A06_Attachment_0002_Hazardous_Tree_Plan_440443365_FRSP_HTR.pdf

FRSP Hazardous Tree Abatement Plan

June 2024

Introduction

Fredericksburg & Spotsylvania National Military Park (FRSP) contains numerous trees as natural or landscape components, many of which occur within public use areas. As important elements of both the natural and cultural landscape, trees should be retained when consistent with the management objectives of the park. However, there are many areas in which trees may pose a special risk to personal safety and property. These include visitor use areas (wayside exhibits, parking lots, picnic areas, visitor center grounds), transportation corridors (park roads, pedestrian trails), utility corridors, and areas where the park bounds private property. The purpose of a Hazard Tree Abatement Plan is to provide a systematic method for mitigating tree hazards to avert damage to people or property while minimizing impacts to natural and cultural resources.

Hazardous tree work at FRSP may be conducted by park staff, contractors, National Park Service (NPS) fire management staff, utility companies, Virginia Department of Transportation (VDOT), and authorized volunteers (Friends groups, Potomac Appalachian Trail Club [PATC]). All parties are responsible for abiding by this Hazard Tree Abatement Plan unless exceptions are approved in advance by the park Superintendent.

Definitions

Hazardous Tree: A dead or live tree which has a significant structural defect, damage, or lean that predisposes it to failure and puts people or property at risk of injury or damage.

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Statutory and Policy Guidance

The National Park Service recognizes its obligation to protect the visitor as its primary responsibility taking precedence over all other management activities (Management Policies 2006). However, the NPS also has an obligation to manage its resources in such a manner that they are left unimpaired for future generations. This requires an approach that prevents hazards in high use areas without unduly manipulating the natural environment and historic landscapes.

Guidance for tree maintenance, management, and management of risk for damage to property and protection of public safety are based on:

• Servicewide policy (NPS Management Policies 2006, Chapters 4 and 9)

• NPS-77, “Natural Resource Management”

• NPS-28, “Cultural Resource Management”

• DO-50B, “Occupational Health and Safety Program”

• DO-50C, “Public Risk Management Program”

• Park-specific guidance, FRSP Resource Management Plan

Hazardous Tree Inspections

An effective hazard tree management program requires periodic, thorough, and documented inspections of developed sites and other public use areas. Each tree that has a visible defect and is within striking distance of a target should be considered a potential hazardous tree and should undergo periodic inspections. Following inspections, funding will be sought to mitigate the hazards. Additional inspections may be required after heavy storm events.

In order to maintain the park in a "reasonably safe" condition, regular inspections of high use areas are required. The visitor cannot reasonably expect the entire park to be free of all hazards of any sort, so the park has identified different management zones based on the probability of trees causing damage to property or threatening visitor’s safety. Each management zone should have surveys for which the frequency and intensity of inspection is commensurate with the hazard potential. The areas of greatest concern are where a stationary target is presented (people or structure). For moving targets, the percentage of time the target is within striking distance should be considered.

The four Hazard Tree Management Zones (HTMZ) and the inspection standards specific to each are as follows:

1. Developed Areas include high visitor use areas such as picnic areas, parking lots, wayside exhibits, buildings, monuments, and formally landscaped grounds. A systematic inspection of all developed sites within the park will be performed by the park on an annual or as needed basis and will be documented by condition assessments and work orders created in the Facility Management Software System (FMSS) for work needing to be performed. To distinguish between living and dead material, these surveys should be

FRSP Hazardous Tree Abatement Plan 2 December 2023 performed after spring green-up and before leaf-fall in autumn. Removal of trees or pruning of limbs will be limited to only those within striking distance of designated developed areas (up to 100 feet). Many of these developed areas are considered significant cultural landscapes and the vegetation within may be identified as contributing features of the historic landscape.

2. Transportation Corridors include roads maintained by the park or VDOT and pedestrian trails. Removal of transportation corridor trees will be limited only to those which are within striking distance of the road or trail (up to 100 feet). Trees that clearly lean away from the road or trail or are of insufficient size to cause concern will not be removed unless necessary to ensure safety of workers in the area.

Roadside and pedestrian trail hazards are much more numerous than those in developed sites. However, the probability of any tree striking a moving vehicle or pedestrian is much lower than a stationary building or visitor in a public-use area. Many park roadsides are lined with shallowly rooted shortleaf and Virginia pines, resulting in frequent episodes of several trees blocking roads as a result of heavy storms. These factors require a more cursory method of inspection than in developed areas. Each year, the battlefields are inspected/reviewed.

Roadside trees are inspected using the same analysis of defects as in developed areas.

Those trees which are deemed hazardous enough for immediate removal or needing other corrective actions will be marked. As with developed areas, each survey will be documented on condition assessment forms and work orders created if needed in FMSS.

If no hazards are found, this will also be documented accordingly. The level of detail in documentation may depend on availability of trained staff.

3. Utility Corridors include areas where utility infrastructure may be impacted by adjacent trees. Due to the urban and suburban surroundings and sprawling nature of FRSP park units, utility corridors intersect park land in multiple locations. These include electrical, gas, water, sewer, and communication utilities, some of which are maintained by park staff but the majority of which are maintained by utility companies (i.e., Dominion, Rappahannock Electric Cooperative, Columbia Gas, Verizon). Many of these corridors are surrounded by mature forest, resulting in the potential risk from falling trees and limbs to damage utility infrastructure.

Periodic inspection and maintenance of utility corridors and adjacent hazards is the responsibility of the companies who own the infrastructure. These entities have the authority to maintain these corridors through designated easements or rights-of-way (ROW). Special Use Permits (SUP) are issued by the park for maintenance activities such as removal of hazardous trees; guidance and standards in this document apply and are included in the terms and conditions of the SUPs.

4. Property Boundaries include those areas of the park that border private property. FRSP has over 110 linear miles of boundary throughout all the park units, much of which is

FRSP Hazardous Tree Abatement Plan 3 December 2023 bordered by private property that includes structures and landscaped areas. While the park generally does not have the capacity to conduct regular inspections of these boundaries, trees of concern on park property are often reported by neighboring property owners and addressed expeditiously by park staff. Park neighbors are permitted to trim branches hanging over their land from trees on park property as far back as the boundary line.

Only NPS staff having the necessary training, skills, and abilities or other designated personnel to identify and diagnose potential tree hazards, physiological disorders, and insect and disease infestations will conduct inspections and decide on treatments. Contractors or other designated tree professionals conducting inspections and deciding on treatments are required to be ISA Certified Arborists. The forms in Appendix A are intended to assist inspectors in identifying hazardous trees. When work is to be performed by contractors, NPS personnel will identify trees to be removed or pruned and point out locations of the trees prior to contractor arrival.

As previously noted, detailed record keeping is important for evaluating trends, documenting for legal purposes, and reporting for compliance with the Endangered Species Act, Section 7. Each survey will be documented on the condition assessment forms and work orders created if necessary in FMSS. For trees that require limbing or pruning, the tree will simply be identified as needing removal of dead limbs, pruning, or a need for other arboricultural treatment (cabling, etc.). Additional information may be necessary to that found on the inspection form. The level of detail in documentation may depend on availability of trained staff.

Standards for Hazardous Tree Treatments & Safety

Safety:

• Tree removal operations will comply with the OSHA 1910 General Industry Standards and

ANSI Z 133.1 Safety Standards for Arboricultural Operations, NPS Chain Saw policy and all Federal, State, and Local safety requirements, Manual on Uniform Traffic Control Devices (MUTCD) signage and/or VDOT roadway work zone requirements (depending on location, etc).

Access:

• No vehicles will travel over or park within the area generally defined by the canopy of a tree, except if the tree is to be removed and/or if a bucket truck is the only safe means to treat a tree. The root zone of neighboring trees which are not being treated will not be traveled over. Load distribution matting may be used. COR or Park POC will oversee operations.

• Stage equipment and vehicles on paved surfaces when possible. To stabilize any exposed soil caused by off-pavement work, apply straw/mulch and/or seed with a NPS-approved soil mix.

Disposal of debris:

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• Treatment and disposal of cut logs, limbs, and debris will be disposed of in compliance with

NPS Management Policies (2006) and as deemed appropriate by FRSP staff depending on location, HTMZ, available equipment, and proximity to sensitive resources. Options include:

o Load and haul to an authorized dump.

o Leave on site in the vicinity of the cutting area. Cut debris left on site will be bucked and scattered so it is touching the ground as much as possible to encourage faster decomposition.

o Chip trees and branches under 8” diameter and haul off site.

o Chip trees and branches under 8” diameter and distribute in the adjacent forest. Chips will be distributed as best as possible and in a thin layer to allow for vegetation growth, no deeper than 3-4”. Chips will not be left piled up against the trunks of standing trees, as this may cause damage to those trees and result in further hazards.

• Debris will not be left stacked, windrowed, or left in a "pile".

• Debris will not be felled or scattered in streams or wetlands.

• Clear debris from roads, walkways, and trails before leaving the area.

Treatment of Stumps:

• Where a tree has been uprooted and there is a “root ball”, the stump will be turned back upright in order to preserve what was uprooted.

• All stumps will be cut to a height not to exceed 4” from grade.

• In developed or historic areas such as house sites and visitor use areas stumps will be ground to a depth of at least 3 inches but no more than six inches below the ground surface and clean, weed-free soil will be used to bring the area flush to the surrounding terrain.

Pruning:

• Trees will be pruned to maintain and/or improve health and structure and to remove visible hazards with potential for damage to property or personal injury. Removal will include but is not limited to interfering/objectionable branches, deadwood, heavy or weak horizontal branches, and weak crotches. Weak crotches are defined as split or rotted wood between two trunks of limbs that may break and fall during high wind.

• The work to be performed under this section will include pruning trees in accordance with the American National Standard for Arboricultural Operations Pruning, Repairing, Maintaining and Removing Trees and Cutting Brush – Safety Requirements – ANSI Z133.1- 2017.

• Clearance:

o Branches hanging over tour roads, parking areas, and roadways will be cut back to a height of no less than 13.5 feet above the ground or as approved by the COR.

o Branches hanging over sidewalks and trails will be cut back to a height of no less than 10 feet above the ground or as approved by the COR.

FRSP Hazardous Tree Abatement Plan 5 December 2023 o Branches hanging over buildings will be cut back to ensure they are out of the footprint of the building and any associated walkways.

• Proper cutting:

o All cuts should be made sufficiently close to the parent stem so that healing can readily start under normal conditions. Do not leave stubs. Do not cut into the branch collar.

o Lowering of pruned branches may require ropes to ensure that the tree is not injured during fall.

Resource Protection Measures

• Whenever any trees of historical importance (see maps in APPENDIX B) are deemed to be hazardous and require action, the park's Cultural Resource Specialist will be consulted to ensure the actions taken will be the least impactful to the cultural landscape and cultural resources. If an individual tree is identified as a contributing feature of the cultural landscape, the park will consider methods and feasibility of mitigating the hazard by pruning or stabilization prior to electing for removal. Any existing Cultural Landscape Reports will be consulted for guidance.

• If concealed archeological resources are encountered during project activities, all necessary steps will be taken to protect them and the FRSP Archeologist will be notified immediately.

• Trees and debris will not be felled or thrown onto earthworks or into any depressions or trenches. See APPENDIX B for maps of earthworks and other historic features in the vicinity of potential Hazard Tree Management Zones.

• Soil disturbance will be minimized to the greatest extent possible to reduce the potential for disturbing archeological resources, reduce disturbance to native plants, and reduce the potential for the introduction or spread of invasive non-native plant species.

• Trees not occurring within an HTMZ as defined above are not considered for removal or trimming as part of this Plan.

• Care will be taken not to disturb any wildlife species (reptiles, migratory birds, raptors, or bats) found nesting, hibernating, estivating, or otherwise living in, or immediately nearby, worksites. Consult with the park NR Manager if injured or otherwise problematic wildlife is encountered.

• Where they do not present a hazard or adversely impact historic landscapes, retain dead snags to provide wildlife habitat.

• Tree removal will occur between November and March to avoid impacts to Federally protected bats and migratory birds, unless the individual tree poses an “imminent threat to life or property” (per US Fish & Wildlife Service [USFWS] guidance). If extenuating circumstances exist and work must be scheduled during the April to October time frame, avoid June and July when Endangered bat pups could be present in roost trees. Potential roost trees are any dead or live tree at least 3 inches in diameter at breast height (DBH) that have cracks, crevices, cavities, or exfoliating bark. If timing restrictions cannot be met, notify the Natural Resources Program Manager at least 90 days in advance so formal consultation with the USFWS can be completed before work begins.

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• To reduce the chance that invasive non-native plants, spotted lantern fly (SLF), or other harmful organisms will be introduced or spread in the park, all vehicles, equipment, tools, and gear shall be free and clean of soil, vegetation, seeds, egg sacs, and other sources of plant parts, insects, and pathogens when entering the park and before moving from one work site to the next. Cleaning should consist of brushing off and washing with water, will occur off-site prior to entering the park, and will include vehicle frames, tires, tracks, beds, buckets, and other attachments, showing careful attention to the undercarriage and any cracks, crevices, and tire treads. Inspect for spotted lanternfly or have contractors provide self-inspection confirmation before entering the park: spotted-lanterfly-inspection.pdf (virginia.gov), particularly if they are coming from counties that have confirmed infestations (see map Spotted Lanternfly Map - Stop SLF). If SLF are observed during inspection, all living insects and egg masses are to be removed and destroyed and equipment/vehicles shall be pressure washed off-site. CORs and park staff should reserve the right to conduct inspections at any time.

• Preserve and protect all existing vegetation such as trees, shrubs, and grass areas that do not reasonably interfere with work. Limit collateral damage done to other vegetation due to careless operation of equipment, stockpiling of materials, or tracking of grass and other surfaced areas by equipment. Large tree material will be moved in such a way that ground disturbance and damage to existing vegetation is minimized. Do not drag, slide, or push large limbs and trees across the surface.

• After tree removal, areas should approximate their appearance prior to the felling operation and will not cause damage to resources including but not limited to trees, earthworks and markers. Restoration of disturbed areas will require stabilization of substantial areas of disturbed soil, to include the application of straw/mulch and/or NPS-approved seed mix.

Compliance (PEPC 116440)

The park is responsible for conducting reviews of proposed actions, including routine and recurring actions, to address requirements of the National Environmental Policy Act (NEPA), National Historic Preservation Act (NHPA) Section 106, and other applicable federal and state regulations. This document is intended to provide the information needed to conduct a compliance review for routine treatment of hazardous trees at FRSP for a 5-year period.

To fulfill Endangered Species Act (ESA), Section 7 and Migratory Bird Treaty Act responsibilities, the park may need to consult with USFWS Virginia Field Office annually or on the basis of individual project proposals. As the guidance stands currently, timing of tree cutting will impact whether the finding for Endangered bats is “not likely to adversely impact” or “likely to adversely impact”. This determination dictates the level of USFWS consultation required (automated concurrence letter or formal Section 7 consultation). See list of resource protection mitigations above for more information on the process for fulfilling these obligations.

Treatment of trees or limbs not occurring within an HTMZ is not covered under this Plan or the associated compliance review. Tree removal or limbing proposed as part of routine landscape maintenance, new construction, vista rehabilitation, etc. will require separate compliance review.

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APPENDIX A: Hazard Tree Evaluation Forms

Hazardous Tree Checklist

This is a checklist designed to assist in the decision-making process of determining a hazardous tree.

Date:

Location of Tree:

Evaluator:

Please check any of the following that apply:

Root system damage / Uprooting (Root ball coming up, roots appear broken)

Extreme degree of Lean (Tree leaning past 35 degrees)

Excessive damage to tree trunk / Canopy (Cracks, splinters, breaks)

Defects, deadwood, rot, infestation (Fungi, holes, bugs, missing bark)

Extreme weight distribution issues / Uneven (All limbs, branches, leaves on one side of tree)

Entanglement / Hung up.

(Tree resting on another tree or tangled up amongst other tree branches)

Risk of Life / Targets * (High potential for tree to land on motorists, joggers, bikers, animals if it was to fall)

Risk of property damage / Targets * (High potential for tree to land on house, vehicle, shed, fence, power lines, etc.)

*Denotes automatic Hazardous condition if combined with one or more listed defects.

If more than 2 boxes are checked or any combinations include * = Hazardous Tree

If not found to be in Hazardous condition:

Re- evaluate at later date.

No further evaluations needed.

(Tree will not cause any harm/damage if it falls)

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APPENDIX B: Maps of Sensitive Cultural Resources

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