Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

Long Pond Phragmites Management Notice of Intent Submittal

Nantucket, Massachusetts

Prepared for Nantucket Conservation Foundation, Inc.

Prepared by SWCA Environmental Consultants

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Massachusetts Department of Environmental Protection Provided by MassDEP:

This Ecological Restoration Limited Project Eligibility Checklist guides the applicant in determining if their project is eligible to file as an Inland or Coastal Ecological Restoration Limited Project (310 CMR 10.53(4) or 310 CMR 10.24(8) respectively). These criteria must be met when submitting the Ecological Restoration Limited Project Notice of Intent to ensure that the restoration and improvement of the natural capacity of a Resource Area(s) to protect and sustain the interests identified in the WPA is necessary to achieve the project’s ecological restoration goals.

Important: When filling out Regulatory Features of All Coastal and Inland Ecological Restoration Limited Projects forms on the computer, use only the tab key (a) May result in the temporary or permanent loss of/or conversion of Resource Area: An Ecological to move your Restoration Limited Project that meets the requirements of 310 CMR 10.24(8) may result in the cursor - do not use the return temporary or permanent loss of Resource Areas and/or the conversion of one Resource Area to key. another when such loss is necessary to the achievement of the project’s ecological restoration goals.

(b) Exemption from wildlife habitat evaluation: A NOI for an Ecological Restoration Limited Project that meets the minimum requirements for Ecological Restoration Projects and for a MassDEP Combined Application outlined in 310 CMR 10.12(1) and (2) is exempt from providing a wildlife habitat evaluation

(310 CMR 10.60).

Note: (c) The following are considerations for applicants filing an Ecological Restoration Limited Project NOI Before and for the issuing authority approving a project as an Ecological Restoration Limited Project: completing this form consult your The condition of existing and historic Resource Areas proposed for restoration. local Conservation Evidence of the extent and severity of the impairment(s) that reduce the capacity of the Resource Commission Areas to protect and sustain the interests identified in M.G.L. c. 131, § 40. regarding any municipal bylaw or ordinance. The magnitude and significance of the benefits of the Ecological Restoration Project in improving the capacity of the affected Resource Areas to protect and sustain the other interests identified in M.G.L. c. 131, § 40. The magnitude and significance of the impacts of the Ecological Restoration Project on existing Resource Areas that may be modified, converted and/or lost and the interests for which said Resource Areas are presumed significant in 310 CMR 10.00, and the extent to which the project will:

a. avoid adverse impacts to Resource Areas and the interests identified in M.G.L. c. 131, § 40, that can be avoided without impeding the achievement of the project’s ecological restoration

goals. b. minimize adverse impacts to Resource Areas and the interests identified in M.G.L. c. 131, § 40, that are necessary to the achievement of the project’s ecological restoration goals. c. utilize best management practices such as erosion and siltation controls and proper construction sequencing to avoid and minimize adverse construction impacts to resource areas and the interests identified in M.G.L. c. 131, § 40.

noiappa.doc • rev 2/8/2018 Notice of Intent Appendix A: Ecological Restoration Limited Project Eligibility Checklists • Page 1 of 16

Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number WPA Form 3 – Notice of Intent 1249503 Document Transaction Number Appendix A: Ecological Restoration Limited Nantucket Project Checklists City/Town Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Eligibility Criteria - Coastal Ecological Restoration Limited Projects (310 CMR 10.24(8))

Complete this Eligibility Criteria Checklist before filling out a Notice of Intent Application to determine if your project qualifies as a Coastal Ecological Restoration Limited Project. (310 CMR 10.24(8)) Sign the Eligibility Certification at the end of Appendix A, and attach the checklist with supporting documentation and the Eligibility Certification to your Notice of Intent Application.

General Eligibility Criteria for All Coastal Ecological Restoration Limited Projects

Notwithstanding the requirements of 310 CMR 10.25 through 10.35, 310 CMR 10.54 through 10.58, and the Wildlife Habitat evaluations in 310 CMR 10.60, the Issuing Authority may issue an Order of Conditions permitting an Ecological Restoration Project listed in 310 CMR 10.24(8)(e) as an

Ecological Restoration Limited Project and impose such conditions as will contribute to the interests identified in the WPA M.G.L. provided that the project meets all the requirements in 310 CMR 10.24 (8). The project is an Ecological Restoration Project as defined in 310 CMR 10.04 and is a project type

listed below [310 CMR 10.24(8)(e)]. Tidal Restoration.

Shellfish Habitat Restoration.

Other Ecological Restoration Limited Project Type.

The project will further at least one of the WPA (M.G.L. c. 131, § 40) interests identified below.

Protection of public or private water supply.

Protection of ground water supply.

Flood control.

Storm damage prevention.

Prevention of pollution.

Protection of land containing shellfish.

Protection of fisheries.

Protection of wildlife habitat.

If the project will impact an area located within estimated habitat which is indicated on the most recent Estimated Habitat Map of State-Listed Rare Wetlands, a NHESP preliminary written determination is attached to the NOI submittal that the project will not have any adverse long-term and short-term effects on specified habitat sites of Rare Species or the project will be carried out in accordance with an approved NHESP habitat management plan.

noiappa.doc • rev 2/8/2018 Notice of Intent Appendix A: Ecological Restoration Limited Project Eligibility Checklists • Page 2 of 16

Massachusetts Department of Environmental Protection Provided by MassDEP:

General Eligibility Criteria for All Coastal Ecological Restoration Limited Projects (cont.) If the project is located in a Coastal Dune or Barrier Beach, the project avoids and minimizes

armoring of the Coastal Dune or Barrier Beach to the maximum extent practicable. The project complies with all applicable provisions of 310 CMR 10.24(1) through (6) and 310 CMR

10.24(9) and (10). Additional Eligibility Criteria for Specific Coastal Ecological Restoration Limited Project Types

These additional criteria must be met to qualify as an Ecological Restoration Limited Project to ensure that the restoration and improvement of the natural capacity of a Resource Area to protect and sustain the interests identified in the WPA is necessary to achieve the project’s ecological restoration goals.

This Ecological Restoration Limited Project application meets the eligibility criteria for Ecological Restoration Limited Project [310 CMR 10.24(8)(a) through (d) and as proposed, furthers at least one of the WPA interests is for the project type identified below.

Tidal Restoration Projects

A project to restore tidal flow that will not significantly increase flooding or storm damage impacts to the built environment, including without limitation, buildings, wells, septic

systems, roads or other man-made structures or infrastructure.

Shellfish Habitat Restoration Projects The project has received a Special Projects Permit from the Division of Marine Fisheries or, if a municipality, has received a shellfish propagation permit. The project is made of cultch (e.g., shellfish shells from oyster, surf or ocean clam) or is a structure manufactured specifically for shellfish enhancement (e.g., reef blocks, reef balls, racks, floats, rafts, suspended gear). Other Ecological Restoration Projects that meet the criteria set forth in 310 CMR

10.24(8)(a) through (d). Restoration, enhancement, or management of Rare Species habitat.

Restoration of hydrologic and habitat connectivity.

Removal of aquatic nuisance vegetation to impede eutrophication.

Thinning or planting of vegetation to improve habitat value.

Fill removal and re-grading.

Riparian corridor re-naturalization.

River floodplain re-connection.

noiappa.doc • rev 2/8/2018 Notice of Intent Appendix A: Ecological Restoration Limited Project Eligibility Checklists • Page 3 of 16

Massachusetts Department of Environmental Protection Provided by MassDEP:

Additional Eligibility Criteria for Specific Coastal Ecological Restoration Limited Project Types

In-stream habitat enhancement.

Remediation of historic tidal wetland ditching.

Eelgrass restoration.

Invasive species management.

Installation of fish passage structures.

Other. Describe: This project involves the construction, repair, replacement or expansion of public or private

infrastructure (310 CMR 10.24(9). The NOI attachment labeled is an operation and maintenance plan to ensure that the

infrastructure will continue to function as designed. The operation and maintenance plan will be implemented as a continuing condition in the

Order of Conditions and the Certificate of Compliance. This project proposes to replace an existing stream crossing (310 CMR 10.24(10). The crossing complies with the Massachusetts Stream Crossing Standards to the maximum extent practicable with details provided in the NOI. The crossing type: Replaces an existing non-tidal crossing that is part of an Anadromous/Catadromous Fish

Run (310 CMR 10.35) Replaces an existing tidal crossing that restricts tidal flow. The tidal restriction will be

eliminated to the maximum extent practicable. At a minimum, in evaluating the potential to comply with the standards to the maximum extent

practicable the following criteria have been consider site constraints in meeting the standard, undesirable effects or risk in meeting the standard, and the environmental benefit of meeting the standard compared to the cost, by evaluating the following:

The potential for downstream flooding;

Upstream and downstream habitat (in-stream habitat, wetlands);

Potential for erosion and head-cutting;

Stream stability;

Habitat fragmentation caused by the crossing;

The amount of stream mileage made accessible by the improvements;

Storm flow conveyance;

noiappa.doc • rev 2/8/2018 Notice of Intent Appendix A: Ecological Restoration Limited Project Eligibility Checklists • Page 4 of 16

Massachusetts Department of Environmental Protection Provided by MassDEP:

Additional Eligibility Criteria for Specific Coastal Ecological Restoration Limited Project Types

Engineering design constraints specific to the crossing;

Hydrologic constraints specific to the crossing;

Impacts to wetlands that would occur by improving the crossing;

Potential to affect property and infrastructure; and

Cost of replacement. Eligibility Criteria - Inland Ecological Restoration Limited Project (310 CMR 10.53(4))

Complete this Eligibility Criteria Checklist before filling out a Notice of Intent Application to determine if your project qualifies as an Inland Ecological Restoration Limited Project. (310 CMR 10.53(4)) Sign the Eligibility Certification at the end of Appendix A, and attach the checklist with supporting documentation and the Eligibility Certification to your Notice of Intent Application.

General Eligibility Criteria for All Inland Ecological Restoration Limited Projects

Notwithstanding the requirements of any other provision of 310 CMR 10.25 through 10.35, 310 CMR 10.54 through 10.58, and 310 CMR 10.60, the Issuing Authority may issue an Order of Conditions permitting an Ecological Restoration Project listed in 310 CMR 10.53(4)(e) as an Ecological Restoration Limited Project and impose such conditions as will contribute to the interests identified in M.G.L. c. 131, § 40, provided that: The project is an Ecological Restoration Project as defined in 310 CMR 10.04 and is a project type listed below [310 CMR 10.53(4)(e)]. Dam Removal

Freshwater Stream Crossing Repair and Replacement

Stream Daylighting

Tidal Restoration

Rare Species Habitat Restoration

Restoring Fish Passageways Invasive plant management Other (describe project type):

noiappa.doc • rev 2/8/2018 Notice of Intent Appendix A: Ecological Restoration Limited Project Eligibility Checklists • Page 5 of 16

Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number WPA Form 3 – Notice of Intent 1249503 Document Transaction Number Appendix A: Ecological Restoration Limited Nantucket Project Checklists City/Town Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Eligibility Criteria - Inland Ecological Restoration Limited Project (310 CMR 10.53(4)) (cont.)

General Eligibility Criteria for All Inland Ecological Restoration Limited Projects

The project will further at least one of the WPA (M.G.L. c. 131, § 40) interests identified below.

Protection of public or private water supply

Protection of ground water supply

Flood control

Storm damage prevention

Prevention of pollution

Protection of land containing shellfish

Protection of fisheries

Protection of wildlife habitat

If the project will impact an area located within estimated habitat which is indicated on the most recent Estimated Habitat Map of State-Listed Rare Wetlands, a NHESP preliminary written

determination is attached to the NOI submittal that the project will have no adverse long-term and short-term effects on specified habitat sites of Rare Species or the project will be carried out in

accordance with an approved NHESP habitat management plan.

The project will be carried out in accordance with any time of year restrictions or other conditions recommended by the Division of Marine Fisheries for coastal waters and the Division of Fisheries

and Wildlife in accordance with 310 CMR 10.11(3).

If the project involves the dredging of 100 cubic yards of sediment or more or dredging of any amount in an Outstanding Resource Water, a Water Quality Certification has been applied for or

obtained.

The project complies with all applicable provisions of 310 CMR 10.53(1), (2), (7), and (8).

noiappa.doc • rev 2/8/2018 Notice of Intent Appendix A: Ecological Restoration Limited Project Eligibility Checklists • Page 6 of 16

Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number WPA Form 3 – Notice of Intent 1249503 Document Transaction Number Appendix A: Ecological Restoration Limited Nantucket Project Checklists City/Town Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Eligibility Criteria - Inland Ecological Restoration Limited Project (310 CMR 10.53(4)) (cont.)

Additional Eligibility Criteria for Specific Inland Ecological Restoration Limited Project Types

the interests identified in the WPA is necessary to achieve the project’s ecological restoration goals.

This project application meets the eligibility criteria for Ecological Restoration Limited Project in accordance with [310 CMR 10.53(4)(a) through (d) and as proposed, furthers at least one of the

WPA interests is for the project type identified below:

Dam Removal

Project is consistent with MassDEP’s 2007 Dam Removal Guidance. Freshwater Stream Crossing Repair and Replacement. The project as proposed and the NOI describes how:

Meeting the eligibility criteria set forth in 310 CMR 10.13 would result in significant stream instability or flooding hazard that cannot otherwise be mitigated, and site constraints make

it impossible to meet said criteria.

The project design ensures that the stability of the bank is NOT impaired.

To the maximum extent practicable, the project provides for the restoration of the stream upstream and downstream of the structure as needed to restore stream continuity and

eliminate barriers to aquatic organism movement.

The project complies with the requirements of 310 CMR 10.53(7) and (8).

Stream Daylighting Projects

The project meets the eligibility criteria for Ecological Restoration Limited Project [310 CMR 10.53(4)(a) through (d)] and as proposed the NOI describes how the proposed

project meets to the maximum extent practicable, consistent with the project’s ecological restoration goals, all the performance standards for Bank and Land Under Water Bodies

and Waterways. The project meets the requirements of 310 CMR 10.12(1) and (2) and a wildlife habitat evaluation is not included in the NOI.

Tidal Restoration Project

Restores tidal flow.

the project, including any proposed flood mitigation measures, will not significantly increase flooding or storm damage to the built environment, including without limitation,

buildings, wells, septic systems, roads or other man-made structures or infrastructure.

noiappa.doc • rev 2/8/2018 Notice of Intent Appendix A: Ecological Restoration Limited Project Eligibility Checklists • Page 7 of 16

Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number WPA Form 3 – Notice of Intent 1249503 Document Transaction Number Appendix A: Ecological Restoration Limited Nantucket Project Checklists City/Town Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Eligibility Criteria - Inland Ecological Restoration Limited Project (310 CMR 10.53(4)) (cont.)

Other Ecological Restoration Projects that meet the criteria set forth in 310 CMR 10.53 (4) (a) through (d).

Restoration, enhancement, or management of Rare Species habitat.

Restoration of hydrologic and habitat connectivity.

Removal of aquatic nuisance vegetation to impede eutrophication.

Thinning or planting of vegetation to improve habitat value.

Riparian corridor re-naturalization.

River floodplain re-connection.

In-stream habitat enhancement.

Fill removal and re-grading.

Flow restoration.

Installation of fish passage structures.

Invasive species management.

Other. Describe: This project involves the construction, repair, replacement or expansion of public or private infrastructure. (310 CMR 10.53(7)) The NOI attachment labeled is an operation and maintenance plan to ensure that the infrastructure will continue to function as designed. The operation and maintenance plan will be implemented as a continuing condition in the Order of Conditions and the Certificate of Compliance.

This project replaces an existing stream crossing (310 CMR 10.53(8)). The crossing type: Replaces an existing non-tidal crossing designed to comply with the Massachusetts Stream Crossing Standards to the maximum extent practicable with details provided in the NOI. Replaces an existing tidal crossing that restricts tidal flow. The tidal restriction will be eliminated to the maximum extent practicable.

noiappa.doc • rev 2/8/2018 Notice of Intent Appendix A: Ecological Restoration Limited Project Eligibility Checklists • Page 8 of 16

Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number WPA Form 3 – Notice of Intent 1249503 Document Transaction Number Appendix A: Ecological Restoration Limited Nantucket Project Checklists City/Town Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Eligibility Criteria - Inland Ecological Restoration Limited Project (310 CMR 10.53(4)) (cont.)

At a minimum, in evaluating the potential to comply with the standards to the maximum extent practicable the following criteria have been consider site constraints in meeting the standard, undesirable effects or risk in meeting the standard, and the environmental benefit of meeting the standard compared to the cost, by evaluating the following:

The potential for downstream flooding;

Upstream and downstream habitat (in-stream habitat, wetlands);

Potential for erosion and head-cutting;

Stream stability;

Habitat fragmentation caused by the crossing;

The amount of stream mileage made accessible by the improvements;

Storm flow conveyance;

Engineering design constraints specific to the crossing;

Hydrologic constraints specific to the crossing;

Impacts to wetlands that would occur by improving the crossing;

Potential to affect property and infrastructure; and

Cost of replacement.

noiappa.doc • rev 2/8/2018 Notice of Intent Appendix A: Ecological Restoration Limited Project Eligibility Checklists • Page 9 of 16

Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number WPA Form 3 – Notice of Intent 1249503 Document Transaction Number Appendix A: Ecological Restoration Limited Nantucket Project Checklists City/Town Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Required Actions (310 CMR 10.11) Complete the Required Actions before submitting a Notice of Intent Application for an Ecological Restoration Project and submit a completed copy of this Checklist with the Notice of Intent.

Massachusetts Environmental Policy Act (MEPA) / Environmental Monitor http://www.mass.gov/eea/agencies/mepa/submitting-notices-to-the-environmental-monitor.html

For Ecological Restoration Limited Projects, there are no changes to MEPA requirements.

Submit written notification at least 14 days prior to the filing of a Notice of Intent (NOI) to the Environmental Monitor for publication. A copy of the written notification is attached and provides at

minimum:

A brief description of the proposed project.

The anticipated NOI submission date to the conservation commission.

The name and address of the conservation commission that will review the NOI. Specific details as to where copies of the NOI may be examined or acquired and where to obtain the date, time, and location of the public hearing.

Massachusetts Endangered Species Act (MESA) /Wetlands Protection Act Review Preliminary Massachusetts Endangered Species Act Review from the Natural Heritage and Endangered Species Program (NHESP) has been met and the written determination is attached.

Supplemental Information for Endangered Species Review has been submitted.

1. Percentage/acreage of property to be altered: 20% a. Within Wetland Resource Area Percentage/acreage 0% b. Outside Wetland Resource Area Percentage/acreage

2. Assessor’s Map or right-of-way plan of site

3. Project plans for entire project site, including wetland resource areas and areas outside of wetlands jurisdiction, showing existing and proposed conditions, existing and

proposed tree/vegetation clearing line, and clearly demarcated limits of work. 4. Project description (including description of impacts outside of wetland resource area & buffer zone)

5. Photographs representative of the site 6. MESA filing fee (fee information available at http://www.mass.gov/dfwele/dfw/nhesp/regulatory_review/mesa/mesa_fee_schedule.htm)

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Massachusetts Department of Environmental Protection Provided by MassDEP:

Make check payable to “Commonwealth of Massachusetts - NHESP” and mail to NHESP: Natural Heritage & Endangered Species Program MA Division of Fisheries & Wildlife 1 Rabbit Hill Road Westborough, MA 01581

7. Projects altering 10 or more acres of land, also submit:

a. Vegetation cover type map of site

b. Project plans showing Priority & Estimated Habitat boundaries

OR Check One of the Following:

1. Project is exempt from MESA review. Attach applicant letter indicating which MESA exemption applies. (See 321 CMR 10.14, http://www.mass.gov/eea/agencies/dfg/dfw/natural-heritage/regulatory-review/mass- endangered-species-act-mesa/; the NOI must still be sent to NHESP if the project is within estimated habitat pursuant to 310 CMR 10.37 and 10.59 – see C4 below)

2. Separate MESA review ongoing.

a. NHESP Tracking # b. Date submitted to NHESP 3. Separate MESA review completed. Include copy of NHESP “no Take” determination or valid Conservation & Management Permit with approved plan.

Estimated Habitat Map of State-Listed Rare Wetlands Wildlife

If a portion of the proposed project is located in Estimated Habitat of Rare Wildlife as indicated on the most recent Estimated Habitat Map of State-Listed Rare Wetland Wildlife published by the

Natural Heritage and Endangered Species Program (NHESP), complete the portion below. To view habitat maps, see the Massachusetts Natural Heritage Atlas or view the maps

electronically at: http://www.mass.gov/eea/agencies/dfg/dfw/natural-heritage/regulatory-review A preliminary written determination from Natural Heritage and Endangered Species Program (NHESP) must be obtained indicating that:

Project will NOT have long- or short-term adverse effect on the actual Resource Area located within estimated habitat indicated on the most recent Estimated Habitat Map of

State-Listed Rare Wetlands Wildlife published by NHESP.

Project will have long- or short-term adverse effect on the actual Resource Area located within estimated habitat indicated on the most recent Estimated Habitat Map of State-

Listed Rare Wetlands Wildlife published by NHESP. A copy of NHESP’s written preliminary determination in accordance with 310 CMR 10.11(2) is attached. This

specifies:

Date of the map:

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Massachusetts Department of Environmental Protection Provided by MassDEP:

If the Rare Species identified is/are likely to continue to be located on or near the project, and if so, whether the Resource Area to be altered is in fact part of the habitat of the Rare

Species.

That if the project alters Resource Area(s) within the habitat of a Rare Species:

The Rare Species is identified;

NHESP’s recommended changes or conditions necessary to ensure that the project will have no short or long term adverse effect on the habitat of the local population of the Rare

Species is provided; or

An approved NHESP habitat management plan is attached with this Notice of Intent.

Send the request for a preliminary determination to: Natural Heritage & Endangered Species Program

MA Division of Fisheries & Wildlife 1 Rabbit Hill Road

Westborough, MA 01581

Division of Marine Fisheries

If the project will occur within a coastal waterbody with a restricted Time of Year, [see Appendix B of the Division of Marine Fisheries (DMF) Technical Report TR 47 “Marine Fisheries

Time of Year Restrictions (TOYs) for Coastal Alteration Projects” dated April 2011 http://www.nae.usace.army.mil/Portals/74/docs/regulatory/StateGeneralPermits/NEGP/MADMFTR

-47.pdf].

Obtain a DMF written determination stating:

The proposed work does NOT require a TOY restriction. The proposed work requires a TOY restriction. Specific recommended TOY restriction and recommended conditions on the proposed work is attached.

If the project may affect a diadromous fish run [re: Division of Marine Fisheries (DMF) Technical Reports TR 15 through 18, dated 2004:

http://www.mass.gov/eea/agencies/dfg/dmf/publications/technical.html]

Obtain a DMF written determination stating: The design specifications and operational plan for the project are compatible with the passage requirements of the fish run. The design specifications and operational plan for the project are not compatible with the passage requirements of the fish run.

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Massachusetts Department of Environmental Protection Provided by MassDEP:

Send the request for a written or electronic determination to: South Shore – Cohasset to Rhode Island border, North Shore – Hull to New Hampshire border: and the Cape & Islands: Division of Marine Fisheries – Division of Marine Fisheries – South Coast Field Station North Shore Field Station Attn: Environmental Reviewer Attn: Environmental Reviewer 836 South Rodney French Blvd. 30 Emerson Avenue New Bedford, MA 02744 Gloucester, MA 01930 Email: [email protected] Email: [email protected]

Division of Fisheries and Wildlife – http://www.mass.gov/eea/agencies/dfg/dfw/ Projects that involve silt-generating, in-water work that will impact a non-tidal perennial river or stream and the in-water work will not occur between May 1 and August 30. Obtain a written determination from the Division of Fisheries and Wildlife (DFW) as to whether the proposed work requires a TOY restriction.

The proposed work does NOT require a TOY restriction. The proposed work requires a TOY restriction. The DFW determination with TOY restriction and other conditions is attached.

MassDEP Water Quality Certification

Project involves dredging of 100 cubic yards or more in a Resource Area or dredging of any amount in an Outstanding Resource Water (ORW). A copy and proof of the MassDEP Water

Quality Certification pursuant to 314 CMR 9.00 is attached to the NOI.

This project is a Combined Permit Application for 401 Dredging and Restoration (BRP WW 26).

MassDEP Wetlands Restriction Order Is any portion of the site subject to a Wetlands Restriction Order under the Inland Wetlands Restriction Act (M.G.L. c. 131, § 40A) or the Coastal Wetlands Restriction Act (M.G.L. c. 130, § 105)?

Yes No

Department of Conservation and Recreation

Office of Dam Safety

For Dam Removal Projects, obtain a written determination from the Department of Conservation and Recreation Office of Dam Safety that the dam is not subject to the jurisdiction of the Office

under 302 CMR 10.00, a written determination that the dam removal does not require a permit under 302 CMR 10.00 or a permit authorizing the dam removal in accordance with 302 CMR

10.00 has been issued.

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Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number WPA Form 3 – Notice of Intent Document Transaction Number Appendix A: Ecological Restoration Limited Nantucket Project Checklists City/Town Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Required Actions (310 CMR 10.11) (cont.)

Areas of Critical Environmental Concern (ACECs)

Is any portion of the proposed project within an Area of Critical Environmental Concern (ACEC)? If yes, provide name of ACEC (see instructions to WPA Form 3 or Yes No MassDEP Website for ACEC locations).

Name of ACEC Minimum Required Documents (310 CMR 10.12) Complete the Required Documents Checklist below and provide supporting materials before submitting a Notice of Intent Application for an Ecological Restoration Project. This Notice of Intent meets all applicable requirements outlined in for Ecological Restoration Projects in 310 CMR 10.12. Use the checklist below to insure that all documentation is included with the NOI.

At a minimum, a Notice of Intent for an Ecological Restoration Project shall include the following:

Description of the project’s ecological restoration goals;

The location of the Ecological Restoration Project;

Description of the construction sequence for completing the project;

A map of the Areas Subject to Protection Under M.G.L. c. 131, § 40, that will be temporarily or permanently altered by the project or include habitat for Rare Species, Habitat of Potential Regional

and Statewide Importance, eel grass beds, or Shellfish Suitability Areas.

The method for BVW and other resource area boundary delineations (MassDEP BVW Field Data Form(s), Determination of Applicability, Order of Resource Area Delineation, etc.) is attached with

documentation methodology.

List the titles and dates for all plans and other materials submitted with this NOI.

a. Plan Title

b. Prepared by c. Signed and Stamped by

d. Final Revision Date e. Scale

f. Additional Plan or Document Title g. Date If there is more than one property owner, attach a list of these property owners not listed on this form.

Attach NOI Wetland Fee Transmittal Form.

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Massachusetts Department of Environmental Protection Provided by MassDEP:

An evaluation of any flood impacts that may affect the built environment, including without limitation, buildings, wells, septic systems, roads or other man-made structures or infrastructure as

well as any proposed flood impact mitigation measures;

A plan for invasive species prevention and control; The Natural Heritage and Endangered Species Program written determination in accordance with 310 CMR 10.11(2), if needed;

Any Time of Year restrictions and/or other conditions recommended by the Division of Marine Fisheries or the Division of Fisheries and Wildlife in accordance with 310 CMR 10.11(3), (4), (5), if

needed;

Proof that notice was published in the Environmental Monitor as required by 310 CMR 10.11(1; A certification by the applicant under the penalties of perjury that the project meets the eligibility criteria set forth in 310 CMR 10.13;

If the Ecological Restoration Project involves the construction, repair, replacement or expansion of infrastructure, an operation and maintenance plan to ensure that the infrastructure will continue to

function as designed;

If the project involves dredging of 100 cubic yards or more or dredging of any amount in an Outstanding Resource Water, a Water Quality Certification issued by the Department pursuant to

314 CMR 9.00;

If the Ecological Restoration Project involves work on a stream crossing, information sufficient to make the showing required by 310 CMR 10.24(10) for work in a coastal resource area and 310

CMR 10.53(8) for work in an inland resource area; and If the Ecological Restoration Project involves work on a stream crossing, baseline photo-points that capture longitudinal views of the crossing inlet, the crossing outlet and the upstream and downstream channel beds during low flow conditions. The latitude and longitude coordinates of the photo-points shall be included in the baseline data.

This project is subject to provisions of the MassDEP Stormwater Management Standards. A copy of the Stormwater Report as required by the Stormwater Management Standards per 310 CMR

10.05(6)(k)-(q) is attached. Provide information as the whether the project has the potential to impact private water supply wells including agricultural or aquacultural wells or surface water withdrawal points.

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1249503

LONG POND PHRAGMITES MANAGEMENT NOTICE OF INTENT SUBMITTAL

Prepared for Karen Beattie Director of Science and Stewardship Department Nantucket Conservation Foundation, Inc. 118 Cliff Road; P.O. Box 13 Nantucket, Massachusetts 02554-0013

Prepared by SWCA Environmental Consultants 15 Research Drive Amherst, Massachusetts 01002 (413)256-0202 www.swca.com

January 13, 2021

Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

CONTENTS

1.0 Introduction ...... 1 2.0 Site Description ...... 2 2.1 Invasive Plant Species Present ...... 2 2.2 Native Vegetation Present ...... 2 2.3 Wildlife Observations ...... 3 3.0 Wetland Resources ...... 3 3.1 Bordering Vegetated Wetland ...... 3 3.2 Bank ...... 4 3.3 Coastal Dune ...... 4 3.4 Land Subject to Coastal Storm Flowage ...... 4 4.0 Other Sensitive Areas : MassGIS Database Review ...... 5 4.1 Natural Heritage and Endangered Species Program ...... 5 4.2 Outstanding Resource Waters and Areas of Critical Environmental Concern ...... 5 5.0 Proposed Work ...... 5 5.1 Management Timing ...... 6 6.0 Performance Standards Review ...... 7 6.1 Bordering Vegetated Wetland (310 CMR 10.55[4]) ...... 7 6.1.1 Vegetated Wetlands (Nantucket Wetland Regulations 3.02) ...... 8 6.2 BANK (310 CMR 10.54[4]) ...... 8 6.2.1 Inland Banks and Beaches (Nantucket Wetland Regulations 3.01) ...... 9 6.2.2 Inland Water Bodies (Nantucket Wetland Regulations 3.03) ...... 9 6.3 Coastal Dunes (Nantucket Wetland Regulations 2.03) ...... 9 6.4 Land Subject to Coastal Storm Flowage (Nantucket Wetland Regulations 2.10) ...... 10 6.5 Estimated Habitat for Rare/Significant Wildlife and Rare/Significant Flora and Fauna (Nantucket Wetland Regulations 3.05) ...... 10 7.0 Team Qualifications ...... 10 8.0 Summary ...... 11

Appendices

Appendix A. Abutter Notificaiton, Certified Abutters List, and Copy of Fee Submittal Checks Appendix B. Web Soil Survey Appendix C. Long Pond Assessment Report, SWCA 2020 Appendix D. Clearcast Information Appendix E. Photo Pages Appendix F. Figures

Tables

Table 1. Example Native Seed Mix ...... 6

i Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

ii Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

1.0 INTRODUCTION

SWCA Environmental Consultants (SWCA) has prepared this Notice of Intent (NOI) on behalf of Nantucket Conservation Foundation, Inc. (the Conservation Foundation) for a Phragmites Management Plan along the southeastern Bank and buffer zone to Long Pond. This portion of Long Pond (the project area) area is located south of Cambridge Street (Massasoit Bridge) on the southwestern side of Nantucket, Massachusetts. This section of the pond is managed by the Conservation Foundation, while other phragmites management activities are currently taking place on other portions of the Bank by other parties. The proposed project seeks to control a population of Phragmites australis (phragmites) within the Bank, adjacent Bordering Vegetated Wetland (BVW), and a small portion of Coastal Dune along the southeasternmost end of Long Pond. The ultimate goal of this project is to eliminate invasive phragmites from the site. This NOI is being submitted to implement this invasive plant management program for 5 years (2021-2025). Therefore, we are requesting that a 5-year Order of Conditions be issued for the proposed project work.

Implementation of this plan will serve to protect the health of the ecosystem by reducing the spread and cover of invasive phragmites and encourage the return of native wetland plant species within the resource areas in and around the pond. Figure 1 illustrates the location of the site on a USGS topographic base map and Figure 2 illustrates the extent of the phragmites population (in a green hatched polygon) on an orthophotograph. The project work area includes the phragmites population south of Massasoit Bridge. This work will complement and expand similar permitted phragmites management currently being undertaken by the Nantucket Pond Coalition, Long Pond Homeowners Association, and the Nantucket Islands Land Bank in the southwestern and northern portions of Long Pond.

The proposed work includes manual cutting and removal and chemical management of phragmites followed by the dissemination of native wetland plant seed, as needed. Full details on the specific proposed Phragmites Management Plan are outlined in the Proposed Work section of this NOI submission (Section 5.0). Portions of the proposed project will take place within the BVW, Bank, and Coastal Dune but will not impact Land Under Water. The project work area is also within Land Subject to Coastal Storm Flowage (LSCSF), which does not have specific performance standards within 310 CMR but is jurisdictional under the Nantucket Conservation Commission Wetland Protection Regulations. No permanent impact will take place within any resource areas within or around the project work zone. More information about each resource area is included in Sections 3 and 6 of this document.

SWCA has prepared this application and supporting documentation in accordance with 310 CMR 10.00 of the Massachusetts Wetlands Protection Act (MGL c. 131, s.40) and The Town of Nantucket Conservation Commission’s Wetland Protection Regulations, dated July 1, 2013. While most aspects of the proposed project meet the Performance Standards (Section 6.0 of this NOI) set by both regulations, the temporary disturbance of Bank is above the performance standards for that resource area. Therefore, SWCA is submitting this NOI as an Ecological Restoration Limited Project. See Form 3 Appendix A for all details regarding the adherence to the Ecological Restoration Limited Project filing requirements.

In accordance with the Wetland Protection Act (WPA) and the Nantucket Conservation Commission Wetland Protection Regulations, one original and one paper copy of the application package (including all figures) are being submitted to the Conservation Commission a minimum of 20 days prior to the regularly scheduled public hearing date. SWCA will also submit an electronic copy of this NOI to the Nantucket Conservation Commission and the Massachusetts Department of Environmental Protection (MassDEP) using the eDEP online filing site. This filing is also being concurrently submitted to MassWildlife Natural Heritage and Endangered Species Program (NHESP) for review.

1 Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

The local filing fee and review fee in Nantucket, as mandated under their Wetland Protection Regulations, for the submission of this NOI are $25 and $200, respectively. The filing fee for this project under the WPA was calculated as a Category 2(h) for removal of nuisance vegetation, totaling $500. As required, the appropriate Town fee of $262.50 is included with this filing, and the State fee of $237.50 has been sent to the Commonwealth of Massachusetts via the online eDEP filing system. SWCA has notified abutters located within 100 feet of the project work area. A list of abutters, map of a certified abutting properties list, and a copy of the notification letter are included in Appendix A and a figure of the phragmites management area overlayed with each project work area parcel is included in Figure 6. Copies of the local filing fee checks are also included in Appendix A.

2.0 SITE DESCRIPTION

Long Pond is comprised of a large series of connected ponds within a glacial outwash valley that extends from the southwestern portion of Nantucket almost all the way to the northwest side of the island. The section of the pond within the project work area includes the southeast Bank section of Long Pond south of Cambridge Street (Massasoit Bridge). See Figure 2 for the location of phragmites within the project area, which extends across just under 3,150 linear feet of the Bank. This length includes almost the entirety of this portion of the pond’s Bank.

The pond is surrounded by BVW on its eastern Bank and the Bank of the pond is well defined. The Bank abuts the edge of the phragmites population almost along the entirety of the population. The BVW and Bank within the project area are shown on Figure 3. The entire phragmites population is within and above Bank, with none of the population within land under water.

The Natural Resources Conservation Service Web Soil survey map shows that the BVW and Bank area where this project is set to occur is made up entirely of Riverhead sandy loam with 3 to 8 percent slopes. The locations and descriptions of these soil classification areas are presented in Appendix B.

In review of the wetland resources, SWCA also reviewed the most recent 100-year flood maps and found that the entire project area is within the 100-year flood zone (see Figure 5). In this region, the 100-year flood zone defines the line of LSCSF. There are certain qualities of LSCSF that have preliminarily been defined as vital for coastal communities; primarily, compensatory flood storage capacity and habitat quality. No aspect of the phragmites management will affect these functions and values of LSCSF.

2.1 Invasive Plant Species Present

SWCA conducted a survey of phragmites on the southeasternmost Bank of Long Pond utilizing a drone with an attached high-quality camera on August 11, 2020. The drone imagery was used to develop an orthomosaic to delineate the outer bounds of all phragmites on the Bank. These data were collected with a Phantom 4 drone, which collected photographs with a 0.5-inch resolution at the ground surface. These photographs were stitched together as an orthomosaic and used to delineate the precise boundary of the phragmites population. The total population surrounds almost the entirety of the Bank within the project area. The report from this survey is included in Appendix C.

The population of phragmites within the project area is depicted in Figure 2. The area identified in green as “Phragmites (Common Reed)” includes the dense monoculture of phragmites along the Bank and buffer. The area identified with a yellow line fill as “Sparse Phragmites” is the portion of the phragmites population that exists at approximately 3% cover and is mixed in with the native shrubs and American beach grass adjacent to the monoculture of phragmites. The total square footage of phragmites within the project area is approximately 1.5 acres (63,655 square feet). This calculation is based on the absolute

2 Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts percent cover within each sub-area of the population: 100% cover within the monoculture and 3% cover throughout the sparse area.

2.2 Native Vegetation Present

Because the goal of this project is to chemically manage phragmites along this section of Long Pond, SWCA also conducted a survey to determine if any emergent plant populations were present just in-water of the phragmites population that might be affected by management activities. SWCA did note one submerged aquatic plant along portions of Long Pond just in-water of the Bank. This plant has been preliminarily identified as beaked ditch-grass/widgeongrass (Ruppia maritima). This is documented as a preliminary identification because further inspection of the plant when reproductive parts are present is needed to confirm the species identification. Beaked ditch-grass is a native plant that is an important food source for waterfowl, wading birds, and shorebirds.

There were no other emergent plant populations identified within the project area. However, there is a robust population of coastal shrubland vegetation just east of the phragmites population, which makes it very difficult to traverse the buffer around the pond and prevents phragmites from continuing to spread east. The management of phragmites will need to be performed from the water side of the phragmites population as well as the landward side for it to be effective. To do this, small access lanes will be created to manage the full extent of the phragmites. These lanes will be manually cut with hand tools and will include minimal pruning to allow foot access. This pruning will not disturb any root mass to allow the native vegetation to grow back quickly and without any damage to the plant. See Section 5 for a full description of the scope of work associated with the Phragmites Management Plan

2.3 Wildlife Observations

SWCA did not observe any amphibians or fish within Long Pond during the 2020 survey but did note a few bird species: Robins (Turdus migratorius), Northern cardinals (Cardinalis cardinalis), and Red- winged blackbirds (Agelaius phoeniceus). Removal of phragmites, as proposed in this management plan, will increase native biodiversity, and increase the habitat for native wildlife species, such as nesting birds. Phragmites is not suitable habitat for these nesting birds, as the stalks are not sturdy enough to support the weight of their nests like cattail (Typha sp.) and native shrub species would.

3.0 WETLAND RESOURCES

The Long Pond management area exists within BVW and Bank. The BVW, Bank, and Coastal Dune within the project area are shown on Figure 3. As all the phragmites is within and above Bank, there is no need to delineate land under water in association with the phragmites management. The project area is also within LSCSF. The Nantucket Conservation Commission Wetland Protection Regulations does include both characteristics and protection interests as well as performance standards for LSCSF; therefore, those regulations set forth are included below.

3.1 Bordering Vegetated Wetland

As defined in 310 CMR 10.55(a-c), BVW area “area(s) where the soils are saturated and/or inundated such that they support a predominance of wetland indicator plants, 50% or more of the vegetative community consists of wetland indicator species, and the ground surface water regime and the vegetative community which occurs in each type of freshwater wetland area specified in M.G.L c 131 40.”

3 Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

BVW areas identified on the southeast end of Long Pond are depicted on Figure 3 with a light blue vegetated wetland fill. There is a 100-foot buffer zone to BVW with performance standards within the Nantucket Conservation Commission Wetland Regulations. The performance standards are detailed in Section 6.

The BVW on the southeast end of Long Pond is predominantly phragmites with a robust population of coastal shrubland vegetation just east of the phragmites population. The coastal shrubland predominantly contains northern bayberry (Myrica pensylvanica) and sweet pepperbush (Clethra alnifolia).

3.2 Bank

As defined in 310 CMR 10.54 (2)(a), a Bank is "the portion of the land surface which normally abuts and confines a water body. It occurs between a water body and a vegetated bordering wetland and adjacent flood plain, or, in the absence of these, it occurs between a water body and an upland. A Bank may be partially or totally vegetated, or it may be comprised of exposed soil, gravel or stone.”

The Nantucket Conservation Commission Wetland Regulations also protect land within 100 feet of Inland Banks and Beaches as well as inland waterbodies. These areas are completely within BVW and its 100- foot buffer zone. The performance standards for these jurisdictional areas are included in Section 6.

The southeast Bank of Long Pond is depicted on Figure 3 with an orange line. The phragmites population extends to the Bank in some areas.

3.3 Coastal Dune

As defined in 310 CMR Section 10.28(2), Coastal Dunes are “any natural hill, mound, or ridge of sediment landward of a coastal beach deposited by wind action or storm overwash… [or] sediment deposited by artificial means and serving the purpose of storm damage prevention or flood control.”

There are no performance standards listed for Coastal Dunes in the WPA; however, our proposed phragmites management plan is within the guidelines for acceptable projects. There will be no creation of any structures and as-needed restoration will occur to enhance habitat value of the Coastal Dune.

Section 2.03 (a)(1) of the Nantucket Conservation Commission Wetland Protection Regulations further describes the values of Coastal Dunes as a “sediment source for beach and intertidal areas; serve to provide wildlife habitat to rare, endangered, and otherwise significant wildlife; and serve to provide important wetland scenic views and recreation.”

Existing vegetation within the Coastal Dune within and around the project work area includes American beach grass (Ammophila breviligulata) and phragmites. The American beach grass is very well developed in the areas where it extends (see Photos E-7 and E-8 in Appendix E).

Coastal Dunes do have performance standards under Section 2.03(B) of these regulations, which are further elaborated on in Section 6.3.

3.4 Land Subject to Coastal Storm Flowage

As defined in 310 CMR Section 10.04, “Land Subject to Coastal Storm Flowage means land subject to any inundation caused by coastal storms up to and including that caused by the 100-year storm, surge of record or storm of record, whichever is greater.”

4 Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

Section 2.10 (a)(2) of the Nantucket Conservation Commission Wetland Protection Regulations further describes LSCSF as “significant to the protection of the following interests: flood control, erosion control, and storm damage prevention, water quality, erosion and sediment control, wildlife habitat.”

4.0 OTHER SENSITIVE AREAS : MASSGIS DATABASE REVIEW SWCA reviewed the Massachusetts Geographic Information System (MassGIS) to determine if this site was within or near other sensitive environmental areas. These areas protect rare species, important watersheds, and other special environmental characteristics.

4.1 Natural Heritage and Endangered Species Program

SWCA reviewed the MassGIS database to determine if the site was located within or adjacent to areas designated as Priority Habitats of Rare Species, Estimated Habitats of Rare Wildlife, Certified Vernal Pools, or Potential Vernal Pools by the MassWildlife NHESP. The project area is within the outer limits of both Priority Habitats of Rare Species and Estimated Habitats of Rare Wildlife. There are no potential or certified vernal pools within or adjacent to the project area (Figure 4).

Due to the proximity of rare species and rare wildlife habitat, this NOI will be submitted to NHESP for review. The Nantucket Conservation Commission will not be able to vote on acceptance of the project prior to receiving a letter of no adverse impact.

4.2 Outstanding Resource Waters and Areas of Critical Environmental Concern

SWCA also reviewed the MassGIS database to determine if the site was located within Outstanding Resource Waters (ORW). ORWs are watershed areas that have been classified as such under the Massachusetts Surface Water Quality Standards. These watersheds constitute an outstanding resource as determined by their important socioeconomic, recreational, ecological and/or aesthetic values. Such areas have been identified so that they may be protected and maintained. There are no ORWs located within or adjacent to the proposed project work area.

An Area of Critical Environmental Concern (ACEC) is also an area designated in Massachusetts that receives special recognition because of the quality, uniqueness, and significance of its natural and cultural resources. There are no ACECs mapped on or near the project site or within the proposed project work area.

5.0 PROPOSED WORK

The purpose of the proposed work is to control and ultimately remove phragmites present along the 3,150 linear feet of the southeastern Bank of Long Pond. The project work area is restricted to the southeastern Bank of Long Pond south of Massasoit Bridge. Due to the extent and density of the phragmites population, the best means of management will be foliar application of the herbicide Clearcast (ammonium salt of imazamox). This will likely need to be performed both from the land and from a boat on the pond. Although glyphosate is often used for the management of phragmites, as was used on the Bank opposite from the management area described in this report, Clearcast is similarly effective and is

5 Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts more selective than glyphosate. Therefore, it reduces the potential risk of non-target impacts. See Appendix D for more details on Clearcast.

Phragmites is a very aggressive and invasive colonizer. SWCA proposes pre-management cutting and removal of phragmites in the early spring or late fall prior to management. This will minimize the height of the population prior to herbicide application and increase full-population herbicide contact by removing standing dead stems. A second follow-up cutting event should occur before the second year of treatment. This cutting and removal schedule will serve two purposes: (1) Hand-cut, contain on tarps, and remove the previous growing season’s dead material and reduce density and height for the subsequent management events to the extent practicable, and (2) remove phragmites following herbicide application to open the area for native vegetation establishment. Initial phragmites management will focus on the dense monoculture of phragmites. Follow-up herbicide application will include spot foliar application where appropriate and will include clip and drip application in areas where it is mixed in with native vegetation. See photos E-4 and E-5 in Appendix E for an example of the current distribution of phragmites from these existing monocultures through the bordering native vegetation.

There is also a section of the phragmites population that is not surrounded by a defined buffer and lies within a Coastal Dune and sandy beach area at the southernmost section of the phragmites management area (Photos E-7 and E-8). While it is possible that the existing robust American beach grass will in-fill the areas of phragmites once managed, SWCA proposes restoration of these sandy areas with American beach grass if necessary. These will be installed as bare root plant material at a spacing of approximately 1 foot on center and will only be installed once the phragmites population has received two herbicide applications and is well-managed in this section.

To successfully perform manual cutting and removal of the phragmites, access lanes will need to be established through the BVW and buffer zone to the east of the phragmites population. These lanes will be minimally disturbed; just enough to access by foot and transport bags of collected phragmites cuttings and will include trimming of above-ground vegetation with hand tools only. No vegetation will be destroyed or permanently damaged during the process of access lane creation.

The act of cutting and removing phragmites will expose bare soil. It is crucial to reduce the risk of recolonization of phragmites or other invasive plants to any bare soil around the pond. SWCA proposes revegetation with seed only, as the robust populations of native shrub species will expand and recolonize the managed areas naturally. The seed mix chosen will be a native wetland seed mix sourced through Cape Coastal Nursery, which is based in South Dennis, Massachusetts. Cape Coastal Nursery is very familiar with sourcing local seed (including local genotypes, when possible) and is the best source for Cape and Islands plant material in the area. The precise composition of a native seed mix cannot be determined until the time of ordering, as availability of species will vary based on a given year’s yield and remaining stock after other nursery sales. See Table 1 for an example of a seed mix that could be used. Table 1. Example Native Seed Mix

% Mix by Weight Latin Name Common Name 10% Asclepia incarnata Swamp Milkweed 60% Juncus effusus Soft rush 3% Eutrochium dubium Coastal Joe Pye Weed 5% Eupatorium perfoliatum Boneset 2% Hibiscus moscheutos Swamp Rosemallow 15% Iris versicolor Blue Flag Iris 5% Solidago sempervirens or odora Seaside or Sweet Goldenrod

6 Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

5.1 Management Timing

The first year of management will include cutting and removal of phragmites, as described above, and two foliar applications of the herbicide Clearcast. The first application should occur in August or September, and the second should occur at least 2 weeks following the initial treatment, but not after the first week in October. Conducting two herbicide treatments within the first year will significantly reduce the amount of live phragmites plant material surrounding the pond.

The best management approach for the second year of management should be determined after a follow- up phragmites survey. It is likely that the second year will require two additional treatments of Clearcast and additional cutting and removal of phragmites. However, it is crucial to practice adaptive management in invasive plant management projects such as this. Once the phragmites on site are substantially reduced, SWCA recommends seeding with a native wetland seed mix at a high rate of dissemination. It is important to populate all exposed ground with native seed as soon as possible each spring to encourage native growth and to discourage phragmites regrowth. Seeding is a good, low-cost means of revegetation that is less risky to perform prior to the complete eradication of invasive plants. Overall, conditions on- site will likely change throughout the management program. Therefore, the exact timing of restoration seeding will depend on conditions each year following the initial treatments.

6.0 PERFORMANCE STANDARDS REVIEW

The following sections detail the performance standards associated with the jurisdictional resource area in which the proposed work would occur. SWCA’s responses to the performance standards are in response to both performance standards of 310 CMR and the Nantucket Conservation Commission Wetland Regulations. Each aspect of the proposed project complies with the regulations and success standards as follows.

6.1 Bordering Vegetated Wetland (310 CMR 10.55[4]) (a) Where the presumption set forth in 310 CMR 10.55(3) is not overcome, any proposed work in a Bordering Vegetated Wetland shall not destroy or otherwise impair any portion of said area. The only destruction proposed within BVW is that of invasive vegetation. Any exposed soil following phragmites treatment will promptly be revegetated using with native seed mix and infill from the existing native vegetation surrounding the phragmites population. Reduction of phragmites is viewed as an improvement in habitat value and impacts to the Bank should be minimal. (b) & (c) Notwithstanding the provisions of 310 CMR 10.55(4)(a), the issuing authority may issue an Order of Conditions permitting work which results in the loss of … Bordering Vegetated Wetland … While invasive vegetation will be destroyed (alteration to BVW), no BVW will be lost during the proposed project. Native vegetation will be restored throughout the existing footprint of the phragmites population. (d) Notwithstanding the provisions of 310 CMR 10.55(4)(a), (b) and (c), no project may be permitted which will have any adverse effect on specified habitat sites of rare vertebrate or invertebrate species, as identified by procedures established under 310 CMR 10.59.

7 Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

NHESP will evaluate this NOI for adherence to this performance standard. However, the proposed phragmites management program will ultimately enhance habitat value within BVW by removing an aggressive invasive plant and allowing native vegetation to revegetate this area. (e) Any proposed work shall not destroy or otherwise impair any portion of a Bordering Vegetated Wetland that is within an Area of Critical Environmental Concern designated by the Secretary of Energy and Environmental Affairs under M.G.L. c. 21A, § 2(7) and 301 CMR 12.00: Areas of Critical Environmental Concern. 310 CMR 10.55(4)(e) There are no ACEC’s within the project work area.

6.1.1 Vegetated Wetlands (Nantucket Wetland Regulations 3.02)

B. PERFORMANCE STANDARDS Vegetated wetlands or Land within 100 feet of Vegetated Wetlands shall be presumed significant to the Interests Protected by the Bylaw as referenced in Section A, therefore, the following regulations shall apply: 1) Proposed projects which are not water dependent shall maintain at least a 25-foot natural undisturbed area adjacent to vegetated wetlands. All structures which are not water dependent shall be at least 50 feet from a vegetated wetland, and all structures shall maintain an undisturbed two-foot separation to high groundwater. Fifty percent (50%) of the area between the 25-foot buffer and the 50-foot buffer shall not be altered. Additional soils and groundwater information may be required for applications in areas of high groundwater.

While work is proposed to occur within BVW and small temporary access paths will be created within its buffer, these impacts will be temporary. No structures will be created to impair the growth of vegetation and seeding will occur wherever soil is exposed. The entire project area is intended to remain as natural, undisturbed vegetated area.

Performance standards 3.02 (2)࣓(7) do not apply to this project.

6.2 BANK (310 CMR 10.54[4]) (a) Where the presumption set forth in 310 CMR 10.54(3) is not overcome, any proposed work on a Bank shall not impair the following: 1. the physical stability of the Bank, 2.the water carrying capacity of the existing channel within the Bank, 3. ground water and surface water quality 4. the capacity of the Bank to provide breeding habitat, escape cover and food for fisheries, 5. the capacity of the Bank to provide important wildlife habitat functions. A project… that (cumulatively) alter(s) up to 10% or 50 feet (whichever is less) of the length of the Bank found to be significant to the protection of wildlife habitat, shall not be deemed to impair its capacity to provide important wildlife habitat functions. Reduction/elimination of phragmites is viewed as an improvement in habitat value. Since the proposed alteration is grater than 10% and 50 feet of Bank, and the project meets the qualifications of 10.24(8), SWCA is submitting this as a Ecological Restoration Limited Project. See Form 3 Appendix A for more details. 6. Work on a stream crossing shall be presumed to meet the performance standard set forth in 310 CMR 10.54(4) (a)(b)(c)

8 Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

The proposed work does not include any stream crossings.

6.2.1 Inland Banks and Beaches (Nantucket Wetland Regulations 3.01)

B. PERFORMANCE STANDARDS Inland Banks and Beaches or Land within 100 feet of an Inland Bank and Beach shall be presumed significant to the Interests Protected by the Bylaw as referenced in Section A, therefore the following regulations shall apply: 1) Projects shall be permitted only where no adverse effect exists on Bank stability, groundwater and surface water quality, the water carrying capacity of an existing channel within a Bank, Bank height, and the capacity of the Bank to provide habitat for fisheries and/or wildlife.

There will be no disturbance to soil and all phragmites cutting will occur above the root mass. Therefore, the act of phragmites removal will not disturb the stability of the Bank. Furthermore, any exposed soil following phragmites treatment and removal will be revegetated using native seed mix and through natural infill of native vegetation. Reduction of phragmites is viewed as an improvement in habitat value and impacts to the Bank should be minimal.

Performance standards 3.01 (2)࣓(7) do not apply to this project. 6.2.2 Inland Water Bodies (Nantucket Wetland Regulations 3.03)

B. PERFORMANCE STANDARDS Inland Water Bodies or Land within 100 feet of an Inland Water Bodies shall be presumed significant to the Interests Protected by the Bylaw as referenced in Section A, therefore the following regulations shall apply: 1) No proposed project shall use procedures that the Commission determines have an adverse effect on significant wildlife habitat, wildlife, fisheries, existing water quality, recreation, wetland scenic views, or alter the critical characteristics of an inland water body.

Reduction of phragmites is an improvement in habitat value and will not impact fisheries, as all work under these regulations pertains to the 100-foot buffer zone. 2) Proposed projects which are not water dependent shall maintain at least 25-foot natural undisturbed area adjacent to land under water body. All structures which are not water dependent shall be at least 50 feet from land under a water body, and all structures shall maintain an undisturbed two-foot separation to high groundwater. Fifty percent (50%) of the area between the 25-foot buffer and the 50-foot buffer shall not be altered. Additional soils and groundwater information may be required for applications in areas of high groundwater.

While work is proposed to occur within BVW and small temporary access paths will be created within its buffer, all these impacts will be temporary. No structures will be created to impair the growth of vegetation and seeding will occur wherever soil is exposed. The entire project area is intended to remain as natural, undisturbed vegetated area.

Performance standards 3.03 (3)࣓(6) do not apply to this project.

9 Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

6.3 Coastal Dunes (Nantucket Wetland Regulations 2.03)

B. PERFORMANCE STANDARDS: A Coastal dune, coastal dune field, or land within 100 Feet of a coastal dune or coastal dune field, shall be presumed significant to the Interests Protected by the Bylaw as referenced in Section A, therefore the following regulations shall apply: 3) No excavation or disturbance of vegetative cover shall be allowed on a coastal dune unless the area is completely restored, replanted, and stabilized to its original form and volume.

While there will not be any disturbance of native vegetation within Coastal Dunes within the project limits, the removal of phragmites may create bare areas of Coastal Dune. Therefore, native revegetation of American beach grass will be installed should natural regeneration from robust nearby populations not in-fill the areas of phragmites management. Performance standards 2.03 (1)࣓(2) DQG ࣓ do not apply to this project.

6.4 Land Subject to Coastal Storm Flowage (Nantucket Wetland Regulations 2.10)

B. PERFORMANCE STANDARDS Estimated habitat areas shall be presumed significant to the Interests Protected by the Bylaws as referenced in Section A, therefore the following regulations apply:

1) The work shall not reduce the ability of the land to absorb and contain flood waters, or to buffer inland areas from flooding and wave damage.

The proposed project will not alter the ability of the land to absorb or contain flood waters or buffer in any way. Revegetation is an important aspect of the proposed project. Performance standards 2.10 (2)࣓(5) do not apply to this project.

6.5 Estimated Habitat for Rare/Significant Wildlife and Rare/Significant Flora and Fauna (Nantucket Wetland Regulations 3.05)

B. PERFORMANCE STANDARDS Estimated habitat areas shall be presumed significant to the Interests Protected by the Bylaws as referenced in Section A, therefore the following regulations apply: 1) No activity shall be permitted that alters existing vegetation within 50 feet of verified rare/significant species habitat, including certified vernal pools, and vernal pools defined in Section 1.02.

The proposed project does include destruction of invasive vegetation within and adjacent to Priority Habitats of Rare Species as well as Estimated Habitats of Rare Wildlife. However, the proposed project intends to improve the value of habitat and NHESP will evaluate this NOI and provide comments on the proposed work. Performance standards 3.05 (2)࣓(6) do not apply to this project.

10 Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

7.0 TEAM QUALIFICATIONS

SWCA has provided invasive species management services for over two decades. We actively manage invasive plant species, including phragmites, at project sites throughout the northeast. We have completed invasive species projects at New York State Parks, land owned by the Massachusetts Division of Fish and Wildlife, and property overseen by the Massachusetts Department of Conservation and Recreation. In addition, we have worked on National Park Service property, State Departments of Transportation properties, and private properties. Much of these projects include sensitive resource areas and require selective invasive plant management. SWCA’s invasive plant management team is highly skilled in improving and managing sensitive resource areas (e.g., wetland mitigation, streambank restoration, remediations) and adhering to state and federal success standards. In addition to these services, SWCA has offered a complete suite of environmental consulting services associated with the protection, assessment, and improvement of biologically diverse and ecologically significant natural resources in New England for over 35 years.

SWCA has recently assisted in the assessment of Capaum Pond and assessment, permitting and management of Pest House Pond on behalf of NCF. SWCA has also assisted the Nantucket Islands Land Bank Commission with permitting of aquatic invasive plant management within Burchell’s Pond.

Our staff consists of professionals experienced in invasive species control, botany, rare species habitat assessment and identification, natural resource area delineation, GIS/GPS mapping, and ecological restoration. The strength of our project approach is defined by our project team and their relevant experience. The project team incorporates wetland scientists and invasive plant species control specialists. We are confident that our relevant project experience will allow us to perform the proposed project work without any deleterious environmental effects, to neither native wildlife nor vegetation.

8.0 SUMMARY

SWCA is submitting this NOI as an Ecological Restoration Limited Project to implement a phragmites management program along the southeast Bank of Long Pond. The proposed project seeks to control phragmites within Bank, BVW, and LSCSF, as well as small portions of buffer zones associated with these resource areas along the southeasternmost end of Long Pond. The goal of the proposed project is to eliminate invasive phragmites from the site. This will be done through the application of herbicide and manual removal of phragmites, followed by re-seeding of affected Bank and BVW with native wetland species. Once implemented, the proposed management plan will increase native biodiversity and increase the habitat for native wildlife species, such as nesting birds.

We are requesting a waiver of the local Wetland Regulations to manage aggressive invasive plants and restore the project work area with native vegetation.

All work performed within sensitive resource areas discussed in this NOI submission will be performed with the utmost care and selectivity. Erosion controls will not be necessary, as soil disturbance will not occur. Pesticides proposed for use are certified for aquatic use and will be applied with caution to non- target species. We are seeking an Order of Conditions for 5 years, to implement a 5-year Phragmites Management Plan that focuses on annual monitoring and adaptive management.

The proposed scope of work will only occur as necessary over the requested 5 years and will include only the pesticides and methodologies listed in this NOI submission.

11 Long Pond Phragmites Management Notice of Intent Submittal Nantucket, Massachusetts

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iii

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Appendix C.

Long Pond Assessment Report, SWCA 2020

TECHNICAL MEMORANDUM

To: Karen Beattie Director of Science & Stewardship Nantucket Conservation Foundation 118 Cliff Road Nantucket, MA 02554

From: Naomi Valentine, Ecological Restoration Team Lead Date: November 2, 2020

Re: Long Pond Summary Report / SWCA Job No. 59518.00

Dear Ms. Beattie:

SWCA Environmental Consultants (SWCA) is pleased to present a summary of the assessment conducted by SWCA on August 11, 2020, of the southeasternmost section of Long Pond, located south of Cambridge Street on the southwestern side of Nantucket, Massachusetts. While SWCA will be providing a full notice of intent (NOI) filing package, this summary report presents an overview of the results of our survey and the wetland resource areas that will need to be addressed in the NOI filing.

During this survey, SWCA flew a drone to collect data for the development of an orthomosaic and delineation of phragmites (Phragmites australis), determined if there were emergent or submerged aquatic vegetation along the edge of the phragmites, and verified the wetland line off of Massachusetts Department of Environmental Protection wetland layers.

The purpose of this survey is to provide sufficient information to develop a phragmites management plan (presented in this report) and submit an NOI on behalf of the Nantucket Conservation Foundation (NCF). SWCA will commence development of the NOI for phragmites management at Long Pond as soon as the contents and approach within this report are approved by NCF.

If you have any questions or comments, please do not hesitate in contacting me by phone at 413.658.2012 or by email at [email protected].

Sincerely,

Naomi Valentine Ecological Restoration Team Lead

Long Pond Summary Report

1.0 OVERVIEW

Long Pond, located south of Cambridge Street on the southwestern side of Nantucket, Massachusetts, includes a large series of connected ponds within a glacial outwash valley that extend from the southwestern portion of Nantucket almost all the way to the northwest side of the island. The southeast bank of the section of Long Pond south of Cambridge Street, and any associated fieldwork, is discussed in this report; this is also the extent of the survey. See Figure A-2 (Attachment A) for the location of phragmites (Phragmites australis). The project area extends just under 3,150 linear feet, of which the vast majority is covered in phragmites.

SWCA Environmental Consultants (SWCA) conducted the survey on August 11, 2020, in order to collect the necessary information for development of a phragmites management plan and notice of intent (NOI) submission. Therefore, the most crucial pieces of information gathered during this survey were the location, cover, and extent of phragmites existing in the project area; verification of wetland resource area boundaries; and observations of any species that could potentially be affected by phragmites management. Survey results are included in the sections below and have been used to inform the phragmites management plan (Section 5).

All data collected during SWCA’s survey of Long Pond were geolocated with a submeter global positioning system (GPS) unit and have subsequently been projected on the figures in Attachment A.

2.0 PHRAGMITES SURVEY

SWCA conducted a survey of phragmites on the southeasternmost bank of Long Pond utilizing a drone with an attached high-quality camera. The drone imagery was used to develop an orthomosaic in order to delineate the outer bounds of all phragmites on the bank. These data were collected with a Phantom 4 drone, which collected photographs with a 0.5-inch resolution at the ground surface. The Phantom 4 drone’s internal GPS system is accurate enough to forgo using ground control points to locate the imagery in space. Therefore, this imagery was stitched together as an orthomosaic and used to delineate the precise boundary of the phragmites population, which is depicted in Figure A-2 (see Attachment A). The total area with phragmites presence on the southeast bank of Long Pond is approximately 3.3 acres (143,153.8 square feet). However, the area identified on Figure A-2 in green as “Phragmites (Common Reed)” includes the dense monoculture of phragmites along the Bank and buffer and the area identified with a yellow line fill as “Sparse Phragmites” is the portion of the phragmites population that exists at approximately 3% cover and is mixed in with the native shrubs adjacent to the monoculture of phragmites. Therefore, the actual square footage of phragmites cover within the project area is approximately 1.5 acres (63,655 square feet). This calculation is based on the absolute percent cover within each sub-area of the population: 100% cover within the monoculture and 3% cover throughout the sparse area.

Because the goal of this project is to chemically manage phragmites along this section of Long Pond, SWCA also conducted a survey to determine if any emergent plant populations were present just in-water of the phragmites population that might be affected by management activities. SWCA did note one submerged aquatic plant along portions of Long Pond just in-water of the bank. This plant has been preliminarily identified as beaked ditch-grass/widgeongrass (Ruppia maritima). This is documented as a preliminary identification because we would need to inspect the plant when reproductive parts are present to be sure of the species identification. Beaked ditch-grass is a native plant that is an important food source for waterfowl, wading birds, and shorebirds.

There were no other emergent plant populations identified within the project area. However, there is a robust population of scrub-shrub vegetation just east of the phragmites population, which makes it very

1 Long Pond Summary Report difficult to traverse the buffer around the pond and prevents phragmites from continuing to spread east. The management of phragmites will need to be performed from the water side of the phragmites population, and all care must be taken to minimize overspray to the scrub-shrub population to the east.

3.0 WETLAND RESOURCE AREAS

SWCA loaded the Massachusetts Department of Environmental Protection (MassDEP) wetland layer onto Collector for ArcGIS to field verify and/or adjust the area of bordering vegetated wetland (BVW) around Long Pond during the 2020 survey. The MassDEP layer was found to be fairly accurate and needed only slight adjustments. The bank at the pond is well defined and abuts the edge of the phragmites population almost along the entirety of the population. The BVW and bank within the project area are shown on Figure A-3 (see Attachment A). As all of the phragmites is within and above bank, there is no need to delineate land under water in association with the phragmites management.

In review of the wetland resources, SWCA also reviewed the most recent 100-year flood maps and found that the entire project area is within the 100-year flood zone. In this region, the 100-year flood zone defines the line of Bordering Land Subject to Flooding (BLSF) for inland resources and also defines the area of Land Subject to Coastal Storm Flowage (LSCSF). There are certain qualities of LSCSF that are vital for coastal communities—primarily, compensatory flood storage capacity. No aspect of the phragmites management will affect the functions and values of LSCSF.

SWCA will include the definitions, performance standards, and responses to each performance standard for each of the abovementioned wetland resource areas in the final NOI for phragmites management.

4.0 OTHER SENSITIVE AREAS

SWCA reviewed the Massachusetts Geographic Information System (MassGIS) database to determine if this site was within or near other sensitive environmental areas. These areas protect rare species, important watersheds, and other special environmental characteristics.

4.1 Natural Heritage and Endangered Species Program

SWCA reviewed the MassGIS database to determine if the site was located within or adjacent to areas designated as Priority Habitats of Rare Species, Estimated Habitats of Rare Wildlife, Certified Vernal Pools, or Potential Vernal Pools by the MassWildlife Natural Heritage & Endangered Species Program (NHESP). The project area is within the outer limits of both Priority Habitats of Rare Species and Estimated Habitats of Rare Wildlife. There are no potential or certified vernal pools within or adjacent to the project area (Figure A-4 in Attachment A).

Due to the proximity of rare species and rare wildlife habitat, the NOI developed for the management of phragmites at Long Pond will need to be submitted to the NHESP for review. The Nantucket Conservation Foundation (NCF) will be required to pay a review fee for this filing through the NHESP and the Nantucket Conservation Commission will not be able to vote on acceptance of the project prior to receiving a letter of no adverse impact.

2 Long Pond Summary Report

4.2 Outstanding Resource Waters and Area of Critical Concern

SWCA also reviewed the MassGIS database to determine if the site was located within Outstanding Resource Waters (ORW). ORWs are watershed areas classified as such under Massachusetts Surface Water Quality Standards. These watersheds constitute an outstanding resource as determined by their important socioeconomic, recreational, ecological, and/or aesthetic values. Such areas have been identified so that they may be protected and maintained. There are no ORWs located within or adjacent to the project area.

An Area of Critical Environmental Concern (ACEC) in Massachusetts is an area that receives special recognition because of the quality, uniqueness, and significance of its natural and cultural resources. There are no ACECs mapped on or near the project site or within the project area.

5.0 PHRAGMITES MANAGEMENT PLAN

The management of phragmites at Long Pond will need to extend along almost the entire 3,150 linear feet of bank. Due to the extent and density of the phragmites population, the best means of management will be foliar application of the herbicide Clearcast (ammonium salt of imazamox). This will likely need to be performed both from the land and from a boat on the pond. Although glyphosate is often used for the management of phragmites, as was used on the bank opposite from the management area described in this report, Clearcast is similarly effective and is more selective than glyphosate. Therefore, it reduces the potential risk of non-target impacts. See Attachment B for more details on Clearcast.

Phragmites is a very aggressive, invasive colonizer. SWCA proposes pre-management cutting and removal of phragmites in the early spring or late fall prior to management. This will minimize the height of the population prior to herbicide application and increase full-population herbicide contact. A second follow-up cutting event should occur before the second year of treatment. This cutting and removal schedule will serve two purposes: (1) remove the previous growing season’s dead material and reduce density and height for the next year’s management events, and (2) remove phragmites following herbicide application to open the area for native vegetation establishment.

In order to successfully perform manual cutting and removal of the phragmites, access lanes will need to be established through the BVW and buffer zone to the east of the phragmites population. These lanes will be minimally disturbed; just enough to access by foot and transport bags of collected phragmites cuttings. Alternatively, management could include a combination of annual foliar herbicide application and gradual cutting and removal from the primary access point (the Cambridge Street bridge). This would include small-scale cutting each year prior to herbicide application and working down toward the beach in larger sections each year. This option could potentially reduce the impact to the surrounding BVW and buffer zone but would require more labor hours to cut and remove the entire phragmites population.

3 Long Pond Summary Report

5.1 Management Timing

The best management approach for the second year of management should be determined after a follow- up phragmites survey. It is likely that the second year will require two additional treatments of Clearcast and additional cutting and removal of phragmites. However, it is crucial to practice adaptive management in invasive plant management projects such as this. Adaptive management is the best practice to control invasive plants. Once the phragmites on site is substantially reduced, SWCA recommends seeding with a native wetland seed mix at a high rate of dissemination. It is important to populate all exposed ground with native seed as soon as possible each spring to encourage native growth and to discourage phragmites regrowth. Seeding is a good, low-cost means of revegetation that is less risky to perform prior to the complete eradication of invasive plants. Overall, conditions on-site will likely change throughout the management program. Therefore, the exact timing of restoration seeding will depend on conditions each year following the initial treatments.

6.0 POND ASSESSMENT SUMMARY

The phragmites at Long Pond is the primary concern for the NCF. SWCA delineated the bounds of the phragmites present at the pond and surveyed the phragmites management area for any critical impediments to management as well as natural resources. The drone survey of the phragmites population indicated that the population to be managed covers approximately 3.3 acres along the southeastern bank of the pond.

The proposed management plan for phragmites around the pond will provide the highest efficacy while maintaining ecological sensitivity. SWCA will work with the NCF to ensure this is clear in our presentation to the Nantucket Conservation Commission and feels confident that the proposed management plan will be approved as described. Once implemented, the proposed management plan will increase native biodiversity and increase the habitat for native wildlife species, such as nesting birds.

Appendix D.

Clearcast Information

Clearcast is beneficial to use on sites where selectivity to native grasses was desired. Now, with growing public pushback on glyphosate, we’ve seen Clearcast making its way into larger management sites. True et al (2010) demonstrated 50% control using a 1.25% spray solution and Cheshier et al (2012) reports 80% growth reduction.

SePRO’s technical bulletin should be used as a guide for treatment. The 1% v/v or 64 oz/A recommendation for broadcast spraying is in line with the rates tested in the attached papers. We suggest increasing the rate closer to 2% v/v or 96 oz/A to raise level of control beyond 80%.

Jon Gosselin | Technical Specialist

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J. Aquat. Plant Manage. 48: 121-123 NOTES

Efﬁcacy of Selected Aquatic Herbicides on Common Reed

SARAH L. TRUE, R. J. RICHARDSON1, P. L. HIPKINS AND A. P. GARDNER2

INTRODUCTION (Mal and Narine 2004). Selective grass herbicides often used in ornamentals and turf management (clethodim, dithiopyr, Common reed (Phragmites australis [Cav.] Trin. ex Steud.) fenoxaprop, fluazifop, MSMA, and sethoxydim) did not pro- is an invasive perennial grass with a near-worldwide spread vide control in greenhouse studies (Derr 2008a). Monteiro (Weakley 2008). It forms dense aggregations in fresh, salt, et al. (1999) found that cutting or mowing in the fall before and brackish wet areas including marshes, stream and lake a spring herbicide application improved control. In that banks, drainage ditches, and roadsides (Mal and Narine study, both isopropylamine (2.9 kg ai/ha) and trimesium 2004). Common reed has drastically increased in numbers (2.6 kg ai/ha) salts of glyphosate provided equivalent con- and distribution over the past 150 years (Saltonstall 2002). It trol, but treatment rates of 2.5% v/v rather than 2% v/v (400 withstands salt and alkaline waters and can grow in still or and 320 L/ha application volume, respectively) gave greater flowing water (Uva et al. 1997), aggressively taking over these control (Monteiro et al. 1999). Ailstock et al. (2001) found water areas and displacing native species (Weakley 2008). common reed treatment with glyphosate or glyphosate plus Common reed is classified as a “cryptic” invader because it burning, greatly reduced plant abundance and increased cannot be easily identified as native or introduced (Salton- plant biodiversity. However, this study found frequent re-es- stall 2002). A native form of Phragmites australis ([Cav.] Trin. tablishment due to the prolific nature of common reed rhi- ex Steud. ssp. Americanus) is rare and grows in freshwater zomes (Ailstock et al. 2001). marshes (Weakley 2008). This haplotype has been displaced Virginia Cooperative Extension has recommended foliar from New England, and its numbers have greatly decreased applications of glyphosate at labeled rates for common reed in other parts of the country as the introduced aggressive control (Barnes 2003); however, Mozdzer et al. (2008) found haplotype has become dominant (Saltonstall 2002). The in- that an imazapyr foliar application (2 to 5% v/v) was more vasive haplotype is considered one of the most profuse plant effective than glyphosate (2% v/v). Kay (1995) found that species in coastal wetlands of the United States (Blossey wipe-on applications of imazapyr or glyphosate did not pro- 2002). vide sufficient common reed control. Derr (2008b) evaluat- A primary concern with common reed is the invasion of ed postemergence herbicides with treatments in summer coastal wetlands. Its presence is often considered a sign of and fall. In field and greenhouse studies, glyphosate (2% v/ wetland disturbance (Blossey 2002). Common reed invasion v) and imazapyr (1% v/v) reduced Phragmites growth at reduces floral and faunal biodiversity and changes the struc- least 80%. Fosamine treatments provided 68% control at 7 ture of the ecosystem (Mozdzer et al. 2008). It grows in wa- months after treatment (MAT) and 43% at 10 MAT (Derr ters of varying salinities and out-competes native brackish- 2008b). Imazapyr and glyphosate can be applied to foliage in water plant species, thus degrading habitat for native insects summer or fall, with equivalent results the following year and animals. Vasquez et al. (2005) found that the invasive Derr (2008b). In summer, Phragmites plants are smaller and biotype of common reed tolerated much higher levels of sa- easier to spray compared to fall when plants are much taller linity than did two native biotypes. On much of the eastern (Derr 2008b). U.S. coast, common reed is replacing the dominant native Derr (2008a) also evaluated common reed response to plant Spartina alterniflora (Able and Hagan 2000). This shift mowing and herbicide applications. Plots treated with 2.24 was shown to have a negative effect on larval and small juve- kg ai/ha glyphosate had a higher control rating than those nile fish (Able and Hagan 2000). treated with 1.12 kg ai/ha glufosinate (96 vs. 71% control, re- Previous research has evaluated common reed manage- spectively). Mowing every 2 weeks resulted in 93% common ment with herbicides, cutting, burning, and de-watering reed control at 4 MAT, while mowing every 4 or 8 weeks provided less control (81 and 69% at 4 MAT, respectively). At 12 MAT, plots that were mowed every 2, 4, or 8 weeks all had 1Department of Crop Science, North Carolina State University, Raleigh, similar control levels. Mowing could be a control option for NC 27695. common reed where nonchemical options are preferred. Re- 2Department of Plant Pathology, Physiology, and Weed Science, Virginia Tech, Blacksburg, VA 24060. Received for publication May 2, 2010 and in gardless of control method, this species needs to be moni- revised form August 20, 2010. tored and managed for subsequent years to combat regrowth

J. Aquat. Plant Manage. 48: 2010. 121

(Monteiro et al. 1999, Ailstock et al. 2001, Barnes 2003, Derr treatments included 0.25% v/v nonionic surfactant (Induce, 2008a, 2008b). Helena Chemical Co., Collierville, TN). A nontreated con- While numerous herbicides have been evaluated for com- trol was also included. Study design was a randomized common reed control, the focus has often been on products la- plete block with four treatment replications. Experimental beled for terrestrial rather than aquatic sites. Triclopyr is treatments were applied to foliage with 280 L/ha spray vol- registered for use on aquatic sites, and the product label also ume. Applications were sprayed to wet, but not runoff. Plots lists common reed as a species controlled. However, little in- were rated at 3 and 12 MAT on a 0 to 100% scale as described formation is available with regard to actual triclopyr efficacy in field study 1. on this weed. In addition, two herbicides recently registered for aquatic use, imazamox and penoxsulam, have not been Statistical Analysis fully evaluated. The objective of this research was to evaluate herbicides with aquatic site registrations for common reed Data were subjected to analysis of variance, and means control. were separated using Fisher’s Protected LSD (P ≤ 0.05) in SAS v. 9.1 (SAS Institute Inc., Cary, NC). Nontreated controls MATERIALS AND METHODS were not included in statistical analysis of visual ratings. Data were combined across study repetitions because no treatment by year interaction occurred. Field Trial 1 A field herbicide trial was initiated on 6 June 2006, in a RESULTS AND DISCUSSION brackish marsh near Aurora, North Carolina, and on 7 July 2006, at a roadside in Mathews County, Virginia, to evaluate Field Trial 1 control with four different herbicides registered for application to aquatic sites. In North Carolina, plots were 7 m long At 3 MAT, control with all imazapyr and glyphosate treat- by 3 m wide and were located in a well-established 2 to 3 m ments was at least 78%, with 93% control obtained with tall common reed stand. In Virginia, plots were 3 m long by 2 1.25% v/v imazapyr plus 1.25% v/v glyphosate (Table 1). m wide and common reed was 1 m tall after being mowed 5 Common reed, however, was not controlled with penoxsu- weeks prior. Treatments included glyphosate (Touchdown lam, and control with triclopyr was only 52%. At 12 MAT, Pro, Syngenta Crop Protection, Inc., Greensboro, NC) at control was 74 to 86% with treatments containing glyphosate 1.25 and 2.5% v/v, imazapyr (Habitat, BASF Corporation, or imazapyr. Control with triclopyr and penoxsulam did not Research Triangle Park, NC) at 1.25 and 2.5% v/v, imazapyr exceed 2%. (1.25% v/v) plus glyphosate (1.25% v/v), penoxsulam (Gal- leon SC, SePRO Corporation, Carmel, IN) at 0.5% v/v, and Field Trial 2 triclopyr (Renovate, SePRO Corporation, Carmel, IN) at At 3 MAT, common reed control was 93% or greater with 5.0% v/v. Herbicides were applied using a CO2-pressurized backpack sprayer with an application volume of 280 L/ha. imazapyr (Table 2). Control with glyphosate and triclopyr Treatments were applied by handgun to foliage and sprayed treatments was 73 to 79%, while imazamox and penoxsulam to wet, but not runoff. Each treatment included a non-ionic did not control common reed more than 51%. At 12 MAT, surfactant in North Carolina (Induce, Helena Chemical Co., Collierville, TN) at 0.25% v/v and in Virginia (Cide-Kick, Brewer International, Vero Beach, FL) at 0.5% v/v. TABLE 1. PHRAGMITES CONTROL WITH SELECTED POSTEMERGENT HERBICIDES A,B Experimental design was a randomized complete block IN FIELD STUDY 1. with three treatment replications. Common reed control was Treatment c Rate 3 MAT d,e 12 MAT estimated visually at 3 and 12 MAT on a 0 to 100% scale. Rat- ings compared treated plots to nontreated plots and consid- % v/v ------% ------ered chlorosis, necrosis, and stunting, with 0% Glyphosate 1.25 78 c 74 b corresponding to no control and 100% corresponding to Glyphosate 2.5 85 b 86 a complete plant death. Imazapyr 1.25 86 b 83 ab Imazapyr 2.5 88 ab 78 ab Field Trial 2 Imazapyr + glyphosate 1.25 + 1.2 93 a 80 ab Penoxsulam 0.5 8 e 2 d In 2007, a separate trial was initiated on two sites at Caroli- Triclopyr 5.0 52 d 0 d na Beach and Wilmington, North Carolina. Experimental aResults pooled across Aurora, NC, and Mathews, VA, locations due to no plots were 6 m long by 3 m wide and located in a well-estab- treatment by location interaction. lished 1 to 3 m tall stand of common reed. Five currently reg- bMAT = months after treatment. istered aquatic herbicides were selected including cNIS at 0.25% v/v included with all treatments in the North Carolina study glyphosate, imazamox, imazapyr, penoxsulam, and triclopyr. and NIS at 0.5% v/v included with all treatments in the Virginia study. d Treatments included glyphosate at 1.25 and 2.5% v/v, Weed control rated on 0 to 100% scale; 0% equals no plant response and 100% equals plant death. imazamox (Clearcast, BASF Corporation, Research Triangle eMeans within a column followed by the same letter are not significantly dif- Park, NC) at 0.63 and 1.25% v/v, imazapyr at 1.25 and 2.5% ferent according to Fisher’s Protected LSD (P ≤ 0.05). Nontreated control v/v, penoxsulam at 0.5% v/v, and triclopyr at 5% v/v. All not included in statistical analysis of visual ratings.

122 J. Aquat. Plant Manage. 48: 2010. Invasive Plant Science and Management 2012 5:101–105

Notes and Commentary

Evaluating the Potential for Differential Susceptibility of Common Reed (Phragmites australis)Haplotypes I and M to Aquatic Herbicides

Joshua C. Cheshier, John D. Madsen, Ryan M. Wersal, Patrick D. Gerard, and Mark E. Welch*

Common reed (Phragmites australis) is an invasive perennial grass in aquatic and riparian environments across the United States, forming monotypic stands that displace native vegetation that provides food and cover for wildlife. Genetic variation in global populations of common reed has given rise to two invasive haplotypes, I and M, in the United States. Our objectives were to (1) determine if any differences in herbicide efficacy exist with respect to common reed haplotypes I and M and (2) screen for other labeled aquatic herbicides that may have activity on common reed haplotypes I and M, most notably imazamox and diquat. A replicated outdoor mesocosm study was conducted in 1,136-L (300-gal) tanks using haplotypes I and M of common reed. Restriction fragment length polymorphism methodologies were used to verify 2 2 the identification of I and M haplotypes used in this study. Diquat at 2.2 (1.9) and 4.5 (4.0) kg ai ha 1 (lb ai ac 1), 2 2 2 2 glyphosate at 2.1 (1.8) and 4.2 (3.7) kg ae ha 1 (lb ae ac 1), imazamox at 0.6 (0.5) and 1.1 (0.9) kg ai ha 1 (lb ai ac 1), 2 2 2 2 imazapyr at 0.8 (0.7) and 1.7 (1.5) kg ai ha 1 (lb ai ac 1), and triclopyr at 3.4 (3.0) and 6.7 (5.9) kg ae ha 1 (lb ae ac 1) were applied to the foliage of common reed. After 12 wk, no difference (P 5 0.28) in herbicide tolerance was seen 2 2 between the two haplotypes with respect to biomass. The 4.2-kg ae ha 1 rate of glyphosate and the 0.8- and 1.7 kg ai ha 1 2 rates of imazapyr reduced common reed by . 90% at 12 wk after treatment (WAT). Imazamox at 0.6 and 1.1 kg ai ha 1, 2 and triclopyr at 3.4 and 6.7 kg ae ha 1 reduced common reed biomass (62–86%) at 12 WAT, though regrowth occurred. Diquat did not significantly reduce biomass by 12 wk. Glyphosate and imazapyr were the only herbicides that resulted in . 90% biomass reduction and corroborate control from previous studies. Nomenclature: Diquat; glyphosate; imazamox; imazapyr; triclopyr; common reed, Phragmites australis (Cav.) Trin. ex Steud PHRCO. Key words: Phragmites australis, invasive plant management, wetland, chemical control, riparian.

Common reed is a perennial aquatic and riparian grass that is found on every continent except Antarctica (Holm et al. 1977) and has the widest distribution of any DOI: 10.1614/IPSM-D-11-00051.1 flowering plant (Tucker 1990). In the United States, * First, second, and third authors: Research Associate, Associate common reed is found in every state except Alaska and Professor, and Postdoctoral Associate, respectively, Geosystems Hawaii. Today, rapid expansion of common reed is Research Institute and Department of Plant and Soils Science, attributed to multiple introductions of nonnative strains, Mississippi State University, Box 9652, Mississippi State, MS 39762; likely from Europe and Asia in the late 1700s (Saltonstall fourth author: Professor, Department of Mathematical Sciences, 291 2002). Anthropogenic effects such as hydrologic alterations Barre Hall, Clemson University, Clemson, SC 29634; fifth author: and disturbances (Roman et al. 1984), and increased Assistant Professor, Department of Biological Sciences, Mississippi eutrophication of the environment through nutrient runoff State University, Box 9536, Mississippi State, MS 39762. Current (Chambers et al. 1999) have all been factors in common address of first author: 377 SW McFadden Ave, Chehalis, WA reed expansion. The primary source of propagation for 898532. Corresponding author’s E-mail: [email protected] common reed is vegetative growth through the formation

Cheshier et al.: Common reed susceptibility to aquatic herbicides N 101 Haplotype I is thought to have originated in South Management Implications America and parts of Asia and is the most prevalent Common reed (Phragmites australis) is an invasive perennial haplotype along the Gulf Coast of the United States grass in aquatic and riparian environments across the United (Hauber et al. 1991; Saltonstall 2002). Haplotype I has States. Common reed has high genetic variability, with two unique been present along the Gulf Coast since the late 1800s haplotypes, I and M, having the greatest distribution. Our (Saltonstall 2002). Genetic analysis of pre-1910 herbarium common garden mesocosm study indicated that there was samples as well as current samples indicate genetic no difference in the susceptibility of the two most common haplotypes (I and M) to a selection of aquatic herbicides. autonomy and geographic isolation of this haplotype along Glyphosate and imazapyr at all rates evaluated provided excellent the Gulf Coast of the United States (Pellegrin and Hauber control of common reed and would be recommended for large- 1999; Saltonstall 2002) from all other populations of scale applications. Triclopyr provided good control only at the common reed in North America. Haplotype I’s closest maximum application rate, and regrowth tended be quicker (as relative is only found in Asia (Saltonstall 2002). Haplotype observed new shoot growth) than in plants treated with either glyphosate or imazapyr, but may be a more selective option M is found throughout Eurasia and Africa and is depending upon associated species. Identifying effective herbicides considered native to those ranges. In North America, and use patterns for controlling common reed will provide land haplotype M is replacing native haplotypes in the New managers with necessary information on effective selective and England states and has become prevalent in the Midwest- nonselective control of this invasive plant in aquatic systems. ern states (Saltonstall 2002). Haplotype M displays invasive characteristics in that it overtakes wetlands and shorelines, of rhizomes and stolons (Haslam 1973). Rhizomes not produces monotypic stands, and outcompetes native only function as the primary means of reproduction vegetation and wildlife (Able and Hagan 2000; Chambers (Kilmesˇ et al. 1999) but they store the majority of the et al. 1999; Marks et al. 1994; Saltonstall 2002; Windham plant’s carbohydrates (Fiala 1976; Kilmesˇ et al. 1999). and Lathrop 1999). Species in the genus Phragmites display high phenotypic To mitigate the spread of invasive haplotypes, management has utilized herbicides to control this species. plasticity, making identification difficult (Clayton 1967; % Haslam 1972; Koppitz 1999). Multiple morphological Glyphosate and imazapyr provided 82 and 93 control, traits have been suggested for differentiation between respectively, under field conditions (Derr 2008a). Triclo- common reed of various origins, however the sole use of pyr, which is typically selective for monocot species, these characteristics as a definitive identification tool is reduced common reed shoot, regrowth shoot weight, and stem number by 40 to 92% when applied at 1.12 (0.9) difficult and highly subjective (Saltonstall et al. 2004). A 21 21 key tool in the identification of invasive lineages of and 6.72 (5.9) kg ae ha (lb ae ac ), respectively under common reed has been the use of polymerase chain greenhouse conditions (Derr 2008a). Wipe-on applications reaction, restriction fragment-length polymorphism analy- of both glyphosate and imazapyr were not considered % ses (PCR-RFLPs) (Saltonstall 2001, 2003). The differences efficacious (Kay 1995). Imazapyr provided 57 and 75 % in DNA fragment size can be used to identify unique control of common reed respectively, when 25 and 50 genetic variants, also commonly referred to as haplotypes. dilutions were applied to plants (Kay 1995). Glyphosate % Haplotype differences have been linked with invasions applied using a wiper applicator provided 38 and 33 of nonnative common reed (Saltonstall 2002) and are control when applied at similar rates as imazapyr; however, important for properly identifying an unknown population when glyphosate was applied as a foliar spray it provided as well as providing a vital tool in management decision 100% control (Kay 1995). Monteiro et al. (1999) reported support. These cryptic invasions of common reed over the that cutting common reed prior to herbicide applications last 200 yr have resulted in a loss of native common reed had a positive effect. Pursuant to this, increasing the spray and an increase in nonnative haplotypes (Saltonstall 2002). volume increased the control of common reed; a higher Currently, there are 29 haplotypes of common reed that volume provided . 90% control, resulting in less plant have been identified worldwide, 13 of which are native to biomass and less plant density than the lower spray volume. North America; five of these are native to the northeastern With the ongoing spreading of nonnative common reed portion of North America (K. Saltonstall, personal haplotypes across North America, an assessment of communication). Of the 29 haplotypes discovered world- herbicides is necessary to identify effective chemistries wide, haplotypes I and M have the most widespread and screen for potential differential susceptibility between distribution on multiple continents, with haplotype M haplotypes. Therefore, the objectives of this study were to being the most common type in North America, Europe, (1) determine if any differences in herbicide efficacy exist and Asia today (Saltonstall 2002). Haplotypes I and M are with respect to common reed haplotypes I and M, and (2) the most problematic haplotypes in the United States, screen for other labeled aquatic herbicides that may have though haplotype M is expanding its range at a faster rate activity on common reed haplotypes I and M, most notably than that of haplotype I (Saltonstall 2002). imazamox and diquat.

102 N Invasive Plant Science and Management 5, January–March 2012 Materials and Methods study was conducted as a split plot design with the whole plot factor being two rates of diquat, glyphosate (iso- Haplotype Identification. Rhizomes of haplotype I were propylamine and mono-potassium), imazamox, imazapyr, collected from Polecat Bay, east of Mobile, AL (Lat. triclopyr, and an untreated reference. The subplot factor 30u4298.180N, 88u0925.700W). Rhizomes of haplotype was haplotype, I and M, of common reed. Each treatment M were collected from the St. John’s Marsh, located on was replicated four times in the 1,136-L tanks. Herbicide the northern shore of Lake St. Clair, near Harsens Island, treatment data were analyzed by fitting mixed models using MI (Lat. 42u359970N, 88u37930.500W). Rhizomes were the Mixed Procedure (SAS software, SAS Institute Inc., transported to an outdoor mesocosm facility at the R. R. Cary, NC). Common reed shoot biomass was included in Foil Plant Science Research Facility, Mississippi State the model as the dependent variable. Treatment, haplotype, University, Starkville, MS, and separate culture popula- and the treatment by haplotype interaction term were tions were established. Leaf tissue samples of each included as independent variables. Trial, the interaction haplotype culture were assayed using PCR-RFLP to terms tank by trial, and the treatment by tank within trial identify the variation in chloroplast DNA and verify the were included as a random effects to account for their haplotype identities used in this study (Saltonstall 2003). influence on the results. Haplotype (P 5 0.28) and 5 Planting. Common reed rhizomes were taken from the treatment by haplotype interaction (P 0.31) were not haplotype cultures and two 20 cm (8 in) rhizome segments significant, therefore data were pooled by trial and haplotypes to test for treatment effects. Treatment was of haplotypes I or M were planted in separate 18.9-L , (5 gal) plastic pots that were filled with soil. All pots were significant (P 0.01) and means were separated using least 2 2 amended with 2 g L 1 (0.32 oz gal 1) of 19–6–12 fertilizer squares means and grouped using Dunnett’s test. Only the H comparisons to the untreated references are reported, and all (Osmocote , Scotts-Sierra Horticultural Products Compa- , ny, Marysville, OH). A total of 104 pots were planted for analyses were conducted at the P 0.05 significance level. each haplotype. Two pots of each haplotype were then placed into each of 52 1,136-L tanks with water depth of Results and Discussion 15 cm that was maintained throughout the trials. Plants were . % allowed to grow for approximately 6 wk or until plants were The application of imazapyr resulted in 90 biomass 100 cm tall, an accepted treatment height in previous trials reduction for both rates against common reed (Figure 1). (Derr 2008a). Previous studies have shown similar results with imazapyr where applications successfully controlled common reed Treatment. Following the growth period, foliar applica- under greenhouse and field conditions (Derr 2008a; 2 tions of diquat (RewardH, 4.5 and 2.2 kg ai ha 1, Syngenta Mozdzer et al. 2008). Pursuant to this, Mozdzer et al. Crop Protection Inc., Greensboro, NC), glyphosate (2008) reported imazapyr applications to be more effective 2 (isopropylamine salt, RodeoH, 4.2 and 2.1 kg ae ha 1, than glyphosate applications, reducing common reed Dow AgroSciences LLC, Indianapolis, IN) and (mono- biomass by 95 and 79%, respectively. In the current study, 2 potassium salt, Touchdown Hi-TechH, 4.2 and 2.1 kg ae ha 1, glyphosate applied at the higher rate resulted in . 90% Syngenta Crop Protection Inc., Greensboro, NC), imazamox control regardless of the salt formulation (Figure 1). 2 (ClearcastH, 1.1 and 0.6 kg ai ha 1,SePROCorporation, Control of common reed when using glyphosate has been 2 Carmel, IN), imazapyr (HabitatH, 1.7 and 0.8 kg ai ha 1, reported to increase with increasing application rates BASF Corporation, Research Triangle Park, NC), and (Ailstock et al. 2001; Derr 2008a, Kay 1995; Riemer 2 triclopyr (Renovate3H, 6.7 and 3.4 kg ae ha 1,SePRO 1976). Although glyphosate effectively controls common 21 Corporation, Carmel, IN) were made to common reed. reed at label rates (4.2 to 8.8 L ha ), repeat applications Treatments were applied using a CO2-pressurized backpack have been reported as necessary to maintain control of sprayer (R&D Sprayers, Opelousas, LA) calibrated to deliver a existing common reed populations (Derr 2008a; Riemer 2 spray volume of 187 L ha 1. A nonionic surfactant (Dyne- 1976). AmicH, Helena Chemical, Collierville, TN) was added to the Unlike the nonselective systemic herbicides imazapyr spray solution at a rate of 0.25% v/v. Barriers were placed and glyphosate, triclopyr is typically selective for grass around each tank during application to prevent herbicide species, though it suppresses growth of common reed (Derr 21 drift. At 12 WAT, the aboveground biomass of common reed 2008a). Triclopyr at 3.4 and 6.7 kg ae ha reduced was harvested and dried in a forced-air oven at 70 C (158 F) common reed biomass by 68 and 86%, respectively, for 72 h, then weighed to determine dry mass of plants. compared to untreated reference plants, though regrowth occurred by 12 wk as new shoots were observed growing Experimental and Statistical Design. The study was from the sediment in treated containers. Control of conducted for 12 wk, from July to October 2008, and was common reed with triclopyr as observed in this study repeated when growing conditions were favorable. The corroborates results reported by Derr (2008a), where

Cheshier et al.: Common reed susceptibility to aquatic herbicides N 103 dominance and subsequent outgrowth of lateral buds (Murai et al. 1980). Plant hormones are typically produced in the meristematic regions of the plant and enforce apical dominance; treating a plant with an imidazolinone herbicide results in the death of the apical tip of a plant shoot bringing about a decrease in the rate of auxin production and the subsequent release of apical dominance (Shaner 1991). The loss of apical dominance could be an explanation or a secondary sublethal effect of imazamox causing the observed growth of common reed. In field situations, management of common reed will be most often influenced by habitat type, accessibility, budget constraints, and public perception, all of which will impact herbicide choice. Glyphosate and imazapyr provided the greatest level of control as indicated by percentage of biomass reductions, although imazamox and triclopyr did significantly reduce common reed biomass. Diquat showed early signs of efficacy on common reed, but did not result in control by 12 WAT. It is important to note that no single application of any herbicide or rate in this study completely controlled common reed, an observation seen in similar studies (Derr 2008a; Kay 1995; Monteiro et al. 1999); this reinforces the need for research on other herbicides and management strategies. Figure 1. Mean (6 1SE) biomass of common reed 12 wk after Management strategies for common reed could include treatment with select herbicides. There were no significant the newly registered herbicides for aquatic habitats including differences between trial and haplotypes, therefore data were penoxsulam, flumioxazin, and bispyribac-sodium. However, combined. Mean comparisons between herbicide treatments and common reed is not currently listed on the label for any of the untreated reference were made using the Dunnett’s test at a those herbicides; therefore, the efficacy of these herbicides on 0.05 level of significance. Significant differences are denoted by common reed is unknown. Mowing has been effective at an asterisk. The isopropylamine salt formulation of glyphosate is controlling common reed within season (Cross and Fleming denoted as IPA and mono-potassium salt formulation is denoted 1989; Derr 2008b; Gu¨sewell 2003). When integrating as MP. mowing with herbicide applications it was reported that applying glyphosate 1 mo after a mowing or 2 wk prior to mowing reduced common reed regrowth the following % reductions in regrowth shoot weight of 40 to 92% were season by 90 (Derr 2008b). However, applying glyphosate observed following triclopyr applications. The use of alone provided similar control the following season triclopyr may offer a more selective option depending on compared to glyphosate combined with a single mowing rate and associated species than using glyphosate or (Derr 2008b). The success or failure of common reed management may be dictated more by the timing of imazapyr; however, further research is needed to under- management practices than the selection of management stand triclopyr’s mechanism of action in monocotyledon techniques. For example, it is likely more efficacious to target species and to ascertain the level of selectivity that could seedlings instead of more mature plants or to target weak be achieved if using this herbicide with respect to the points in the life history of common reed such as times of nontarget plant associations. low carbohydrate storage. However, species specific life Applications of imazamox resulted in a growth reduction % 21 history data are often lacking when making decisions with of 62 and 78 , respectively, for 0.6 and 1.1 kg ai ha , respect to management timing and selection of techniques. though imazamox had more of a growth regulating effect on common reed than actually causing plant mortality. Biomass 12 WAT was lower with respect to the untreated Acknowledgments reference plants (Figure 1). After the initial plant injury This research was supported by the U.S. Geological Survey following imazamox applications, several new stems began Biological Resources Discipline, Invasive Species Program to grow from the nodes of the original culm, an under agreement 08HQA6013908121105. Chemicals were observation frequently referred to as witch’s broom. provided by BASF, Helena Chemical, SePRO Corporation, Witch’s broom is characterized by the release of apical and Syngenta Professional Products. We thank Drs. Gary

104 N Invasive Plant Science and Management 5, January–March 2012 Ervin, Kurt Getsinger, and David Shaw for reviews of previous Koppitz, H. 1999. Analysis of genetic diversity among selected versions of this manuscript. Approved for publication as populations of Phragmites australis world-wide. Aquat Bot. 64: Journal Article No J-11715 of the Mississippi Agricultural and 209–221. Forestry Experiment Station, Mississippi State University. Marks, M., B. Lapin, and J. Randall. 1994. Phragmites australis (P. communis): threats, management and monitoring. Nat. Areas J. 14: 285–294. Literature Cited Monteiro, A., I. Moreira, and E. Sousa. 1999. Effect of prior common reed (Phragmites australis) cutting on herbicide efficacy. Hydrobio- Able, K. W. and S. M. Hagan. 2000. Effects of common reed logia 415:305–308. (Phragmites australis) invasion of marsh surface macropauna: response Mozdzer, T. J., C. J. Hutto, P. A. Clarke, and D. P. Field. 2008. of fishes and decapods crustaceans. Estuaries 23:633–636. Efficacy of imazapyr and glyphosate in the control of non-native Ailstock, M. S., C. M. Norman, and P. J. Bushman. 2001. Common Phragmites australis. Restor. Ecol. 16:221–224. reed Phragmites australis: control and effects upon biodiversity in Murai, N., F. Skoog, M. E. Doyle, and R. S. Hanson. 1980. freshwater nontidal wetlands. Restor. Ecol. 9:49–59. Relationships between cytokinin production, presence of plasmids, Chambers, R. M., L. A. Meyerson, and K. Saltonstall. 1999. Expansion and fasciation caused by strains of Corynebacterium fascians. Proc. of Phragmites australis into tidal wetlands of North America. Aquat. Natl. Acad. Sci. U. S. A. 77:619–623. Bot. 64:261–273. Pellegrin, D. and D. P. Hauber. 1999. Isozome variation among Clayton, W. D. 1967. Studies in the Gramineae: XIV. Kew Bull. 21: populations of the clonal species Phragmites australis (Cav.) Trin ex. 111–117. Steudel. Aquat. Bot. 63:241–259. Cross, D. H. and K. L. Fleming. 1989. Control of Phragmites australis Riemer, D. N. 1976. Long-term effects of glyphosate applications to or common reed. U.S. Fish and Wildlife Service Leaflet 13.4.2:1–5. Phragmites. J. Aquat. Plant Manag. 14:39–43. Derr, J. F. 2008a. Common reed (Phragmites australis) response to Roman, C. T., W. A. Niering, and R. S. Warren. 1984. Salt marsh mowing and herbicide application. Invasive Plant Sci. Manag. 1: vegetation change in response to tidal restriction. Environ. Manag. 8: 12–16. 141–150. Derr, J. F. 2008b. Common reed (Phragmites australis) response to postemergence herbicides. Invasive Plant Sci. Manag. 1:153–157. Saltonstall, K. 2001. A set of primers for amplification of noncoding Fiala, K. 1976. Underground organs of Phragmites communis, their growth, regions of chloroplast DNA in the grasses. Mol. Ecol. Notes 1:76–78. biomass, and net production. Fola´ Geobot. Phytotaxon. 11:225–259. Saltonstall, K. 2002. Cryptic invasion by non-native genotypes of the Gu¨sewell, S. 2003. Management of Phragmites australis in Swiss fen common reed, Phragmites australis, into North America. Proc. Nat. meadows by mowing in early summer. Wetl. Ecol. Manag. 11: Acad. Sci. U. S. A. 99:2445–2449. 433–445. Saltonstall, K. 2003. A rapid method for identifying the origin of North Haslam, S. M. 1972. Biological flora of the British Isles, no. 128. American Phragmites populations using RFLP analysis. Wetlands 23: Phragmites communis Trinidad J. Ecol. 60:585–610. 1043–1047. Haslam, S. M. 1973. Some aspects of the life history and autoecology of Saltonstall, K., P. M. Peterson, and R. J. Soreng. 2004. Recognition of Phragmites communis Trin. Hydrobiologia 20:79–100. Phragmites australis subsp. americanus (Poaceae: Arundinoideae) in Hauber, D. P., D. A. White, S. P. Powers, and F. R. De Francesch. North America: evidence from morphological and genetic analyses. 1991. Isozyme variation and correspondence with unusual infrared SIDA 21:683–692. reflectance patterns in Phragmites australis (Poaceae), Plant System. Shaner, D. L. 1991. Physiological effects of the imidazolinone Evol. 178:1–8. herbicides. Pages 129–137 in D. L. Shaner and S. L. O’Conner, Holm, L. G., D. L. Plucknett, J. V. Pancho, and J. P. Herberger. 1977. eds. The Imidazolinone Herbicides. Boca Raton, FL: CRC. The World’s Worst Weeds: Distribution and Biology. Honolulu: The Tucker, G. C. 1990. The genera of Arundinoidea (Graminae) in the University Press of Hawaii. Pp. 373–378. southeastern United States. J. Arnold Arboretum 71:145–177. Kay, S. 1995. Efficacy of wipe-on applications of glyphosate and Windham, L. and R. G. Lathrop, Jr. 1999. Effects of Phragmites australis imazapyr on common reed in aquatic sites. J. Aquat. Plant Manag. (common reed) invasion on aboveground biomass and soil properties 33:25–26. in brackish tidal marshes of the Mullica River, New Jersey. Estuaries Kilmesˇ, L., J. Klimesˇova´, and H. Cˇ´ızˇkova´. 1999. Carbohydrate storage 22:927–935. in rhizomes of Phragmites australis: the effects of altitude and rhizome age. Aquat. Bot. 64:105–110. Received July 12, 2011, and approved December 12, 2011.

Cheshier et al.: Common reed susceptibility to aquatic herbicides N 105 Using Clearcast ® to control cattails and phragmites in and around golf course ponds

Cattails (Typha spp.) are native to North America. However, they can quickly populate a water body or pond on a golf course if left unmanaged. Populations of cattails will aggressively spread once established via seed dispersion and underground rhizomes. Additionally, cattails can grow to heights of 5 to 10 feet that can impede line of sight and impact visual appearance.

Using Clearcast® Herbicide to Control Cattails Clearcast is effective for control of cattails† during spring, summer and fall months. Best control with Clearcast has been found with applications during the fall months. For spring applications, use a higher rate range. Always use a surfactant for foliar applications.

Broadcast applications – Apply Clearcast at 32 to 64 l oz/A. For best results, use a methylated seed oil surfactant at 1% v/v. Other nonionic surfactants are also suitable.

Spot treatments – Mix Clearcast at a 1 to 2% solution (1.3 to 2.6 l oz Clearcast/1 gallon of water) in water. For best results, use a methylated seed oil surfactant at 1% v/v. Other nonionic surfactants are also suitable.

†For quicker browning of cattails, add AquaPro* at 32 l oz/A or 1% solution (1.3 l oz). Do not add AquaPro if desirable vegetation or turf is subject to overspray.

Continued on back.

*Trademark of SePRO Corporation. Clearcast is a registered trademark of BASF Corporation. Always read and follow label directions. Phragmites (Phragmites australis), also known as common reed, is an invasive aquatic and wetland weed found across the United States that was introduced from Europe in the 1800’s. It can spread rapidly often displacing native species and habitat. Phragmites spreads primarily via underground rhizomes making mechanical removal only a short term solution. It can grow to heights between 8 and 16 feet tall which can negatively impact golf course ponds and wetlands.

Using Clearcast® Herbicide to Control Phragmites Clearcast provides best control of phragmites with applications made in late summer and early fall. This application timing maximizes translocation of Clearcast to the underground rhizomes resulting in effective longterm control. Always use a surfactant for foliar applications.

Broadcast applications Apply Clearcast at 64 l oz/A. For best results, use a methylated seed oil surfactant at 1% v/v. In target areas where no desirable vegetation or turfgrass is subject to overspray or direct application, and to broaden spectrum of activity, control of phragmites is improved by tank mixing AquaPro* (glyphosate) at 32 l oz/A with Clearcast at 64 l oz/A. Good coverage will improve control.

Spot treatments – Mix Clearcast at a 2% solution (2.6 l oz Clearcast/1 gallon of water) in water. For best results, use a methylated seed oil surfactant at 1% v/v. In target areas where no desirable vegetation or turfgrass is subject to overspray or direct application, and to broaden spectrum of activity, control of phragmites is improved by tankmixing AquaPro (glyphosate) at a 1% solution (1.3 l oz AquaPro/1 gallon water) with a 2% solution of Clearcast. Good coverage will improve control.

Beneits of Clearcast for Weed Control in Golf Course Ponds: • Registered for use in golf course irrigation ponds†. • Can be applied near and around many desirable hardwood species. • Controls the entire plant, including the root system. • Allows for recolonization of desirable species due to minimal soil residual. • Controls other loating, emergent and shoreline weeds including: Alligatorweed Water Hyacinth Watershield Common Salvinia Water Lettuce Water Stargrass Frogbit Water Lily Japanese Stiltgrass Pennywort Water Primrose • Overspray will not generally damage most desirable turf species††. † Refer to label for specific irrigation restrictions. †† Minimize direct application to desired turf. Minor discoloration may occur. Turfgrass response to Clearcast may vary due to large number of species, cultivars and varieties. User should apply Clearcast to a small test area prior to large-scale application.

For more information about Clearcast Aquatic Herbicide, please contact your SePRO Specialist or call 1-800-419-7779. Visit our web site at www.sepro.com

Appendix E.

Photo Pages

Photo E-1. Overview of the project area of Long Pond looking south. Dated: August 11, 2020

Photo E-2. View of eastern edge of phragmites with buffer vegetation. Dated: August 11, 2020

E-1

Photo E-3. View of phragmites population up to the bank of Long Pond. Dated: August 11, 2020

Photo E-4. Example 1 of phragmites distribution from bank to buffer vegetation. Dated: August 11, 2020

E-2

Photo E-5. Example 2 of phragmites distribution from bank to buffer vegetation. Dated: August 11, 2020

Photo E-6. View of northernmost extent of the project area – initial access point from Massasoit Bridge. Dated: August 11, 2020

E-3

Photo E-7. Southernmost section of phragmites management area for as-needed American beach grass. Note existing American beach grass in the foreground. Dated: January 13, 2021

Photo E-8. Aerial view of southernmost section of phragmites management area for as-needed American beach grass planting. Dated: August 11, 2020

E-4

Appendix F.

Figures

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