successful, habitats and native species are safeguarded against the impacts caused by the harmful alien species out- side this area. In cases where eradication is not feasible and the range of the invasive species is restricted in a rather iso- lated area, containment of the species in that area can be highly effective in saving other parts even if the species is harmful in the containment area. Containing a species in a defined area will, however, need constant attention and con- trol of the species at the border. The chances for successful containment of invasive species are relatively good for species living in freshwater habitats; for example, fish spread limited to specific water catchment areas, unless human activities such as artificial canals connect catchment areas and allow alien species to spread between systems. A related but different approach is exclusion, which aims to protect a sensitive area against invasive species by keeping them out. This method often combines eradication, prevention, and fencing techniques. An area of high con- servation value can be enclosed with an animal-proof fence and if the invasive species occurs inside it will be eradi- cated. This mainland–islands concept is very effective in supporting crucial populations of endangered species, if eradication of the invasive species within the containment area is possible but eradication on a large scale is not feasi- ble. Again, feasibility and potential unintended conse- quences of the solution need to be examined. DEPARTMENT OF TRANSPORTATION PREVENTION ACTIVITIES Just six state DOTs (15% of respondents) believe that they have developed and implemented systems for prevention, detection, analysis, control, and management of invasive species. Eleven DOTs (28% of respondents) have mapped and are currently tracking and monitoring areas of infestation as part of efforts to prevent the spread of invasive species. A similar number have developed policies and procedures to support control efforts and/or implemented IRVM plans, statewide or by district. Six DOTs (15% of respondents) reported that they are reviewing the ROWs and are treating them annually for control of invasive species. Nevertheless, many DOTs have begun to implement ad hoc policies and practices to control invasive species that may be spread in the course of business. Several agencies are developing more formal, standardized invasive species pre- vention procedures, practices, and even contract quantities. Invasive Species Prevention in the Project Development Process Under E.O. 13112, a federal agency cannot authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species in the United States or elsewhere unless all reasonable mea- sures to minimize risk of harm have been analyzed and con- sidered. To fulfill the objectives of the executive order, FHWA asks that the NEPA analyses include a determina- tion of the likelihood of introducing or spreading invasive species and a description of the measures being taken to minimize their potential harm. Consideration of invasive species should occur during all phases of the environmen- tal process to fulfill the requirements of NEPA. Initial dis- cussions with stakeholders can identify the potential effects from invasive species and possible prevention and control measures (57). Once the plan specified in the executive order is com- pleted, NEPA analyses rely on each state’s noxious weed list to define the invasive plants that must be addressed and the measures to be implemented to minimize their harm (57). The actual NEPA analysis should include the identification of any invasive terrestrial or aquatic species—plant or animal—that could do harm to native habitats within the project area and could involve mapping all existing invasive populations on and adjacent to the project (57). The analysis should also include the potential effect of the disturbances caused by con- struction on the spread of invasive species and a discussion of any preventative measures or eradication measures that will be taken during the project (57). Measures may include inspecting and cleaning construction equipment; ensuring the use of invasive-free mulches, topsoils, and seed mixes; and control and management strategies to be deployed should an invasion occur.

NYSDOT has an invasive species prevention policy and an engineering bulletin requiring designers and maintenance man- agers—for all projects and activities—to inventory, consider impacts, and incorporate appropriate management techniques for priority invasive plant and animal species (58). NYSDOT’s Environmental Procedures Manual outlines the following steps for completion during the project development process (59): • During project scoping and State Transportation and Improvement Plan development, inventory project area for priority invasive species (plants and animals) and consider possible control strategies. Considering inva- sive species issues as early as possible is important so that long-term invasive species control strategies can be implemented during maintenance operations, as appro- priate, before project construction. • During project planning, for federally funded projects, complete NEPA checklist and conduct preliminary assessment of priority invasive species issues (plants and animals). Also, conduct preliminary assessment for invasive species issues for nonfederally funded projects. • During project development, review project limits and adjacent areas for presence of priority invasive species (plants and animals), note locations on plan sheets, and add information to Regional Invasive Species Inven- tory. Priority invasive species will include, but not be limited to, purple loosestrife, common reed (Phrag- mites australis), Japanese knotweed, and giant hog- weed (Heracleum mantegazzianum). • During project delivery, in consideration of local proj- ect area conditions and regional invasive species prior- ities and management plans; for example, WMAs, APIPP, and Watershed Management Plans: – Document invasive species issues in the system used for tracking environmental issues and commitments, and communicate those to other design, environ- mental, and construction staff. – Incorporate, as appropriate, standard specifications, special specifications, notes, and special notes to: (1) limit the additional introduction of invasive species, (2) limit the further spread of existing invasive species, and (3) eradicate and/or control existing invasive species populations. Considerations should include: (1) limiting area and duration of soil disturbance; (2) cleaning construction equipment; (3) limiting con- struction equipment access and movement within proj- ect area; (4) using approved water sources; (5) using native plants and seed; (6) using weed-free planting, bedding, and mulching (straw, wood, and fiber) materi- als; (7) implementing accepted control and disposal practices; and (8) proper spoil management. General Weed Prevention Practices for Site-Disturbing Projects in Construction Projects and Maintenance Programs The following weed prevention practices for construction projects and maintenance programs are synthesized from 24 practices recommended by NYSDOT (59) and the U.S. For- est Service (60), two of the more complete sets of practices offered by managers of linear corridors in the United States. • Tools—Provide tools for inspection, enforcement, and results by incorporating, as appropriate, standard spec- ifications, special specifications, notes, and special notes as described in the previous section. • Identification, awareness, and education—Once it is determined which invasive species are a priority in your area, learn to identify these plants. Improve effective- ness of prevention practices through weed awareness and education. – Provide information, training, and appropriate weed identification materials to individuals potentially involved in weed introduction, establishment, and spread on agency lands, including agency managers, employees, contract workers, permit holders, and recreational visitors. Educate them to an appropriate level in weed identification, biology, impacts, and effective prevention measures. – Provide proficient weed management expertise at each administrative unit. Expertise means that nec- essary skills are available and corporate knowledge is maintained. – Develop incentive programs encouraging weed awareness detection, reporting, and for locating new invaders. – During project construction phase ensure that provi- sions for location, prevention, and control of invasive species are understood by department construction staff and contractor staff before construction and are implemented throughout the project. Invasive species considerations should be routinely addressed by department staff to contractor staff during pre-bid, preconstruction, get-start, and weekly safety meet- ings, as appropriate. • Inventory—Developing an inventory of the priority invasive plants on your site or in your management area is important for several reasons. First and fore- most, knowing where the invasive plants live is essen- tial to control efforts; the species will continue to exist and spread until controlled. Also, because new invaders can show up at any time and are the easiest to control when they first arise in an area, regular check- ing of the site(s) and updating of the inventory is important. – Before ground-disturbing activities begin, inventory and prioritize weed infestations for treatment in proj- ect operating areas and along access routes. – Identify what weeds are on site or within reasonably expected potential invasion vicinity and do a risk assessment accordingly. – Any additional priority invasive species populations encountered within the project area during construc- tion should be noted and, if invasive species within the project limits are not adequately controlled, the Regional Maintenance Engineer should be notified

25 immediately so that controls can be addressed post- construction. – To assist with future control efforts, during the oper- ation and maintenance of all elements of the state transportation system, the agency shall initiate a sys- tem and regions are encouraged to formally identify and inventory priority invasive species known to exist along the roadside within and immediately adjacent to the ROW. Owing to their heightened role in the introduction and spread of invasive species, priority areas to initiate invasive species inventory efforts shall be the Interstate, expressway, and park- way systems, as practical. Additional priority species and inventory locations may develop as the result of region-wide planning efforts and should also be considered. This inventory should also provide information regarding the extent of invasive species populations adjacent to and outside the ROW. Iden- tified priority invasive species will be considered and managed as appropriate to: (1) limit additional intro- duction of invasive species, (2) limit the further spread of invasive species, and (3) eradicate or con- trol existing invasive species populations. • Incorporate weed prevention and control into project lay- out, design, alternative evaluation, and project decisions. – For the site or maintenance program in question, assess weed risks, analyze potential treatment of high-risk sites for weed establishment and spread, and identify prevention practices. – Determine prevention and maintenance needs to include the use of herbicides, if needed, at the onset of project planning. • Control weeds as necessary. – Begin project operations in uninfested areas before operating in weed-infested areas. – Locate and use weed-free project staging areas. – Avoid or minimize all types of travel through weed- infested areas or restrict to those periods when spread of seed or propagules is least likely. – Coordinate project activities with any nearby herbi- cide application to maximize cost-effectiveness of weed treatments. – Evaluate options, including closure, to regulate the flow of traffic on sites where desired vegetation needs to be established. Sites could include road and trail ROWs and other areas of disturbed soils. • Minimize soil disturbance—Owing to the nature of invasive plants to rapidly colonize areas of disturbed soil, out-compete native species, and become firmly established very quickly, it is essential to minimize areas of soil disturbance. – For vegetation types with relatively closed canopies, retain shade to the extent possible to suppress weeds and prevent their establishment and growth. – Avoid creating soil conditions that promote weed germination and establishment. – Minimize soil disturbance to the extent practical, consistent with project objectives. • Materials sources—Prevent the introduction and spread of weeds caused by moving infested sand, gravel, bor- row, and fill material by inspecting material sources on site and ensuring that they are weed-free before use and transport. Treat weed-infested sources for eradication, and strip and stockpile contaminated material before any use of pit material. – Inspect and document the area where material from treated weed-infested sources is used annually for at least 3 years after project completion to ensure that any weeds transported to the site are promptly detected and controlled. – Maintain stockpiled, uninfested material in a weed- free condition. – Avoid or remove sources of weed seed and propag- ules to prevent new weed infestations and the spread of existing weeds. • Temporary erosion and sediment control—DOT policy requires sound temporary erosion and sediment control practices on all projects that disturb soil. This practice is particularly important in preventing the introduction and continued spread of invasive plant species. Where invasive species are known to exist, rapid and diligent erosion and sediment control is particularly important. • Mulch—Owing to the nature of invasive plants to rapidly colonize any area of disturbed soil, it is essen- tial that all disturbed areas be mulched and seeded as soon as possible. If outside the growing season for seed germination, disturbed sites should still be mulched. Sources of mulch should be free of invasive plant parts or seeds. Use of straw or wood fiber mulch is preferred. If hay mulch is used, it should be verified as originating from an invasive-free source. • Early detection and rapid response—Invasive species, by their nature, spread very rapidly once introduced to a new area. Therefore, it is essential that new infesta- tions be identified and controlled as quickly as possible. Control practices for small populations are far more likely to succeed, are significantly less expensive, and provide more options for control methodology. • Rapid revegetation—Although not a specific condition, replanting or reseeding with native species is highly desired. All of the control methods cited here are intended to reduce or eliminate invasive species so that native species are encouraged to grow and reestablish stable conditions that are not conducive to invasive col- onization. In most cases, removal or reduction of inva- sive populations will be enough to release native species and reestablish their dominance on a site. Replanting may be desirable on private lands, where it can be used as a quid pro quo with the landowner for permission to remove invasive plants. Where project disturbance creates bare ground, consistent with project objectives, reestablish vegetation to prevent conditions to establish weeds. – Revegetate disturbed soil (except travelways on sur- faced projects) in a manner that optimizes plant establishment for that specific site. Define for each

project what constitutes disturbed soil and objectives for plant cover revegetation. – Revegetation may include topsoil replacement, planting, seeding, fertilization, liming, and weed- free mulching as necessary. Use native material where appropriate and feasible. Use certified weed- free or weed seed-free hay or straw where certified materials are required and/or are reasonably avail- able. Always use certified materials in areas closed by administrative order. Where practical, stockpile weed seed-free topsoil and replace it on disturbed areas (e.g., road embankments or landings). – Use local seeding guidelines to determine detailed procedures and appropriate mixes. To avoid weed contamination, a certified seed laboratory needs to test each lot against the all-state noxious weed list to Association of Seed Technologists and Analysts standards, and provide documentation of the seed inspection test. There are plant species not on state and federal noxious weed lists that the U.S. Forest Service would consider non-native invasive weeds. Review state and federal lists to determine if any local weeds need to be added before testing. Seed lots labeled as certified weed free at time of sale may still contain some weed seed contamination. Non- certified seed should first be tested before use. – Inspect and document all limited-term ground- disturbing operations in noxious weed-infested areas for at least three growing seasons following comple- tion of the project. For on-going projects, continue to monitor until reasonable certainty is obtained that no weeds have occurred. Provide for follow-up treat- ments based on inspection results. • Ditching—Many priority invasive plants prefer moist soil conditions and are tolerant of saline environments; there- fore, they grow very well in highway drainage ditches and other components of the drainage system. As the dense root systems of invasive plants such as purple loosestrife, phragmites, and Japanese knotweed proliferate, they rapidly clog drainage ditches and reduce sight distances, especially where water velocities slow; for example, the up gradient of culvert inverts and above check dams. As a result of the rapid growth of invasive plants, mainte- nance cycles are far more frequent where they exist. Before excavating the plants from drainage ditches, the entire invasive plant infestation should be treated with the appropriate herbicide. This will ensure that the plants, seeds, and root parts will not spread and reestablish. Fail- ure to treat the invasive plants before physical removal will most likely result in the immediate regrowth of the plants in the ditch and the spread of the plant to adjacent and downstream areas. In addition, if the invasive plants are not killed before ditch cleaning, the spoil produced can further spread the plants upon disposal. • Shoulder scraping—Removing the build-up of organic material along highway shoulders is essential to main- taining pavement quality, providing adequate sheet 26 flow drainage and providing safe driving conditions. Owing to their disturbed nature and harsh growing con- ditions, highway shoulders provide a prime area for invasive plants to establish and spread. Therefore, shoulder scraping activities address invasive plant con- trol, although scraping is not a desirable control method in and of itself. Before scraping highway shoulders, all existing priority invasive plants should be treated with the appropriate herbicide or other control measure to kill seeds and plant parts, including the root stock. This will prevent the plant from reseeding, resprouting in situ, or spreading to adjacent areas by means of water, wind, hitching a ride on equipment, or through spoil disposal. • Vine, brush, and tree removal—Several common species of vines, brush, and trees that grow readily along highway roadsides are considered invasive species. These species frequently are a nuisance to maintenance workers, block traffic signs, or limit sight distances and therefore are removed in routine maintenance opera- tions. Invasive species should be given preference in the evaluation of these removal priorities and be controlled by accepted practices that will ensure no resprouting and prevent additional spread through seed dispersal. Because these species do not reproduce vegetatively, plant parts do not need to be buried or land filled, and equipment does not require cleaning. Accepted methods of control include foliar herbicide treatment or cutting followed by stump treatment with herbicide. Mowing alone frequently results in resprouting and cloning and is not an effective control methodology. • Poisonous plant removal—A few invasive species pose a serious threat to worker safety and public health. Giant hogweed is one such plant. On dermal contact this plant causes severe skin burns that are exacerbated through exposure to sunlight. Where this plant is encountered, the location should be located using Global Positioning System (GPS) coordinates and ref- erence marker identification, and the size of the popu- lation should be noted and maintained in a regional database. • Disposal—Proper disposal of harvested invasive plant parts and soil containing invasive plant seeds or root stock (rhizomes) is essential to controlling the spread of invasive plants. Full consideration should be given, as appropriate, as follows: – Transportation—While on the treatment site, bag all cut living plant material in heavy-duty, 3 mil or thicker, black contractor quality plastic clean-up bags. Securely tie the bags and transport from the site in a truck with a topper or cap to securely fasten the load to prevent spread of the plant material from the project work site. Transport the material to an appro- priate disposal location. – Compost—Because of the extremely robust nature of invasive species, composting in a typical backyard compost pile or composting bin is not appropriate.

27 However, methods can be instituted whereby sun- generated heat can be used to destroy the harvested plant materials. For instance, storage in sealed 3-mil- thick (minimum) black plastic garbage bags on blacktop in the sun until the plant materials liquefy is effective. If a larger section of blacktop is avail- able, make a black plastic (4-mil-thickness mini- mum) envelope sealed on the edges with sand bags. The plant material left exposed to the sun will liq- uefy in the sealed envelope without danger of dis- persal by wind. The bags or envelopes must be mon- itored to make sure the plants do not escape through rips, tears, or seams in the plastic. – Bury—Owing to the incredible capacity of many invasive species to reproduce by seed, clone, and vegetative propagation, it is absolutely imperative that spoil material contaminated with invasive plant material not be disposed of in an indiscriminant manner. It is recognized that the contractor owns spoil material and, therefore, contract documents should identify locations of contaminated soil and address disposal options. Spoil material that con- tains invasive plant material should be buried in an excavated pit, covered with woven geotextile, and covered with at least 3 ft of uncontaminated fill material. – Landfill—If harvested invasive plant parts or spoil material containing invasive plant material is not composted or buried, it should be transported directly to a sanitary landfill for proper disposal. • Bridge washing—All bridge washing activities, whether for biannual maintenance or in preparation for repaint- ing, require the use of water. Several invasive plant and animal species are aquatic or are dispersed through water; therefore, DOT activities that require the transport and use of water need to consider invasive species con- trol. Control considerations include the use of municipal water sources, filters on water intakes, decontamination and sanitation of equipment, and use of in situ water sources. In addition, the equipment used in transporting and spraying water should be cleaned before use or between uses at sites in different watersheds. • Construction equipment in water bodies—Several inva- sive species are aquatic and many additional nonaquatic species are readily spread by flowing water. In addition, many aquatic invasive species are capable of survival out of water for extended periods. To prevent the acci- dental introduction of invasive species that are “hitching a ride” on construction equipment, all equipment that is to be placed in a water body should be cleaned, as appro- priate (e.g., tracks and buckets) to remove invasive species and their seeds and propagules. This require- ment applies to equipment arriving on the project and equipment that is being relocated within the project. • Restricted construction equipment access—To prevent the accidental introduction of invasive plants during construction or maintenance activities, all tracked equipment involved in earthwork should be cleaned to remove plants, seeds, and propagules that may be hitch- hiking before arrival on site. If tracked equipment is used in earth work on a portion of a project where inva- sive species are known to exist, this portion of the earth- work should be conducted last, or the equipment shall be cleaned before use on any portion of the site that is known to be free of invasive plants. • Cleaning of construction equipment—Cleaning should occur before equipment arrives on site. Once on site, if equipment involved in earthwork is contaminated with invasive species, the equipment should be cleaned before moving into uncontaminated areas. Cleaning shall con- sist of using physical means and hand tools, such as brushes, brooms, rakes, or shovels, on all track and bucket/blade components to adequately remove all visi- ble dirt and plant debris. If water is used, the water/slurry shall be contained so as to restrict introduction of inva- sive plants, seeds, and propagules into the project or off site through future surplus material disposal. – Treat weeds at administrative sites and use weed pre- vention practices to maintain sites in a weed-free condition. – Determine the need for and, when appropriate, identify sites where equipment can be cleaned. Clean equipment before entering area targeted for prevention of invasives, including federal forest and park lands. When practical, collect and incin- erate plant parts. Remove mud, dirt, and plant parts from project equipment before moving it into a project area. – Clean all equipment before leaving the project site if operating in areas infested with weeds. Deter- mine the need for and, when appropriate, identify sites where equipment can be cleaned. Seeds and plant parts need to be collected when practical and incinerated. – Workers should inspect, remove, and properly dis- pose of weed seed and plant parts found on their clothing and equipment. Proper disposal means bag- ging the seeds and plant parts and incinerating them. – Set the example; maintain weed-free administrative sites. Potential Construction Contract Wording and Measures for Invasive Control The Center for Invasive Plant Management recommends the following contract language for weed prevention (61). Before any construction disturbance: • Identify and map all noxious and invasive weed popu- lations present in the project area. • Treat or contain any weed populations that may be impacted or disturbed by construction activity. • Flag all weed populations to be avoided.

• Provide training to construction workers and equipment operators on the identification of weeds to be avoided. • Certify that all construction material sources used for supplies of sand, gravel, rock, and mulch are weed free before obtaining or transporting any material from them. • Obtain and use only certified weed-free straw or use fiber roll logs for sediment containment. • Wash and inspect all vehicles for weed seeds and plant parts before bringing them onto the job site. • Install stormwater BMPs to prevent erosion of the job site and the potential transport of weedy material onto or off of the job site. During construction: • Minimize ground disturbance and vegetation removal as much as possible and practical. • Wash, or using an air compressor, blow clean all vehi- cles (including tires and undercarriage) that may have entered weed-infested areas before entering uninfested areas of the job site. • Restrict vehicles or other traffic that may transport weed seeds or plant material from entering the job site unless they are first washed and inspected. After construction is complete: • Revegetate or otherwise prevent the establishment of weeds in all areas of the job site through a program of monitoring and post-construction weed treatment for the life of the project. • Revegetate using soil components and mulches obtained from non-weed-infested sources. • Use seed and other plant material that has been checked and certified as noxious weed-free and that has a weed content of 0.05% or less. • Revegetate using plant materials that have a high like- lihood of survival. • Maintain all planted material and native vegetation located on the project site for the life of the project. • Monitor all seeded sites for weed infestation. Treat all weeds adjacent to newly seeded areas before planting and treat planted areas for weeds in the first growing season. NYSDOT uses the following contract item methods of measurement: • Controlling invasive plants will be measured as the number of square meters of surface area that have been satisfactorily controlled. • The unit price bid per square meter shall include the cost of all labor, materials, and equipment, including dis- posal, and incidentals necessary to complete the work. • Item and pay unit: – Controlling invasive plants with plastic (square meter) 28 – Controlling invasive plants with herbicides (square meter) – Controlling invasive plants by pulling (square meter) – Controlling invasive plants by digging (square meter). EARLY DETECTION AND RAPID RESPONSE Early detection of nonindigenous species should be based on a system of regular surveys to find newly established species. Methods to detect species differ between taxonomic groups, and their success depends largely on taxonomic dif- ficulties and how conspicuous the species are. A drawback of general surveys is that only well-trained staff will be able to identify nonindigenous species in many taxonomic groups. Effective Early Detection Programs A crucial part of early detection is a contingency plan, which determines the action to be taken when an alien species is found. Given the diversity of potential new incur- sions, the initial plan will be rather general. It should include a list of the stakeholders and experts who need to be contacted for a more detailed action plan. Contingency plans targeted at specific high-risk species can be very effi- cient, with an exact schedule for what to do. For a contin- gency plan to work, the equipment needed must be ready at the designated place and funding must be available for emergency eradication or control. Rapid response is a systematic effort to eradicate, contain, or control invasive species while the infestation is still localized. It may be implemented in response to new introductions or to isolated infestations of a previously established organism that is non-native to the ecosystem. Preliminary assessment and subsequent monitoring may be part of the response. It is based on a system and infrastruc- ture organized in advance so that the response is rapid and efficient (18). When reviewing models of EDRR from oil spills to fire to invasive species and diseases, some of the general features associated with effective EDRR programs are (18): • Strong interest by localities or states in detection and response. • Federal leadership through means in addition to fund- ing (science, training, logistics, and leadership itself). • Effective communication of ideas and data with stake- holders and partners. • Clear organization, authority, and responsibility. • Exploitation of the most effective means of detection for the particular system. • Adequate funding.

29 • Advance, detailed planning of response organization and arrangements. By means of research for NISC on effective EDRR pro- grams, opportunities for substantial enhancement of passive, early detection could be exploited. • For each type of invasive species, consideration should be given to advantages and opportunities for passive versus active detection. Most detection of invasive species has been passive, and the approach can be cost-effective when multiple agencies, states, universities, private groups, and amateur biologists are involved. • Anyone who frequently goes into the field and has some knowledge of biology should be aware of the need for surveillance and enlisted to help. Publicly available, user-friendly databases support EDRR efforts. The U.S. Geological Survey’s Invasive Species Research Center in Fort Collins, Colorado, working with several partners, has created a web-based early detection and rapid reporting database for use by vol- unteer groups trained to assist in identifying local inva- sive species. The database is publicly available to any agencies that wish to use the data and may help local mapping and response efforts. • Effective EDRR requires strong public awareness and involvement. Many agencies have public education programs that support EDRR efforts with cross train- ing and volunteer programs. They have increased pub- lic curiosity and awareness of the environment. For example, Bureau of Land Management (BLM) is col- laborating with local Coordinated WMAs and the state of Wyoming to test the different elements of the FICMNEW EDRR plan for invasive plants. The con- cepts of the FICMNEW EDRR plan have been inte- grated into all of BLM’s actions with more than 50 Coordinated WMAs in the western United States. The Invasive Plant Atlas of New England (IPANE) (62) developed “Invasive Alerts” so that individuals can watch for additional incursions. Each alert contains information on the occurrence, when it was first observed, and the potential threats from the invader. A regional map to show where these incursions are and photographs to facilitate identification are included. IPANE’s “Rapid Responders” database is used to establish teams of experts once a new incursion has been reported. The Invaders Database includes weed distribution records for five northwestern states, with maps, photographs, and biological information updated regularly. Also, the Western Weed Coordinating Committee distribution maps of leafy spurge (Euphorbia esula) and yellow starthistle (Centaurea solstitialis) in the western United States indicate areas where early detection and rapid response may help land managers avoid widespread infestations. Active Detection—Surveys, Data Collection, and Storage Active detection may be most effective when targeted to sites near invasion pathways and to sensitive ecosystems. NISC compiled the following examples of successful EDRR prac- tices among NISC cooperating agencies (63): • Because little may be known about certain new invasive species and because the correct identification of speci- mens is critical, National Oceanic and Atmospheric Administration (NOAA) has developed a list of more than 100 taxonomic experts who can identify specimens. • Monitoring high-risk areas and knowing what is pres- ent before an invasive species arrived (baseline data) are essential to the early detection of new invasions. Aquatic Nuisance Species Task Force members have instituted systematic monitoring programs for aquatic invasive species in San Francisco Bay, Puget Sound, the Lower Columbia River, Prince William Sound, Honolulu Harbor, Mobile Bay, Chesapeake Bay, and Massachusetts Bay. This provides baseline surveys of aquatic organisms that occur in those systems as well as looks for new invasions. Although DOTs more often depend on chance sightings for early detection of invasive species, experts recommend that early detection of nonindigenous species be based on a system of regular surveys to find newly established species (64). In general, surveys for early detection are designated and targeted to answer specific questions quickly and eco- nomically, and give a “yes” or “no” answer. There are three general types of surveys to consider: • General surveys for large or conspicuous animals and plants may be conducted by means of a “looking sur- vey.” While doing other work, staff should be vigilant and continually aware of possible signs of new invaders. The public should be encouraged to report new sightings as well. • Site-specific surveys can be characterized as general surveys targeted at key sites; for example, high-value biodiversity areas and areas near high-risk entry points. • Species-specific surveys where specific threats are identified and prioritized. Frequency and timing of sur- veys is important. The potential range of newly arrived invaders needs to be considered, along with the climate of the region. Survey methods for specific invasive plants will depend on how easy it is to recognize the tar- get. If there are similar noninvasive and/or indigenous species present, then field guides, illustrations, and training may be necessary. Recommended practices for surveying include: • Recordkeeping of the species found, both native and introduced, and the action taken.

• Collection and preservation of specimens. When local knowledge is not adequate to make an authoritative identification, material should be sent for specialist identification. Local and regional museums are a good starting point for advice on identification of invasives. • Storage of information in a database, in a standard format. DOTs may want to establish and keep up-to-date a con- tact list for their specific state or region, including the names of both institutions and individuals, what types of invasive species they might be able to identify, and the methods that should be used for the specimen collection. Records of NEPA evaluations should be collected in a standard format so that they form a baseline for further use by the DOT and/or other agencies. Information about incorporating volunteers into early detection and monitoring programs may be found in The Early Detectives: How to Use Volunteers Against Invasive Species, Case Studies of Volunteer Early Detection Programs in the U.S. (65). Effective Rapid Response A crucial part of early detection is a contingency plan, which determines the action to be taken when an invasive species is found. Contingency plans targeted at specific high-risk species can be very efficient, providing an exact schedule for what to do. Response cannot be rapid if elaborate steps are required between detection and actual attempts at contain- ment or eradication. Therefore, the following recommenda- tions were derived from a national examination of rapid response approaches (18): • The process for assessment and decision making should be flexible and simple, and involve detailed agreements worked out carefully in advance. This allows partners to focus on the actual response rather than on negotiating in an atmosphere of confusion and ambiguity. Agreements may be numerous and involve many levels of a hierarchical system and multiple agencies. They specify what will be done by whom in any given situation, how leadership will be identified, how funding will be arranged, and what preparation will be undertaken. Agreements should be made at the lowest appropriate levels (18). If flexibility in organizational structure is desired, it can be added after the preplanned organization is in operation. • Identify an organizational structure for response in advance, but appoint individuals to positions as appro- priate to the situation while organizing the response. In interagency responses, a system for assigning leaders of response organizations (Incident Commanders) could be identified through agreements made in advance. The Incident Command System could be adopted as a stan- dard organizational model for rapid response and con- sidered also for long-term, interagency control projects. 30 Early Detection and Rapid Response Findings for Federal Programs and Oversight Agencies Research on the most effective EDRR systems nationally also found that federal programs that are successful include more than financial support. Simply disbursing funds and attempting to control states and localities with them is not likely to be successful in the long run. Provision of logistical and scientific support and qual- ity leadership engenders a close working relationship and a spirit of federal–state cooperation. Areas where scientific expertise is likely to be useful to states are (18): • Identification and systematics; • Techniques for surveillance, detection, monitoring, and related data analyses; • Eradication and control technology; and • Biology/ecology with emphasis on risk assessments. These areas of expertise are needed in each taxonomic group or type of invasive species. NISC’s research also found that the quality of detection and response activities may be enhanced by providing training and certification in detection and response (18). Over a 5-year period, FICMNEW developed a Concep- tual Design for a National EDRR System for Invasive Plants, after deciding that EDRR is the most cost-effective and envi- ronmentally sound approach to addressing invasive species. The proposed National EDRR System for Invasive Plants has five elements: (1) Detection and Reporting, (2) Identification and Vouchering, (3) Rapid Assessment, (4) Planning, and (5) Rapid Response (66). To facilitate these elements, the effort plans to develop and identify lists of target species, list- serves, and contacts for reporting, and develop generic (broadly applicable) rapid response protocols and action pro- cedures for use by local, state, tribal, and regional partners. These generic rapid response plans are to be provided in var- ious invasive plant websites and publications. They plan to include basic protocols for detection and delimiting survey data to be collected during treatment efforts and methods for post-treatment appraisal surveys. The initiative also plans to develop and provide technical expertise on rapid response methods and procedures through the development of a cadre of scientists and technical specialists to provide on-site and distant support on rapid response initiatives and developing, modifying, or adapting web-based, computer-assisted, deci- sion support systems to aid land managers in identifying and developing management options and priorities for address- ing new invasive plants. The effort also seeks to collaborate with state and national partners to develop, test, and imple- ment post-response monitoring protocols and establish a mechanism for reporting post-management monitoring results and an alert network if more action is needed (adap- tive management feedback loop).

05 10 15 20 25 30 35 40 45 50 Pe rc e n ta ge o f r es po nd en ts In ve n to ry o f i nv a si ve s co m pl et e G IS u se d in in ve n to ry Ye s, su rv ey in p ro ce ss N o, su rv ey n ot in p ro ce ss Ye s, pl an to c on du ct su rv ey N o, do n ot p la n to co n du ct s ur ve y 31 State Department of Transportation Early Detection and Rapid Response Efforts Thirteen DOTs (33% of respondents) have implemented rapid responses to discovered locations or patches of invasive species. Subsets of these have developed EDRR programs. In Illinois and Maryland, District Landscape Architects notify the local maintenance yard, which responds as soon as it is able. State agriculture department staff also contacts the DOT when infestations are observed. TxDOT uses rapid response statewide and the WSDOT’s EDRR use an e-mail list of field staff. DOTs are more likely to employ EDRR for species that are new to the state to eliminate and avoid new burgeoning problems (Nevada, New Hampshire, and Oregon DOTs). EDRR is also used when a big push is on for elimination or reduction of priority species. For example, Mn/DOT is attempting to eradicate common reed and Grecian foxglove (Digitalis lanata) from the ROWs; early detection and rapid response are employed to “hold the line” on weed spread into new counties or to prevent it from gaining a foothold in new segments of highway. California DOT (Caltrans) and FHWA have partnered to address exploding populations of the Sahara Mustard plant in the Mojave and Sonora deserts, where highway corridors have been blamed for the weed’s spread. FHWA was instru- mental in gathering federal and state partners to work with Caltrans as part of a rapid response effort and in funding a workshop. Caltrans is inventorying the plant on the ROW, which will be used as a benchmark for subsequent control (B. Harper-Lore, personal communication, Aug. 18, 2005). STATEWIDE INVENTORY OF INVASIVE OR NOXIOUS SPECIES IN RIGHT-OF-WAY AND UPDATE OF DATABASES Twenty-eight percent of responding state DOTs (11 states) have undertaken a statewide inventory of at least one inva- sive species in the ROW. Four state DOTs (10% of respon- dents) have one currently in process and five states (13% of respondents) plan to implement one in the future. Nearly one-third of responding DOTs reported that they do not plan to implement a statewide survey in the future (see Figure 3). Although statewide tracking of invasive species is rela- tively uncommon, the Maryland State Highway Administra- tion tracks the location and quantities of certain invasive species on ROWs statewide. In particular, the agency is trying to achieve and document a 25% reduction in Canada thistle in the ROW by 2008. Tree of heaven (Ailanthus altissima) has also been targeted. Mn/DOT is working on a research initia- tive with the University of Minnesota to develop a statistically valid weed sampling system to determine weed extent and whether the agency is gaining or losing ground. In 2006, Mon- tana (MDT) is completing a noxious weed inventory of all roadsides. NYSDOT has developed an extensive electronic inventory with control information for the APIPP, which is then used in annual meetings with partners to evaluate and continuously improve treatment efforts, adjust plans, and ensure accountability, as necessary. Counties are increasing in sophistication as well. Some New York counties are main- taining GIS data for tracking and controlling infestations of priority invasives. Colorado and North Carolina DOTs have used GPS to map and track larger problem sites. Ohio DOT is exploring combining its endangered plant inventory program with an invasive plant inventory. WSDOT maintains area IVM plans, with treatments tracked in an associated database. A number of state transportation agencies, including the Louisiana Department of Transportation and Development (LADOTD), Mn/DOT, and NYSDOT, have been tracking and evaluating control of particular invasives over smaller areas (i.e., not statewide), sometimes using GPS units with sub-meter accuracy (Minnesota). Although statewide sur- veys have not been undertaken in Arizona, within the main- tenance division, the Arizona DOT has been using the annual level of service surveys to map invasive species within ROWs. Maintenance staff uses that information in manage- ment and work planning. Maintenance and construction staff takes weed awareness training to identify invasive and nox- ious species and control them. Inventory Approaches and Use State DOTs have performed inventories in a variety of ways; however, by far the most common method has been inventory FIGURE 3 Inventory and surveys.

by local maintenance yards and districts. Temporary staff and universities have been hired, and DOT office technical staff helped in a number of cases. Alabama was the only state to have a university conduct the inventory statewide, although after attempting to perform an inventory through county weed coordinators, MDT is working through Montana State University and the Agricultural College to hire temporary employees to conduct the inventory, with support from uni- versity staff. WSDOT involved counties, in that case, noxious weed boards. In almost all cases, updating of the database and GIS occurs through ongoing observation by mainte- nance staff. Of those DOTs that have undertaken a survey, more than two-thirds used GPS and GIS. States using GPS to map stands of invasive species included Iowa, Kansas, Maryland, Minnesota, Missouri, New Mexico, New York, Oklahoma, Oregon, Texas, Utah, and West Virginia. Such GPS and GIS information can then be used to track treatment effective- ness (M. Venner, 2002 survey). Implementation of a map- ping system is an element of the IRVM plan for Mn/DOT Maintenance Area 3B. To accomplish this, computer-sided dispatch maps were obtained from Mn/DOT and plat books were obtained from the county. The maps that were devel- oped included established areas of noxious weed infesta- tions, hazard trees, native seeding, and other important ele- ments of the management plan. These maps are updated and assist in program planning, recordkeeping, and assessment. Paper-based map systems are widely being converted to GIS. NCHRP Synthesis of Highway Practice 341 reported that Maryland and Utah have connected their IRVM plans to GIS and GPS (67). WSDOT is using ArcIMS (Informa- tion Management System) to track both species location and treatment effectiveness. New York State Department of Transportation’s Inventory Model In addition to maintaining an electronic database of all pri- ority invasive plant locations identified in association with capital project development and delivery, NYSDOT strongly encourages all transportation regions to initiate and manage an inventory of priority invasive plant species for the high- way systems within their jurisdiction. NYSDOT’s directions identify four species of statewide priority to include as a starting point and common basis in any inventory. Additional consideration is recommended for region-wide priority species established through participation in WMAs, APIPP, Watershed Management Plans, or similar planning efforts. For prioritization purposes, the regional inventories begin with the Interstate, expressway, and parkway systems, the primary introduction and dispersal conduits for invasive plant species. The NYSDOT calls for a similar format and compatible databases for regional inventories, with variabil- ity expected regarding the specific inventory methods and parameters included in the regional inventory. The forms 32 NYSDOT uses for data collection and monitoring are in Appendix C. NYSDOT also has a sample database format available for sharing. NYSDOT recommends establishment of a Regional Inventory Coordinator and a multidiscipline Regional Team. Although inventory information has been coordinated by the headquarters Environmental Analysis Bureau primarily through the regional maintenance environmental coordina- tors, design and construction staff are now collecting inven- tory information as well. NYSDOT describes the following inventory methods in the agency’s Environmental Procedure Manual (68): • Collect reference marker location information and com- plete the Inventory Data Collection Form for manual entry into GIS project. • In GPS “Mapping Mode,” collect “Point” GPS coordi- nates from the center of the plant infestation and com- plete preprogrammed GPS data dictionary attribute information or NYSDOT Inventory Data Collection Form, for each point. • In GPS “Mapping Mode,” collect “Line” GPS “start” and “pause” coordinates for linear plant infestations or collect “Area or Polygon” coordinates for patches, complete preprogrammed GPS data dictionary or NYSDOT Inventory Data Collection Form, thus allow- ing GIS to map and sum the inventory information. Collecting information in this manner facilitates entry into a Regional Invasive Species GIS Project. Each Re- gional Maintenance Environmental Coordinator receives electronic copies of the NYSDOT Invasive Species Inven- tory database and copies of the NYSDOT Inventory Data Collection Forms attached in Appendix C of this document. This information can then be used during project develop- ment as a site screening tool and provided to maintenance staff for risk assessment and planning for necessary roadside maintenance activities or for implementing additional “pre- emptive” invasive species controls. As these regional data- bases develop, NYSDOT aims to track and monitor progress of control efforts at regional and statewide levels and contribute to larger statewide and region-wide inventory programs; for example, WMAs, APIPP, and Watershed Management Plans. Two other sample inventory methodologies that are currently in use in New York State are (1) The APIPP Methodology (www.adkinvasives.com) and (2) The Nature Conservancy Weed Information Management Sys- tem (WIMS) (www.TNC.org). The APIPP methodology has been implemented in portions of 12 counties in Regions 1, 2, and 7 inside the 6.5 million acre Adirondack Park since 1999. NYSDOT’s data forms are modeled closely after the APIPP forms. This inventory is conducted mutually by NYSDOT, The Nature Conservancy, APA,

33 and volunteers. The database is managed by the Adiron- dack Nature Conservancy with GIS products produced and distributed by NYSDOT. Information is collected through the use of mail-in postcards that provide the approximate location of suspected invasive plant infestations. These postcards have been distributed to NYSDOT maintenance staff and a network of volunteers. Cards are mailed to the Adirondack Nature Conservancy and staff visit the site to confirm the information and enter the data onto a field data collection form, by reference marker (blank form attached), and then into the APIPP ACCESS database. This information is next sent to NYSDOT, entered by NYSDOT into the APIPP GIS system, and a species- specific location map is produced and distributed to APIPP partners and participants. The Invasive Plant Council of New York State has promoted the use of the WIMS data- base as generally adopted by The Nature Conservancy as their national standard. How Departments of Transportation Are Using Collected Information DOT roadside invasive species inventories are all used to identify and locate areas for treatment, invasion by new species, and to set priorities. DOTs also indicated that inven- tories are being used to: • Partner with other agencies in providing funding for control of specific species (California), • Estimate expansion of weed presence (Alabama and Montana) and monitor treatment results and acres infested (Alabama and Washington State), • Guide and evaluate invasive species control efforts (Cal- ifornia, Colorado, Florida, Indiana, and Maryland), and • Guide effort and budgeting to meet established goals (Maryland). Just one state had determined the rate at which weeds are spreading: Alabama DOT estimated that the acreage of cogongrass (Imperata cylindrical) is expanding at a rate of 20% per year within the state. NDOT was able to estimate the accuracy of an inventory contracted out by the depart- ment by checking it against maintenance spray logs from weed crews. The agency found that the inventory was 25% different (75% accurate) by the time spraying was con- ducted. The agency attributed this to the accuracy of the study rather than the spread of weeds during the interim. Alabama DOT is also using their database to monitor treatment results. Maryland State Highway Administration’s inventories (each September from 2002 through 2004 for phragmites and in December 2004 for Canada thistle) are being used to chart current control efforts and to provide information on how much effort needs to be put into the program to meet the goal. FDOT focuses on two priority species. Inventory and Mapping, Monitoring, and Analysis Resources BLM, U.S. Forest Service, U.S. Fish and Wildlife (FWS), and the Bureau of Indian Affairs conduct inventory and map- ping in coordination with county and state agencies. Other resources of inventory or mapping, monitoring, and analysis of invasive species include: • APIPP. • Chapter 2 of the University of Northern Iowa IRVM technical manual contains a detailed discussion on how to map and inventory vegetation. • Mapping standards from the North American Weed Management Association. • Invasive species monitoring resources from the National Park Service, which also provides information and links on prevention and early detection, prioritiza- tion tools, databases, references and invasive species bibliographies, and much more. • Guidelines for Terrestrial Noxious Weed Mapping and Inventory in Idaho. • Information on how to document new weeds, from Idaho’s Noxious Weeds. • Montana Noxious Weed Survey and Mapping System— Guidelines for individuals participating in statewide mapping project. • Introduction to Mapping Noxious Weeds in Montana. • Map Important Weeds for A Living Inventory, part of the War on Weeds series from University of Nevada Extension Publications. Remote sensing has played an increasingly important role in identifying large-scale weed infestations. Remote sensing provides information on the location, quantity, and condition of land cover, which can be compared over time. The success of remote sensing as a monitoring tool largely depends on the instrument, topography, size of infestation, timing, and the ability to distinguish target plants from the landscape. Three to five meter scale mapping and hyperspectral analysis is often necessary during the flowering season for detection of larger populations of invasive species. TxDOT has been able to identify large populations in this manner. Protection of Native and Rare Plant Communities in Right-of-Way A number of states are beginning to identify rare plant species in the ROW and tailor ROW management to encour- age native species. Transportation agencies in California, Colorado, Delaware, Iowa, Minnesota, Missouri, New York, and Wisconsin are among those that have begun to preserve high-quality roadside remnant native habitats, Karner Blue butterfly habitat, and other sensitive habitat types (9). These initiatives typically have several common elements: • Mapped information is combined from multiple agen- cies. Typically, the primary mapped data on known

plant locations of rare species is obtained from the state NHP. Other potential contributing agencies may include the state DNR or forest agency, FWS, BLM, U.S. Forest Service, native plant societies, DOA, knowledgeable individuals, and local counties. • Upon completion of the initial data compilation phase, field surveys are conducted in some cases. • Special Management Areas are set up with particular management practices. • Maintenance forces are educated regarding the special maintenance needs of and expectations in these areas. • Tracking of species condition and progress may occur. MONITORING AND FOLLOW-UP Monitoring the numbers of a pest species killed or removed is a measure of the work being done, but is not a measure of invasive species control. The success of an invasive species control project can be measured by monitoring numbers of the pest species that remain and ultimately the condition of the ecosystem they are in. Removing an invasive alien species from an ecosystem will not automatically lead to the return of the indigenous flora and fauna. Although this is often the case, removal of one alien species may simply open the way for colonization by another. Monitoring of the impact of control actions needs to be put in place, preferably starting with small-scale activities to verify the impact of control opera- tions, and if the results are not as expected, the management plan may need to be reconsidered and adapted in light of this new knowledge. In most cases successful eradication programs need to be accompanied by prevention measures against recolonization by the removed species, and early warning systems should be put in place to detect colonizers early. A new infestation of the successfully eradicated species can be wiped out swiftly when detected early by using the appropriate eradication method, because the knowledge of the negative impact of the invasive species and the experience in controlling the species is estab- lished and will be supported by those previously involved. INFORMATION MANAGEMENT AND DECISION SUPPORT SYSTEMS IN EARLY DETECTION RAPID RESPONSE Effective systems of detection and response require ready access to data. For invasive species, these needs may be most efficiently served from a central system, or at least standard- ization of a designated system for each group of invasives. Needs that have been addressed in the NISC’s Invasive Species Management plan include (18): • A database of existing and potential invasive species in the United States with current geographic information, identification details, and control information. 34 • A database of institutions and experts for identification and biology of invasive species in each taxonomic group. • A database of individuals and groups to contact in case of detection, depending on geographic location, type of invasive species, and potential threat (for use by a reporting point). The NISC is charged with establishing a coordinated, up-to- date information-sharing system that emphasizes the use of the Internet for documenting, evaluating, and monitoring impacts from invasive species on the economy, environment, and human and animal health. Although there are many sources of information concerning invasive species, incompatible data- base formats and other factors impede information sharing. The NISC is currently developing an information “gate- way” accessible through the Council’s website at www. invasivespecies.gov. The Council plans to help develop a fully integrated Internet-based network system that eventu- ally will support rapid and accurate discovery of data, the automatic correlation and synthesis of pertinent data from many sources, and provide a presentation of the results of data synthesis that meets the needs of users. The long-term goal is to provide accessible, accurate, referenced, up-to- date, comprehensive, and comprehensible information on invasive species that will be useful to local, state, tribal, and federal managers; scientists; policymakers; teachers; stu- dents; and others. To help ensure that stakeholder needs are met, the NISC has formed a steering committee that includes state, tribal, federal, and local governments; non- government organizations; the private sector; and other stakeholders. Some basic elements of this site are now in operation and work is ongoing. Weed Information Management System BLM developed the “WIMS” more than 10 years ago and has since built on the system in cooperation with others. BLM developed the database called Boise–Vale to capture inventory, monitoring, and control information for noxious and invasive weeds on BLM lands. BLM still uses the model of Boise–Vale, but has developed a national web- based and spatial database for the BLM to which all offices will convert once it is completed. BLM’s database now incorporates information on all invasive species on BLM managed lands; however, its primary purpose is to collect weed data. Because it is considered public domain, The Nature Conservancy has taken the database and improved its components. The database on which The Nature Conservancy, BLM, FWS National Refuge System, U.S. Geological Survey National Institute of Invasive Species Science (Oregon), and the California Department of Food and Agriculture collaborated is free and may be used to track invasive species occurrence data, current status, and treatment information.

35 As currently maintained by The Nature Conservancy, WIMS is a Microsoft Access-based relational database application that is designed to assist natural resource man- agers in managing their weed data. It can be used as a stand-alone database application that resides on a laptop or desktop computer or can be used in combination with a hand-held unit to collect field data. WIMS keeps track of three types of data records: weed occurrences (GPS point locations), assessments (size and status of the weed infes- tation to facilitate monitoring over time), and management treatments applied to those weed infestations. Data can be easily exchanged between multiple users, exported in North American Weed Management Association stan- dards, and written to shapefiles for mapping in any stan- dard GIS program. A variety of reports can also be easily generated. Field data collected with hand-held electronic data re- corders can be easily downloaded into the database. WIMS can be used on a hand-held unit (either MS Windows-based Pocket PC or Trimble) with a GPS unit to capture data in the field. When using WIMS on a hand-held unit with an ArcPad interface, a site manager can use background imagery and other GIS layers for mapping weeds, then upload the new data into the Access database automatically. Utah Department of Transportation’s ROADVEG Geographic Information System UDOT’s vegetation management professionals use the ROADVEG system, a GIS, to inventory invasive plants along with other transportation-related data. UDOT staff can track the spread of invasive plant species, monitor the progress of mitigation strategies, and query and display various vegetational attributes as needed. To date, approxi- mately 1,360 linear miles of Utah roadways have been field- assessed and scored. As funding becomes available, the remainder of the state’s major roadways will be inventoried. Utah State University assisted in the road and county land inventory process. Pennsylvania Department of Transportation’s Roadside Spray Application Pennsylvania DOT (PennDOT) has developed a Roadside Spray Application (RoSA) system, a web-based GIS appli- cation developed with Microsoft’s .NET. RoSA assists PennDOT district roadside spray specialists with collecting, storing, and reviewing herbicide spray activity along state highways. The output data from this application will serve as a status report for the districts, state, and outside agencies (e.g., DOA, EPA). The system was developed to relieve dis- trict roadside specialists from having to tally by hand results and sums and develop summary spraying reports. System users include PennDOT central office and districts, coun- ties, and outside contractors. The system allows PennDOT’s statewide roadside manager to oversee all roadside activities more effectively, including cost and production figures. According to PennDOT’s vegetation manager, Joe Demko RoSA is taking the department’s spray information from the file cabinet to the 21st century of GIS mapping and database reporting . . . The development of RoSA has been an exciting and worthwhile experience which will allow our local mainte- nance operations to inquiry and map spray information in min- utes from their computers. Users input data on the location of the spraying, the type and amount of chemicals used, the contract and date, weather conditions, the applicator of the spray mixture, and material and resource costs. The system enables map views of new and historical spray data, and easier data collection, storage, and retrieval (see Figure 4). Counties and districts are also using the system to reorder chemicals based on usage figures. FIGURE 4 Roadside spray application (RoSA) on the web.

California Department of Transportation’s Geographic Information System for Locating Appropriate Plant Species Caltrans is developing a GIS to help employees quickly access lists of plant species for revegetation that are both eco- logically appropriate for the project site and potentially use- ful in minimizing erosion from roadcuts and roadsides. The GIS uses hydrologic units of CALWATER at 1:24,000 as a means to link physiographic and climatological data together with the presence or absence of selected plant species in each hydrologic unit. Plant climate classifications are being refined using elevation contours and topographic aspects derived from digital elevation models to allow for assign- ment of different plant climates to portions of hydrologic units that exhibit steep elevational gains or considerable landform diversity. Through the overlay of other data depict- ing county boundaries, roads, and places, users are able to locate project sites, query the plant species climate matrix, and export data tables to spreadsheets or reports. Guidebooks that index the same plant species climate matrix through a standard “route  county  mile/km” georeferencing sys- tem make these data available to district personnel in another format as well (69). Caltrans is also developing an ROW inventory system, which will include all resources in the ROW, “from stop signs to salamanders.” One-foot-resolution aerial photog- raphy will allow prediction of species most likely to be there. Caltrans and the University of California–Davis plan to do resource and land use modeling to generate a variety of useful information, from the viability of wildlife cross- ings to the presence of different natural communities (G. Erikson, personal communications, Sep. 2005 and Jan. 2006). Oregon Department of Transportation’s Geographic Information System-Based Sensitive Resource Inventory ODOT has developed a GIS-based inventory of sensitive resources and erosion control problem areas along nearly 6,000 mi of state highway as part of its Salmon Resources and Sensitive Area Mapping Project. The primary purpose of the project is to provide accurate resource protection maps to roadway maintenance crews so that mowing, pesti- cide application, and other activities do not harm listed salmon species and other sensitive resources, and that streams and banks in poor condition might begin to be addressed. The comprehensive resource inventory was developed by using color infrared digital imagery with 2-ft resolution. Other sensitive resource features were recorded from current knowledge bases and limited roadside surveying and from modeling of interactions between multiple resources and data layers. After distance to water, stream, and bank 36 characteristics, known threatened and endangered species locations and the overall condition of the salmon and trout habitats were identified. ODOT compared the imagery to previous data collected from other sources, such as wetland information from the National Wetland Inventory and hydro- graphic data from the U.S. Geological Survey, to update and validate these findings. GIS maps were tied into ODOT’s linear referencing sys- tem, which enables the agency to identify the locations of sensitive natural resources features within one-hundredth of a mile (70). From this GIS resource, ODOT’s Trans- portation Inventory and Mapping Unit and the Information Systems Branch developed a series of detailed resource maps in 0.01-mi segments, which indicate where sensitive resources are present, including which side of the road. Based on the potential for environmental harm, certain restrictions were developed for each mile of highway. This information was then placed on restricted activity zone maps, which were designed to alert ODOT staff to specific locations of sensitive natural resource features to avoid inad- vertently harming wildlife or wetlands when performing routine maintenance practices, such as slope maintenance, snow removal, and vegetation management. They also served to help minimize the potential for violations of the Federal Endangered Species Act and the Clean Water Act. ODOT supplied these maps to all districts for use by biolo- gists, planners, and maintenance managers. Laminated Restricted Activity Zone Maps for maintenance use a sim- ple color-coding scheme of green and red to indicate, for each major class of maintenance activity (e.g., surface and shoulder work, vegetation management, snow and ice removal), whether or not that activity should be restricted along the left or right side of a given 0.01-mi segment of highway. For approximately the same cost as field surveys, ODOT produced better quality data that were less subject to indi- vidual interpretation and covered a much larger analysis area—1,000 ft from the roadway centerline, without concern for access and trespass issues. By using remote sensing tech- niques to collect and map data, ODOT recognized significant savings, both in cost and time. The library of GIS data resulting from the project has given ODOT’s regional staff a detailed environmental inventory of ecological resources, facilitating consideration of sensitive natural resource features when planning and designing transportation system improvements. The maps have proven to be a reliable, desktop scoping tool. The GIS system, data layers, and existing modeling routines facilitate easy updating as new information and aerial photography becomes available. ODOT is now developing an Internet- based application to enable wider desktop access to the information. Because the inventory data are digital and eas- ily transferable between agencies, ODOT can also easily share these data and streamline communication processes

37 New York State Department of Transportation’s Plant Database NYSDOT’s plant database is updated annually with occur- rences mapped in GIS for four base species and additional ones in some regions. Detailed information on more species is being collected by volunteers and partners within the Adiron- dack Park. Sites are prioritized for management and updated manually. A field coordinator performs quality control for the system. NYSDOT is incorporating invasive species inventory with National Pollutant Discharge Elimination System outfall mapping, herbicide recertification and application, and other ongoing departmental activities. NYSDOT’s database is avail- able for sharing with other DOTs by contacting the agency. Information collection forms for the database are included in this report in Appendix C. with the National Marine Fisheries Service, the Oregon Department of Fish and Wildlife, FWS, and the U.S. Army Corps of Engineers. ODOT’s Resource and Restricted Activity Zone Maps were also key to negotiation of pro- grammatic consultation for maintenance operation activities with the National Marine Fisheries Service (now NOAA Fisheries), under the federal Endangered Species Act. Specifically, ODOT received an exemption under 4(d) of the Endangered Species Act, allowing crews to perform routine road maintenance without having to consult with NOAA Fisheries on individual actions. ODOT is also exploring real-time GPS connection to maintenance vehicles, as well as herbicide application spray booms to automatically acti- vate and deactivate applicators as needed to avoid affecting sensitive resources including streams, wetlands, or rare plant populations.