Attachment_1_SHEN_MR_EA_1.pdf

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EXECUTIVE SUMMARY

Meadow Run is a stream located in the South District of Shenandoah National Park (the park) in the Commonwealth of Virginia. Like other watersheds in the park, decades of acidic deposition (acid rain) from regional air pollution have negatively affected soil and water quality in Meadow Run’s watershed.

Acidic soils have altered the water chemistry, impacting species richness and abundance of macroinvertebrates (mostly aquatic insects) and fish such as brook trout. Meadow Run, located in congressionally designated wilderness, is listed as impaired under Section 303d of the Clean Water Act by the Virginia Department of Environmental Quality (VADEQ) because of its elevated acidity (low pH).

Acidic deposition has been found to negatively affect songbirds, plants, and forest health in forests similar to the forest in the watershed. These degraded conditions affect ecosystem health and visitor experience.

Because of Meadow Run’s underlying bedrock geology, the soil and stream cannot recover naturally to pre-pollution conditions for well over 100 years. Meadow Run specifically has a history of scientific research on acid rain effects and is the ideal size for a restoration effort. Therefore, the park proposes to improve and restore the long-term health of the terrestrial and aquatic ecosystem and mitigate the harmful effects of acidic deposition in the Meadow Run watershed.

Under the no-action alternative (alternative A), current conditions would continue, resulting in long-term, adverse impacts on the ecosystem. Stream macroinvertebrate and fish communities (including brook trout) would likely remain degraded; native plants would remain limited in their growth and health; and the reproduction, growth, and/or abundance of some terrestrial wildlife (e.g., birds, snails, and some salamanders species) may remain adversely affected.

Under the two action alternatives, the park would apply limestone sand by helicopter in park-managed portions of the upper watershed (2,150 acres) to reduce its acidity. Proposed alternative B (split-dose liming) would use a higher liming dose of 3.0 tons per acre (t/acre) on more acidified soils and a lower dose of 2.25 t/acre on less acidified soils. Alternative C (uniform-dose liming) would apply a uniform dose of 2.75 t/acre. While alternative C would be slightly simpler to implement, alternative B (the preferred alternative) would be more closely tailored to site-specific soil conditions.

The application of limestone sand is expected to require two to three months and would occur during the winter (December–February), a period of low visitor use in the park and dormancy for many plants and animals. The project would be staged from areas along Skyline Drive and/or from outside the park. The park would consider multiple staging areas to minimize noise near any given staging area, allow for flexibility to accommodate winter weather conditions, and maximize the efficiency of project implementation, thereby keeping the implementation period as short as practicable. Any staging area outside the park would be located preferentially within a 0.5-mile zone immediately adjacent to the park boundary, although areas up to 1 mile from the boundary may be considered, if suitable. The park would gain permission from landowners for staging areas outside the park and communicate with affected neighbors. The helicopter carrying external loads (limestone sand) would only fly over lands where the park has made arrangements for that activity with the respective landowners.

For visitor safety, Riprap and Wildcat Ridge Trails would be closed, and backcountry camping in the project area would be prohibited during the full application period; closures of sections of Skyline Drive and the Appalachian Trail would be shorter and more intermittent based on project activity. The project implementation plan, to be prepared prior to any work on-site, would include measures for ensuring public safety, as well as a plan for coordination and communication with neighbors and the larger community of park users.

It is highly likely that a single limestone sand application would achieve the desired long-term restoration goal of improving the ecosystem of this watershed. If soil sampling and stream monitoring after the first

EXECUTIVE SUMMARY

ii liming demonstrated that long-term restoration goals were not met, one additional application could be considered in the future, conducted in a similar manner as the first application.

Alternatives B and C would have similar impacts (described below), although beneficial impacts would be more evenly distributed over the project area under alternative B than under alternative C:

Soil Chemistry: Soil acidity and toxic aluminum in the Meadow Run watershed would be reduced. Improvements should be observable within a year and would have beneficial impacts on soils for well over 100 years.

Water Quality: Monitoring data indicate that Meadow Run has poor water quality for brook trout. Liming would have ecologically significant, beneficial impacts on water quality by measurably increasing the acid neutralizing capacity and pH, and decreasing aluminum toxicity.

The pH in the stream water is expected to increase to > 6.0, which would allow Meadow Run to be removed from VADEQ’s Section 303d list for impaired waters.

Aquatic Wildlife (Fish and Macroinvertebrates): Beneficial changes in stream water quality would result in the likely return or increased abundance of fish species (such as brook trout and blacknose dace) and macroinvertebrates (an important food source for fish).

Vegetation: Changes in soil chemistry would result in long-term improvements of plant growth, improving the overall health of the forest. This includes improved growth of acid-sensitive plants in the project area, giving them a slight competitive advantage over acid-dependent plants. While the spread of non-native invasive plants could occur, the implementation of mitigation measures would minimize adverse impacts.

Terrestrial Wildlife (Birds, Salamanders, and Snails): Birds, especially ground- and understory-foraging species, would benefit in the long term from an increase in calcium-rich food items (e.g., snails) because birds require large amounts of calcium to produce eggshells and raise young. Some salamanders could experience more growth and reproduction because of increased availability of invertebrates and reduced aluminum toxicity. Snails are expected to become more abundant due to calcium additions available for shell growth.

Wilderness Character: Liming would manipulate natural processes in the project area, require the use of a helicopter and vehicles that generate noise and produce visual impacts, and require trail and area closures—all of which would adversely affect wilderness character during the application period. However, liming would help the park meet its wilderness and backcountry management goals by reducing adverse impacts on wilderness resources (soil, stream water, vegetation, and wildlife) and would have long-term, beneficial impacts on the natural quality of wilderness character.

Acoustic Environment (audible sound): Liming would have adverse impacts on the acoustic environment in terms of human and wildlife annoyance during the application period of up to three months. More intense impacts would occur near staging areas with low-elevation helicopter activity and truck deliveries of limestone sand (although specific staging areas outside the park [if any] have not been specified). Impacts would occur during the daytime only. Noise impacts would be mitigated through careful planning of flight paths and staging areas.

Visitor Use and Experience: During the application period, there would be closures of varying duration of trails (Riprap and Wildcat Ridge Trails and a section of the Appalachian Trail), backcountry areas, and a section of Skyline Drive. Closures, along with visual and noise disturbances, would affect visitor use and experience. Over the long term, visitor experience in the project area would improve because opportunities for recreational fishing and experiencing wildlife would benefit from improved natural resource conditions (including fish and wildlife habitats).

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CONTENTS

EXECUTIVE SUMMARY ............................................................................................................ I

CHAPTER 1: PURPOSE OF AND NEED FOR ACTION

INTRODUCTION

PURPOSE OF AND NEED FOR ACTION

PROJECT AREA FOR RESTORATION

ISSUES AND IMPACT TOPICS ANALYZED IN THIS ENVIRONMENTAL ASSESSMENT

CHAPTER 2: ALTERNATIVES

INTRODUCTION

ALTERNATIVE A: NO ACTION

ALTERNATIVE B: SPLIT-DOSE LIMING (NPS PROPOSED ACTION AND PREFERRED ALTERNATIVE)

ALTERNATIVE C: UNIFORM-DOSE LIMING

MITIGATION MEASURES INCLUDED IN THE ACTION ALTERNATIVES (ALTERNATIVES B AND C)

Water Quality Vegetation Terrestrial Wildlife Wilderness Character Acoustic Environment Visitor Use and Experience Historic Resources and Archeological Sites Air Quality Public Health and Safety

CHAPTER 3: AFFECTED ENVIRONMENT

INTRODUCTION

SOIL CHEMISTRY

Bedrock Geology Soil Descriptions Physical and Chemical Characteristics of Soils Trends

WATER QUALITY

Groundwater Surface Water Trends

AQUATIC WILDLIFE (FISH AND MACROINVERTEBRATES)

Fish Aquatic Macroinvertebrates Trends

VEGETATION

Dominant and Codominant Native Vegetation Rare Native Vegetation Non-native Invasive Vegetation

TABLE OF CONTENTS

iv

Trends and Planned Actions

TERRESTRIAL WILDLIFE (BIRDS, SALAMANDERS, AND SNAILS)

Birds Salamanders Snails Trends

WILDERNESS CHARACTER

Trends and Planned Actions

ACOUSTIC ENVIRONMENT

Sound Levels in the Park Sound Levels Outside the Park Trends

VISITOR USE AND EXPERIENCE

Skyline Drive Hiking Fishing Trends

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

INTRODUCTION

SOIL CHEMISTRY

Methods and Assumptions Alternative A: No Action Alternative B: Split-dose Liming Alternative C: Uniform-dose Liming

WATER QUALITY

Methods and Assumptions Alternative A: No Action Alternative B: Split-dose Liming Alternative C: Uniform-dose Liming

AQUATIC WILDLIFE (FISH AND MACROINVERTEBRATES)

Methods and Assumptions Alternative A: No Action Alternative B: Split-dose Liming Alternative C: Uniform-dose Liming

VEGETATION

Methods and Assumptions Alternative A: No Action Alternative B: Split-dose Liming Alternative C: Uniform-dose Liming

TERRESTRIAL WILDLIFE (BIRDS, SALAMANDERS, AND SNAILS)

Methods and Assumptions Alternative A: No Action v

Alternative B: Split-dose Liming Alternative C: Uniform-dose Liming

WILDERNESS CHARACTER

Methods and Assumptions Alternative A: No Action Alternative B: Split-dose Liming Alternative C: Uniform-dose Liming

ACOUSTIC ENVIRONMENT

Methods and Assumptions Alternative A: No Action Alternative B: Split-dose Liming Alternative C: Uniform-dose Liming

VISITOR USE AND EXPERIENCE

Methods and Assumptions Alternative A: No Action Alternative B: Split-dose Liming Alternative C: Uniform-dose Liming

CHAPTER 5: CONSULTATION AND COORDINATION

PLANNING

CIVIC ENGAGEMENT

AGENCY CONSULTATION

Section 7 of the Endangered Species Act Section 106 of the National Historic Preservation Act

ACRONYMS AND ABBREVIATIONS

DEFINITION OF FREQUENTLY USED TERMS

REFERENCES

LIST OF FIGURES

Figure 1. Meadow Run, a Wild Trout Stream Degraded by Low pH Waters (June 2019) Figure 2. Project Area for Restoration, View from Skyline Drive Figure 3. Meadow Run Project Area Figure 4. Liming by Helicopter in Monongahela National Forest, 2018. Left Loading of Bucket in Staging Area. Right: Spreading of Limestone Sand Figure 5. Potential Staging Areas Figure 6. Limestone Sand on the Forest Floor Immediately after Liming. Left: On Hard Surface or Compacted Leaf Litter (Dose of 3-5 t/acre); Right: On Loose Leaf Litter Surface (Dose of 2 t/acre) Figure 7. Geological Formations and Structures in the Project Area and Vicinity Figure 8. pH and ANC in Meadow Run, Measured Quarterly During Baseflow Conditions (1987– 2018) Figure 9. Dominant and Codominant Vegetation Communities and Known Non-native Invasive Vegetation in the Project Area vi

Figure 10. Vegetation Communities Ranked as Globally Uncommon or at Moderate Risk for Extinction Figure 11. Wilderness Within the Project Area Figure 12. Average Monthly Traffic Counts from 2009 to 2018 at Rockfish Gap Entrance, the Entrance of Skyline Drive Closest to the Project Area

LIST OF TABLES

Table 1. Soil Properties of Soil Acidification Metrics for the Project Area from 46 Sites in 2019 (upper 20 cm) and 6 Sites in 2000 (20–80 cm depth) Table 2. Dominant and Codominant Plant Species and Associated Forest Communities for these Plant Species Table 3. Soil pH Ranges for Plant Species Within or Near the Project Area Table 4. Reduction in Listening Area and Alerting Distance Due to Increases in Ambient Sound Levels Table 5. Sound Levels with Distance from Helicopter and Everyday Sounds and Noises Table 6. Science Team Members

APPENDICES

Appendix A—Issues, Impact Topics, and Alternatives Dismissed from Detailed Analysis Appendix B—Technical Information for Liming Meadow Run Watershed Appendix C—Vertebrate Species of Greatest Conservation Need Potentially Present in the Project Area

CHAPTER 1: PURPOSE OF AND NEED FOR ACTION

INTRODUCTION

Shenandoah National Park (park) encompasses part of the Blue Ridge Mountains in the Commonwealth of Virginia and is bordered by the Shenandoah River valley to the west and the Virginia Piedmont to the east. Almost 40% of the park has been congressionally designated as wilderness, which is managed to preserve its wilderness character. Located just 75 miles from Washington, DC, the park is a popular destination for visitors to enjoy waterfalls, quiet hiking trails, scenic vistas, plants, and wildlife. Each year the park welcomes approximately 1.4 million visitors. Skyline Drive, a scenic roadway, runs through the full length of the park near its highest elevations. As a unit of the national park system, the park’s mission is to “...conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations” (NPS 2020a).

Over many decades, scientists and managers have learned that high levels of acidic atmospheric pollutants emitted by fossil-fuel-burning industrial facilities, power plants, and other sources in the surrounding region have been deposited in the park—this process is referred to as acidic deposition. As a result, some of the park’s watersheds have highly acidified soils and streams. In these watersheds, acidic deposition has depleted important elements in the soil, such as calcium and magnesium. These elements help the soil resist acidification and are referred to as base cations.1 Buffering capacity, a term describing the soil’s ability to resist changes in pH (the measurement of acidity in soil and water) due to the addition of an acid, depends on the level of base cations available in the soil. The capacity to buffer against acidification is also known as acid neutralizing capacity (ANC), especially when referring to water. Base cations naturally accumulate in soils through breaking down (weathering) of bedrock (and remain there if not depleted by processes such as acidic deposition). Base cations are nutrients essential for the growth of trees and understory plants.

The effects of acidic deposition vary across the park. The underlying bedrock, or parent geology, of each watershed and the soils that form on top of it contribute to this variation. Most of the park’s soils retain the capacity to buffer acidic deposition, which prevents acidic deposition from causing significant impacts on natural resources. However, roughly a quarter of the park’s area, including the Meadow Run watershed, is situated on bedrock with low base cation content, and the soils that form in these areas have a low buffering capacity. Therefore, these soils are less resilient to sustained acidic deposition, and the associated watersheds have become acidified.

Meadow Run is a stream located on the west side of the park’s South District that is underlain by silica-rich bedrock (figure 1). This type of bedrock is particularly poor in base cations, and the soils that form on it have limited capacity to neutralize acidic deposition as the bedrock naturally weathers.

1 A cation is a positively charged ion (atom or molecule). Base cations are defined as the most prevalent, exchangeable and weak acid cations in the soil, such as calcium or magnesium.

FIGURE 1. MEADOW RUN, A WILD TROUT STREAM DEGRADED BY

LOW PH WATERS (JUNE 2019)

Resulting acidic groundwater flows through those soils and feeds the tributaries of Meadow Run, affecting water quality. Consequently, some fish species (including brook trout), many insect species, and other aquatic organisms struggle to survive in Meadow Run. Acidification also adversely affects songbird, plant, and forest health. Degraded ecosystem health in turn diminishes the visitor experience.

Because its low pH is affecting aquatic life, the Virginia Department of Environmental Quality (VADEQ) formally lists Meadow Run as impaired waters under Section 303d of the Clean Water Act (CWA)

(VADEQ 2020).

In August 2016, the US District Court for the District of Maryland responded to complaints against Westvaco Corporation over air quality permitting violations at the company’s Luke Mill, which resulted in an alleged 200,000 tons of highly acidic “excess” sulfur dioxide emissions (Consent Decree No. MJG 00-CV-2602, US v. Westvaco Corporation). The court approved a settlement agreement where Westvaco Corporation agreed to fund mitigation/restoration projects in the park and nearby US Forest Service (USFS) areas potentially affected by emissions from the Luke Mill. The consent decree and settlement stated that “…Westvaco shall pay $800,000 to the National Park Service to be used in accordance with 54 [United States Code] U.S.C. § 100724 for the restoration of land, watersheds, vegetation, and forests in Shenandoah National Park using techniques designed to improve ecosystem health and mitigate harmful effects from air pollution.”

The National Park Service (NPS) proposes to mitigate acidic deposition by dropping limestone sand on the terrestrial watershed (referred to as limestone sand application or liming hereafter) using a helicopter.

Watershed liming is a type of project identified in the Consent Decree (2016) as an appropriate use of funds. This environmental assessment (EA) evaluates a no-action alternative (alternative A), a proposed action (alternative B; preferred alternative), and another action alternative (alternative C) that would implement watershed liming in a different manner than the preferred alternative (see chapter 2).

PURPOSE OF AND NEED FOR ACTION

The purpose of the proposed action is to improve the long-term health of the terrestrial and aquatic ecosystems and mitigate the harmful effects from decades of atmospheric acidic deposition in the Meadow Run watershed. Of all the areas with silica-rich bedrock in the park, Meadow Run is one of the most impacted watersheds. This is based on more than 30 years of scientific monitoring of water quality and aquatic life in the stream. Additionally, the size of the Meadow Run watershed makes the action practical given the amount of funding available for restoration projects. The long history of scientific data and the ideal size of the Meadow Run watershed make it the most suitable area for restoration.

Action is needed because acidic deposition has led to reduced ANC and pH in Meadow Run, which has degraded soil and water quality and negatively affected the habitat for fish and aquatic organisms. Recent reductions in regional air pollutant emissions have not led to natural ecosystem recovery in Meadow Run because the system has already lost a significant amount of its natural buffering capacity. The watershed is located on bedrock with comparatively low concentrations of base cations, so base cations lost from the soil from acidic deposition are not replenished naturally. Without restoration, the watershed’s aquatic and terrestrial ecosystem would continue to be degraded, and the watershed would remain degraded for well over 100 years.2

2 For a detailed analysis, see “Appendix B: Technical Information for Liming Meadow Run Watershed.”

PROJECT AREA FOR RESTORATION

The Meadow Run watershed is located approximately 10 miles northeast of Waynesboro, Virginia.

Meadow Run is a tributary to the South River, which flows into the South Fork of the Shenandoah River.

The headwaters and most of the upper watershed of Meadow Run are within the park. The lower watershed is west of the park in the town of Crimora in Augusta County.

The 2,150-acre area for the proposed liming project lies entirely within the park boundary, is completely forested, and extends from a steep ridge to the west of Meadow Run, to the Riprap Trail to the north, Skyline Drive to the east, and Wildcat Ridge Trail to the south (figures 2 and 3). The project area allows for a minimum 100-yard buffer between the park boundary and private lands adjacent to it.

ISSUES AND IMPACT TOPICS ANALYZED IN THIS ENVIRONMENTAL ASSESSMENT

This EA analyzes issues and impact topics for the project area, as well as for the staging areas used for the implementation of the project and the flight path between the staging areas and the project area (see “Chapter 2: Alternatives” for details). Issues and impacts topics are related to the following resources and values: soil chemistry, water quality, aquatic wildlife (fish and macroinvertebrates), vegetation, terrestrial wildlife (birds, salamanders, and snails), wilderness character, acoustic environment, and visitor use and experience. Several other issues and impact topics were considered but dismissed for reasons specified in “Appendix A: Issues, Impact Topics, and Alternatives Dismissed from Detailed Analysis.”

Issues analyzed in the EA were identified with support from a science team established for this project.

The team consisted of experts familiar with Meadow Run’s acid-impacted systems and watershed liming;

these experts are affiliated with federal agencies, state agencies, and universities (see “Chapter 5:

Consultation and Coordination” for science team members and their roles).

If an action alternative were selected, an implementation plan would be developed that would contain the logistical details, communication plan, safety measures, and all other aspects relevant for the implementation of the project. In addition, this implementation plan would be evaluated against the National Environmental Policy Act (NEPA) analysis, contained in this EA, to ensure that all potential impacts were considered.

FIGURE 2. PROJECT AREA FOR RESTORATION,

VIEW FROM SKYLINE DRIVE

FIGURE 3. MEADOW RUN PROJECT AREA

CHAPTER 2: ALTERNATIVES

INTRODUCTION

This chapter describes alternatives for the restoration of the Meadow Run watershed, consistent with the purpose of and need for action. Three alternatives are analyzed in detail: the no-action alternative (alternative A) and two action alternatives. Alternative B is the NPS proposed action and preferred alternative. This chapter also lists mitigation measures that would apply to both action alternatives.

Several other alternatives were identified during internal and public scoping but do not meet the purpose and need, are not feasible, or would result in too great of an environmental impact; therefore, those alternatives were dismissed from detailed analysis in the EA (see appendix A).

ALTERNATIVE A: NO ACTION

Under the no-action alternative, liming of the Meadow Run watershed would not occur. Natural processes would continue to be influenced by acidic deposition, and the high acidity of the soil and water would remain.

ALTERNATIVE B: SPLIT-DOSE LIMING (NPS PROPOSED ACTION AND

PREFERRED ALTERNATIVE)

Under alternative B, the park would use a split-dose liming approach to replace base cations lost from soils and ANC lost from the stream as a result of historical acidification. Soils most depleted in base cations would receive a higher dose of limestone sand than soils that are less depleted in base cations.

Generally, soils in the eastern half of the Meadow Run project area, closest to Skyline Drive, are most depleted in base cations and would receive the higher dose of limestone sand. Under alternative B, approximately 5,250 tons of dolomitic limestone sand would be applied via helicopter in the project area. A helicopter would provide an efficient and effective way to access the steep terrain and to avoid ground disturbances in a wilderness area, which spans 80% of the project area. The dolomitic limestone sand would be obtained from local quarries.

Limestone Sand Doses. Alternative B would apply two different doses of limestone sand in the project area: a higher dose (3.0 short tons per acre [t/acre]) over soils with a greater deficit of base cations (i.e., soils that are generally more developed and thicker), and a lower dose (2.25 t/acre) over soils with a lower deficit of base cations. Details on how these doses were determined are available in appendix B. Approximately 5,250 tons of limestone sand are expected to be applied across the two subareas based on soil depletion (assuming a 50/50 split). The subareas would be delineated prior to project implementation and would be based on soil analyses, which could change this split and therefore slightly increase or decrease the total weight of limestone sand (perhaps by up to 10%).

Liming Area and Exclusion Zones. Approximately 2,000 acres within the 2,150-acre project area (figure 3) would be limed; the remaining 150 acres of the project area would be excluded from liming to protect rare, threatened, and endangered plants; limit the spread of non-native invasive plant communities; and avoid an area where a predatory beetle (Laricobius nigrinus) was released for biological control of hemlock woolly adelgid (Adelges tsugae). Buffer areas would be identified around these locations and would be part of the respective exclusion zones. The final size and boundary of the exclusion zones would be specified in the implementation plan to ensure maximum resource protection, following appropriate surveys in the field. In addition, the project area allows for a minimum 100-yard buffer between the park boundary and private lands adjacent to it. Most of the project area is set back one-half mile or more from the park boundary and private lands. Precise positioning capability by the helicopter would avoid identified exclusion and buffer zones from being limed.

Helicopter Service Landing Areas. Suitable helicopter service landing areas would be located outside wilderness areas, and no helicopter landings would occur in wilderness areas. A helicopter would arrive during mobilization. At service landing areas, it would be able to land for downtime periods, refueling operations (from a fuel truck), preventative maintenance activities, and overnight parking. Service landing areas would be located as close to the project area as possible to limit travel times and may include a staging area (see next section), assuming sufficient space was available and permissions from landowners were obtained. A nearby airport could also be used as a service landing area. Helicopter use would follow all Federal Aviation Administration (FAA) regulations and stay within the FAA-managed airspace.

Staging Areas. Implementation of the project requires staging areas for transporting the limestone sand to the project area by the helicopter. While the entire project could be staged from one area, the park would consider multiple staging areas that ideally would be distributed/located closest to the portion of the project area with ongoing application at a given time. This approach—multiple staging areas and close proximity to an actively limed area—would limit the duration of noise near any active staging area, allow for flexibility to accommodate winter weather conditions, and maximize the efficiency of project implementation, thereby keeping the implementation period as short as practicable.

An active staging area (i.e., the staging area where liming operations are underway) requires as a minimum space to accommodate the following (figure 4):

A large enough stockpile of limestone sand to ensure uninterrupted daily operations by the helicopter.

Space for filling the liming bucket with a front-loader and/or bobcat. Two buckets would typically be used—one would be refilled with loading equipment, while the other would be used by the helicopter. The helicopter would return the empty bucket and leave with a full bucket.

Sufficient clearance without overhanging branches or other obstructions to ensure safe lifting of a filled bucket into the air by the helicopter and lowering the emptied bucket back down after a liming run.

Source: USFS staff at Monongahela National Forest

FIGURE 4. LIMING BY HELICOPTER IN MONONGAHELA NATIONAL

FOREST, 2018. LEFT LOADING OF BUCKET IN STAGING AREA.

RIGHT: SPREADING OF LIMESTONE SAND

The required estimated size of an active staging area is at least approximately 300 square feet, although a larger area is preferred. Active staging areas may require some preparation, including trimming overhanging tree branches, clearing small trees and bushes, and placing wooden construction matting for ground protection (for additional measures, see the “Mitigation Measures” section later in this chapter).

In addition, space would be needed for the following:

Parking for staff working at an active staging area.

A small operations trailer for staff for storing equipment and for shelter in case of inclement weather conditions.

If space at an active staging area were inadequate, this need for additional space could be accommodated off a road (e.g., Skyline Drive) or at a nearby staging area (e.g., parking area or overlook).

Finally, the park may decide to build one or several larger stockpiles of limestone sand in advance of liming either at planned active staging areas (if enough space exists) or at one or several other nearby staging areas to ensure uninterrupted limestone sand supply once liming starts.

Staging areas may be paved or unpaved, but truck access for unloading limestone would be required.

The limestone sand would be transported to staging areas by quarry trucks with gross vehicle weights dictated by road and site conditions. Weight restrictions on Skyline Drive would result in substantially more truck traffic than on public highways to deliver the same amount of material. As necessary, all staging areas may be fenced, and stockpiles would be protected from precipitation, erosion, and seeds of non-native invasive plant species using plywood, tarps, and other runoff control measures.

The staging areas would be located at overlooks and parking areas along Skyline Drive and/or, with landowner support, at specific (yet to be determined) locations within a zone just outside the park’s western boundary (figure 5). This zone is approximately 9 miles long and generally up to 0.5-mile wide, but the width may extend to 1 mile if necessary. The park would gain permission and coordinate with the landowners and affected neighbors for any staging area(s) outside the park. In addition, the helicopter carrying limestone sand would only fly over undeveloped lands where the park has made arrangements for that activity with the respective landowners. The exact location of the staging areas would be determined well in advance of project implementation, which would include site condition surveys and any appropriate landowner agreements.

Liming Approach. The bucket used for liming would be capable of carrying several tons of limestone sand and would be fitted with a spreading mechanism. The helicopter would lift this bucket, transport it to an area to be limed, drop to a lower flying height, and activate the spreading mechanism (figure 4).

Flights would follow precise transects following land contours to systematically apply the limestone sand over the project area at the prescribed liming doses. For transport using a staging area outside the park, appropriate measures would be incorporated through bucket design and/or flight operation to minimize the loss of limestone sand grains over non-park land (after permission for use of land and overflights was received by the landowner[s]).

The helicopter would release the limestone sand approximately 50 to 100 feet above the tree tops.

Because of its relatively coarse grain size, the limestone sand would fall quickly to the ground. Rapid settling was observed, for example, during the USFS Lower Williams Terrestrial Liming Project (USFS 2018; Science Team, pers. comm. 2019a).

FIGURE 5. POTENTIAL STAGING AREAS

Liming Season and Closures in the Park. Limestone sand application would occur during the winter, a low visitor-use period and leaf-off/dormant season (December–February). Using multiple staging areas close to the project area may allow for completion of liming in two months because of its proximity to the project area. Using staging areas farther away may require up to three months. Liming would be conducted only during daylight hours on weekdays (approximately 8 hours per day), and potentially on Saturdays and Sundays if necessary, because of logistical or weather-related reasons (Sundays would be considered for helicopter liming operations [with loaded bucket] exclusively within park boundaries). No operations would occur on holidays.

Liming would require safety closures of sections of Skyline Drive and the affected backcountry and wilderness areas, and nearby trails in the South District of the park. Examples of closures for safety reasons include the following:

Riprap and Wildcat Ridge Trails and Lands in the Immediate Area: The two trails and lands in the immediate area would likely be closed for the entire duration of liming because the helicopter would cross this area frequently.

Appalachian Trail: The affected section of the Appalachian Trail would be closed for as long as needed to accommodate liming of the eastern part of the project area and to avoid safety concerns from the use of staging areas along Skyline Drive. Hikers on the Appalachian Trail would be rerouted or potentially shuttled to a safe bypass. The Trail could be opened if/when staging areas outside are used, and once the eastern part of the project area has been limed.

Therefore, the Appalachian Trail may be closed only for a portion of the implementation period.

Skyline Drive: The affected section of Skyline Drive would also require closures during liming of the eastern portion of the project area and for active use of staging areas along the road. The duration of closures would depend on the selected staging areas for the entire project, and the final logistical approach developed in the implementation plan. For example, Skyline Drive may only be closed for weeks or around a month (if Skyline Drive is not used entirely for staging), could be open during days of non-operation (e.g., on holidays or days of stronger winds or other weather concerns), and perhaps could be open at night (6:00 p.m. to 6:00 a.m.).

The goal would be to limit closures to the minimum number of days feasible to complete the project while providing for visitor safety. Required closures and bypass recommendations would be specified in the implementation plan during project design.

Truck deliveries to stockpile limestone sand at staging areas could start in November but would not result in closures of Skyline Drive or any of the trails. Deliveries may include the closure of a parking area or overlook along Skyline Drive while the stockpile(s) is being built prior to project implementation.

The park expects that a single limestone sand application would achieve the desired long-term restoration goal of improving the ecosystem of this watershed; criteria and targets to achieve this goal are discussed in chapter 4. If soil sampling and stream monitoring after the first application demonstrate that long-term restoration goals were not adequately achieved or that an additional limestone sand application would improve the conditions in the watershed further, a future application could be considered. No more than two applications would be implemented as part of this proposal. A second application, if needed, would be conducted in a similar manner as the first application and would include public notices.

The duration of each limestone sand application period (up to two, as described above) would depend on the location of the staging areas, helicopter service area(s), weather conditions, the total weight of limestone sand to be applied, and other factors, and could last two to three months. Flight time by the helicopter for project implementation could range from 200 to 400 flight hours for 5,250 tons of limestone sand, depending on the locations of the staging areas used. In case of a second liming event, flight times could result in an additional 200 to 400 hours for the second application.

Limestone Sand Mixing with Soil. The limestone sand would be visible on the forest floor for a few months until natural processes (such as biological activity, rain, and wind) mix the sand into the leaf litter (figure 6). By early summer, the sand should no longer be readily visible (Science Team, pers.

comm. 2019a, and follow-up communications).

Sources: Left: USFS staff at Monongahela National Forest. Right: Dr. William E. Sharpe, Pennsylvania State University

FIGURE 6. LIMESTONE SAND ON THE FOREST FLOOR IMMEDIATELY AFTER LIMING.

LEFT: ON HARD SURFACE OR COMPACTED LEAF LITTER (DOSE OF 3-5 T/ACRE);

RIGHT: ON LOOSE LEAF LITTER SURFACE (DOSE OF 2 T/ACRE)

Post-liming Monitoring. The park intends to collaborate with scientists from NPS and other agencies/institutions to monitor the environmental response of the liming. Effectiveness monitoring would be conducted in the project area and potentially in an unlimed control area in a watershed immediately to the north or south of the project area with similar geological and ecological conditions.

A monitoring plan, to be developed prior to liming, would be designed to gather new and existing data on conditions before liming occurred and to provide information on the project’s effectiveness.

Measurable response indicators might include soil base cation saturation, stream water ANC, return of acid-sensitive aquatic organisms, and vegetation monitoring. If funding and support were available, monitoring would include collecting samples for laboratory analysis for soil, stream water quality, and aquatic organisms in the Meadow Run watershed at regular intervals (e.g., quarterly or annually). Any monitoring would use low-impact methods, such as using soil recovery probes (1-inch diameter) or collecting fish in ways that allow for their safe release back to the stream. These monitoring approaches have been in use for years in Meadow Run and other locations by park staff and partners and provided the baseline data to compare pre- and post-liming conditions.

ALTERNATIVE C: UNIFORM-DOSE LIMING

Under alternative C, the park would apply limestone sand via helicopter using a uniform-dose liming approach of 2.75 t/acre. Unlike alternative B, alternative C would not distinguish between more depleted and less depleted soils and would instead distribute the limestone sand evenly across the project area (except over exclusion zones). This dose would result in 5,500 tons of limestone sand applied over 2,000 acres. The total flight time for 5,500 tons under alternative C would be slightly longer (approximately 5%) than the flight time under alternative B (i.e., 210 to 420 hours). All other aspects of alternative C, including size of the project area, size of the exclusion zones, operational logistics, potential staging areas, monitoring plan, and a potential second limestone sand application would be the same as described for alternative B.

MITIGATION MEASURES INCLUDED IN THE ACTION ALTERNATIVES

(ALTERNATIVES B AND C)

To protect natural and historic resources, the quality of the visitor experience in the park, and the surrounding community outside the park, this section lists mitigation measures and best management practices that would be included in both alternatives B and C. These actions would be developed in further detail in the implementation plan.

Water Quality

Comply with and meet all relevant requirements under the CWA, including management of stormwater-related non-point source pollutants under the National Pollutant Discharge Elimination System. Implement best management practices for drainage and sediment erosion control (e.g., VADCR 2020) at staging areas to prevent or reduce non-point source runoff and minimize soil loss from the limestone sand stockpile and any unpaved surfaces. Inspect and clean out erosion control structures periodically and remove them only after unpaved staging areas are restored fully.

Avoid locating staging areas near wetlands and waterways.

Develop a refueling and maintenance plan for the helicopter and all construction vehicles to prevent potential contamination of surface waters and groundwater caused by accidental spills.

Vegetation

Evaluate sensitive areas prior to project design to include new information on rare, threatened, and endangered plants, as well as non-native invasive plant species, as input for the delineation of zones to be excluded from liming (i.e., exclusion zones).

In addition to excluding locations with documented non-native invasive plant infestations from receiving limestone sand, treat such locations with appropriate herbicide, mechanical, or manual removal methods prior to project implementation, where practical. Take special care to treat infestations in and around selected staging areas.

Prevent or minimize establishment and spread of non-native invasive plants, noxious weeds, and spread of diseases through the following measures:

– coordinate with the quarry supplying the limestone sand to cover the sand with a tarp immediately after the sand is generated by crushing limestone source rock;

– cover each load of limestone sand on trucks with a tarp during transport;

– cover the stockpile in staging areas when not actively being used;

– stage equipment and materials on durable paved surfaces where possible;

– evaluate existing topsoil in and around any unpaved staging area for non-native invasive plant infestations, and place rubber matting or plywood over the soil prior to stockpiling limestone sand to avoid seeds being mixed in with the sand; and

– minimize disturbance to soils to reduce disturbance to native plants and reduce the potential for introduction or spread of non-native invasive plants.

Clean all vehicles, heavy equipment, and tools used in staging areas of weeds, seed, debris, and mud prior to entry into the park to prevent the introduction or spread of non-native invasive plants. Allow for NPS inspection for proper level of cleanliness prior to entry into the park or into an active staging area if equipment is being moved from an area where non-native invasive plants are known to occur. Restore any unpaved parts of staging areas disturbed during project implementation to pre-implementation conditions. Ensure that plant species and all materials (e.g., rolled erosion control products) used for revegetation are approved by NPS.

Terrestrial Wildlife

Properly store and dispose of food, garbage, and potential contaminants at an active staging area until they can be transported off-site to avoid attracting wildlife and causing human-wildlife conflicts.

Have NPS provide information to contractors and other project staff during the pre-application meeting about any special-status species or other sensitive wildlife in the project area to minimize disturbance to wildlife.

Use biodegradable matting with a large-diameter natural fiber to prevent entrapment of wildlife if using erosion netting.

Wilderness Character

Limit management actions (e.g., resource management, resource monitoring, and research) in wilderness areas to the minimum necessary to achieve the objective. For each individual action associated with this project, carefully consider impacts on wilderness character and use Minimum Requirements Analyses, as appropriate, to minimize impacts.

Direct visitors to other trails in park wilderness where they can still experience this opportunity.

Acoustic Environment

When carrying loads (i.e., filled or empty bucket attached via cable underneath the helicopter) during flights between a staging area outside the park and the project area, prohibit flying directly over residences and other buildings occupied by people or livestock.

Carefully select flight paths, hours of operation, and other appropriate best management practices such as limits to idling of engines to minimize noise impacts on wildlife, livestock, neighbors, and the local community, as much as possible and practicable.

Notify affected neighbors and the local community near the project area and any staging area outside the park, at least a month in advance of the schedule of operations if possible, to allow for factoring helicopter operations into their daily activities. Distribute notifications by newsletter, website, social media posts, emails, or other means to affected neighbors near the project area, specifically near staging areas outside the park staging areas.

Visitor Use and Experience

Develop and implement a communications plan to inform the public about project-related management activities and any associated closures of Skyline Drive and affected trails. Prepare news and social media releases, signage, websites, and other forms of communication well in advance of project implementation.

Historic Resources and Archeological Sites

Historic resources are dismissed as an impact topic (see appendix A) because impacts can be minimized or avoided by implementing the following mitigation measures:

Use wooden construction matting on overlook pavements, the vegetative buffer between Skyline Drive, or any overlook (if used) and portion of Skyline Drive used to stockpile limestone sand or maneuver heavy equipment (e.g., wheeled loaders), to prevent pavement surface and structural damage.

Protect historic guard walls with appropriate barriers in areas of constantly moving vehicles (e.g., the bucket loading area).

Protect drainage structures (drop inlets, weep holes in walls) at overlooks to prevent filling or clogging with stockpiled limestone sand.

Maintain loaded truck weights below seasonal weight limits for Skyline Drive by conducting weight monitoring of all loaded trucks–using the scale at the quarry–before transporting the material to the park and requiring regular weight checks by park staff.

Avoid locating heavy loads (such as large stockpiles) on sections of any overlook built on fill.

Air Quality

Air quality is dismissed as an impact topic (see appendix A) because the emissions contribution from liming activities would be extremely low relative to existing regional emissions. In addition, the following mitigation measures would be implemented to minimize localized impacts:

Allow for a buffer between the limestone sand application and the park boundary to minimize noise and avoid potential drift of limestone material. Buffers are substantial near most of the boundary (greater than 0.3 miles on the west and well over a mile in the east) with the closest distance at a few points in the souths (100 yards). Ideally, apply limestone sand along the southern and southwestern edges of the project area only on days when wind speeds are low or the wind blows predominately from the south or west to avoid residual limestone sand particles from drifting outside the park boundary.

If a staging area(s) outside the park is used, minimize the loss of the limestone sand particles from the bucket during transport over non-park land.

Public Health and Safety

Public health and safety is dismissed as an impact topic (see appendix A) because impacts would be minimized or avoided. Appropriate health and safety measures would be detailed in the implementation plan. The plan would include safety measures, e.g., closures for safety reasons and emergency management:

Prohibit helicopter flights over buildings, vehicles, or other areas potentially occupied by people or livestock when the liming bucket is attached. Close areas during limestone sand application to the extent needed for public safety (see the section entitled “Liming Season and Closures in the Park” above) and provide an alternative route for Appalachian Trail users in that area (along with appropriate signage and directions), in coordination with the Appalachian Trail Conservancy and Appalachian Trail clubs. Close portions of Skyline Drive and work with local jurisdictions to implement closures near the project area and active staging areas as needed for public safety. Work with these jurisdictions if there is a need for alternate vehicle routes for the public as a result of closures. Develop and implement traffic control and safety plans for park and public use prior to project implementation and coordinate with law enforcement rangers, volunteer staff, and other agency staff, who could potentially be working in and around closed areas.

CHAPTER 3: AFFECTED ENVIRONMENT

INTRODUCTION

This chapter presents information about existing conditions of resources that are analyzed in this EA, along with trends observed over recent decades and likely for coming decades if no action is taken. Any planned actions in the project area are included in the section on trends for specific impact topics.

SOIL CHEMISTRY

As noted in chapter 1, Meadow Run is the most acidified stream in the park because of its soils and bedrock geology. Soils are the critical factor in a watershed’s sensitivity to acidification, because they serve as the primary store and source for exchangeable base cations, such as calcium and magnesium, that buffer acidic deposition on land and provide…