Recently I sent a letter on behalf of the NEC board to Humboldt Bay National Wildlife Refuge Manager Eric Nelson, expressing our concerns about their decision to certify a Categorical Exclusion under the National Environmental Policy Act (NEPA) for use of the herbicides glyphosate and imazapyr at the Lanphere Dunes Unit of Humboldt Bay National Wildlife Refuge. This was done with almost zero public notice or involvement.
This was a violation of the intent of the National Environmental Policy Act (NEPA) which calls for full public involvement in these types of decisions. The excuse for this lapse was to treat the invasive European beach grass, Ammophila arenaria. While we wholeheartedly support the restoration of this inherently dynamic ecosystem that shifts as weather and vegetation changes, the NEC believes strongly that there should be more public involvement and discussion if chemical treatments are considered
in the future.
Though we understand the difficulty in removing beachgrass as a precursor to restoration with native plants, we seriously question the use of a Categorical Exclusion to accomplish this action. The Environmental Assessment/Finding of “No Significance” for this project contains no mention of herbicide use, and since chemical methods were not considered or proposed, the public has been denied the opportunity to comment on such methods.
The March 10, 2016 Categorical Exclusion states, we believe erroneously, that the project does not “have highly controversial environmental effects or unresolved conflicts concerning alternative uses of available resources [NEPA section 102(2) (E)].” Use of this Categorical Exclusion is in conflict with the findings of the more complete Spartina Programmatic EIS, which found that the use of herbicides clearly raised public concerns. At minimum, use of the herbicides should certainly have triggered a more robust public discussion and, in this case, where the treatment area was extremely small, alternatives such as volunteers to remove the new sprouts might have been adequate. We cannot find that any such notification or discussion ever occurred.
We believe the action is based primarily on expediency of the timing for treatment and ignores the full spirit of NEPA by neither clearly identifying the size of the area to be treated (usually critical to limiting the nature of the action) nor limiting this to a one-time application for circumstances that cannot be predicted for future treatments (i.e., lack of funds or staff).
By adopting a Categorical Exclusion, the agency chose to minimize public input and response to concerns that have clearly been identified during previous public comment periods.
The Northcoast Environmental Center has formally requested that U.S. Fish and Wildlife Service reach out to all stakeholders including the NEC and its member groups, well in advance of any future chemical treatments associated with this restoration plan. This type of full public discussion would certainly be educational and might, in fact, lead to alternative treatments. In addition, the NEC Board of Directors has invited staff of the Humboldt Bay National Wildlife Refuge to participate in a meeting with members of our Board to further discuss our concerns.
-Larry Glass, NEC Executive Director and Board President