Best Management Practices
Practices that Avoid or Minimize Impacts to Listed Species and Critical Habitats
Federal agencies must ensure actions are not likely to jeopardize the survival of listed species nor adversely modify critical habitats. Best management practices (BMPs) are intended to reduce adverse effects to wildlife, plants, and their habitats. The following list of BMPs includes general measures as well as nationwide standard conservation measures intended to reduce impacts to listed species and associated critical habitats.
All BMPs should be reviewed before any rapid response action to identify those BMPs that would avoid and minimize take. All BMPs pertinent to a specific control action should be reviewed during discussions initiating the emergency consultation process with the USFWS and in advance of the action to ensure optimal protections for listed species.
General Best Management Practices
1. Properly Handle and Remove Hazardous and Solid Waste
a. Provide enclosed solid waste receptacles at all project areas. Non-hazardous solid waste (trash) would be collected and deposited in the on-site receptacles. For more information about solid waste and how to properly dispose of it, see the EPA Non-Hazardous Waste website.
b. Develop a written contingency plan for all project sites where hazardous materials (e.g., pesticides, herbicides, petroleum products) will be used or stored. To clean up small-scale accidental hazardous spills, ensure appropriate materials/supplies (e.g., shovel, disposal containers, absorbent materials, first aid supplies, clean water) are available on site. Report all hazardous spills. Emergency response, removal, transport, and disposal of hazardous materials shall be done in accordance with the U.S. Environmental Protection Agency. Store at least 150 feet from surface water and in areas protected from runoff hazardous materials and petroleum products in approved containers, or chemical sheds.
c. All chemicals shall be handled in strict accordance with label specifications. Proper personal protection (e.g., gloves, masks, protective clothing) shall be used by all applicators. The material safety data sheet (MSDS) from the chemical manufacturer shall be readily available to the project coordinators for detailed information on each chemical to be used, in accordance with applicable Federal and State regulations concerning the use of chemicals.
d. To protect the health of workers, pesticide applicators shall wear appropriate personal protective gear (e.g., clothing, gloves, and masks) in accordance with state applicators’ licensing requirements when applying, mixing, or otherwise handling pesticide.
e. Avoid chemical contamination of the project area by implementing a spill prevention, control, and countermeasures (SPCC) plan. A copy of the plan will be maintained at the work site.
i. Outline BMPs, responsive actions in the event of a spill or release, and notification and reporting procedures. Take corrective actions in the event of any discharge of oil, fuel, or chemicals into the water, including:
a. Containment and cleanup efforts will begin immediately upon discovery of the spill and will be completed in an expeditious manner, in accordance with all local, state, and federal regulations. Cleanup will include proper disposal of any spilled material and used cleanup material.
b. The cause of the spill will be determined, and appropriate actions taken, to prevent further incidents or environmental damage.
c. Spills will be reported to the appropriate state and/or federal agency.
d. Work barges will not be allowed to ground out.
e. Excess or waste materials will not be disposed of or abandoned waterward of ordinary high water or allowed to enter waters of the state. Waste materials will be disposed of in an appropriate manner consistent with applicable local, state, and federal regulations.
f. Materials will not be stored where wave action or upland runoff can cause materials to enter surface waters.
ii. Outline the measures to prevent the release or spread of hazardous materials found on site and encountered during construction but not identified in contract documents, including any hazardous materials that are stored, used, or generated on the construction site during construction activities. These items include, but are not limited to gasoline, diesel fuel, oils, and chemicals.
iii. Maintain at the site applicable spill response equipment and material.
2. Minimize Disturbance and Restore Disturbed Areas
a. Minimize construction impacts on fish and wildlife, including avoiding unnecessary disturbance to habitats by driving on existing roads, working only in the required area, and minimizing direct disturbance to streams and open water sources. Maximize use of disturbed land for all project activities (i.e., siting, lay-down areas, and construction).
b. Complete restoration activities at individual project sites in a timely manner to reduce disturbance and/or displacement of wildlife in the immediate project area. Minimize project creep by clearly delineating and maintaining project boundaries (including staging areas).
c. Use existing roadways or travel paths for access to project sites.
d. Avoid the use of heavy equipment and techniques that will result in excessive soil disturbances or compaction of soils, especially on steep or unstable slopes.
e. To avoid direct and indirect adverse effects to listed plants and habitats, delineate and cordone off the areas, and communicate to equipment operators and project participants/volunteers.
f. Replant bank stabilizing vegetation that is removed or altered because of restoration activities with native vegetation and protect it from further disturbance until new growth is well established.
g. Source seedlings, cuttings, and other plant propagules for restoration from local ecotypes.
h. Implement pre-watering, and other preparations at project site and staging areas, prior to ground-disturbing activities, to maintain surface soils in stabilized conditions where support vehicles and equipment will operate.
i. Apply water, or an approved dust palliative during ground-disturbing activities including clearing, grubbing and earth moving activities, to keep soils moist throughout the process and immediately after completion.
j. Incorporate the use of sediment barriers, or other erosion control devices, downstream of ground-disturbing activities.
k. Limit stream crossings to designated and existing locations.
l. Obliterate all temporary roads and paths upon project completion
3. Comply with all Terms, Conditions, and Stipulations in Permits and Project Authorizations—Eliminate or reduce adverse effects to endangered, threatened, and sensitive species and their critical habitats.
4. Protect Wetland Areas
a. Avoid contaminating natural aquatic and wetland systems with runoff by limiting all equipment maintenance, staging laydown, and dispensing of fuel, oil, etc., to designated upland areas, i.e., equipment shall be stored, serviced, and fueled a minimum of 150 feet from aquatic habitats and other sensitive areas.
b. Implement sedimentation and erosion controls, when and where appropriate, during wetland restoration or creation activities to maintain the water quality of adjacent water sources.
c. Avoid removal of riparian vegetation.
d. Complete any construction associated with the project onsite in compliance with each state's water quality standards, including:
i. Petroleum products, fresh cement, lime, concrete, chemicals, or other toxic or deleterious materials will not be allowed to enter surface waters or onto land where there is a potential for reentry into surface waters.
ii. Fuel hoses, oil drums, oil or fuel transfer valves, fittings, etc., will be checked regularly for leaks, and materials will be maintained and stored properly to prevent spills.
iii. When fill (e.g., gravel) is required in the staging area and water access location, only clean rock is permitted, and all fill will be removed post-action. Fill would not be permitted to enter the water. During construction activities, the minimum amount of vegetation will be removed to gain access. Wetland sites will be avoided to the extent possible.
5. Protect Special Status Species and Wildlife
a. Implement, to the extent feasible, habitat management activities during the non-breeding/nesting season for waterfowl. When project activities cannot occur outside the bird nesting season, conduct surveys prior to scheduled activity to determine if active nests are present within the area of impact and buffer any nesting locations found during surveys.
b. Wildlife surveys, and corresponding needed rescue/salvage, should occur if the creation of a riparian access route is necessary. Trained biologists would conduct all manner of surveys necessary to identify the abundance and distribution of ESA-listed taxa. Where possible, all nest trees/shrubs would be avoided, and all mobile wildlife would either be relocated from the immediate access route or encouraged to depart the site to avoid and minimize impacts to individuals and species and their habitats. In most cases, electrofishing would be employed as a fish salvage technique prior to treatment using the guidelines and protocols identified in Reynolds (1996) and NMFS (2000). Mollusks and crustaceans would not be salvaged.
c. To protect special status species:
(a) Close trails, roads, and/or areas to ensure that human access does not disturb special status species;
(b) Prior to habitat and ground disturbing activities, evaluate potential habitat for special status species and, if appropriate, conduct presence/absence surveys and take additional mitigation measures (e.g., avoid location, change timing of action), if necessary, to ensure that planned activities do not affect special status species;
(c) Implement all terms and conditions resulting from section 7, Endangered Species Act consultation; and
(d) Additional conservation measures for plants—If one or more ESA-listed plant species are present and may be affected by the action, the project may require protective measures and corresponding consultation. All appropriate measures will be taken to avoid introduction of invasive plants and noxious weeds into the action area.
6. Protect Cultural Resources
Cultural resources should be identified and avoided in all treatment areas. If cultural resources are discovered during activities, all work in the immediate vicinity of the cultural resource should cease until an archaeologist designated by the lead action agency surveys and records the location, and issues a written notice to resume activities. Generally, best practices include avoidance, minimization, mitigation, monitoring, and standard measures to reduce visual contrast (BLM 2017).
Activities that involve hand labor, such as thinning brush, are least likely to impact cultural resources, compared to ground disturbing activities that use mechanized equipment.
a. Minimize potentially adverse effects to cultural resources through cultural resource reviews, surveys, and compliance with section 106 of the National Historic Preservation Act (NHPA).
b. Federal lands with archaeological and historical resources receive protection under federal laws mandating the management of cultural resources, including, but not limited to, Archaeological Resources Protection Act (ARPA), AHPA, Native American Graves Protection and Repatriation Act of 1990 (NAGPRA), and National Historic Preservation Act (NHPA). Stop ground-disturbing activities if cultural resources are discovered on federal lands. Do not resume activities until authorized in writing by the federal government. Follow state archaeological reporting guidelines on all state lands.
7. Monitor Post-Action—Monitoring is required during restoration project implementation and for at least one year following the action to ensure that restoration activities implemented at individual project sites are functioning as intended and do not create unintended consequences to fish, wildlife, and plant species and their critical habitats or adversely impact human health and safety. Corrective actions, as appropriate, shall be taken to address potential and existing adverse effects to fish, wildlife, and plants.
8. Train Personnel—Provide environmental awareness training program to all personnel to brief them on the status of the special status species and the required avoidance measures.
9. Notify the Public and Post Action Areas
a. Temporarily close staging and action areas to public use for public safety. Make information available to the public on the purpose and timing of the closure.
b. Flag and identify sensitive resource areas, equipment entry and exit points, road and stream crossings, staging, storage and stockpile areas, and no-spray/application areas and buffers.
10. Ensure Responsible Use of Clean Equipment
a. Provide vehicle wash stations prior to entering sensitive habitat areas to prevent accidental transport of non-native and invasive species.
b. Avoid soil contamination by using drip pans underneath equipment and containment zones at construction sites and when refueling vehicles or equipment.
c. Consistently check equipment for leaks and other problems that could result in the discharge of petroleum-based products or other material into the water or riparian area.
11. Protect the Integrity of the Water Body
Contain the in-water treatment area by installing a vertical floating curtain barrier that extends from the surface of the water to the bottom of the water body, restricting flow and open water exchange. The barrier outlining the treatment area should contact the shoreline and encompass any existing public boat ramps, docks, or other infrastructure.
12. Protect Disturbance/Effects to Listed Species During Key Vulnerable Life History Stages—The following in-water work treatment windows are designated for each state by state and federal agencies. The guidelines restrict in-water work during certain periods to protect fish and wildlife resources during vulnerable and critical life stages. In-water work should be conducted only during the approved in-water work window, as described by each of the four CRB states or federal agencies. If an action is proposed outside of the recommended windows, the action entity should receive approval for all appropriate variances to these windows to avoid any potential effects on listed species and their habitats. Also note that each state has designated state-listed species in addition to federal listed species and critical habitats. Contact your state fish and wildlife agency to ensure protections for state-listed species are implemented.
The Washington Department of Fish and Wildlife (WDFW) provides recommended treatment windows (last revised on 2/23/2016) for aquatic herbicide treatment. WDFW recognizes that aggressive treatment of emerging invasive species may sometimes be advisable during these treatment windows. In these situations, the Washington Department of Ecology and the permittee must consult WDFW to determine ways to minimize or mitigate treatment impacts to fish and wildlife. Contact the local WDFW regional office. The annual treatment window is July 15–October 31, unless the specific water body is listed in the treatment window table. If an action is proposed outside of this window, the Department of Ecology and the permittee must consult WDFW to determine an alternate timing window or if priority species are present, potential species impacts and appropriate mitigation.
ODFW, under its authority to manage Oregon’s fish and wildlife resources, developed the Oregon Guidelines for Timing of In-Water Work (last revised in 2000) to assist the public in minimizing potential impacts to important fish, wildlife, and habitat resources. The guidelines are based on ODFW district fish biologists’ recommendations. Primary considerations are given to important fish species including anadromous and other game fish and threatened, endangered, or sensitive species. Time periods are established for in-water work to avoid the vulnerable life stages of these fish including migration, spawning, and rearing.
ODFW, on a project-by-project basis, may consider variations in climate, location, and category of work that would allow more specific in-water work timing recommendations. The appropriate ODFW district office will make these more specific timing recommendations through the applicable planning or permitting process. ODFW in-water timing guidelines are typically applied to activities that are proposed in streams, rivers, upstream tributaries, and associated reservoirs and lakes. The timing guidelines are not typically applied in ocean waters or wetlands.
The US Fish and Wildlife Service has established in-water timing work with the US Army Corps of Engineers. In bull trout feeding, migrating, overwintering habitat: In-channel work can only occur from July 1 to September 30.
In bull trout spawning and rearing habitat: In-channel work can only occur from May 1 to August 31.
National Marine Fisheries Service (NMFS) staff provide guidelines for in-water work in Idaho.
Instream work windows for all other streams in the project area (Lower Salmon River, Lower Snake River, and Clearwater River Basins).
13. Mitigation—Any native fish and wildlife habitat destroyed in the development of an access corridor would be restored with appropriate, native species once the final treatment is completed. Replacement plant species will be recommended by a local state botanist. No ground disturbance outside of the area previously opened for treatment site access is be required. Mitigation methods may include:
Mowing the site for ease of planting and to reduce initial plant competition during establishment.
Removal of any fill using proper equipment.
Planting to include hand tools, a power auger, hydraulic auger operated by equipment, or stinger operated by equipment. A 1 m buffer of herbaceous vegetation will be left between the shoreline and upland plantings to prevent potential sediment runoff.
Installing weed matting or plant protection material to keep competition down while plants establish, and keep any loose sediment in place.
Seeding, either via top seeding or seed drill depending upon herbaceous species and site characteristics.
Seed native grasses, forbs, and pollinator species as available.
Silt fence or weed-free straw will be used to contain runoff, if necessary.
Monitoring plant establishment with adaptive management to ensure appropriate plant survival of 80% at 24 months.
Best Management Practices to Avoid the Spread of Invasive Species
Agencies throughout North America institute best management practices to reduce the likelihood of introducing invasive species, particularly via plant seed or propagules, during maintenance, construction and vegetation management activities. The following general best management practices, adapted from a variety of sources (Creative Resource Strategies, LLC 2019; Elwell and Phillips 2016; Halloran et al. 2013, US Forest Service 2012; British Columbia Ministry of the Environment 2011), can help prevent the spread of invasive species.
A. Education and Support
Knowledge of invasive species and techniques to avoid their spread is critical to the implementation of all BMPs.
A.1 Provide trainings and educational materials for staff and contractors.
Conduct training sessions on sanitation procedures for other equipment.
Provide brochures and other materials on weed identification.
Provide checklists and instructions for execution of BMPs in the field.
Communicate the impact of invasive species and the importance of prevention.
B. Planning and Records
B.1 Include an invasive species risk evaluation as a component of initial project planning.
Evaluate the risk of:
Spreading invasive seeds and other propagules from the project site to new areas. Identify invasive species in and surrounding the site. Identify control and sanitation measures that would reduce risk.
Bringing invasive propagules into the site during project activities. Consider any use and transportation of project vehicles outside of the project area. Identify sanitation measures that would reduce this risk.
B.2 Incorporate design components that minimize the movement of invasive propagules into or out of the site.
B.3 Incorporate sanitation and invasive control measures into plans, budgets, and contracts.
Consider the use of specialized gear and clothing, tools for sanitation, and any staff training.
Allocate time for prevention and sanitation activities.
B.4 Schedule activities to minimize the potential for spread of invasive propagules into or out of the site.
Consider life stages of invasive plants. Avoid activities that may spread propagules when plants are fruiting.
Consider the toxicity, ecological fate, persistence, and unintended consequences of pesticides. Consider timing to avoid impacts to listed, or at-risk species, pollinators, nesting birds and mammals, and to trail users, medicine and food harvesters, and other public use.
B.5. Record observations of all suspected priority invasive species and others of concern. Note the date, location in as much detail as possible, approximate size of the patch, species identity if known, and stage of the plant (flowering, fruiting, etc.).
C. Soil Disturbance
Disturbing soil creates opportunities for the establishment of weed species.
C.1 Minimize soil disturbance—Whenever possible, activities should be avoided in areas containing fruiting, or rhizomatous invasive plants.
When soil must be disturbed, use proper erosion control practices—Minimize soil disturbance in areas containing invasive plants. Should invasive plants be detected early, use a certified pesticide applicator and spray within limits of pesticide permit, and/or take other actions as may be deemed appropriate.
Stabilize disturbed soils as soon as possible by seeding, mulching or using stone or other materials that are free of invasive plant materials. Site-specific revegetation efforts should address site preparation, species selection, and overall maintenance of the area. The activities to reduce invasive plants are intended to complement other practices addressing erosion control, proper drainage, and protecting infrastructure. Materials, such as fill, loam, gravel, mulch or hay should not be brought into project areas from sites where invasive plants are known to exist or have existed.
C.2 Manage and contain any water runoff, which can carry weed propagules.
C.3 Plan for cleaning time.
D. Project Materials
Project materials are common dispersal vectors for weed propagules to new locations. Soils, erosion control materials (especially if reused), landscape materials, water, and other materials can all contain propagules. Use of these BMPs can prevent the introduction of weed species to a project site through contaminated materials.
D.1 Use project materials that are known to be weed free.
Whenever possible, re-use weed-free materials from onsite rather than importing new materials. When re-using materials is not possible, obtain materials from local vendors, ideally those offering weed-free materials. Inspect materials for weed propagules.
Use certified weed-free seed. Monitor for weeds after the installation of new materials. Treat any state/local-listed priority weeds found at early stages to maximize effectiveness of control.
D.2 Prevent contamination and germination of weed propagules in unused stockpiles of materials.
Cover exposed materials to protect from wind and rain. Inspect stockpiles prior to use. Treat any weeds found before the material is used.
D.3 Prevent contamination when transporting project materials.
Never move materials from a weed-infested to an un-infested location.
Cover materials during travel to prevent either contamination of clean materials, or spread of propagules from infested materials.
E. Travel and Maintenance of Equipment—Disinfection Protocols
Workers can spread invasive species as they travel from site to site. These BMPs should be implemented at all visits to sites known to, or suspected to, contain invasive species. All vehicles should be examined for potential weed propagules: mud, soil, vegetation on vehicle undercarriages, wheel wells, bumpers and grills. Wearing appropriate clothing, boots, and other gear, and cleaning them before leaving a site can prevent them from transporting weeds to new sites. Following these BMPs will minimize introduction of invasive species by equipment, vehicles, and people traveling among project sites.
E.1 Locate and use a staging area that is free of invasive plants.
E.2. Avoid driving off-road, or parking in areas infested with invasive species.
Arrange routes to travel to uninfested sites first, when the vehicle is clean. Visit weedy/infested sites last.
E.3. Inspect and Clean
Designate cleaning areas for tools, equipment and vehicles—Ideal locations include paved or sealed surfaces. Avoid waterways and sensitive habitat areas. If equipment must be used or staged in areas where invasive plants occur, all equipment, gear (i.e., boots), machinery, and hand tools should be cleaned of all viable soil, plant, and animal material before leaving the project. Acceptable methods of cleaning include but are not limited to:
Portable wash station that contains runoff from washing equipment (containments must be in compliance with wastewater discharge regulations). If on-site cleaning is not an option, clean equipment at a commercial car wash facility. For vehicles and other large equipment, pay particular attention to the undercarriage and treads of tracks and tires.
High pressure air.
Brush, broom or other tool (used without water) – this is likely to be the BMP most practiced to avoid unintentional transport of invasive species as equipment moves from site to site.
Aquatic sites— Before leaving any aquatic site or any site in wet condition, thoroughly remove all organic matter (e.g., mud, plants, algae) from nets, sampling devices, boots (especially the tread), and any other equipment or clothing that has come into contact with water or aquatic sediments.
Watercraft—Inspection and decontamination procedures for watercraft entering and leaving waterbodies should follow the Uniform Minimum Standards and Protocols for Watercraft Inspection and Decontamination Programs for Dreissenid Mussels in the Western United States (Elwell and Phillips 2016).
Firefighting activities—US Forest Service and Bureau of Land Management prevention activities associated with the transport of water during firefighting activities should be used to prevent the spread of invasive species, sanitize equipment, and address disposal and safety concerns.
Working in water bodies:
Sample from least to most invasive species-contaminated areas within the waterbody, for example, sample upstream to downstream or from areas of less weed growth to dense weed growth.
Minimize wading and avoid running boats onto sediment. For example, use bank sampling poles instead of wading.
Avoid getting plants and sediment inside boats or other sampling gear.
Use a catch pan underneath dredges, etc., to keep potential invasive species off boat decks and out of bilges.
Clean, Drain, Dry
CLEAN – Remove any visible vertebrates, invertebrates, plants, plant fragments, seeds, algae, and dirt. If necessary, use a scrub brush and rinse with clean water either from the site or brought for that purpose. Continue this process until the equipment is clean.
DRAIN all water in bilges, samplers, and other equipment that could hold water before leaving the site.
DRY – Fully wipe down all equipment until dry.
Decontaminate, if possible—Decontaminate using options for aquatic invasive species (Elwell and Phillips 2016).
F. Transport & Disposal of Plants
After invasive plant removal, plant parts must be properly disposed of to prevent establishment in other locations.
F.1 When disposing on site, minimize the chance of viable material spreading by choosing a location where viable plant material will be contained, buried, or destroyed. Conduct monitoring at and near debris piles to treat any weeds that may have spread during the disposal and degradation process.
Drying/Liquefying: For large amounts of plant material, or for plants with rigid stems, place the material on asphalt, and under tarps, or heavy plastic to prevent the material from blowing away. For smaller amounts of plant material, or for plants with pliable stems, bag the material in heavy- duty (3 mil or thicker) garbage bags. Keep the plant material covered or bagged for at least one month and up to 3 months. Material is nonviable when it is partially decomposed, very slimy, or brittle. Once material is nonviable, it can be disposed of in an approved landfill or brush pile.
Brush Piles: Plant materials from most invasive plants can be piled on site to dry. However, for some species, care must be taken to pile stems so that the cut surfaces are not in contact with soil. This method is not recommended for any invasive plant with seeds or fruit attached, unless plants can be left within the limits of the infestation.
Burying: Plant material from most invasive plants can be buried a minimum of three feet below grade. This method is best used on a job site that is already has disturbed soils.
Burning: Plant material should be taken to a designated burn pile. (All necessary permits must be obtained before burning).
F.2 Herbicides—If herbicides are applied at the disposal sites, only licensed applicators are allowed to apply herbicide treatments.
F.3 When disposing off site, select appropriate disposal locations and transport properly.
Invasive plant material must be covered during transport and transport vehicles swept clean at the transported location.
G. Revegetation and Landscaping
Proper revegetation and landscaping work can create weed-resistant plant communities. Without proper care, however, landscaping activities and materials can serve as vectors for invasive species.
G.1 Select vegetation appropriate to the site to maximize weed resistance.
G.2 Use plants from a local source.
Use local ecotypes whenever possible for best plant establishment. Verify the taxonomy of species to be planted. Ensure all species to be used are approved.
G.3 Mitigate the risks of unintentional invasive species introductions during site preparation activities.
Whenever possible, time site preparation activities when invasive species are not producing seed.
Treat any invasive species found during the site preparation process.
Minimize soil disturbance to the amount necessary for planting.