Attachment 2.pdf

United States Forest-wide Nonnative Invasive Plant

Department of Management Project

Agriculture Environmental Assessment

Forest Monongahela National Forest

Service Supervisor’s Office

Eastern Barbour, Grant, Greenbrier, Nicholas, Pendleton, Region Pocahontas, Preston, Randolph, Tucker, and Webster

Counties, West Virginia

March, 2010

Responsible Agency: USDA Forest Service

Responsible Official: Clyde N. Thompson, Forest Supervisor

USDA Nondiscrimination Statement

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, gender, religion, age, disability, political beliefs, sexual orientation, and marital or family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA's TARGET

Center at 202-720-2600 (voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326-W, Whitten Building, 14th and Independence

Avenue, SW, Washington, DC 20250-9410 or call (202) 720-5964 (voice or TDD). USDA is an equal opportunity provider and employer.

The photo on the cover is of garlic mustard, a non-native invasive plant on the Forest.

Monongahela National Forest Forest-wide NNIS Management Project ii

Preface

Non-native invasive plants continue to spread on the Forest. Several rare plant communities are imminently threatened by expanding infestations. Many other high-interest ecosystems and large areas of contiguous federal ownership remain largely uninvaded, but threats to these ecosystems are increasing due to new spot infestations and continued spread along transportation corridors.

Control of invasive species continues to be a national and regional priority. The Forest-wide

Nonnative Invasive Plant Management Project is being proposed to expand the Forest’s existing

NNIS plant management strategy to include treatment of existing and emerging infestations.

Such treatments would better implement the NNIS goals and objectives in the Forest Plan.

The Monongahela National Forest (MNF) is preparing this Environmental Assessment (EA) in compliance with the National Environmental Policy Act (NEPA) and other relevant Federal and

State laws and regulations. This EA discloses direct, indirect, and cumulative environmental impacts that would result from the Forest-wide Nonnative Invasive Plant Management Project proposed action and alternatives. This document is organized into 4 chapters and 2 appendices.

Chapter 1 - Purpose of and Need for Action: This Chapter summarizes the proposed action, describes the project area, discusses Forest Plan Direction related to this project, discloses the existing vegetative condition of the area, explains why action is needed (referred to as the

“purpose and need for action”), defines the scope of the analysis, identifies the decisions to be made with this project, and lists the applicable laws, regulations, and executive orders related to this project. This chapter details how the Forest Service informed the public of the proposal, how the public responded, and what issues or concerns were identified through comments.

Chapter 2 - Alternatives Considered: This chapter provides a more detailed description of the agency’s proposed action, as well as alternative methods for achieving the stated purpose. All alternatives were developed based on issues raised internally or externally. Summary tables of the proposed activities, potential effects, monitoring, design features, implementation strategies, and mitigation measures associated with the action alternative are also provided.

Chapter 3 – Affected Environment and Environmental Effects: This chapter describes the existing conditions and the environmental effects of implementing the proposed action and No

Action alternatives. Environmental effects include direct, indirect, and cumulative effects, unavoidable adverse impacts, and irreversible or irretrievable commitments of resources.

Chapter 4 - Project Consultation and Coordination: This chapter provides a list of preparers or contributors to this assessment. It also lists the Federal and State agencies that were consulted during the development of the EA, along with organizations, businesses, and individuals.

Appendix A and Appendix B provide detailed maps and tables of the areas proposed for treatment under the Proposed Action. Additional documentation, including detailed analyses of the project area resources, is located in the project planning file at the Forest Supervisor’s Office in Elkins, West Virginia.

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Table of Contents Page

Preface ...................................................................................................................................... ii

Table of Contents .................................................................................................................... iii

Chapter 1 – Purpose and Need for Action ........................................................................... 1-1

1.1 – Summary of Proposed Action ................................................................................... 1-1

1.2 – Project Area Description ........................................................................................... 1-1

1.3 – Forest Plan Direction ................................................................................................ 1-3

1.4 – Existing Conditions ................................................................................................... 1-3

1.5 – Purpose and Need for Action .................................................................................... 1-4

1.6 – Scope of the Environmental Analysis ....................................................................... 1-5

1.7 – Responsible Official and Decisions to be Made ....................................................... 1-5

1.8 – Applicable Laws and Executive Orders .................................................................... 1-5

1.9 – Public Involvement ................................................................................................... 1-6

1.10 - Issues ....................................................................................................................... 1-7

1.10.1 – Issue: Reduce the Impacts to Forest Resources from NNIS ........................................................ 1-7

Chapter 2 – Alternatives Considered .................................................................................... 2-1

2.1 – Alternatives Considered but Eliminated from Detailed Study ................................. 2-1

2.1.1 – Control NNIS on Private Land Not Adjacent to National Forest Land ......................................... 2-1

2.1.2 – Collaborate with Adjacent Landowners on Prescribed Fire .......................................................... 2-1

2.1.3 – Do Not Plant Species on the West Virginia Division of Natural Resources NNIS List ............... 2-1

2.1.4 – Control Nonnative Insects ............................................................................................................. 2-2

2.1.5 – Treat Undesirable Native Plant Species ....................................................................................... 2-2

2.2 – Alternatives Given Detailed Study ........................................................................... 2-2

2.2.1 – Alternative 1 – No Action ............................................................................................................. 2-2

2.2.2 – Alternative 2 – Proposed Action ................................................................................................... 2-2

2.3 – Monitoring Applicable to Alternative 2 .................................................................. 2-15

2.4 – Design Features and Implementation Strategies Applicable to Alternative 2 ........ 2-16

2.5 – Mitigation Measures Applicable to Alternative 2 ................................................... 2-18

2.6 – Comparison of Activities by Alternative ................................................................ 2-21

2.7 – Comparison of Environmental Effects by Alternative ............................................ 2-21

Chapter 3 – Affected Environment & Environmental Effects ............................................ 3-1

3.1 - Introduction ............................................................................................................... 3-1

3.1.1 – Chapter Organization .................................................................................................................... 3-1

3.1.2 – Presence or Absence of Particular Resources ............................................................................... 3-2

3.1.3 – Analysis Calculations ................................................................................................................... 3-2 iv

3.2 – Terrestrial Ecosystems .............................................................................................. 3-3

3.2.1 - Scope of the Analysis .................................................................................................................... 3-3

3.2.2 - Affected Environment .................................................................................................................... 3-3

3.2.3 - Environmental Consequences ....................................................................................................... 3-5

3.2.4 - Consistency with the Forest Plan ................................................................................................. 3-10

3.2.5 - Consistency with Laws, Regulations, and Handbooks ............................................................... 3-10

3.3 – Threatened, Endangered, and Sensitive Plants ....................................................... 3-12

3.3.1 - Scope of the Analysis .................................................................................................................. 3-12

3.3.2 - Affected Environment .................................................................................................................. 3-12

3.3.3 - Environmental Consequences ..................................................................................................... 3-18

3.3.4 - Consistency with the Forest Plan ................................................................................................. 3-35

3.3.5 - Consistency with Laws, Regulations, and Handbooks ............................................................... 3-36

3.4 – Soil Resource .......................................................................................................... 3-37

3.4.1 - Scope of the Analysis .................................................................................................................. 3-37

3.4.2 - Affected Environment .................................................................................................................. 3-37

3.4.3 - Environmental Consequences ..................................................................................................... 3-39

3.4.4 - Consistency with the Forest Plan ................................................................................................. 3-46

3.4.5 - Consistency with Laws, Regulations, and Handbooks ............................................................... 3-46

3.5 – Aquatic Resources .................................................................................................. 3-47

3.5.1 - Scope of the Analysis .................................................................................................................. 3-47

3.5.2 - Affected Environment .................................................................................................................. 3-47

3.5.3 - Environmental Consequences ..................................................................................................... 3-54

3.5.4 - Consistency with the Forest Plan ................................................................................................. 3-58

3.5.5 - Consistency with Laws, Regulations, and Handbooks ............................................................... 3-58

3.6 - Recreation and Scenery ........................................................................................... 3-59

3.6.1 - Scope of the Analysis .................................................................................................................. 3-59

3.6.2 - Affected Environment .................................................................................................................. 3-59

3.6.3 - Environmental Consequences ..................................................................................................... 3-60

3.6.4 - Consistency with the Forest Plan ................................................................................................. 3-62

3.6.5 - Consistency with Laws, Regulations, and Handbooks ............................................................... 3-62

3.7 - Human Health and Safety ........................................................................................ 3-63

3.7.1 - Scope of the Analysis .................................................................................................................. 3-63

3.7.2 - Affected Environment .................................................................................................................. 3-63

3.7.3 - Environmental Consequences ..................................................................................................... 3-64

3.7.4 - Consistency with the Forest Plan ................................................................................................. 3-70

3.7.5 - Consistency with Laws, Regulations, and Handbooks ............................................................... 3-70

3.8 - Wildlife Resources .................................................................................................. 3-71

3.8.1 - Scope of the Analysis .................................................................................................................. 3-71

3.8.2 - Affected Environment .................................................................................................................. 3-72

3.8.3 - Environmental Consequences ..................................................................................................... 3-88

3.8.4 - Consistency with the Forest Plan ............................................................................................... 3-106

3.8.5 - Consistency with Laws, Regulations, and Handbooks ............................................................. 3-106

Chapter 4 - Preparers, Contacts, and Literature Cited ........................................................ 4-1

4.1 Persons Who Prepared or Contributed to This EA ..................................................... 4-1

4.2 Agency, Organization, and Individual Contacts ......................................................... 4-2

4.3 Literature Cited ........................................................................................................... 4-5 v

Appendix A – Treatment Area Maps ................................................................................... A-1

Appendix B – Treatment Area Tables ..................................................................................B-1

Forest-wide NNIS Management Project Chapter 1 – Purpose and Need for Action

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Chapter 1 - Purpose and Need for Action

This chapter:

Provides a summary of the proposed action;

Describes the project area;

Discusses Forest Plan direction related to this project;

Describes the existing condition of the area as it relates to non-native invasive plants;

Explains why action is needed (referred to as the “purpose and need for action”);

Defines the scope of the analysis undertaken for this project;

Identifies the decisions to be made with this project;

Lists the applicable laws, regulations, and executive orders related to this project;

Explains how the public was informed of this proposal, and describes opportunities for public input; and

Summarizes the issues that were identified as a result of public involvement.

1.1 - Summary of Proposed Action

The Monongahela National Forest proposes to implement vegetation management and associated activities across the Forest over the next ten years to help meet direction in the Monongahela

National Forest Land and Resource Management Plan (Forest Plan, USDA Forest Service 2006).

This vegetative management is being proposed to:

Reduce the risk of nonnative invasive plant species (NNIS) introduction, Control NNIS plants that threaten high-interest ecosystems, Eliminate emerging infestations, and

Control NNIS plants that cause problems for resource management.

The proposed project includes the following actions:

Eradication of emerging infestations at trailheads, Limiting access and maintenance on roads that constitute high-risk invasion pathways, Establishment of programmatic treatment protocols, and

Site-specific treatments of existing high-priority infestations.

1.2 - Project Area Description

The proclamation and purchase unit boundary of the Monongahela National Forest includes approximately 1.7 million acres in Preston, Tucker, Grant, Barbour, Randolph, Pendleton, Pocahontas, Greenbrier, Nicholas, and Webster Counties, West Virginia. Lands within the boundary consist of approximately 920,000 acres of National Forest System (NFS) lands and about 780,000 acres of private, state, and other federal lands. The Forest includes land in the drainage basins of the Cheat, Elk, Gauley, Greenbrier, Potomac, and Tygarts Valley Rivers.

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Figure 1.1. Vicinity Map

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1.3 - Forest Plan Direction

National Forest Service land within the proclamation boundary is allocated to several management prescriptions, with management emphases ranging from timber production and age class diversity to wilderness. Management direction for non-native invasive species is contained within Forest-wide direction, which applies to all management prescriptions, although management direction in a particular management prescription can affect how Forest-wide direction is implemented in that management prescription.

Desired Conditions: The Forest-wide integrated desired conditions include the following statement: “[e]xisting non-native invasive species populations are not expanding and new invader species are not becoming established” (Forest plan, p. II-6). Forest-wide desired conditions for vegetation emphasize NNIS prevention by calling for an early detection/rapid response strategy for dealing with new invasive plant occurrences, and also by emphasizing the use of non-invasive species for revegetation efforts. Desired conditions address treatment by encouraging prioritization of existing infestations for treatment based on threats to specific resources and the ability to achieve control (Forest Plan, pp. II-17 and II-18).

Management Direction: Forest-wide goals, standards and guidelines for NNIS give specific direction for achieving desired conditions (Forest Plan, pp. II-19 through II-20). This direction emphasizes prevention, coordination with state and other federal agencies, prioritized treatment of infestations, inventory, and monitoring.

1.4 - Existing Conditions

Non-native invasive plants continue to spread on the Forest. Several rare plant communities are imminently threatened by expanding infestations. Many other high-interest ecosystems and large areas of contiguous federal ownership remain largely un-invaded, but threats to these ecosystems are increasing due to new spot infestations and continued spread along transportation corridors.

Control of invasive species continues to be a national and regional priority.

The Forest currently pursues several prevention and treatment strategies for NNIS. We anticipate that these strategies will continue regardless of the decision reached on the proposed project.

Public Outreach – The Forest uses web pages, brochures, posters, and personal contacts with the public to encourage visitors to take preventative measures such as cleaning boots, bicycles, vehicles, horses, carts, etc. prior to recreational visits to the Forest; not bringing livestock forage onto the Forest; using only locally-procured firewood; and other measures as deemed appropriate.

Weed-Free Forage and Mulch – Weed-free forage and mulch (hay) currently is not available in the local area. Therefore, the Forest generally requires that straw be substituted for hay wherever mulch is used. Straw is less likely than hay to contain NNIS because of the

1-4 more intensive cultivation under which it is produced. Permits for organized equestrian use on the Forest encourage users not to bring hay on to the National Forest whenever practical.

Cleaning of Logging Equipment – Cleaning of logging equipment prior to use on National

Forest land is national and regional policy. This activity is addressed through NEPA analyses for specific timber projects.

Follow-up Monitoring and Treatment of Project Sites – Projects that could contribute to the spread of NNIS generally include monitoring and follow-up treatment of high-priority

NNIS. Treatment activities are addressed through NEPA analyses for the specific projects.

Weed-Free Seed – Seed mixtures used on the Forest are tested by the vendor to ensure that they are free of noxious weed seeds.

Special Use Permits – When necessary, special use permits are conditioned to require prevention measures such as seed testing, prohibiting use of hay for mulch, and cleaning of construction and maintenance equipment.

Borrow Pit Inspection – The Forest Plan requires that on-Forest sources of borrow material be inspected to ensure that contaminated material is not used on Forest projects (Standard

VE21, p. II-20). Project-specific mitigation measures encourage inspection of off-Forest borrow sources to the extent practical.

The proposed action would expand the Forest’s existing NNIS plant management strategy to include treatment of existing and emerging infestations. Such treatments would better implement the NNIS goals and objectives in the Forest plan.

1.5 - Purpose and Need for Action

The purpose of this project is to limit, or where feasible, eliminate, the adverse effects of NNIS plants on ecosystems and other resources. This purpose is in accordance with desired conditions, goals, standards, and guidelines in the Forest Plan, as outlined above. Specific needs that have been identified are listed below:

Reduce the risk of NNIS plant introduction into currently un-infested areas;

Control NNIS plants that threaten rare communities and high-interest ecosystems such as botanical areas, candidate research natural areas, National Natural Landmarks, and TES species habitat;

Control NNIS plants that threaten ecosystem integrity in landscape-scale ecological reserves (wilderness areas, remote backcountry, etc.);

Eliminate emerging infestations of NNIS that have the potential to develop into large-scale ecosystem-damaging infestations;

Control NNIS plants that are impeding crop tree regeneration or damaging wildlife habitat improvements; and

Control NNIS plants that cause management problems for roads and facilities.

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1.6 - Scope of the Environmental Analysis

National Forest planning takes place at several levels: national; regional; forest; and project.

Analysis for the Monongahela Forest-wide Nonnative Invasive Plant Management Project is a combined analysis of Forest-level programmatic activities and specific project-level activities.

Its scope is confined to addressing the purpose and need of the project and possible environmental consequences of the proposal and alternatives. It implements direction provided at higher levels, but does not attempt to address decisions made at higher levels.

Where appropriate, this Environmental Assessment (EA) tiers to the 2006 Forest Plan Final

Environmental Impact Statement (FEIS), as encouraged by 40 CFR 1502.20. The FEIS and its

Record of Decision resulted in the Forest Plan that embodies the provisions of the National

Forest Management Act (NFMA), its implementing regulations, and other guiding documents, and sets forth in detail the direction for managing the land and resources of the Forest. This EA evaluates and documents the effects caused by the proposed activities and various alternatives.

The site-specific proposed action and alternatives to it are identified in Chapter 2. The administrative scope of this document can be defined as the laws and regulations that provide the framework for analysis.

1.7 - Responsible Official and Decisions to be Made

The Forest Supervisor of the Monongahela National Forest is the Responsible Official for the

Forest-wide Nonnative Invasive Plant Management Project decision. Given the information collected to date, the Forest Supervisor determined that an EA is the appropriate format for documenting the possible environmental impacts of proposed activities. This determination was based on a review of existing resource information and issues. The Forest Supervisor or designated representative will answer the following three questions based on the environmental analysis:

1) Will the proposed action proceed as proposed, as modified by an alternative, or not at all?

2) If it proceeds, what mitigation measures and monitoring requirements will be implemented?

3) Will the project require a Forest Plan amendment?

The decision will be documented in a Decision Notice and made available to the public.

1.8 - Applicable Laws and Executive Orders

The following is a partial list of federal laws and executive orders pertaining to project-specific planning and environmental analysis on federal lands that are addressed in Chapter 3 of this EA:

Multiple-Use Sustained-Yield Act of 1960;

National Historic Preservation Act of 1966 (as amended);

Wild and Scenic Rivers Act of 1968, amended 1986;

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National Environmental Policy Act of 1969 (as amended);

Clean Air Act of 1977 (as amended);

Endangered Species Act of 1973 (as amended);

Forest and Rangeland Renewable Resources Planning Act (RPA) of 1974 (as amended);

National Forest Management Act of 1976 (as amended);

Clean Water Act of 1977 (as amended);

American Indian Religious Freedom Act of 1978;

Archeological Resource Protection Act of 1979;

Cave Resource Protection Act of 1988; Executive Order 11593 (cultural resources);

Executive Order 11988 (floodplains);

Executive Order 11990 (wetlands);

Executive Order 12898 (environmental justice);

Executive Order 12962 (aquatic systems and recreational fisheries)

Executive Order 13112 (invasive species).

1.9 - Public Involvement

Scoping is the process of gathering comments about a site-specific proposed federal action to determine the scope of issues to be addressed and for identifying any unresolved issues that are related to the proposed action (40 CFR 1501.7).

Public input on proposed NNIS activities was solicited from the general public, Forest Service employees, other public agencies, adjacent property owners, and organizations. Public involvement was sought through various means:

On April 10, 2008, the scoping letter requesting input was sent to approximately 140 interested parties and landowners. This scoping letter summarized the purpose and need for action, the proposed action, and described various ways to get additional information and how to provide input on the proposal.

On April 11, 2008, a news release was sent to 14 local newspapers that cover media markets in Randolph, Pocahontas, Tucker, Pendleton, Grant, Greenbrier, Barbour, and Nicholas

Counties, as well as the cities of Morgantown, Charleston, Beckley, and Buckhannon. This news release gave a short summary of the purpose and need and proposed action, and described how to get additional information and how to provide input on the proposal.

The proposal and request for input were posted for review on the Monongahela National

Forest’s website at www.fs.fed.us/r9/mnf/ under “Forest Planning.”

Thirteen individuals and organizations have contacted us about the NNIS proposal in the form of letters, e-mails, or phone calls since the scoping process began in April, 2008 (project record).

Comments were used to define issues, develop alternatives, or identify environmental effects.

http://www.fs.fed.us/r9/mnf/

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The official 30-day Notice and Comment period began with the publication of a legal notice in

The Inter-Mountain newspaper, published in Elkins, West Virginia on March 5, 2009. That notice announced the availability of the Draft NNIS Environmental Assessment (EA and requested comments and input. The Responsible Official and Interdisciplinary Team (IDT) reviewed comments and input. The Decision Notice (DN) and Finding of No Significant Impact

(FONSI) for this EA will be signed and distributed to people who commented on the Draft EA, and a legal notice will be published to begin the appeal period.

1.10 - Issues

The purpose of soliciting comments is to determine whether significant issues exist that affect the proposed action or that may be affected by the proposed action. An issue is a point of discussion, dispute, or expression of concern (often about environmental effects). Not all issues are significant issues. Issues may be deemed significant because of the extent of their geographic distribution, the duration or intensity of their effects, or the intensity of interest or resource conflict. They are used to help formulate alternatives, prescribe mitigation measures, or analyze environmental effects. They are also used to determine the scope (49 CFR 1508.25) of the environmental analysis.

The Interdisciplinary Team (IDT) reviewed information received from individuals, adjacent landowners, organizations, internal specialists, and other agencies. The disposition of the comments that were received during the initial scoping period is documented in the project record. One issue was deemed to be significant and is described in the following section.

1.10.1 - Issue: Reduce the Impacts to Forest Resources from NNIS

This issue is the driver behind the purpose and need for the proposed action. Current NNIS populations are negatively affecting many different resources across the Forest, including native vegetation, crop tree establishment, wildlife habitat, livestock forage, and soil productivity.

Impacts to these and other resources are described in detail in Chapter 3 of this EA. As NNIS plant populations continue to increase, so will their impacts. The Forest needs to develop a long-term strategy for addressing and reducing NNIS impacts to meet Forest Plan direction and desired conditions related to native vegetation and other resources, as described above.

This issue is so dominant that many scoping comments focused on a desire to expand the proposed action to cover additional NNIS species, additional treatment sites, and to grant a broader programmatic authority to treat unspecified future sites. These comments expressed concern that the proposed action did not include enough high-priority sites, such as specific wildlife openings and botanical areas, or high-priority species, such as multiflora rose and pitcher plants. We do not disagree with these comments, but the reality is that we do not have the workforce or funding to treat all of the NNIS that currently exist across the Forest. That is why the establishment of treatment protocols is such a key component of the proposed action.

These protocols would allow us to treat additional infestations, either existing or new, as funds become available and are prioritized for this important task.

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The indicator for effectively addressing this issue is the potential reduction in NNIS plants and their impacts by alternative, which includes not only treatment of current infestations but also measures to prevent establishment of new infestations. The units of measure we will use to compare the effectiveness of the alternatives are:

Acres of potential NNIS treatment by alternative, Treatment protocols established by alternative, and

NNIS preventive measures proposed by alternative.

Forest-wide NNIS Management Project Chapter 2 – Alternatives Considered

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Chapter 2 – Alternatives Considered

This chapter:

Describes the alternatives that were considered to address issues and concerns;

Identifies the design features and mitigation measures that would be implemented to reduce the chance of adverse resource effects; and

Summarizes the activities and effects of the alternatives in comparative form to clearly display the differences between each alternative and to provide a clear basis for choice among options by the decision maker and the public.

2.1 - Alternatives Considered but Eliminated from Detailed Study

During initial planning and scoping, several potential alternatives to the proposed action were suggested. The following is a summary of the alternatives that contributed to the overall range of alternatives considered, but, for the reasons noted here, were eliminated from detailed study.

2.1.1 - Control NNIS on Private Land Not Adjacent to National Forest Land

Several people expressed interest in collaborating with the Forest to control NNIS on private property that is not adjacent to National Forest land. While such collaboration may be desirable for reducing local NNIS populations, the proper vehicle for such collaboration is a Cooperative

Weed Management Area (CWMA) involving landowners, the Forest Service, and other state, federal, and local agencies. The purpose and need focuses on authorizing treatment of infestations; collaborating to achieve control on a broader scale can be pursued independent of this project as staff and funding allow. Elimination of this concept as an alternative does not preclude the Forest from collaborating with the owners of land that is adjacent to treatment sites on National Forest land.

2.1.2 - Collaborate with Adjacent Landowners on Prescribed Fire

One adjacent private landowner expressed a desire to cooperate with the Forest on prescribed fire. While prescribed fire can assist with the control of some NNIS plants, it would be ineffective to pursue as a separate management strategy. Collaboration with adjacent landowners is likely to be desirable where the Forest uses prescribed fire, but such collaboration is best addressed in the context of projects that focus on prescribed fire for silviculture or ecosystem restoration.

2.1.3 - Do Not Plant Species on the West Virginia Division of Natural

Resources NNIS List

The purpose and need focuses on treatment of existing infestations rather than planting. The

Forest Service already has national, regional, and local policies and management direction in place to prohibit the planting of species determined by the Forest Service to be NNIS.

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2.1.4 - Control Non-native Insects

The purpose and need for this project focuses on NNIS plants. The Forest Service, acting through State and Private Forestry and in conjunction with the West Virginia Department of

Agriculture, already has programs in place to monitor and control non-native insects.

2.1.5 - Treat Undesirable Native Plant Species

One comment suggested treating aggressive native species such as black locust, striped maple, beech suckers, and ferns in wildlife habitat developments and old timber harvest units across the

Forest. The purpose and need for this project is specific to non-native invasive plants. Control of undesirable native species in wildlife habitat developments is best addressed through a separate analysis that covers all aspects of the maintenance of such developments. Control of undesirable native vegetation in timber management units is best addressed at the project level through NEPA documents for timber projects.

2.2 - Alternatives Given Detailed Study

The following section describes the two alternatives that were studied in detail: Alternative 1

(No Action) and Alternative 2 (Proposed Action). Acres or miles identified for activities have been identified from mapping and should be considered estimates.

2.2.1 - Alternative 1 – No Action

The No Action alternative was developed as a baseline for comparison with the action alternative. This alternative provides the decision-maker with a clearer basis for a reasoned choice among the alternatives studied in detail. Under this alternative, additional new management activities would not be implemented to help meet the purpose and need for action described in Chapter 1. This alternative is essentially the “status quo” strategy. It allows current management activities and policies to continue unchanged. For example, the ongoing NNIS prevention and treatment strategies outlined in section 1.4 would continue, but no additional sites would be treated and Forest-wide protocols for future NNIS plant management would not be established. No herbicide use or other forms of NNIS control would occur beyond those control activities that are conducted in conjunction with other projects.

2.2.2 - Alternative 2 – Proposed Action

The proposed action is an integrated, Forest-wide management strategy for NNIS plants. This action consists of two major components: preventing the spread of NNIS plants into new areas, and treating existing infestations. Although components of both prevention and treatment are included in many of the proposed activities, the activities have been categorized below according to the major emphasis.

The proposed action is both programmatic and site-specific. It is programmatic in that it establishes basic protocols for prevention and control of many high-priority species in typical

2-3 situations. It is also site-specific in that it identifies a limited set of high-priority sites where specific prevention and control measures would be implemented.

Total eradication of all NNIS is considered impractical due to the widespread nature of some

NNIS, the large number of species involved, multiple locations, the difficulty of obtaining a complete inventory, lack of acceptable control methods for certain species and habitats, potential effects on desirable species, the likelihood of reinvasion in disturbed habitats, and the prohibitive amount of labor and money that likely would be required. Therefore, consistent with Forest Plan direction, proposed activities have been prioritized to focus on protection of high-interest ecosystems and resources, and on plant species that pose the greatest risk and for which control efforts have a reasonable chance of succeeding.

Prevention

Trailhead Sanitation

Selected trails and trailheads that provide access to sensitive ecosystems and major backcountry areas would be monitored at least once every three years, especially near parking areas, to detect new NNIS infestations (Map 1, Appendix A). If NNIS with the potential to cause ecosystem disruption or damage to facilities (high-priority NNIS) appear, they would be controlled using one of the treatment methods outlined in the Treatment section below.

Invasion Pathways

Roads that provide potential invasion pathways for high-priority NNIS into sensitive ecosystems would be placed into storage. Road storage involves blocking access to the road, removing culverts, and conducting activities that may be necessary to maintain long-term stability such as constructing water bars and seeding or mulching erosion-prone areas. Cessation of vehicle traffic and maintenance would reduce the likelihood of NNIS plants dispersing along the road corridor. Because the road prisms would remain intact, stored roads could be re-opened if they are needed for future management access. Preventative measures such as equipment cleaning, clean mulch, use of non-invasive plant species, seed testing, and follow-up monitoring would be employed to reduce the risk of introducing or spreading NNIS via the storage activities.

Proposed road storage would involve 10 roads (including four non-system roads) totaling approximately 11.5 miles. The roads would be stored in conjunction with NNIS treatment activities in the Cheat Mountain area (see map for Cheat Mountain area referenced in the

Treatment section below). All of the roads proposed for storage are currently shown as gated on the Forest visitor map (i.e., closed to the public), but the gate on one of the roads (Forest Road

27B) recently has remained open year-round. Because the road prisms would remain intact, stored roads could be re-opened if they are needed for future management access.

Treatment

Treatment would focus on NNIS that pose a direct threat to ecosystems and resources of interest.

Many of the species proposed for treatment spread aggressively, are shade-tolerant, or both.

These species pose particular risks to forested ecosystems or to unique communities such as

2-4 limestone glades or wetlands. These species are not proposed for control at every site where they are known to occur; rather, they are proposed for control at sites where they threaten high-value resources or where they are believed to be small emerging infestations that can be eliminated before they get out of hand. Likewise, some NNIS plants that are known to occur on the Forest are not proposed for site-specific control because they are not known to threaten high-value resources or they are so ubiquitous that control is not practical. Programmatic protocols have been developed for many of these in case control of these species becomes a high priority in the future.

The treatment component of the proposed action includes the establishment of programmatic protocols for treatment in typical situations, as well as treatment of specific high-priority sites.

At most sites, treatments likely will need to be repeated annually for several years to achieve effective control.

Programmatic Protocols

The following protocols are proposed for typical treatment methods and the typical situations where these methods will be applied:

Foliar Application of Herbicide Foliar application involves spraying or wiping herbicide on the leaves of NNIS plants. The herbicide generally is diluted in water, and the solution often contains a nonionic surfactant that helps the herbicide penetrate the waxy cuticle of the leaf. The solution may also contain a dye to help the applicator avoid double application. This method can be used for targeted spot applications where NNIS plants are scattered among desirable vegetation. It can also be used to broadcast herbicide over large, continuous NNIS infestations. Because of limitations of the application equipment, applicator safety concerns, and the potential for impacts to non-target vegetation, foliar application typically would be limited to vegetation that is no more than 6 feet tall. For spot applications and applications in areas that are not accessible by vehicle, backpack sprayers would be used. Where very precise spot applications are needed, a wick or glove would be used to wipe herbicide onto the target plants. For large infestations along roads, skid trails, and other areas accessible by vehicle, vehicle-mounted sprayers would be used. Aerial application is not proposed.

Cut Surface Application of Herbicide Cut surface application of herbicide is used to control NNIS trees, shrubs, and vines. Several cuts are made in the outer bark, and an herbicide solution is squirted onto the exposed cambium

(inner bark). Alternatively, the plant can be cut down and the herbicide solution applied to the stump. The herbicide generally is diluted in water, although the solution usually is several times more concentrated than solutions used for foliar applications. This precisely targeted application method has very low potential for runoff or impacts to non-target plants.

Basal Spray Application of Herbicide Basal spray is similar to cut surface in that the herbicide is applied directly to the lower stem of

NNIS trees, shrubs, and vines. However, basal spray differs by applying the herbicide solution to the outer bark, without making any cuts. Therefore, basal spray applications are less labor

2-5 intensive than cut surface applications. The herbicide generally is diluted in an oil solution to allow it to penetrate the bark.

Hand Pulling Very small infestations of weak-rooted NNIS plants can be controlled through pulling the plants up by hand. This method is useful for herbaceous and small woody NNIS that are interspersed with high-value non-target plants such as threatened, endangered, or sensitive species. However, it is slow and labor intensive and therefore not practical for large infestations.

Mowing Mowing can be useful for preventing seed production and exhausting root reserves in annuals, biennials, or short-lived perennials. It can be accomplished using tractors, brush hogs, mowing machines, scythes, or string trimmers. Mowing is sometimes used in lieu of herbicides where soil or water quality concerns exist. However, it is not useful for many NNIS species, and it must be timed precisely to cut the plants just before seed production. Mowing also can affect non-target plants that are interspersed with the NNIS. Care must be taken to avoid spreading viable plant parts via mowing equipment.

Grubbing In situations where herbicide use is undesirable and mowing and hand pulling are not effective, NNIS plants may be dug out by the roots using hand tools such as grubbers, weed wrenches, and shovels. Although grubbing avoids the use of herbicide, it causes soil disturbance and can have physical impacts on non-target species. It does not provide effective control for species that are capable of regenerating from small pieces of plant material left in the soil.

Biological Control Of the variety of high-priority NNIS plants in need of control on the Forest, only the knapweeds are known to be susceptible to effective and commercially available biological control agents.

Several species of seed-head feeding and root-boring flies, moths, and beetles may be used to control knapweeds. These biological control agents eat only knapweeds and do not pose a risk to non-target plants or animals. If biological control agents become available for other species, these agents may be used after they have passed standard U.S. Department of Agriculture screening.

Prescribed Fire Prescribed fire can exert a controlling effect on some NNIS plants, notably garlic mustard.

While prescribed fire alone is unlikely to achieve effective control, on large infestations it may be used in conjunction with other methods to reduce the extent of herbicide applications.

Prescribed fire would only be applied in fire adapted or highly altered ecosystems.

Typical Control Situations We anticipate that most NNIS control needs on the Forest will fall into one of the following situations:

Forest Roads – Many infestations occur along Forest roads because of their function as dispersal vectors. Most NNIS in this situation are low growing due to recurrent maintenance; therefore, 2-6 foliar application of herbicide would be the most common control method. Vehicle mounted sprayers likely will be used for many infestations, although a backpack sprayer may be used for isolated spot spraying. Carefully timed mowing may be used to control seed production in widespread annuals such as Japanese stiltgrass.

State Roads and Highways – Some infestations occur where state roads and highways traverse

National Forest land. Control activities would be similar to those along Forest roads, but coordination with the West Virginia Division of Highways would be necessary.

General Forest Areas – Many high-priority NNIS have penetrated into natural habitats via old skid routes, trails, or overland seed dispersal. Any of the control methods outlined above may be used on these infestations, depending on the species to be controlled and the presence of other resource concerns.

Near Streams or Other Bodies of Water – A Forest-wide effort to control high-priority NNIS that threaten high value ecosystems cannot avoid control efforts near water bodies. Control methods that do not use herbicides would be used whenever possible. However, in many cases, non-herbicide methods could not be expected to provide effective, practical control. Where herbicides must be used within stream channel buffers as defined by the Forest Plan, or within

100 feet of other water bodies, only herbicides registered for aquatic use would be used. Where herbicides must be applied to emergent vegetation, only wick or glove applicators would be used.

Near Rare Plant Occurrences – NNIS plants may need to be controlled to protect occurrences of threatened, endangered, and sensitive plants from aggressive competition. However, the control methods also have the potential to affect rare plants inadvertently. Control methods that do not use herbicides would be used whenever possible. However, non-herbicide methods may not be effective or practical in some cases. Where herbicides must be used within 100 feet of known occurrences, only spot application methods would be used. Care would also be used to minimize the non-target effects of hand and mechanical control methods (trampling, soil disturbance, or cutting).

Future Treatment Activities Although the proposed action identifies many specific sites across the Forest for treatment, it is likely that more high-priority treatment sites will be discovered. Therefore, the proposed action provides for the treatment of these additional sites after a review of the condition of any resources that may be affected. At a minimum, this review would involve wildlife, aquatics, botany, TES species, silviculture, recreation, and cultural resources. Treatment activities must involve situations similar to those programmatic and site-specific situations already analyzed, and any resource effects must be within the scale and scope of effects already analyzed. Line officer review and approval would be required prior to treatment. New herbicides and treatment methods would not be used without appropriate additional NEPA analysis and documentation.

Table 2.1 summarizes…