Environmental Assessment Is Recorded in a Decision Notice

Environmental

United States Department of Assessment Agriculture

Forest Service Vegetation Management in Open Areas

November 2017 Ocoee Ranger District, Polk and McMinn Counties, Tennessee Tellico Ranger District, Monroe County, Tennessee Unaka Ranger District, Cocke and Greene Counties Watauga Ranger District, Carter, Johnson, Sullivan, Unicoi and Washington Counties, Tennessee

For Information Contact: Mary Miller 2800 Ocoee Street North Cleveland, TN 37312 423-476-9700

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Table of Contents

Glossary, Acronyms and Abbreviations ...... 1 Introduction ...... 7 Document Structure ...... 7 Background ...... 7 Purpose and Need for Action ...... 9 Proposed Action ...... 15 Decision Framework ...... 17 Public Involvement ...... 17 Issues ...... 17 ALTERNATIVES, INCLUDING THE PROPOSED ACTION ...... 19 Alternatives ...... 19 Alternatives Not Considered in Detail ...... 22 Design Criteria Common to All Alternatives ...... 22 Comparison of Alternatives ...... 23 AFFECTED AREA AND Environmental Consequences ...... 29 Biological Factors ...... 29 Social/Economic Factors ...... 81 Physical Factors ...... 99 Human Health and Safety ...... 136 Consultation and Coordination ...... 144 References/Literature Cited ...... 149

GLOSSARY, ACRONYMS AND ABBREVIATIONS

36 CFR 800 Regulations implementing Section 106 of the National Historic Preservation Act, as amended Acre (ac.) A unit of land area equal to 43,560 ft2 (208.7 ft. x 208.7 ft.) Acid Equivalent (a.e.) The portion of a formulation that theoretically could be converted back to the corresponding or parent acid. Alternative (Alt) A mix of resource outputs designed to achieve a desired management emphasis as expressed in goals and objectives, and in response to public issues or management concerns. AT (A.T.) Appalachian Trail Basal Area (BA) The area of a given section of land that is occupied by the cross-section of tree trunks and stems at their base. Units = ft2/acre. Biodiversity The diversity of life in all its forms and all its levels of organization. Biological Evaluation (BE) A documented Forest Service review of its activities in sufficient detail to determine how an action may affect any proposed, threatened, endangered, or sensitive species. Biomass The total mass of living matter within a given unit of environmental area. BMP Best Management Practices Breeding Habitat A large area of essential habitat that provides for the biological needs of the species within its breeding range. CCF Hundred cubic feet of timber. 1 standard cord = 0.79 CCF. CEQ (CEQ Regulations) Council of Environmental Quality, established by the National Environmental Policy Act of 1969, for regulating how NEPA is to be implemented. The Council is part of the Executive Branch of Federal Government. CFR Code of Federal Regulations CNF Cherokee National Forest Compartment A portion of a forest usually one ownership, usually contiguous and composed of a variety of forest stand types, defined for purposes of location reference and as a basis for forest management. (The percentage of land owned by the U. S. Forest Service within any one compartment may vary from <1% to 100%). Cultural Resource Physical remains of districts, sites, structures, buildings, networks or objects used by humans in the past. They may be historic, prehistoric, archaeological, architectural, or spiritual in nature. Cultural resources are non-renewable. Cumulative Effects Past, present, and reasonably foreseeable effects (regardless of who or what has caused, is causing, and might cause these effects) analyzed together with the effects from the management actions. Cx/Sy Compartment x/Stand y (e.g. C100/S10) Decommissioning Roads Restore roads to a more natural state. Decision maker Forest Supervisor or District Ranger Decision Notice (DN) The decision to implement or not implement an alternative for an Environmental Assessment is recorded in a Decision Notice.

Desired Condition Description of land and resource conditions if all long-term goals are achieved. DFC Desired Future Condition (a.k.a. Desired Condition) EA Environmental Assessment Early-successional Forest The biotic community that develops immediately following the removal or (ESF) mortality of most or all the forest canopy, resulting in a predominance of woody species regeneration. As used in Land Management Planning, a stand age of 0 to 10 years defines this condition. Often referred to as Early- successional Habitat (see below). Early-successional Habitat A vegetative condition typically characterized by low density to no tree (ESH) canopy cover and an abundance of herbaceous and/or woody ground cover. This condition may include early-successional forest, maintained openings, pastures, balds, and open woodlands. Ecosystem All the interacting populations of plants, animals, and microorganisms occupying an area, plus their physical environment. Effective treatment An activity resulting in a full benefit at year 1, then declining linearly over time until there are minimal benefits. Varies depending on activity. EHWA (a.k.a. HWA) Eastern Hemlock Wooly Adelgid EHWPF Eastern Hemlock and White Pine Forest EPA Environmental Protection Agency Erosion The wearing away of the land’s surface by running water, wind, ice, other geological agents, and human activity. ESA Endangered Species Act of 1973, as amended Even-aged The condition of a forest or stand composed of trees having no or relatively small differences in age. FEIS Final Environmental Impact Statement for the Cherokee National Forest’ Revised Land and Resource Management Plan (USDA Forest Service 2004b). Finding of No Significant A document that records the decision maker’s conclusion that implementing Impact (FONSI) an alternative would have no significant impact on the quality of the human environment, as defined in CEQ Regulations 1508.14. Forest Plan Short for the Cherokee National Forest’ Revised Land and Resource Management Plan (USDA Forest Service 2004a). FSR (a.k.a. NFSR) Forest Service Road GIS Geographic Information System Group Selection An uneven-aged regeneration method in which trees are removed periodically in small groups, resulting in uneven age classes for trees established in the group. Guideline Preferable limit to management actions that may be followed to achieve desired conditions. HESH High Elevation Shrubby Habitat Interdisciplinary Team (IDT) A group of resource specialists who conducted the environmental analysis and who wrote this Environmental Assessment. Issue An environmental resource about which someone has a concern. Issues are identified in NEPA § 102(2) (E) as unresolved conflicts. Land Class Code (LC) The fitness of a given type of land for a defined use. Large Woody Debris (LWD) Any piece(s) of dead woody material, e.g. dead boles, limbs and large root masses (wads), on the ground in forest stands, or in rivers and streams. 2

An animal or plant selected for use as a planning tool in accordance with 1982 NFMA regulations. MIS are used to help set objectives, analyze Management Indicator effects of alternatives, and monitor plan implementation. Chosen because Species (MIS) their population changes are believed to indicate the effects of management on selected biological components. Management practices and intensity selected and scheduled for Management Prescription application on a specific area to attain multiple-use and other goals and Area (MPA or PA) objectives. MPAs are defined in the RLRMP MCF Thousand Cubic Feet MDF Mesic Deciduous Forest Actions to avoid, minimize, reduce, eliminate or rectify the impact of a Mitigation Measure management practice (a.k.a. design criteria). Monitoring Report The annual CNF Monitoring and Evaluation Report MSF Mid-successional Forest

Natural Regeneration Tree seedlings that become established without artificial efforts.

NCT No Conclusive Trend NEP Net Ecosystem Productivity National Environmental Policy Act: a public law that outlines specific procedures for integrating environmental considerations into agency NEPA planning, and requires analyzing possible environmental effects of any major action on public land, and the disclosure of the possible effects to the public and other agencies for review and comment. NFMA National Forest Management Act (36 CFR 219.27) NFSR National Forest Service Road (a.k.a. FSR) NHPA National Historic Preservation Act (Public Law 102-575, 16 U.S.C. 470) NNIS Non-Native Invasive Species The most likely condition expected to exist in the future if current management direction continues unchanged; actions would be deferred; No Action Alternative used a the baseline in evaluating possible effects of implementing the action alternatives. NRHP National Register of Historic Places. Concise, time-specific statement of measurable and planned results that respond to identified desired conditions; forms the basis for further Objective planning; and are action items oriented and specifically describe measurable results. OOPF Oak and Oak-Pine Forest OR “Old” Road; an unauthorized road. OUT “Outlaw” Road; an unauthorized road pH A measure of acidity

An area planted to trees, typically with a planting machine or by hand Plantation planting PNV Present Net Value PO Permanent Opening The alternative (option/plan) that the decision maker plans to select near Preferred Alternative the end of the analysis process. This is not necessarily the selected alternative. Deliberately ignited fire for the purpose of forest management, often to Prescribed fire remove a heavy fuel buildup or simulate natural cycles of fire in an ecosystem. Portion of a landscape with similar management objectives and a common management prescription; prescription areas have specific Prescription Area direction regarding their desired condition, objectives, and Standards and Guidelines as provided in the RLRMP. (See also Management Prescription Area.) Reforestation To establish trees on a site by natural or artificial means. Responsible Official Forest Supervisor or District Ranger RF Riparian Forest RLRMP Cherokee National Forest Revised Land and Resource Management Plan The established criterion that prescribes the intensity of maintenance necessary for the planning operation of a road. There are five levels from Road Maintenance Level level 1 to level 5, with level 5 requiring the highest intensity of maintenance. See Appendix F of the RLRMP for details on level definitions. Scenic Integrity Objectives guide the amount, degree, intensity, and Scenic Integrity Objective distribution of management activities needed to achieve desired scenic (SIO) conditions. Objectives range from very high to very low. See Appendix F in the RLRMP for objective definitions. SDDW Snags, Dens and Down Wood The alternative (option/plan) that the decision maker selects to Selected Alternative implement. See Species Viability. Populations that are sufficiently abundant and have sufficient diversity to display the array of life history strategies and Self-sustaining forms to provide for their long-term persistence and adaptability over time. Plant and animal species identified by the Regional Forester for which Sensitive Species population viability is a concern. These species are included in the Eastern Region Sensitive Species list. Generally, short term means the duration of the activity plus a few months. Long term means after the short term, extending out to a Short and Long Term specified number of years. Long term (and in some cases, short term) will differ for each resource (e.g. fire, heritage, wildlife, etc).

State Historic Preservation Officer (SHPO) means the official appointed or designated pursuant to section 101(b) (1) of the National Historic SHPO Preservation Act to administer the State [Tennessee] historic preservation program or a representative designated to act for the State historic preservation officer. Slash Limbs, branches and tops of trees left after timber harvest. SMZ Streamside Management Zone A standing dead tree used by wildlife for breeding, roosting, perching Snag and/or foraging purposes. SPB Southern Pine Beetle SPF Sapling/Pole Forest A viable species consists of self-sustaining and interacting populations Species Viability that are well distributed through the species’ range. A contiguous group of trees sufficiently uniform in species composition, Stand arrangement of age classes, and condition to be a distinguishable unit. A requirement found in the RLRMP, which impose limits on natural Standard resource management activities, generally for environmental protection. Standards are required limits to activities. Stocking density Density of trees in an area, usually expressed in trees per acre. The diversity in a community that results from having many horizontal or Structural Diversity vertical physical elements (e.g. layers of canopy, supercanopy trees, down wood, etc.). Suitable Habitat Habitat able to support a reproducing subpopulation of a species. TDEC TN Department of Environment and Conservation TES Threatened, Endangered and Sensitive species Trail An existing one-track path or way of travel. An activity undertaken to modify or maintain the existing condition of Treatment the vegetation. TWRA TN Wildlife Resource Agency Unsuitable Habitat Habitat not able to support a reproducing subpopulation of a species. USDA United States Department of Agriculture USDI United States Department of Interior User-created trail A trail developed by users or use not maintained by the Forest Service. USFWS United States Fish and Wildlife Service VC Viability Concern species A population that has the estimated numbers and distribution of Viable Population reproductive individuals to ensure the continued existence of the species throughout its range. The physical capability of the land to support management activities and Visual Absorption Capability maintain visual integrity. VMEIS Vegetation Management Environmental Impact Statement

VQO Visual Quality Objective WLO Wildlife Opening

INTRODUCTION Document Structure The Forest Service, U.S. Department of Agriculture (Forest Service) has prepared this Environmental Assessment in compliance with the National Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. This Environmental Assessment discloses the direct, indirect, and cumulative environmental impacts that would result from the proposed action and alternatives. The document is organized into five parts: Introduction: The section includes information on the history of the project proposal, the purpose of and need for the project, and the agency’s proposal for achieving that purpose and need. This section also details how the Forest Service informed the public of the proposal and how the public responded. Comparison of Alternatives, including the Proposed Action: This section provides a more detailed description of the agency’s proposed action as well as alternative methods for achieving the stated purpose. These alternatives were developed based on significant issues raised by the public and other agencies. This discussion also includes possible mitigation measures. Finally, this section provides a summary table of the environmental consequences associated with each alternative. Environmental Consequences: This section describes the environmental effects of implementing the proposed action and other alternatives. This analysis is organized by resource area. Within each section, the affected environment is described first, followed by the effects of the No Action Alternative that provides a baseline for evaluation and comparison of the other alternatives that follow. Agencies and Persons Consulted: This section provides a list of prepares and agencies consulted during the development of the environmental assessment. Appendices: The appendices provide more detailed information to support the analyses presented in the environmental assessment. Additional documentation, including more detailed analyses of project-area resources, may be found in the project planning record located at the Supervisor’s office in Cleveland, Tennessee. Background

The project area is comprised of the Cherokee National Forest (the Forest or the Cherokee) in its entirety (Figure 1). Openings across the Forest persist due to maintenance actions and include openings maintained for wildlife habitat, as well as openings maintained as scenic vistas and utility easements. There are approximately 3,064 acres of permanently maintained spot and linear openings on the Forest, 14 developed scenic overlooks and 1,576 acres of electrical line easements. Many spot openings were created by the expansion of log landings following timber harvest. Some were maintained as pastures or crop fields before the Forest was established. Linear openings are roads that are closed and maintained in an open grassy/forb condition. Openings are maintained with funding provided by the Forest Service, the Tennessee Wildlife Resources Agency, as well as other partners including the National Wild Turkey Federation and

Appalachian Trail Conservancy. They may be dominated by native grasses and forbs or are planted in grass-clover mixtures, which include combinations of white clovers along with winter wheat and/or annual rye. Some openings are dominated by fescue, orchard grass and/or annual non-native species. The fourteen developed scenic overlooks are along the Ocoee Scenic Byway and Cherohala Skyway and provide travelers with unobstructed views to the surrounding mountains. These are generally maintained in non-native grasses which are mowed during the growing season.

Figure 1. Project Area - Cherokee National Forest

The electrical line easements across the Forest are maintained by fifteen electric systems including the Tennessee Valley Authority. These utilities provide electrical service to numerous Tennessee communities in and around the Cherokee National Forest. Electricity is transmitted from generating sources to various users through a network of distribution lines. Utility easements or rights-of-way are usually corridors across the landscape that are kept cleared of tall vegetation. Tall trees growing under or too close to utility lines often create problems. Trees or

8 branches which grow into power lines or break during wind or ice storms can cause power outages. Purpose and Need for Action The Cherokee National Forest Revised Land and Resource Management Plan (RLRMP), approved in 2004, made broad decisions regarding allocation of land and measures the need to manage National Forest resources. The RLRMP establishes direction for the multiple use management and sustained yield of goods and services for all National Forest lands within the CNF boundaries. It describes how different areas of land and forest should be portrayed and what resources could be provided from these lands in the present and what the desired future condition should be for the same lands. The RLRMP further allocates land into Management Prescriptions (MPs). A MP is a selected grouping of National Forest lands with similar land and resource characteristics and similar management goals. MPs provide a more specific set of goals and objectives, which help lead to the forests overall desired future condition (DFC). This action responds to the goals and objectives outlined in the Cherokee National Forest Plan, and helps move the forest towards desired future conditions described in that plan (Cherokee National Forest 2004a). Southern Appalachian grass and shrub balds, Southern and Central Appalachian bog and fen and old field/successional habitats are identified in the Tennessee State Wildlife Action Plan (Tennessee State Wildlife Action Plan Team 2015) as priority habitats. Species of Greatest Conservation Need found in these habitats include Northern bobwhite, red-headed woodpecker, golden-winged warbler, Southern cricket frog, seepage salamander crawfish frog, mountain chorus frog, mud salamander, Rafinesque’s big-eared bat, little brown bat and many others. Grassland ecological systems provide primary habitat for 74 Greatest Conservation Need (GCN) species identified in the Tennessee State Wildlife Action Plan. Native grassland ecological systems are among the most imperiled in Tennessee. In particular, grassland songbird populations are experiencing more severe declines than any other songbird guild in North America. Quality old field habitats are especially scarce and are critical to species such as northern bobwhite quail, turkey, deer, and numerous nongame species. Small open grassland communities such as glades and balds contribute to habitat diversity in extensive forested landscapes and provide essential habitat for many species that would not be present otherwise (Tennessee Wildlife Resources Agency 2014). Native grasses/grasslands are beneficial since they are long-lived, deep rooted, well adapted to poor soils and local soil types, drought tolerant, require less soil amendments in fertilizer and lime, and require less annual maintenance. They can provide increased benefit to agricultural producers due to their high-quality hay and forage for livestock and at the same time provide good wildlife habitat. In the utility corridors, there is a need for more effectively controlling encroaching undesired woody vegetation, reducing invading exotic vegetation, and establishing native grasses and other desirable species in a cost efficient manner. Current manual methods such as repeatedly cutting woody vegetation, cultivation, digging, or scalping with mechanized equipment every 3-6 years are ineffective and inefficient, and can be more ground-disturbing than herbicide use.

The conversion of the utility easements into grasses, forbs and shrubs would provide food sources as well as nesting and rearing habitat for several species of native wildlife. In addition, the National Forest would also benefit by the potential use of these areas as fire breaks. Tennessee Valley Authority and other utilities would benefit by a reduction in costs associated with maintaining an area free of woody stems that create obstruction to the electrical lines. Many of the cooperatives are non-profits operated for the mutual benefit of its members. The primary purpose of the cooperatives is to furnish its members with electric service at the lowest rates. Therefore, a reduction in costs associated with maintaining electrical lines would also benefit people in communities within and around the National Forest. Expediting evaluation and authorization of maintenance projects in utility corridors improves reliability of the electrical grid and supports transmission of renewable energy. The Forest Service has issued national directives implementing a 2006 interagency Memorandum of Understanding (MOU) to (1) ensure better cooperation and coordination with other federal agencies in evaluating and authorizing electric transmission projects; (2) optimize siting of rights-of-way for energy transmission corridors; and (3) expedite applications for electric transmission projects on NFS lands (United States Departments of Energy, Defense, Agriculture and Interior 2006). Permanent openings maintained by the Forest Service are used by a variety of wildlife, both game and non-game species. Permanent openings are used intensively in early spring and summer, but also are an important source of nutritious forage in winter; especially when acorns are in short supply. Forest openings are a key habitat component for wild turkeys and many other birds throughout the year. They provide nutritious green forage in the winter and early spring and seeds during late summer and fall. Because of the abundance of insects and herbaceous plants produced in these openings they are especially important as brood rearing habitat for young birds. Linear openings, especially those associated with young regenerating forests provide optimal brood habitat conditions for ruffed grouse. Currently these openings are maintained by mechanical means. Trees and other woody vegetation growing along the edges are pushed back with bulldozers or cut periodically to prevent encroachment in the opening. Some of the Objectives and Prescription Direction from the Revised Cherokee National Forest Land and Resource Management Plan (RLRMP) that specifically pertain to management of these areas are: Goal 10 Maintain and restore natural communities in amounts, arrangements, and conditions capable of supporting viable populations of existing native and desired non-native plants, fish, and wildlife species within the planning area. Goal 12 Provide breeding, wintering, and migration staging and stopover habitat for migratory birds in ways that contribute to their long-term conservation.

OBJECTIVE 12.01 Maintain at least 1000 acres above 3000 feet elevation in habitats characterized by grassy/herbaceous ground cover. This acreage may be comprised of open woodlands, savannas, and grasslands; old fields; and regenerating forests (0-10 years old).

Goal 15 Minimize adverse effects of invasive non-native species. Control such species where feasible and necessary to protect national forest resources.

Objective 15.02 Control non-native and unwanted native species, where they threaten Threatened, Endangered, or Sensitive species elements, ecological integrity of communities, or habitats created for demand species. Goal 17 Restore and maintain forest communities to those plant communities predicted as most likely to occur based upon the ecological potential of the site potential natural vegetation. Objective 17.09 Convert fescue fields to native grasses within a 10-year period where practical. Goal 31 Where financially and economically feasible, enhance the following opportunities: water based activities, sightseeing, camping, hunting, fishing, driving for pleasure, wildlife viewing/nature study, day-use and group facilities, non-motorized trail systems for hiking, biking, and equestrian use, designated OHV routes, special interest areas, interpretation and conservation education. Goal 52 Utility corridors and communication sites on NFS lands are located and managed to minimize adverse environmental, social, and impacts to scenery; minimize acres of land affected; designed using good engineering and technological practices; and clearly benefit society. The existing condition when contrasted with the Forest Plan Direction and Desired Condition, lay out the specific need for this project The purpose and need for this project includes: • Restoring and maintaining the early successional habitats (grassland and shrubland habitats) within the Cherokee National Forest project area to benefit native wildlife species • Restoring and maintaining the forest ecosystems on these lands, including fire adapted ecosystems and mesic forest communities, to promote diverse communities of native plants and animals • Preventing the establishment and spread of nonnative invasive species that pose a threat to this area and other native ecosystems. In addition to Forest Plan goals, President Bush’s Executive Order 13212, “Actions to Expedite Energy-Related Projects” signed on May 2001 established The White House Task Force on Energy Project Streamlining to improve and expedite cooperation among the Federal agencies evaluating energy related transmission and distribution projects on Federal lands. This Executive Order established a policy that the departments and agencies must take appropriate actions, consistent with applicable law, to expedite projects that will increase the supply and availability of energy for the country. Title XII, Section 215 of the Energy Policy Act of 2005, requires Federal agencies to expedite approvals that are necessary for owners or operators of electrical transmission and distribution facilities to comply with applicable reliability standards. These standards pertain to vegetation management, electric service restoration or resolution of situations that imminently endanger the reliability or safety of the facilities. In the utility corridors, the purpose of this proposal is to utilize mechanical and herbicide treatments to manage vegetation. The purpose of managing vegetation within the utility right-of- way is to reduce the potential for outages caused by faults along the lines and to allow ready access for maintenance and emergency repairs while meeting the management objectives set

11 forth in the Cherokee National Forest Revised Plan. This action is needed because electricity is transmitted from generating sources to various users through a network of distribution lines. Electric utilities must provide adequate protection to their distribution lines to allow uninterrupted service to their customers. Service can be interrupted by a fault in the line. The two main types of faults are short circuits and flashovers. Short circuits result when direct contact occurs between an energized conductor and another conductor or a grounded object such as a fallen tree. Flashovers are electrical discharges or currents through the air that result from conductors coming too close to other conductors or to grounded objects such as vegetation. The primary means of preventing faults is to maintain adequate clearance between the conductors and other objects such as trees. Therefore, the utility must remove tall trees within the right-of-way and ones which could fall and contact the conductors. Ecologically, the need for this proposal is based on historic and continuing losses of early successional habitats and the subsequent declines among wildlife species associated with these habitats. Nationally, grassland, savanna, and shrubland habitats have declined by greater than 98 percent (Noss et al. 1995). Predictably, the species associated with these habitats have declined with the loss of these habitats. In a Presidential Memorandum - Creating a Federal Strategy to Promote the Health of Honey Bees and Other Pollinators dated June 20, 2014, a Pollinator Health Task Force was established. Among other things, task force member agencies are to evaluate management practices on rights- of way and easements and make necessary changes to enhance pollinator habitat on Federal lands through the use of integrated vegetation management and pollinator friendly best management practices. The following photos illustrate the differences between the existing and the desired conditions. Figure 2 is a photograph displaying the existing condition in an area that has not been mechanically treated recently. Dense woody stems are shading out grasses and other perennial ground vegetation. Dense woody stems are shading out grasses and other herbaceous vegetation. In this case, grasses and forbs dominate the site. Figure 3 displays a more desired condition of a utility corridor maintained primarily by herbicides. Table 1 describes the comparison of existing and desired conditions.

Figure 2. Example of an existing condition in an opening where dense woody stems are shading out grasses and other perennial ground vegetation.

Figure 3. Example of a desired condition in a utility corridor maintained primarily by herbicides

Table 1. Comparison of Existing and Desired Conditions.

Element Existing Conditions Desired Conditions Predominant Utility corridors: Generally a Utility corridors: Minimally maintained Vegetation mixture of native and non- low growing native grasses, legumes and native grasses and forbs, as shrubs and desired cool season grasses. well as woody vegetation in need of cutting every 3-6 years Forest openings: Minimally maintained low to maintain electrical service. growing native grasses, legumes and shrubs and desired cool season grasses. Forest openings: Generally a mixture of native and non- native grasses and forbs, as well as woody vegetation in need of cutting every 3-6 years to maintain the opening.

Table 1. Comparison of Existing and Desired Conditions.

Element Existing Conditions Desired Conditions Noxious Utility corridors: Noxious All areas: Noxious weeds are controlled. weeds weeds are established and encroaching.

Forest openings: Noxious weeds are often controlled. Wildlife Utility corridors: Minimal soft Utility corridors: Nesting, bugging, brood habitat mast, nesting and bugging rearing habitat and escape cover maintained habitat created immediately with minimal maintenance and ground and temporarily after cutting or disturbance. Soft mast, nesting and bugging mowing. habitat created and maintained by mechanical and herbicide means. More Forest openings: Soft mast, desirable native grasses and herbaceous nesting and bugging habitat cover prevalent at a lower cost. created and maintained by mechanical means. Openings Forest openings: Soft mast, nesting and often are shaded out by bugging habitat created and maintained by encroaching vegetation and mechanical and herbicide means. More maintenance is sometimes desirable native grasses and herbaceous costly. cover prevalent at a lower cost.

Recreational Utility corridors: Minimal Utility corridors: Miles of opportunities for opportunities opportunities for wildlife wildlife viewing, hunting, berry picking, viewing, hunting, berry etc. picking, etc. created after cutting or mowing. Usually Forest openings: Acres of increased the recent cutting is unsightly. opportunities for wildlife viewing, hunting, berry picking, etc. with less unsightly Forest openings: Some cutting or bulldozing. opportunities for wildlife viewing, hunting, berry picking, etc. maintained by mechanical means. Reduction of woody vegetation sometimes unsightly.

Proposed Action The Proposed Action is to maintain approximately 4,654 acres of existing openings across the Forest using a combination of manual, cultural, and chemical control methods discussed below. The treatments are expected to begin in the fall of 2017 and are estimated to occur until 15 conditions change requiring new analysis. This proposed action is intended to be adaptive in nature. Not all openings would be treated every year. While the overlooks may be treated each year, wildlife openings and utility corridors would have varying treatments from year to year. Some would not be treated at all, others would be mechanically treated and still others would be chemically treated. In addition, this decision encompasses maintenance of future openings. This decision does not create openings, only maintain. Table 2 lists the total acreage of current openings and associated acreages as of September 2017. This could change as openings are created under other decisions.

Table 2. Current openings and associated acreages Treatment Area Acres Wildlife openings-spot and linear 3,064 Overlooks 14 Utility openings 1,576 TOTAL 4,654

The treatments proposed for maintaining early successional habitat in openings are:

. Manual cutting—use chainsaws or other cutting devices to remove woody vegetation. The intent is to maintain conditions suitable for the growth of grasses, forbs, and shrubs within the openings and on the edges. This will include cutting trees to increase feathering of the edges. Cutting along the edge averages about 25-75 feet and may include daylighting with heavy equipment such as bulldozers to remove vegetation. . Mowing—use equipment such as tractor-powered mowers to cut grass, brush, and tree seedlings at ground level. . Nonnative Invasive Species (NNIS) and Woody Encroachment Treatment—use hand, mechanical, and chemical treatments to remove or limit NNIS and to help reduce excess woody vegetation. This may include spot application of herbicides to prevent resprouting and use of herbicides instead of cutting woody vegetation. It is anticipated that chemical treatments might occur on 10-25% of the forest openings each year depending on need, funding and vegetative response. . Controlled Fire—increase vegetative diversity and quality through management-ignited fire. . Road Maintenance—maintain existing access roads to these locations through blading, mowing, culvert maintenance or ditching if needed. This decision does not include new roads. Access is available on public roads to most of the proposed treatment areas. . Root Raking—use dozers with raking attachments to remove woody encroachment. . Planting—to enhance vegetative diversity, if needed, plant a native seed mixture or desired non-native that includes shrubs, grasses, and herbaceous plants; broadcast seed or use no- till drills. . Strip Disking—drag equipment to rip the soil, loosening thick mats of grass and providing aeration and opportunity for new plants to grow.

Existing permits allow several maintenance activities in the utility corridors. The Forest proposes to add herbicide use to the treatments allowed for maintenance of utility corridor

16 segments, plus treatments such as seed drilling to establish native warm season grasses. This analysis does not commit a utility company to complete work beyond that required by its existing permit. Environmental effects of the proposed action and alternatives are disclosed in the AFFECTED AREA AND ENVIRONMENTAL CONSEQUENCES section of this document. Due to the broad scale of the proposal and its adaptive nature, additional site specificity would be ensured through the use of an implementation checklist (Appendix 1). Any ground disturbing management actions authorized through the NEPA document would be subject to additional site specific review by Forest staff in the areas of botany/ecology, wildlife biology, aquatic biology, hydrology/soils, and heritage resources prior to any treatments. The use of the implementation checklist would ensure that an interdisciplinary review is conducted regarding the management and restoration of each opening subject to ground disturbance, and would ensure that potential environmental impacts are within the scope of the impacts predicted in the NEPA document. Site specific impacts evaluated would include, but are not limited to:  Potential impacts to threatened, endangered, and sensitive species  Potential impacts to rare and unique communities  Potential impacts to forage and other wildlife investments  Potential impacts to water quality and aquatic species  Potential impacts to sites of historical or cultural significance

Decision Framework The decision to be made is whether or not to implement all or portions of the proposed action, another alternative, or a combination of actions in order to fulfill the purpose and need for the proposal. Public Involvement Scoping to solicit the issues and concerns related to the Proposed Action were received from November 20 to December 20, 2014. Letters (see Project Record) were mailed to approximately 200 interested or potentially affected agencies, organizations, tribes, individuals and adjacent landowners. The Consultation and Coordination section includes a listing of the agencies, organizations, tribes, individuals and adjacent landowners contacted. These letters informed recipients of the Proposed Action and requested their input. Additional information was sent to those that requested it. The proposal has also been listed in the CNF Schedule of Proposed Actions from October 2014 through the present. Issues Issues were derived from the public, other agencies, organizations and businesses, and Forest Service resource specialists. Issues are defined as a point of discussion, debate, or dispute about environmental effects. From the public comments received, several issues were identified. The issues have been refined based on input from the 30 day comment periods. These issues are the basis for the project analysis, project design criteria, alternatives, and overall disclosure of information in this document and supporting documentation found in the project record.

The Forest Service Interdisciplinary Team analyzed comments and separated the issues into two groups: 1) Issues to be analyzed and issues considered but not carried forward in the analysis. Issues to be analyzed are defined as those directly or indirectly caused by implementing the proposed action and that would require project specific alternatives, mitigation measures or design criteria to address them. 2) Issues considered but not carried forward are identified as those: a) outside the scope of the proposed action; b) already decided by law, regulation, Forest Plan, or other higher level decision; c) irrelevant to the decision to be made; or d) conjectural and not supported by scientific or factual evidence. The Council for Environmental Quality (CEQ) NEPA regulations require this delineation in Sec. 1501.7, “…identify and eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review (Sec. 1506.3)…”

Issues to be analyzed are derived from the comments received from the public and by the ID Team:  Herbicides could adversely impact humans, water sources, wildlife and aquatic life. All herbicides used will be applied according to the registered label requirements and specifications. In addition, all herbicide treatments proposed have been discussed with the U.S. Fish and Wildlife Service (Cookeville, TN).

There is a concern that the decline in frogs is related to the increase use of herbicides. “Glyphosate is lethal to gray tree frogs and leopard frog tadpoles…Glyphosate is just one of several pesticides that have been found in beeswax…milkweeds are killed along with other native vegetation by the use of glyphosates and other herbicides…” Power line companies spray everything, not just woody vegetation. “Wildflowers, like Solomon seal, will never bother the power lines. Even shrubs will not get into the power lies and should not be killed.” There is also a concern that: glyphosate interferes with the human body’s detoxification system; 2, 4-D is a suspected carcinogen; trout species are sensitive to picloram. The Forest Service should limit the use of these materials on Forest Service land.

The above issue is significant to the project

 Management options within the Appalachian National Scenic Trail Corridor

The Appalachian Trail Conservancy and Tennessee Eastman Hiking & Canoeing Club, which is the local maintaining club, support the proposed management options to maintain existing open areas within the A.T. corridor providing the U.S. Forest Service continue to coordinate and consult with them prior to project implementation. This would ensure that chemical applications and non-chemical treatments (burning, mowing, etc.) would not pose threats to hikers, campers, or wildlife. Moreover, consultation would provide opportunities to identify and prioritize special places along the A.T. for implementation such as Roan Mountain, Big Bald and Beauty Spot.

The above issue is non-significant to the project.

ALTERNATIVES, INCLUDING THE PROPOSED ACTION

This chapter describes and compares the alternatives considered for the Openings project. It includes a description and map(s) of each alternative considered in detail. This section also presents the alternatives in comparative form, defining the differences between each alternative and providing a choice among options by the decision maker and the public. Alternatives Alternative A – No Action

Under the No Action Alternative, routine mechanical activities on wildlife openings and overlooks would continue as would activities authorized through other decisions. Herbicide is currently only authorized on administrative sites, on non-native invasive species, on Fort Loudoun Electric Cooperative utilities in Monroe County and on a section of Tennessee Valley Authority line in Polk County. These activities would continue.

Alternative B - Proposed Action

The Cherokee National Forest proposes to maintain grassy, herbaceous and shrubby openings using a combination of manual, cultural, and chemical control treatment methods across the National Forest. While treatments are currently ongoing, new treatment methods are expected to begin in the fall of 2017 and are estimated to occur until conditions change requiring new analysis. Openings include those managed by the National Forest as openings benefiting wildlife species and utility corridors under special use permit by utility agencies, cooperatives and companies. In this proposal, openings would continue to be maintained by mechanical means. In addition, chemical methods would be used to establish desired vegetation. Openings would be treated with an appropriate rate of herbicide, using a backpack or portable low-pressure sprayer to promote native grasses and forbs during manipulation and establishment of grasses. Some areas may be planted using the no-till method or could remain unplanted. At that time, one of two seed mixtures could be used 1) a cool season mixture including annual rye grass and clover or 2) a native mixture including Indian grass, little bluestem, switchgrass, partridge pea, and big bluestem. Mixture selection would be based on site characteristics and species composition may vary. Plugs of native species that benefit pollinators may be planted as appropriate. Mechanical and chemical methods would also be used to maintain the preferred vegetation by selectively treating the woody sprouts that develop after planting. The treatments proposed for maintaining early successional habitat in openings are:  Manual cutting—use chainsaws or other cutting devices to remove woody vegetation. The intent is to maintain conditions suitable for the growth of grasses, forbs, and shrubs within the openings and on the edges. This will include cutting trees to increase

feathering of the edges. Cutting along the edge averages about 25-75 feet and may include daylighting with heavy equipment such as bulldozers to remove vegetation.  Mowing—use equipment such as tractor-powered mowers to cut grass, brush, and tree seedlings at ground level.  Non-native Invasive Species (non-natives) and Woody Encroachment Treatment—use hand, mechanical, and chemical treatments to remove or limit non-natives and to help reduce excess woody vegetation. This may include spot application of herbicides to prevent resprouting and occasional use of herbicides instead of cutting woody vegetation. Existing permits allow several maintenance activities in the utility corridors. The Forest proposes to add herbicide use to the treatments allowed for maintenance of utility corridor segments, plus treatments such as seed drilling to establish native warm season grasses. This analysis does not commit a utility company to complete work beyond that required by its existing permit.  Prescribed Fire—increase vegetative diversity and quality through management-ignited fire.  Road Maintenance—maintain existing access roads to these locations through blading, mowing, culvert maintenance or ditching if needed, but build no new roads. Access is available on public roads to most of the proposed treatment areas.  Root Raking—use dozers with raking attachments to remove woody encroachment.  Planting—to enhance vegetative diversity, if needed, plant a native seed mixture or desired non-native that includes shrubs, grasses, and herbaceous plants; broadcast seed or use no-till drills.  Strip Disking—drag equipment to rip the soil, loosening thick mats of grass and providing aeration and opportunity for new plants to grow. Openings maintained by the Forest would be treated as funding and logistical constraints allow. Most would be maintained by mechanical means each year, however, chemical treatments would occur on some areas. It is anticipated that chemical treatments might occur on 10-25% of the forest openings each year. Utilities would be required to submit annual operating plans with areas of maintenance identified. Buffers of untreated vegetation would remain near streams and other areas not appropriate for manipulation. Stream buffers would meet or exceed Revised Plan direction. Specific herbicides that could be used in the project area are listed below. Detailed descriptions of these chemicals including comprehensive risk assessments for each can be found at: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml.  Aminopyralid is a new herbicide that has been registered by the U.S. EPA for the control of invasive weeds. Uses of aminopyralid involve applications to forest and rangelands, rights-of-way, and developed recreational areas such as campgrounds, picnic areas and trails. Application methods include backpack (selective foliar). Two formulations of aminopyralid are specifically considered: Milestone and Milestone VM.  2,4-D, the common name for 2,4-dichlorophenoxyacetic acid, is a selective systemic herbicide used to control broadleaf weeds. In Forest Service programs, herbicide formulations containing 2,4-D are most commonly used in wildlife opening, rights-of- way maintenance, and noxious weed control.  Clopyralid is a selective herbicide that controls broadleaf herbs, primarily composites, legumes, and smartweeds. This chemical acts as a growth regulator and is typically 20

applied as a direct foliar application. With selectivity to legumes, this chemical is particularly useful in the control of kudzu, mimosa, and lespedeza. It may be used for wildlife opening maintenance, planting site preparation, and release of tree seedlings. Commercial brand-names include, but are not limited to TranslineTM.  Dicamba is a somewhat selective herbicide that controls most annual and perennial broadleaf herbs and some woody species. This chemical acts as a growth regulator and is typically applied as a direct foliar application. It is known to be effective on autumn olive. Commercial brand-names include, but are not limited to VanquishTM and OverdriveTM.  Fluazifop-P-butyl is an effective herbicide for the control of many annual and perennial grass weeds. It is used in forestry related applications including the control of grasses in tree farms, conifer nurseries, and conifer plantations as well as applications to rights-of- way, utility lines, fence lines, and several other non-crop sites.  Fluroxypyr is a selective post-emergent systemic herbicide registered for the control of broadleaf weeds in rangeland, non-crop areas, and grazed areas as well as for the control of woody brush. Uses of fluroxypyr involve applications to forest and rangelands, rights- of-way, and developed recreational areas such as campgrounds, picnic areas, and trails.  Glyphosate is a non-selective, broad spectrum herbicide that can be used to control many grasses, forbs, vines, shrubs, and tree species. Specific formulations of Glyphosate have been labeled for aquatic application. Formulations labeled for aquatic sites can be effective on both emergent aquatics and shoreline vegetation. This chemical is a growth inhibitor that can be applied through direct foliar application, stem injection, and cut- surface application. It has been proven effective on a wide variety of non-native invasive plant species. Commercial brand-names include, but are not limited to AccordTM, RoundupTM, and RodeoTM.  Imazapic is a selective herbicide that is used primarily in and around populations of native, warm season grasses. Warm season grasses, many wildflower species, and legumes are resistant, while many cool season grasses (including non-native species of Fescue) and broadleaf weeds are susceptible. It is often used for restoration of native plants in pastures and fields.Commercial brand-names include, but are not limited to PlateauTM.  Imazapyr is a selective herbicide that is used primarily in the control of hardwood trees and some species of grasses. This chemical is a plant protein production inhibitor that can be absorbed either through roots or foliage, or injected directly into the stem, and works systemically throughout the target plant. It has been proven effective in the control of tree of heaven, princess tree, mimosa, autumn olive, privet, and multiflora rose. Used in combination with Triclopyr or Glyphosate can increase target specificity. Commercial brand-names include, but are not limited to ArsenalTM and ChopperTM .  Metsulfuron methyl is a systemic herbicide that is selective to woody species, broadleaf weed species, and many annual grasses. It has been proven to be effective in the control of lespedeza, Japanese honeysuckle, kudzu, and multiflora rose. Commercial brand- names include, but are not limited to EscortTM.  Picloram is a systemic herbicide that is registered for the post-emergent control of broadleaf weeds and woody plants. Picloram is used in Forest Service programs primarily for the control of noxious weeds. Rights-of-way management is a minor use for

picloram. The formulations of picloram used most often by the Forest Service are Tordon K and Tordon 35 22K.  Triclopyr is a selective herbicide that controls many species of herbaceous and woody broadleaf weeds, but has little to no effect on grasses. This chemical acts as a growth regulator and can be applied as a direct foliar application, stem injection, or cut-surface treatments. Specific formulations of Triclopyr have been labeled for aquatic application. Formulations labeled for aquatic sites can be effective on both emergent aquatics and shoreline vegetation It has been proven effective on a wide variety on non-native invasive plant species. Commercial brand-names include, but are not limited to Garlon 3ATM, Garlon 4TM, and Pathfinder IITM. Methods of application would be:  Foliar, where the foliage of the individual plant to be controlled is sprayed;  Basal (streamline), where the herbicide is sprayed onto the individual stem of the plant to be controlled;  Cut surface, where the herbicide is applied to an axe-chop in the stem (hack and squirt), or to the freshly sawn stump. Aerial spraying will not be considered in this analysis as it is not allowed in utility corridors according to the Forest Plan. Alternative - C

In this proposal, appropriate vegetation would continue to be established by mechanical means. In addition, chemical methods could be used to establish the desired vegetation on openings managed by the Forest Service. Utility corridors would be treated mechanically only and no herbicide would be allowed with the exception of areas previously authorized. Alternatives Not Considered in Detail ______These alternatives were considered but eliminated from detailed study:  Do not allow herbicide in Forest Service maintained openings. This alternative was dropped from further consideration because it doesn’t meet the Purpose and Need.  Require utility companies to bury utility lines. This alternative would be too costly and utility lines are not FS property  Include the creation of new wildlife openings in the proposed action. The intent of the proposed action is more focused and is to cover maintenance activities on existing openings; however, any new openings authorized through the NEPA process will be covered in the future under this decision for maintenance purposes. Design Criteria Common to All Alternatives ______1. Due to the broad scale of the proposal and its adaptive nature, additional site specificity would be ensured through the use of an implementation checklist (Appendix 1). Any ground disturbing management actions authorized through the NEPA document would be subject to additional site specific review by Forest staff in the areas of botany/ecology, wildlife biology, aquatic biology, hydrology/soils, and heritage resources prior to any treatments. The use of the implementation checklist would ensure that an interdisciplinary review is conducted regarding the management and restoration of each 22

opening subject to ground disturbance, and would ensure that potential environmental impacts are within the scope of the impacts predicted in the NEPA document. Site specific impacts evaluated would include, but are not limited to:  Potential impacts to threatened, endangered, and sensitive species  Potential impacts to rare and unique communities  Potential impacts to forage and other wildlife investments  Potential impacts to water quality and aquatic species  Potential impacts to sites of historical or cultural significance

2. Based on soil characteristics and management experience, the following soils were identified as soils of concern with respect to erosion potential related to ground disturbing activities:  Ranger  Citico  Sylco  Brasstown  Cataska  Junaluska  When avoidance is not an option, all disturbed surfaces on soils of concern with a slope greater than 15% shall be mulched as well as seeded.  Root raking and/or strip disking are not to be prescribed on sustained slopes greater than 35% or on slopes greater than 20% with soils of concern (as identified in the existing condition section, above). Mowing may occur on any slope where the equipment can be operated safely.

3. Mechanical treatments shall not be prescribed for openings or portions of openings that fall within the streamside management zone.

Comparison of Alternatives ______Table 3 compares major categories of elements and effects. Further discussion follows in the Environmental Consequences chapter.

Table 3. Comparison of the Range of Alternatives.

Alternative C

All Activities Allowed in Alternative A Alternative B FS Openings-Mechanical Treatment Only in Utility Element (No Action) (Proposed Action) Corridors) All Forested Openings and Prescribed burning Prescribed burning Communities corridors would be activities and herbicide activities and herbicide mechanically may have short-term may have short-term maintained. No direct effects; tree direct effects; tree additional effects to mortality adjacent to mortality adjacent to communities would treated areas would be treated areas would be occur. negligible; no change in negligible; no change in forest community type; forest community type; no no creation of early creation of early successional forest successional forest Invasive Mechanical Authorized treatments of Authorized treatments of species activities would invasive plants within invasive plants within continue on all managed openings; managed openings; existing opening potential introduction potential introduction and including activities and spread of new spread of new species authorized through species would be would be mitigated other decisions; no mitigated through the through the use of effects to wild boar. use of equipment equipment washing; no No additional effects washing; no effects to effects to wild boar are to noxious weeds wild boar are expected. expected. Wildlife Generally habitat The addition of Better structure and habitat would be maintained structural and biological diversity of habitats could in openings for diversity is the form of be expected in forest grassy species. No shrub/sapling vegetation openings. However, no increased habitat in and grassy areas would effect in utility corridors. utility corridors. provide soft mast, insects, forage, and escape cover; negative effects would be temporary increase in disturbance of movement patterns.

Table 3. Comparison of the Range of Alternatives.

Alternative C

All Activities Allowed in Alternative A Alternative B FS Openings-Mechanical Treatment Only in Utility Element (No Action) (Proposed Action) Corridors) Recreational There would be Increased use of forest Increased use of forest opportunities continued use of openings and utility openings for hunting, forest openings for corridors for hunting, picnicking and berry hunting, picnicking picnicking and berry picking. Scenic overlooks and berry picking. picking. Scenic would continue to be No effect in utility overlooks would utilized. No effect in corridors. Scenic continue to be utilized. utility corridors. overlooks would continue to be utilized. Aquatics No direct effects. No direct effects. No direct effects.

Visuals/ Utility corridors: Herbicide use would Same as for Alternative B Scenery most visual impacts temporarily decrease for scenic overlooks and caused by scenic integrity of forest openings. Same as maintenance would affected areas to various Alternative A for utility be noticeable for one degrees based on the corridors. or two growing season and scale of seasons after treatments; Actions in clearing vegetation. scenic vistas would be Consistent with consistent with achieving SIOs achieving HIGH SIOs LOW to VERY and the objectives for HIGH; the negative management visual effects created prescription 7A Scenic by mechanical Byway Corridors. In exposure would forest spot openings, the remain on the use of herbicides would landscape for more be consistent with than one or two achieving the SIOs growing seasons. ranging from LOW to Effects would HIGH. In linear continue to be openings, actions would inconsistent with be consistent with achieving assigned achieving assigned SIOs SIOs ranging from ranging from LOW to

Table 3. Comparison of the Range of Alternatives.

Alternative C

All Activities Allowed in Alternative A Alternative B FS Openings-Mechanical Treatment Only in Utility Element (No Action) (Proposed Action) Corridors) MODERATE to VERY HIGH and in VRY HIGH; utility corridors, the effects use of herbicide would be consistent with achieving SIOs ranging from LOW to VERY HIGH; the preferred timing for herbicide applications would be August and September if practicable. Hydrology no change from Manual cutting is Effects would be existing soil or water unlikely to have any consistent with those quality conditions, effect on soil and water discussed in Alternative including changes to resources. Manual weed B, with the exception of sediment delivery pulling will have herbicide which would potential or changes minimal effects due to have reduced effects due to water quality from the annual maximum to the smaller acreage herbicide. spatial extent treated. treated under Alternative There could be some C. If Alternative C is localized erosion but implemented, then there design criteria would should be no measurable offset the potential for direct effects to soil and measurable soil and water quality. water quality effects. Planting via broadcast seeding or no-till drills would have a beneficial effect soil microbial diversity. Five treatments have the potential to affect soil and water quality: mowing, mechanical, herbicide, prescribed fire, and road maintenance.

Table 3. Comparison of the Range of Alternatives.

Alternative C

All Activities Allowed in Alternative A Alternative B FS Openings-Mechanical Treatment Only in Utility Element (No Action) (Proposed Action) Corridors) Soils No change from Manual cutting Treatments with no effect existing soil or water treatments will have no on soils are listed in quality conditions, effect on soil and water Alternative B. Treatments including changes to quality. Treatments with minimal potential sediment delivery involving manual weed effects on soils are listed potential or changes pulling and planting will in Alternative B; Five to water quality from have minimal potential treatments that have herbicide effects on soils. Five potential affect to soil and treatments have the water quality: mowing, potential to affect soil mechanical, prescribed and water quality: fire, herbicide, and road mowing equipment, maintenance; the mechanical, herbicide, exception is herbicides prescribed fire, and road would have reduced maintenance. The effects due to smaller effects to soil and water acreage. quality should be adequately controlled through project design. Cultural No direct or indirect All sites proposed for All sites proposed for Resources effects on cultural treatment involve treatment involve ground resources ground disturbance disturbance would be would be evaluated by evaluated by the Forest the Forest Archeologist Archeologist prior to prior to treatment; no treatment; no affect to affect to cultural cultural resources as long resources as long as as site(s) that have site(s) that have potential eligibility for potential eligibility for inclusion in the National inclusion in the National Register of Historic Places Register of Historic (NRHP) are avoided Places (NRHP) are during project avoided during project implementation implementation.

Table 3. Comparison of the Range of Alternatives.

Alternative C

All Activities Allowed in Alternative A Alternative B FS Openings-Mechanical Treatment Only in Utility Element (No Action) (Proposed Action) Corridors) Climate Vegetation: Effects Vegetation: Effects of Vegetation: Effects of Change of proposed project proposed project proposed project activities activities are not the activities are not the sole are not the sole sole contributing contributing factor for contributing factor for factor for climate climate change. Project climate change; project change. Project activities are minute in activities are minute in activities are minute scale compared to scale compared to in scale compared to regional, continental or regional, continental or regional, continental global contributions; the global contributions; the or global alternative would alter alternative would alter the contributions; the the carbon cycle in that carbon cycle in that it alternative would it affects the carbon affects the carbon stock in alter the carbon stock in any one of the any one of the pools. cycle in that it pools. Fire: The ecological role affects the carbon Fire: The ecological of the fire is variable from stock in any one of role of the fire is location to location and the pools. variable from location to region to region. The location and region to task/goal is to balance region. The task/goal is carbon storage and loss to balance carbon while maintaining storage and loss while ecosystem diversity and maintaining ecosystem resilience diversity and resilience Wildlife: Habitat changes Wildlife: Habitat in response to associated changes in response to warming and cooling associated warming and periods could force cooling periods could distribution of many force distribution of terrestrial species to shift many terrestrial species in latitude or elevation. to shift in latitude or elevation. Human No effects to human No adverse effects are Involves less herbicides Health & health anticipated than Alternative B. No Safety adverse effects are anticipated.

AFFECTED AREA AND ENVIRONMENTAL CONSEQUENCES

This section summarizes the biological, social, physical and economic environments of the affected analysis area and the potential changes to those environments due to implementation of the alternatives. It also presents the scientific and analytical basis for comparison of alternatives presented in the chart above. Biological Factors Existing Condition

This section discloses effects to biological elements of the environment expected as a result of implementing the proposed action or alternatives. The biological environment includes the diversity of plant and animal communities, habitat components, and individual species of concern or interest. Analysis of effects to these elements is organized in this document following the framework used during Forest Plan revision (USDA 2004b). Use of this framework is designed to ensure comprehensive consideration of effects to the biological environment. Elements in this framework are listed in Table 4, where they are assessed for their relevance to this project. Only those relevant to the project are analyzed further in this document. Because the existing openings (especially long, linear features such as utility corridors) intersect nearly every major habitat type on the Cherokee National Forest, numerous communities are analyzed based upon simple proximity. Due to the small possibility of herbicide impacts to individual plants along the edges of the existing openings, a general effects analysis of All Forested Communities is included here. For the “All Forested Communities” section, the project area is the openings plus 25 feet along the edges. For all other Biological Factors, including Management Indicator Species, the project area is comprised of the openings themselves. This is because only previously managed existing openings are being considered (i.e. no new openings are being created within intact forest communities), and even within those existing openings, proposed chemical maintenance is focused primarily on smaller woody or non-native plant species. Any communities that may occur in an intact, natural habitat nearby would not be affected. Scope of Analysis

The Cherokee National Forest currently encompasses approximately 656,000 acres. The area varies widely in topography, from sloping hills and flatter areas around the streams to steeper slopes on ridges in the area. Elevations are from approximately 700 feet to 6,200 feet above sea level. This project proposes alternative methods to maintain existing openings on the forest. Openings considered include corridors for electrical utility lines comprising approximately 1,576 acres, linear wildlife openings comprising approximately 859 acres, spot wildlife openings (including managed openings such as mountain balds) comprising approximately 2,205 acres, and scenic overlooks comprising approximately 14 acres. These existing openings total approximately 4,654 acres, which is less than one percent of the total 656,000 acres of the Cherokee National Forest. Unless otherwise described in the sections below, analysis of direct and indirect effects

29 for terrestrial elements is primarily focused within the boundaries of the individual treatment areas. No site surveys were conducted specifically for this project. All the potentially affected sites have been previously managed as open areas (many for decades), thus species occurring within those sites are typically those adapted to open conditions and the associated disturbance that creates and maintains them. Existing data on locations of rare or uncommon species was overlaid with maps of all of the existing openings to see what known sites for species may be coincident or proximal to the openings included in the proposed action. The timeframe for short-term effects is within the first year after treatment, and long-term effects up to 10-15 years from treatment. Analysis of cumulative effects also includes past, present and reasonably foreseeable activities on the forest, and thus may extend beyond the limits of the defined project area to include the range of a species or habitat type. Time frames for cumulative effects analysis for terrestrial elements generally include 10 years prior to 10-15 years post treatment. A list of past, present and reasonably foreseeable activities to be considered is included here. Cumulative Effects

Cumulative effects analysis is based on the following activities in addition to the proposed action.

 Vegetation Management: 500-1500 acres/yr. Based upon past and current trends, it is estimated that we will conduct vegetation management projects on the range of acres shown above each year. Types of projects include, but are not limited to, various forms of timber harvest as well as noxious weed treatments and other forms of management.  Trails: 2-10 miles/yr. This includes new construction, re-habilitation work, and re- alignments.  Prescribed Burning: 5,000-25,000 acres/yr.  Road construction/temp roads: 5-10 miles/yr. This is the estimated total annual mileage that is OUTSIDE of proposed utility and opening access.  Special uses/recreation- roads/utility lines/vegetation manipulation: 10-40 acres/yr. This is the current estimated total annual acreage that is OUTSIDE of proposed opening vegetation manipulation.  Land acquisition: maximum 5,000 acres/yr.  Hemlock wooly adelgid (HWA) outbreak  Emerald ash borer outbreak

Elements of the Biological Environment

Table 4. Elements of the biological environment, derived from the RLRMP analysis, and their relevance to the openings analysis area. Discussed Biological Element Relevance to this Project Further?

Mesic Deciduous Forest Yes Openings intersect this type of habitat Spruce-fir Forest Yes Openings intersect this type of habitat Eastern Hemlock and White Pine Forest Yes Openings intersect this type of habitat Oak and Oak-pine Forest Yes Openings intersect this type of habitat Pine and Pine-oak Forest Yes Openings intersect this type of habitat Woodlands, Savannas, and Grasslands Yes This type of habitat occurs in the analysis area. Rare Communities Wetland Communities Yes Wetland communities are mapped as openings. There are likely some additional small wetlands associated with the many small streams in the project area. Barrens, Glades, and Associated Woodlands No There are no known acres of this forest type in the area. Carolina Hemlock Forests No There are no known acres of this forest type in the area. Table Mountain Pine Forests No There are no known acres of this forest type in the area. Basic Mesic Forests No There are no known acres of this forest type in the area. Beech Gap Forests No There are no known acres of this forest type in the area. Rock Outcrops and Cliffs (includes forested No None of this type of habitat occurs in boulderfields) the vicinity of the affected areas. High Elevation Balds and Meadows Yes Management in this type of habitat is proposed. Caves and Mines No None of this type of habitat would be affected by any of the alternatives Successional Habitats Yes Openings are a type of successional habitat High Elevation Early Successional Habitats Yes Openings are a type of successional habitat Permanent openings and old fields, Rights- Yes The project proposes to maintain this of way, Improved pastures type of habitat Forest Interior Birds No The alternatives would not affect any forest edge quantities Old Growth Yes Not an issue Riparian Habitats Yes Openings intersect this type of habitat Snags, Dens, and Downed Wood No Not an issue. Forest Plan standards apply.

Table 4. Elements of the biological environment, derived from the RLRMP analysis, and their relevance to the openings analysis area. Discussed Biological Element Relevance to this Project Further?

Aquatic Habitats Yes Aquatic habitats occur in the proposed affected areas. Threatened and Endangered Species Yes Potential effects to T and E species are analyzed. Demand Species Yes Demand species could be impacted by the project. Migratory Birds Yes Migratory bird issues are included in individual Major Forested Communities sections Invasive Non-native Plants and Animals Yes Invasive non-natives are located in the areas Species Viability Yes Species with viability concerns occur in the areas. Forest Health No Forest health is not an issue in the proposed affected areas.

The RLRMP selected management indicator species (MIS) as a tool to help indicate effects of management on some elements of this framework. A subset of these MIS is selected for consideration in this project because their populations or habitats may be affected by the project (Table 5).

Table 5. Forest-level Management Indicator Species Selected Reasons for Selection/Non- Species Name Purpose for Project Selection Analysis? Prairie warbler To help indicate management Yes The proposed activities would effects of creating and maintain early successional maintaining early communities. successional forest communities Chestnut-sided warbler To help indicate management Yes The proposed activities would effects of creating and maintain early successional maintaining high elevation communities. early successional forest communities and habitat Pine warbler To help indicate effects of Yes Openings intersect this type of habitat management in pine and pine-oak communities Pileated woodpecker To help indicate management No No habitat affected. effects on snag dependent wildlife species Acadian flycatcher To help indicate management No No habitat affected. effects within mature riparian forest community

Table 5. Forest-level Management Indicator Species Selected Reasons for Selection/Non- Species Name Purpose for Project Selection Analysis? Scarlet tanager To help indicate effects of Yes Openings intersect this type of habitat management in xeric oak and oak pine communities

Ruth’s golden aster To help indicate management No No populations of this species or their effects on the recovery of this habitat occur in or near the vicinity of T&E plant species the project. Ovenbird To help indicate management No Edge is not created in any alternative effects of wildlife species dependent upon mature forest interior conditions Black bear To help indicate management Yes Hunting demand for black bear could effects on meeting hunting be impacted by the alternatives. demand for this species Hooded warbler To help indicate effects of No No habitat affected. management on providing dense understory and midstory structure within mature mesic deciduous forest communities

In addition to the above MIS, the Forest Service is mandated to minimize impacts to neotropical migratory birds. Those birds are represented by Partner’s in Flight priority species for the Southern Blue Ridge (Physiographic Province 23), which encompasses all Cherokee National Forest lands. Various neotropical migratory bird species, representing several habitat types, were addressed and included in Table 5 as associated species in the Forest Plan. These species were specifically selected to represent habitats that include a wide variety of communities across the Forest, including grassland/early succession, deciduous mixed forest, pine forest, and riparian areas. This analysis will consider the effects, including cumulative effects, for each alternative on these MIS, and thus associated neotropical migratory birds that may use the Cherokee National Forest. The following sections describe the affected environment and effects by alternative for each biological element listed above in Table 4. Existing Condition on all Forested Communities

The RLRMP categorizes forest types from the Field Sampling Vegetation (FSVEG) database into forested community types (USDA 2004a). Nine forested community types have been identified on the Cherokee National Forest CNF (Table 6). The area proposed for treatment (existing Forest Service openings and utility corridors) are considered non forest land and are not included in acreage for the listed community types.

Table 6. Forest community types, as defined in the 2004 RLRMP, found on the Cherokee National Forest, Tennessee. Forest Community Type1 Forest Type(s) (FSVEG Code2) Acres on CNF (in 2004) Sugar maple-Beech-Yellow birch (81),Black birch Northern Hardwood Forest 18,516 (83) Fraser fir (6), Red spruce-Fraser fir (7), Red spruce- 647 Montane Spruce-Fir Forest Northern hardwood (17) Cove hardwood-White pine-Hemlock (41), Yellow Mixed Mesophytic-Hardwood Forest poplar (50), Yellow poplar-White oak-Red oak (56), 138,858 Black Locust (88) White pine (3), White pine-Hemlock (4), Hemlock Conifer-Northern Hardwood Forest (5), Hemlock-Hardwood (8), White pine-Cove 52,072 hardwood (9), White pine-Upland hardwoods (10). Post oak-Black oak (51), White oak-Red oak- Dry to Mesic Oak Forest Hickory (53), White oak (54), Northern red oak- 125,189 Hickory (55). Upland hardwoods-White pine (42), Southern red oak-Yellow pine (44), Chestnut oak-Scarlet oak- Dry and Dry-Mesic Oak-Pine Forest Yellow pine (45), Bottomland hardwoods-Yellow 56,465 pine (46), White oak-Black oak-Yellow pine (47), Northern red oak-Hickory-Yellow pine (48). Chestnut oak (52), Scarlet oak (59), Chestnut oak- Dry and Xeric Oak Forest 69,984 Scarlet oak (60). Shortleaf pine-oaks (12), Loblolly pine/hardwood (13), Pitch pine-oaks (15), Virginia pine-oaks (16), Xeric Pine and Pine-Oak Forest Table-mountain pine-Hardwoods (20), Shortleaf pine 140,872 (32), Loblolly pine (31), Virginia pine (33), Spruce pine (37), Pitch pine (38), Table-mountain pine (39). Sweetgum-Yellow poplar (58), River birch- Eastern Riverfront and River Floodplain Sycamore (72), Sweetgum-nuttall oak-willow oak 1,086 Hardwood Forests (62), Black Walnut (82)  1 = Forest community types as defined in the 2004 RLRMP, CNF (USDA Forest Service 2004a).  2 = Field sampled Vegetation (FSVEG) database forest stand type codes.

Prairie Warbler (MIS) Prairie warblers (Dendroica discolor) are shrub land-nesting birds found in suitable habitats throughout the southern Appalachians (Hamel 1992). Prairie warblers require dense forest regeneration or open shrubby conditions in a forested setting. Near optimal habitat conditions are characterized by regeneration, thinned areas or patchy openings ten acres or more in size where woody plants average two to three meters in height, three to four centimeter in diameter, and occur in stem densities around 3,000 stems/acre (USDA 2004b). Populations respond favorably to conditions created three to ten years following forest regeneration in larger forest patches. Providing a sustained flow of regenerating forests is necessary to support populations of prairie warbler. Populations of prairie warbler have been steadily declining in the eastern U.S. (Trend - 2.08, P value 0.0000; Sauer et al. 2005).

Chestnut-sided warbler (MIS) The chestnut-sided warbler is strongly associated with high-elevation early-successional habitats. This warbler is a disturbance-dependent specialist found in early-successional habitats, and its

34 populations are in decline (Trend –0.69, P value 0.05258, Sauer 2001). Chestnut-sided warblers are closely associated with stand replacement burns, extensive blowdowns, riparian early- successional habitat created by flooding or beaver activity (Richardson 1995, Askins 2000), and may reach their highest densities in clearcuts (Freedman 1981). At high elevations, deciduous shrubs or laurel brush along streams or field borders, deciduous second growth, alder thickets, and large forest clearings (Richardson 1995) provide suitable nesting and foraging habitat for this species. In portions of the Appalachians chestnut-sided warblers were found in thickets of young chestnut trees which die prior to reaching maturity (Richardson 1995). Near optimal habitat conditions are characterized by regeneration or shrub dominated deciduous conditions typically containing blackberry, or Rubus spp. (Richardson 1995), with woody plants between one and ten meters in height. Populations of chestnut-sided warblers have been observed to decline with a decrease in Rubus spp. (Pfeifer Nature Center 2002).

Pine Warbler (MIS) The pine warbler (Dendroica pinus) is a short-distance migrant and summer resident that occurs primarily at elevations below 3500 feet. It is apparently more abundant on the southern ranger districts of the Cherokee National Forest. Based on 1992-1993 point count data collected on the Tellico Ranger District, this species is not a predominant component of any community type, but was detected in yellow pine forest types across all successional stages. Point count data collected for this species from 1996-2002 on the Tellico and Ocoee/Hiwassee Ranger Districts, indicates 88% of pine warbler observations were in conifer forests, 17% were in early successional vegetation, 54% were in mid successional, and 29% were in late successional. Scarlet Tanager (MIS)

The breeding range of scarlet tanager (Piranga olivacea) includes eastern North Dakota and southeastern Manitoba across southern Canada and northern U.S. to New Brunswick and central Maine, south to central Nebraska, Kansas, Oklahoma, Arkansas, northern Alabama, northern Georgia, northwestern South Carolina, western North Carolina, central Virginia, and Maryland (NatureServe 2004). North American Breeding Bird Survey data indicate a stable population in the Eastern U.S. from 1966-2005, but a declining trend in the Blue Ridge Mountains in the same time period (Sauer et al. 2005). Habitat on breeding grounds is deciduous forest and mature deciduous woodland, including deciduous and mixed swamp and floodplain forests and rich moist upland forests. The scarlet tanager prefers oak trees for nesting. They nest less frequently in mixed forest and are most common in areas with a relatively closed canopy, a dense understory with a high diversity of shrubs, and scanty ground cover. They are able to breed successfully in relatively small patches of forest. Tanagers also sometimes nests in wooded parks, orchards, and large shade trees of suburbs. They are known to breed in various forest stages but are most abundant in mature woods (according to some sources, prefers pole stands).

Direct and Indirect Effects on all Forested Communities

Alternative A (No Action) Under the No Action Alternative, routine mechanical activities on wildlife openings and overlooks for maintenance would continue as would activities authorized through other decisions. Herbicide is currently only authorized on limited areas. These activities would 35 continue. The effects to forested communities of continuing these treatments would not change. There would be no additional direct or indirect effects as a result of this alternative to the forested communities or the MIS associated with those communities. Alternatives B (Proposed Action) and C The treatments proposed in both alternatives are intended to maintain or enhance open, grassy, and brushy conditions on existing open areas. These alternatives do not create any new openings and do not reduce the amount of existing forested communities, or change the composition of existing forested communities. Prescribed burning activities and herbicide use may have some short-term direct effects by causing mortality to individual trees along or near the edge of existing openings. Minor amounts of tree mortality on the periphery of these openings can occur as the result of run-off or drift from herbicide use. Mortality of trees adjacent to treated areas would be insignificant and minor to the extent that there would only impact individual and scattered trees and not change the species composition resulting in a change in forest community type classification or create new early successional habitat. Mortality would be limited and disbursed and would result in the creation of individual scattered snags. Snags are a natural component of a healthy forest environment. Indirect effects of individual tree mortality may be an increased growth rate of adjacent unaffected trees, an increase in overall forest structure complexity, and an increase in roosting habitat for certain bats. The use of prescribed fire is designed to restore forest plant communities to a more natural species assemblage with direct long-term beneficial effects on organisms associated with native forest communities. Beneficial effects include increased forage, nesting/denning and brooding structure, travel lanes as well as escape cover for some species. Individual effects of herbicides are analyzed in detail under “Permanent openings and old fields, Rights-of way, Improved pastures” elsewhere in this document. In general, the bird MIS representing early successional habitat (prairie warbler and chestnut- sided warbler) require larger areas then what would typically be represented in the openings addressed in the EA. There are some larger openings which could benefit these birds by maintaining in native grassy/shrubby habitat resulting from the proposed action. Pine warbler and scarlet tanager would not be affected either due to the dispersed and individual nature of any tree mortality due to herbicide or ground disturbance nearby. Cumulative Effects on all Forested Communities

Alternative A (No Action) Under the No-Action alternative, routine mechanical activities on wildlife openings and overlooks would continue as would activities authorized through other decisions. Herbicide use is currently only authorized on limited areas. These activities would continue. No new project activities would be implemented under this alternative however, because the analysis area includes the entire Forest, many other routine and ongoing activities may or will occur within the project area. Cumulative effects of past, present and reasonably foreseeable future activities are or will be listed in separate, project specific environmental effects analysis documents. There would be no effect to forested communities or representative MIS.

Alternatives B and C The treatments proposed in both alternatives are intended to maintain open, grassy, and brushy conditions on existing open areas. The mechanical treatments would have no effect on neighboring forest communities and as-such not have cumulative effects on these communities or MIS. The use of herbicides in alternatives B and C may cause a small amount of dispersed tree mortality along the edges of the treated areas. The anticipated mortality associated with these alternatives is limited and insignificant in scale. Past, present or future management actions such as vegetation management via timber sales, non- commercial silvicultural treatments, and project level prescribed burning for hazardous fuels reduction are intended to alter the forest communities where they are applied. The environmental effects of these activities are or will be analyzed in project specific NEPA documents and are intended to meet the objectives of the Revised Forest Plan. Because the anticipated mortality associated with Alternative B and C is expected to be insignificant in scale and will not result in changes to the overall forest community type or condition classification, little or no cumulative effects are expected to the community or the MIS. Additionally, tree mortality from insect and disease outbreaks are a common condition on the landscape. Because the anticipated mortality resulting from off-target herbicide and/or prescribed fire effects associated with Alternatives B and C are expected to be scattered and inconsequential in scale, the cumulative effects are expected to be insignificant and may mimic these natural conditions. Existing Condition Woodlands, Savannas, and Grasslands

The areas maintained within the framework of this EA would largely fall under the category of “Permanent openings and old fields, Rights-of way, Improved pastures” considered elsewhere in this document for analysis. None would be considered woodlands and few would be considered savannas due to the lack of overstory in the openings that those communities have. Ideally, native and to a lesser extent desired non-native grassland types would result from the proposed action. In an effort to restore some of the ecological role that these communities have historically played, the Forest Plan includes objectives for restoring complexes of woodlands, savannas, and grasslands to fire-maintained landscapes. Prescribed fire on relatively short rotations (1 to 3 years) typically would be used to maintain desired conditions, and may involve both dormant and growing season fires. While fire can and does play a role in many Forest Service maintained openings, it is unlikely to become a frequent method of maintaining rights-of way or overlooks. Fire in those areas must be managed very carefully and suitable conditions are not abundant. Complexes of woodlands, savannas, and grasslands were once a frequent occurrence across portions of the southeastern landscape, primarily in the Piedmont and Coastal Plain provinces. Smaller occurrences likely occurred in the southern Appalachians on xeric ridge-tops and south- facing slopes where they were maintained by frequent fire (USDA 2004a). Savannas are usually defined as having lower tree densities than woodlands; grasslands are mostly devoid of trees. All of these conditions typically occurred in mixed mosaics within a fire-maintained landscape. In all cases, a well-developed grassy or herbaceous understory is present. One hundred thirty-seven species of viability concern are associated with this community in the southern Appalachian region. Of these, thirty-five species are of concern on the CNF. Because

37 existing woodland, savanna, and grassland complexes are rare and not consistently tracked, the current acreage in such conditions is not well documented. These communities would likely have occurred on landforms currently occupied by xeric pine and oak communities. Direct and Indirect Effects Woodlands, Savannas, and Grasslands

Alternative A (No Action) There would be no treatment to maintain this community beyond the current mechanical methods. While mechanical treatments help these areas by at least keeping the overstory trees from interfering with the utility lines or preventing an opening from being overgrown completely, little progress can be made to actually enhance these communities. Other treatments that might foster an ecological role the communities have historically played are costly and inefficient and therefore do not occur often. Many openings currently are in non-native cool season grasses which while marginally beneficial as forage or travel lanes, do not afford the structure needed for nesting for a variety of birds or for forage and egg laying for pollinators. There would be no effect with this alternative. Alternative B (Proposed Action) and C Maintenance activities including mechanical, herbicides and burning would provide habitat for species associated with these community types, including several species of viability concern. Fire adapted species are expected to increase over time within these areas. Activities, including prescribed burning, may cause some short-term negative effects to individual species, by causing disturbance, mortality, or temporarily setting back plant and animal reproduction or growth. The use of prescribed fire is designed to restore these plant communities to a more natural species assemblage, and the goal is to have a long-term beneficial effect on organisms associated with savannas and grasslands. Species associated with this community are relatively adapted to such disturbances, which are necessary to create and maintain optimal habitat conditions. In balance, these actions would result in long-term beneficial effects to associated species including thirty-five species of concern on the CNF. These areas would be monitored periodically to determine if the results are as expected. Informal walk-through surveys would be done after treatments to assess effects. Herbicide use would reduce the number of undesirable plant species and woody encroachment leading to an increase in native plants and wildlife habitat. Nesting structure for golden-winged warbler and other species dependent on this type of habitat would increase. An increase in cover and forage is also expected with the increase of soft mast including blackberry and blueberry. Pollinator habitat would also increase with the reduction of non-native plants and woody encroachment shading out vegetation preferred by those species. In some cases, native plants may be planted, further increasing the habitat available. An indirect effect may be an increase in predators of wildlife and insects preferring this type of grassy, shrubby habitat. Individual effects of herbicides are analyzed in detail under “Permanent openings and old fields, Rights-of way, Improved pastures” elsewhere in this document.

Cumulative Effects Woodlands, Savannas, and Grasslands

Alternative A (No Action) Past maintenance benefited this community by keeping the canopy open and increasing the grassy component. Grassland species have benefited by the open areas, however, the woody encroachment has limited available habitat and decreased the potential for these species to thrive. The death of hemlock from hemlock woolly adelgid has opened up some areas and potentially created openings, however these are not being maintained and thus don’t have long term effects. The other past, present and future activities have and would have little effect as they have not occurred near the openings. Historically present on xeric sites due to presence of fire, these habitats are much reduced today. Restoration within openings to natural species assemblages and management activities on National Forests would play a critical role in the conservation of this community within the landscapes containing National Forest land. Natural savanna and grassland habitats are currently rare, occurring on private ownerships primarily along mowed roadside and powerline rights-of- ways. It is not expected that private landowners will restore or manage to maintain significant amounts of savanna and grassland complexes; therefore, they would remain limited in acreage without National Forest restoration efforts. Alternative B (Proposed Action) and C Past maintenance benefited this community by keeping the canopy open and increasing the grassy component. Grassland species have benefited by the open areas, however, the woody encroachment has limited available habitat and decreased the potential for these species to thrive. The death of hemlock from hemlock woolly adelgid has created openings in the canopy, however these are not being maintained and are closing in. There are no long term effects. The other past, present and future activities have and would have little effect as they have not occurred near the openings. Historically present on xeric sites due to presence of fire, these habitats are much reduced today. Restoration within openings to natural species assemblages and management activities on National Forests would play a critical role in the conservation of this community within the landscapes containing National Forest land. Natural savanna and grassland habitats are currently rare, occurring on private ownerships primarily along mowed roadside and powerline rights-of- ways. It is not expected that private landowners will restore or manage to maintain significant amounts of savanna and grassland complexes; therefore, they would remain limited in acreage without National Forest restoration efforts. Existing Condition High Elevation Balds and Meadows

Two types of high elevation balds are found in the southern Appalachians; grassy balds and shrub (or heath) balds. Grassy balds are characterized by extensive areas dominated by herbaceous vegetation at high elevations (generally above 5,000 feet). They generally are found on ridgetops, domes, and gentle slopes. Shrub balds are typically found on steep exposed slopes and ridges at elevations ranging from 2,000 to 6,500 feet, and are characterized by dominance of ericaceous shrubs. Grassy balds in the southern Appalachians are characterized by extensive areas dominated by herbaceous vegetation at high elevations (generally above 5,000 feet). Conditions typically occurring on high elevation balds include strong wind, high rainfall,

39 frequent fog and extremes of temperature and moisture. Species composition varies regarding topographic features, moisture, exposure, types of disturbances and land use history. The known distribution of grassy and heath bald communities is described in the Southern Appalachian Assessment (SAA) Terrestrial Technical Report (SAMAB 1996:188-190). This report indicates that approximately two-thirds of the occurrences of grassy balds and nearly one half of the occurrences of heath balds in the southern Appalachian area are located on NFS lands. Distribution of this habitat type likely increased during European settlement, but has been slowly declining in recent years. High elevation early successional habitat is important to many species and has been declining as these open areas close with succession. Twenty-nine balds and high elevation meadows of various origins are known to occur on the CNF. Primary management needs for natural balds, and some of human origin, are protection from recreational impacts and maintenance of open condition with desired vegetation. Sixty-five species of viability concern are associated with southern Appalachian grassy and shrub bald communities (USDA 2004b). Of these, 29 species are of concern on the CNF. Certain types of high elevation balds and meadows are designated as rare communities in the RLRMP and are afforded protection under MP 9.F. Direct and Indirect Effects High Elevation Balds and Meadows

Alternative A (No Action) There would be no treatment to maintain this community beyond the current mechanical methods. While mechanical treatments help these areas by preventing a bald from being overgrown completely, little progress can be made to actually enhance these communities. Other treatments that might foster an ecological role the communities have historically played are costly and inefficient and therefore do not occur often. Many balds and meadows currently are in non-native cool season grasses or other herbs which while marginally beneficial as forage and travel lanes, do not afford the structure needed for nesting for a variety of birds or for forage and egg laying for pollinators. Alternative B (Proposed Action) and Alternative C The proposed wildlife habitat improvement activities would occur within the openings themselves. Rare community complexes are often a mosaic of different community types. Prescription 9.F states that “rare communities, wherever they occur on the forest, are managed under this prescription to ensure their contribution to meeting goals for community diversity, endangered and threatened species recovery, and providing habitat for sensitive and locally rare species.” These activities will maintain and enhance the open grassy community and move it closer to the desired natural species assemblage appropriate for that site and consistent with a grassy bald rare community. The maintenance/enhancement would benefit several species at risk including golden-winged warbler, American woodcock, woodland jumping mouse, Appalachian cottontail, and meadow jumping mouse. It would provide nesting and foraging habitat consisting of interspersed grassy, shrubby and herbaceous cover.

Cumulative Effects High Elevation Balds and Meadows

All Alternatives Most high elevation habitat (> 4,000’ elevation) in the southern Appalachian region occurs on public lands placing the responsibility of restoration and maintenance of balds on public land managers. Similar restoration efforts for balds are occurring throughout the southern Appalachian region which should result in a long-term improvement of this habitat type in the future. The CNF RLRMP recognizes the value of rare communities on the landscape and provides for their protection. These lands serve as core areas for conservation of the most significant elements of biological diversity on the forest. Because the CNF places priority on protection and maintenance of rare communities regardless of alternative, cumulative effects on NFS lands are expected to be positive. The restoration and enhancement of the bald communities would greatly benefit this community and associated species on a landscape scale. Without management (i.e., lack of fire and herbicide, encroachment of woody species) the loss of grassy habitats at high elevations is likely to continue across the Southern Appalachians. In light of these cumulative effects, efforts to maintain quality high-elevation grassy habitats on NFS lands is critical to sustaining associated species. The addition of utility lines maintained to provide this grassy, herbaceous and shrubby component in Alternative B would enhance the diversity across the Forest by utilizing linear corridors in an otherwise forested environment. Existing Condition Permanent openings and old fields, Rights-of-way, Improved pastures

Habitats considered here include permanent openings and old fields, utility ROWs, and improved pastures. This section also analyzes effects from maintaining 14 acres of scenic overlooks. Permanent Openings and Old Fields Permanent grass/forb and seedling/sapling/shrub habitats are important elements of early successional habitat. Permanent openings typically are maintained for wildlife habitat on an annual or semi-annual basis with the use of cultivation, mowing, or other vegetation management treatments. These openings may contain native grasses and forbs, but many are planted to non-native agricultural species such as clover, winter wheat, annual rye, or other small grains. Old fields are sites that are no longer maintained and or succeeding to forest or are maintained on a less frequent basis (5-10 year intervals, usually with burning and mowing). They are largely influenced by past cultural activities and may be dense sod or a rapidly changing field of annual and perennial herbs, grasses, woody shrubs and tree seedlings. Permanent openings are used by a variety of wildlife, both game and non-game species. The benefits of permanent openings to white-tailed deer are well documented. Permanent openings, especially those containing grass-clover mixtures, are used most intensively in early spring, but also are an important source of nutritious forage in winter, especially when acorns are in short supply. Forest openings also are a key habitat component for wild turkeys throughout the year. Maintained openings provide nutritious green forage in the winter and early spring and seeds during late summer and fall. Because of the abundance of insects and herbaceous plants produced in these openings they are especially important as brood rearing habitat for young

41 turkeys. Linear openings, especially those associated with young regenerating forests; provide optimal brood habitat conditions for ruffed grouse among other species. There also are numerous wildlife benefits from openings maintained in native species. Native warm season grasses provide nesting, brood-rearing, and roosting habitat for northern bobwhite and other grassland species of wildlife. Native species are well adapted to local environments and generally require less intensive maintenance following establishment. Old fields provide food and cover for a variety of wildlife species. A number of disturbance- dependent birds, such as northern bobwhite, grasshopper sparrow, golden-winged warbler, and blue-winged warbler are associated with old field habitat. Recently abandoned fields are important for rabbits and many small mammals. Woodcock use old fields as courtship, feeding, and roosting sites. Although managed less intensively than other types of permanent openings, some degree of periodic management is necessary to maintain these habitats. There are approximately 859 acres of linear wildlife openings and 2,205 acres of spot wildlife openings (including managed openings such as mountain balds) on the Forest. These existing openings comprise a total of approximately 3,064 acres, which is about half of one percent of the total 656,000 acres of the Cherokee National Forest. Many of the wildlife openings were created by the expansion of log landings following timber harvest or by closing and seeding old roads to create linear openings. They are maintained with funding provided by the Tennessee Wildlife Resources Agency (TWRA), the Forest Service, and partners including the National Wild Turkey Federation (NWTF). Many are planted in non-native grass-clover mixtures, which include combinations of white or red clovers along with wheat, rye, oats, and ryegrass. Some of the older openings are dominated by fescue and/or annual weed species. Old fields acreage is currently unknown. Rights-of-Way and Improved Pastures Although pastureland acreage has declined over the last 50 years, pastures still comprise approximately seven percent of the southeastern U.S. For the SAA Area, pastures comprise approximately 17 percent of the area, 99 percent of which is on private land. There are no comparable estimates for ROWs. Utility ROWs and improved pastures typically are managed for purposes other than to provide wildlife habitat. However, they can provide wildlife benefits if managed appropriately. Rights- of-way can be established and maintained in plantings that enhance their benefits to wildlife. Once established, maintenance costs generally are reduced. There are approximately 1,576 acres of rights-of-way corridors for electrical utility lines on the CNF. The majority of these ROWs supports a mixture of herbaceous plants and shrubs and are maintained by a variety of mechanical methods. The utility companies and cooperatives must manage the vegetation on rights-of-way and easements to ensure emergency maintenance access and routine access to structures, switches, conductors, and communications equipment. In addition, they must maintain adequate clearance, as specified by the National Electrical Safety Code, between conductors and tall growing vegetation and other objects. This requirement applies to vegetation within the right-of- way as well as to trees located off the right-of-way.

Scenic Overlooks There are 14 acres of existing scenic overlooks located along the Ocoee Scenic Byway and Cherohala Skyway. These viewpoints are typically less than an acre in size (200x200 feet). Some are cleared more frequently than others ranging from once a year to once every 5 years. They are currently maintained in their open condition through the use of mechanical means. Direct and Indirect Effects Permanent Openings and Old Fields, Rights-of-Way, Improved Pastures

Alternative A (No Action) Openings would continue to be maintained by mechanical means under this alternative. There would be no change in management. Rights–of-way would continue to be mowed or otherwise cleared mechanically when vegetation reaches a certain height or obstructs the desired views. Non-native invasive plants could be treated chemically on Forest Service maintained openings only due to a previous EA. There is no provision for treating non-native invasive plants on utility corridors. Those would continue to proliferate. Specific to neotropical migratory birds, non-native invasive plants can significantly reduce areas of suitable open grassland by replacing native plants. This reduces nesting and roosting cover. It also reduces food sources for various terrestrial insects, including pollinators which in turn reduces prey for bats and other insectivores. During the past 45 years, the golden- winged warbler has experienced one of the steepest declines of any North American songbird. The decline in the Appalachian Mountains is especially alarming—a 97.8% population loss from 1966 to 2010 and a 61.7% loss over the last decade (NC -10%, NJ -9%, WV -9%, TN and VA -8%, PA -7%, MD -6%, NY -5% per year) according to the Breeding Bird Survey (2015). The Appalachian population is now largely disjunct from the Great Lakes population. Much of the decline is attributed to habitat loss and land use change, while hybridization with blue-winged warbler has exacerbated the declines and added complexity to the development of effective conservation strategies (Petzinger 2014). This alternative would not deter this decline. While mechanical treatments might foster good shrubby habitat right after treatment, most areas would grow out of optimal habitat quickly in between treatments. Alternative B (Proposed Action) and C Utility ROWs consist of long, linear corridors that are often managed in a way that can provide habitat for golden-winged warbler and other shrubland birds (Petzinger et al 2014). Many landscapes within the range of the species are traversed by extensive networks of electric transmission lines and gas pipelines, which are expanding in response to increased gas extraction in the northeastern United States. In some states, such as New Jersey, more than half of the breeding golden-winged warblers occur on ROWs. Only a small proportion of these utility ROWs are managed for golden-winged warbler; therefore, substantial opportunities exist to benefit this species while still meeting the vegetation management goals of utility companies and working within acceptable budgets. The openings provide an important source of nutritious forage in winter, especially when acorns are in short supply. Forest openings also are a key habitat component for wild turkeys throughout the year. Maintained openings provide nutritious green forage in the winter and early

43 spring and seeds during late summer and fall. Because of the abundance of insects and herbaceous plants produced in these openings they are especially important as brood rearing habitat for young turkeys. Linear openings, especially those associated with young regenerating forests provide optimal brood habitat conditions for ruffed grouse. The maintenance of the openings through mechanical means, herbicide and fire would benefit these species of wildlife, both game and non-game species. Along their migration routes and on their summer ranges, monarch butterflies require two suites of plants: (1) host plants for monarch caterpillars, which are primarily milkweeds (Asclepias spp.) within the family Apocynaceae upon which adult monarchs lay eggs; and (2) nectar- producing flowering plants of many other species that provide food for adult butterflies. Having both host and nectar plants available from early spring to late fall and along migration corridors is critical to the survival of migrating pollinators (USDA 2015). Through better management of these openings, better habitat will exist for monarchs and other pollinators. The conversion of fescue pastures and other non-desirable vegetation to native plants improves habitat conditions for northern bobwhite and numerous grassland species. Featured sites are primarily old farms that were in cultivation when acquired by the Forest Service. Native warm season grass plantings have been established at Doc Rogers fields, several tracts along the French Broad River, along a powerline ROW on the Ocoee Ranger District permitted to Tennessee Valley Authority and a powerline ROW on the Tellico Ranger District under permit to Fort Loudoun Electric Cooperative. Emphasized species include bluestems, Indian grass, switchgrass and native legumes. An experimental native cool season grass planting (Virginia wild rye) has been established along the Nolichucky River. These plantings total approximately 215 acres and were established with funds provided by the Forest Service, TWRA, TVA and several sportsmen’s organizations including Quail Unlimited. Removal of trees encroaching on openings would provide a transitional zone between the opening and mature forest and provide vertical habitat structure for nesting, cover, and browse for species that do not benefit from mature forest conditions or grassy openings. Wider edges around openings would also decrease the potential for nest predation. Reducing canopy cover along linear openings would allow for more sunlight to reach areas seeded for wildlife forage and also aid road maintenance. Herbicide application on undesirable woody species and non- native plants would also improve wildlife opening conditions by reducing encroachment upon more desirable native plants. Allowing the use of herbicide in rights-of-way would increase the ability of those areas to play an enhanced role in benefiting wildlife. The conversion of the utility easements into native grasses and forbs would provide bugging, rearing and other food sources for many native wildlife. In addition, the Forest would also benefit by the potential use of these areas as fire breaks. TVA and the Electric Cooperatives would benefit by a reduction in costs associated with maintaining an area free of woody stems that create obstruction to the electrical lines. Many of the cooperatives are non-profits operated for the mutual benefit of its members. The primary purpose of the cooperatives is to furnish its members with electric service at the lowest rates. Therefore, a reduction in costs associated with maintaining electrical lines would also benefit people in communities within and around the CNF. Current manual methods such as repeatedly chainsawing woody vegetation, cultivation, digging, or scalping with mechanized equipment are sometimes ineffective and inefficient, and more ground-disturbing than herbicide use.

Mechanical mowers not only cut the tall saplings and seedlings on the right-of-way, they also shatter the stump and the supporting near surface root crown. The tendency of resistant species is to re-sprout from the root crown and shattered stumps can produce a multi-stem dense stand in the immediate area. Repeated use of mowers on short cycle re-clearing with many original stumps re-growing in the above manner can create a single species thicket or monoculture. With the original large root system and multiple stems, the resistant species can produce re-growth at the rate of 5-10 feet in a year. In years with high rainfall, the growth can reach 12-15 feet in a single year. These dense, monoculture stands can become nearly impenetrable for even large tractors. Such stands have low diversity and little wildlife food or nesting potential. Selective herbicide application may be used to control monoculture stands. Low volume herbicide applications are often recommended as research demonstrates much wider plant diversity after such applications. There is better ground erosion protection and more wildlife forage plants and cover plants develop. In most situations there is increased development of wild flowering plants and shrubs benefitting pollinators as well. In conjunction with herbicides, the diversity and density of low-growing plants provide control of tall-growing species through competition. This method retains ground cover year around with a better mix of food species and associated high-protein insect populations for birds in the right seasons. There is also reportedly less damage to soils even when compared with rubber-tired equipment. Overlooks are generally too small of an opening to provide a great deal of wildlife benefits. In addition, their very nature means people are attracted to them and thus they are less attractive to wildlife. Overlooks would be maintained in Alternatives B and C through mechanical and chemical means making their maintenance more efficient, however, effects to wildlife are few. Wildlife species, including MIS and associated neotropical migratory birds, could come in contact with herbicides by direct contact with spray streams or with recently treated foliage. Wildlife could also be exposed to herbicides by ingesting treated foliage, insects or other prey species, or through contact with treated water sources. However, the animal would generally have to be exposed continuously to the treated vegetation. The application rates and areas to be treated are of such limited area physically and in time that this seems unlikely. Herbicide toxicity data is presented below for mammals, birds and terrestrial invertebrates. The data suggest that the herbicides proposed for use in terrestrial and aquatic settings are generally safe to wildlife if used in accordance with the manufacturer label. Research suggests there is low risk of bioaccumulation in the environment and food chain from use of the herbicides (SERA 2004a, 2004b, 2004c, 2004d, 2006, 2007, 2009, 2011a, 2011b, 2011c, 2011d, 2014). Aminopyralid (SERA 2007) Adverse effects are not likely in mammals that consume contaminated vegetation or insects at typical and maximum application rates of 0.003 lb a.e./acre to 0.11 lbs. a.e./acre. Over the range of application rates and over the range of the estimated exposures, the hazard quotients for mammals range from 0.00001 (the lower bound for direct spray of a small mammal assuming first-order absorption at an application rate of 0.03 lb a.e./acre) to 0.07 (the consumption of contaminated insects by a small mammal after an application of 0.11 lb a.e./acre).

2,4-D (SERA 2006) Adverse effects are plausible in mammals that consume contaminated vegetation or insects at typical and maximum application rates of 0.5 lb a.e./acre to 4 lbs. a.e./acre, but not at the lowest rate. However, there is no indication that substantial numbers of

45 mammals would be subject to lethal exposure. Canines and other sensitive carnivorous mammals are more sensitive than other mammals. Birds appear to be much more tolerant than mammals and long-term exposure is unlikely to cause adverse effects. Adverse effects are a concern after acute exposure for birds. Adverse effects on terrestrial invertebrates may occur at the highest application rate of 4 lb a.e./acre.

Clopyralid (SERA 2004d) No adverse effects are anticipated in terrestrial animals from the use of clopyralid in Forest Service programs at the typical application rate of 0.35 lb a.e./acre. The same holds for the maximum application rate of 0.5 lb a.e./acre, except for large birds or mammals feeding exclusively on contaminated vegetation over a long period of time (i.e., 90 days). The scenarios assume that the vegetation is treated and that the animal stays in the treated area consuming nothing but the contaminated vegetation. Given that most forms of vegetation would likely die or at least be substantially damaged, this exposure scenario is implausible. It is, however, routinely used in Forest Service risk assessments as a very conservative upper estimate of potential exposures and risks. The longer term consumption of vegetation contaminated by drift or the longer term consumption of contaminated water or fish yield hazard quotients that are in the range of 0.00005 to 0.02, far below a level of concern.

Dicamba (SERA 2004a) No adverse effects are anticipated in terrestrial animals from the use of dicamba in Forest Service programs at the typical application rate of 0.3 lb a.e./acre. The same holds for the maximum application rate of 2 lb a.e./acre except that reproductive effects is plausible for birds or mammals feeding on contaminated vegetation or insects at this application rate. However, even this scenario yields hazard quotients that are below the level of concern by factors of 5 to over 16,000. Small animals seem to be less sensitive to dicamba than larger animals.

Fluazifop (SERA 2014) For exposure scenarios involving the consumption of contaminated vegetation following one or two applications, the hazards are lower than with more applications, but some scenarios exceed the level of concern. Longer-term exposures to mammals and birds are a concern. The hazards for mammals are of greater concern because of a possible association between exposure levels and endpoints involving reproductive capacity (i.e., decreased testes weight). There are no data to suggest that levels of long-term exposure to fluazifop-P-butyl will cause adverse effects in birds. Furthermore, acute exposures associated with the consumption of contaminated vegetation by birds do not appear to pose a hazard. For mammals, some of the acute hazard quotients associated with the consumption of contaminated vegetation exceed the level of concern. The highest levels of exposure are associated with the consumption of contaminated short grasses, which enhances the level of concern for acute exposures, because fluazifop-P-butyl is applied to grasses. For chronic exposures, the consumption of treated contaminated grasses is less plausible, because fluazifop-P-butyl will kill most treated grasses with the exception of resistant grasses. Exposure scenarios for mammals and birds involving contaminated water are of much less concern than those associated with contaminated vegetation. Some scenarios for the consumption of contaminated fish by a canid, large mammalian carnivore, and piscivorous bird result in hazard quotients that exceed the level of concern at the upper bounds of estimated exposures.

Based on these data, no risks to terrestrial insects would be anticipated. Based on the results of one bioassay on a predatory mite (Typhlodromus pyri), risks to sensitive species of terrestrial arthropods could be substantial. Based on another bioassay in this species as well as toxicity data on other terrestrial arthropods, risks are apparent but could be much lower. Many of the most relevant studies are summarized only briefly in a review by the European Food Safety Authority (EFSA 2012). Published field studies indicate that applications of fluazifop-P-butyl used to enhance the growth of wildflowers can be beneficial to both bees and butterflies. These field studies, however, do not exclude the possibility of direct adverse effects in sensitive species of terrestrial arthropods.

Fluroxypyr (SERA 2009) Fluroxypyr is practically non-toxic to honey bees and birds on an acute and dietary basis. It is slightly toxic to small mammals. This herbicide does not bioaccumulate in mammals or bioconcentrate through the food chain. At typical application rates and considering the small amount of area to be treated, there is an insignificant risk to mammals and birds and no adverse effects are anticipated.

Glyphosate (SERA 2011a) Based on pesticide use reports from the Forest Service, typical application rates for glyphosate in Forest Service programs are in the range of 0.5 to 4 lbs a.e./acre. Applications of more toxic formulations of glyphosate at rates of up to 2.5-3 lb a.e./acre do not appear to present any apparent risks to terrestrial animals, based on upper bound estimates of exposures. At application rates above 2.5 lb a.e./acre, risks to mammals cannot be ruled out based on upper bound estimates of exposure, but no risks are apparent based on central estimates of exposure. At application rates above about 3.3 lb a.e./acre, the hazard quotients for birds modestly exceed the level of concern, but there is no basis for asserting that overt toxic effects in birds are likely. Risks to terrestrial insects are a greater concern in dietary exposures than direct spray. Based on upper bound estimates of dietary exposure at the maximum application rate of 8 lb a.e./acre, the hazard quotients for terrestrial insects can reach a value of 10. Concern for terrestrial invertebrates is enhanced by two toxicity studies using South American formulations of glyphosate which noted adverse effects on reproduction and development. While most field studies suggest that effects on terrestrial invertebrates are due to secondary effects on vegetation, the field studies do not directly contradict the South American toxicity studies. The less toxic formulations of glyphosate do not appear to present any risks to terrestrial organisms other than terrestrial plants.

Imazapic (SERA 2004b) In acute exposure scenarios, the highest exposures for small terrestrial vertebrates would occur after a direct spray and could reach up to about 2.4 mg/kg at an application rate of 0.1 lb a.e./acre. There is a wide range of exposures anticipated from the consumption of contaminated vegetation by terrestrial animals: central estimates range from 0.125 mg/kg for a small mammal to 2.69 mg/kg for a large bird with upper ranges of about 0.27 mg/kg for a small mammal and 7.6 mg/kg for a large bird. The consumption of contaminated water leads to much lower levels of exposure. A similar pattern is seen for chronic exposures. Estimated daily doses for a small mammal from the consumption of contaminated vegetation at the application site are in the range of about 0.0001 mg/kg to 0.01 mg/kg. The upper ranges of exposure from contaminated vegetation far exceed doses that are anticipated from the consumption of contaminated water, which range from 0.0000001 mg/kg/day to 0.00000044 mg/kg/day for a small mammal. Based on general relationships of body size to body volume,

47 larger vertebrates would be exposed to lower doses and smaller animals, such as insects, to much higher doses than small vertebrates under comparable exposure conditions. Because of the apparently low toxicity of imazapic to animals, the rather substantial variations in the different exposure assessments have little impact on the assessment of risk to terrestrial animals. Imazapyr (SERA 2011b) Although the current risk assessments are based on the unit application rate of 1 lb a.e./acre, other applications are considered in the risk characterization up to the maximum labeled rate of 1.5 lbs a.e./acre. The U.S. EPA/OPP classifies imazapyr as practically non-toxic to mammals, birds, honeybees, fish, and aquatic invertebrates. This classification is clearly justified. None of the expected (non- accidental) exposures to these groups of animals raise substantial concern; indeed, most accidental exposures raise only minimal concern. The major uncertainties regarding potential toxic effects in animals are associated with the lack of toxicity data on reptiles and amphibians. No hazards associated with the direct toxic action of imazapyr can be identified for either terrestrial or aquatic animals. Chronic studies in three mammalian species and several reproduction studies in two mammalian species indicate that imazapyr is not likely to be associated with adverse effects at relatively high-dose levels. Like the acute and chronic studies in mammals, the available avian studies on imazapyr, all of which were conducted up to limit doses, do not report any signs of toxicity. The direct spray scenarios lead to hazard quotients far below the level of concern, Metsulfuron methyl (SERA 2004c) There is no clear basis for suggesting that effects on terrestrial or aquatic animals are likely or would be substantial. Adverse effects in mammals, birds, terrestrial insects, and microorganisms are not likely using typical or worst-case exposure assumptions at the typical application rate of 0.03 lb a.e./acre or the maximum application rate of 0.15 lb a.e./acre. Metsulfuron-methyl has been tested in only a limited number of species and under conditions that may not well-represent populations of free-ranging non-target species. Notwithstanding this limitation, the available data are sufficient to assert that no adverse effects are anticipated in terrestrial animals.

Picloram (SERA 2011c) Exposures of terrestrial animals to contaminated water do not lead to apparent risks even in the case of an accidental spill. For contaminated vegetation or prey, none of the central estimates of exposure (i.e., the most likely events) result in hazard quotients that exceed the level of concern. At the maximum anticipated application rate of 1 lb a.e./acre, upper bound hazards that exceed the level of concern are associated with the consumption of contaminated grasses (i.e., food items which contain the highest concentrations of picloram) by a small mammal. For longer-term scenarios, the consumption of contaminated grasses leads to upper bound hazards that exceed the level of concern for a small mammal, a large mammal, and a small bird. At the typical application rate of 0.25 lb a.e./acre, all of these upper bound hazard quotients would be at or below the level of concern except for the small mammal and the small bird. Direct toxic effects on terrestrial invertebrates as well as terrestrial microorganisms cannot be ruled out but do not appear to be substantial. Because of effects on terrestrial vegetation, secondary effects on terrestrial animals may occur due to changes in habitat quality and/or food availability. These secondary effects could be beneficial to some species and detrimental to other species.

Triclopyr (SERA 2011d) Contaminated vegetation is primary concern in the use of triclopyr and high application rates will exceed the level of concern for both birds and mammals in longer term exposure scenarios. At an application rate of 1 lb a.e./acre, hazards exceed the level of concern for exposures involving the consumption of contaminated vegetation by mammals and birds. Hazard quatients are greatest for large mammals. The high hazards suggest the potential for adverse effects, but not overt toxic effects, in large mammals. Based on a very cursory probabilistic assessment, exposures of mammalian wildlife that would be associated with upper bound hazards are probably rare occurrences. The highest exposures are associated with the consumption of contaminated grasses, and the lowest exposures are associated with the consumption of contaminated water. This is a common pattern for pesticides applied to vegetation. The exposure assessment for mammals is somewhat more detailed to encompass more diverse body weights. This approach is taken because the toxicity data (Section 4.3.2) indicate that larger mammals are more sensitive than smaller mammals to triclopyr. The direct spray scenarios lead to hazard quotients far below the level of concern, and an elaboration for body size would have no impact on the risk assessment. Honeybees are not sensitive to triclopyr. Alternative C would allow Forest Service openings to be treated mechanically as well as with herbicide; however, utilities would not be able to use chemicals. Mowers would be used every few years to cut vegetation regardless of species. There would be no economic or wildlife habitat improvement. There would be no opportunity to enhance pollinator, forage or nesting habitat on this acreage. Resprouting would be prevalent and thickets would result as described in Alternative B. Cumulative Effects Permanent Openings and old fields, Rights-of way, Improved pastures

Alternative A (No Action) There would be no cumulative effects because no new treatments are proposed. Alternative B (Proposed Action) and C Since the early 1900’s, naturally occurring shrub/scrub/grassy habitats have been lost to development (i.e., housing subdivisions), more efficient “clean” farming practices with few hedgerows, and succession which has resulted in much less early-successional habitat and more upland forests occurring overall. Typically, the openings on private land are not maintained in the grass-clover or native warm season grass mixtures as Forest Service openings are. Therefore, most of the openings on private land do not provide comparable benefits to wildlife or hunting opportunity. In addition, the Forest Service does not have control of the management of the openings on private land. Areas that currently provide habitat may be developed in the future and therefore cannot be relied upon to provide long-term wildlife benefits. It is important to maximize the benefits from this limited acreage on the national forests by maintaining these openings in high quality habitat conditions. Other cumulative effects activities would not have an effect on these biological elements.

Existing Condition Rare Communities, Riparian Forests, and Old Growth Forests

Rare communities, riparian forests, and old growth forests are special habitats that often harbor unique species assemblages. They will be evaluated in one section of this document since effects are similar. These communities typically represent only a small percentage of the land base of an area, yet contribute significantly to regional biodiversity. For example, within the southern Blue Ridge Mountains, the 1996 Southern Appalachian Assessment documented 31 rare communities each occupying less than one percent of the land base, yet 75 percent of the rare plants and animals of the region can be found within those communities (SAMAB 1996). These communities have suffered serious historic declines across the United States, especially on private lands, and are in need of protection and restoration (Ernst and Brown 1988, Knopf et al. 1988, Dahl 1990, Noss et al. 1995). Due to similar conditions and affects, these elements are analyzed together. Rare communities would not typically be associated with a project designed to manage man- made openings, especially spot or linear wildlife openings, however the linear character of utility lines, and the fact that they can span features aerially, does lend them to intersect such communities. One such rare community, a hillside fen supporting the rare Cypripedium reginae, is spanned by a transmission line near Watauga Lake. Additionally, some naturally open communities such as Cutshall Bog and the grassy balds at Roan Mountain are also included in this project as a type of managed opening. Specific forest plan standards exist regarding the management of rare communities wherever they occur on the landscape. Terrestrial riparian habitats encompass the transitional area between aquatic systems and upland terrestrial systems. All wetlands (including beaver ponds), as well as margins of varying widths along streams, rivers, lakes, ponds, and reservoirs, typically support terrestrial riparian habitats of varying degrees. These areas provide a number of critical functions for associated species. Most importantly, they provide rich, moist environments, not often found in upland areas. Riparian terrestrial habitats may serve as corridors for wildlife movement, allowing for daily travel and seasonal migration. The riparian area may serve as a connector of habitats and populations allowing gene flow to occur, thus keeping populations genetically vigorous (USDA 2004b). Riparian habitats ideally include a mosaic of native plant and animal communities and successional stages, with a predominance of late-successional forests. Late successional riparian forests contain multiple canopy layers that provide a variety of ecological niches, thermal and protective cover, and maintenance of moist conditions. Decadence of older forests provide an abundance of snags and downed wood, which also help retain moisture and provide important habitat substrate for reptiles, amphibians, small mammals, invertebrates, and mosses and liverworts. The majority of riparian dependent species need or prefer late-successional forest conditions for the diverse structure and the moist, temperature-moderated microclimates they provide. Terrestrial riparian habitats within the planning area are typical for the physiographic region, occurring as narrow bands along numerous small streams and tributaries. Most of these tributary streams are in incised landforms with relatively small floodplains and functional riparian areas that rapidly transition to steep, upland slopes. While there are river front forests and some open areas supporting wetland forbs and grasses along the larger streams and rivers, the majority of smaller riparian habitats are dominated by thickets of Rhododendron (Rhododendron maximum)

50 which exclude most other vegetation. These areas are typically excluded from any impacts from projects through adherence to Forest Plan standards. Due to extensive cutting in eastern forests throughout the early and mid-1900’s true old growth forests are rare on the landscape in the eastern United States. In June of 1997 a team chartered by the Southern Regional Forester completed a report entitled Guidance for Conserving and Restoring Old-Growth Forest Communities on National Forests in the Southern Region; (USDA Forest Service, 1997). Using this report as a guide, the CNF outlined an old growth strategy during its Forest Plan revision which was completed in 2004. This strategy is listed in Appendix D to the 2004 RLRMP. The Plan lists three types of old growth: Existing Old Growth is defined by four criteria which include factors of age, basal area, diameter at breast height, and disturbance; Possible Old Growth is defined as forest stands that meet the minimum age requirement for a given old growth community type; and Future Old Growth is defined as those stands that do not necessarily exhibit old growth characteristics now, but are allocated to old growth through land management decisions (examples include allocations of wilderness and other management prescriptions that are designated as unsuitable for timber management including riparian areas).

No large or small patches of old-growth forest were found to be associated with managed openings.

Acadian Flycatcher (MIS) The breeding range of the Acadian flycatcher (Empidonax virescens) includes southeastern South Dakota east across the southern Great Lakes region to southern New England; south to southern Texas, the Gulf Coast, and central Florida; and west to central Kansas. The Acadian flycatcher also breeds in southwestern Ontario. The highest breeding densities are in the Cumberland Plateau of Tennessee and in Virginia and West Virginia. Key habitat requirements include mesic deciduous forests with a moderate understory, generally near a stream. Humid deciduous forest (primarily mature), shaded ravines, floodplain forest, river swamps, hammocks and cypress bays in the South, thickets, second growth, and plantations are used for nesting and breeding. These birds tend to be scarce or absent in small forest tracts, unless the tract is near a larger forested area. The Breeding Bird Survey (BBS) data indicate an insignificant declining trend (-0.7%) for the Acadian flycatcher in the Appalachian Mountain region for the time period of 2000-2010 (Sauer et al. 2010). Based on National Forest bird surveys from 1992-2004, the Acadian flycatcher has an annual change of -1.3% for the Southern Blue Ridge physiographic region (La Sorte et al. 2007). Direct and Indirect Effects Rare Communities, Riparian Forests, and Old Growth Forests

Alternative A (No Action) Under this alternative no project activities would be implemented, thus there would be no direct or indirect effects to rare communities, terrestrial riparian or old growth habitats. Likewise, this alternative would have no direct or indirect effect to Acadian flycatchers.

Alternative B (Proposed Action) Potential management could occur within rare communities that are considered open areas, such as the balds at Roan Mountain, the hillside fen at Watauga Lake, or the open wetland at Cutshall Bog, however any management at these sites would comply with forest plan standards that are designed to protect or enhance these habitats. Across the project area, riparian forests would be excluded from management activities and protected in accordance with riparian standards. It is expected that any prescribed burning would not carry into riparian areas or other moist environments. Based upon this, no effects to terrestrial riparian habitats are expected. No old growth forests would be affected under this alternative. Based upon the information above, Alternative B would have no effects on Acadian flycatchers. Alternative C The only difference in the action alternatives potentially affecting rare communities, riparian forests, or old growth forests, would be that under this alternative, no herbicides could be used at the hillside fen near Watauga Lake. Since the proposed action does not specifically propose any activity there, effects from implementing alternative C would likely be the same as those described above in alternative B for rare communities, riparian forests, old growth and Acadian flycatchers. Cumulative Effects Rare Communities, Riparian Forests, and Old Growth Forests

Alternative A (No Action) It is estimated that more than 50% of the nation’s wetlands have been destroyed in the past 200 years (Ernst and Brown 1988, Dahl 1990) and almost 90% of virgin forests are gone (Noss et al. 1995). This is a statistic that cannot easily be reversed, however, conservation and restoration of these communities is occurring on public lands. Past, present and reasonably foreseeable activities are listed in the project environmental assessment. No new project activities would be implemented under this alternative, though many other routine and ongoing activities may occur within the project area. Based upon this, there would be no incremental contribution to cumulative effects on these resources from this alternative. Likewise, this alternative would have no direct or indirect effect to Acadian flycatchers. Alternative B (Proposed Action) and Alternative C None of the proposed activities would affect rare communities or old growth forests. Riparian vegetation is protected across the project area through forest plan standards requiring buffers to ground disturbing activities and other best management practices. Based upon this, there would be no incremental contribution to cumulative declines in these habitat types or the Acadian flycatcher. The Cherokee National Forest old growth strategy is listed in Appendix D to the 2004 revised land management plan. Its goal is to “manage through protection, maintenance, or restoration, a variety of large, medium, and small old growth patches to provide biological and social benefits.” (USDA Forest Service 2004c). No impacts to old growth forests are expected from the proposed action, thus there would be no incremental contribution to cumulative declines in this habitat type. Lands set aside in Wilderness designations or other lands unsuitable for

timber management are likewise contributing to future old growth, which is intended to offset some of the historical losses of this important habitat. There are no differences in the action alternatives as they relate to potentially affecting rare communities, riparian forests, old growth forests or Acadian flycatcher thus potential cumulative effects from implementing alternative C are the same as those described above in alternative B. Existing Condition Aquatic Habitats

The aquatic habitats in this analysis area are composed of approximately 6017 miles of ephemeral, intermittent and perennial streams with 860 miles capable of supporting fish (Table 7).

Table 7 Stream miles in the analysis area Type of Stream Miles Ephemeral 3868 Intermittent 1289 Perennial 860

Approximately half of Forest Service managed streams capable of supporting fish are cool water communities and half are cold water communities. Aquatic Species There are one hundred forty-three species of fish present (Table 8) in this analysis area (Cherokee National Forest 2014a); seven are managed as Endangered or Threatened with a Viability Goal of Protector/Restore; nine are managed as Sensitive with a Viability Goal of Protector/Restore; two are managed as Locally Rare with a Viability Goal of Protector/Restore; one hundred are managed as Natives with a Viability Goal of Maintain; and seventeen are managed as game or Introduced/Desirable with a Viability Goal of Enhance; and eight are Introduced/Undesirable with no Viability Goal.

Table 8 Fish Species Present in Streams Table 8 Fish Species Present in Streams within the Analysis Area within the Analysis Area Status Species Status Species Endangered Citico darter Sensitive bronze darter Endangered Conasauga Sensitive fatlips minnow logperch Sensitive holiday darter Endangered smoky madtom Sensitive mountain brook Threatened blue shiner lamprey Threatened snail darter Sensitive olive darter Threatened spotfin chub Sensitive sharphead darter Threatened yellowfin madtom Sensitive sickle darter Sensitive blotchside logperch Sensitive Tennessee dace

Table 8 Fish Species Present in Streams Table 8 Fish Species Present in Streams within the Analysis Area within the Analysis Area Status Species Status Species Sensitive wounded darter Native blueside darter Locally Rare smoky dace Native bluntnose minnow Locally Rare southern brook Native bridled darter lamprey Native brook silverside Game Alabama bass Native brown bullhead Game bluegill Native bullhead minnow Game brook trout Native burrhead shiner Game green sunfish Native central stoneroller Game largemouth bass Native channel catfish Game longear sunfish Native chestnut lamprey Game redbreast sunfish Native Coosa darter Game redear sunfish Native Coosa shiner Game redeye bass Native creek chub Game rock bass Native dusky darter Game shadow bass Native eastern blacknose Game smallmouth bass dace Game spotted bass Native fantail darter Game spotted sunfish Native flathead catfish Game warmouth Native freshwater drum Introduced/Desirable brown trout Native gilt darter Introduced/Desirable rainbow trout Native gizzard shad Native Alabama hogsucker Native golden redhorse Native Alabama shiner Native greenbreast darter Native American brook Native greenfin darter lamprey Native greenside darter Native banded darter Native highfin carpsucker Native banded sculpin Native highland shiner Native bigeye chub Native largescale Native black buffalo stoneroller Native black bullhead Native least brook lamprey Native black crappie Native logperch Native black redhorse Native longnose dace Native blackbanded darter Native longnose gar Native blackspotted Native mimic shiner topminnow Native mirror shiner Native blacktail redhorse Native Mobile logperch Native blacktail shiner Native mooneye Native blotched chub Native mottled sculpin Native bluebreast darter Native mountain madtom

Table 8 Fish Species Present in Streams Table 8 Fish Species Present in Streams within the Analysis Area within the Analysis Area Status Species Status Species Native mountain shiner Native Tuckasegee darter Native northern hogsucker Native walleye Native northern studfish Native warpaint shiner Native Ohio lamprey Native western blacknose Native quillback dace Native rainbow darter Native white bass Native rainbow shiner Native white crappie Native redline darter Native white sucker Native riffle minnow Native whitetail shiner Native river carpsucker Native yellow bullhead Native river chub Introduced/Undesirable blueback herring Native river redhorse Introduced/Undesirable carp Native rock darter Introduced/Undesirable fathead minnow Native saffron shiner Introduced/Undesirable golden shiner Native sauger Introduced/Undesirable mountain redbelly Native sawfin shiner dace Native shoal chub Introduced/Undesirable striped bass Native silver redhorse Introduced/Undesirable white catfish Native silver shiner Introduced/Undesirable yellow perch Native silverstripe shiner Native skipjack herring Native smallmouth buffalo Native smallmouth redhorse Native snubnose darter Native southern studfish Native speckled darter Native speckled madtom Native spotfin shiner Native spotted gar Native spotted sucker Native stargazing minnow Native striped shiner Native Swannanoa darter Native tangerine darter Native telescope shiner Native Tennessee darter Native Tennessee shiner Native tricolor shiner

In addition to fish, there are several other aquatic groups that are monitored on the Forest (Table 9).

Table 9 Other Aquatic Species Monitored Group Status Number Freshwater Mussels Threatened/Endangered/CH* 15 Reptiles Threatened 1 (none documented on Forest) Freshwater Mussels Sensitive 7 (one not documented on Forest) Salamanders Sensitive 6 (two not documented on Forest) Aquatic Insects Sensitive 5 (three no documented on Forest) *Critical Habitat occurs on the Forest but the species has not been documented here.

All of these species have a Viability Goal of Protect/Restore. Direct Effects Aquatic Habitats

Direct effects to aquatic habitats and organisms happen only when an activity occurs within the stream channel. Alternatives A (No Action), B, and C (Proposed Action) There will be no direct impacts to aquatic habitats from lternative A, B (Proposed Action) and C since no activities will occur in stream channels. Indirect and Cumulative Effects Aquatic Habitats

Indirect effects to aquatic organisms arise from activities authorized outside the stream channel that allow sediment or herbicide to enter and alter aquatic habitats. When the sediment or herbicides generated by these indirect effects are added to the sediment or herbicide generated by ongoing activities, the combination is referred to as cumulative effects. Alternative A (No Action)

Alternative A proposes no new ground disturbing or herbicide activities, however, routine mechanical activities would occur on all existing openings, as would activities authorized through other decisions. Herbicide use is currently only authorized on limited areas. No effects would occur to aquatic habitats because there would be no increase above current levels of sedimentation or herbicide. Current levels of sedimentation and herbicide usage are not having adverse effects based on monitoring (Cherokee National Forest 2013). Alternative B (Proposed Action) and Alternative C Ground disturbances and herbicide treatments associated with a combination of manual, cultural, and chemical control treatment methods across the National Forest would follow Forest Plan standards and limit impacts to soil and water resources to acceptable levels. Forest Plan Standards (USDA Forest Service 2004a) were designed to protect the most susceptible aquatic species (trout) from harmful levels of sediments. There will be no indirect or cumulative impacts to aquatic habitats from either action alternative.

Existing Condition Threatened and Endangered Species

Effects to federally-listed threatened and endangered species are analyzed in detail in the Biological Assessment (Appendix 2) for this project. The results are summarized here. Terrestrial Wildlife Species Four federally listed mammals (Virginia big-eared bat, Gray bat, Northern long-eared bat and Indiana bat) are present or have habitat in or near openings on the Forest.

Virginia big-eared bat Corynorhinus townsendii virginianus This bat is found in the Appalachian Mountains in Virginia, West Virginia, North Carolina, and eastern Kentucky. It was recently found in northeast Tennessee. Presently it occurs in decreased numbers throughout much of the historic range. The largest colonies are in several caves in Pendleton County, West Virginia; some caves serve as both hibernation and maternity sites, others are primarily maternity caves. Colonies occur also in Lee County and surrounding counties, Kentucky (the best known site being Stillhouse Cave); in Bath, Highland, Rockingham, Bland, and Tazewell counties, Virginia; and in Avery and Watauga counties, North Carolina (NatureServe 2015). It was documented in northeast Tennessee in 2013.

Gray bat Myotis grisescens This bat is found throughout the limestone region of southern middle-western and southeastern United States (Whitaker 1998). It has been documented at 11 locations on the CNF, most on the north end of the Forest. Gray bats use caves year-round for hibernating, maternity colonies, and roosting. They forage for insects over water along riparian areas and shorelines with forest cover (USFWS 1982). They feed primarily on flying insects such as mayflies, moths, flies, and beetles (LaVal 1977).

Northern long-eared bat Myotis septentrionalis Northern long-eared bat (NLEB) is found throughout the eastern United States and Canada (Caceres 2000). This bat uses caves and man-made structures for hibernation. They leave their hibernacula in March and April and return in August and September (USFWS 2013). On the CNF, this bat has been documented in many locations.

Indiana bat Myotis sodalis Indiana bat occurs from Vermont to Michigan, south to South Carolina, west to Alabama, Indiana to Arkansas, and Oklahoma. Only nine hibernacula in three states (KY, IN, MO) harbor 75% of the remaining population (NatureServe 2012). No hibernacula are known from the CNF, but one is located in the Great Smoky Mountains National Park. Plant Species No federally listed proposed, endangered, or threatened plant species are known to occur, nor would be expected to occur, within any of the typical openings included in his project. The proposal does include the high mountain balds of Roan Mountain, however, which is a very unique area of high botanical diversity. One federally endangered species, Roan Mountain bluet

(Houstonia montana) is known to occur within portions of the bald habitat on Roan Mountain. Potential effects to Houstonia montana are described below.

Roan Mountain bluet Houstonia montana Roan mountain bluet is a federally endangered species with a very limited range. The species is endemic to the high Blue Ridge of northwestern North Carolina and northeastern Tennessee, most notably occurring on Roan Mountain, Grandfather Mountain, Bluff Mountain, and Three Top Mountain (Weakley 2012). Habitat is described as crevices of rock outcrops at the summits of high elevation peaks of the Southern Blue Ridge, also in thin, frost-heaved, gravelly soils of grassy balds near summit outcrops, from 1250-1950 m in elevation (Weakley 2012). Aquatic Species There are 23 aquatic T&E species that occur or have Critical Habitat within this analysis area. Their distribution and preferred habitat is shown by watershed in Table 10.

Table 10 Aquatic T&E Species Groups on the Forest or with Critical Habitat on the Forest Watershed Group Number of Species Preferred Habitat Conasauga Mussels 10 Medium and Large Rivers Conasauga Fish 2 Medium and Large Rivers Hiwassee Mussels 4 Large Rivers Hiwassee Fish 1 Large Rivers Little Tennessee Fish 4 Medium Rivers Nolichucky Mussel 1 Large Rivers South Holston Reptile 1 Bogs Totals 23

Citico darter Etheostoma sitikuense This fish inhabits large streams with low gradients at low elevations. Citico darters are usually found in the transitional zone between riffles and pools. They were never observed in pool habitats even when suitable slab rocks were present (Shute, Rakes and Shute, 1997). Flat rocks for spawning and hiding cover are essential (Shute, Rakes and Shute, 1997). Excess sediment may be detrimental to its survival. Male Citico darters excavate nest cavities under flat rocks where they guard their eggs and young. These darters use the interstitial spaces between rocks for escape cover and for foraging on aquatic insects. Formerly known as the duskytail darter, this species is endemic to tributaries of the Little Tennessee River system and occurs naturally only in Citico Creek on the Cherokee National Forest. Two non-essential, experimental, populations have been established: one in Abrams Creek and the other in the Tellico River.

Citico darters were first introduced into the Tellico River in 2003. Approximately 430 have been introduced every year since. They were found to be successfully reproducing in 2004.

Conasauga logperch Percina jenkinsi The Conasauga logperch is endemic to the Conasauga River. On the Cherokee NF it occurs for the entire length of the Conasauga and Jacks Rivers within the Forest Boundary. Critical habitat is defined on the Cherokee NF in the Conasauga River from Halfway Branch downstream to Georgia State Hwy 2, Murray Co., Ga. Habitat is typically large streams with low gradients at low elevations; deep gravel runs or pools with small stones and sandy bottoms. Conasauga logperch feed on aquatic invertebrates which are obtained by flipping over stones with its snout. Spawning occurs in the spring over shallow gravel with fast current. Threats include sedimentation, channelization, and impoundment.

Smoky madtom Noturus baileyi This catfish inhabits large streams with low gradients at low elevations. It prefers transitional areas between pools and riffles (Etnier and Starnes 1993); shallow riffles containing flat, palm sized slab rocks, pea sized gravel; and deep pools (during colder months) (Dinkins 1984) with silty/sandy bottoms with large boulders (Biggins 1985). Excess sediment may be detrimental to their survival. This species is nocturnal. Male madtoms excavate nest cavities under flat rocks where they guard their eggs and young. Madtoms use the interstitial spaces between rocks for escape cover and for foraging on aquatic insects. This species is endemic to the Little Tennessee River system and occurs naturally only in Citico Creek on the Cherokee National Forest. Critical Habitat for the smoky madtom was designated at the time of listing (Biggins 1985) for Citico Creek from the upper Mountain Settlement Bridge upstream to the confluence with Barkcamp Branch. Smoky madtoms have documented both above and below the Critical Habitat (USDA Forest Service 2014). Two non-essential, experimental, populations have been established: one in Abrams Creek and the other in the Tellico River.

Smoky madtoms were first introduced into the Tellico River in 2003. Approximately 270 have been introduced every year since. They were found to be successfully reproducing in 2005.

Blue shiner Cyprinella caerulea The blue shiner is endemic to the upper Mobile Basin drainage ranging from Tennessee down to central Alabama. On the Cherokee NF, it occurs only in the Conasauga River watershed where it is known from the Conasagua River, Jacks River, Sawmill Branch and Mooneyham Branch. Habitat includes small streams to large rivers with low gradients at low elevation; firm substrates in pools and areas of moderate current. Feeding is surface or mid water collumn where terrestrial and immature aquatic insects are taken. Spawning is from spring into summer. Threats include water quality degradation associated with urbanization, sewage pollution, and strip mining; introduced biota; and impoundments.

Snail darter Percina tanasi The snail darter is endemic to larger tributaries of the Tennessee River from the Sequatchie River to the confluence of the French Broad and Holton Rivers. Seven extant populations exist. On the Cherokee NF it occurs in the Hiwassee River from the downstream Forest boundary upstream to Reliance. A single individual was collected in Citico Creek in 2007; its origin is unknown. Preferred habitat is small rivers with low gradient at low elevation with sand and gravel shoals to deep pools with some current. Snail darters feed primarily on snails with some insects also taken. Spawning occurs in late winter to early spring. Eggs are deposited in gravel

59 areas; larva drift downstream. Juveniles migrate upstream after 3 to 4 months. Threats are primarily from impoundments.

Spotfin chub Erimonax monacha This chub inhabits cool and warm, typically clear, large creeks or medium-sized rivers of moderate gradient, in upland and montane areas, generally in or near moderate and swift currents over gravel to bedrock, rarely over sand or silt. The spotfin chub is a rock crevasse spawner; males guard cracks in bedrock in swift flows. Spotfin chubs forage on drifting insects in the water column and seek escape by moving to other swift flowing areas. They are endemic to the Tennessee River in Tennessee, Virginia, North Carolina and Georgia. On the Cherokee NF, it has been re-introduced into Tellico River as a non-essential experimental population. No other occurrences are likely on the Forest. Threats include fragmentation and loss of habitat from reservoirs and siltation.

Spotfin chubs were first introduced into the Tellico River in 2002. Approximately 1700 have been introduced every year since. They were found to be successfully reproducing in 2006.

Yellowfin madtom Noturus flavipinnis This catfish inhabits large streams to large rivers with low gradients at low elevations. It occurs in pools associated with cover such as flat rocks for spawning and leaf packs for shelter (USDI FWS 1983). This species is nocturnal. Excess sediment may be detrimental to its survival (Shute, 1984). Male madtoms excavate nest cavities under flat rocks where they guard their eggs and young. Madtoms use the interstitial spaces between rocks for escape cover and for foraging on aquatic insects. Yellowfin madtoms are endemic to the upper Tennessee River and occur on the Cherokee National Forest in 2 miles of Citico Creek, in the Powell River in northern Tennessee, and in Copper Creek in Virginia. Two non-essential, experimental, populations have been established: one in Abrams Creek and the other in the Tellico River. Yellowfin madtoms were first introduced into the Tellico River in 2003. Approximately 230 have been introduced every year since. They were found to be successfully reproducing in 2008.

Appalachian elktoe Alasmidonta raveneliana The Appalachian elktoe is endemic to the Tennessee River in East Tennessee and western North Carolina. Only 2 extant populations remain. It occurs in the Nolichucky River on the Cherokee NF. Preferred habitat is small to large rivers with low gradient at high and low elevations; among cobbles and boulders with some sand and gravel. Fish host is the banded sculpin. Threats include siltation from logging, mining, agriculture and construction; organic and inorganic pollutants from industrial, agricultural, and other point and non-point sources; habitat loss due to impoundments, channelization and dredging.

Tan riffleshell Epioblasma florentina walkeri The tan riffleshell mussel is endemic to major tributaries of the Tennessee and Cumberland Rivers. Only two extant populations remain. It is known from two sites in the Hiwassee River on the Cherokee NF and the other population is in the Clinch River. The upper site, on the Hiwassee River, was augmented in 1999 with juveniles raised by Dr. Dick Neves, Va. Tech. but none of these have been seen since. The last observation of a live tan riffleshell mussel in the

Hiwassee River was in 1993. Preferred habitat is large streams and small rivers with low gradient at low elevation in shallow riffles (less than 3 feet deep) with coarse sand, gravel, and some silt. Fish hosts include sculpins, greenside darter, fantail darter, and redline darter. Threats are from impoundments that flood habitat or alter flow regime; siltation from strip mining, coal washing, dredging, farming, logging and road construction; and pollution from municipal, agricultural, and industrial waste discharges.

Upland combshell Epioblasm metastriata The upland combshell is endemic to the Mobile River system. It has not been documented on the Cherokee NF but is known from the Conasauga River five miles below the Forest boundary. Critical Habitat includes all of the Conasauga River on the Forest. Preferred habitat is medium size rivers with moderate gradient in riffle areas. Fish host is unknown. Threats include dams, dredging, mines, point source pollution, and non-point source pollution.

Southern acornshell Epioblasma othcaloogensis The southern acornshell is endemic to the Mobile River system. It has not been documented on the Cherokee NF but is known from the Conasauga River eight miles below the Forest boundary. Critical habitat includes all of the Conasauga River on the Forest. Preferred habitat is medium size rivers with moderate gradient in riffle areas. Fish host is unknown. Threats include dams, dredging, mines, point source pollution, and non-point source pollution.

Coosa moccasinshell Medionitus parvulus The Coosa moccasinshell is endemic to the Mobile River system. It has not been documented on the Cherokee NF but the only extant population is in the Conasauga River where it has been found five miles downstream of the Forest Boundary. Critical habitat includes all of the Conasauga River on the Forest. Preferred habitat is usually sand and gravel in highly oxygenated, clear streams with moderate to strong flows in streams and small rivers. Threats include dams, dredging, mines, point source pollution, and non-point source pollution.

Southern clubshell Pleurobema decisum The southern clubshell was known from Mississippi, Alabama, Georgia and Tennessee. It has not been documented on the Cherokee NF but is known from the Conasauga River five miles below the Forest boundary. Critical habitat includes all of the Conasauga River on the Forest. The preferred habitat is highly oxygenated streams with sand and gravel substrate in shoals of large rivers to small streams; it may be found in sand and gravel in the center of the stream or in sand along the margins of the stream. Threats include habitat modification, sedimentation, and water quality degradation.

Southern pigtoe Pleurobema georgianum The southern pigtoe is endemic to the Alabama River system with four extant populations. On the Cherokee NF it occurs in the main channel of the Conasauga River where it was last collected in 2011. Critical Habitat includes all of the Conasauga River on the Forest. Preferred habitat is large streams with low gradient at low elevation; sand, gravel, and cobble shoals and runs. Fish host is unknown. Threats include habitat modification, impoundments, sedimentation, eutrophication, household and agricultural runoff, recreational activities.

Georgia pigtoe Pleurobema hanleyianum The Georgia pigtoe is endemic to the Alabama River system. On the Cherokee NF it occurs in the Conasauga River which may be the only extant population. Critical Habitat includes all of the Conasauga River on the Forest. Preferred habitat is large streams and small rivers with low gradient at low elevation; moderate current over sand and gravel substrate. Fish host is unknown. Threats include sedimentation.

Ovate clubshell Pleurobema perovatum The ovate clubshell is endemic to the Mobile River system. It has not been documented on the Cherokee NF but is known from the Conasauga River five miles below the Forest boundary. Critical habitat includes all of the Conasauga River on the Forest. The preferred habitat is sand/gravel shoals and runs of small rivers and large streams. Fish host is unknown. Threats include dams, dredging, mines, point source pollution, and non-point source pollution.

Slabside pearlymussel Pleuronaia dolabelloides This mussel is endemic to the Tennessee River system; few extant populations are left range wide. It is found at two sites on the Cherokee NF in the Hiwassee River. Critical habitat includes all of the Hiwassee River from Hwy 411 to Hwy 68. Preferred habitat is large streams with low gradient at low elevation with moderately strong currents in sand, fine gravel, and cobble substrate. Fish hosts include: popeye, rosyface, saffron, silver, telescope, and Tennessee shiners. Threats include pollution, siltation, habitat perturbation, inundation, over-collecting, and loss of glochidial hosts.

Rayed kidneyshell Ptychobranchus foremanianus The rayed kidneyshell is endemic to Alabama River system. On the Forest it is known to occur in the Conasauga River above Jacks River but is likely to occur all the way down stream. Critical habitat includes all of the Conasauga River on the Forest. The preferred habitat is in medium to large rivers with a mixture of sand and gravel in moderate to swift current. Fish hosts are darters and sculpins. Threats include genetic isolation.

Fluted kidneyshell Ptychobranchus subtenum The fluted kidneyshell is found in the Cumberland and Tennessee River systems. It has not been documented on the Cherokee NF but individuals were introduced into the Hiwassee River approximately five miles downstream of the Forest boundary. Critical habitat has been designated for the Hiwassee River from Hwy 411 to Hwy 68. Preferred habitat is small to medium rivers in areas with swift current or riffles. Fish hosts are darters and sculpins. Threats include impoundments, stream channel alterations, water pollution, and sedimentation.

Cumberland bean pearly mussel Villosa trabalis The Cumberland bean pearly mussel is endemic to the Tennessee and Cumberland River systems; four extant populations exist. It is known from two sites in the Hiwassee River on the Cherokee NF and was last collected here in 2010. Two collections were downstream of the powerhouse in the Hiwassee River – Athern in 1970 and Ortmann in 1915. Both of these are considered to be from historical populations that no longer have suitable habitat in the river. Preferred habitat for this mussel is found in large streams and small rivers with low gradient at

62 low elevation. Current is usually fast with gravel or sand and gravel substrate. Fish host is unknown. Threats are from impoundments that flood habitat, alter flow regime, or decrease water temperature; siltation from strip mining, coal washing, dredging, farming, logging and road construction; and pollution from municipal, agricultural, and industrial waste discharges.

Finelined pocketbook Hamiota altilis The finelined pocketbook is endemic to the Alabama River system; three extant populations are known; one is the Conasauga River within the Forest Boundary. Critical habitat includes all of the Conasauga River on the Forest. Preferred habitat is large streams to large rivers with low gradient at low elevation; in moderate current less than 3 feet deep with a substrate composed of sand and mud with some gravel. Fish hosts include redeye and largemouth bass. Threats include habitat modification, impoundments, sedimentation, eutrophication, urban and agricultural runoff, and sand and gravel mining.

Alabama moccasinshell Medioidus acutissimus The Alabama moccasinshell is endemic to the Mobile River system. It has not been documented on the Cherokee NF but is known from the Conasauga River four miles below the Forest boundary. Critical habitat includes all of the Conasauga River on the Forest. The preferred habitat is on the margins of streams with a sand and gravel substrate in clear water of moderate flow in small to large rivers. Fish hosts include several darters and a topminnow. Threats include habitat modification, sedimentation, and water quality degradation.

Bog turtle Clemmys muhlenbergii The bog turtle is known from New York to Georgia along the Appalachian Mountains. Populations are disjunctive. They occur near the Cherokee NF in the South Holton watershed. Preferred habitat is low, shallow, muck-bottomed rivulets of sphagnum bogs, calcareous fens, marshy/sedge-tussock meadows, spring seeps, wet cow pastures, and shrub swamps; habitat usually contains an abundance of grassy or mossy cover. Threats include loss, degradation, and fragmentation of habitat and excessive (and illegal) collecting for the pet trade.

Direct and Indirect Effects Threatened and Endangered Species -- Terrestrial Wildlife

Alternative A (No Action) There would be no change in management with this Alternative. Effects would not change as current management would continue. Alternative B (Proposed Action) and C With the proposed action, the Cherokee National Forest proposes to manage grassy, herbaceous and shrubby openings using a combination of manual, cultural, and chemical control treatment methods across the National Forest. No direct effects are expected for the gray bat or Virginia big-eared bat. Habitat associated with caves would not be impacted because no caves are located within the action areas. Hibernacula and maternity colony habitat would not be affected. Proposed activities would occur during the day while bats are roosting in caves and are absent from the project area.

Effects to northern long-eared bats and Indiana bats are unlikely. There are no known hibernacula on the Forest, no caves are near any openings, and no Indiana bats have been found on the northern districts of the CNF. Indiana bats have been found on the southern districts of the Forest. Trees very near wildlife openings have been documented as roost trees in the past. None are currently documented. Should an Indiana bat or Northern long-eared bat roost site be discovered prior to and/or during project implementation, project activities would stop, and the CNF would again consult with the FWS. The southern districts have incidental take for Indiana bats. This project tiers to that document. Riparian zone restrictions (no harvest within 100 feet of perennial streams) and streamside buffer zones (no ground disturbance) would protect foraging habitat downstream from changes to vegetation and water quality. If individual northern long-eared or Indiana bats are present in areas where openings are being maintained by tree removal, disturbance may disrupt individuals or cause inadvertent loss of individual bats or small groups roosting in trees that are cut or pushed over. The RLRMP requires the largest trees with favorable conditions for roosting bats to be left. It also requires retention of all shagbark hickory trees (>6 inch diameter) and snags with exfoliating bark. This would protect most roosting bats from harm. If harvest disturbs roost trees it could cause the bats to increase roost dispersal, leading to fewer shared roost trees. These lower group numbers could decrease the spread of disease (USFWS 2013). Removal of trees would contribute to the loss of future roosting habitat. However, northern long-eared bats and Indiana bats are opportunistic and flexible in roost tree selection. Indiana bats have adapted to these types of situations as roost trees are temporary in nature (O’Keefe 2011). This flexibility in roosting may allow bats to be adaptable in managed forests and avoid competition for roosting habitat with more specialized species (USFWS 2013). The overall effect of these activities would provide open patches of forest with standing snags for roosting in the Forest openings. The open condition of these areas would make roosting habitat more suitable by providing more sunlight to maintain warmer conditions in the roost. Female NLEB have been found to prefer roosts with lower canopy cover most likely for increased solar radiation for pup development and for greater ease for pups learning to fly (USFWS 2013). Maintenance of these open areas would increase light intensity and herbaceous plant diversity for the next five to ten years. These activities would increase insect production and improve forage conditions for NLEB. The proposed project is likely to improve foraging habitat. Less than one percent of the potential roosting habitat would be impacted on the Forest. Dormant season controlled burning to maintain native plants in the openings would have no direct effects on bats because burning would take place when bats are not present. However, foraging, roosting, and maternity colony habitat may be altered. Since roost trees are ephemeral, bats are adapted to finding new roost trees should historic roosts be lost during the fire. Burns would have indirect beneficial impacts to bats by maintaining open habitat which in turn increases insect production (Lacki et. al 2009). The increase in insect production would provide better foraging opportunities for bats in general. Herbicides would be used to control woody vegetation and treat non-native invasive species.

The herbicides used for treatments would not contact bats directly, but may be present in trace amounts on an occasional insect ingested by bats, although the likelihood of this occurrence is small. The following factors would further minimize the risk of contamination: 1) herbicide applied in small amounts; 2) application methods targeting woody stems; and 3) design criteria for herbicide use such as timing to avoid rainfall and 30-foot buffer zones. Timing of application and quantities applied would ensure that no measurable effects to water quality would occur even in aquatic scenarios. Effects of the individual herbicides can be found below. Herbicide toxicity data is presented above in the “Permanent openings and old fields, Rights-of way, Improved pastures” section for mammals, birds and terrestrial invertebrates. The data suggest that the herbicides proposed for use in terrestrial and aquatic settings are generally safe to wildlife if used in accordance with the manufacturer label. Research suggests there is low risk of bioaccumulation in the environment and food chain from use of the herbicides (SERA 2004a, 2004b, 2004c, 2004d, 2006, 2007, 2009, 2011a, 2011b, 2011c, 2011d, 2014). See the Biological Assessment for additional specific information about each herbicide. Alternative C would have essentially the same effects as Alternative B. No herbicides would be allowed on the utility lines, thus effects would be seen on a smaller area with this alternative. Cumulative Effects Threatened and Endangered Species -- Terrestrial Wildlife

Alternative A (No Action), B (Proposed Action) and C No management would change. Private land within the analysis area is predominantly in forested condition as well as farmland and fields and no known future activities are expected to occur. Therefore, no cumulative effects to bats would occur. Determination of Effect Due to the limited nature of foraging habitat in the action area and timing of activities, effects of the action alternative would be discountable. Some effects may be slightly beneficial. No known Northern long-eared bat roosts or hibernacula are within 0.25 mile of any openings. The proposed project may affect, not likely to adversely affect Virginia big-eared bat and gray bat. This project is likely to adversely affect the northern long-eared bat; however, there are no effects beyond those previously disclosed in the programmatic biological opinion dated August 5, 2015 (FWS Log #04E00000-2015-F-0003). Any taking that may occur incidental to this project is excepted from the prohibitions for taking threatened species under 50 CFR 17.31 and 17.32. This project is consistent with the forest plan, the description of the proposed action in the programmatic biological opinion, and activities excepted from taking prohibitions under the ESA section 4(d) rule applicable to the northern long-eared bat; therefore, the programmatic biological opinion satisfies the Forest Service’s responsibilities under ESA section 7(a)(2) relative to the northern long-eared bat for this project. The proposed project may affect, not likely to adversely affect Indiana bat on the Northern districts because none have been found on those districts, adverse effects would be discountable and some effects would be beneficial if the bats were using the area. The proposed project may affect, likely to adversely affect the Indiana bat on the southern districts due to the presence of the bat in the area and the potential for removal of roost trees. This document tiers to the

Biological Opinion for Indiana bat on the southern districts (USFWS 2015) where the bats have been found. Direct and Indirect Effects Threatened and Endangered Species -- Plants

Alternative A (No Action) No new management activities are proposed under this alternative. Many mechanical treatments are part of routine actions already approved within forest openings and those would continue. Current vegetation management that is carried out at Roan Mountain is based on recommendations from the Environmental Assessment for Vegetation Management of the Roan Mountain Grassy Balds (USDA Forest Service 1991) and standards from the Roan Mountain management prescription in the Cherokee National Forest Revised Land and Resource Management Plan (USDA Forest Service 2004c). All vegetation management on the Roan Mountain balds is coordinated through a working group of federal, state and private agencies and individuals, and is designed to maintain and enhance existing plant communities and associated rare species. Populations of Roan Mountain bluet are monitored annually by an interagency group to determine if any management around populations is needed. Implementation of this alternative would have no known direct or indirect effects on Houstonia montana. Alternative B (Proposed Action) Houstonia montana is known to occur at a few sites within the grassy bald habitat of Roan Mountain. The proposed action would add the potential use of herbicides and/or prescribed fire to the mix of management tools available for vegetation management within the balds. Current vegetation management that is carried out at Roan Mountain is based on recommendations from the Environmental Assessment for Vegetation Management of the Roan Mountain Grassy Balds (USDA Forest Service 1991) and standards from the Roan Mountain management prescription in the Cherokee National Forest Revised Land and Resource Management Plan (USDA Forest Service 2004a). All vegetation management on the Roan Mountain balds is coordinated through a working group of federal, state and private agencies and individuals, and is designed to maintain and enhance existing plant communities and associated rare species. No specific management for Houstonia montana is proposed as a part of this project, however any management activities within the vicinity of Houstonia montana sites would be carefully planned and implemented to ensure only neutral or beneficial effects to the species. Based upon this, the implementation of this alternative may affect but is not likely to adversely affect Houstonia montana. Alternative C The only difference between Alternatives B and C is that no herbicide use would be approved within utility corridors under Alternative C. Based upon this, potential effects to Houstonia montana are the same as those described above for alternative B. Cumulative Effects Threatened and Endangered -- Plants

66 high mountain tops in northwestern North Carolina and adjacent northeastern Tennessee (Weakley 2012, NatureServe 2015). Regardless of this proposal, this species is intrinsically threatened by its small population size and very limited distribution. The primary threats to this species are intensive recreational uses such as ski resort development, trampling by hikers, and climbing/rock scrambling. Populations could also be lost to woody plant succession (NatureServe 2015). Populations of Roan Mountain bluet are monitored annually by an interagency group to determine if any management around populations is needed. Alternative B (Proposed Action) and Alternative C Under the action alternatives there are no anticipated direct or indirect effects, and thus there would be no incremental contribution to cumulative effects to the species from either of these alternatives. Cumulative effects would be the same as those described in Alternative A. Determination of Effect The determination of effect for the Roan Mountain Bluet is No effect for Alternative A and May affect, not likely to adversely affect for Alternative B and C. Direct and Indirect Effects Threatened and Endangered Species – Aquatic Species

Alternative A (No Action), Alternative B (Proposed Action) and Alternative C There will be no direct impacts to T&E species from alternative A, B (proposed Action) and C since no activities will occur in stream channels. Indirect and Cumulative Effects Aquatic Species

Alternative A (No Action)

Alternative A proposes no new ground disturbing or herbicide activities, however, routine mechanical activities would occur on all existing openings, as would activities authorized through other decisions. Herbicide use is currently only authorized on 116 acres of Fort Loudoun Electric Cooperative administered utilities in Monroe County and 56 acres of Tennessee Valley Authority administered utilities in Polk County along with administrative sites and non-native invasive plant sites. There would be no effects to any aquatic T&E species because there would be no increase above current levels of sedimentation or herbicide. Current levels of sedimentation and herbicide usage are not having adverse effects based on monitoring (Cherokee National Forest 2013) and adhere to Forest Plan standards. Alternative B (Proposed Action) and Alternative C Indirect and/or cumulative effects may affect but are not likely to adversely affect any aquatic T&E species because ground disturbances and herbicide treatments associated with a combination of manual, cultural, and chemical control treatment methods across the National Forest would follow Forest Plan standards and limit impacts to soil and water resources to

67 acceptable levels. Forest Plan Standards (USDA Forest Service 2004a) were designed to protect the most susceptible aquatic species (trout) from harmful levels of sediments. Determination of Effect The determination of effect for the aquatic species is no effect for Alternative A and may affect but not likely to adversely affect Alternatives B and C. Existing Condition for Regional Forester’s Sensitive Species

Terrestrial Species Five Regional Forester’s Sensitive terrestrial wildlife species were found to have habitat in or near managed openings. Because the existing openings (especially long, linear features such as utility corridors) intersect nearly every major habitat type on the Cherokee National Forest, numerous additional species could occur based upon habitat affiliation, however they are not included in this analysis. This is because only previously managed openings are being considered (i.e. no new openings are being created within intact forest communities), and even within those existing openings, proposed management is focused primarily on woody or non- native plant species. Species considered in this analysis are shown below in Table 11. Plant Species Sixteen Regional Forester’s Sensitive plant species were found to be either coincident or proximal to existing managed openings during the data analysis phase for this project. Some of these species may benefit from the open habitat conditions, while others simply occur in adjacent unaffected habitats and were included in this analysis based on proximity. Because the existing openings (especially long, linear features such as utility corridors) intersect nearly every major habitat type on the Cherokee National Forest, numerous additional species could occur based upon habitat affiliation, however they are not included in this analysis. This is because only previously managed openings are being considered (i.e. no new openings are being created within intact forest communities), and even within those existing openings, proposed management is focused primarily on woody or non-native plant species. Any rare plant species currently found within these existing openings would very likely benefit from such management, and any rare plant species that may occur in an intact, natural habitat nearby, would not be affected. Species considered in this analysis are shown below in Table 11. Aquatic Species There are 27 aquatic Sensitive species in this analysis area. No effects would occur to Aquatic Habitats, Sensitive Species, Demand Species, or Viability Concern Species because there would be no increase above current levels of sedimentation or herbicide. Current levels of sedimentation and herbicide usage are not having adverse effects based on monitoring (Cherokee National Forest 2013). Species considered in this analysis and the determinations of effect for each are shown below in Table 11.

Table 11. Effects Determinations for Regional Forester’s Sensitive Species Common Name Scientific Name Alt A Alt B Alt C Peregrine falcon Falco peregrinus 2 2/3 2/3 Migrant loggerhead shrike Lanius ludovicianus migrans 2 2/3 2/3 Diana fritillary Speyeria diana 1 2/3 2/3

Table 11. Effects Determinations for Regional Forester’s Sensitive Species Common Name Scientific Name Alt A Alt B Alt C Rafinesque’s big-eared bat Corynorhinus rafinesquii 1 2/3 2/3 Eastern small-footed bat Myotis leibii 1 2/3 2/3 Pirate bush Buckleya distichophylla 1 2/3 1 Roan Mountain sedge Carex roanensis 1 1 1 Riverbank bush-honeysuckle Diervilla rivularis 1 2/3 1 Bent avens Geum geniculatum 1 1 1 White-leaved sunflower Helianthus glaucophyllus 1 2/3 2/3 Maple-leaved alumroot Heuchera longifolia var aceroides 1 1 1 Mountain St. Johns wort Hypericum graveolens 1 2/3 2/3 Blue Ridge St. John’s wort Hypericum mitchellianum 1 2/3 2/3 Gray’s lily Lilium grayii 1 2/3 2/3 Fraser’s loosestrife Lysimachia fraseri 1 2/3 1 Pigmy pipes Monotropsis odorata 1 1 1 Nevius’ stonecrop Sedum nevii 1 1 1 Clingman’s hedge-nettle Stachys clingmanii 1 2/3 2/3 Ash-leaved bush pea Thermopsis fraxinifolia 1 2/3 2/3 Southern nodding trillium Trillium rugelii 1 1 1 Carolina hemlock Tsuga caroliniana 1 1 1 Carolina mountain dusky Desmognathus carolinensis 1 2 2 salamander Santeetlah dusky salamander Desmognathus santeetlah 1 2 2 Junaluska salamander Eurycea junaluska 1 2 2 Tennessee dace Phoxinus tennesseensis 1 2 2 sharphead darter Etheostoma acuticeps 1 2 2 holiday darter Etheostoma brevirostrum 1 2 2 wounded darter Etheostoma vulneratum 1 2 2 mountain brook lamprey Ichthyomyzon greeleyi 1 2 2 blotchside logperch Percina burtoni 1 2 2 bronze darter Percina palmaris 1 2 2 olive darter Percina squamata 1 1 1 sickle darter Percina williamsi 1 1 1 fatlips minnow Phenacobius crassilabrum 1 2 2 Helma's net-spinning Cheumatopsyche helma 1 2 2 caddisfly Cherokee clubtail Gomphus consanguis 1 2 2 green-faced clubtail Gomphus viridifrons 1 2 2 mountain river cruiser Macromia margarita 1 2 2 Smokies needlefly Megaleuctra williamsae 1 2 2 Allegheny snaketail Ophiogomphus incurvatus 1 2 2 alleghaniensis Edmund's snaketail Ophiogomphus edmundo 1 2 2 Tennessee heelsplitter Lasmigona holstonia 1 2 2 green floater Lasmigona subviridis 1 2 2

Table 11. Effects Determinations for Regional Forester’s Sensitive Species Common Name Scientific Name Alt A Alt B Alt C Tennessee clubshell Pleurobema oviforme 1 2 2 Tennessee pigtoe Pleuronaia gibberum 1 2 2 Alabama creekmussel Strophitus connasaugaensis 1 2 2 Alabama rainbow Villosa nebulosa 1 2 2 Coosa creekshell Villosa vanuxemensis umbrans 1 2 2

1= No impact; 2=May impact individuals but not lead to a trend toward federal listing or loss of viability; 3=Beneficial effect

Existing Condition Demand Species

Terrestrial Species

Black Bear (MIS) The black bear (Ursus americanus) uses a wide variety of habitats in the southern Appalachians, occurring primarily on national forests and national parks of the Southern Blue Ridge, Northern Cumberland, and Allegheny Mountains and the Northern Ridge and Valley. These public lands in Virginia, West Virginia, North Carolina, Tennessee, and Georgia connect to form a forested landscape of over six million acres where bears are generally distributed at low to medium densities. The increase of older oak forests in this large block of habitat, along with increased protection and conservative hunter harvest, has allowed bear populations throughout the southeastern mountain region to moderately increase over the past 30 years. Tennessee’s black bear population is estimated at 1,000 to 1,500 animals, half of which may occupy the CNF. Bait station survey data and legal harvest data indicate a significant population increase since 1980 (USDA 2004b). In the southern Appalachians, including the CNF, important habitat elements are habitat remoteness, habitat diversity, den site availability, and availability of hard mast. Black bears are opportunistic omnivores and consume a variety of seasonal plant and animal foods including flowering plants, grasses, various roots and tubers, and especially soft mast (grapes, berries, apples, etc.). However, availability of hard mast (acorns and hickory nuts) is critical throughout the winter, and reproductive success is closely related to this habitat factor. Total production of hard mast and production by individual trees can fluctuate from year to year due to climatic and other factors (USDA 2004b). Bears den in a wide variety of sites including road culverts, abandoned buildings, and in vegetation. Traditional dens are found on the ground in caves, rockfalls, or under the root mass of uprooted trees, and in hollow trees. Some researchers have found that hollow trees are preferred dens. Others have found that ground dens are preferred in the North Carolina mountains. Preference may be related to availability and may be a learned behavior (USDA 2004b). Availability of potential den trees on the CNF is augmented by a forest wide standard requiring their retention during all vegetation management treatments. For this reason, the black bear was

70 selected as an MIS to help indicate management effects on meeting hunting demand for this species.

Aquatic Species There are 17 aquatic demand (Game and Introduced/Desirable) fish species that have been documented within the analysis area (Table 12). The number of populations for each watershed is shown.

Table 12 Distribution of Demand Species Across the Analysis Area Watershed Con Ocoee Hiw L Tn Pigeon Fr Br Nol Wat S Hol Totals Alabama bass 3 0 0 0 0 0 0 0 0 3 bluegill 4 7 18 15 1 5 3 5 5 63 brook trout 0 0 0 20 0 8 51 58 37 174 green sunfish 4 10 18 6 1 1 2 1 2 45 largemouth bass 3 7 8 6 1 1 2 0 2 30 longear sunfish 4 4 5 2 0 0 0 0 0 15 redbreast sunfish 4 6 23 7 1 4 4 0 0 49 redear sunfish 1 1 7 1 0 1 1 0 0 12 redeye bass 6 4 2 0 0 0 0 0 0 12 rock bass 0 18 33 17 1 3 4 1 3 80 shadow bass 6 0 0 0 0 0 0 0 0 6 smallmouth bass 3 9 20 17 1 4 3 2 3 62 spotted bass 0 4 7 5 1 2 3 0 1 23 spotted sunfish 1 0 0 0 0 0 0 0 0 1 warmouth 0 1 0 1 0 0 1 0 0 3 brown trout 0 4 20 29 1 12 1 25 15 107 rainbow trout 4 27 36 75 2 27 53 42 47 313 Totals 43 102 197 201 10 68 128 134 115 998

Direct and Indirect Effects Demand Species

Alternative A (No Action)

Terrestrial Species Black Bear (MIS) The No Action Alternative would not change the vegetative diversity or components of the openings. Black bear utilize shrub/sapling stage vegetation to varying degrees. Forest-wide population trends should not be affected given current population data, bear reserves (protection from hunting), and that habitat diversity management is occurring on other parts of the Forest.

Aquatic Species There will be no direct impacts to Demand Species from alternative A since no activities will occur in stream channels. Indirect effects to aquatic organisms arise from activities authorized outside the stream channel that allow sediment or herbicide to enter and alter aquatic habitats.

Alternative A proposes no new ground disturbing or herbicide activities, however, routine mechanical activities would occur on all existing openings, as would activities authorized through other decisions. No direct or indirect effects would occur to Demand Species because there would be no increase above current levels of sedimentation or herbicide. Current levels of sedimentation and herbicide usage are not having adverse effects based on monitoring (Cherokee National Forest 2013) and adhere to Forest Plan standards. Alternative B (Proposed Action) and C

Terrestrial Species Black Bear Openings benefit black bear by providing soft mast and cover. The addition of structural and biological diversity in the form of shrub/sapling vegetation and grassy areas would provide soft mast, insects, forage, and escape cover. Soft mast-producing species (dogwood, black gum, hawthorn, grapes, serviceberry, etc.) would be retained during openings treatments to the extent possible, within constraints of meeting treatment objectives. Soft mast and other forage is a valuable diet supplement to black bears, especially during the months when hard mast is absent and in years when there is a hard mast failure. Those that would grow naturally after harvest, such as blackberries, would provide this. Negative effects would be a temporary increase in human disturbance during project implementation. Disturbance disrupts movement patterns affecting feeding and mating. Treatments would occur in areas that are already treated on a regular basis, therefore no additional disturbance is foreseen. The use of prescribed fire is designed to restore these plant communities to a more natural species assemblage, and would likely have a long-term beneficial effect on bears. With Alternative C, there would be no habitat improvements in the utility corridors.

Aquatic Species There will be no direct impacts to Demand Species from alternative B (Proposed Action) or C since no activities will occur in stream channels. Ground disturbances and herbicide treatments associated with a combination of manual, cultural, and chemical control treatment methods across the National Forest would follow Forest Plan standards and limit impacts to soil and water resources to acceptable levels. Forest Plan Standards (USDA Forest Service 2004a) were designed to protect the most susceptible aquatic species (trout) from harmful levels of sediments. There will be no indirect or cumulative impacts to Demand Species. Cumulative Effects Demand Species

Alternative A (No Action)

Terrestrial Species Black Bear (MIS) There would be no additional cumulative effects to black bears from alternative A. No additional work would be completed and no additional habitat would be gained or lost.

Aquatic Species Cumulative effects are the sum of indirect effects plus those affects resulting from past, present and reasonably foreseeable activities not proposed by any of these alternatives. The cumulative effects of sediment and herbicides on aquatic demand species are the same as the effects discussed in the Aquatic Habitats section. Alternative A would not involve any ground disturbance or herbicide treatments. Cumulative effects would be no greater than those associated with past, present and reasonably foreseeable activities. Alternative B (Proposed Action) and Alternative C

Terrestrial Species Black Bear (MIS) With Alternative B, beneficial cumulative effects to black bears would result due to the increase of habitat on the utility lines with the use of herbicides. With Alternative C, none of these improvements would occur.

Aquatic Species There would be no cumulative effects to any aquatic demand species. Ground disturbances and herbicide treatments associated with a combination of manual, cultural, and chemical control treatment methods across the National Forest would follow Forest Plan standards and limit impacts to soil and water resources to acceptable levels. Forest Plan Standards (USDA Forest Service 2004c) were designed to protect the most susceptible aquatic species (trout) from harmful levels of sediments. There will be no cumulative impacts to Demand Species from either action alternative. Existing Condition Non-native Invasive Plants and Animals

A multitude of non-native invasive plant species threaten the integrity of native ecosystems in the southern Appalachian area. The Southern Appalachian Assessment (SAMAB 1996) provided a summary of the major threats to southern Appalachian forests from non-native invasive species and much of this information has been revised and updated in the recent Southern Forest Futures Project (USDA Forest Service 2013). In 1999 President Clinton issued Executive Order 13112 on invasive species which among other things, states that federal agencies shall “not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species in the United States or elsewhere unless, pursuant to guidelines that it has prescribed, the agency has determined and made public its determination that the benefits of such actions clearly outweigh the potential harm caused by invasive species; and that all feasible and prudent measures to minimize risk of harm will be taken in conjunction with the actions.” Also in 1999, the Southern Region released a Noxious Weed Management Strategy that outlined five emphasis areas, 1) Prevention and Education, 2) Control, 3) Inventory, Mapping, and Monitoring, 4) Research, and 5) Administration and Planning. This was followed in 2001 with the development of the Regional Forester’s Invasive Exotic Plant Species list for Region 8 and in 2004 with a national strategy for invasive species management (USDA Forest Service 2004d). The Revised Land and Resource Management Plan (USDA Forest Service 2004a) includes numerous Goals, Objectives, and

Standards to address the potential impacts of non-native invasive species. These include control efforts and maintenance and restoration of native species. On the Cherokee National Forest, the following non-native invasive plant species are tracked through project level inventories: Tree of heaven (Ailanthus altissima), small carpetgrass (Arthraxon hispidus), autumn olive (Eleagnus umbellata), English ivy (Hedera helix), sericea lespedeza (Lespedeza cuneata), privet (Ligustrum sinense), Japanese honeysuckle (Lonicera japonica), Nepal grass (Microstegium vimineum), princess tree (Paulownia tomentosa), kudzu (Pueraria lobata), and multiflora rose (Rosa multiflora). While other non-native invasive plant species may occur with scattered distributions on the Forest, these species are recognized as having substantial occurrences with a high potential for impacts to native communities on the Forest. Because they often occur in areas of disturbance, non-native invasive plant species are abundant within managed openings on the forest. Nepal grass (Microstegium vimineum), autumn olive (Eleagnus umbellata), sericea lespedeza (Lespedeza cuneata), bicolor lespedeza (Lespedeza bicolor), multi-flora rose (Rosa multiflora), and fescue (festuca arundinacea), are a particular problem along linear and spot wildlife openings across the forest. Wildlife generally does not use Nepal grass, thus the plant is likely having an adverse effect on wildlife habitat within the project area. Japanese honeysuckle (Lonicera japonica) is one of the most widespread weeds in southern forests and is likely present in almost every area where actions are proposed. Infestations of numerous other invasive species are surely found within some of the managed openings. The proposed action states that utility companies shall be required to submit annual operating plans indicating proposed areas of treatment and associated methods. Part of the approval of these plans shall be the requirement that prior to any equipment being brought onto the forest to manage vegetation, equipment shall be washed and free of any non-native plant propagules. Although not mentioned in the SAA, the wild boar (Sus scrofa) is another example of non-native species that is negatively affecting certain habitats (beech forests and wetlands) in the southern Appalachians (USDA 2004b). Wild boars were introduced into the southern Appalachian Mountains in the early 1900’s. Originally imported for hunting, they eventually escaped from their enclosed hunting reserves in North Carolina and over time have become a naturalized component of the area’s fauna (USDA 2004b). Management of this species is somewhat controversial in that some hunters desire it as a major game species, yet its impacts to the natural environment must be considered. Direct and Indirect Effects Non-native Invasive Plants and Animals

Alternative A (No Action) Under the No Action Alternative, routine mechanical activities would continue to occur on all existing openings, as would activities authorized through other decisions. Herbicide use is currently authorized on 116 acres of Fort Loudoun Electric Cooperative administered utilities in Monroe County and 56 acres of Tennessee Valley Authority administered utilities in Polk County along with administrative sites and non-native invasive plant sites. No new management activities would be approved under this alternative. The southern Forest Futures Project (USDA Forest Service 2013) provides projected annual rates of spread (absent control programs) for numerous high-priority invasive plant species in southern forests. These range from a low rate of

74 an average of just over 50 acres per year across the southeast for Oriental bittersweet, to an average rate of over 60,000 acres per year for Japanese honeysuckle. If alternative A were chosen, there would be no change in effect to, or from, invasive plant species, over their baseline rates of spread. Specific actions to treat invasive plant infestations on highest priority acres may occur within the project area under other authorities, and such treatments would be considered under cumulative impacts. There would be no effects to wild boar. Alternative B (Proposed Action) and Alternative C

Alternative B would implement the proposed action which includes the use of herbicides specifically targeted at non-native invasive species within managed openings. While utility companies, specifically, are not required to complete any management beyond what their permit stipulates, it would be in their benefit to specifically manage non-native invasive plant occurrences within their rights of way. Treatment of non-native invasive plant species is occurring forest-wide on the basis of prioritized acres. If an infestation within the project area meets the criteria of highest priority acres for treatment as outlined in the forest wide environmental assessment (USDA Forest Service 2008) it would be treated accordingly, however this alternative would also authorize treatment of invasive plants within managed openings and may open up opportunities for sites to be treated using other fund sources than those typically used for the “highest priority acre” treatments. Potential introduction and spread of new species would be mitigated through the use of equipment washing as described above. The southern Forest Futures Project (USDA Forest Service 2013) provides projected annual rates of spread (absent control programs) for numerous high-priority invasive plant species in southern forests. These range from a low rate of an average of just over 50 acres per year across the southeast for Oriental bittersweet, to an average rate of over 60,000 acres per year for Japanese honeysuckle. Mitigations that are a part of this proposal, and possible future treatments, should work together to slow the spread of these species. No effects to wild boar are expected. Cumulative Effects Non-native Invasive Plants and Animals

The southern Forest Futures Project (USDA Forest Service 2013) provides an excellent summary of the various impacts non-native invasive plant species are having within southern forests. Projected annual rates of spread (absent control programs) for numerous high-priority invasive plant species are provided. These range from a low rate of an average of just over 50 acres per year across the southeast for Oriental bittersweet, to an average rate of over 60,000 acres per year for Japanese honeysuckle. Alternative A (No Action)

Past, present and reasonably foreseeable activities are listed in the project environmental assessment. No new project activities would be implemented under this alternative, though many other routine and ongoing activities may occur within the project area. Treatment of non- native invasive plant species is occurring forest-wide on the basis of prioritized acres. If an infestation within the project area meets the criteria of highest priority acres for treatment as

75 outlined in the forest wide environmental assessment (USDA Forest Service 2008) it would be treated accordingly. Cumulatively, Forest Service actions are intended to slow the spread of these species on the landscape. Despite best efforts, weed species continue to spread. Dispersal mechanisms are wide and varied and only some are within the control of land managers. It is hoped that the mitigating efforts described above would result in cumulative benefits over time.

No effects to wild boar are expected. Alternative B (Proposed Action) and Alternative C This alternative would implement the proposed action. Invasive plants occur throughout much of the project area along roads, trails, and other disturbed sites, and they rapidly colonize newly disturbed habitats when seed sources are nearby. The Cherokee National Forest is currently treating non-native invasive species on high priority acres through an environmental assessment that was completed in June of 2008 (USDA Forest Service 2008). The action is intended to slow the spread of these species on the landscape. Despite best efforts, weed species continue to spread. Dispersal mechanisms are wide and varied and only some are within the control of land managers. It is hoped that any treatments that would occur as a result of implementing this alternative combined with the mitigating efforts described above would result in cumulative benefits over time. No effects to wild boar are expected. Existing Condition Viability Concern Species

Species of viability concern typically include threatened and endangered species, regional Forester Sensitive species, and other species for which viability is of concern in the planning area. Threatened, endangered and sensitive species are discussed above under separate headings. As described in the previous sections, threatened and endangered species, and Regional Forester’s Sensitive Species are certainly species for which viability is a concern, however, this section specifically addresses those additional species that may be rare on the landscape but are not afforded protective status under either of the previous two categories. The Revised Land and Resource Management Plan (RLRMP) for the Cherokee National Forest (USDA Forest Service 2004c) contains a standard (FW-28) that states that forest managers have responsibility to maintain occurrences of species that are necessary to maintain viable populations of these species on the Forest. Appendices E and F to the Final Environmental Impact Statement for the RLRMP (USDA Forest Service 2004b) lists species of viability concern known or predicted to occur on the Forest.

Numerous plant and wildlife species of viability concern were found to be either coincident with, or proximal to managed openings during the analysis phase of this proposed project. There are two Locally Rare aquatic species; the smoky dace occurs only in the Little Tennessee watershed and the southern brook lamprey only occurs in the Conasauga Watershed. Information on occurrence for each terrestrial wildlife and plant species is provided below in Table 13, followed by effects analyses.

Table 13: Viability Concern Plant and Wildlife Occurrence Locations by Topo-Map Quadrangle Quad TES Species Coincident/proximal with Location Notes Name Opening Oswald Mammal-Neotoma floridana haematoreia Near opening off of FSR 5050 Dome Parksville Plant-Agalinis plukenetii, Between dam and marina Ducktown Plant-Thermopsis mollis LWO (FSR 117701) Farner Plant-Symplocos tinctoria LWO (FSR 311A) Bald River Plant-Menziesia pilosa Fort Loudon electric to Falls Waucheesi Big Plant-Carex ruthii Whigg Meadow Junction Bird-Vermivora chrysoptera Mecca Mammal-Neotoma floridana haematoreia Starr Mountain near opening off of FSR 220 White Oak Plant-Trichomanes petersii LWO (FSR 5022) Flats Mammal-Neotoma floridana haematoreia Near opening off of FSR 59 Waterville Plant-Chrysogonum virginianum LWO (FSR 5141A) Mammal-Neotoma floridana haematoreia Utility line near Green Corner Road Lemon Gap Plants-Heracleum maximum LWO (FSR 96B) Birds- Pooecetes gramineus Max Patch opening Sams Gap Plant-Heracleum maximum Opening along AT at Lick Rock Bald Creek Plant-Packera schweinitziana, Sibbaldiopsis Openings along AT at Big Bald tridentata, Platanthera psycodes and Big Stamp Davy Plant-Pedicularis lanceolata, Caltha Cutshall Bog Crockett palustris Lake Greystone Plant-Epilobium ciliatum Along AT at Coldspring Mtn Bald Carvers Plants-Hieracium scabrum, Packera Roan Mountain Gap schweinitziana, Streptopus roseus, Minuartia groenlandica, Menziesia pilosa, Alnus viridus ssp crispa, Sibbaldiaopsis tridentata, Platanthera psycodes Bird - Pooecetes gramineus Unicoi Plant-Cardamine rotundifolia Erwin Utilities along 107 near Rocky Branch Iron Plant-Platanthera orbiculata, Corydalis Opening between Little Rock Mountain sempervirens Knob and Strawberry Mtn, Gap LWO (FSR 53322), LWO (FSR 53222)

Table 13: Viability Concern Plant and Wildlife Occurrence Locations by Topo-Map Quadrangle Quad TES Species Coincident/proximal with Location Notes Name Opening White Plant-Carex manhartii, Carex ruthii, LWO (FSR 53302), LWO off Rocks Mtn Hieracium scabrum, Brachyelytrium FSR 293, LWO (FSR 50A), aristosum, LWO (FSR 53024), LWO(FSR 530211) Elizabethto Plant-Abies fraseri (planted) Old homesite opening along AT n Watauga Plant-Cardamine rotundifolia, Carex ruthii, Old homesite opening along Dam Carex bromoides ssp. montana AT, LWO (FSR 303) Elk Mills Plant-Cypripedium reginae Transmission line at Pine Knob Watauga Lake Keensburg Plant-Goodyera repens Bristol Essential Services line at Hatcher Creek off FSR 251 Carter Plant-Corallorhiza maculata, Pyrola Transmission lines near Low americana, Gap, Bristol Essential Services Line at Holston Mountain Doe Plants-Platanthera orbiculata, vaccinium Openings near Cross Mtn off macrocarpon TN 91, LWO (FSR 60151) Bird- Pooecetes gramineus Shady Plants-Melanthium latifolium, Goodyera LWO (FSR 60802, LWO (FSR Valley repens, 69B) Bird-Pooecetes gramineus Laurel Plant-Platanthera orbiculata, Platanthera LWO (FSR 4052), LWO (FSR Bloomery grandiflora, Cymophyllus fraseri, Corydalis 60451), Transmission line south sempervirens of Backbone Rock LWO = Linear Wildlife Opening. FSR = Forest Service Road.

Direct and Indirect Effects Viability Concern Species

Alternative A (No Action) Under the No Action Alternative, routine mechanical activities would occur on all existing openings, as would activities authorized through other decisions. Herbicide use is currently authorized on a limited number of acres. No new management activities would be approved under this alternative. Based upon this, choosing Alternative A would have no new effects to any Viability Concern plant, wildlife or aquatic species. There will be no direct impacts to aquatic species since no activities will occur in stream channels. No indirect effects would occur to aquatic species because there would be no increase above current levels of sedimentation or herbicide. Current levels of sedimentation and herbicide usage are not having adverse effects based on monitoring (USDA Forest Service 2013). Based upon this, choosing Alternative A would have no new effects to any Viability Concern species.

Alternative B (Proposed Action) Under alternative B the activities listed under the proposed action would be implemented. Many of the viability concern plant species likely benefit to some degree from the open habitat conditions provided in the managed openings or around their edges, while several others (Carex ruthii, Trichomanes petersii, Streptopus roseus, Cardamine rotundifolia, Carex bromoides ssp. montana, Corallorhiza maculata, Pyrola americana, Goodyera repens, Cymophyllus fraseri, Melanthium latifolium, and Platanthera orbiculata ) simply occur in adjacent unaffected habitats and were included in this analysis based on proximity to an existing opening.

The vesper sparrow and golden-winged warbler require grassy shrubby openings for nesting and foraging. Implementation of this alternative would benefit the bird. Herbicide use is intended to allow the Forest wildlife openings to become more native plant based which would provide better foraging and nesting habitat. This alternative also allows the use of herbicides in utility corridors which have not generally been maintained in a native grassy/shrubby understory, the exception being the lines in Monroe County and a portion of the lines in Polk County. Transforming the acreage of the remaining utility lines into this type of habitat would enhance vesper sparrow and golden-winged warbler habitat preferences greatly. The woodrat is adapted to several communities. It largely falls under the category of occurring in unaffected habitats and is included in the analysis based on proximity to an opening. It does however use openings such as rocky areas or wet areas that may be categorized as openings. Therefore this alternative will benefit the woodrat by maintaining and enhancing these special habitats through the use of chemicals or other vegetation manipulation.

Most of these openings have been under management for many years and the plant species have become established and persist at the sites with the current regime of mechanical treatments. The proposed use of herbicides in this alternative would target non-native, invasive species and/or woody species that threaten to encroach and change the open character of these habitats, and as such should not have any negative effects on viability concern plant species, though it is always possible that limited damage to individuals could occur through unintended drift. In fact, targeted use of herbicides around some of these rare plant locations should benefit them in the long-term by ensuring open conditions on which these species depend. Forest plan standards regarding the use of herbicides remain in effect throughout this proposal and further reduce the chance of any negative effects on rare plant species. Additionally, species such as Hieracium scabrum, Packera schweinitziana, Minuartia groenlandica, and Sibbaldiopsis tridentata occurring within the balds at Roan Mountain, Cypripedium reginae at Pine Knob, vaccinium macrocarpon in Shady Valley or other bogs, and Pedicularis lanceolata and Caltha palustris at Cutshall Bog, are further protected through additional management prescriptions (4K and 9F) that ensures all management at these sites is designed to perpetuate and preserve the species and their habitats.

Controlled burning is proposed as a potential tool for openings management within this alternative, though there are many constraints on its application so it is not as likely to be used on a broad scale as some of the other methods. As described above under the section on Regional Forester’s Sensitive Plant Species, many of these species that occur in open areas have some affinity to fire and often occur in fire prone habitats (Pistrang 2013). Despite this, there would always be some chance of limited damage to individuals if a prescribed fire burned too hot in the

79 proximity of one of these species location. Prescribed fire has been discussed as a possible management tool on Roan Mountain in the past, but has never been proposed there on any continuing basis. Any use of prescribed fire on Roan Mountain would first be evaluated by the interagency group that is involved in the management and monitoring of rare species on the Roan. Likewise, the use of fire in any other opening that is a natural rare community would be further evaluated for its potential effect on the species present before being implemented.

There would be no indirect or cumulative effects to any aquatic species. Reddington (2015) analyzed the proposed actions and determined the ground disturbances and herbicide treatments associated with a combination of manual, cultural, and chemical control treatment methods across the National Forest would follow Forest Plan standards and limit impacts to soil and water resources to acceptable levels. Forest Plan Standards (USDA Forest Service 2004a) were designed to protect the most susceptible aquatic species (trout) (USDA Forest Service 2004b pp 285-288) from harmful levels of sediments or herbicides. There will be no indirect effects to aquatic Viability Concern Species from alternative B.

Based upon the above, the implementation of Alternative B would likely have either neutral or beneficial effects on Viability Concern Species. Alternative C Under alternative C effects to viability concern species are similar to those described for alternative B. Although the benefits would not be as great for the vesper sparrow or golden- winged warbler without the addition of the utility line habitat. Cumulative Effects for Viability Concern Species

Alternative A (No Action) Under this alternative there are no anticipated direct or indirect effects, and thus there would be no incremental contribution to cumulative effects to these species from this alternative. All of these species are designated as species for which viability is of some concern, primarily due to historic land use resulting in habitat alterations. Previous actions have likely led to the declines, however ongoing protection on public lands is serving to stabilize populations. Populations of viability concern species located on private lands may be susceptible to future declines dependent upon landowner agreements to protect the species. Alternative B (Proposed Action) Under this alternative, anticipated direct or indirect effects are primarily neutral or beneficial for most species, or limited to the possibility of impacts to individual plants. In all cases, any populations that are present would be expected to remain viable, and thus there would be no incremental contribution to cumulative effects to these species from this alternative. Forest Service policy is to maintain viability for these species on the planning unit, thus protected sites on federal lands remain the primary sites for conservation for many of these species. Sites not occurring on protected lands remain susceptible to future declines. No cumulative effects would arise from the implementation of this alternative. Alternative C Under this alternative the cumulative effects are the same as those described for Alternative B.

Social/Economic Factors ______Scenery and Recreation Resources Existing Condition

The affected environment is limited to existing grassy, herbaceous and shrubby openings currently maintained throughout the national forest. Scenic overlooks, wildlife spot openings, wildlife linear openings and utility corridors are different types of openings that directly or indirectly impact recreation opportunities and settings. Currently, there are fourteen developed scenic overlooks along the Ocoee Scenic Byway and Cherohala Skyway that provide travelers with unobstructed views to the surrounding mountains. In more remote areas of the forest, spot wildlife openings often serve as sightseeing and backcountry destinations. These high elevation mountain balds and fields afford visitors with panoramic views and sometimes serve as backcountry campsites. Several of these openings are maintained along the Appalachian National Scenic Trail. Figures 4 and 5 are photographs from two overlooks and are examples of these types of openings. Figure 4 Sugarloaf Overlook view, Ocoee Scenic Byway

Figure 5. Beauty Spot, Appalachian National Scenic Trail & Unaka Mountain Road

National Forest System (NFS) roads that have been closed to public motor vehicle use year round or opened temporarily for seasonal hunting access are frequently managed as linear wildlife openings. An example is shown in Figure 6. These linear openings provide miles of designated and undesignated backcountry trails suitable for equestrian, bicycle and foot travel. Over the years, the majority of new NFS trails designed for equestrian use have been constructed for the purpose of connecting closed or seasonally opened NFS roads to form desired complexes and riding opportunities. Figure 7 depicts a spot opening.

Figure 6. An existing linear wildlife opening that functions as a backcountry trail

Figure 7. An existing wildlife opening that affords views to surrounding mountains

Utility Corridors – Several utility corridors traverse the National Forest to extend services to facilities within the National Forest and adjacent communities. The U.S. Forest Service

83 cooperates with the providers to reduce the potential negative visual impacts commonly associated with utility corridors. Measures have typically been taken to minimize the appearance of lines, colors, forms and textures that contrast with the surrounding natural appearing landscapes. Figure 8 displays an area with cleared woody vegetation and soil disturbances within a corridor that creates noticeable contrasts with the natural appearing landscape. These initial impacts fade after one or two growing seasons. Figure 9 displays an example of retention or regrowth of woody vegetation within utility corridors that helps reduce contrasts and makes the corridors less noticeable. Figure 8. Cleared woody vegetation and soil disturbances within a corridor create noticeable contrasts with the natural appearing landscape.

Figure 9. Retention or regrowth of woody vegetation within utility corridors helps reduce contrasts and makes the corridors less noticeable

Scope of Analysis

The scope of analysis for social factors is limited to consequences of maintaining existing openings within the Cherokee National Forest using the various options described for each alternative. The impacts that immediately follow implementation are disclosed with the assumption that these effects would be the most noticeable or consequential to visitors, i.e. viewing unseasonal loss of foliage or being exposed to applied herbicides. Because these openings require routine maintenance, these effects would be reoccurring on an annual or perennial basis as needed to achieve vegetation management objectives. The expected changes or alterations to affected Scenery Resources are described in terms of being consistent or inconsistent with the Scenic Integrity Objectives (SIOs) as specified in the RLRMP for each management prescription and inventoried scenic class. As per the USDA Scenery Management System (USDA 1995a), SIOs set the thresholds or limitations for creating alterations to the existing natural appearing landscapes. These alterations are typically a direct result of implementing actions such as silvicultural treatments, wildlife habitat improvements, road construction, prescribed fire, etc. Proposed actions would be considered consistent with SIOs if they would meet the following descriptions within one to two growing seasons after implementation to the extent practicable:

VERY HIGH – The valued landscape character remains intact with only minute if any deviations. The sense of place is expressed at the highest possible level. HIGH – Deviations created by humans (such as proposed silvicultural treatments, road construction, prescribed fire, etc.) may be present but repeat the form, line, color, texture and pattern common to the landscape character so completely and at such scale that they are not evident and the landscape appears unaltered. MODERATE - Noticeable deviations created by human alterations remain visually subordinate to the natural appearing landscape being viewed and create only a slightly altered appearance. LOW – Noticeable deviations created by human alterations begin to dominate the landscape being viewed but they borrow valued attributes such as size, shape, edge effect and patterns of natural openings and vegetative type changes. Alterations create only a moderately altered appearance. (USDA 1995 p. 2-4) Design Criteria have been developed as part of the proposed actions to minimize potential negative impacts to the recreating public and scenic integrity. The disclosure of effects is based on the assumption that these measures would be implemented as needed. Direct and Indirect Effects Scenery and Recreation Resources

Alternative A (No Action)

Under Alternative A (No Action) the maintenance of existing openings would not change. The use of herbicides would be limited to developed facilities, Fort Loudoun Electric Cooperative (FLEC) a portion of a line of Polk County administered by Tennessee Valley Authority and the control of non-native invasive species (NNIS) outside of congressionally designated Wilderness. All other existing grassy, herbaceous and shrubby openings would be maintained through mechanical means.

Scenic Overlooks – The fourteen existing scenic overlooks located along the Ocoee Scenic Byway and Cherohala Skyway would be maintained in their open condition through the use of mechanical means unless NNIS were present. Overlooks areas would continue to be cleared when vegetation enclosed or obstructed the desired views. Woody vegetation would then be cut back leaving residual slash within the immediate foreground, but typically out of plain sight downslope from affected viewpoints. Overlooks with grass in the immediate foreground would continue to be mowed and trimmed. The improved views would be consistent with achieving assigned HIGH SIOs and the objectives for management prescription 7.A, Scenic Byway Corridors.

Spot Wildlife Openings - In the absence of NNIS, these openings would continue to be maintained through mechanical means such as mowing and chainsaw work. Visitors would continue to enjoy these unique places within the national forest and the views afforded by the openings. However, there would be opportunities to encounter the active management of the openings throughout the growing seasons. They would possibly hear or see work crews, tractors, chainsaws and other equipment being used to maintain the openings. They would also view recently cut woody vegetation on the ground, but these effects would noticeably decrease after

86 one growing season. In some instances, visitors would be inconvenienced if trails or roads were temporarily closed when management activities occurred, i.e. prescribed burning (Figure 10). Actions would continue to be consistent with meeting assigned SIOs ranging from LOW to VERY HIGH.

Figure 10. Signed temporary trail closure for prescribed burn area

Linear Wildlife Openings – With the exception of treating NNIS, these openings would be maintained through mechanical means only. Seeding would continue to provide the desired forage. Unless posted otherwise, recreational use of these openings would continue without restrictions. Activities would include, but would not be limited to, hunting, berry picking, hiking, biking and equestrian use. Clearing vegetation on approximately 25-feet of each side of linear openings, commonly referred to as day-lighting, would continue as planned. Residual slashed down woody vegetation would be visible within the immediate foreground of affected openings, but would not be noticeable after one or two growing seasons (Figure 11). Actions would continue to be consistent with meeting assigned SIOs ranging from LOW to VERY HIGH.

Figure 11. Linear wildlife opening that has been “daylighted” by mechanical means

Utility Corridors - With the exception of FLEC utility corridors and a small portion of a Tennessee Valley Authority line in Polk County and treatment of NNIS, utility corridors would continue to be maintained by mechanical means only. The visual impacts of maintaining these corridors would remain varied across the national forest. In general, the typical direct and linear routing of utilities would continue to impose cleared corridors across the Forest in a manner that contrasts with the natural lines, forms, colors and textures of their surrounding landscapes. These contrasts would continue to be noticeable over time, but more so immediately after clearing vegetation (Figures 12, 13 and 14).

Figure 12. Recent changes to color and texture due to soil disturbance on Chilhowee Mountain made this corridor more noticeable from distances nearly 20 miles away

Figure 13. The retention of woody debris within the corridor would be unattractive within the immediate foreground, but would effectively minimize color and texture contrasts when viewed from greater distances

Figure 14. Grassy and herbaceous cover also effectively reduces the contrasts of linear corridors and helps blend them into the affected landscapes

Figure 15. The recent cutting off the tops of mature trees underneath existing utilities along the Ocoee Scenic Byway (US Highway 64) reduced scenic integrity and is inconsistent with achieving the assigned HIGH SIO

Figure 16. Existing utility corridors at Doc Rogers Fields are less noticeable because the crisscrossed utility lines and surrounding open fields visually reduce the linear nature of a typical corridor.

In general, most visual impacts caused by maintaining utility corridors would be noticeable for only one or two growing seasons after clearing vegetation. Downed woody vegetation and shredded mulch would rapidly begin to decay and become less visible. These actions would be consistent with achieving SIOs LOW to VERY HIGH.

However, the negative visual effects created by mechanically exposing bare soil or topping and shearing trees within utility corridors would remain on the landscape for more than one or two growing seasons. These effects would continue to be inconsistent with achieving assigned SIOs ranging from MODERATE to VERY HIGH (Figure 15). Actions to improve scenic integrity would include recovering and revegetating areas with noticeably disturbed soils and reshaping or removing topped and sheared trees. Design Criteria would address these types of impacts to make future actions more consistent with SIOs (Figure 16).

FLEC Utility Corridors – FLEC has been using herbicides to maintain utility corridors within the Forest for nearly 10 years (Figure 17). The use of herbicides would continue to temporarily decrease the scenic integrity of affected areas to various degrees based on the season and scale of treatments. The unseasonal loss of foliage due to applications in the months of June, July and August when vegetation is growing and at its greenest would be the most noticeable to visitors. Applications during the preceding spring months of March, April and May would be less noticeable, especially at high elevations when the forest vegetation is still in the process of leafing out.

As the growing season wanes in late August and the colors of foliage naturally begin to change, the visual effects of herbicide treatments would be less noticeable. Any dead and dying

92 vegetation resulting from herbicide applications would not be noticeable during the leaf-off, winter months of December, January and February.

The use of herbicides versus mechanical treatment of woody vegetation would reduce opportunities to create the impacts with longer durations. Soils would not be exposed when applying herbicides and trees would not reach sizes that would require them to be topped or sheared in the future (Figure 18). The applications of herbicides would continue to be consistent with achieving SIOs ranging from LOW to VERY HIGH.

Figure 12. Utility corridor managed by herbicides and mechanical means

Figure 13. This utility corridor has been treated with herbicides without creating noticeable soil disturbances

NNIS Control & Eradication - Presently, the most noticeable use of herbicides to control NNIS has been the treatment of invasive kudzu along forest roads (Figures 19 and 20). Over the last several years, kudzu patches along the Tellico River, Hiwassee River, French Broad River and other areas have been aggressively treated to reclaim native vegetation. The scenic integrity of the affected areas is temporarily decreased due to the appearance of dead and dying vegetation. However, the management actions are consistent with achieving all assigned SIOs because native vegetation is being restored, which is a component of the desired landscape character and future condition.

Figure 14. Invasive patch of Kudzu along forest road in 2008

Figure 5. The same area in 2011 after being treated with herbicide

Alternative B (Proposed Action) Proposed actions in Alternative B would expand the use of herbicides to include existing linear wildlife openings, spot wildlife openings and fourteen scenic overlooks located on the Ocoee Scenic Byway and Cherohala Skyway. FLEC and a small portion of TVA utility corridors and NNIS outside of congressionally designated Wilderness would continue to be treated with herbicides. Methods of application would be:  Foliar, where the foliage of the individual plant to be controlled is sprayed;  Basal (streamline), where the herbicide is sprayed onto the individual stem of the plant to be controlled;  Cut surface, where the herbicide is applied to an axe-chop in the stem (hack and squirt), or to the freshly sawn stump.

As described for the use of herbicides within FLEC corridors, herbicide use would temporarily decrease scenic integrity of affected areas to various degrees based on the season and scale of treatments. The unseasonal loss of foliage during the summer months would be the most noticeable to visitors. Spring treatments would also be noticeable but to a lesser extent because untreated vegetation would be in various stages of leafing out. Changes in the colors of foliage due to herbicide applications would blend most successfully in the fall and extend through the winter months. For this reason, Design Criteria would recommend that the application of herbicides occur in August and September whenever practicable to limit unseasonal visual impacts. Any vegetation that was hacked prior to herbicide applications would be noticeable for one to two growing seasons.

Scenic Overlooks – The fourteen existing scenic overlooks located along the Ocoee Scenic Byway and Cherohala Skyway would be maintained in their open condition through the use of both mechanical and chemical means. The selective use of herbicides would allow managers to control woody vegetation on an annual basis before it encloses or obstructs views. The proper

95 application of herbicides would be safer than operating chainsaws, trimmers and mowers on the steep side slopes typically associated with overlooks. This would result in less down woody debris within the immediate foreground. Actions would be consistent with achieving HIGH SIOs and the objectives for management prescription 7.A. Scenic Byway Corridors.

Spot Wildlife Openings - Spot openings would be maintained in their open conditions through the use of mechanical and chemical means. This would include the applications of herbicides to maintain several mountain balds and fields that receive recreational use, especially along the Appalachian National Scenic Trail. Design Criteria would be implemented to inform the visitors that herbicides have been applied in the area. This would potentially affect more than 20 developed trails. Communications would include posting appropriate signage at trail junctions and coordinating with organized trail user groups.

Overall, the use of herbicides would be consistent with achieving the SIOs ranging from LOW to HIGH. Visitors would continue to enjoy these unique places within the national forest and the views afforded by the grassy, herbaceous and shrubby openings.

Linear Wildlife Openings – These openings would be maintained in their open condition through the use of mechanical and chemical means. Seeding would continue to occur to provide the desired benefits to wildlife. Unless posted otherwise, recreational use of these openings would continue without restrictions. Activities would include, but are not limited to, hunting, berry picking, hiking, biking and equestrian use. Design Criteria would be implemented to inform the visitors that herbicides have been applied in the area. This would potentially affect approximately 35 trails, primarily equestrian trails. Communications would include posting appropriate signage at trail junctions and coordinating with organized trail user groups.

Planned day lighting, which includes clearing vegetation on approximately 25-feet of each side of linear openings, would continue as planned. Residual slashed down woody vegetation would be visible in the immediate foreground of affected openings, but would not be noticeable after one or two growing seasons. Actions would be consistent with achieving assigned SIOs ranging from LOW to VERY HIGH.

Utility Corridors – The effects would be the same as described for Alternative A (No Action) for utility corridors. The use of herbicides for managing vegetation within utility corridors would be limited to FELC corridors.

Alternative C Alternative C would be the same as Alternative B in regard to the use of herbicides to manage vegetation at Scenic Overlooks, Spot Wildlife Openings and Linear Wildlife Openings. The effects for these types of existing openings would be the same as described for Alternative B.

Utility Corridors – Alternative C would allow for other utility providers besides FLEC to utilize approved herbicides to manage vegetation within utility corridors. The effects described for Alternative A (No Action) related to FLEC’s use of herbicides would be expanded across the national forest and consistent with achieving SIOs ranging from LOW to VERY HIGH. Opportunities to create impacts of longer duration such as soil disturbances and the topping trees

96 would be reduced forest-wide. Restoration of native vegetation would be consistent with the desired landscape character.

There are more than 30 developed trails that intersect utility corridors at one or multiple locations across the Forest (Figure 21). Design Criteria would be implemented to require utility providers to inform visitors that herbicides have been applied in the vicinity of these trails and corridors. Communications would include posting appropriate signage at corridor access points and trail junctions and notifying organized trail user groups.

The preferred timing for herbicide applications would be August and September if practicable. These types of actions would be specified by the utility providers in their operating plans as requested by the U.S. Forest Service.

Figure 6. Trails that transect utility corridors are typically encroached by early successional vegetation and require clearing during the growing season. Most trail users would come in contact with the vegetation

Cumulative Effects Scenery and Recreation Resources

All Alternatives Other management actions related to utility corridors such as the maintenance or improvement of support structures could potentially impact scenic integrity and recreation opportunities. The removal of several structures and utility lines that once crisscrossed the Ocoee River several years ago increased scenic integrity within the river gorge. However, along the Hiwassee River, recent work to improve support structures resulted in making the structures more noticeable due to the addition of newer, brighter materials (Figure 22). Although these initial impacts are expected to fade over time, the impacts would be visible for several years.

Figure 7 New structural materials recently added to existing utility poles along the Hiwassee River have increased the visibility of the structures and utility corridor within the landscape

No reasonably foreseeable management actions affecting utility lines and vegetation would result in cumulative effects inconsistent with achieving SIOs ranging from LOW to VERY HIGH. Proposed management of vegetation for purposes other than creating or maintaining openings for overlooks, wildlife openings or utility lines would not result in permanently maintained openings. Within approximately 15 to 20 years, most of these created openings would be reforested with an enclosed canopy. Changes to scenery due to natural processes would be expected over time. The succession of vegetation and disturbances caused by fire, insects, disease, and storms would continue to alter the appearance of landscapes and create new openings in addition to those being maintained within the Forest. For example, a recent wildfire caused by a downed electric utility line on Chilhowee Mountain altered the appearance of scenery as viewed from the Ocoee Scenic Byway and Parksville Lake. These new landscape patterns created by disturbance events would continue to be noticeable but would naturally blend with the surrounding landscapes. The affected scenery would remain consistent with achieving SIOs. Cultural Resources Existing Condition

Cultural resources can be defined as physical evidence or a place of past prehistoric or historic human activity and can consist of a site, object, landscape, or structure. A cultural resource can also be a site, structure, landscape, object or natural feature that has significance to a group of people traditionally associated with it. Cultural resources are non-renewable. Ground disturbance associated with such activities as vegetation management and road construction can damage or destroy the historical, cultural, or scientific integrity of cultural resources. Federal laws and regulations require that significant cultural resources are identified and protected from adverse effects

Direct and Indirect Effects Cultural Resources

Alternative A (No Action) This alternative would have no direct or indirect effects on cultural resources. Alternative B (Proposed Action) and Alternative C All areas proposed for treatment that involve ground disturbance would be subjected to cultural resource inventory and evaluation prior to treatment and a determination of effect will be submitted to the Tennessee SHPO for review, comment and concurrence. Consultation with the ten federally recognized Cherokee and Muscogee (Creek) Tribes would also be conducted. Alternatives B and C would receive a determination of no effect to cultural resources if: no historic properties are identified during inventory; or historic properties are identified but are determined to not be eligible for the National Register of Historic Places (NRHP); or historic properties that are potentially eligible for inclusion in the NRHP are identified but are avoided during project implementation.

Cumulative Effects Cultural Resources

Alternatives A, B (Proposed Action) and Alternative C There are no known cumulative effects under any alternative.

Civil Rights Direct, Indirect and Cumulative Effects

None of the alternatives would have disproportionate adverse health or environmental impacts to minority groups, women, or low-income populations. It is difficult to assess the degree of impact each alternative presents to these groups due to other variables. The best information suggests that when assessing the effects of each alternative on minority and low-income groups, the effects are minimal and not disproportionate to these groups when compared to other groups. Physical Factors Soil and Water Resource Existing Condition

Soils Project Area Soils. Soils derived from sandstone, phyllite, and shale parent materials dominate the mountainous relief of the CNF. Minor soil areas have developed from other kinds of rocks such as limestone, granite, quarzite, gneiss, schist, and slate. The many kinds of soil differ in physical and chemical properties such as texture, depth, rock content, relief, acidity, plant nutrients, and available moisture. The differences in the erodability and stability of these soils vary with steepness of slope and amount and kind of vegetative cover, and amount and timing of soil disturbance.

In general, most of the soils across the project area may be described as deep and moderately deep, well-drained, either formed in place above the parent material (residuum) or transported down a slope (collivium). Broadly speaking, project area soils are strongly leached, highly weathered, old, acid, and have definite horizon development and low native fertility (ultisols). A smaller portion of the soils, particularly those on steep, exposed upper and side slopes, are recently formed with no horizon development (entisols) or are very mildly weathered with some horizon development (inceptisols). Existing forest openings proposed for maintenance as part of this project are generally located on soils that are somewhat compacted. Wildlife Openings are often located on old logging roads or log landings. Overlooks are frequently located on the fill slope of roads. Utility corridors are compacted by the equipment used to construct and maintain them. Many different soil series were inventoried and classified during soil survey mapping within the project area boundaries. This information was derived from an analysis of existing GIS map and attribute data. Forested soils have not been mapped to the same precision as agricultural soils, an action which has resulted in soil complexes that include multiple soils. A comprehensive list of project area soil map units are presented in Appendix 4. The most common soil map units found across the project area are Junaluska fine sandy loam, Junaluska-Brasstown complex, Junaluska-Citico complex, and Junaluska-Tsali complex. These four map units comprise 18% of the project area. Ditney soils comprise 12% of the project area. All other map units comprise less than 5% of the project area, each. The relative abundance of project area soil series are presented in Appendix 5. Junaluska soils developed in metasedimentary geology, which can contribute to several soil concerns. These soils formed in residuum that is affected by soil creep in the upper part of the soil profile, and is weathered from metasedimentary rocks including phyllite, slate, and metasandstone. Permeability is moderate in Junaluska soils. Depth to weathered bedrock is 20 to 40 inches. Channer-size rock fragments (flat, 1-2 inches in length) up to 35% by volume can be found in the subsoil material. This volume of rock can impose challenges in soil and/or site management. Surface soil texture is fine sandy loam. Subsoil texture is sandy clay loam and fine sandy loam in loam. Ditney soils occur on mountain slopes. These soils developed in loamy residuum and/or creep deposits derived from metasedimentary rock. The natural drainage class is well drained. Water movement in the most restrictive layer is high. Available water to a depth of 60 inches is very low. Depth to weathered bedrock is 20 to 40 inches. Channer-size rock fragments (flat, 1-2 inches in length) up to 5% by volume can be found in the subsoil material. Subsoil texture is sandy clay loam. Although loams are the most common soils in the project area, soils with higher clay and sand content may occur on ridgetops and valley bottoms. The texture of a soil (the amount of sand, silt, and/or clay) influences its water holding capacity and drainage speed. The drainage speed in turn affects the movement or storage of chemicals that may enter the soil. Soils that are well- drained with normal permeability are preferred for vegetative growth and commonly found across the project area. If a chemical is in the water and enters a sandy soil, the soil may quickly drain the water and chemical. Sandy soils typically have low runoff and high leaching potential.

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On the other hand, clay enriched soils hold water very tightly, so tight in fact, that plant roots often cannot access it. Clay soils typically have high runoff and low leaching potential. Clay soils may become waterlogged and anaerobic, and plant roots in this situation will not have adequate soil gas exchange and will effectively drown. If a chemical is applied to a waterlogged soil it may run offsite during a heavy or prolonged precipitation event. If a chemical is applied to a clay soil that is not waterlogged, it may become bound along with the water in the soil and persist on a site for longer than anticipated. It could also run off in heavy or prolonged precipitation events. Soils that contain more than 30% clay in the surface are not common on the forest, only covering at most 1% of the total acreage. Soils heavy in clay are often found deeper in the profile beneath the surface horizon. This fact underscores the importance of minimizing erosion of the surface horizon, or topsoil, so that clay subsoils are not exposed. Clay soils on the CNF are often found in borrow or spoil areas, where the topsoil has been removed. The organic matter found in a sandy or clay enriched soil will alleviate some of the drainage characteristics. The amount of organic matter from the litter layer that has been incorporated into the soil will decrease the drainage speed in a sandy soil, and will increase the drainage speed in a clay enriched soil. Furthermore, organic matter has a chemical exchange potential, or the ability to capture and exchange certain chemical elements in the soil water. Sandy soils on the CNF are found on the landscape extremes: on exposed sandstone ridges where the soil is thin and highly weathered, and in valley bottoms along streams. Ironically, the same landscape positions may also have soils that are high in clay content. Sandstone ridgetops may have pockets of soils with comparatively higher clay content, which will drain water much slower than sandy or silty soils. More often, clay influenced soils are found in stream bottoms and terraces, where they may be waterlogged for all or part of the year. Erosion Potential of Project Area Soils. A primary management concern on project area soils is the potential for erosion from ground disturbance, particularly removal of protective vegetation cover. Timely attention to maintenance of mitigation measures designed in the ground disturbance areas is required to protect soils function and achieve project objectives. Best Management Practices shall be used to mitigate erosion, compaction or slope creep caused by project activities. Erosion is defined as a process where soil and rock-particles detach from the land and transport over an area by wind, water, gravity, ice, and chemical action (Keller et al., 2011). Forested soil erosion is affected by rainfall erosivity (amount and intensity), soil erodibility (infiltration capacity and structural stability), topography (slope percent and length), and vegetative cover (Brady and Weil, 2002). Erosion potential of a soil increases with:  Increasing rainfall amount and intensity Rain is the primary erosive force acting on the soil. The longer and harder it rains, the higher the potential for the soil to become detached and flow downhill.  Decreasing soil infiltration capacity and structural stability Soil infiltration capacity and structural stability can be negatively affected by compaction. Areas that have been disturbed by human activities, such as roads and log landings, often have very compacted soils.  Increasing slope percent and length

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As a slope gets steeper and longer, the potential of soil detachment increases as does the opportunity for concentration of the runoff water.  Decreasing vegetation cover on the slope Vegetation reduces erosion in several ways: it reduces the amount of water flowing over the surface by intercepting it on the foliage, stems, and surface organic matter; it inhibits channel formation, which reduces the rate and slope of soil movement; and soils with small particles can be held together by roots and fungal strands (Oliver & Larson, 1996). The large majority of the project area soils do not have high natural erosion potential as long as the vegetative cover and litter layer remain intact. Based on soil characteristics and management experience, the following soils were identified as soils of concern with respect to erosion potential related to ground disturbing activities:  Ranger  Citico  Sylco  Brasstown  Cataska  Junaluska On these soils of concern, erosion potential of disturbed areas becomes severe on slopes greater than 35%. Most of the damage to these soils can be minimized by not conducting ground disturbing activities on steep slopes. The percentage of project area soils of concern occurring on slopes greater than 35% was evaluated by intersecting the project area soils map with a slope classification based on a 10m DEM in GIS. This analysis revealed that approximately 0.05% of the soils in the analysis area can be characterized as soils of concern on steep slopes. When avoidance is not an option, all disturbed surfaces on soils of concern with a slope greater than 15% shall be mulched as well as seeded, in accordance with project-specific design criteria. Soil microbial community, chemistry, and plant-soil feedback. To this point, the project area soils have been described by their physical attributes. Another important aspect of the soils across the project area is their relationship with the plant community that grows on them. An area of soil should be thought of as an entire environment that includes a community of microbes and other inhabitants that serve to break down and transform the soil into available nutrients for plant growth. Nutrient availability is highly influenced by microbial activity and other chemical parameters, particularly pH. Many nutrients taken up by plant roots are first cycled through a soil organism before becoming available to the plant. In fact, natural biological processes in the soil are responsible for about 60% of the available nitrogen and 50% of the available phosphorus in the soil (Follett, 1995). The soil microbial community and the chemical environment of the soil directly affect the type, density, and diversity of the plants that can grow on it. When a plant loses its leaves and/or dies, it will decompose and affect the soil by adding organic matter, which can stimulate microbial activity, change the soil nutrient availability, change the soil water availability, affect the soil pH, and change the soil structure, among other things. The cycle between plants and soil is known as a plant-soil feedback (van der Puttin et al., 2013). As young forests mature across the CNF, the native condition of the plant-soil feedback is negative. A positive plant-soil feedback would favor only one species, whereas a negative plant-

102 soil feedback encourages diversity of species. A diverse plant community tends to encourage a soil environment that includes beneficial and harmful organisms, and those plant species that can adapt to the environment will survive and reproduce. On native forest communities in the CNF, plant and soil diversity is comparatively high.

Water The CNF spans 75 6th Level Watersheds. Under Alternatives B and C project activities would occur in 59 of these watersheds. Project activities would occur on less than 1% of the land in each watershed (Appendix 6). The CNF contains about 2900 miles of perennial streams, and including five major Tennessee Valley Authority (TVA) reservoirs, over 16,000 acres of lakes and other permanent surface water bodies. The land adjacent to the stream network is called the riparian zone. The zone is functionally defined as a three-dimensional ecotone of interaction that includes both terrestrial and aquatic ecosystems. The riparian zone often acts as filter that buffers out upslope sediment, nutrients, and chemicals. This zone is important in reducing the effects of vegetation management. The riparian corridor associated with perennial and intermittent streams on CNF is estimated to be 126,000 acres. Riparian ecosystems are generally maintained in a healthy condition, and are in a later seral stage of forest development. Where present, roads and dispersed recreation use are the primary impacts to riparian areas. Project activities would occur in the riparian corridor in 60 of the project area watersheds. Project activities would occur on less than 0.9% of the FS owned riparian corridor in each watershed (Appendix 7). All waters within the Cherokee National Forest are classified as Exceptional Tennessee Waters (TDEC 2013), consequently no degradation that threatens the designated uses of these waters is permitted. Water quality is generally good, and meets quality criteria established by the state of Tennessee. Some of the larger rivers flowing through the CNF proclamation boundary are listed on the state of Tennessee’s 303d list as partially or fully impaired. These include all or part of the Ocoee, Hiwassee, Pigeon, Nolichucky, and Doe Rivers. In each case, the cause of the impairment is due to sources located off of national forest (NFS) lands or is due to water withdrawals for TVA power generation. Approximately 16 miles of perennial streams or waterbodies on the CNF are within or immediately adjacent to open areas that would be managed as part of this project. The maximum stream/shoreline length within or immediately adjacent to proposed treatment areas for any given 6th level watershed is 1.58 miles (Nolichucky River – Clark Creek). With the exception of unnamed tributaries in the Nolichucky River – Clark Creek watershed, no individual waterbody is in or immediately adjacent to the areas proposed for management for longer than 1 mile (Appendix 8). Management Direction

Regulatory Framework The regulatory framework providing direction and guidance for protection of water quality/quantity and a soil’s inherent capacity and productivity comes from the principle sources below:

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 Clean Water Act Section 319 (nonpoint source water pollution). The pollutants related to this proposal include herbicide and sediment.  Executive Orders 11990 and 11988 – Floodplains and Wetlands  Forest Service Manual - Section 2500  Multiple-Use Sustained-Yield Act of 1960  National Forest Management Act of 1976  Forest Service Handbook - FSH 2509.18-2003-1, Region 8 Soil Quality Standards  Forest Service - Region 8 Soil and Water Conservation Practices (SWCPs) Handbook, 2003  Tennessee Best Management Practices (BMPs) (TDF 2003 or most recent revision)  All Forest Standards (USDA Forest Service. 2004. Revised Land and Resource Management Plan for the Cherokee National Forest). Those listed below are particularly applicable to Soil and Water resources and the actions included in this proposal. Project-Specific Design Criteria  Based on soil characteristics and management experience, the following soils were identified as soils of concern with respect to erosion potential related to ground disturbing activities: o Ranger o Citico o Sylco o Brasstown o Cataska o Junaluska

 When avoidance is not an option, all disturbed surfaces on soils of concern with a slope greater than 15% shall be mulched as well as seeded.  Root raking and/or strip disking are not to be prescribed on sustained slopes greater than 35% or on slopes greater than 20% with soils of concern (as identified in the existing condition section, above). Mowing may occur on any slope where the equipment can be operated safely.  Mechanical treatments shall not be prescribed for openings or portions of openings that fall within the streamside management zone. Direct and Indirect Effects Soil and Water Resource

Methodology

Treatments analyzed. There are seven treatments proposed to manage open areas. Not all treatment methods have the potential to affect soil and water. Treatment methods were categorized according to soil and water effects, which allowed for better organization of effects analysis (Table 14).

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Table 14. Categorization of treatment methods according to soil and water effects

No Effects To Soil Potential And Effects To Soil Treatment Water And Water Notes

Chainsaw Work X No Soil Or Water Disturbance

Manual X Effects Expected To Be Minimal Based On Annual Maximum Spatial Extent

Planting (Broadcast or Seed X Effects Expected To Be Drilling) Minimal Based On Annual Maximum Spatial Extent

Mowing X

Mechanical (Root Raking & X Strip Disking)

Herbicide X

Prescribed Fire X

Road Maintenance X

For effects analysis treatments were divided into three categories:

1. Treatments that will have no effect on soil and water quality 2. Treatments that will have minimal potential effects on soil and water quality due to the annual maximum spatial extent treated 3. Treatments that will have potential effects on soil and water quality Approach, rationale, and assumptions. Since soil and water are two of the requisites for the growth of any plant, then it is reasonable to assume that both would be affected by methods to reduce or eradicate a particular group of plants. The goal of this effects analysis was to quantify the acceptable risk to soil and water when deploying specific treatments.

Resource elements analyzed include water quality and soil quality. The potential for the treatment to affect either of these elements was based on various indicators. For water quality three indicators were analyzed: 1.) change in sediment delivery, 2.) change in water quality from herbicide, and 3.) change in the quality and effectiveness of the native riparian communities. For

105 soil quality three indicators were analyzed: 1.) change in erosion potential, 2.) change in soil quality from herbicide, and 3.) change in soil microbial and decomposer community from herbicide (Table 15).

Table 15. Resource Indicators and Measures for Assessing Effects Resource Element Resource Indicator Measure Water quality Change in sediment delivery Change in erosion potential Water quality Change in water quality from Literature review on herbicide herbicide environmental fate; herbicide persistence in water; herbicide half-life in water Water quality Change in the quality and Anticipated change in riparian areas effectiveness of native riparian communities Soil quality Change in erosion potential Change in soil exposure Soil quality Change in soil quality from Literature review on herbicide herbicide environmental fate; herbicide mobility and persistence in soil; herbicide half- life in soil Soil quality Change in soil microbial and Literature review and risk assessment decomposer community literature; change in plant-soil feedback from herbicide or excluding herbicide

Spatial and Temporal Context for Effects Analysis. The spatial extent of analysis for direct and indirect effects to soils is limited to the area proposed for management. The spatial extent of analysis for direct and indirect effects to water resources shall include NFS lands in the watersheds where treatments are proposed. The time period for the cumulative effects analyses is the past 10 years. Research demonstrates that the majority of direct and indirect effects on soils recover, post treatment, to baseline or near-baseline levels within this timeframe. Additionally, sediment delivered to the stream network should have worked its way through the system within this timeframe. The cumulative effects analysis also considers future activities in the next five years since this timeframe coincides roughly with USFS out-year planning. Alternative A (No Action) If Alternative A is implemented, then there would be no change from existing soil or water quality conditions, including changes to sediment delivery potential or changes to water quality from herbicide.

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Alternative B (Proposed Action)

Treatments that will have no effect on soil and water quality. Manual cutting is unlikely to have any effect on soil and water resources. This method would not disturb the soil or result in nutrient or chemical runoff into streams, lakes, or groundwater. In addition, this method would have very limited annual forest-wide spatial extent based on implementation capacity

Treatments that will have minimal potential effects on soil and water quality due to the annual maximum spatial extent treated. Manual weed pulling will have minimal effects due to the annual maximum spatial extent treated. There could be some localized erosion but the following design criteria would offset the potential for measurable soil and water quality effects:

 FW-5: DISTURBED AREAS REQUIRING RE-VEGETATION AND/OR MULCHING FOR EROSION CONTROL WILL BE TREATED ON AN ONGOING BASIS DURING THE ACTIVITY.

Planting a diverse mixture of native plants or desired non-native plants that includes shrubs, grasses, and herbaceous plants via broadcast seeding or no-till drills would have a beneficial effect soil microbial diversity via the plant-soil feedback relationship. Treatments that will have potential effects on soil and water quality. Five treatments have the potential to affect soil and water quality: mowing, mechanical, herbicide, prescribed fire, and road maintenance. Mowing. No soil disturbance is associated with mowing, however the use of tractors to pull mowing equipment would contribute to keeping the soil in these areas compacted, which in turn affects water infiltration and runoff characteristics. Mechanical treatments. Mechanical treatments such as root raking and strip disking could potentially affect the soil quality by changing the erosion potential, which in turn could affect a change in sediment delivery to water. A change to the erosion potential could be caused by two things: 1.) compaction of the soil from wheeled and tracked vehicles and 2.) removal of the vegetation and exposure of the soil by uprooting, disking, and plowing. This treatment would be used on larger, relatively open areas that commonly have a history of prior soil disturbance, such as overgrown fields, pastures, roadsides, and wildlife openings. These sites often have compacted soils on shallow slopes. If a site has compacted soils and has a mechanical treatment prescription, then the specific treatments of uprooting, disking, or plowing would be preferred from a soil and water perspective. If implemented, then these treatments would alleviate compaction while concurrently meeting the purpose and need of this project. Minimizing the use of heavy equipment on clay soils would minimize additional soil compaction. When a mechanical treatment is prescribed for a site that has compacted soils, the preferred treatment from a soil and water perspective would be uprooting, disking, or plowing, followed by prompt re-vegetation.

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If mechanical treatments occur on areas with shallow slopes, then a change in erosion potential would not be likely given the project design criteria. Even if vegetation is removed from a steeper area and soil is exposed, the project design criteria (including BMPs) would offset the potential for soil and water quality effects. Project-specific design criteria are listed below:  FW-4: WATER CONTROL STRUCTURES SUCH AS WATERBARS AND DIPS NEEDED TO CONTROL SURFACE WATER MOVEMENT FROM NEWLY DISTURBED SITES WILL BE CONSTRUCTED DURING THE ACTIVITY.  FW-5: DISTURBED AREAS REQUIRING RE-VEGETATION AND/OR MULCHING FOR EROSION CONTROL WILL BE TREATED ON AN ONGOING BASIS DURING THE ACTIVITY.  Root raking and strip disking is not to be prescribed on sustained slopes greater than 35% or on slopes greater than 20% with soils of concern (as identified in the existing condition section, above). Mowing may occur on any slope where the equipment can be operated safely.  Mechanical treatments shall not be prescribed for openings or portions of openings that fall within the streamside filter zone as defined by FW-3. If mechanical treatment is deployed as part of this project, then a measurable change in erosion potential should not occur. If a change in erosion potential does not occur, then a change in sediment delivery would not occur, thereby causing no direct or indirect effects to water quality. The spatial and temporal scale of this treatment should also be kept in perspective. It is estimated that annually, less than 25% of the project area would be treated using mechanical ground disturbing methods. Thus in any given year, such activity would occur on less than 0.25% of the CNF. Prescribed fire. Prescribed fire could potentially affect the soil quality by changing the erosion potential, which in turn could affect a change in sediment delivery to water. When burning a steep slope, there would be the possibility that the fire could get too hot and burn off the protective litter layer, which would cause exposed mineral soil. The creation of fire lines would also expose mineral soil. If mineral soil is exposed on a steep slope, then erosion potential increases. If erosion occurs, then the potential for stream sedimentation increases. The CNF has historically used prescribed fires to achieve different objectives, such as species reduction, species enhancement, and fuels reduction. These prescribed burns are carefully planned and monitored to create low temperatures and flame heights so that soil and water resources are protected. The following design criteria would offset the potential for soil and water quality effects:

 FW-18: WHEN PREPARING FOR PRESCRIBED FIRE, USE WET LINES, BLACK LINES OR HAND LINES WITHIN THE CHANNELED EPHEMERAL STREAM ZONE AND ACROSS EPHEMERAL CHANNELS TO MINIMIZE SOIL DISTURBANCE. USE WATER DIVERSIONS TO KEEP SEDIMENT OUT OF THE STREAM CHANNEL. REMOVAL OF LITTER AND DEBRIS FROM THE CHANNEL IS PERMISSIBLE. DO NOT CONSTRUCT FIRELINES IN CHANNELS, BUT THEY MAY BE USED AS NATURAL FIREBREAKS.

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 FW-19: DO NOT PLOW FIRELINES WITH HEAVY MECHANIZED EQUIPMENT (E.G. BULLDOZERS AND TRACTORS) IN CHANNELED EPHEMERAL ZONES WHEN PREPARING FOR PRESCRIBED FIRE.

 FW-88: WHERE NEEDED TO PREVENT SOIL EROSION, WATER DIVERSIONS ARE BUILT INTO FIRELINES SURING THEIR CONSTRUCTION, OR WHEN IMMEDIATELY REASONABLE TO DO SO. FIRELINES ARE RE-SEEDED AND IN SENSATIVE AREAS REHABILITATED IMMEDIATELY AFTER THE FIRE IS CONTROLLED.

 RX11-13: CONSTRUCTION OF FIRELINES FOR PRESCRIBED FIRE WITH HEAVY MECHANIZED EQUIPMENT (E.G., BULLDOZERS) IN WETLANDS, SMZ AND RIPARIAN CORRIDORS IS MINIMIZED.

 RX11-14: HAND LINES ARE USED TO CREATE FIRELINES NEAR STREAMS TO MINIMIZE SOIL DISTURBANCE. WATER DIVERSIONS ARE USED TO KEEP SEDIMENT OUT OF STREAMS. FIRELINES ARE NOT CONSTRUCTED IN STREAM CHANNELS, BUT STREAMS MAY BE USED AS FIRELINES.

Applicable TDF Skid Trail BMPs (modified for application to dozer line) include:

 Locate dozer lines on grades of 2 to 30 percent (preferably less than 20%). Steeper grades are acceptable for short distances only if adequate water control/drainage structures are provided. Runoff from dozer lines should not discharge into a stream.  Control runoff from dozer lines using such techniques as varying trail grade (rolling dips), water bars, wing ditches and/or sediment control structures.  Do not operate dozers in streams.  Avoid installing a dozer line directly up or down hill; slant the course, follow the contour or use a “zigzag” pathway, if possible.  Upon completion of burning remove sediment and debris from dips and revegetate potential problem areas.  Use mulch, and/or seed with appropriate amounts of lime and fertilizer when needed to prevent soil erosion. Recommendations concerning lime and fertilizer are available from University of Tennessee Agricultural Extension Service county offices.  Avoid ruts that risk channeling water into a stream.  Firelines that are needed for frequent or regular burning cycles are best designed and maintained on the landscape to provide for both long term use and ability to control concentrated flow and erosion by employing relatively permanent drainage dips, reverse grades, out-sloping and lead-off ditches along with reinstalling and maintaining of other erosion control measures when not used. These measures should be implemented when constructing fireline for recurring prescribed burns.

If prescribed fire is deployed as part of this project, then a change in erosion potential would not be likely. If a change in erosion potential does not occur, then a change in sediment delivery would not occur, thereby causing no effects to water quality. The spatial and temporal scale of this treatment should also be kept in perspective. It is estimated that annually, less than 25% of

109 the project area would be treated using prescribed fire. Thus in any given year, such activity would occur on less than 0.25% of the CNF as part of this project. Herbicide. A change in erosion potential or sediment delivery should not occur with the use of herbicides because herbicides would be directly applied to the target plants using spot treatment (foliar, basal, or cut surface). When spot treatment of herbicide is employed, large patches of total vegetation removal that would result in exposed mineral soil would be unlikely. If mineral soil is not exposed, then erosion potential and sediment delivery should remain unchanged. If large patches of vegetation are eradicated through the use of herbicide, then the remaining plant residue should arrest any soil movement. Furthermore, if an area is especially bare following herbicide treatment, the following design criteria would offset soil and water effects:

 FW-5: DISTURBED AREAS REQUIRING RE-VEGETATION AND/OR MULCHING FOR EROSION CONTROL WILL BE TREATED ON AN ONGOING BASIS DURING THE ACTIVITY.

Herbicide applications to control competing vegetation do not disturb the topsoil layer, do not create additional bare soil, and do not adversely affect watershed condition when used responsibly (Neary and Michael 1996). By utilizing herbicides as opposed to mechanical methods, the soil organic matter is left in place, and off-site soil movement does not increase the loss of nutrients following harvest activities. Maxwell and Neary (1991) concluded that the impact of vegetation management techniques on erosion and sediment losses occurs in this order, herbicides < fire < mechanical. A SERA risk assessment for each of the herbicides proposed for use as part of this project is available on the forest service website (http://www.fs.fed.us/foresthealth/pesticide/risk.shtml). Each of these risk assessments models a scenario where herbicide is spilled directly into water. Frequently, the human health and ecological risks associated with this scenario are unacceptable while the risks associated with normal use fall within the acceptable range. Mixing the appropriate concentration of herbicide in water is the most common time during which an herbicide spill could occur. Cleaning of equipment and disposal of excess mix are also activities that could result in contamination of water resources if not conducted appropriately. Thus, the CNF relies on forest plan standards related to where mixing, cleaning, and disposal are allowed to prevent a direct spill to water.

FW-16: PESTICIDE MIXING, LOADING, OR CLEANING AREAS ARE NOT LOCATED WITHIN THE CHANNELED EPHEMERAL STREAM ZONE.

FW-77: A CERTIFIED PESTICIDE APPLICATOR SUPERVISES EACH FOREST SERVICE APPLICATION CREW AND TRAINS CREW MEMBERS IN PERSONAL SAFETY, PROPER HANDLING AND APPLICATION OF HERBICIDES, AND PROPER DISPOSAL OF EMPTY CONTAINERS.

FW-82: APPLICATION EQUIPMENT, EMPTY HERBICIDE CONTAINERS, CLOTHES WORN DURING TREATMENT, AND SKIN ARE NOT CLEANED IN OPEN WATER

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OR WELLS. MIXING AND CLEANING WATER MUST COME FROM A PUBLIC WATER SUPPLY AND BE TRANSPORTED IN SEPARATE LABELED CONTAINERS.

FW-84: HERBICIDE MIXING, LOADING, OR CLEANING AREAS IN THE FIELD ARE NOT LOCATED WITHIN 200 FEET OF PRIVATE LAND, OPEN WATER OR WELLS, OR OTHER SENSITIVE AREAS.

Herbicide use could potentially affect soil and water quality in the project area depending on the effects to the riparian communities, the soil microbial and decomposer community, and the environmental fate of the chemical used. A change in the quality and effectiveness of the riparian communities could potentially occur with the use of herbicide. All herbicide applications would comply with the following design criteria:

FW-14: SOIL-ACTIVE HERBICIDES ARE NOT BROADCAST WITHIN CHANNELED EPHEMERAL STREAM ZONES. SELECTIVE TREATMENTS WITH AQUATIC- LABELED HERBICIDES MAY OCCUR WITHIN THIS ZONE FOLLOWING SITE- SPECIFIC ANALYSIS. STREAM ZONES ARE IDENTIFIED BEFORE TREATMENT, SO APPLICATORS CAN EASILY AVOID THEM.

FW-15: NO HERBICIDE IS AERIALLY APPLIED WITHIN 200 HORIZONTAL FEET, NOR GROUND APPLIED WITHIN 30 HORIZONTAL FEET, OF LAKES, WETLANDS, OR PERENNIAL OR INTERMITTENT SPRINGS AND STREAMS. NO HERBICIDE IS APPLIED WITHIN 100 HORIZONTAL FEET OF ANY PUBLIC OR DOMESTIC WATER SOURCE. SELECTIVE TREATMENTS (WHICH REQUIRE ADDED SITE- SPECIFIC ANALYSIS AND USE OF AQUATIC-LABELED HERBICIDES) MAY OCCUR WITHIN THESE BUFFERS ONLY TO PREVENT ENVIRONMENTAL DAMAGE SUCH AS NOXIOUS WEED INFESTATIONS. BUFFERS ARE CLEARLY MARKED BEFORE TREATMENT SO APPLICATORS CAN EASILY SEE AND AVOID THEM.

FW-72: HERBICIDES AND APPLICATION METHODS ARE CHOSEN TO MINIMIZE RISK TO HUMAN AND WILDLIFE HEALTH AND THE ENVIRONMENT. NO CLASS B, C, OR D CHEMICAL MAY BE USED ON ANY PROJECT, EXCEPT WITH REGIONAL FORESTER APPROVAL. APPROVAL WILL BE GRANTED ONLY IF A SITE-SPECIFIC ANALYSIS SHOWS THAT NO OTHER TREATMENT WOULD BE EFFECTIVE AND THAT ALL ADVERSE HEALTH AND ENVIRONMENTAL EFFECTS WILL BE FULLY MITIGATED. DIESEL OIL WILL NOT BE USED AS A CARRIER FOR HERBICIDES, EXCEPT AS IT MAY BE A COMPONENT OF A FORMULATED PRODUCT WHEN PURCHASED FROM THE MANUFACTURER. VEGETABLE OILS WILL BE USED AS THE CARRIER FOR HERBICIDES WHEN AVAILABLE AND COMPATIBLE WITH THE APPLICATION PROPOSED.

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FW-73: HERBICIDES ARE APPLIED AT THE LOWEST RATE EFFECTIVE IN MEETING PROJECT OBJECTIVES AND ACCORDING TO GUIDELINES FOR PROTECTING HUMAN (NRC 1983) AND WILDLIFE HEALTH (EPA 1986A). APPLICATION RATE AND WORK TIME MUST NOT EXCEED LEVELS THAT POSE AN UNACCEPTABLE LEVEL OF RISK TO HUMAN OR WILDLIFE HEALTH. IF THE RATE OR EXPOSURE TIME BEING EVALUATED CAUSES THE MARGIN OF SAFETY OR THE HAZARD QUOTIENT COMPUTED FOR A PROPOSED TREATMENT TO FAIL TO ACHIEVE THE CURRENT FOREST SERVICE R-8 STANDARD FOR ACCEPTABILITY (ACCEPTABILITY REQUIRES A MOS > 100 OR, USING THE SERA RISK ASSESSMENTS FOUND ON THE FOREST SERVICE WEBSITE, A HQ OF < 1.0) ADDITIONAL RISK MANAGEMENT MUST BE UNDERTAKEN TO REDUCE UNACCEPTABLE RISKS TO ACCEPTABLE LEVELS OR AN ALTERNATIVE METHOD OF TREATMENT MUST BE USED.

FW-83: NO HERBICIDE IS BROADCAST ON ROCK OUTCROPS OR SINKHOLES EXCEPT FOR MANAGEMENT OF TES SPECIES, FOR EXAMPLE, RUTH’S GOLDEN ASTER PITYOPSIS RUTHII. NO SOIL-ACTIVE HERBICIDE WITH A HALF-LIFE LONGER THAN 3 MONTHS IS BROADCAST ON SLOPES OVER 45 PERCENT, ERODABLE SOILS, OR AQUIFER RECHARGE ZONES. SUCH AREAS ARE CLEARLY MARKED BEFORE TREATMENT SO APPLICATORS CAN EASILY SEE AND AVOID THEM.

For the purpose of this analysis, erodible soils are defined as soils of concern on slopes greater than 20% where the vegetative cover has been removed. Thus, broadcast application of soil- active herbicides with half-lives greater than 3 months will not be prescribed in such locations. However, targeted (foliar, stem, etc.) is appropriate and may still be prescribed. State BMPs (TDF 2003) require the applicator to “Consider weather conditions (such as temperature, wind speed and precipitation) and equipment capabilities to avoid herbicide drift (p.25).” It should be noted that for the purpose of this project, treatment of native woody vegetation encroaching on open wetland habitats will be defined as preventing environmental degradation under FW-15 and treatment using aquatic approved herbicides will be permitted. Additionally, treatment of native woody vegetation encroaching on managed wildlife openings in riparian areas and ephemeral streamside management zones (including but not limited to French Broad Fields and locations where linear wildlife openings cross streams) will be defined as preventing environmental degradation under FW-15 and treatment using aquatic approved herbicides will be permitted. Changes to the soil microbial/decomposer community and the environmental fate of the chemical used would be influenced by the persistence and mobility of the chemical in soil and water.

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Each herbicide proposed will be discussed in this light, below. It should be kept in mind that on an annual basis, herbicide treatment is expected to occur on less than 25% of the total project area. Aminopyralid. Field dissipation studies indicate that the soil half-life of aminopyralid ranges from 6 to 74 days. The primary mode of degradation is microbial (USEPA 2005). Aminopyralid is weakly sorbed to soil, thus leaching to groundwater and surface water is a concern. However field dissipation studies identified minimal leaching below a soil depth of 15-30cm, indicating that microbial degradation generally occurs before groundwater transport away from the application site occurs (USEPA 2005). In aquatic systems, the primary route of degradation is photolysis. Due to the limited amount of light that penetrates water in natural systems, observed half-lives in the water phase of aerobic sediment-water systems ranged from 127-447 days. Aminopyralid was stable to direct hydrolosis in aerobic and anaerobic sediment-water systems, indicating that it is likely to persist longer in groundwater if leaching to groundwater does occur (SERA 2007). A study by McMurray (2002) indicates that the only effects associated with aminopyralid concentrations of up to 8.4 mg a.e./kg soil were transient and modest increases in nitrate and total mineral nitrogen concentrations in soil. These increases were statistically significant only on Day 0 of the study – i.e., the day that the aminopyralid was applied – and no statistically significant effects were noted on Days 7, 14, and 28 of the study. The SERA (2007) Risk Assessment modeled the maximum concentrations of aminopyralid in the top 1 foot of soil at an application rate of 0.078 lb a.e./acre to be about 25 ppb or 0.025 mg a.e./kg soil. This concentration is about a factor of 336 below the concentration of 8.4 mg a.e./kg soil in the study by McMurray (2002). Thus, there does not appear to be a basis for suggesting that adverse effects on soil microorganisms are plausible. The product Label for MilestoneVM (Dow Agrosciences 2008) says the following with respect to aquatic systems:

“Do not apply to water, to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwater or rinsate (p.1).”

and

“It is permissible to treat non-irrigation ditch banks, seasonally dry wetlands (such as flood plains, deltas, marshes, swamps, or bogs) and transitional areas between upland and lowland sites. Milestone VM can be used to the waters edge. Do not apply directly to water and take precautions to minimize spray drift onto water (p.2).”

Aminopyralid is not approved for aquatic use and shall be excluded from use within 30 feet of all perennial and intermittent waterbodies in compliance with FW-15. Aminopyralid may not be used in the ephemeral stream zone (25’ on either side) in compliance with FW-14. Due to its soil-activity and long half-life in water, aminopyralid is not suitable for broadcast application on slopes over 45 percent, erodable soils, or aquifer recharge zones in accordance with FW-83.

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Based on the available evidence, aminopyralid is likely to be non-persistent and relatively immobile. If aminopyralid is used to control undesirable species in the project area, then effects to soil and water quality should be adequately controlled through the project design criteria.

2,4-D. 2,4-D may be applied in acid, salt, or ester formulations, but in most cases, each of these formulations are apparently converted rapidly to the acid form once it contacts soil (Foster & McKercher 1973; Smith 1988; Wilson et al. 1997). Consequently, the rate of dissipation from soils is often the same regardless of the formulation of 2,4-D that is applied (Wilson et al. 1997).

The primary degradation mechanism is microbial metabolism. The half-life of 2,4-D in the environment is relatively short, averaging 10 days in soils and less than ten days in water, but can be significantly longer in cold, dry soils, or where the appropriate microbial community is not present to facilitate degradation (Tu et al. 2001). Although half-lives are short, detectable residues can persist for up to a year (McCall et al. 1981). It should be noted that 2,4-D has been shown to dissipate more rapidly in soils that were previously treated with 2,4-D, presumably because there was an increase in 2,4-D degrading bacteria after the first application (Oh & Tuovinen 1991; Smith & Aubin 1994; Shaw & Burns 1998).

Most formulations of 2,4-D do not bind tightly with soils and, therefore, have the potential to leach down into the soil column and to move off-site in surface or subsurface water flows. Leaching of 2,4-D to 30 cm has been reported (Johnson et al. 1995a). In many cases, extensive leaching does not occur, most likely because of the rapid degradation of the herbicide (Que Hee & Sutherland 1981). Where 2,4-D does leach, however, it will be more persistent because populations of microbes responsible for the degradation of 2,4-D tend to decrease with soil depth (Wilson et al. 1997). Photodegradation and chemical degredation are very minor components of 2,4-D dissipation (Tu et al, 2001). Despite its short half-life in soil and in aquatic environments, the compound has been detected in groundwater supplies in at least five States and in Canada. Very low concentrations have also been detected in surface waters throughout the U.S. (Extoxnet 1996a). There are several studies regarding the toxicity of 2,4-D to soil bacteria and fungi. The information provided in the studies is not useful for making definitive conclusions about the toxicity of 2,4-D to soil microorganisms; however, it suggests that when applied at rates at or above those typically used by the Forest Service, 2,4-D could have at least a transient impact on algae living in the soil. This conclusion is based on reported inhibition of oxygen uptake in Chlorella pyrenoidosa at a concentration of 0.221 ppm (Bertagnolli and Nadakavukaren 1974). Based on GLEAMS modeling conducted as part of the risk assessment (USDA 2006b), concentrations of 2,4-D in the top 12 feet of soil are about 0.17 ppm. Concentrations of 2,4-D at shallower depths are likely to exceed 0.2 ppm at least for a short time. Effects on other soil microorganisms seem less likely based on the studies by Ibola (1978) – i.e., an lowest-observed-adverse-effect concentration of 1000 ppm – and Estok et al.(1989) – i.e., a no-observed-effect concentration of 10 ppm. Soil concentrations in this range are not likely to occur; however, if they did occur, they would be maintained in soil for a very brief period of time. Several formulations (all dimethylamine salts) are labeled for aquatic use. These formulations may be used within the buffers specified in FW-14 and FW-15. Other formulations are not suitable for application within buffer zones identified by FW-14 and FW-15. There are no 114 restrictions on application of 2,4-D on slopes over 45 percent, erodable soils, or aquifer recharge zones in accordance with FW-83. The primary concern with this chemical is the potential to affect water quality. If 2,4-D is used as proposed to control undesirable species in the project area, then effects to soil and water quality should be adequately controlled through project design criteria. Clopyralid. Clopyralid does not bind tightly to soil; therefore leaching of the chemical into surface and groundwater could be an issue (Tu et al., 2001). In soil and water, clopyralid is degraded primarily by microbial metabolism (Pik et al., 1977). It is resistant to degradation by sunlight, hydrolysis, or other chemical degradation. It is water soluble. Tu et al. (2001) report a soil half-life of 40 days. Where the environment is characterized by sandy soil conditions, a sparse microbial population, and high rainfall, caution must be exercised when applying clopyralid and design features must be in place to protect surface and groundwater contamination. It is recommended not to apply this chemical to loamy sands or sands with rapid or very rapid permeability through the profile (Dow AgroSciences, 2011). Smith and Aubin (1989) measured the dissipation of clopyralid in three prairie soils (clay, clay loam and sandy loam) at different temperatures. They found that dissipation increased as temperature increased (from 10 to 30 °C). Chemical dissipation ranged from 10 to 47 days, and values were similar in the clay and sandy loam soils, and fastest dissipation being in the clay loam soil at higher temperatures. A more recent four-year study on a sandy loam soil indicated that clopyralid dissipation was rapid, occurring on average less than seven days over the study period (Sakaliene et al., 2011) . The authors concluded that clopyralid dissipation by leaching was not a significant factor. That being said, the same study directly related the short residence time to a population of active microbial degraders, highlighting the importance of environmental conditions needed to limit the leaching potential of this chemical. Because it is degraded entirely by soil microbes, soil conditions that maximize microbial activity will facilitate clopyralid degradation. Rates of microbial metabolism increase with increasing soil moisture and temperature, and decrease with increasing amounts of organic matter. Soil adsorption of clopyralid has been shown to increase with time (Pik et al. 1977; DowElanco 1997), which can also limit long term leaching. With regard to effects on soil microbes and other decomposers, Durkin and Follansbee (2004a) suggest that projected maximum concentrations in soil (0.1 to 0.125 mg clopyralid/kg soil) are below potentially toxic levels. The information on soil organisms is limited, consisting of an acute LC50 value for earthworms reported as >1000 mg/kg soil (LC50 value is the standard measure of chemical toxicity. Half of the sample population (50%) of a specific test-animal in a specified period die from exposure to the chemical) (Dow Agrosciences, 1998). McCall et al. (1979) found that it took 10 mg clopyralid/kg soil to have a negative effect on microbial function and processes, such as nitrification, nitrogen fixation, and carbon degradation. Clopyralid is water-soluble and will not bind with suspended particles in the water column. Degradation is almost entirely through microbial metabolism in aquatic sediments, but because clopyralid does not bind with sediments readily, it can be persistent in an aquatic environment (Tu et al., 2001). The half-life of clopyralid in water ranges from 8 to 40 days (Tu et al., 2001).

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Clopyralid is not approved for aquatic use and shall be excluded from use within 30 feet of all perennial and intermittent waterbodies in compliance with FW-15. Clopyralid may not be used in the ephemeral stream zone (25’ on either side) in compliance with FW-14. There are no restrictions on application of Clopyralid on slopes over 45 percent, erodable soils, or aquifer recharge zones in accordance with FW-83.. If clopyralid is used as proposed to control undesirable species in the project area, then effects to soil and water quality should be adequately controlled through project design criteria. Dicamba. Dicamba is typically applied as a direct foliar application. The herbicide is moderately persistent in the soil (Extoxnet 1996b). The half-life of dicamba in the soil is typically 1 to 4 weeks (Extoxnet 1996b). Metabolism by soil micro-organisms is the major pathway for breakdown under most soil conditions. Breakdown tends to be faster with increasing soil moisture and when the soil is slightly acidic. There is very little evidence that dicamba adversely affects soil micro-organisms (SERA 2004a). Dicamba does not bind to soil particles and is highly soluble in water. As a result, it is highly mobile in the soil and may leach to groundwater. Dicamba, like any herbicide, may be transported off-site as runoff or through soil percolation. Runoff is negligible in sandy or loam soils. In clay soils that have the highest runoff potential, off-site loss may reach up to about 3.5 % of the applied amount (SERA 2004a). In water, microbial degradation is the main route of dicamba disappearance. Photolysis may also occur. Aquatic hydrolysis, volatilization, adsorption to sediments, and bioconcentration are not expected to be significant (Extoxnet 1996b). The half- life of dicamba in water is less than 7 days (SERA 2004a). Dicamba is not approved for aquatic use and shall be excluded from use within 30 feet of all perennial and intermittent waterbodies in compliance with FW-15. Dicamba may not be used in the ephemeral stream zone (25’ on either side) in compliance with FW-14. There are no restrictions on application of Dicamba on slopes over 45 percent, erodable soils, or aquifer recharge zones in accordance with FW-83 If Dicamba is used as proposed to control undesirable species in the project area, then effects to soil and water quality should be adequately controlled through project design criteria. Fluazifop-P-butyl. Fluazifop’s average field half-life is 15 days (WSSA 1994). Fluazifop-p- butyl is degraded primarily by hydrolysis, and secondarily by microbial metabolism. Both mechanisms first convert the herbicide to its acid form (fluazifop acid), which is further degraded by microbes, and can have a half-life of less than 1 week. Fluazifop-p-butyl binds readily with soil particles, limiting leaching and soil runoff (Tu et. al. 2001). Fluazifop-p-butyl is not water-soluble. Because it binds strongly with soils, it is not highly mobile in soils and does not pose a significant risk of groundwater contamination (WSSA 1994). In water, fluazifop-p-butyl rapidly hydrolyzes to fluazifop acid. Fluazifop acid is stable in water at all pHs tested (Tu et. al. 2001). It is relatively stable to breakdown by UV or sunlight, and nonvolatile (Extoxnet 1996c). The half-life of fluazifop acid in water is estimated to be 60-78 days (SERA 2014). Based on modeling conducted as part of the risk assessment (USDA 2014), the maximum expected soil concentration in the top 12 inches of soil is about 0.13 (0.010 to 0.28) mg a.e./kg soil (dry weight). A study by Abdel-Mallek et al. (1996) indicates no adverse effects on soil fungi at a concentration of 0.6 mg/kg soil (dry weight). This is the only bioassay of microorganisms in

116 a soil matrix. EFSA (2012) notes effects on nitrogen and carbon mineralization following an application rate of about 2.86 lb a.e./acre but the relevance of these effects to the much lower registered application rates for fluazifop-P-butyl (i.e., up to 0.32 lb a.e./acre) is unclear. The product label (Syngenta 2011) contains the following advisories:

 “Ground Water Advisory: Fluazifop-p-butyl is known to leach through soil into ground water under certain conditions as a result of label use. This chemical may leach into ground water if used in areas where soils are permeable, particularly where the water table is shallow.”  “Surface Water Advisory: This product may impact surface water quality due to runoff of rain water. This is especially true for poorly draining soils and soils with shallow ground water. This product is classified as having high potential for reaching surface water via runoff for several months or more after application. A level, well-maintained vegetative buffer strip between areas to which this product is applied and surface water features such as ponds, streams, and springs will reduce the potential loading of fluazifop-p-butyl from runoff water and sediment. Runoff of this product will be reduced by avoiding applications when rainfall is forecasted to occur within 48 hours.” Fluazifop-p-butyl is not approved for aquatic use and shall be excluded from use within 30 feet of all perennial and intermittent waterbodies in compliance with FW-15. Fluazifop-p-butyl may not be used in the ephemeral stream zone (25’ on either side) in compliance with FW-14. There are no restrictions on application of fluazifop-P-butyl on slopes over 45 percent, erodable soils, or aquifer recharge zones in accordance with FW-83. The primary concern with this chemical is the persistence of its metabolites in groundwater. If Fluazifop-p-butyl is used as proposed to control undesirable species in the project area, then effects to soil and water quality should be adequately controlled through project design criteria. Fluroxypyr. Fluroxypyr was developed more recently than many of the other herbicides evaluated in this proposal, thus information on it is not as widely available. Many of the available data are based on laboratory experiments or modeled results, rather than field measurements in natural systems. Fluroxypyr is of moderate persistence in soils with EPA calcualted half-lives of 46 days (silt loam), 41 days (sandy loam), 46 days (loam), and 53 days (silty clay). Metabolism by soil microorganisms is the major pathway for breakdown under most soil conditions. It is stable to photolysis. Fluroxypyr does not adsorb strongly to soil, making it highly mobile. Soil adsorption of fluroxypyr strongly increases with time (as the chemical becomes more tightly bound with soil organic matter), which can limit long term leaching. Based on GLEAMS modeling, the maximum penetration of fluroxypyr into clay soils is estimated as 4-48 inches, with the depth of penetration increasing as rainfall rates increase. In predominantly loam and sand soils, fluroxypyr may penetrate to a depth of 60 inches, depending on rainfall rates (SERA 2009). The half-life of fluroxypyr in water ranges from 13-36 days. The primary pathway for breakdown in aquatic systems is also metabolism by microorganisms. Fluroxypyr and its metabolites are expected to disappear from typical pond and lake water by the end of the growing season (SERA 2009).

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There is little information available about the effects of fluroxypyr on the soil microbial and decomposer community. SERA (2009) infers that if fluroxypyr was highly toxic to soil microorganisms, the effect might be reflected in degradation studies as a rapid decline in degradation rates and no such pattern is reported in the available literature. Fluroxypyr is not approved for aquatic use and shall be excluded from use within 30 feet of all perennial and intermittent waterbodies in compliance with FW-15. Fluroxypyr may not be used in the ephemeral stream zone (25’ on either side) in compliance with FW-14. There are no restrictions on application of fluroxypyr on slopes over 45 percent, erodable soils, or aquifer recharge zones in accordance with FW-83. The primary concern with this chemical is the potential to affect water quality. If fluroxypyr is used as proposed to control undesirable species in the project area, then effects to soil and water quality should be adequately controlled through project design criteria. Glyphosate. Several studies have addressed the environmental fate of glyphosate in soil and water and concluded that the effects are minimal. Glyphosate has a tendency to adsorb strongly to soils and is moderately persistent with a 3 to 130 day half-life (USDA 1984). Mobility, and hence leachability, of a compound in soil depends on its sorption characteristics, i.e. strong sorption to soil solids results almost in immobilization, while a weakly adsorbed compound can be readily leached. Compared with other pesticides, glyphosate possesses unique sorption characteristics in soil. Almost all other pesticides are moderately to weakly adsorbed in soils, mainly by soil organic matter. In contrast, glyphosate, which is a small molecule with three polar functional groups (carboxyl, amino and phosphonate groups), is strongly adsorbed by soil minerals (Borgggard and Gimsing, 2008). Schuette (1998) also found that glyphosate will not move readily through soil and leach into non-target areas. Degradation of glyphosate in soils is mainly a biological process accomplished by different microorganisms, but bacteria were found to be the most common agent of degradation (Borgggard and Gimsing, 2008). A study on the effects of glyphosate on microbial biomass (Stratton G. and Stewart K. 1992) found glyphosate generally had no significant effect on the numbers of bacteria or fungi in forest soil and overlying forest litter. Since glyphosate has a tendency to adsorb strongly to soils it is unlikely that it will leach into waterways. Feng, et al. (1990) concluded that even under worst case conditions of direct overspray, chemical concentrations would be insufficient to result in a significant toxic impact on aquatic organisms. Borggard and Gimsing (2008) found that the risk of ground and surface water pollution by glyphosate was limited. If the herbicide does reach a waterway, the U.S. Environmental Protection Agency (EPA) tests using water from natural sources, found the half- life ranged from 35 to 63 days (USEPA 1986). Several formulations of glyphosate are labeled for aquatic use. These formulations may be used within the buffers specified in FW-14 and FW-15. Other formulations are not suitable for application within buffer zones identified by FW-14 and FW-15. There are no restrictions on application of glyphosate on slopes over 45 percent, erodable soils, or aquifer recharge zones in accordance with FW-83. If glyphosate is used as proposed to control undesirable species in the project area, then effects to soil and water quality should be adequately controlled through project design criteria. Imazapic. There is not a lot of information in the published literature regarding soil and water effects from the use of this herbicide. All information presented here came from the labels

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(NuFarm 2012; BASF, 2011), the Material Safety Data Sheet (NuFarm 2012), and the Risk Assessment prepared by the U.S. Forest Service (Durkan & Follansbee 2004b). Additional information was found in Tu et al., 2001. If using imazapic, then the primary soil and water concerns would be 1.) runoff potential and 2.) groundwater contamination. Imazapic has an average half-life of 120 days in soil, has low mobility and is rapidly degraded by sunlight in aqueous solution, but is not registered for use in aquatic systems (Tu et al. 2001). The half-life of imazapic in water averages one to two days (American Cynamid 2000), although Tu et al. (2001) reported an aqueous half-life of less than eight hours. Imazapic is degraded primarily by soil microbial metabolism but is also degraded by sunlight in water (Tu et al., 2001). No information has been encountered in the published literature or in the U.S. EPA registration files on the toxicity of imazapic to soil microorganisms or decomposers (Durkan & Follansbee 2004b). Per the imazapic labels, if sites with high clay soils receive heavy rainfall after being treated with imazapic, then the potential for offsite movement would be high. Furthermore, if shallow soils with rapid permeability are exposed to imazapic, then groundwater contamination could occur if the groundwater table is close to the surface. Recommended rates of imazapic should be lower (2.0 oz/acre) when certain soil conditions occur, such as pH>7, low clay or organic matter content, or coarse textures (high sand or rock content). The primary concern with this chemical is the potential to affect water quality. However, even if imazapic enters a surface water body, the short half-life of this chemical in water indicates that effects would be minimal. Groundwater would be more susceptible since it would not receive sunlight, which rapidly breaks the chemical down in surface water. Imazapic is not approved for aquatic use and shall be excluded from use within 30 feet of all perennial and intermittent waterbodies in compliance with FW-15. Imazapic may not be used in the ephemeral stream zone (25’ on either side) in compliance with FW-14. Although imazapic has a half-life > 3 months, it is not soil-active and therefore is not subject to the restrictions laid out in FW-83. There are no restrictions on application of imazapic on slopes over 45 percent, erodable soils, or aquifer recharge zones in accordance with FW-83. If imazapic is used as proposed to control undesirable species in the project area, then effects to soil and water quality should be adequately controlled through project design criteria. Imazapyr. If imazapyr is used for treatment as part of this project, then the primary effects to soil and water would be: 1.) soil persistance and 2.) runoff potential. Imazapyr should be applied directly to plants and not soil. If imazapyr gets into the soil, the existing soil pH would affect the mobility or persistence of the chemical. A soil with a pH less than 5 would cause the chemical to bind with the soil, whereas a pH greater than 5 would not bind the chemical to the soil, allowing it to be mobile in the soil solution (Durkin 2011). If imazapyr is mobile in the soil solution, then it could be taken up by plants, degraded by microbes, or leached off-site in heavy rain events (Tu et al. 2001). If imazapyr remains bound to the soil, then it could have a negative effect on plant re-establishment. Soil-mobile imazapyr is degraded primarily by microbial metabolism (Tu et al. 2001). Sunlight does not degrade imazapyr but it does degrade it in water. Estimates for the soil half-life of imazapyr vary widely (from 25 to 2,972 days) in the published literature (Durkin 2011). 119

Because of this uncertainty, it would be important to adhere to conditions that maximize this chemical’s degradation. If a soil is waterlogged and anaerobic, degradation of imazapyr is decreased (WSSA 1994). As the pH of a soil increases, microbial degradation of imazapyr will decrease (Tu et al. 2001). In general, microbial metabolism increases with increasing temperature and increasing soil moisture (to a point). There is little information available about the effects of imazapyr on the soil microbial and decomposer community. Forlani et al. (1995) reported that imazapyr inhibited growth for some types of soil bacteria in laboratory assays; however, the effects appeared to be species specific. No field studies have been reported. In water, imazapyr can be rapidly degraded by sunlight with a half-life averaging two days. Runoff is a concern because soil particles that bind imazapyr can be transported offsite. If a site to be treated with imazapyr has steep slopes, bare soils, minimal vegetation coverage, soils with high clay content, and heavy or prolonged precipitation, then runoff may be an issue. Non-target plants could be affected by runoff that contains imazapyr. Some formulations of imazapyr are labeled for aquatic use. These formulations may be used within the buffers specified in FW-14 and FW-15. Other formulations shall not be applied within these buffers. Due to its soils persistence and runoff potential, imazapyr is not suitable for broadcast application on slopes over 45 percent, erodable soils, or aquifer recharge zones in accordance with FW-83. If imazapyr is used as proposed to control undesirable species in the project area, then effects to soil and water quality should be adequately controlled through project design criteria. Metsulfuron methyl. Escort XPTM is the only formulation of metsulfuron-methyl that is currently used by the Forest Service. Application rates are from 0.0125 to 0.15 pounds of metsulfuron-methyl per acre. The higher rates are used for the control of kudzu. The most common method of ground application of metsulfuron-methyl is with backpack applicators that are selective for particular plants. Metsulfuron-methyl is soil active. The breakdown of metsulfuron-methyl in soils is largely dependant on soil temperature, moisture content, and pH (Extoxnet 1996d). The chemical degrades faster under acidic conditions and when soil moisture and temperature is high. Half-life estimates for metsulfuron-methyl in soil range from 14 to 180 days, with an overall average of reported values of 30 days (Extoxnet 1996d). Metsulfuron-methyl is stable to photolysis, but breaks down in ultraviolet light. Limited data are available on the toxicity of metsulfuron-methyl to soil micro-organisms. Studies indicate, however, that most effects on soil micro-organisms appear to be transient and recovery occurs within 9 to 14 days (SERA 2004b). Metsulfuron-methyl, like any herbicide, may be transported offsite as runoff or through soil percolation. Runoff is negligible in sandy or loam soils on the CNF. In clay soils that have the highest runoff potential, off-site loss may reach up to about 60 % of the applied amount in regions with very high rainfall rates (SERA 2004b). The half-life of this chemical in water is approximately 30 days (Extoxnet 1996d) Metsulfuron-methyl is not approved for aquatic use and shall be excluded from use within 30 feet of all perennial and intermittent waterbodies in compliance with FW-15. Metsulfuron- methyl may not be used in the ephemeral stream zone (25’ on either side) in compliance with FW-14. Metsulfuron-methyl is soil-active and may have a half-life > 3 months depending on 120 site-specific conditions. Consequently, it is not suitable for broadcast application on slopes over 45 percent, erodable soils, or aquifer recharge zones in accordance with FW-83. The primary concern with this chemical is the potential to affect water quality. If metsulfuron- methyl is used as proposed to control undesirable species in the project area, then effects to soil and water quality should be adequately controlled through project design criteria. Picloram. Picloram is moderately to highly persistent in the soil environment, with reported field half-lives from 20 days to 3 years depending on soil conditions. The average environmental half-life is estimated to be approximately 90 days. Photodegradation is significant only on the soil surface and volatilization is practically nil. Although microbial degradation of picloram is generally slow, it is believed to be the major pathway of picloram degradation in soils. Increasing soil organic matter increases the sorption of picloram and increases the soil residence time. Picloram is poorly bound to soils, although it is bound better by soils with higher proportions of soil organic matter. It is soluble in water and highly mobile. These properties, combined with its persistence, mean it may pose a risk of groundwater contamination (Extoxnet 1996e; Tu et. al. 2001). Picloram has been detected in the groundwater of eleven states at concentrations ranging from 0.01 ug/L to 49 ug/L. In laboratory studies, sunlight readily broke down picloram in water, with a half-life of 2.6 days (Extoxnet 1996e). The persistence of picloram in soil increases with increasing application rates or soil concentrations, which suggests that picloram is toxic to soil microorganisms. In soil column studies conducted over a 30-day period, Krzyszowska et al. (1994) notes that the soil half-life of picloram is directly related to the application rate. Application rates of 0.47, 0.97, and 1.85 kg/ha (about 0.4, 0.86, and 1.6 lb/acre) are associated with half-lives in soil of 13, 19, and 23 days, respectively. Based on the assay by Prado and Airoldi (2001), picloram concentrations as low as 1 mg/kg soil may delay the microbial use of glucose. SERA 2011a modeled peak picloram concentrations in the top 12 inches of soil as less than 0.2 mg a.e./kg soil. Higher concentrations will likely occur at shallower soil depths for a least a brief period of time following applications of picloram. Although picloram could have an effect on soil microorganisms, the consequences of such effects are not clear. Picloram has been used as an herbicide since 1964 (USEPA 1995). No field studies linking adverse effects on soil microorganism with detectable adverse impacts on soil productivity have been encountered. Picloram is not approved for aquatic use and shall be excluded from use within 30 feet of all perennial and intermittent waterbodies in compliance with FW-15. Picloram may not be used in the ephemeral stream zone (25’ on either side) in compliance with FW-14. Picloram is soil- active and may have an environmental half-life > 3 months depending on site-specific conditions. Consequently, it is not suitable for broadcast application on slopes over 45 percent, erodable soils, or aquifer recharge zones in accordance with FW-83. The primary concern with this chemical is the potential for leaching to groundwater. If picloram is used as proposed to control undesirable species in the project area, then effects to soil and water quality should be adequately controlled through project design criteria. Triclopyr. Studies have addressed the environmental fate of triclopyr in soil and water (USDA 1996; Ganapathy 1997). Both showed that triclopyr binds to organic matter in the soil and is held near the surface where it degrades more easily than in the lower horizons of the soil. Adsorption

121 of triclopyr is generally characterized as “not strong." Microorganisms degrade triclopyr readily. It degrades more rapidly under warm, moist conditions which favor microbial activity. Persistence varies widely, depending on soil type and climate. Under most conditions triclopyr breaks down relatively quickly and has a half-life in soil of 1.1 to 90 days (NPIC 2002). Long-term forest and pasture studies found very little indication the triclopyr will leach substantially either horizontally or vertically in loamy soils (SERA 1996). This reduces the likelihood that the herbicide will leach into streams, lakes, or groundwater. If it does reach water, triclopyr breaks down relatively quickly and has a half-life 1 to 10 days in water (NPIC 2002). Ganapathy (1997) concluded that “with the use of buffer zones around streams and ephemeral drainage routes, forestry applications of triclopyr could be made without harm to nearby streams”. The most important breakdown process in water is photolysis (Extoxnet 1996f). The USFS (1996) stated that “triclopyr contamination of groundwater has not been reported.” The potential for substantial effects on soil microorganisms appears to be low. The risk assessment (SERA 2011b) reported that laboratory bioassays conducted in artificial growth media suggest a very high degree of variability in the response of soil bacteria and fungi to triclopyr with no adverse effect levels of up to 1000 ppm in some species and growth inhibition at concentrations as low as 0.1 ppm in other species. Modeled concentrations of triclopyr in the top 12 to 36 inches of soil range from about 0.04 to 0.1 ppm for both triclopyr BEE and triclopyr TEA. Some transient inhibition in the growth of some bacteria or fungi could occur as a result of triclopyr application. This inhibition could result in a shift in the population structure of microbial soil communities, but substantial impacts on soil, including gross changes in capacity of soil to support vegetation, do not seem plausible. This assessment is consistent with USFS field experience involving the use of triclopyr to manage vegetation. Triclopyr TEA is labeled for aquatic use and may be used within the buffers specified in FW-14 and FW-15. Triclopyr BEE is not approved for aquatic use and shall be excluded from use within 30 feet of all perennial and intermittent waterbodies in compliance with FW-15. Triclopyr BEE may not be used in the ephemeral stream zone (25’ on either side) in compliance with FW-14. All formulations of triclopyr are suitable for application on slopes over 45 percent, erodable soils, or aquifer recharge zones in accordance with FW-83. If triclopyr is used as proposed to control undesirable species in the project area, then effects to soil and water quality should be adequately controlled through project design criteria. Herbicide Summary: A summary of the interpretations provided above are presented in Table 16.

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Table 16. Summary Interpretation of Herbicide Design Criteria Herbicide Aquatic approved Suitable for and suitable for use broadcast within 25 ft. of application on slopes ephemeral streams over 45 percent, and 30 ft. of erodable soils, or perennial/intermitte aquifer recharge nt waterbodies in zones in accordance accordance with with FW-83? FW-14 and FW-15? Aminopyralid No No 2.4-D Some Formulations Yes Clopyralid No Yes Dicamba No Yes Fluazifop-p-butyl No Yes Fluroxypyr No Yes Glyphosate Some Formulations Yes Imazapic No Yes Imazapyr Some Formulations No Metsulfuron-methyl No No Picloram No No Triclopyr Some Formulations Yes (Triclopyr TEA)

In general, herbicides can enter surface waters via three main routes including: 1. Movement or leaching through the soil profile to subsurface water and travel until contact is made with surface systems, 2. Absorption to a soil particle and movement to surface water systems during heavy rains and; 3. Direct contact with surface water during application. Several factors are important to consider related to the potential for surface or ground water contamination by herbicides: 1. Mitigation such as streamside buffer zones applied during treatment activity would greatly reduce contamination potential. Generally speaking, buffer zones of 50 feet or larger are effective in minimizing pesticide residue contamination of streamflow (Neary and Michael 1996). 2. The very small amounts of herbicide used (generally a pint or less per acre) would greatly reduce the chance of any detectable herbicide reaching ground or surface water. 3. The method of herbicide application (generally foliar treatments) would minimize herbicide contact with the soil and eliminate direct application or drift to surface water.

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4. Timing the herbicide application to avoid rainfall during and immediately after application reduces the risk of contamination. The quantity of herbicide to be used, on-site degradation processes, the method of application, in-stream dilution and degradation, and mitigation measures to be used would result in minimal risk of surface and ground water quality impact. No herbicide would be applied within 30 feet of open water except for selective treatments that use herbicides labeled for aquatic use. This along with careful control over the weather conditions during which the herbicide would be applied would prevent direct contamination of surface water. Many of the herbicide treatments would be applied directly to targeted species and very little herbicide would make ground contact. As a result, infiltration into the soil and movement via soil water (subsurface) would be minimal. The greatest hazard to surface and ground water quality would result from a possible accident during transportation, storage, mixing and disposal of the chemicals and forestwide standards are in place to mitigate those risks. Considering the project design criteria and the information outlined in the SERA Herbicide Risk Assessments, Implementation of Alternative B should not result in any measurable adverse effects from herbicide use on soil or water quality in the project area. Less than 0.25 percent of the Forest would be treated with herbicide on an annual basis. Road Maintenance. The proposed road maintenance activities under this alternative would result in some short-term soil erosion and sedimentation due to soil/roadbed disturbance from heavy equipment. However, the action would also provide opportunities to correct and/or improve Forest Service system roads, thus reducing or eliminating problems that can lead to soil erosion and increased sedimentation over the long term. Alternative C Treatments that will have no effect on soil and water quality Treatment effects would be consistent of those listed under Alternative B. Treatments that will have minimal potential effects on soil and water quality due to the annual maximum spatial extent treated Treatment effects would be consistent of those listed under Alternative B. Treatments that will have potential effects on soil and water quality Five treatments have the potential to affect soil and water quality: mowing, mechanical, prescribed fire, herbicide and road maintenance. Effects would be consistent with those discussed in Alternative B, with the exception of herbicide which would have reduced effects due to the smaller acreage treated under Alternative C. If Alternative C is implemented, then there should be no measurable direct effects to soil and water quality. Indirect effects to soil and water quality under this alternative include: 1.) the potential for increased ground disturbance; and 2.) the potential reduction in the ability to maintain utility corridors in riparian and/or aquatic communities. Potential increased ground disturbance. If Alternative C is implemented and no herbicides are applied in utility corridors in the project area, then an increase in all other non-herbicide methods, including mechanical and controlled fire would be expected to address the issue. If mechanical and prescribed fire occur more often and over larger areas than indicated, then the 124 potential for soil erosion and stream sedimentation may increase because of increased ground disturbance. It would be expected that project design criteria would offset effects to soil and water, even if acres treated per year increased. Potential Reduction in the Ability to Maintain Utility Corridors in riparian and/or aquatic communities. If Alternative C is implemented no herbicides would applied in utility corridors in the project area. Utility companies would not have the option of using aquatic approved herbicides for corridor maintenance within the buffers allowed by the forest plan. Since the plan places restrictions on ground disturbance and ignition of prescribed fire in riparian areas, the only methods available to the utility companies to maintain the streamside portions of their corridors would be Chainsaw Work, Manual Weed Pulling and Planting. Due to the labor intensive nature of these methods, the constraints imposed by Alternative C may interfere with achievement of the stated purpose and need in riparian/streamside areas: “In the utility corridors, there is a need for more effectively controlling encroaching undesired woody vegetation, reducing invading exotic vegetation, and establishing native grasses and other desirable species in a cost efficient manner. Current manual methods such as repeatedly chainsawing woody vegetation, cultivation, digging, or scalping with mechanized equipment every 3-6 years are ineffective and inefficient, and can be more ground-disturbing than herbicide use.”

That said, because of the small portion of the project area that falls within the specified buffers, no measurable effects to soil or water quality would be anticipated to occur if Alternative C were selected for implementation.

Cumulative Effects Water and Soil Resource

Alternative A (No Action)

There would be no cumulative effects to soil and water quality in the project area under Alternative A since no actions would be implemented. Herbicide use is currently only authorized on 116 acres of Fort Loudoun Electric Cooperative administered utilities (USDA Forest Service 2006a), Forest Service administrative sites, and to treat non-native invasive species (USDA Forest Service 2008). These activities would continue. Alternative B (Proposed Action) Other activities in the project area include ongoing herbicide use on 116 acres of Fort Loudoun Electric Cooperative (FLEC) administered utilities (authorized by USDA Forest Service 2006a), a portion of a TVA administered line in Polk County, Forest Service administrative sites, and to treat non-native invasive species (NNIS) (authorized by USDA Forest Service 2008). The current FLEC herbicide use is evaluated as part of the proposed action. Selection of Alternative B would reauthorize this ongoing activity – thus, it is not cumulative with Alternative B. Effects of NNIS treatment in the project area would be cumulative with Alternative B. However, NNIS treatment is implemented under the same regulatory framework and design criteria as Alternative B. NNIS treatment does not result in measurable direct/indirect effects to soil and water

125 resources and would not result in unacceptable cumulative effects to soil and water resources if Alternative B were selected. Alternative C There would be no measurable cumulative effects to soil and water if Alternative C were selected for implementation.

As with Alternative B, other activities in the project area include ongoing herbicide use on 116 acres of Fort Loudoun Electric Cooperative (FLEC) administered utilities (authorized by USDA Forest Service 2006a), a portion of a TVA administered line in Polk County, Forest Service administrative sites, and to treat non-native invasive species (NNIS) (authorized by USDA Forest Service 2008). The current FLEC and TVA herbicide use would continue and would be cumulative with the FS use of herbicide. Effects of herbicide use for NNIS treatment in the project area would be cumulative with the FS use of herbicide to maintain openings under Alternative C. However, NNIS treatment is implemented under the same regulatory framework and design criteria as Alternative C. NNIS treatment does not result in measurable direct/indirect effects to soil and water resources and would not result in unacceptable cumulative effects to soil and water resources if Alternative C were selected. Clean Water Act

Section 313 of the Clean Water Act requires the Forest Service to adhere to state water quality requirements. Section 319 of the Clean Water Act of 1972 requires the Forest Service to accommodate concerns of States regarding the consistency of federal projects with State nonpoint source pollution control programs. All waters within National Forests are Exceptional Tennessee Waters (TDEC 2007b) and consequently no degradation that threatens the designated uses of these waters is permitted. As stated in the Existing Condition Water Resources section, water quality in the analysis area is generally good, and meets quality criteria established by the state of Tennessee. Some of the larger rivers flowing through the CNF proclamation boundary are listed on the state of Tennessee’s 303d list as partially or fully impaired. In each case, the cause of the impairment is due to sources located off of national forest (NFS) lands or is due to water withdrawals for TVA power generation. Implementation of any of the Alternatives considered in this assessment would not contribute to the degradation of any waterbody. Alternatives A, B, and C are all fully consistent with Clean Water Act because no adverse water quality impacts are anticipated, beneficial uses would not be adversely affected, and BMPs and other design features including RLRMP Standards are included in the proposed project.

Executive Orders 11988 (Floodplains) and 11990 (Wetlands)

The objective of EO 11988 is to avoid, to the extent possible, long- and short-term adverse impacts associated with the occupancy and modification of floodplains and to avoid direct or indirect support of floodplain development wherever there is a practicable alternative. No occupancy is proposed with this action. All alternatives are consistent with the Executive Order. EO 11990 requires the Forest Service to take action to minimize the destruction, loss, or degradation of wetlands, and to preserve the natural and beneficial values of wetlands. 126

Alternative A would prohibit management in open wetlands to minimize their loss. Alternative A is therefore inconsistent with the Executive Order. Alternatives B and C include authorization of multiple methods that could be used to preserve existing wetlands as well as design criteria to ensure their continued protection. Alternatives B and C are therefore consistent with the Executive Order. Climate Change Existing Condition

“Climate” is defined by two parameters: average annual temperature and precipitation. “Change” is defined as the increase or decrease of those two parameters. Temperature and precipitation influence the forest through growth and regeneration. Climate changes becomes an influencing factor along with carbon dioxide emissions, growing season length, insect pollinators, and plant demography in shaping the forest environment.

The climate of the Southern Region is classified as humid subtropical -- hot, humid summers and mild-to cool winters. This area is influenced from the Gulf of Mexico and the Atlantic Ocean. Consequently, the Southern Region contains a diverse climate and vegetation. In general, forest types are primarily deciduous hardwoods and evergreen conifers. Deciduous forests are dominated mainly by upland hardwoods, primarily oak-hickory (Querus spp. – Carya spp.). The conifer forest types consist almost entirely of southern pines: shortleaf (Pinus echinata), longleaf (Pinus palustris), loblolly (Pinus taeda), and slash (Pinus elliottii).

The last decade has brought increased awareness and concern over earths changing climate and variable carbon balance. The passage of the Energy Independence and Security Act of 2007, the U.S. Secretaries of Interior and Agriculture were tasked with completing a national assessment of carbon emissions from U.S. ecosystems. The assessment must identify adaptation and mitigation strategies for carbon management that will lead to reduced emission and enhanced sequestration on terrestrial landscapes. This task is consistent with other global efforts. (Vose et al 2012)

This report summarized current conditions and analyzes the direct, indirect, and cumulative effects of the proposed alternatives on climate conditions in the project area. This analysis incorporates the concern about the proposed activities influencing climate change and the effect climate change could have on the resources in the project area. The following analysis focuses on climate change on the current landscape and anticipated changes as a result of implementing the alternatives.

Scope of Analysis

The scope of this analysis for direct, indirect, and cumulative effects on climate change includes the following for each alternative.

Alternative A: Under the No Action Alternative, routine mechanical activities would occur on all existing openings, as would activities authorized through other decisions. Herbicide use is currently only authorized on 116 acres of Fort Loudoun administered utilities in Monroe County and 56 acres of Tennessee Valley Authority administered utilities in Polk County (USDA Forest

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Service 2006a), Forest Service administrative sites, and on non-native invasive species (USDA Forest Service 2006a). These activities would continue.

Alternative B: This project proposes alternative methods to manage existing openings on the forest. Openings considered include corridors for electrical utility lines comprising approximately 1,576 acres, linear wildlife openings comprising approximately 859 acres, spot wildlife openings (including managed openings such as mountain balds) comprising approximately 2,205 acres, and scenic overlooks comprising approximately 14 acres.

Alternative C: In this proposal, vegetation within openings would continue to be managed by mechanical means. In addition, chemical methods could be used to establish the desired vegetation on openings managed by the Forest Service. Utility corridors would be treated mechanically only. No herbicide would be allowed within utility corridors with the exception of 116 acres of Fort Loudoun and 56 acres of TVA utilities that have been previously authorized under a separate environmental analysis.

The timeframe of activities considered are those activities that have occurred in the past 10 years, present activities, and those in the foreseeable future (the next 10 years).

Existing Condition

Climate change may affect the resources in the project area and the proposed project may affect climate change through altering the carbon cycle. Climate models are continuing to be developed and refined, but the two principal models found to best simulate future climate changed conditions for the various regions across the country are the Hadley Centre model and the Canadian Climate Centre model (Climate Change Impacts on the United States 2001). Both models indicate warming in the southern region of the US. However, the models differ in that one predicts little change in precipitation until 2030 followed by much drier conditions over the next 70 years. The other predicts a slight decrease in precipitation during the next 30 years followed by increased precipitation. These changes could affect forest productivity, forest pest activity, vegetation types, major weather disturbances (droughts, hurricanes), and streamflow. These effects would likely be seen in some sensitive areas sooner.

Tree species distribution across a geographic scale is primarily limited by temperature and precipitation with integrated influences of relative humidity, evapotranspiration, and moistures deficits. Temperature and availability of water during the growing season are essential to optimum tree growth. Physiological damage can occur when the limits of temperature and precipitation are reached for a given tree species. (McNab et al 2014).

The effects of various treatment options on nonnative invasive species are important. Biodiversity and plant species richness for native vegetation and pant communities and wildlife habitat and species population may have various levels of impacts through the encroachment of noxious weeds. Disturbance factors such as road and utility corridors, timber sales, and recreational sites contribute to the increase vulnerability of noxious weed invasion.

The introduction and spread of noxious weeds threaten biological diversity of native plant communities, thus altering ecosystem processes such as fire frequency, soil erosion, and 128 hydrological cycles. The impacts extend to wildlife foraging, habitat modification, and species interaction with the environment.

Direct and Indirect Effects Climate Change

Alternative A (No Action), Alternative B (Proposed Action), Alternative C In general, genetic diversity provides resilience to a variety of environmental stressors (Moritz, 2002, Reed and Frankham, 2003, Reusch et al., 2005). Climate change affects biodiversity directly by altering the physical conditions to which many species are adapted. In some instances, changes in precipitation patterns may disrupt animal movements and influence recruitment and mortality rates (Inouye et al., 2000). Evidence is accumulating to indicate that species interactions and competitive responses under changing climates are complex and unexpected (Suttle, Thompsend, and Power, 2007). Although species with large geographic ranges have a wide range of physiological tolerance, species that are rare, threatened, endangered, narrowly distributed, and endemic, as well as those with limited dispersal ability, would be particularly at risk under climate change (Pounds et al., 2006) because they may not be able to adapt in situ or migrate rapidly enough to keep pace with changes in temperature (Hansen et al., 2001; Wilmking et al., 2004; Neilson et al., 2005b). A key predicted effect of climate change is the expansion of native species’ ranges into biogeographic areas in which they previously could not survive (Simberloff, 2000; Dale et al., 2001). This prediction is supported by the observed northward shift in the ranges of several species, both native and introduced, due to the reduction of cold temperature restrictions (Parmesan, 2006).

Vegetation Projected changes in climate (temperature and precipitation), along with increased nitrogen deposition affect all forests throughout the United States. Effects can be direct (e.g. elevated carbon dioxide on forest growth and water use) and indirect (e.g. altered disturbance regimes) and differ temporally and spatially across the United States. Past examples include insect outbreaks and large wildfires. The effects of these examples demonstrate a changing climate on the forest ecosystems; thus re-shaping forest landscapes with a change in forest structure, function, and species composition. To definitively conclude observation trends from ecological resources are the result of human-caused climate change or simply natural climatic variability can not be determined. (Vose et al 2012) Effects of proposed project activities are not the sole contributing factor for climate change. Project activities are minute in scale when compared to regional, continental, or global contributions.

Forest ecosystems are inherently resilient to variability in climate with scale ranging from daily to millennial variations. Forest species disturbance and abundance respond individually to changes in temperature, precipitation, and other disturbances regimes. Thus, gradual or moderate changes in climate influence gradual changes in the ecosystem. However, rapid or drastic changes in climate influence rapid changes in composition and forest dynamics. Forests which experience frequent disturbances tend to exhibit characteristics which enhance their survival rate. The complexity of fragmented landscapes combined with multiple stressors influences the threshold response of forest ecosystems. (Vose et al 2012)

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Climate change, increased carbon dioxide concentrations, and increased nitrogen deposition have already affected the Nation’s forests. Projecting the response of forest ecosystems to global change is not only difficult but complex. Projected changes are based on models. However, the output is subjective because of uncertainty in parameters, such as size of land, ecosystem interactions, time periods, etc.

Climatic warming and elevated carbon dioxide may have a positive effect on tree growth and may result in creased maturation rates in some regions of the United States. Climate change may increase the frequency of epidemics of forest insects and pathogens and subsequently related tree mortality. Examples may include seed production, mortality, regeneration and successional progression among competing species. (Vose et al 2012)

“Temperature, atmospheric carbon dioxide concentration, ecosystem water balance, and nitrogen cycling all interact to alter photosynthesis and growth. The critical issue is the balance among these factors affecting growth… Disturbance is the largest factor changing the balance between production and decomposition but chronic changes in temperature, precipitation, carbon dioxide, and nitrogen deposition over large areas can also alter the U.S. forest carbon balance.” (Vose et al 2012)

Experimental results indicate that primary direct effects of elevated carbon dioxide on forest vegetation is an increase in photosynthesis (Norby et al 2005, p. 43) However, individual studies indicate that photosynthetic enhancement, growth, and carbon storage are moderated by the presence of drought or nutrient limitations (Finzi et al 2006, Garten et al 2011, Johnson 2006, Norby et al 2010, p. 43). Recent studies by Norby and Zak (2011) showed the following: (1) elevated carbon dioxide does not increase the leaf area of forested sites, (2) net primary production is enhanced under elevated carbon dioxide only when water and nutrient supplies are abundant, (3) water use is reduced through stomatal closure, and (4) promotion of carbon dioxide increases photosynthesis and net primary productivity does not always increase forest carbon storage. (Vose et al 2012)

Older forests can be strong carbon sinks (Stoy et al. 2006), and older trees absorb more carbon dioxide in an elevated carbon dioxide atmosphere, but wood production of these trees show limited or only transient response to carbon dioxide (Korner et al. 2005). Studies of elevated carbon dioxide on trees have been done with young trees (which show a positive growth response), but the one study on mature trees showed no growth response (Korner, et al. 2005). This is consistent with model results found in an independent study (Kirschbaum 2005). The general findings from a number of recent syntheses using data from the three American and European FACE sites (King et al. 2004; Norby et al. 2005; McCarthy et al. 2006a; Palmroth et al. 2006) show that North American forests will absorb more carbon dioxide and might retain more carbon as atmospheric carbon dioxide increases. In this study, thinning removed carbon from the stand (in the form or removed logs) and also resulted in substantial, but temporary, reduction in above ground net primary production. The reduction of above ground net primary productivity by thinning lasted only one year, and its recovery was likely due to changes in the foliar mass and leaf traits. Finally, the data portrayed that there is a transient impact of thinning on above ground net primary production, but that there is no long-term effect of thinning on

130 above ground carbon uptake in oak forests. Although this study focused on oak forests, the same principles and effects would apply to the hemlock forests.

The alternatives would alter the carbon cycle in that it affects the carbon stock in any one of the pools. Each alternative would remove biomass as a result of down hemlock trees. This would reduce the amount of carbon stored in the treated stands. A portion of the carbon removed would remain stored for a period of time in wood products.

The increase in down, dead wood would temporarily convert stands from a carbon sink that removes more carbon from the atmosphere than it emits, to a carbon source that emits more carbon through respiration than it absorbs. These stands would remain a source of carbon to the atmosphere until carbon uptake by new trees and other vegetation exceeds the emissions from decomposing dead organic material. The stands would likely remain a carbon source for several years, and perhaps for more than a decade, depending on the amount of dead biomass left on site, the length of time before new trees become reestablished, and their rate of growth once reestablished. As the stands continue to develop, the strength of the carbon sink would increase until peaking at an intermediate age and then gradually decline but remain positive. Similarly, once new trees are established, carbon stocks would accumulate rapidly for several decades. The rate of accumulation would slow as the stands age. Carbon stocks would continue to accumulate, although at a declining rate, until impacted by future disturbances.

Scientific literature confirms this general pattern of changes in net ecosystem productivity (NEP)1 and carbon stocks over the period of forest stand development. Most mature and old stands remained a net sink of carbon. Pregitzer and Euskirchen (2004) synthesized results from 120 separate studies of carbon stocks and carbon fluxes for boreal, temperate, and tropical biomes. They found that in temperate forests net ecosystem productivity is lowest, and most variable, in young stands (0-30 years), highest in stands 31-70 years, and declines thereafter as stands age. These studies also reveal a general pattern of total carbon stocks declining after disturbance and then increasing, rapidly during intermediate years and then at a declining rate, over time until another significant disturbance (timber harvest or tree mortality resulting from drought, fire, insects, disease or other causes) kills large numbers of trees and again converts the stands to a carbon source where carbon emissions from decay of dead biomass exceeds that amount of carbon removed from the atmosphere by photosynthesis within the stand.

The impacts of the action alternatives on global carbon sequestration and atmospheric concentrations of carbon dioxide are miniscule. However, the forests of the United States significantly reduce atmospheric concentrations of carbon dioxide resulting from fossil fuel emissions. The forest and wood products of the United States currently sequester approximately 200 teragrams2 of carbon per year (Heath and Smith, 2004). This rate of carbon sequestration offsets approximately 10% of carbon dioxide emissions from burning fossil fuels (Birdsey et al.,

1 Net ecosystem productivity, or NEP, is defined as gross primary productivity (GPP) minus ecosystem respiration (ER) (Chapin et al. 2006). It reflects the balance between (1) absorbing CO2 from the atmosphere through photosynthesis (GPP) and (2) the release of carbon into the atmosphere through respiration by live plants, decomposition of dead organic matter, and burning of biomass (ER). When NEP is positive, carbon accumulates in biomass. Ecosystems with a positive NEP are referred to as a carbon sink. When NEP is negative, ecosystems emit more carbon than they absorb. Ecosystem with a negative NEP are referred to as a carbon source. 2 200 teragrams, or Tg, equals 196,841,306 US tons. 131

2006). U.S. forests currently contain 66,600 teragrams of carbon. The short-term reduction in carbon stocks and sequestration rates resulting from the proposed project are imperceptibly small on global and national scales, as are the potential long-term benefits in terms of carbon storage.

The currently large carbon sink in US forests is a result of past land use changes, including the re-growth of forests on large areas of the eastern U.S. harvest in the 19th century, and 20th century fire suppression in the western U.S. (Birdsey et al. 2006). The continuation of this large carbon sink is uncertain because some of the processes promoting the current sink are likely to decline and projected increases in disturbance rates such as fire and large-scale insect mortaily may release a significant fraction of existing carbon stocks (Pacala et al. 2008; Canadell et al. 2007). Management actions – such as those proposed – that improve the resilience of forest to climate-induced increases in frequency, and utilize harvested trees for long-lived forest products and renewable energy sources may help sustain the current strength of the carbon sink in US forests (Birdsey et al. 2007).

Fire Fire (natural, intentional, or accidental) does contribute to global greenhouse gas (GHG) emissions; thus, they are the most widely studied contributors of carbon dioxide and methane. The ecological role of fire is variable from location to location and region to region. Decades of research indicates that fire can play an integral part/role in the ecological ecosystem. Strategically incorporating the knowledge learned about fire into carbon management and climate change concerns is one component in reducing atmospheric carbon levels.

Fire-prone ecosystems have evolved to respond to varying levels of fire impacts and are comprised of species and processes that are not only fire adapted but fire dependent. Research suggests that carefully designed and executed treatments with subsequent re-occurring prescribed burning decreased the risk of high-severity wildfires and maintains a developing fire-tolerant forest. The task/goal is to balance carbon storage and loss while maintaining ecosystem diversity and resilience.

Forest soils and biota store various amounts of carbon and other nutrients in the soil and in surface debris. Low intensity burns can enhance carbon-sequestering soil ecosystems while charring pieces of the surface debris which inturns delays the decaying process and subsequent fuel loading in the future.

Wildlife Climate change is influenced by activities associated with human population activities that increase carbon dioxide emissions. Effects on wildlife from climate change are complicated by land-use changes associated with population and economic expansion which reduces the amount of contiguous habitat, and thus may limit or alter their ability to respond. Strategic planning for wildlife is complicated by uncertainty; such as human population growth, economic growth, how/where/when climatic variable occur (time and magnitude), and how wildlife species respond at various times given the complex habitat requirements and life cycles. Habitat changes in response to associated warming and cooling periods could force distribution of many terrestrial species to shift in latitude or elevation. Historical documentation of these events may have contributed to some species extinction. (Greenberg et al 2014) Similar to plant communities,

132 wildlife communities have reassembled as species are responding to different changes in climate and associated vegetation composition and structure. (Graham and Grimm 1990).

Evolutionary adaptive responses (natural selection) of a particular species depends on rates of mutation, rates of gene flow, amount of genetic variation, level and consistency of selective pressure exerted on a particular trait, and generation time and age structure of the population. (Greenberg et al 2014)

Species vulnerability to climate change depends on their exposure, sensitivity, and adaptive capacity (Glick et al 2011; Intergovernmental Panel on Climate Change 2007). Extreme weather events, such as hurricanes, tornados, or storms, and extremes changes of temperature and precipitation, may also affect wildlife species by altering their breeding patterns, life cycle, and/or survival rates. (Greenberg et al 2014) Species which are adapted to warmer or drier conditions may expand their current home ranges. Conversely, the direct effects of altered temperature or rainfall may adversely affect animal species that are especially sensitive to air or water temperature, have specific moisture requirements, or rely on specific weather patterns for survival on success breeding. Generalist species may be less sensitive and adapt more easily to changes in climate than specialists. Species which have the capacity to respond behaviorally (such as local movement during microhabitat for thermoregulation) or physiologically (such as becoming dormant during dry periods) (Glick et al 2011) may only be indirectly impacted from climate change. Similarly, wildlife species that occur in multiple ecosystems may be more resilient, as climate-driven alternatives will likely differ among ecosystems.

Wildlife may decline in response to higher temperatures and decreased precipitation. Wildlife associated with rare habitats, such as bogs, may also be more susceptible to changes in temperature and precipitation than species which occur in more abundant habitat because they have reduced habitat, and limited mobility.

High temperatures along with altered or variable weather patterns may have direct and indirect effect on biological diversity: these effects may differ among animal populations or communities, as well as, species that have different life histories and physiology. Examples include birds and bats which have the ability to move long distances thus reducing their vulnerability to climate change; whereas, reptiles and amphibians have limited mobility and a narrow tolerance limit for temperature and moisture changes. Similarly, mammals with a narrow habitat range and small home-range size may be more susceptible to micro-climate changes. Other stressors (environmentally and physically of each particular species) should be taken into account.

Indirect effects/impacts to wildlife are uncertain at this time because of the current scale of information is available. Shifts in vegetation and habitat as a result of gradual changes in climate or altered natural disturbances (frequency, duration, or intensity of drought, wind, fire, or floods) may affect many species for survival, reproduction or possibly extinction. Changes in forest composition, pattern or the amount could impact the animal’s ability to disperse in response to climate change. Other impacts of consideration include food availability and/or predator-prey relationships.

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Mammals Mammals have the ability to regulate their body temperature. They generally respond directly and indirectly to changes in climate through their interaction with food source, predators, and habitat associations (Berteaux and Senseth 2006). Sustained extreme changes in temperature and precipitation could alter habitats or decreased food resources. Additional effects may include increased disease outbreaks, physiological changes, nutritional state, and survival rate.

Studies on the effects of climate change on mammals are limited and/or unknown on many southeastern mammals. Predicting or projecting the magnitude and direction of those changes are difficult and uncertain at this time due to the lack of targeted research in this area. Historical data theorize that mammals associated with low elevation may expand their range, whereas, high-elevation species may contract.

Bats Bats play an important role in forest ecosystems by suppressing populations of night-flying insects. Bats species vary considerable in their habitat associations, roosting and foraging habitats, and strategies for coping with harsh winter conditions such as cold temperatures and reduced food supply. Thus, responses to climate change will likely differ among species.(Greenberg et al 2014).

Climate change may influence the distribution of bats during the summer and winter. In the Eastern United States, preferred hibernation temperatures of little brown bat (Myotis lucifugus) indicate their winter distribution may show a northward movement (Humphries et al 2002), whereas models suggest that both the little brown bat and the northern long-eared bat (Myotis septentrionalis) could expand farther southward in response to global climate change (Kalcounis-Ruepell et al 2010). Currently, little information in known about the timing of bat migration in the southeastern United States, thus complicating the efforts to disclose effect on migration from climate change.

Birds Birds are an appropriate species for studying potential responses to climate change because: (1) long-term data exist for their abundance and distribution, and (2) their ranges are associated with temperature. Climate alterations can indirectly affect birds by changing the amount, distribution, structure, and condition of habitat. Bird responses may include adapting, temporal or phenological changes, spatial distribution changes, or elevation changes.

Extremes in climate may impact game birds at all points of their life cycle, including the timing of breeding, selection of nest sites, and availability of food resources. Increased precipitation which may result in unusually wet springs, could flood or wash away nests and drown chicks. In contrast, increased drought frequency could also adversely affect upland birds in the breeding, reproducing, and survival rate of chicks (Greenberg et al 2014).

Northern bobwhite (Colinus virginianus) and ruffed grouse (Bonasa umbellus) – two southeastern non-migratory game birds with different habitat association and range distributions are predicted to differ in their response to climate change (Matthews et al 2007). Bobwhite is the least abundant in the Southern Appalachians (Matthews et al 2007). Optimal bobwhite habitat in

134 forested areas consists of early successional forests that are dominated by pines or hardwoods and that include both herbaceous and woody growth (Wildlife Management Institute 2008). Hot dry summers could potentially reduce bobwhite recruitment. Ruffed grouse use deciduous forest and prefer young forest with abundant ground cover. Increased temperatures during winter time could also potentially reduce survival rates (Greenberg et al 2014)

Amphibians Shifts in climate may have negative effects on amphibian populations (Beebee 1995; Gibbs and Breisch 2001, Parmesan and Yohe 2003). Temperature and precipitation does influence amphibian life cycles, especially during breeding activities (Greenberg et al 2014). Because amphibians lay their eggs in water, the timing of precipitation could affect their reproductive activities and survival rate. For adult amphibians the access to available water source is necessary because they are vulnerable to losing water from their skin which ultimately affects their respiratory system (Carey and Alexander 2003).

“Emission and pollutants associated with climate change may also cause thinning of the stratosphere ozone, leading to increased atmospheric ultraviolet-B radiation (UV-B) that has been suggested as a cause of amphibian declines (Blaustein et al 2003).” (Vose and Klepzig 2014). Research by Corn (2005) does not show a link between ultraviolet –B exposure with changes in abundance or distribution of amphibians. Amphibians (wood frog (Lithobates sylvaticus), spring peeper (Pseudacris crucifer), and bull frogs (Lithobates catesbeiansu)) breeding has been documented to shift earlier during winter and spring in response to increased temperatures. In addition, increased water temperatures may affect the reproductive success by altering their geographic distribution (seeking optimal minimum/maximum water temperature) and developmental rates (increased maturation). (Greenberg et al 2014)

“Milanovich et al (2010) predicted that increased temperatures projected in long-term weather models would cause a loss of salamander diversity in the Appalachians. Many mountain-top species may be near their thermal maxima and have limited dispersal ability. Increase in temperature would result in lost habitat for many species, and those with small geographic ranges will be at greatest risk of extinction.”(Greenberg et al 2014)

Primarily adult aquatic amphibians may be adversely affected by changes in temperature or precipitation reduces the availability of permanent ponds, streams, or water sources. Stream dwelling salamanders are dependent upon stable stream flows for larval development, which is variable from several months to several years (Rodenhouse et al 2009). In addition, increased water temperature may be detrimental to stream dwelling salamander survival. Also, changes in precipitation pattern may affect those amphibian species which have distinct breeding season and are dependent on seasonal rainfall patterns. (Greenberg et al 2014)

Change in precipitation, primarily drought conditions is considered as a threat to southeastern amphibians. Drier soils and leaf litter may create suboptimal conditions for terrestrial salamanders and the terrestrial stages of aquatic-breeding amphibians. Consequently, terrestrial salamanders (Plethodontidae) may decrease surface foraging in response to dry forest floor conditions. Studies of the two-lined salamander (Eurycea wilderae) in sites with reduced leaf litter depth, soil moisture, and overstory cover (Crawford and Semlitsch 2008; Moorman et al 2011) indicates their sensitivity to moisture and temperature.” 135

Reptiles Generally reptiles are less vulnerable to climate change than amphibians because of their scale- covered skin. Reptiles are able to tolerate drier warmer climate conditions. Their eggs are contained within a calcareous shell which also is a protective covering for desiccation. In addition, their life cycle does not involve aquatic egg or larval stages. Reptiles are highly mobile, thereby, capable of avoiding thermal stressors. They can travel long distances and can have large home ranges. Reptiles may be indirectly affected by changes in primary habitat, changes in food availability, and temperature –dependent availability; thus, increased temperature correlated directly with increased growth maturation, and/or increased temperature correlates to decreased energy. (Greenberg et al 2014) Cumulative Effects Climate Change

Alternatives A, B and C For all alternatives, there is confidence that temperatures are changing at a global scale, yet it is difficult to predict the effect of climate change at local and regional scales because the relationship between climate change and the proposed project areas are at a minute scale. Thus the contribution of the proposed actions to the carbon cycle is extremely small. When looked at the implementation collectively, the risk and rate of additional carbon release through regeneration is minimal for the reasonably foreseeable future in comparison to extinction of species and the complete loss of a carbon source. Human Health and Safety Herbicide Hazard Quotients and Effects to Human Health

Existing Condition

Effects and associated risks of all herbicides listed in the proposed action for this project have been assessed by Syracuse Environmental Research Associates, Inc. (SERA 2014, 2011a, 2011b, 2011c, 2009, 2007, 2006, 2004a, 2004b, 2004c, and 2004d). The complete text of these documents in .pdf format can also be found at: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml

In the risk assessments, there are two terms that are very important as they pertain to human health. These are Reference Dose (RfD) and Hazard Quotient (HQ).

 RfD - Derived by USEPA, this is the maximum dose in mg of herbicide active ingredient per kg of body weight per day that is not expected to cause injury over a lifetime of exposure. In other words, it is, in EPA’s opinion, a “safe” lifetime daily dose. This is a conservative estimate, and is designed to be protective.  HQ - This is the ratio of the estimated exposure dose to the RfD. A HQ of 1 equals exposure to the RfD; HQs less than 1 represent exposures to less than the RfD, while HQs greater than 1 represent exposures greater than the RfD. HQs of 1.0 or less represent exposure levels that are not of concern. HQs greater than 1.0 represent possible effects to be examined more closely. The assumptions for any exposures producing a HQ greater than 1.0 are examined to see if the exposures need to be mitigated or avoided. For the

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effects on wildlife, one must remember that these effects are constructed for individuals and not populations.

This effects discussion for the proposed herbicides is focused on workers and the public. It is a brief summary based on the analysis done by Syracuse Environmental Research Associates, Inc. More information can be found in the Assessments located at the above mentioned link.

It should be noted that the following effects section makes mention of aerial spraying. This is for the purpose of understanding the risk related effects of the various herbicides, and no aerial spraying is proposed in this project. In the effects section that follows, herbicide testing was done at extremes that sometimes produce HQ’s greater than 1. In practical situations, these HQ’s can be reduced by mitigation and following label direction. These mitigation measures include but are not limited to workers changing out of herbicide soaked clothing, washing herbicide off of skin, reporting spills, and placing signs on areas that have been treated.

Direct and Indirect Effects Herbicide Hazard Quotients and Effects to Human Health

Alternative A (No Action) Under Alternative A, no activities using herbicides are proposed resulting in no effects to human health. Alternatives B and C Alternative B proposes herbicide use on a larger area (includes ROW’s) than Alternative C. Both alternatives B and C propose the use of the same herbicides and the herbicide risks to workers and public are the same in both alternatives. Under Alternatives B and C, the pesticide emergency spill plan (Appendix 9) would be in place. Alternatives B and C also assume that all herbicides will be applied in accordance with their label requirements and that all of the mitigation measures in Chapter II of this document would be followed. The following excerpts from the herbicide risk assessments use hazard quotient (HQ) values to indicate and compare herbicide exposure levels with respect to human health.

Aminopyralid – A quantitative summary of the risk characterization for workers associated with exposure to aminopyralid is presented in the aminopyralid risk assessment (SERA 2007).

For workers, no exposure scenarios, acute or chronic, exceeds the RfD at the upper bound of the estimated dose associated with the highest application rate of 0.11 lb a.e./acre. The hazard quotients for directed ground spray, broadcast ground spray, and aerial applications are below the level of concern by factors of 33 to 200 over the range of application rates considered in this risk assessment.

For members of the general public, upper bounds of hazard quotients at the highest application rate are below a level of concern by factors of 100 to 125,000 for longer term exposures. For one accidental exposure scenario, the consumption of contaminated water by a child immediately after an accidental spill of aminopyralid into a small pond, the hazard quotient is 0.6, approaching the level of concern (1.0). This is an intentionally extreme exposure scenario that typically leads to the highest hazard quotient in pesticide risk assessments similar to the current assessment on aminopyralid. The upper bounds of acute exposure scenarios for contaminated vegetation or fruit are below the level of

137 concern by factors of 10 to 50. Acute non-accidental exposure scenarios for members of the general public that involve contaminated water are below the level of concern by factors of about 50 to 500.

2,4-D – A quantitative summary of the risk characterization for workers associated with exposure to 2,4-D is presented in the 2,4-D risk assessment (SERA 2006).

For workers, longer-term exposures associated with ground spray applications of 2,4-D yield risks twice those associated with either backpack or aerial application methods. Based on upper bound hazard quotients which exceed 1, adverse health outcomes are possible for workers exposed repeatedly over a longer period of time. Hazard quotients for workers spraying at the typical application rate of 1 lb a.e./acre are 16 for both backpack and aerial spray methods, and 30 for ground spray application. Short-term accidental exposures via contaminated gloves as well as some spill scenarios yield hazard quotients that are of concern, particularly for the scenario involving contaminated gloves that are worn for 1 hour, which yields a hazard quotient of 94. For all of these hazard quotients, the magnitude of the hazard quotient is linearly related to the application rate.

As with hazard quotients for workers, hazard quotients for members of the general public are linearly related to application rate. Upper bound hazard quotients for accidental exposures associated with spills into a small body of water range from 0.8 (consumption of fish by non- subsistence populations at an application rate of 0.5 lb a.e./acre) to 328 (a child consuming 1 liter of contaminated water at an application rate of 4 lb a.e./acre). The amounts spilled are set at the amounts required to treat from 1 to100 acres. These assumptions are completely arbitrary and may be unrealistic. The scenario for an accidental spill into a small pond is intended simply to illustrate the different consequences of spilling different amounts of 2,4-D.

Clopyralid – A quantitative summary of the risk characterization for workers associated with exposure to clopyralid is presented in the Clopyralid risk assessment (SERA 2004c).

The hazard quotients for general occupational exposure scenarios are similar to those for the accidental exposure scenarios. As with the highest hazard quotient for accidental exposures, the upper limit of the hazard quotients for both backpack and aerial applications are below the level of concern by a factor of 5 (i.e., hazard quotients of 0.2 relative to a level of concern of one). For broadcast ground applications, the hazard quotient is 0.4, below the level of concern by a factor of 2.5.

All of these hazard quotients are based on a typical application rate of 0.35 lb a.e./acre. The Forest Service may consider applications of up to 0.5 lb a.e./acre, a factor of about 1.5 higher than the typical application rate [0.5 lb a.e./acre ÷ 0.35 lb a.e./acre = 1.429]. Because the hazard quotients are linearly related to exposure and the exposures are linearly related to the application rate, the highest hazard quotient of 0.4 at an application rate of 0.35 lb a.e./acre would correspond to a hazard quotient of about 0.6 at an application rate of 0.5 lb a.e./acre – i.e., 0.4 × 1.429 = 0.5716, which rounds to 0.6 using one significant decimal place.

The simple verbal interpretation of this quantitative characterization of risk is that even under the most conservative set of exposure assumptions, workers would not be exposed to levels of clopyralid that are regarded as unacceptable even at the highest application rate that would be

138 considered in Forest Service programs. Under typical application conditions and applications rates, levels of exposure for workers will be far below levels of concern.

Like the quantitative risk characterization for workers, the quantitative risk characterization for the general public is expressed as the hazard quotient using the acute RfD of 0.75 mg/kg/day for acute exposures and the chronic RfD of 0.15 mg/kg/day for longer term exposures.

None of the longer-term exposure scenarios approach a level of concern and none of the acute/ accidental scenarios exceed a level of concern, based on central estimates of exposure, although the upper limit of the hazard quotient for the consumption of water after an accidental spill slightly exceeds the level of concern – i.e., a hazard quotient of 2.

Dicamba – A quantitative summary of the risk characterization for workers associated with exposure to dicamba is presented in the risk assessment (SERA 2004d).

The highest hazard quotient for workers based on general exposures is 1 – the upper range for workers involved in broadcast ground sprays. Thus, at the typical application rate, the upper range of hazard quotients reaches but does not exceed the level of concern. At the highest application rate that might be used in Forest Service programs, the level of concern is not exceeded for any worker groups based on the central estimates of exposure. At the upper range of exposure, however, the level of concern (0.15) is exceeded for all groups of workers. For ground broadcast applications, the upper range of the level of concern would be exceeded for all applications above 0.3 lb/acre. For directed ground spray and aerial workers, the upper range of the level of concern would be exceeded for applications in excess of 0.6 lb/acre.

While the accidental exposure scenarios are not the most severe one might imagine (e.g., complete immersion of the worker or contamination of the entire body surface for a prolonged period of time) they are representative of reasonable accidental exposures. The highest hazard quotient for accidental worker exposures – i.e., the upper range for a worker wearing contaminated gloves for 1 hour and the upper range for a worker with a spill on the lower legs that is not removed for 1 hour. Because the estimate of the absorbed dose is linearly related to the hazard quotient, 10 hours would be required to reach a level of concern (a hazard quotient of one) at the typical application rate. At the maximum application rate, an exposure period of 1.5 hours would be required to reach a level of concern.

Like the quantitative risk characterization for workers, the quantitative risk characterization for the general public is expressed as the hazard quotient using the acute RfD of 0.1 mg/kg/day and the chronic RfD of 0.045 mg/kg/day.

For the acute/accidental scenarios, none of the central estimates of the hazard quotients exceed 1.0, the level of concern for the typical application rate. At the upper range of exposure based on the typical application rate, two accidental scenarios for children – direct spray and consumption of contaminated water after a spill – exceed the level of concern (1.0). At the highest application rate, these accidental scenarios as well as the accidental direct spray scenario for a woman, the consumption of contaminated fruit, and the consumption of fish by subsistence populations exceed the level of concern (0.15). While the direct spray scenarios and spill into water are

139 accidental, the scenarios involving the consumption of contaminated fruit and contaminated fish are scenarios that are plausible.

For longer term exposures, none of the exposure scenarios reach a level of concern at the typical application rate. At the highest application considered in this risk assessment, 2 lbs/acre, the level of concern (0.15) is exceeded only for the consumption of contaminated vegetation (HQ=0.2). Since the hazard quotient is linearly related to the application rate, the level of concern would be reached at an application rate of 1.5 lbs/acre.

Fluazifop-P-butyl – A quantitative summary of the risk characterization for workers associated with exposure to Fluazifop-P-butyl is presented in the Fluazifop-P-butyl risk assessment (SERA 2014).

Based on the toxicity values and the central estimates of exposure, workers involved in mechanical ground spray and aerial applications of fluazifop-P-butyl do not appear to be at risk. This conclusion is consistent with the risk characterization for these worker groups by the U.S. EPA/OPP/HED (2011a). The central estimate of the HQ for backpack workers, however, modestly exceeds the level of concern (HQ=2). U.S. EPA/OPP/HED (2011a) did not assess backpack workers. Based on upper bound estimates of exposures, most of the HQs exceed the level of concern by factors of up to 43. These estimates indicate that measures to limit or otherwise mitigate worker exposures are warranted.

For the general public, none of the acute exposure scenarios substantially exceed the level of concern, except for accidental exposure scenarios involving a spill of fluazifop-P-butyl into a small pond. At the upper bounds, the acute (non-accidental) exposure scenario for the consumption of contaminated vegetation reaches the level of concern following one application (HQ=1) and modestly exceeds the level of concern following two applications (HQ=1.3) and three applications (HQ=1.4) (SERA 2014).

Fluroxypyr – In terms of general exposures—i.e., daily exposure levels anticipated during a prolonged application program—the hazard quotients range from 0.0001 (aerial spray) to 0.08 (ground broadcast spray), which are below the level of concern (1.0) by factors ranging from 12.5 to 10,000. Thus, under normal conditions, even at the highest application rate, exposure levels of fluroxypyr-MHE are substantially below the level of concern.

The risk characterizations for all non-accidental exposure scenarios are easily interpreted, and there is no basis for assuming plausible risks to the general public. The upper bound of the highest hazard quotient for longer-term exposure scenarios is 0.06 (the longer-term consumption of contaminated vegetation), which is below the level of concern by a factor of about 16. The upper bound HQ values for the other longer-term exposure scenarios are associated with upper bound hazard quotients of 0.00002-0.009, which are below the level of concern by factors of about 100 to 50,000 (SERA 2009).

Glyphosate – For workers, the highest hazard quotient – i.e., 0.2, the upper range for workers involved in broadcast ground spray – is below the level of concern by a factor of about 5. The highest hazard quotient for any accidental exposure scenario for workers - i.e., 0.006 for the upper range of the hazard quotient for spill over the lower legs for one hour - is lower than the 140 level of concern by a factor of over 150. Confidence in these assessments is reasonably high because of the availability of dermal absorption data in human as well as worker exposure studies. The Forest Service may apply glyphosate at a maximum rate of 7 lbs a.e./acre, a factor of 3.5 higher than the typical application rate of 2 lbs a.e./acre. This has essentially no impact of the risk characterization for workers. The highest hazard quotient for the typical application rate is 0.2. For an application rate of 7 lbs a.e./acre, the corresponding hazard quotient would be higher by a factor of 3.5 or 0.7, which is still below the level of concern (SERA 2011c).

For members of the general public, the only non-accidental exposure scenario of concern is for acute exposure involving the consumption of contaminated vegetation shortly after glyphosate is applied. For this exposure scenario, the HQ reaches a level of concern (HQ=1) at an application rate of about 1.4 lbs a.e./acre. At the maximum labeled application rate of about 8 lbs a.e./acre, the resulting HQ value would be about 5.6 with a corresponding dose of about 10.8 mg/kg bw.

Imazapic – Typical exposures to imazapic do not lead to estimated doses that exceed a level of concern. For workers, no exposure scenarios, acute or chronic, exceed the RfD even at the upper ranges of estimated dose. For members of the general public, the upper limits for hazard quotients are below a level of concern except for the accidental spill of a large amount of imazapic into a very small pond. Based on the available information and under the foreseeable conditions of application, there is no route of exposure or scenario suggesting that workers or members of the general public will be at any substantial risk from longer-term exposure to imazapic.

The highest hazard quotient for workers based on general exposures is 0.02 – the upper range for directed ground spray and aerial applications. Thus, even at the highest application rate that might be used in Forest Service programs, the upper range of hazard quotients is below the level of concern by a factor of 25. While the accidental exposure scenarios are not the most severe one might imagine (e.g., complete immersion of the worker or contamination of the entire body surface for a prolonged period of time) they are representative of reasonable accidental exposures. The highest hazard quotient for accidental worker exposures given is 0.4 – i.e., the upper range for a worker wearing contaminated gloves for 1 hour. Because the estimate of the absorbed dose is linearly related to the hazard quotient, a scenario in which the worker wore contaminated gloves for 2.5 hours would be required to reach a level of concern (HQ of 1). Although there are several uncertainties in the longer-term exposure assessments for the general public, the upper limits for hazard quotients associated with the longer-term exposures are sufficiently below a level of concern that the risk characterization is relatively unambiguous: based on the available information and under the foreseeable conditions of application, there is no route of exposure or scenario suggesting that the general public will be at any substantial risk from longer-term exposure to imazapic even if the level of concern is set to 0.5 (SERA 2004a).

Imazapyr – Typical exposures to imazapyr do not lead to estimated doses that exceed a level of concern for either workers or members of the general public at either the typical or highest application rate. Although there are several uncertainties in the exposure assessments for workers and the general public, the upper limits for hazard quotients associated with the longer- term exposures are sufficiently below a level of concern that the risk characterization is relatively unambiguous. Based on the available information and under the foreseeable conditions of application, there is no route of exposure or scenario suggesting that the workers or members of 141 the general public will be at any substantial risk from longer-term exposure to imazapyr even at the upper range of the application rate considered in this risk assessment. The highest hazard quotient for workers based on general exposures given is 0.03 – the upper range for broadcast ground spray. Thus, even at the highest application rate that might be used in Forest Service programs, the upper range of hazard quotients is below the level of concern by a factor of 12. While the accidental exposure scenarios are not the most severe one might imagine (e.g., complete immersion of the worker or contamination of the entire body surface for a prolonged period of time) they are representative of reasonable accidental exposures. The highest hazard quotient for accidental worker exposures given is 0.006 – i.e., the upper range for a worker wearing contaminated gloves for 1 hour. Because the estimate of the absorbed dose is linearly related to the hazard quotient, a scenario in which the worker wore contaminated gloves for about 166 consecutive hours, or a about 7 days, would be required to reach a level of concern (a hazard quotient of one) at the typical application rate. Based on the highest application rate, the hazard quotient of 0.006 is below the level of concern by a factor of 60. Thus, at the highest application rate, a worker would have to wear contaminated gloves for 60 hours or 2.5 days to reach a level of concern (SERA 2011c).

Metsulfuron Methyl – Typical exposures to metsulfuron methyl do not lead to estimated doses that exceed a level of concern. For workers, no exposure scenarios, acute or chronic, exceeds the RfD even at the upper ranges of estimated dose. For members of the general public, all upper limits for hazard quotients are below a level of concern. Thus, based on the available information and under the foreseeable conditions of application, there is no route of exposure or scenario suggesting that workers or members of the general public will be at any substantial risk from acute or longer term exposures to metsulfuron methyl. For all exposure scenarios, the estimated dose scales linearly with application rate. Thus, at an application rate of 0.15 lb a.e./acre, the highest application rate contemplated by the Forest Service, the level of concern would be 0.2 – i.e., 0.03 lb/acre ÷ 0.15 lb/acre. The highest hazard quotient for workers is 0.02 – the upper range for directed ground spray. Thus, even at the highest application rate that might be used in Forest Service programs, the upper range of hazard quotients is below the level of concern. It should be noted that confidence in these assessments is diminished by the lack of a worker exposure study and the lack of experimental data on the dermal absorption kinetics of metsulfuron methyl. Nonetheless, the statistical uncertainties in the estimated dermal absorption rates, both zero-order and first-order, are incorporated into the exposure assessment and risk characterization. While the accidental exposure scenarios are not the most severe one might imagine (e.g., complete immersion of the worker or contamination of the entire body surface for a prolonged period of time) they are representative of reasonable accidental exposures. None of these hazard quotients approach a level of concern at the upper ranges (SERA 2004b).

Picloram – Workers are not at substantial risk from exposures to either picloram or hexachlorobenzene—i.e., all of the upper bound HQs are less than one at the maximum anticipated application rate for picloram of 1 lb a.e./acre. Confidence in this assessment is relatively high. For workers, the risk characterization is based on exposure rates used in all Forest Service risk assessments, and these rates are derived from studies which include worker applications of picloram.

For members of the general public, the only exposure scenario that leads to an HQ above the level of concern (HQ=1) is the upper bound HQ for the longer-term consumption of contaminated vegetation (HQ=2) at the maximum anticipated application rate of 1 lb a.e./acre. This scenario would not lead to

142 an exceedance in the level of concern at more typical application rates of 0.5 lb a.e./acre or less. While a modest exceedance in the level of concern cannot be viewed as acceptable, there is no basis for asserting that detectable adverse effects would be noted. In addition, the scenario for the longer- term consumption of contaminated vegetation may not be plausible in most instances because picloram will cause visible damage to vegetation that is directly sprayed (SERA 2011a).

Triclopyr – The risk characterization for workers involved in terrestrial applications of triclopyr TEA formulations is essentially identical, at least quantitatively, to the risk characterization given in the previous Forest Service risk assessment on triclopyr (SERA 2011b).

There is no indication that workers will be subject to hazardous levels of triclopyr at the typical application rate of 1 lb/acre and under typical exposure conditions. Nonetheless, at the upper range of exposures, all application methods exceed the level of concern based on the chronic RfD but not the acute RfD. Thus, for workers who may apply triclopyr repeatedly over a period of several weeks or longer, it is important to ensure that work practices involve reasonably protective procedures to avoid the upper extremes of potential exposure. At higher application rates, particularly rates that approach the maximum application rate of 10 lbs/acre, measures should be taken to limit exposure. These measures would need to be developed on a case-by-case basis depending on the specific application rates that are used and the type of the applications that are employed. For members of the general public, the risk characterization is thus relatively unambiguous at the typical application rate of 1 lb/acre: based on the available information and under the foreseeable conditions of exposure, there is no route of exposure or exposure scenario suggesting that the general public will be at risk from longer-term exposure to triclopyr.

Among the general public, hazard quotients greater than 1 may be possible by ingesting fruit or vegetation that has been sprayed with trichlpyr.

Cumulative Effects Herbicide Hazard Quotients and Effects to Human Health

Alternative A (No Action) Under the no action alternative, no herbicide use is proposed. There are cumulative effects associated with this alternative Alternative B (Proposed Action) The herbicide risk assessments specifically consider the effects of repeated exposures and no adverse effects are anticipated. As discussed in the dose-response and dose-severity relationships (SERA 2014, 2011a, 2011b, 2011c, 2009, 2007, 2006, 2004a, 2004b, 2004c, and 2004d), the daily dose rather than the duration of exposure determines the toxicological response. Consequently, repeated exposure to levels below the toxic threshold should not be associated with cumulative effects. The Cherokee National Forest currently uses small amounts of herbicides for non-native exotic plant control, forestry applications and small amounts of insecticide for hemlock woolly adelgid control. The use of various herbicides on private land is generally for the widespread control of unwanted plants in agricultural treatments or by private individuals near their homes. Cumulative effects that might result from the use of herbicides on private and Forest Service land are difficult to assess. Information about additional effects of herbicide use in an environment already impacted by industrial pollution, pesticide use, and automobile emissions is unavailable. For these reasons, because these treatments are unlikely to

143 interact with other activities, and because effects to human health and safety are likely to be small, Alternative B will result in few or no cumulative effects to human health and safety. Alternative C Alternative C is similar to Alternative B with respect to herbicides being used. Alternative C does not include the use of herbicides for utility corridors that cross Cherokee NF lands. Alternative C involves less herbicide use than Alternative B. For the reasons also stated in alternative B, these treatments are unlikely to interact with other activities, and because effects to human health and safety are likely to be small, Alternative C will result in few or no cumulative effects to human health and safety.

CONSULTATION AND COORDINATION

The Forest Service consulted the following individuals, Federal, State, and local agencies, tribes and non-Forest Service persons during the development of this environmental assessment: ID TEAM MEMBERS: Mary Miller, Forest Wildlife Biologist, Team Leader Robert Lewis, Forest Fuels Specialist Doug Byerly, Forest Landscape Architect Mark Pistrang, Forest Botanist/Ecologist Jim Herrig, Forest Fisheries Biologist Quentin Bass, Forest Archeologist Ali Reddington, Forest Hydrologist Stephanie Medlin, Forest NEPA Coordinator FEDERAL, STATE, AND LOCAL AGENCIES:

Alexander, Lamar U.S. Senate Harper, Herbert Tennessee Historical Commission Carter County Mayor Hawk, David State Representative Cocke County Executive Isaacs, L. Thomas Division of Water Cooper, Robin, Tennessee Department of Pollution Environment and Conservation Johnson County Executive Crowe, Rusty State Senate Johnson, Glen Tennessee Wildlife Galbreath, Dodd Tennessee Resources Agency Environmental Policy Office McCoy, Roger Tennessee Division of Greene County Executive

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Natural Heritage Underhill, Pamela National Park Service

Patrick, Ann, Tennessee Valley Authority Washington County Executive

Ramsey, Ron State Senate Weems, David Greene County Highway Department Rose, Larry, Unicoi County Executive Williams, Kent State Representative Saunders, Ron, Tennessee Wildlife Resources Agency Williams, Virginia AT Coordinator, Mt Rogers NRA Southerland, Steve State Senate Wolfe, Bobby, Tennessee Wildlife Sullivan County Executive Resources Agency

TRIBES:

Alabama-Coushatta Tribe of Texas

Alabama-Quassarte Tribal Town of Oklahoma

Cherokee Nation

Coushatta Tribe of Louisiana

Eastern Band of Cherokee Indians

Kialegee Tribal Town

Muscogee (Creek) Nation

Thlopthlocco Tribal Town

United Keetoowah Band of Cherokee Indians

Poarch Band of Creek Indians

OTHERS: Allen, Barbara J. Banker, Mark, Regional Biologist Ruffed Grouse Society Arnold, Walter Bates, Brian

Ashbrook, Craig M., Professor SVCC Bell, Adrianne, The Nature Conservancy

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Benko, Mark, Tennessee Conservation League Dourson, Dan

Bennett, Matt, Tennessee Forestry Association Duckworth, Rodger Ruffed Grouse Society

Benton, Richard Duncan, Harmon, RGS

Bernardi, William, Ruffed Grouse Society (RGS) East Tennessee Bobwhite Quail Unlimited

Bingham, Hoyle, Mid-Appalachian Highlands Club Eastin, Todd

Bowers, Rick K. Foster, Powell

Bristol Chamber of Commerce Francisco, Sarah, Southern Environmental Law Center Burris, Bill, Willamette Industries, Inc., Kingsport Mills Gobble, Sam

Butler, Andrew Gouge, Mark, RGS

Butler, Mike, Tennessee Conservation League Gregg, Jerry, RGS

Call, Gabrielle The Nature Conservancy Grogan, Jonathan, Off The Beaten Path Adventures

Carolina Mountain Club Guthrie, Julie

Casey, Robert Ruffed Grouse Society Gutierrez, Ruth, Sierra Club

Chapman, Charles Hall, Clifford, RGS

Coffey, Wallace Heinze, Herb, Backcountry Horsemen

Columbia Forest Products Hendrickon, Doug Willamette Industries, Inc.

Culp, John Powell Industries Hensley, Jerry Unaka Forest Products

Cutshaw, Dean Hitchcock, Stan Ruffed Grouse Society

Davis, Sara Hodges, Stephen & Jill

Deloach, Joe, Tennessee Eastman Hiking Club Holtsclaw, Nick, Doe Valley Sportsman Association Derrick, Brian Hood, Aaron Polk County Federal Lands Dinwiddie, Candace, Tennessee Forestry Committee Association Ditzer, Curt Ruffed Grouse Society Hopson, Ed

Douglas, Ted, RGS Hosmer, Mary

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Howell, C.F. Morrell, John

Irwin, Hugh, Southern Appalachian Forest Mounger, Davis Coalition Murray, Catherine Cherokee Forest Voices Isenberg, Greg, Ruffed Grouse Society Murray, Judy Ives, Ken Ruffed Grouse Society Nagel, Jerry W. Jervis, Lawrence Nickell, David Johnson, Kirk Norris, Travis, RGS Kelly, Josh Western North Carolina Alliance Novak, Steve, Wildlaw Longerbeam, Larry Ruffed Grouse Society Palmer, Lyle, Appalachian Whitetail Association Lynch, Johnny Patrick, David Mallicoat, Don Ruffed Grouse Society Payne, Ray Mayfield, G.R. Jr. Peterson, Jim Ruffed Grouse Society McDowell, Tim Pilk, Tim Medlock, Katherine The Nature Conservancy Pinnick, Wayne Mead Corporation Ploetz, Bob RockTenn Mealor, Ken Ruffed Grouse Society Ponder, Terry Merritt, Ron Ruffed Grouse Society Prater, Ben Wild South Miller, Scotty, RGS Puckett, Jason Tennessee Forestry Association Miller, Sonny, RGS Quillen, Gary Modica, Linda, Sierra Club - State of Franklin Group Ramsey, David

Moein, George J. Ramsey, Ron

Momich, Pat Reed, Ernie

Moody, Claudia, North East Tennessee Tourism Richards, Jeff Association Robinett, Rita Morrell, Earnest Rogers, Mark, Ruffed Grouse Society

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Ross, Bob, Trout Unlimited-Cherokee Chapter Street, Parker, RGS

Rusk, Charles R., Tennessee Mountain Switzer, Harry Management Tennessee Citizens for Wilderness Planning Russo, Dan Tester, Mark L., RGS Saunders, Bruce Thornberry, Kathy, WEMB Radio Saylor, Jeff Ruffed Grouse Society Unbarger Joe, RGS Schneider, Gary Partners of the Cherokee Varnell, Charles and Patti Seay, Bob, Newport/Cocke County Chamber of Commerce Volunteer Logging Inc. Seward, John C. Walton, Don Carolina Mountain Club

Shelley, Mark, Southern Appalachian Forest Webb, Gay Coalition Webb, Jim Ruffed Grouse Society Simerly, Larry, RGS Webb, Rodney, Native Forest Network Skelton, William H., Bass, Berry, and Sims PLC Weist, Tom Sledjeski, Michael Whitehead, Lester Leon Smith, David Whitworth, Dean, Cherokee Forest Voices Smith, Trent Williams, Bill W., Rhyman Clock Company Sommerville, Morgan, Appalachian Trail Conference York, Chris Ruffed Grouse Society

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Askins, R.A. 2000. Restoring North America’s birds: lessons from landscape ecology. Yale University Press. 320 pp.

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Barclay, Lee A. 2003. Letter of Concurrence for the Final Environmental Impact Statement on the Revised Land and Resource Management Plan.

Barclay, L. 2007. USFWS concurrence letter #07-I-0288 dated 5 February 2007. BASF. 2011. Plateau herbicide specimen label. Research Triangle Park, NC.

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Bertagnolli BL; Nadakavukaren MJ. 1974. Physiological responses of Chlorella pyrenoidosa to 2,4-dichlorophenoxyacetic acid. J. Exp. Bot. 25(84): 180-188. (Cited in USDA 2006).

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