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DRAFT Savannah NWR Hunt Plan and Environmental Assessment

DRAFT Savannah NWR Hunt Plan and Environmental Assessment

SAVANNAH NATIONAL WILDLIFE REFUGE

AMERICAN , ARMADILLO, BEAVER, OPOSSUM, AND DRAFT HUNT PLAN

AND

ENVIRONMENTAL ASSESSMENT

U.S. Department of the Interior and Wildlife Service Savannah National Wildlife Refuge 694 Beech Hill Ln. Hardeeville, SC 29927

March 2020

Table of Contents

Section A. Draft Hunt Plan ...... 1 I. Introduction ...... 2 A. Refuge Land Acquisition History ...... 4 B. Overview of Refuge Management ...... 5 II. Statement of Objectives ...... 8 III. Description of Hunting Program ...... 9 A. Areas to be Opened to Hunting ...... 9 B. Species to be Taken, Hunting Periods, Hunting Access ...... 9 C. Hunter Permit Requirements...... 10 D. Consultation and Coordination with the State ...... 11 E. Law Enforcement ...... 11 F. Funding and Staffing Requirements ...... 11 IV. Conduct of the Hunting Program ...... 12 A. Hunter Permit Application, Selection, and/or Registration Procedures ...... 12 B. Refuge-Specific Hunting Regulations ...... 12 C. Relevant State Regulations ...... 12 D. Other Refuge Rules and Regulations for Hunting ...... 13 V. Public Engagement ...... 13 A. Outreach for Announcing and Publicizing the Hunting Program ...... 13 B. Anticipated Public Reaction to the Hunting Program...... 13 C. How Hunters Will Be Informed of Relevant Rules and Regulations ...... 13 VI. Compatibility Determination ...... 13 References ...... 14 Section B. Environmental Assessment ...... 15 1.0 Purpose and Need ...... 16 Proposed Action ...... 16 Background ...... 18 Purpose and Need for the Proposed Action ...... 20 2.0 Alternatives ...... 20

Alternatives Considered ...... 20 Alternative A – Continue Current Management – No Action Alternative ...... 20 Alternative B – Implement 2020 American Alligator, Armadillo, Beaver, Opossum, and Raccoon Hunt Plan – Proposed Action ...... 21 3.0 Affected Environment and Environmental Consequences ...... 22 Affected Environment ...... 22 Natural and Physical Resources ...... 22 Cultural Resources ...... 25 Wildlife-Dependent Recreation ...... 26 Socioeconomic Environment ...... 26 Environmental Consequences ...... 26 Cumulative Impact Analysis ...... 28 Hunted Species – White-tailed ...... 30 Hunted Species - ...... 30 Hunted Species – and Squirrel ...... 31 Hunted Species – Migratory ...... 32 Hunted Species - ...... 33 Hunted Species – Feral Hog ...... 34 Hunted Species –American Alligator ...... 34 Hunted Species – Armadillo, Beaver, Opossum, and Raccoon ...... 35 Threatened and and Other Special Status Species ...... 35 Vegetation ...... 36 Air Quality ...... 37 Water Resources ...... 37 Visitor Use and Experience ...... 38 Cultural Resources ...... 38 Refuge Management and Operations ...... 39 Socioeconomics ...... 39 Climate Change and Local Weather ...... 41 Humaneness and Welfare Concerns ...... 41 Environmental Justice ...... 41 Natural Resources ...... 42 Visitor Use and Experience ...... 42

Cultural Resources ...... 43 Refuge Management and Operations ...... 43 Socioeconomics and Other Topics...... 43 Summary of Analysis ...... 45 Monitoring ...... 47 4.0 List of Sources, Agencies, and Persons Consulted ...... 47 References ...... 47 List of Preparers ...... 49 State Coordination ...... 49 Tribal Consultation ...... 49 5.0 Public Outreach ...... 49 6.0 Determination ...... 49 Section C. Appendices ...... 51 Appendix A. Other Key Applicable Statutes, Executive Orders, and Regulations ...... 51 Appendix B. Draft Compatibility Determination ...... 54 Appendix C. Section 7 ...... 63

List of Figures

Figure Hunt Plan-1. Proposed Hunt Areas for American Alligator, Armadillo, Beaver, Opossum, and Raccoon on Savannah NWR ...... 3 Figure EA-1. Proposed Hunt Areas for American Alligator, Armadillo, Beaver, Opossum, and Raccoon on Savannah NWR ...... 17

List of Tables

Table Hunt Plan-1. Species and Refuge Hunt Season on Savannah National Wildlife Refuge .. 10 Table EA-1. Affected Natural Resources and Anticipated Impacts of the Alternatives ...... 30 Table EA-2. Affected Visitor Use and Experience Resources and Anticipated Impacts of the Alternatives ...... 38 Table EA-3. Affected Cultural Resources and Anticipated Impacts of the Alternatives ...... 38 Table EA-4. Affected Refuge Management and Operations Resources and Anticipated Impacts of the Alternatives ...... 39 Table EA-5. Affected Socioeconomic Resources and Anticipated Impacts of the Alternatives . 39 Table EA-5.1. Savannah NWR: 2017 Recreation Visits ...... 40 Table EA-5.2. Savannah NWR: Visitor Recreation (2017, $,000) ...... 40 Table EA-5.3. Savannah NWR: Local Economic Contributions Associated with Recreation Visits (2017 $,000)...... 40 Table EA-6. Anticipated Cumulative Impacts of the Alternatives ...... 42

Section A. Draft Hunt Plan

Savannah National Wildlife Refuge American Alligator, Armadillo, Beaver, Opossum, and Raccoon Draft Hunt Plan

March 2020

U.S. Fish and Wildlife Service

Savannah National Wildlife Refuge 694 Beech Hill Ln. Hardeeville, SC 29927

Submitted By:

Project Leader

______Signature Date

Concurrence:

Refuge Supervisor

______Signature Date

Approved:

Regional Chief, National Wildlife Refuge System

______Signature Date

SAVANNAH NATIONAL WILDLIFE REFUGE AMERICAN ALLIGATOR, ARMADILLO, BEAVER, OPOSSUM, AND RACCOON DRAFT HUNT PLAN

I. Introduction

The proposed 2020 Savannah National Wildlife Refuge (NWR, refuge) Hunt Plan would be an amendment to the 2016 Final Savannah National Wildlife Refuge Hunt Plan (USFWS 2016). The proposed 2020 Hunt Plan would add American alligator (Alligator mississippiensis) to the species listed as open to hunting in both and on 11,648 acres. In addition, armadillo (Dasypus novemcinctus), beaver (Castor canadensis), opossum (Didelphis virginiana), and raccoon (Procyon lotor) would be added under the proposal as additional species to be taken only on 15,066 acres in Georgia as incidental species, which means these species would be able to be taken incidentally during other authorized hunts in the Georgia portion of the refuge. Figure 1 depicts the proposed hunt areas for American alligator and for armadillo, beaver, opossum, and raccoon. To ensure the U.S. Fish and Wildlife Service (Service, USFWS) continues to meet its policies and fulfills the mission and purpose for which the refuge was established, the Service has developed the proposed 2020 Hunt Plan, proposed compatibility determination (USFWS 2020b), and associated Environmental Assessment (EA) (USFWS 2020a) to evaluate the proposal to add American alligator, armadillo, beaver, opossum, and raccoon to the existing hunt program at Savannah NWR.

Public hunting on Savannah National Wildlife Refuge was determined to be a compatible wildlife- oriented recreational use of Savannah NWR based on the 2010 draft Comprehensive Conservation Plan (CCP) and Environmental Assessment (EA) (USFWS 2010) and the 2011 final CCP and Finding of No Significant Impact (FONSI) (USFWS 2011). Hunting is often used to control the overpopulation of some species within a given natural community and can provide for greater wildlife diversity when used as a management tool. Hunting can also be utilized as a means to increase awareness of the refuge, educate refuge users about conservation issues, provide for priority public recreational hunting opportunities, and ensure long-term public support for habitat management and future refuge management activities. The proposed additions to the hunting program at Savannah NWR, outlined in this Hunt Plan, were designed to minimize potential conflicts with refuge purposes and other priority public uses, while providing increased opportunities for a compatible priority public use.

National Wildlife Refuges are guided by the mission and goals of the National Wildlife Refuge System (NWRS, Refuge System), the purposes of an individual refuge, Service policy, and laws and international treaties. Relevant guidance includes the National Wildlife Refuge System Administration Act of 1966, as amended by the National Wildlife Refuge System Improvement Act of 1997; Refuge Recreation Act of 1962; and selected portions of the Code of Federal Regulations and Fish and Wildlife Service Manual.

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Figure Hunt Plan-1. Proposed Hunt Areas for American Alligator, Armadillo, Beaver, Opossum, and Raccoon on Savannah NWR

3 Savannah NWR, one of seven refuges comprising the Savannah Coastal Refuges Complex (Complex), was established by Executive Order 4626 on April 6, 1927, in Jasper County, South Carolina, on 2,352 acres of land owned by the United States near the . Originally called the Savannah River Refuge, these lands were reserved for use by the Department of Agriculture as a preserve and breeding ground for native birds. Savannah NWR is located in both Georgia and South Carolina.

A. Refuge Land Acquisition History

On November 12, 1931, President Herbert Hoover signed Executive Order 5748, revoking Executive Order 4626, adding 207 acres to the existing land base, and renaming the unit the Savannah River Wildlife Refuge. Executive Order 7391, signed by Franklin D. Roosevelt on June 17, 1936, increased the acquisition boundary of the refuge to include an additional 22,870 acres of land either acquired or to be acquired by the federal government. Between 1935 and 1938, a total of 9,980 acres of land were either transferred to or purchased by the Service for to the refuge. A Presidential Proclamation on April 10, 1939 closed migratory bird hunting on channels of the Savannah River known as Steamboat River, Housetown Cut, Middle River (from the head of Argyle Island to its confluence with Front River), and Back River (from the mouth of Union Creek to the foot of Argyle Island). This closure set aside these waters as a permanent sanctuary for migratory birds on these otherwise open waters. On July 30, 1940, Presidential Proclamation 2416 renamed the refuge the Savannah National Wildlife Refuge. In 1956, a five- acre tract was purchased from an individual landowner, and in 1964, 459 acres were added when the fee title to Hog Island and adjacent lands to the north were acquired through an exchange of spoilage rights with Chatham County, Georgia. That same year, Savannah Electric and Power Company deeded 34 acres to the Service in exchange for a power line right-of-way under the Fish and Wildlife Act of 1956. South Carolina landowner Donald Livingston donated 37 acres to the Service in 1968, and in 1974, 24 acres were acquired from the Seaboard Coast Line Railroad Company. The 12,493-acre Argent tract was purchased from Union Camp Corporation in 1978 using Migratory Bird Conservation Act funds. Several years later 54 additional acres were added to the tract to straighten out the east boundary of the refuge. In 1983, a land exchange with David C. Barrow III resulted in the acquisition of 18 acres. Mr. Barrow later sold a 432-acre tract to the Service in 1998. In Effingham County, Georgia, 712 acres known as Bear Island were purchased in 1993 from William Bradley, et al. In 2000, 887 acres known as the Solomon Tract were purchased from Oak Grove Bluff, Inc., and in 2001, 401 acres were purchased from John C. Wylly Jr. (both tracts located in Chatham County, Georgia). In 2002, the Service entered into an agreement with the Georgia Department of Natural Resources assuming management authority over 840-acres known as the Nigel Tract, located in Effingham County. Later that year, a 240-acre tract was purchased from Joseph H. Harrison. The Service acquired 276 acres along the eastern boundary of the refuge from the owners of the Riverport Development. These acres were purchased in two phases, in 2013 and 2014, and helped secure one of the remaining inholdings within the refuge’s acquisition boundary. Abercorn Island, 2,070 acres, was added to the refuge in 2018 bringing the total current refuge acreage to 29,452. These and all other future acquisitions, within the current refuge acquisition boundary, would be included in the refuge’s hunt program, where compatible with other refuge uses.

4 B. Overview of Refuge Management

The majority of refuge habitats are naturally occurring , including tidal and non-tidal bottomland hardwood, tidal estuarine and , and scattered palustrine forested wetlands. Tidal areas within these wetlands are subject to daily water level ranging from six to ten feet. Managed freshwater impoundments (historic rice fields locally known as pools) provide 3,000 acres of wetlands where water levels are fully controlled. Additionally, hardwood hammocks and scattered upland parcels comprised of various hardwoods, pines, and grassland fields are present. Most areas outside of the managed freshwater impoundments are managed passively and monitored for the presence of invasive, exotic plants and . The Solomon Tract contains a combination of upland and habitats that are actively managed for the benefit of various resident and migratory bird species.

Active management of the 16 pools enhances the importance of the refuge as a haven for numerous wildlife species. This area is particularly valuable to migratory bird populations. Heavy emphasis is placed upon habitat management for wintering waterfowl, migratory shorebirds, and wading bird feeding habitat. In addition to these pools, the refuge is required to supply freshwater, through the Diversion Canal, to neighboring Fife Plantation. Through use of the water provided by the refuge, Fife Plantation supports numerous species of wetland dependent wildlife. The refuge provides quality habitat for resident and non-game species as well. Several endangered and threatened species also inhabit the refuge, including Atlantic sturgeon (Acipenser oxyrinchus), shortnose sturgeon (Acipenser brevirostrum), (Trichechus manatus), and wood (Mycteria americana).

Savannah NWR offers an array of public use opportunities, including wildlife observation, photography, interpretation, environmental education, , and hunting. The majority of the refuge is limited to access by boat only from the Savannah River and its tributaries. However, land-based access to the refuge is available to the public with most being centered on the managed freshwater impoundment system. Approximately 36 miles of dikes are open to public use for hiking and cycling primarily in support of wildlife observation and photography. The four-mile long Laurel Hill Wildlife Drive is open to public driving throughout the year.

The refuge’s establishing authorities and related purposes include those listed.

“…as a refuge and breeding ground for birds and wild animals subject to future use in navigation if necessary and to valid existing rights if any” (Executive Order 5748, April 6, 1927)

“…for lands acquired under the Migratory Bird Conservation Act “for use as an inviolate sanctuary, or for any other management purpose, for migratory birds” (16 U.S.C. §715d)

“…for lands acquired under the Refuge Recreation Act for “(1) incidental fish and wildlife-oriented recreational development, (2) the protection of natural resources, (3) the conservation of endangered species or threatened species” (16 U.S.C. §460k)

5 “…for “the conservation of the wetlands of the Nation in order to maintain the public benefits they provide and to help fulfill international obligations contained in various migratory bird treaties and conventions” (16 U.S.C. §3901(b), 100 Stat. 3583, Emergency Wetlands Resources Act of 1968)

“…for the development, advancement, management, conservation, and protection of fish and wildlife resources” (16 U.S.C. §742f (a)(4))

“…for the benefit of the United States Fish and Wildlife Service, in performing its activities and services. Such acceptance may be subject to the terms of any restrictive or affirmative covenant, or condition of servitude” (16 U.S.C. §742f(b)(1), Fish and Wildlife Act of 1956)

To meet specific refuge and Service directives, the primary management goals for Savannah NWR include:

Goal 1. Protect, maintain, enhance, and restore healthy and viable populations of migratory and resident fish, wildlife, and native plants, including all federal and state threatened and endangered species found within the Atlantic Coastal Plain, in a manner that supports state, national, and international treaties, plans and initiatives.

Goal 2. Protect, maintain, enhance, and where appropriate, restore suitable habitat for the conservation and management of migratory and resident fish, wildlife, and native plants, including all federal and state threatened and endangered species endemic to the region. Preserve and enhance wilderness values of designated Wilderness, consistent with the establishing purposes.

Goal 3. Where appropriate and compatible, provide environmental education, wildlife interpretation, and wildlife-dependent recreational opportunities. Public use will be consistent with the Refuge System mission and provide visitors a greater understanding and enjoyment of fish, wildlife, and their habitats on the Complex.

Goal 4. Identify, conserve, and protect natural and cultural resources through partnerships, land protection programs, and law enforcement. Ensure a safe and secure environment for the visiting and Service personnel.

Goal 5. Provide sufficient funding, staffing, facilities, and infrastructure to fulfill the Complex’s purposes, goals, and objectives.

The mission of the NWRS, as outlined by the NWRS Administration Act (NWRSAA), as amended by the NWRS Improvement Act (NWRSIA) (16 U.S.C. §668dd et seq.), is:

“... to administer a national network of lands and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans.”

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The NWRSAA mandates the Secretary of the Interior in administering the Refuge System to (16 U.S.C. §668dd(a)(4)):

 Provide for the conservation of fish, wildlife, and plants, and their habitats within the NWRS;  Ensure that the biological integrity, diversity, and environmental health of the NWRS are maintained for the benefit of present and future generations of Americans;  Ensure that the mission of the NWRS described at 16 U.S.C. §668dd(a)(2) and the purposes of each refuge are carried out;  Ensure effective coordination, interaction, and cooperation with owners of land adjoining refuges and the fish and wildlife agency of the States in which the units of the NWRS are located;  Assist in the maintenance of adequate water quantity and water quality to fulfill the mission of the NWRS and the purposes of each refuge;  Recognize compatible wildlife-dependent recreational uses as the priority general public uses of the NWRS through which the American public can develop an appreciation for fish and wildlife;  Ensure that opportunities are provided within the NWRS for compatible wildlife- dependent recreational uses; and  Monitor the status and trends of fish, wildlife, and plants in each refuge.

Therefore, it is a priority of the Service to provide for wildlife-dependent recreation opportunities, including hunting and fishing, when those opportunities are compatible with the purposes for which the refuge was established and the mission of the NWRS.

The Refuge Recreation Act of 1962 (16 U.S.C. §460k) authorizes the Secretary of the Interior to administer refuges, hatcheries, and other conservation areas for recreational use. The Refuge Recreation Act requires: 1) that any recreational use permitted will not interfere with the primary purpose for which the area was established and 2) that funds are available for the development, operation, and maintenance of the permitted forms of recreation.

Fundamental to the management of lands within the Refuge System is the NWRS Improvement Act of 1997 (NWRSIA) (Public Law 105-57), an amendment to the NWRS Administration Act of 1966. The NWRSIA provides a mission for the Refuge System and clear standards for its management, use, planning, and growth. The NWRSIA recognized that wildlife-dependent recreational uses, including hunting, fishing, wildlife observation and photography, and environmental education and interpretation, can be allowed when determined to be compatible with the mission of the Refuge System and purposes of the refuge. These six compatible wildlife-dependent recreational uses (known as the “Big 6”) are the priority general public uses of the Refuge System and are given priority consideration in planning and management over other uses. Hunting, as specified in this proposed plan, is a Big 6 wildlife-dependent recreational use and the law states that as such, it “shall receive priority consideration in National Wildlife Refuge planning and management.” The Secretary of the Interior may then permit hunting on a refuge if it is determined that the use is compatible and does not materially interfere with the

7 purposes of Savannah NWR. This determination is based upon the 2016 Savannah NWR Compatibility Determination on Hunting (USFWS 2016).

According to Savannah NWR’s 2018 Refuge Annual Performance Plan (RAPP), the Service estimated the number of hunting visits: deer, turkey, and feral hog = 2,875 visits; squirrel = 240 visits; and duck and coot = 539 visits. The refuge requires hunters to purchase an annual hunt permit, which is valid for all refuge hunts on all refuges contained within the Complex. The processing of this permit is administered through RecAccess, a contractor that manages permits for various federal and state agencies. In fiscal year 2017, permits sold for Complex hunts generated approximately $9,500 in revenue through the Service’s Recreational Fee Program. These funds are deposited into a designated account to be used solely for the administration and enhancement of the refuge hunt program. Many of the annual hunt administration costs including salary, equipment, boundary signs, and maintenance are associated with general management of the refuge and are required whether hunting is permitted or not. Printing hunt brochures and conducting other hunt-related administrative activities are the primary costs directly associated with hunting. Total costs are approximately $5,000.00 per year. These costs should remain unchanged with implementation of the proposed Hunt Plan.

II. Statement of Objectives

The objectives of a hunting program on Savannah NWR are listed.

1. Provide the public with a high-quality recreational experience and increase opportunities for hunting on current and future refuge lands consistent with federal and state laws and regulations in a manner that does not adversely affect local or regional wildlife populations. 2. Maintain a compatible hunt program with other uses on current and future refuge properties. 3. Control non-native and/or populations. 4. Allow compatible public use of a valuable, renewable resource on current and future refuge lands. 5. Meet refuge provisions for recreational hunting listed in the 2011 CCP. 6. Support the Conserving the Future vision document by implementing Recommendation 17 to increase quality hunting and fishing opportunities on National Wildlife Refuges and to increase public awareness and support for the refuge and Refuge System.

A total of 29,751 acres of Savannah NWR are currently open to hunting of white-tailed deer (Odocoileus virginianus), turkey (Meleagris gallopavo), feral hog (Sus scrofa), squirrel (Sciurus carolinensis), rabbit (Sylvilagus floridanus), coyote (Canis latrans), waterfowl, and (Zenaida macroura). This plan includes the proposed overall expansion of the hunt area to include the introduction of new species to the hunt program: American alligator, raccoon, opossum, armadillo, and beaver. The latter four species would be treated as incidental species, that is, available for take during other open seasons. The total acreage open to hunting would remain the same. The proposed hunt plan and compatibility determination (USFWS 2020b) would support the CCP for the refuge, notably implementing Objective 3.6.d (Savannah NWR –

8 Hunting: Over the 15-year life of this CCP, maintain, and where possible, expand current hunting opportunities). The proposal would also support refuge management objectives 1.5.d and 2.11.d (Other Fish, Wildlife, and Plants), 2.12.d (Invasive Species), 2.13.d (Wildlife Disease), 4.3.d (Law Enforcement) (USFWS 2011). Management goals and objectives for Savannah NWR are outlined in the final CCP (USFWS 2011).

III. Description of Hunting Program

A. Areas to be Opened to Hunting

Much of Savannah NWR is already open to some form of hunting each year. Specifically for migratory birds, no more than 40% of the refuge can be opened to hunting at any given time. All refuge lands would be designated as one of six types for hunting purposes:

1) Closed to all hunting; 2) Open to youth hunting only; 3) Open to deer/turkey/small game/coyote/feral hog/incidental; 4) Open to deer/turkey/small game/coyote/feral hog/incidental/alligator (north of I- 95)/migratory bird hunting; 5) Open to wheelchair-dependent ; and 6) Open to wheelchair-dependent deer, quota youth waterfowl/limited, trial basis dove hunting.

American alligator hunting would take place on lands owned or administered by the Service for Savannah NWR within the states of Georgia and South Carolina north of I-95 (Figure 1). The area encompasses approximately 11,183 acres of bottomland forested wetlands interspersed with upland hammocks. Armadillo, opossum, raccoon, and beaver would be treated as incidental species and would be open only on the Georgia side where big game and small game are open.

B. Species to be Taken, Hunting Periods, Hunting Access

AMERICAN ALLIGATOR HUNTING: American alligator hunting would occur in the northern section of the refuge within the states of Georgia and South Carolina north of I-95. The refuge is closed to all hunting for species not listed as open. Refuge hunts would follow State seasons and method of take, except for trapping. Trapping would not be allowed. There would be no special entry or access procedures for hunting during the alligator hunt. While participating in these hunts, hunters would be able to enter Refuge hunt areas by boat from the Savannah River or its tributaries or from adjacent private lands by boat or foot access.

ARMADILLO, RACCOON, OPOSSUM, AND BEAVER HUNTING: These species are lumped as incidental species and would be open for incidental harvest during the hunting season on areas only within Georgia and currently open to big game and small game. Trapping of these species would not be allowed. There would be no special entry or access procedures for hunting during the season these species would be open. While participating in

9 these hunts, hunters would be able to enter refuge hunt areas by boat from the Savannah River or its tributaries or from adjacent private lands by boat or foot access.

Table Hunt Plan-1. Species and Refuge Hunt Season on Savannah National Wildlife Refuge

Species Refuge Hunt Season White-tailed Deer -Limited1, within state seasons -Quota2 wheelchair-dependent hunt in South Carolina Wild Turkey -Limited, within state seasons -Quota youth hunt, within state seasons Rabbit -Limited, within state seasons Squirrel -Limited, within state seasons Waterfowl -General3, state seasons -Quota youth hunt in SC Mourning Dove -General, state seasons in migratory bird hunting area -Limited, 3-year trial basis, Tuesdays and Thursdays only in September and October in selected SC impoundments Coyote -During all refuge hunts Feral Hog -During all refuge hunts American Alligator -Limited1, within state seasons Armadillo, Beaver, Opossum, and -Georgia only, during big game and small Raccoon game seasons 1Limited refuge seasons fall within the framework of state seasons, but are/would be further restricted. 2Quota refuge seasons fall within the framework of state seasons but require selection through a lottery. 3General refuge seasons coincide with state seasons.

C. Hunter Permit Requirements

 Hunters would be required to obtain an alligator harvest permit through the selection processes of the states of Georgia and South Carolina.  The Service requires all hunters, 16 years of age or older, to purchase, and carry while hunting on Savannah NWR, a Savannah Coastal Refuges Complex Annual Hunt Permit, which certifies they understand and will comply with all refuge hunting regulations and provides information related to hunter participation. Fees collected (80%) through the purchase of the Savannah Coastal Refuges Complex Annual Hunt Permit are deposited into a Recreational Fee Program account, which is specifically used on refuge hunt program administration and improvements. Additionally, hunters age 15 and under are required to obtain a free hunt-specific permit instead of purchasing a Savannah Coastal

10 Refuges Complex Annual Hunt Permit. This hunt-specific permit allows youth hunters access to all non-quota hunts for the annual hunting season.

D. Consultation and Coordination with the State

Savannah NWR staff work cooperatively and regularly on various projects with staff from both the Georgia and South Carolina departments of natural resources (DNRs). Hunting opportunities on the refuge are generally designed to comply with seasons, limits, and legal firearms and bows in both states. Refuge management and biological staff meet annually with DNR representatives from each state to discuss current issues, status of hunts, and any proposed changes to regulations. The draft hunt plan, CD, and EA were made available to the public for review and comment, including the State and potentially interested Native American Tribes. In the event that new infrastructure or improvements to existing infrastructure that involve ground disturbing activities would be needed to support the hunt program in the future, the Service would coordinate and consult, as needed (e.g. under the National Environmental Policy Act, Endangered Species Act, and National Historic Preservation Act).

E. Law Enforcement

Enforcement of refuge violations normally associated with management of the refuge is the responsibility of commissioned Federal Wildlife Officers (FWOs). Two FWOs are currently assigned to the Complex. Other FWOs, Service Special Agents, state game wardens, and the local sheriff departments often assist the Complex FWOs.

Listed are some of the methods used to control and enforce hunting regulations.

• Refuge and hunt area boundaries are clearly posted. • The refuge provides maps that show hunt areas. • Complex FWOs randomly check hunters for compliance with federal and state laws, as well as refuge-specific regulations pertaining to hunting. This would include stipulations outlined in the proposed Hunting Compatibility Determination. • Complex FWOs coordinate with state game wardens and other law enforcement agencies. • Information is made available at the Savannah NWR Visitor Center and on the refuge’s website.

Detailed information about the Complex Law Enforcement program can be found in the 2016 Complex Law Enforcement Plan.

F. Funding and Staffing Requirements

Many of the annual hunt administration costs including salary, equipment, boundary signs, and maintenance are associated with general management of the refuge and are required whether hunting is permitted or not. Printing hunt brochures, purchasing replacement boundary signs, and providing law enforcement are the primary costs directly associated with hunting. Immediately prior to and during the active hunting season, one full-time employee is devoted to conducting

11 hunt-related administrative activities. The cost associated with implementing this hunt plan would remain unchanged from the current costs.

IV. Conduct of the Hunting Program

A. Hunter Permit Application, Selection, and/or Registration Procedures

The proposed hunts would be open to all eligible hunters, with proper state licenses, who have purchased the Complex Annual Hunt Permit. There is no check-in/check-out required. The Service requires all hunters, 16 years of age or older, to purchase, and carry while hunting, a Savannah Coastal Refuges Complex Annual Hunt Permit, which certifies they understand and will comply with all refuge hunting regulations and provides information related to hunter participation. Fees collected (80%) through the purchase of the Annual Hunt Permit are deposited into a Recreational Fee Program account, which is specifically used on refuge hunt program administration and improvements. Additionally, hunters age 15 and under are required to obtain a free hunt-specific permit instead of purchasing a Complex Annual Hunt Permit. This hunt-specific permit allows youth hunters access to all non-quota hunts for the annual hunting season.

B. Refuge-Specific Hunting Regulations

• For all hunters age 16 and older, in addition to a state license, we require a refuge hunt permit, which must be signed and carried at all times when hunting. We charge a fee for all hunt permits. • Youth hunters age 15 and under must remain within sight and normal voice contact of an adult age 21 or older, who possesses a valid hunting license for the State in which they are hunting. One adult may supervise no more than two youth hunters. • Persons possessing, transporting, or carrying firearms on National Wildlife Refuges must comply with all provisions of state and local law. Persons may only use (discharge) firearms in accordance with refuge regulations (50 CFR §32.29.) • We prohibit hunting on or within 100 yards (90 meters) of public roads; refuge facilities, roads, and trails; and railroad rights of way, and in closed areas. • We prohibit the use of trail or game cameras. We also prohibit the use of trail marking tacks; bright eyes; reflectors; reflecting tape; and any other markers, including biodegradable markers such as toilet paper and paper tape. • No trapping is allowed on the Savannah NWR.

C. Relevant State Regulations

Hunters must follow all relevant state regulations, including obtaining a State alligator harvest permit. Additionally, hunters would be restricted to legal weapons outlined by the state, including hand-held ropes or snares, snatch hooks, harpoons, gigs, or arrows with restraining line attached. Lawfully restrained may be killed with any caliber handgun or bangstick.

12 D. Other Refuge Rules and Regulations for Hunting

All hunter requirements, such as equipment, licenses and permits, check-in, transportation, and hunter training and safety are specified in the refuge-specific hunt regulations.

V. Public Engagement

A. Outreach for Announcing and Publicizing the Hunting Program

The refuge maintains a mailing list for public information bulletins, local newspapers, radio stations, and websites. Special announcements and articles may be released in conjunction with hunting seasons. In addition, information about the hunt would be available at Savannah Coastal Refuges Complex and at its website.

B. Anticipated Public Reaction to the Hunting Program

While we anticipate minor negative comments from some portions of the public regarding the proposed hunt plan, the public has generally supported the refuge hunting program. Each hunting season the refuge receives requests for more hunting, more access, and longer seasons. Some visitor comments and occasional emails received from the public request minimal or no hunting. In addition, concerns are sometimes raised by non-hunting users of the refuge regarding potential conflict with hunters. Through education and outreach, most of these concerns are relatively easy to resolve.

Public reaction to the 2016 Hunt Plan was primarily favorable; however, many comments received during the public comment period for that plan were critical of some parts of the proposed changes. This was mostly due to input from organized non-hunting and anti-hunting groups. It is anticipated that those objections would continue to be voiced concerning the implementation of proposed hunting opportunities within this draft plan. A variety of non- governmental conservation organizations, state departments of natural resources, and individual citizens expressed their fullest support for the 2016 Hunt Plan and would be anticipated to support this proposed Hunt Plan.

C. How Hunters Will Be Informed of Relevant Rules and Regulations

General information regarding hunting and other wildlife-dependent public uses can be obtained at Savannah Coastal Refuges Complex, 694 Beech Hill Ln., Hardeeville, SC 29927; on the refuge’s website; or by phone at 843.784.9911. Dates, forms, hunting unit directions, maps, applications, and permit requirements about the hunt would be available at the refuge’s Visitor Center and on the refuge’s website at: https://www.fws.gov/refuge/Savannah/Visit/Visitor_Activities/Hunting.html.

VI. Compatibility Determination

Hunting and all associated program activities proposed in this plan would be compatible with the purposes of the refuge. See Appendix B for the draft Compatibility Determination for Hunting of

13 American Alligator, Armadillo, Beaver, Opossum, and Raccoon for Savannah NWR (USFWS 2020b).

References

U.S. Fish and Wildlife Service. 2020a. Environmental Assessment for American Alligator, Armadillo, Beaver, Opossum, and Raccoon Hunt Plan for Savannah National Wildlife Refuge. March 2020. Hardeeville, SC. 46 pp.

U.S. Fish and Wildlife Service. 2020b. Savannah National Wildlife Refuge Draft Compatibility Determination: Hunting of American Alligator, Armadillo, Beaver, Opossum, and Raccoon. March 2020. Hardeeville, SC. 9 pp.

U.S. Fish and Wildlife Service. 2016. Savannah National Wildlife Refuge Big Game, Small Game, Migratory Bird, Coyote, and Feral Hog Hunt Plan. October 2016. 20 pp.

U.S. Fish and Wildlife Service. 2011. Savannah Coastal National Wildlife Refuges Complex Comprehensive Conservation Plan. Blackbeard Island, Harris Neck, Pinckney Island, Savannah, Tybee, and Wassaw National Wildlife Refuges. U.S. Department of the Interior, Fish and Wildlife Service, Southeast Region. September 2011. Atlanta, GA. 357 pp. https://catalog.data.gov/dataset/savannah-coastal-national-wildlife-refuges-complex- comprehensive-conservation-plan

U.S. Fish and Wildlife Service. 2010. Draft Comprehensive Conservation Plan and Environmental Assessment for Savannah Coastal Refuge Complex. Blackbeard Island, Harris Neck, Pinckney Island, Savannah, Tybee, and Wassaw National Wildlife Refuges. U.S. Department of the Interior, Fish and Wildlife Service, Southeast Region. September 2010. Atlanta, GA. 545 pp.

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Section B. Environmental Assessment

Environmental Assessment

for

American Alligator, Armadillo, Beaver, Opossum, and Raccoon Hunt Plan

for

Savannah National Wildlife Refuge Chatham and Effingham Counties, Georgia Jasper County, South Carolina

March 2020

Prepared by

U.S. Fish and Wildlife Service Savannah Coastal Refuges Complex 694 Beech Hill Ln. Hardeeville, SC 29927

Environmental Assessment for American Alligator, Armadillo, Beaver, Opossum, and Raccoon Hunt Plan for Savannah National Wildlife Refuge

This Environmental Assessment (EA) is being prepared to evaluate the effects associated with the Proposed Action and complies with the National Environmental Policy Act (NEPA) in accordance with Council on Environmental Quality regulations (40 CFR §§1500-1509) and U.S. Department of the Interior and U.S. Fish and Wildlife Service (USFWS, Service) regulations and policies (43 CFR Part 46, 516 DM 8, 550 FW 3, 603 FW 2, and 605 FW 2). NEPA requires examination of the effects of proposed actions on the human environment, which includes natural and cultural resources.

1.0 Purpose and Need

Proposed Action

The Service is proposing to open hunting opportunities for American alligator, armadillo, beaver, opossum, and raccoon on the Savannah National Wildlife Refuge (NWR, refuge) in accordance with the refuge’s proposed American Alligator, Armadillo, Beaver, Opossum, and Raccoon Hunt Plan (USFWS 2020a) and proposed compatibility determination (USFWS 2020b). American alligator (Alligator mississippiensis) hunting would be allowed on 11,648 acres only within the Georgia (GA) and South Carolina (SC) portions of the refuge north of Interstate-95 (I-95) (Figure 1). Armadillo (Dasypus novemcinctus), beaver (Castor canandensis), opossum (Didelphis virginiana), and raccoon (Procyon lotor) would be considered incidental species and would be open to harvest during other refuge seasons, but only on 15,066 acres within Georgia. The draft Comprehensive Conservation Plan (CCP) and associated EA (USFWS 2010) and the final CCP and Finding of No Significant Impact (FONSI) (USFWS 2011a) for the Savannah Coastal Refuge Complex addressed future management of the refuge and included an objective to create additional public hunting opportunities on Savannah NWR (Objective 3.6.d. Savannah NWR – Hunting: Over the 15-year life of this CCP, maintain, and where possible, expand current hunting opportunities; USFWS 2011a). The proposal would also support refuge management objectives 1.5.d and 2.11.d (Other Fish, Wildlife, and Plants), 2.12.d (Invasive Species), 2.13.d (Wildlife Disease), 4.3.d (Law Enforcement) (USFWS 2011a). This EA is needed for reviewing additional public hunting opportunities (as directed by the 2011 CCP), and ensuring compliance with NEPA and the Service’s policies on Hunting (605 FW 2) and Compatibility (603 FW 2).

A Proposed Action is often iterative and evolves over time during the process as the agency refines its proposal and learns more from the public, Native American Tribes, and other agencies. Therefore, the final Proposed Action may be different from the original. The final decision on the Proposed Action would be made at the conclusion of the public comment period for the EA and the Draft 2020-2021 Refuge-Specific Hunting and Sport Fishing Regulations, which would be anticipated for later in 2020.

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Figure EA-1. Proposed Hunt Areas for American Alligator, Armadillo, Beaver, Opossum, and Raccoon on Savannah NWR

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Background

National Wildlife Refuges (NWRs) are guided by the mission and goals of the National Wildlife Refuge System (NWRS), the purposes of an individual refuge, Service policy, and laws and international treaties. Relevant guidance includes the NWRS Administration Act (NWRSAA) of 1966, as amended by the NWRS Improvement Act (NWRSIA) of 1997, Refuge Recreation Act of 1962, and selected portions of the Code of Federal Regulations and Fish and Wildlife Service Manual.

Savannah NWR was established by Executive Order 4626 on April 6, 1927, in Jasper County, South Carolina, on 2,352 acres of land owned by the United States near the Savannah River. A Presidential Proclamation on April 10, 1939 closed migratory bird hunting on channels of the Savannah River known as Steamboat River, Housetown Cut, Middle River (from the head of Argyle Island to its confluence with Front River), and Back River (from the mouth of Union Creek to the foot of Argyle Island). This closure set aside these otherwise open State jurisdictional waters as a permanent sanctuary for migratory birds. Originally called the Savannah River Bird Refuge, this area was reserved for use by the U.S. Department of Agriculture as a preserve and breeding ground for native birds. Since initial establishment, numerous parcels have been acquired, bringing the current refuge total to 29,452 acres.

Establishing authorities and related purposes of the refuge are listed.

“…as a refuge and breeding ground for birds and wild animals subject to future use in navigation if necessary and to valid existing rights if any” (Executive Order 5748, April 6, 1927);

“…for lands acquired under the Migratory Bird Conservation Act “for use as an inviolate sanctuary, or for any other management purpose, for migratory birds” (16 U.S.C. §715d);

“…for lands acquired under the Refuge Recreation Act for “(1) incidental fish and wildlife- oriented recreational development, (2) the protection of natural resources, (3) the conservation of endangered species or threatened species” (16 U.S.C. §460k);

“…for “the conservation of the wetlands of the Nation in order to maintain the public benefits they provide and to help fulfill international obligations contained in various migratory bird treaties and conventions” (16 U.S.C. §3901(b), 100 Stat. 3583, Emergency Wetlands Resources Act of 1968);

“…for the development, advancement, management, conservation, and protection of fish and wildlife resources” (16 U.S.C. §742f (a)(4));

“…for the benefit of the United States Fish and Wildlife Service, in performing its activities and services. Such acceptance may be subject to the terms of any restrictive or affirmative covenant, or condition of servitude” (16 U.S.C. §742f (b)(1), Fish and Wildlife Act of 1956).

The mission of the NWRS, as outlined by the NWRSAA, as amended by the NWRSIA (16

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U.S.C. §668dd et seq.), is:

“... to administer a national network of lands and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans.”

The NWRSAA mandates the Secretary of the Interior in administering the System to (16 U.S.C. §668dd(a)(4)):

● Provide for the conservation of fish, wildlife, and plants, and their habitats within the NWRS; ● Ensure that the biological integrity, diversity, and environmental health of the NWRS are maintained for the benefit of present and future generations of Americans; ● Ensure that the mission of the NWRS described at 16 U.S.C. §668dd(a)(2) and the purposes of each refuge are carried out; ● Ensure effective coordination, interaction, and cooperation with owners of land adjoining refuges and the fish and wildlife agency of the States in which the units of the NWRS are located; ● Assist in the maintenance of adequate water quantity and water quality to fulfill the mission of the NWRS and the purposes of each refuge; ● Recognize compatible wildlife-dependent recreational uses as the priority general public uses of the NWRS through which the American public can develop an appreciation for fish and wildlife; ● Ensure that opportunities are provided within the NWRS for compatible wildlife- dependent recreational uses; and ● Monitor the status and trends of fish, wildlife, and plants in each refuge.

Therefore, it is a priority of the Service to provide for wildlife-dependent recreation opportunities, including hunting and fishing, when those opportunities are compatible with the purposes for which the refuge was established and the mission of the NWRS.

Public hunting on Savannah NWR was determined to be a compatible wildlife-oriented recreational use of Savannah NWR based on the 2010 draft Comprehensive Conservation Plan (CCP) and Environmental Assessment (EA) (USFWS 2010) and the 2011 final CCP and FONSI (USFWS 2011a). Hunting is often used to control the overpopulation of some species within a given natural community and can provide for greater wildlife diversity when used as a management tool. Hunting can also be utilized as a means to increase awareness of the refuge, educate refuge users about conservation issues, provide for priority public recreational hunting opportunities, and ensure long-term public support for habitat management and future refuge management activities. The proposed additions to the hunting program at Savannah NWR, outlined in this Hunt Plan, were designed to minimize potential conflicts with refuge purposes and other priority public uses, while providing increased opportunities for a compatible priority public use.

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Purpose and Need for the Proposed Action

The purpose is to provide a refuge and breeding ground for wildlife, including migratory birds; provide appropriate and compatible wildlife-oriented recreation; protect, manage, restore, and conserve natural resources; conserve threatened and endangered species; conserve wetlands for public benefits; conserve and protect cultural resources; and provide visitors a greater understanding and enjoyment of fish, wildlife, and their habitats. The need is to meet the requirements of the NWRSIA; evaluate compatibility of proposed uses; protect biological integrity, diversity, and environmental health; and implement the CCP.

The final CCP outlined goals and objectives for future management; Objective 3.6.d is the most directly applicable to this EA (USFWS 2011a).

Objective 3.6.d: Savannah NWR – Hunting: Over the 15-year life of this CCP, maintain, and where possible, expand current hunting opportunities.

2.0 Alternatives

Alternatives Considered

Two alternatives were considered: Alternative A - Continue Current Management (No Action Alternative) and Alternative B - Implement 2020 American Alligator, Armadillo, Beaver, Opossum, and Raccoon Hunt Plan (Proposed Action). The proposed 2020 Savannah NWR Hunt Plan (Section A) and draft Compatibility Determination (Appendix B) were developed for implementation based on the Proposed Action outlined in Alternative B.

Alternative A – Continue Current Management – No Action Alternative Under the No Action Alternative, the 2016 Savannah NWR Hunt Plan would remain in effect with no changes (USFWS 2016). Hunting would continue to be allowed on 29,751 acres of the refuge under existing permits and conditions in accordance with the 2016 Hunt Plan and FONSI for white-tailed deer (Odocoileus virginianus), turkey (Meleagris gallopavo), squirrel (Sciurus carolinensis), rabbit (Sylvilagus floridanus), waterfowl, mourning dove (Zenaida macroura), coyote (Canis latrans), and feral hog (Sus scrofa) (USFWS 2016). Currently, the refuge is not open to alligator hunting. However, some navigable waterways within the boundary of the refuge are open to alligator hunting under Georgia state laws and jurisdiction only for those hunters who have obtained a valid State alligator hunting permit. The navigable waterways include the Savannah River and Abercorn, Little Abercorn, and Big Collis creeks in Georgia. Alligator hunting is not permitted in the Middle, Back, or Little Back rivers or any other creeks other than those listed above. Incidental take of armadillo, beaver, opossum, and raccoon is not allowed under the current 2016 Savannah NWR Hunt Plan. Savannah NWR requires all hunters, 16 years of age or older, to purchase, and carry while hunting, a Savannah Coastal Refuges Complex Annual Hunt Permit, which certifies they understand and will comply with all refuge hunting regulations and provides information related to hunter participation. Additionally, hunters age 15 and under are required to obtain a free hunt specific permit instead of purchasing an Annual Hunt Permit. This permit allows youth hunters access to all non-quota hunts for the annual hunting season. The estimated cost to administer this alternative is estimated to be less

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than $5,000.00 annually. The associated costs primarily involve issuing refuge-specific hunt permits, brochures, and law enforcement activities.

Alternative B – Implement 2020 American Alligator, Armadillo, Beaver, Opossum, and Raccoon Hunt Plan – Proposed Action The Proposed Action would expand the existing hunt program at Savannah NWR to include American alligator, armadillo, beaver, opossum, and raccoon. Under the Proposed Action Alternative, the 2016 Hunt Plan would remain in effect and the proposed 2020 Hunt Plan (USFWS 2020a) would amend the 2016 Hunt Plan to add American alligator, armadillo, beaver, opossum, and raccoon to the refuge’s hunt program with the addition of the proposed compatibility determination (USFWS 2020b). Under the Proposed Action, American alligator hunting would take place on 11,648 acres of lands owned or administered by the refuge within the states of Georgia and South Carolina north of I-95, which includes North Tract GA, north of I-95 (9,336 acres) and North Tract SC, north of I-95 (2,312 acres) (Figure 1). This proposed hunt area encompasses approximately 11,183 acres of bottomland forested wetlands interspersed with upland hammocks. Hunters would be required to obtain an alligator harvest permit through the states of Georgia and South Carolina through their respective selection processes. Armadillo, beaver, opossum, and raccoon would be grouped together as incidental species and would be open for harvest during the hunting season and on areas currently open to all refuge hunts and only within the Georgia portion of the refuge on 15,066 acres. Savannah NWR requires all hunters, 16 years of age or older, to purchase, and carry while hunting, a Savannah Coastal Refuges Complex Annual Hunt Permit, which certifies they understand and will comply with all refuge hunting regulations and provides information related to hunter participation. Additionally, hunters age 15 and under are required to obtain a free hunt specific permit instead of purchasing an Annual Hunt Permit. This permit allows youth hunters access to all non-quota hunts for the annual hunting season. These existing permit requirements would also be required under the Proposed Action.

The listed stipulations would be implemented and/or maintained to ensure compatibility of the proposed hunting of alligator, armadillo, beaver, opossum, and raccoon on the refuge.

 This use must be conducted in accordance with State and Federal regulations, and special refuge regulations published in the hunt regulations brochure. Refuge-specific regulations are reviewed annually.  The length of hunting seasons can be modified, if needed.  This use is subject to modification if on-site monitoring by refuge personnel or other authorized personnel identifies unanticipated adverse impacts, including to natural communities, wildlife species, or habitats.  Non-toxic shot is required for hunting of American alligators, armadillo, beaver, opossum, and raccoon on Savannah NWR.  Hunting of armadillo, beaver, opossum, and raccoon would not occur in the South Carolina portion of the refuge, which is where all the non-hunting public use trails are located.

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Mitigation measures to avoid conflicts are listed.

● There would be no conflicts with other refuge biological activities. The hunting season for alligators would be open during the respective season for the states of Georgia and South Carolina. The number of days may vary depending on the season designated by each state. Generally, the season would open in mid-September and close in the first week of October. No other hunting seasons on the refuge occur at that time except for a short overlap during the first 2 to 3 weeks of archery deer season. However, habitat requirements for each species/hunt would exclude any potential conflict during this overlap. ● No conflicts would be anticipated for the incidental species within Georgia. These species would be considered additional, incidental take during the current hunting seasons. No special hunting seasons or bag limits would be proposed, except to follow State regulations.

Alternative B would offer increased opportunities for public hunting, would implement an objective in the CCP, and would help fulfill the Service’s mandate under the NWRSIA of 1997. The Service has previously determined that the 2016 Hunt Plan and associated compatibility determination are compatible with the purposes of the Savannah NWR and the mission of the NWRS. Under Alternative B, alligator hunting would be implemented within the framework of each state to provide a recreational experience to the general public, while maintaining a sustainable alligator population. The estimated cost to administer the existing hunt with the proposed hunt would be estimated to be less than $5,000.00 annually. The associated costs would primarily involve issuing refuge-specific hunt permits, brochures, and law enforcement activities. The proposed hunt plan and compatibility determination would support the CCP for the refuge, notably implementing Objective 3.6.d (Savannah NWR – Hunting: Over the 15-year life of this CCP, maintain, and where possible, expand current hunting opportunities). The proposal would also support refuge management objectives 1.5.d and 2.11.d (Other Fish, Wildlife, and Plants), 2.12.d (Invasive Species), 2.13.d (Wildlife Disease), 4.3.d (Law Enforcement). (USFWS 2011)

3.0 Affected Environment and Environmental Consequences

Affected Environment

Savannah NWR is located in the Lower Coastal Plain physiographic region in portions of Chatham and Effingham counties, Georgia and Jasper County, South Carolina. The refuge currently includes 29,452 acres and is roughly bounded by the cities of Savannah, Port Wentworth, and Rincon, Georgia and Hardeeville, South Carolina.

Natural and Physical Resources Wetlands dominate the refuge and adjacent surrounding landscape. Most of the refuge lies within the primary floodplain of the Savannah River, an alluvial river with headwaters in the mountains of . All 38 miles of the River that flow through the refuge are at least partially influenced by tides from the Atlantic Ocean. Generally, areas further up-river, are more forested with declining salinities, while further down-river areas are mostly tidal marsh with salinities

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varying with tides, winds, and flow in the Savannah River. Elevations range from near sea level along the lower reaches of the Savannah River to 20 feet above mean sea level on higher hammocks and river floodplain terraces. Much of the refuge is accessible only by boat but access can vary greatly according to water levels in the Savannah River.

The refuge climate is heavily influenced by the coastal waters of the Atlantic Ocean. In Savannah, Georgia, the average January daily high temperature is 60 degrees Fahrenheit and the average January daily low temperature is 38 degrees Fahrenheit (US Climate Data 2016). July is the hottest month of the year with an average daily high temperature of 91 degrees Fahrenheit and average daily low temperature of 72 degrees Fahrenheit (US Climate Data 2016).

Most of the refuge, other than administrative areas and rights-of-way, is covered with a variety of native vegetation. Vegetation types found in this area typically depend on soil conditions, historic land use practices, and current wildlife management objectives. Tidal marsh areas are dominated by giant cutgrass (Zizaniopsis miliacea), big cordgrass (Spartina cynosuroides), cattail (Typha spp.), and bulrush (Schoenoplectus tabernaemontani), while vegetation composition in forested wetlands depends on the amount of tidal influence and elevation. Wetter, more frequently flooded sites are forested with a mix of bald cypress ( distichum), water tupelo (Nyssa aquatica), green ash (Fraxinus pennsylvanica), and red maple (Acer rubrum) with only scattered black willow (Salix nigra), dwarf palmetto (Sabal minor), and hazel alder (Alnus serrulata) as understory components. Less frequently flooded areas contain a mix of sweetgum (Liquidambar styraciflua), laurel oak (Quercus laurifolia), water oak (Quercus nigra), overcup oak (Quercus lyrata), white oak (Quercus alba), cherrybark oak (Quercus pagoda), water hickory (Carya aquatica), and American sycamore (Platanus occidentalis) with a sparse understory of river cane (Arundinaria tecta), greenbriar (Smilax spp.), wild (Vitis spp.), and dwarf pawpaw (Asimina parviflora).

Managed freshwater impoundments (historic rice fields locally known as pools) provide 3,000 acres of wetlands where water levels are fully controlled for the benefit of migratory birds. These areas are dominated by moist soil plants such as smartweed (Persicaria spp.), fall panicum (Panicum dichotomiflorum), barnyard grass (Echinochloa crusgalli), witchgrass (Dichanthelium spp.), foxtail grass (Seteria spp.), giant cutgrass (Zizaniopsis miliacea), and a variety of sedges and rushes.

The balance of the refuge is comprised of relatively small upland features. Numerous, small mesic hardwood stands and hammocks are scattered throughout and are comprised of live oak (Quercus virginana), laurel oak (Quercus laurifolia), water oak (Quercus nigra), cherrybark oak (Quercus pagoda), southern red oak (Quercus falcata), mockernut hickory (Carya tomentosa), sugarberry (Celtis laevigata), American beech (Fagus grandifolia), southern magnolia (Magnolia grandiflora), black cherry (Prunus serotina), and scattered loblolly pine (Pinus taeda). The understory in these areas is often dense with saw palmetto (Serenoa repens), yaupon holly (Ilex vomitoria), and wax myrtle (Morella cerifera). Several areas are dominated by stands of varying successional stages of loblolly pine with mixed sweetgum, red maple, and water oak. These areas generally have a dense understory of loblolly pine regeneration, wax myrtle, and various hardwood saplings. Unfortunately, historical land uses and settlement of the local area resulted in the introduction of many non-native, invasive species. The refuge is continually

23

working to minimize negative impacts incurred by the growth of Chinese tallow tree (Triadica sebifera), Chinaberry (Melia azederach), alligator weed (Alternanthera philoxeroides), water hyacinth (Eichhornia crassipes), parrot (Myriophyllum aquaticum), autumn olive (Eleagnus umbellata), callery pear (Pyrus calleryana), Japanese climbing fern (Lygodium japonicum), and others.

Management of the 16 historic rice field pools enhances the importance of the refuge as a haven for numerous wildlife species. This area is particularly valuable to migratory bird populations. Heavy emphasis is placed upon habitat management for:

 wintering waterfowl [including (Aix sponsa), (Anas platyrhyncos), American widgeon (Mareca americana), (Mareca strepera), northern shoveler (Anas clypeata), (Anas acuta), blue-winged teal (Anas discors), green- winged teal (Anas carolinensis), ring-necked duck (Aythya collaris), (Aythya affinis), (Aythya valisineria), and (Aythya americana)],  migratory shorebirds [including greater yellowlegs (Tringa melanoleuca), lesser yellowlegs (Tringa flavipes), killdeer (Charadrius vociferus), solitary sandpiper (Tringa solitaria), stilt sandpiper (Calidris himantopus), least sandpiper (Calidris minutilla), western sandpiper (Calidris mauri), and semi-palmated sandpiper(Calidris pusilla)], and  wading birds [including wood stork (Mycteria americana), great-blue (Ardea herodias), little blue heron (Egretta caerulea), great egret (Ardea alba), snowy egret (Egretta thula), tri-colored heron (Egretta tricolor), black-crowned night heron (Nycticorax nycticorax), white ibis (Eudocimus albus), glossy ibis (Plegadis falcinellus), American bittern (Botaurus lentiginosus), and least bittern (Ixobrychus exilis)].

Other species, such as white-tailed deer (Odocoileus virginanus), (Lynx rufus), river otter (Lontra canadensis), anhinga (Anhinga anhinga), purple gallinule (Porphyrio martinicus), osprey (Pandion haliaetus), bald eagle (Haliaeetus leucocephalus), red-tailed hawk (Buteo jamaicensis), red-shouldered hawk (Buteo lineatus), Cooper’s hawk (Accipiter cooperii), sharp- shinned hawk (Accipiter striatus), northern harrier (Circus hudsonius), peregrine falcon (Falco peregrinus), merlin (Falco columbarius), American kestrel (Falco sparverius), kite (Ictinia mississippiensis), swallow-tailed kite (Elanoides forficatus), red-winged blackbird (Agelaius phoeniceus), bobolink (Dolichonyx oryzivorus), American alligator, cottonmouth (), mud (Farancia abacura), yellow belly slider (Trachemys scripta), mud (Kinosternum subrubrum), musk turtle (Sternotherus odoratus), snapping turtle (Chelydra serpentina), and a variety of freshwater fish thrive in these intensely managed areas.

The tidal within the refuge boundary vary in salinity from location, tide condition, and flow of the Savannah River. These areas provide ideal conditions for swallow-tailed kite, northern harrier, king (Rallus elegans), clapper rail (Rallus crepitans), marsh wren (Cistothorus palustris), sedge wren (Cistothorus stellaris), red-winged blackbird, rainbow snake (Farancia erytrogramma), and American alligator.

Forested wetlands, mixed mesic hardwoods and hammocks, and loblolly pine dominated stands provide suitable habitat for numerous resident and migratory wildlife species. Species known to

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use these forest stands include white-tailed deer, bobcat, gray squirrel (Sciurus carolinensis), raccoon, river otter, wild turkey (Meleagris gallopavo), brown-headed nuthatch (Sitta pusilla), Carolina chickadee (Poecile carolinensis), tufted titmouse (Baeolophus bicolor), brown creeper (Certhia americana), northern parula (Setophaga americana), pine warbler (Setophaga pinus), yellow-rumped warbler (Setophaga coronata), Swainson’s warbler (Limnothlypis swainsonii), black-throated blue warbler (Setophaga caerulescens), yellow-throated warbler (Setophaga dominica), prothonotary warbler (Protonotaria citrea), white-eyed vireo (Vireo griceus), red- eyed vireo (Vireo olivaceus), and rose-breasted grosbeak (Pheucticus ludovicianus).

Open waters of the refuge harbor numerous fish species. Due to varying salinity in the lower Savannah River and tributaries and a direct tie to the Atlantic Ocean, freshwater and saltwater fish species are present year-round in refuge waters.

Several endangered, threatened, and species of concern inhabit refuge lands and adjacent open waters including Atlantic sturgeon (Acipenser oxyrhynchus), shortnose sturgeon (Acipenser brevirostrum), robust redhorse (Moxostoma robustum), West Indian manatee (Trichechus manatus), Rafinesque’s big-eared bat (Corynorhinus rafinesquii), and wood stork (Mycteria americana). Management actions taken on the refuge always first consider the well-being of these species and their habitat.

Multiple invasive species are found on the refuge. Currently, the most important and destructive invasive animal species on the refuge is the feral hog. Feral hogs are currently distributed throughout the refuge in varying densities. These animals were introduced to the eastern United States from by early European settlers as a free ranging food source. The feral hog population that exists today is a mix of escaped domestic pigs, intentionally raised and released wild pigs, and Eurasian . The rooting and wallowing activities of feral hogs cause serious erosion to riverbanks and areas along streams. Feral hogs carry diseases transmittable to humans, such as swine brucellosis, toxoplasmosis, and trichinosis. They compete for food with numerous native wildlife species and are known to consume a variety of herptiles, including salamanders and . Feral hogs create large wallows in wet sites, destroying the integrity of the native plant and soil community (Georgia Wildlife Web 2016). Soil disturbance by rooting and wallowing of feral hogs also nurtures the invasion of exotic plant pests, such as Chinese tallow tree, Chinaberry, and Japanese climbing fern. Daily activities of feral hogs can also destroy archaeological sites.

Cultural Resources The body of federal historic preservation laws has grown dramatically since the enactment of the Antiquities Act of 1906. Several themes recur in these laws, their promulgating regulations, and more recent Executive Orders. They include: 1) each agency is to systematically inventory the historic properties on their holdings and to scientifically assess each property’s eligibility for the National Register of Historic Places; 2) federal agencies are to consider the impacts to cultural resources during the agencies’ management activities and seek to avoid or mitigate adverse impacts; 3) the protection of cultural resources from looting and vandalism are to be accomplished through a mix of informed management, law enforcement efforts, and public education; and 4) the increasing role of consultation with groups, such as Native American Tribes, in addressing how a project or management activity may impact specific archaeological sites and landscapes deemed important to those groups. The Service, similar to other federal 25

agencies, is legally mandated to inventory, assess, and protect cultural resources located on those lands that the agency owns, manages, or controls. Service cultural resource policy is delineated in 614 FW 1-5 and 126 FW 1-3. In the South Atlantic-Gulf and Mississippi Basin unified regions, the cultural resource review and compliance process is initiated by contacting the Regional Historic Preservation Officer/Regional Archaeologist (RHPO/RA). The RHPO/RA would determine whether the proposed undertaking has the potential to impact cultural resources, identify the “area of potential effect,” determine the appropriate level of scientific investigation necessary to ensure legal compliance, and initiate consultation with the pertinent State Historic Preservation Office (SHPO) and federally recognized Native American Tribes. Much of the managed landscape of the refuge evolved out of the late 18th and 19th century rice plantations and their fields. Following the American Civil War, most of the rice fields were converted into managed impoundments for migratory waterfowl. A historical summary of human inhabitation and land use practices in the area of current refuge lands is included in the CCP and its EA (USFWS 2010, 2011a) and is incorporated herein by reference.

Wildlife-Dependent Recreation Incidental to the primary purpose of migratory bird conservation, Savannah NWR provides opportunities for environmental education, interpretation, and quality wildlife-dependent recreation for the visiting public. With almost 400,000 visitors a year and access to a four-mile wildlife drive, numerous trails, over 30 miles of levees for hiking, 38 miles of river and 25 miles of streams and creeks, the refuge provides many opportunities for outdoor recreation. Additionally, the Savannah NWR offers a variety of hunting opportunities as this wildlife- dependent recreation is of cultural and historical importance to the local community. The hunt program provides an opportunity to increase public awareness of the Savannah NWR and the NWRS. Much of the refuge was purchased using funds from federal stamps and other associated hunting fees. Increased awareness has resulted in increased public support of the Savannah NWR and other programs. Hunters play an important role in assisting with law enforcement and wildlife management activities. Due to limitations in staff resources, hunters often provide vital tips and anecdotal information to law enforcement officers and biological staff, supporting refuge management activities.

Socioeconomic Environment The City of Savannah has historically been the primary economic driver of the coastal region of southeast Georgia and southern South Carolina. The number of jobs in the Savannah Metropolitan Statistical Area has grown at a rate twice as fast as that of the state and nation as a whole (Chatham County 2005). Detailed socioeconomic statistics and local demographics for Chatham, Effingham, and Jasper Counties, are included in the CCP and its EA (USFWS 2010, 2011a) and are incorporated herein by reference.

Environmental Consequences

This section analyzes the environmental consequences of the alternatives on each potentially affected resource, including direct and indirect effects and cumulative impacts. It describes the foreseeable environmental consequences of implementing each of the management alternatives presented. When detailed information is available, a scientific and analytical comparison between alternatives and their anticipated consequences is presented. When detailed information

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is not available, those comparisons are based on the professional judgment and experience of refuge staff and Service and State biologists. This EA only includes the written analyses of the environmental consequences on a resource when the impacts on that resource could be more than negligible and therefore considered an “affected resource.” Any resources that would not be more than negligibly impacted by the action have been dismissed from further analyses. Impact types are listed.

● Direct effects are those that are caused by the action and occur at the same time and place. ● Indirect effects are those that are caused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable. ● Cumulative impacts result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-federal) or person undertakes such other actions.

The effects of hunting alligators on the Savannah NWR in both Georgia and South Carolina, as outlined in the proposed Hunt Plan (USFWS 2020a) and proposed compatibility determination (USFWS 2020b) and analyzed in this EA, would be anticipated to be negligible. In Georgia, only 523 alligators have been harvested in Zone 8 in the past 15 years with only a 30% success rate (GADNR 2018). This harvest represents 17% of the total number of alligators taken in Georgia since 2003. Additionally, the area proposed to be opened in Georgia would increase the available acres for alligator hunting by only 0.4%. In 2019, 326 total alligators were taken in all Georgia zones with 1,000 alligator hunting permits issued, while Zone 8 accounted for 46 of those alligators (GADNR 2019). Since 2008, a total of 12,656 alligator hunting permits were issued by Georgia with 3,712 total alligators harvested (GADNR 2019). Although more than twice as many alligators have been taken in the Southern Coastal Zone in South Carolina since 2008, which represents 27% of the total harvest, the area being proposed to be opened in South Carolina would increase the available acres for alligator hunting by only 0.07% (SCDNR 2019). Cumulative harvest data by county since 2008 are not available. However, no alligators were taken in Jasper County in 2017 and Hampton County, which is located on the Savannah River just north of the refuge, representing less than 0.3% of the total harvest for the Southern Coastal Zone (SCDNR 2017). With the proposed opening of 11,648 acres (in Georgia and South Carolina) to alligator hunting on the refuge, the Service would anticipate adding an estimated 56 total hunter use days (with 46 in Georgia and 31 in South Carolina) with an anticipated change in harvest level of less than one percent. The Service would expect the number of alligator hunters to be fewer than 15 individuals (which is less than 1% of total annual refuge visitation at an estimated 0.004%). The low number of expected individuals may not represent an increase in overall alligator hunters given that the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting under state law. The alligator harvest would be anticipated to be between five and 17 individuals in any given year, however, this may not represent an increase in the overall alligator harvest given that the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting under state law.

The effects of incidental hunting armadillo, beaver, opossum, and raccoon, as outlined in the proposed Hunt Plan (USFWS 2020a) and proposed compatibility determination (USFWS 2020b)

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and analyzed in this EA, would also be anticipated to be negligible. With the proposed opening of 15,066 acres (in Georgia) to the incidental hunting of armadillo, beaver, opossum, and raccoon, the Service would anticipate adding an estimated 149 hunter use days with an estimated change in harvest level of less than one percent. The Service would not anticipate the number of hunters to increase with the addition of hunting the incidental species; rather, existing hunters would have the opportunity to take additional species. Any increase in the number of hunters would be expected to be negligible to minor. The annual harvest of these incidental species would be anticipated to be zero to 15 each for armadillo, opossum, and raccoon and zero to three for beaver.

In summary, no significant impacts would be anticipated to result from the implementation of the Proposed Action (Alternative B); given the low numbers of participants and low harvest of game species anticipated, impacts would be anticipated to be minor or negligible. Tables 1 through 5 outline anticipated direct and indirect impacts.

Cumulative Impact Analysis Cumulative impacts are defined as “the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-federal) or person undertakes such other actions” (40 CFR §1508.7). Cumulative impacts are the overall, net effects on a resource that arise from multiple actions. Impacts can “accumulate” spatially when different actions affect different areas of the same resource. They can also accumulate over the course of time from actions in the past, the present, and the future. Occasionally, different actions counterbalance one another, partially cancelling out each other’s effects on a resource. However, more typically, multiple effects add up, with each additional action contributing an incremental impact on the resource.

Within the surrounding landscape, some private hunt leases in the area have transitioned away from hunting, while commercial and residential land uses have increased, especially around the City of Savannah, GA and especially in Chatham and Effingham counties, GA. Under the Proposed Action, the Service would anticipate adding an estimated 56 hunter use days for alligator hunting and an estimated 149 hunter use days for hunting of the incidental species with an estimated change in harvest level of less than one percent. Actual user numbers and harvests would be anticipated to be low. The Service would expect the number of alligator hunters to be fewer than 15 individuals. The low number of expected individuals may not represent an increase given the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting under state law. The Proposed Action would represent an increase of less than 1% in total refuge annual visitation. The alligator harvest would be anticipated to be between five and 17 individuals in any given year, however, this may not represent an increase in the overall alligator harvest given that the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting under state law. The annual harvest of these incidental species would be anticipated to be zero to 15 each for armadillo, opossum, and raccoon and zero to three for beaver. Despite changes in the surrounding landscape, the Service is not aware of any past, present, or future planned actions that would result in significant cumulative impacts from the alternatives. Table 6 outlines anticipated cumulative impacts for the Proposed Action. Under the 2020-21 Refuge-specific Hunting and Sport Fishing

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Regulations, cumulative impacts are summarized nationally for all Service proposed 2020-21 hunting and sport fishing rulemaking actions in the associated Cumulative Impacts Report.

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Table EA-1. Affected Natural Resources and Anticipated Impacts of the Alternatives Hunted Species – White-tailed Deer Hunting of white-tailed deer was outlined and analyzed in the 2016 Hunt Plan and EA (USFWS 2016). Direct and Indirect Impacts Harvest regulation is an essential part of sound management for white-tailed deer. Regulating the harvest is necessary to keep deer populations at or below habitat carrying capacity and in relative balance with their Alternative A (No Action Alternative) food supply on refuge lands. Over-population leads to increased car-deer collisions and poor overall herd White-tailed deer hunting would continue in accordance with the 2016 Hunt Plan (USFWS 2016) with no health. Due to the relatively small home range size for deer (500-1,500 acres), deer hunting does not have changes. No impacts to white-tailed deer hunting would be anticipated under Alternative A since the use regional population impacts. Population estimates in 2015 were 1,200,000 for Georgia (GADNR 2016a) and would remain unchanged. Under this Alternative, legal harvest of individual animals would continue to 730,000 for South Carolina. Only local impacts are likely to occur from deer hunting on the refuge and those occur on areas of the refuge that are currently open to hunting according to the 2016 Hunt Plan. impacts are generally considered beneficial. Deer harvest on the refuge is estimated at 30-40 per season. Alternative B (Proposed Action Alternative) Deer density on any given area of Savannah NWR varies with season, river height, impoundment Under Alternative B, white-tailed deer hunting would continue as outlined in the 2016 Hunt Plan (USFWS management, outside hunting pressure, and other factors. Overpopulation of deer can be devastating to the 2016) with the addition of incidental hunting of armadillo, beaver, opossum, and raccoon and with the understory component of forested habitat. Excessive browsing has the potential to impact understory- addition of alligator hunting. The addition of the incidental species would not be anticipated to impact dependent species, specifically breeding, migrant, and resident songbirds. Species that could experience white-tailed deer hunting. Hunters would not be anticipated to participate in deer hunting for the sole negative impacts from deer overpopulation and associated habitat degradation include breeding birds, such as purpose of harvesting incidental species and vice versa. The potential increase in hunter numbers would be painted bunting, common yellowthroat, and wood thrush, and migrant birds, including black-throated blue expected to be minimal and only associated with a potential increase in white-tailed deer hunters. Armadillo, warblers, yellow warbler, -eating warbler, hooded warbler, ovenbird, gray-cheeked thrush, Swainson’s opossum, and raccoon are the only incidental species that may share similar habitats with white-tailed deer, thrush, and hermit thrush. Habitat quality for resident species, such as gray catbird, brown thrasher, and but they have different requirements within each habitat. and opossums also are more nocturnal white-eyed vireo, can also decline in the presence of too many deer. and the likelihood of encountering either species is low. Even if these species were to be encountered during the crepuscular period, white-tailed deer hunters would be unlikely to harvest any because of disturbance to Deer herd health checks were conducted most recently by the Southeast Cooperative Wildlife Disease Study deer. Armadillos are considered a nuisance species and can be trapped or hunted throughout the year in in 1993. The report for that check concluded that continuation of current herd density might result in declines Georgia. Armadillos avoid wet areas and prefer dry, sandy to clay soils for foraging and burrows. The in herd health or higher rates of disease-induced mortality. The data suggests that some level of disease majority of the habitat types proposed for opening are wetlands and are not optimal for armadillos. We related mortality might be present. These losses predominantly affect younger animals, 4-12 month of age, would not expect the harvest of these incidental species to be significant or affect populations in any way. mainly during winter and early spring, and are associated with parasitism by stomach and lungworms. For all hunts, annually we would expect armadillo, opossum, and raccoon harvests to be 15 or fewer for each Any considerable increase in density likely would result in declines in population health from this density- species, and we would expect three or fewer beavers harvested each year. Road kill has a far more dependent parasitism/malnutrition syndrome. significant effect on these populations than would be expected from adding them as incidental species. Beavers are rare on the Savannah NWR and occupy a different habitat type than white-tailed deer. We would An active deer hunting program on all areas open to hunting is necessary at Savannah NWR to provide and not expect any effect at all on beaver populations or white-tailed deer harvest as a result of adding these maintain quality habitat for breeding, migrant, and resident birds. The overall health and welfare of the refuge species. Access to areas occupied by beavers is difficult and, most likely, would be avoided by deer hunters deer herd is also maintained or improved through an active hunting program. while travelling to or from a deer stand in upland areas. We would expect less than three beavers harvested each year on Savannah NWR. Alligator hunting and white-tailed deer hunting occur in different habitats and mostly different seasons with a minor 2- to 3-week overlap; white-tailed deer hunting would not be anticipated to be impacted by the proposed alligator hunting. Hunted Species - Wild Turkey Hunting of wild turkey was outlined and analyzed in the 2016 Hunt Plan and EA (USFWS 2016). Once a Direct and Indirect Impacts species that was almost extinct in the U.S in the early 1900s, the wild turkey is now numerous and widely distributed due to reintroduction programs, active management, and regulated hunting. Both Georgia and Alternative A (No Action Alternative) South Carolina have monitored wild turkey populations throughout each state since the 1980s, and have Wild turkey hunting would continue in accordance with the 2016 Hunt Plan (USFWS 2016) with no actively restored populations in all historic ranges. The 2015 turkey population was estimated at 300,000 in changes. No impacts would be anticipated to wild turkey hunting under Alternative A since the use would Georgia (GADNR 2016b). There is no current population estimate for South Carolina. Turkeys are non- remain unchanged. Under this Alternative, legal harvest of individual animals would continue to occur on migratory and maintain relatively small home ranges, generally no more than 1,500 acres in this region. areas of the refuge that are currently open to hunting according to the 2016 Hunt Plan. Gobbler only, spring hunting ensures the survival of hens, allows those hens to breed and continue providing this renewable resource. Harvest during limited turkey hunting at Savannah NWR is expected to be no more

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than 25-30 male turkeys. The limited public hunting of turkeys on the refuge should have no noticeable Alternative B (Proposed Action Alternative) impacts on sustaining this renewable resource. Under Alternative B, wild turkey hunting would continue under the 2016 Hunt Plan (USFWS 2016) with the addition of incidental hunting of armadillo, beaver, opossum, and raccoon and the addition of alligator hunting. The addition of the incidental species would not be anticipated to impact wild turkey hunting. Turkey hunters would not be anticipated to participate in turkey hunting for the purpose of harvesting incidentals and we would expect no increase in the number of turkey hunters. Although the incidental species, except beavers, share similar habitats with turkeys, we would expect the harvest of incidentals to be negligible, if any harvest occurs. Raccoons and opossums primarily are nocturnal and most likely would not be encountered, except during crepuscular periods. If encountered during these times, turkey hunters would likely not harvest them due to the potential to disturb nearby turkeys. Harvest of armadillos also would not be anticipated because of disturbance to potential nearby turkeys. Roadkill is a far more significant factor in effecting populations of these incidentals than would be expected form the proposed hunting. For all hunts, annually we would expect armadillo, opossum, and raccoon harvests to be 15 or fewer for each species, and we would expect three or fewer beavers harvested each year. We would anticipate fewer than five individuals harvested combined for all the incidental species related to turkey hunting. Further, since alligator hunting and wild turkey hunting occur in different habitats and different seasons, no effect on turkey would be anticipated from alligator hunting activities. Hunted Species – Rabbit and Squirrel Hunting of rabbit and squirrel was outlined and analyzed in the 2016 Hunt Plan and EA (USFWS 2016). Direct and Indirect Impacts Small game that can be hunted on the refuge include squirrel and rabbit. Both are abundant statewide in Georgia and South Carolina. Squirrels are greatly affected by limited food and cover resources with disease Alternative A (No Action Alternative) influences common with dense populations. Due to limited access and minimal numbers of small game Rabbit and squirrel hunting would continue in accordance with the 2016 Hunt Plan (USFWS 2016) with no hunters on the refuge, squirrels and thrive where adequate food and cover are available to sustain their changes. No impacts to rabbit and squirrel hunting would be anticipated under Alternative A since the use populations. The bottomland forested habitat of the refuge can be expected to support huntable populations of would remain unchanged. Under this Alternative, legal harvest of individual animals would continue to squirrels into perpetuity. Rabbits can be found in a variety of habitats, but are primarily associated with the occur on areas of the refuge that are currently open to hunting according to the 2016 Hunt Plan. edges of upland openings and dense regeneration areas in woodlands. Annual harvest of squirrel is estimated at 300, while fewer than 25 rabbits are expected to be taken in any season. Road kills likely inflict higher Alternative B (Proposed Action Alternative) mortality rates on squirrel and rabbit populations on the refuge than hunting. Under Alternative B, rabbit and squirrel hunting would continue under the 2016 Hunt Plan (USFWS 2016) with the addition of incidental hunting of armadillo, beaver, opossum, and raccoon and with the addition of alligator hunting. Although the harvest of incidental species most likely would be the highest during small game hunts, the addition of the incidental species would not be anticipated to impact rabbit and squirrel hunting. Squirrel and rabbit hunting is a more “active” style of hunting requiring the hunter to walk as opposed to “still hunting” for turkey and deer. Raccoons and opossums, which are nocturnal, would not be likely to be encountered during squirrel or rabbit hunting as these hunts are usually conducted during the later hours of the morning and into the afternoon. The incidental species most likely to be encountered during turkey hunting would be the armadillo. Armadillos are considered nuisance species by the state of Georgia and are open year round to hunting. Hunters most likely would not harvest armadillos because of disturbance to nearby squirrels or rabbits. Roadkill is expected to have a far more significant effect on incidentals, as well as on rabbits and squirrels, than hunting activities. Rabbits and squirrels do not share the same habitat type as beavers. Access to upland areas on the Savannah NWR where open to incidental hunting is very difficult. We would expect very little, if any, increase in hunting rabbits and squirrels on the refuge especially on upland hammocks located within the large wetland areas of the refuge where the likelihood of a hunter encountering a beaver would be the highest. Therefore, we would expect no harvest of beavers by these hunters and few, if any, squirrels or rabbits taken from the hammocks. Fewer than five individuals of each incidental species would likely be taken during any given year as a result of squirrel and rabbit hunting. For all hunts, annually we would expect armadillo, opossum, and raccoon harvests to be 15 31

or fewer for each species, and we would expect three or fewer beavers harvested each year. Further, since alligator hunting and rabbit and squirrel hunting occur in different habitats and different seasons, rabbit and squirrel hunting would not be anticipated to be impacted by the proposed alligator hunting. Hunted Species – Migratory Birds Hunting of migratory birds was outlined and analyzed in the 2016 Hunt Plan and EA (USFWS 2016). Direct and Indirect Impacts Migratory game birds are those bird species so designated in conventions between the United States and several foreign nations for the protection and management of these birds. Under the Migratory Bird Treaty Alternative A (No Action Alternative) Act (16 U.S.C. §§703-712), the Secretary of the Interior is authorized to determine when "hunting, taking, Migratory bird hunting would continue in accordance with the 2016 Hunt Plan (USFWS 2016) with no capture, killing, possession, sale, purchase, shipment, transportation, carriage, or export of any ... bird, or any changes. No impacts to migratory bird hunting would be anticipated under Alternative A since the use part, , or egg" of migratory game birds can take place, and to adopt regulations for this purpose. These would remain unchanged. Under this Alternative, legal harvest of individual animals would continue to regulations are written after giving due regard to the zones of temperature and to the distribution, abundance, occur on areas of the refuge that are currently open to hunting according to the 2016 Hunt Plan. economic value, breeding habits, and times and lines of migratory flight of such birds, and are updated annually (16 U.S.C. §704(a)). This responsibility has been delegated to the USFWS as the lead federal Alternative B (Proposed Action Alternative) agency for managing and conserving migratory birds in the United States. Acknowledging regional Under Alternative B, migratory bird hunting would continue under the 2016 Hunt Plan (USFWS 2016) with differences in hunting conditions, the USFWS has administratively divided the nation into four Flyways for the addition of incidental hunting of armadillo, beaver, opossum, and raccoon and with the addition of the primary purpose of managing migratory game birds. Each Flyway (Atlantic, Mississippi, Central, and alligator hunting. The addition of the incidental species would not be anticipated to impact migratory bird Pacific) has a Flyway Council, a formal organization generally composed of one member from each state and hunting. All migratory bird hunting occurs within the wetlands or navigable waters of the Savannah NWR. Province in that Flyway. Savannah NWR is within the Atlantic Flyway. Of the incidental species, only beavers may occur in these areas; however, they are rare and no change in harvest would be anticipated for migratory bird hunting. For all hunts, annually we would expect armadillo, The process for adopting migratory game bird hunting regulations, located in 50 CFR Part 20, is constrained opossum, and raccoon harvests to be 15 or fewer for each species, and we would expect three or fewer by three primary factors. Legal and administrative considerations dictate how long the rule making process beavers harvested each year. Further, since alligator hunting and migratory bird hunting occur in different lasts. Most importantly, however, the biological cycle of migratory game birds controls the timing of data seasons, migratory bird hunting would not be anticipated to be impacted by the proposed alligator hunting. gathering activities and thus the dates on which these results are available for consideration and deliberation. The process of adopting migratory game bird hunting regulations includes two separate regulations development schedules, based on "early" and "late" hunting season regulations. Early hunting seasons pertain to all migratory game bird species in Alaska, Hawaii, Puerto Rico, and the Virgin Islands; migratory game birds other than waterfowl (e.g., dove and ); and special early waterfowl seasons, such as teal or resident Canada geese. Early hunting seasons generally begin prior to October 1. Late hunting seasons generally start on or after October 1 and include most waterfowl seasons not already established. There are basically no differences in the processes for establishing either early or late hunting seasons. For each cycle, Service biologists and others gather, analyze, and interpret biological survey data and provide this information to all those involved in the process through a series of published status reports and presentations to Flyway Councils and other interested parties (USFWS 2011b). Because the Service is required to take abundance of migratory birds and other factors in to consideration, the Service undertakes a number of surveys throughout the year in conjunction with the Canadian Wildlife Service, State and Provincial wildlife management agencies, and others. To determine the appropriate frameworks for each species, the Service considers factors such as population size and trend, geographical distribution, annual breeding effort, the condition of breeding and wintering habitat, the number of hunters, and the anticipated harvest. After frameworks are established for season lengths, bag limits, and areas for migratory game bird hunting, migratory game bird management becomes a cooperative effort of State and Federal Governments. After Service establishment of final frameworks for hunting seasons, the States may select season dates, bag limits, and other regulatory options for the hunting seasons. Season dates and bag limits for national wildlife refuges open to hunting are never longer or larger than the State regulations. In fact, based upon the findings of an environmental assessment developed when a national wildlife refuge opens a new hunting activity, season dates and bag limits may be more restrictive than the State allows.

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These frameworks are necessary to allow State selections of season and limits for recreation and sustenance, aid Federal, State, and Tribal governments in the management of migratory game birds, and permit harvests at levels compatible with population status and habitat conditions. Because the Migratory Bird Treaty Act stipulates that all hunting seasons for migratory game birds are closed unless specifically opened by the Secretary of the Interior, the USFWS annually promulgates regulations (50 CFR Part 20) establishing the frameworks from which States may select season dates, bag limits, shooting hours, and other options for each of the migratory bird hunting seasons. The frameworks are essentially permissive in that hunting of migratory birds would not be permitted without them. States may always be more conservative in their selections than the Federal frameworks for migratory bird hunting but never more liberal. Furthermore, season dates and bag limits for NWRs open to hunting can never be any longer than the State regulations. Each new refuge hunt must conduct appropriate NEPA analysis when the NWR opens a new hunting activity, and based upon the findings of the NEPA analysis and decision, season dates and bag limits are then set.

Service policy 605 FW2 states, “If a refuge, or portion thereof, has been designated, acquired, reserved, or set apart as an inviolate sanctuary, we may only allow hunting of migratory game birds on no more than 40% of that refuge, or portion, at any one time unless we find that taking of any such species in more than 40% of such area would be beneficial to the species.” The 2016 Hunt Plan ensures that the management of migratory bird hunts at Savannah NWR strictly adheres to this policy and that migratory bird hunting is restricted to the season, bag limits, and other regulations based on the State in which the hunting occurs. Waterfowl hunting is allowed in many areas of Savannah NWR and is regulated by the respective State seasons. Some areas are open only to quota youth waterfowl hunting, and other areas are closed to all waterfowl hunting.

The mourning dove is one of the most widely distributed and abundant bird species in North America. A popular game bird, this species is monitored at the national and regional level by the Service and state agencies. The primary management objective of the Service is to maintain dove populations in a healthy, productive state. Population monitoring currently consists of several surveys including Breeding Bird Survey (BBS), Banding Program, Harvest Survey and Parts Collection Survey. Every year, the U.S. Fish and Wildlife Service publishes an annual population status report which includes the most current information collected annually in the United States on survival, recruitment, abundance and harvest of mourning doves. According to the most recent BBS data, the estimated continental population of mourning doves during preseason 2014 was at about 274,000,000 birds (Seamans 2015).

Limited mourning dove hunting is allowed in the managed impoundments that lie east of the Back River and north of SC 170 in South Carolina that are normally closed to migratory bird hunting. Hunting is limited to no more than two days per week during the established season for South Carolina and only in areas that are not currently flooded for waterfowl habitat. Based on Breeding Bird Surveys over the past 49 years, mourning dove numbers continue to increase within the Eastern Management Unit (EMU), which includes South Carolina (Seamans 2015). Hunted Species - Coyote Hunting of coyote was outlined and analyzed in the 2016 Hunt Plan and EA (USFWS 2016). Coyote hunting Direct and Indirect Impacts is allowed during other refuge-scheduled hunts using methods of take authorized for those hunts. Although no research projects have been conducted concerning coyote densities and impacts on wildlife populations at Alternative A (No Action Alternative) Savannah NWR, anecdotal evidence suggests that they first appeared on the refuge in 1999. The number of Coyote hunting would continue in accordance with the 2016 Hunt Plan (USFWS 2016) with no changes. No observed by field staff while conducting management activities continues to increase each year. The impacts to coyote hunting would be anticipated under Alternative A since the use would remain unchanged. coyote is considered a non-native nuisance species by both Georgia DNR and South Carolina DNR. Under this Alternative, legal harvest of individual animals would continue to occur on areas of the refuge that are currently open to hunting according to the 2016 Hunt Plan. 33

Cumulative population impacts of hunting coyotes on the refuge cannot be reasonably measured and are most likely not detectable due to the minimal estimated harvest and transient nature of the species. Alternative B (Proposed Action Alternative) Under Alternative B, coyote hunting would continue under the 2016 Hunt Plan (USFWS 2016) with the addition of incidental hunting of armadillo, beaver, opossum, and raccoon to approved hunts and with the addition of alligator hunting. Coyote hunting would not be anticipated to be impacted by the addition of the proposed hunts. Under Alternative B, incidental species would be treated similarly to coyotes. Few, if any, coyotes are harvested on the refuge during any hunts, which would not be affected by opening additional species as incidental to other hunting. For all hunts, annually we would expect armadillo, opossum, and raccoon harvests to be 15 or fewer for each species, and we would expect three or fewer beavers harvested each year. Hunted Species – Feral Hog Hunting of feral hogs was outlined and analyzed in the 2016 Hunt Plan and EA (USFWS 2016). Feral hogs Direct and Indirect Impacts are an extremely invasive non-native species and are not considered a game animal by either Georgia DNR or South Carolina DNR. They also harbor several infectious diseases, some of which can be fatal to native Alternative A (No Action Alternative) wildlife and humans. By rooting and wallowing, feral hogs destroy wildlife habitat. Impacts include severe Feral hog hunting would continue in accordance with the 2016 Hunt Plan (USFWS 2016) with no changes. damage to impoundment dikes, increased erosion along waterways and wetlands, loss of native plants, and No impacts to feral hog hunting would be anticipated under Alternative A since the use would remain soil disturbance that favors the introduction of invasive plants, such as Chinese tallow and Japanese climbing unchanged. Under this Alternative, legal harvest of individual animals would continue to occur on areas of fern. Additionally, feral hogs compete directly for food with native species such as deer, turkeys, squirrels, the refuge that are currently open to hunting according to the 2016 Hunt Plan. raccoons, and many other birds and . They are predators of , small mammals, and ground nesting birds. Feral hogs are an increasing problem on refuge lands and adjoining privately owned lands. Alternative B (Proposed Action Alternative) They occur throughout Savannah NWR and their numbers appear to be stable but fluctuate greatly depending Under Alternative B, feral hog hunting would continue under the 2016 Hunt Plan (USFWS 2016) with the on water levels of the Savannah River. During prolonged events of flooding in the wetlands along the river, addition of incidental hunting of armadillo, beaver, opossum, and raccoon to approved hunts and with the feral hog numbers generally decline but soon recover as floodwaters recede and rapid is addition of alligator hunting. Feral hog hunting would not be anticipated to be impacted by the addition of achieved. Hunting of feral hogs during all open refuge hunts adds to refuge management control of hogs. the proposed hunts. Feral hogs share many of the same habitats as the incidental species. However, raccoon and opossum are nocturnal and the likelihood of encountering one these species while hunting feral hogs would be low. Hunters could potentially encounter armadillo during feral hog hunts with few armadillo, if any, anticipated to be taken. The disturbance associated with taking an incidental species would alert feral hogs to the hunter’s presence. Alligators and feral hogs do not occupy the same habitat type. Therefore, we would anticipate no change in feral hog hunting by adding these species. For all hunts, annually we would expect armadillo, opossum, and raccoon harvests to be 15 or fewer for each species, and we would expect three or fewer beavers harvested each year. Hunted Species –American Alligator The alligator populations in Georgia and South Carolina have been evaluated by each state as a renewable Direct and Indirect Impacts resource that can support harvest under specific state regulations and guidelines. In Georgia, only 523 alligators have been harvested in Zone 8 in the past 15 years with only a 30% success rate (GADNR 2018). Alternative A (No Action Alternative) This harvest represents 17% of the total number of alligators taken in Georgia since 2003. In 2019, 326 total Under Alternative A, alligator hunting and nuisance alligator control would continue to occur under Georgia alligators were taken in all Georgia zones with 1,000 alligator hunting permits issued, while Zone 8 and South Carolina regulations and guidelines, while nuisance alligator control would continue to occur on accounted for 46 of those alligators (GADNR 2019). Since 2008, a total of 12,656 alligator hunting permits the refuge, but alligator hunting would not occur on the refuge. Alligator populations under Alternative A were issued by Georgia with 3,712 total alligators harvested (GADNR 2019). More than twice as many would be anticipated to remain stable or increase on the refuge. alligators have been taken in the Southern Coastal Zone in South Carolina since 2008, which represents 27% of the total harvest (SCDNR 2019). Cumulative harvest data by county since 2008 are not available. Alternative B (Proposed Action Alternative) However, no alligators were taken in Jasper County in 2017 and Hampton County, which is located on the Under Alternative B, nuisance alligator control would continue to occur on the refuge and alligator hunting Savannah River just north of the refuge, represented less than 0.3% of the total harvest for the Southern would be opened on 11,648 acres of the refuge in Georgia and South Carolina. The alligator population on Coastal Zone (SCDNR 2017). Nuisance alligator control occurs in both states. the refuge would be anticipated to remain stable over the long term. The area proposed to be opened in Georgia would increase the available acres for alligator hunting by only 0.4%, while the area proposed to be

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opened in South Carolina would increase the available acres for alligator hunting by only 0.07%. With the proposed opening of 11,648 acres (in Georgia and South Carolina) to alligator hunting on the refuge, the Service would anticipate adding an estimated 56 total hunter use days (with 46 in Georgia and 31 in South Carolina) with an anticipated change in harvest level of less than one percent. The Service would expect the number of alligator hunters to be fewer than 15 individuals. The low number of expected individuals may not represent an increase given the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting under state law. Based on harvest success rates in Georgia and South Carolina and with an estimated increase of 56 hunter use days, the refuge would likely experience an annual alligator harvest of between five and 17 individuals. However, this may not represent an increase in the overall alligator harvest given that the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting under state law. Hunted Species – Armadillo, Beaver, Opossum, and Raccoon Georgia and South Carolina regulate the hunting of species as renewable resources in their respective states, Direct and Indirect Impacts including armadillo, beaver, opossum, and raccoon. These species are common nuisance wildlife in Georgia and South Carolina. The majority of the habitat proposed for opening consists of wetlands interspersed with Alternative A (No Action Alternative) upland hammocks with the majority of the hammocks accessible only from the Savannah River. Armadillo, Under Alternative A, the hunting of these species would continue under Georgia and South Carolina opossum, and raccoon are common in these upland areas. Opossum and raccoons primarily are nocturnal and regulations and guidelines, but would not occur on the refuge. Populations of these species would be rarely seen on the refuge, including the hammocks. Armadillos are increasing in numbers and considered a anticipated to continue to remain stable or increase due to a variety of factors. Roadkill is perhaps the most nuisance species by the state of Georgia. Although beavers are common throughout Georgia and in areas of significant mortality factor for these species. Raccoons, opossums, and beavers would be expected to remain the Savannah River, they are rare in the Savannah NWR estuary. Only one beaver has been observed in the stable, while armadillos would be expected to increase in numbers under Alternative A. last 10 years within the refuge and it was a roadkill. Roadkill is perhaps the most significant mortality factor for these populations. Alternative B (Proposed Action Alternative) Under Alternative B, the Service would open 15,066 acres to the incidental hunting of these species only in Georgia. Under Alternative B, the Service would anticipate adding an estimated 149 hunter use days with an estimated change in harvest level of less than one percent. Populations of these species would be anticipated to continue to remain stable. Harvest of these species on the refuge would be anticipated to be low. For all hunts, annually we would expect armadillo, opossum, and raccoon harvests to be 15 or fewer for each species, and we would expect three or fewer beavers harvested each year. Raccoons and opossums are nocturnal and the likelihood of encountering a raccoon or opossum is very low with harvest anticipated to be even lower. Armadillos are numerous and increasing in number and would be encountered with greater frequency; however harvest would be anticipated to be low. Access to upland areas on Savannah NWR in Georgia is mainly from boats via the Savannah River and requires significant hiking through flooded forested wetlands. This would limit harvest of incidental species in the upland areas even further. Disturbance from harvest activities (i.e., gun noise) to target wildlife, such as white-tailed deer or turkeys, would prevent additional harvest of these species. We would not anticipate hunters pursuing incidentals as the primary species of interest. Additionally, beavers are rare in the Savannah NWR. Although they are common throughout Georgia, the tidal influence of the Savannah River estuary limits beavers from substantial use of the refuge, which is located entirely within the estuary. The Service would not anticipate the number of hunters to increase with the addition of hunting the incidental species; rather, existing hunters would have the opportunity to take additional species. Any increase in the number of hunters would be expected to be negligible to minor. Threatened and Endangered Species and Other Special Status Species Impacts to imperiled species would be similar under each of the two alternatives. It is the policy of the Direct and Indirect Impacts Service to protect and preserve all native species of fish, , reptiles, birds, mammals, , and plants, including their habitats, which are designated threatened or endangered. Several endangered

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species, threatened species, and species of concern inhabit refuge lands and adjacent open waters, including Alternative A (No Action Alternative) Atlantic sturgeon, shortnose sturgeon, robust redhorse, West Indian manatee, Rafinesque’s big-eared bat, and Hunting would continue in accordance with the 2016 Hunt Plan (USFWS 2016) with no changes. No wood stork. The Proposed Action would not likely affect any threatened species, endangered species, or impacts to threatened and endangered species would be anticipated under Alternative A, with a previous species of concern. Optimally matching hunting seasons with times that hunting would cause the least amount Section 7 finding of “not likely to adversely affect” from the 2016 Hunt Plan. Under this Alternative, legal of disturbance and the legal authority available to the Refuge Manager to close areas to public access, when harvest of individual animals would continue to occur on areas of the refuge that are currently open to necessary, would ensure that Alternative B would not be any more likely to adversely affect threatened and hunting according to the 2016 Hunt Plan. endangered species than the No Action Alternative. Intra-Service Section 7 Endangered Species Act consultations were completed for the 2020 Hunt Plan, 2016 Hunt Plan, 2011 CCP, and 2007 Hunt Plan. Alternative B (Proposed Action Alternative) Findings of “no effect” were determined for all species related to waterfowl hunting in 2007 and 2011 and for Under Alternative B, hunting would continue under the 2016 Hunt Plan (USFWS 2016) with the addition of migratory bird hunting in 2016. Findings of “not likely to adversely affect” were determined for all species alligator hunting and with the addition of incidental hunting of armadillo, beaver, opossum, and raccoon to related to all other hunting in 2007, 2011, and 2016. A draft finding of “not likely to adversely affect” was approved hunts. Through the design of the hunts, including the times, locations, levels, and species, and the determined for all species related to the Proposed Action. ability to modify or close certain areas as needed to minimize impacts to threatened and endangered species, no impacts to threatened and endangered species would be anticipated to occur under this Alternative. Vegetation Most of the refuge, other than administrative areas and rights-of-way, is covered with a variety of native Direct and Indirect Impacts vegetation. Vegetation types found in this area typically depend on soil conditions, historic land use practices, and current wildlife management objectives. Tidal marsh areas are dominated by giant cutgrass, big Alternative A (No Action Alternative) cordgrass, cattail, and bulrush, while vegetation composition in forested wetlands depends on the amount of Hunting would continue in accordance with the 2016 Hunt Plan (USFWS 2016) with no changes. tidal influence and elevation. Wetter, more frequently flooded sites are forested with a mix of bald cypress, Negligible to minor adverse impacts to vegetation would be anticipated under Alternative A (e.g., minor water tupelo, green ash, black willow, and red maple with only scattered black willow, dwarf palmetto, and trampling of vegetation during hunting activities), however these impacts would be anticipated to be limited hazel alder as understory components. Less frequently flooded areas contain a mix of sweetgum, laurel oak, in duration, scope, and intensity and would be anticipated to be dispersed throughout the hunt areas and hunt water oak, overcup oak, white oak, cherrybark oak, water hickory, and American sycamore with a sparse season. Under this Alternative, legal harvest of individual animals would continue to occur on areas of the understory of river cane, greenbriar, wild grape, and dwarf pawpaw. Managed freshwater impoundments refuge that are currently open to hunting according to the 2016 Hunt Plan. (historic rice fields locally known as pools) provide 3,000 acres of wetlands where water levels are fully controlled for the benefit of migratory birds. These areas are dominated by moist soil plants, such as Alternative B (Proposed Action Alternative) smartweed, fall panicum, barnyard grass, witchgrass, foxtail grass, giant cutgrass, and a variety of sedges and Under Alternative B, hunting would continue under the 2016 Hunt Plan (USFWS 2016) with the addition of rushes. alligator hunting and with the addition of incidental hunting of armadillo, beaver, opossum, and raccoon to approved hunts. Impacts to vegetation would be anticipated to be similar to those under Alternative A. The balance of the refuge is comprised of relatively small upland features. Numerous, small mesic hardwood stands and hammocks are scattered throughout and are comprised of live oak, laurel oak, water oak, cherrybark oak, southern red oak, mockernut hickory, sugarberry, American beech, southern magnolia, black cherry, and scattered loblolly pine. The understory in these areas is often dense with saw palmetto, yaupon holly, and wax myrtle. Several areas are dominated by stands of varying successional stages of loblolly pine with mixed sweetgum, red maple, and water oak. These areas generally have a dense understory of loblolly pine regeneration, wax myrtle, and various hardwood saplings. Unfortunately, historical land uses and settlement of the local area resulted in the introduction of many non-native, invasive species. The Service is continually working to minimize negative impacts incurred by the growth of Chinese tallow tree, Chinaberry, alligator weed, water hyacinth, parrot feather, autumn olive, callery pear, Japanese climbing fern, and others.

Bradley (2018, 2019) recently completed a floristic survey of Savannah NWR. One At-Risk plant was identified along with an additional 19 species tracked by either South Carolina or Georgia. Five new rare species were recorded. Only one of the rare species, Persicaria arifolia, is located in the area proposed for opening. Additionally, this species has global rank of G5, which indicates the species as a whole is secure and is common and widespread, suggesting it is on the edge of its range at Savannah NWR.

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Air Quality Savannah NWR, as most NWRs, is a designated Class II Clean Air Area under the Clean Air Act. This means Direct and Indirect Impacts that limited sources of pollution can be permitted on and near the refuge as long as the levels of particulate, matter, sulfur dioxide, and nitrogen dioxide do not exceed the class II increments. Air quality on the refuge is Alternative A (No Action Alternative) influenced by off-site sources, including the Savannah Harbor and other industrial output west and south of No impacts to air quality would be anticipated under Alternative A. Under this Alternative, legal harvest of the refuge. individual animals would continue to occur on areas of the refuge that are currently open to hunting according to the 2016 Hunt Plan.

Alternative B (Proposed Action Alternative) No impacts to air quality would be expected to occur under this Alternative. Water Resources The Savannah River, with certain of its tributaries, forms the boundary between the states of Georgia and Direct and Indirect Impacts South Carolina along its entire length of 313 miles. There are three Federally authorized reservoirs (i.e., Hartwell, Richard B. Russell, and J. Strom Thurmond) and the New Savannah Bluff Lock and Dam at Alternative A (No Action Alternative) Augusta operated by the Army Corps of Engineers (Corps). These Corps dams and reservoirs largely control No impacts to water resources would be anticipated under Alternative A. Under this Alternative, legal the freshwater flow within the Savannah River. The Savannah River has a drainage area of approximately harvest of individual animals would continue to occur on areas of the refuge that are currently open to 9,850 square miles and an average discharge of 11,290 cubic feet per second (cfs). The tidal influence hunting according to the 2016 Hunt Plan. extends approximately 45 miles upstream to Ebenezer Landing, Georgia. The Savannah River Estuary contains an historic harbor established in 1733 and the Savannah NWR. The harbor, the Port of Savannah, is Alternative B (Proposed Action Alternative) the fourth largest container port in the United States. The Savannah estuary is a partially mixed estuary in No impacts to water resources would be expected to occur under Alternative B. which the vertical mixing of salt and freshwater is not complete over the length of saltwater intrusion. Surface salinities are appreciably less than the bottom salinities and there is a large zone of mixing between fresh and saltwater.

The refuge relies on freshwater to meet its objective of providing migration and wintering habitat for waterfowl and other wetland-dependent birds. Freshwater management (salinity less than 0.5 parts per thousand) is necessary to maintain maximum waterfowl use of the refuge’s managed wetlands. Freshwater coastal impoundments in South Carolina produce a greater variety of marsh plants, many of which are desirable food for waterfowl, than the brackish impoundments. Freshwater managed wetlands on Savannah NWR currently provide high quality feeding habitat for many species of wading birds, including the endangered wood stork. Several areas are managed each year specifically to provide optimum feeding opportunities for wading birds during and after the nesting season. Construction of a freshwater diversion canal, which provides freshwater to the refuge and adjacent plantations, was completed as mitigation for the tide gate and harbor deepening in 1977. It was rehabilitated in 2011 to correct deficiencies from the 1977 construction.

Tidal freshwater wetlands (palustrine emergent wetlands) cover much of Savannah NWR in the vicinity of the harbor and, in contrast to the managed wetlands, are flooded twice daily by tidal action. These marshes were either never diked or the dikes constructed for rice culture have eroded to marsh elevation allowing tidal flooding. Based on vegetation, interstitial (marsh root zone) salinity, and soils studies conducted in 1999 to 2001, the tidal freshwater marshes in the study area are composed of a highly diverse plant community and the community composition is highly dependent on the salinity gradient in the estuary. The areas proposed for hunting under this EA would be located within the tidal forested wetlands.

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Table EA-2. Affected Visitor Use and Experience Resources and Anticipated Impacts of the Alternatives Visitor Use and Experience Compatible with the primary purpose of migratory bird conservation, Savannah NWR provides opportunities Direct and Indirect Impacts for environmental education, interpretation, and quality wildlife-dependent recreation for the visiting public. With almost 400,000 visitors a year, access to a four-mile wildlife drive, numerous trails, over 30 miles of Alternative A (No Action Alternative) levees for hiking, 38 miles of river and 25 miles of streams and creeks, the refuge provides many Hunting would continue in accordance with the 2016 Hunt Plan (USFWS 2016) with no changes. Minor opportunities for outdoor recreation. Additionally, the refuge offers a variety of hunting opportunities as this beneficial impacts to visitor use and experience would be anticipated under Alternative A with the visitor wildlife-dependent recreation is of cultural and historical importance to the local community. The refuge hunt opportunities on the refuge including wildlife observation and photography, environmental education and program provides an opportunity to increase public awareness of the refuge and the NWRS, much of which interpretation, hunting, and fishing. Hunting activities are separated from other use activities through was purchased using funds from federal waterfowl hunting stamps and other associated hunting fees. This temporal and spatial separation. Under this Alternative, legal harvest of individual animals would continue awareness has resulted in increased public support of the refuge and other refuge programs. Hunters play an to occur on areas of the refuge that are currently open to hunting according to the 2016 Hunt Plan. important role in assisting with law enforcement and wildlife management activities. Due to limitations in refuge staff resources, hunters often provide vital tips and anecdotal information to law enforcement officers Alternative B (Proposed Action Alternative) and biological staff. Under Alternative B, hunting would continue under the 2016 Hunt Plan (USFWS 2016) with the addition of alligator hunting and with the addition of incidental hunting of armadillo, beaver, opossum, and raccoon to approved hunts. Minor beneficial impacts to visitor use and experience would be anticipated under Alternative B with the visitor opportunities on the refuge including wildlife observation and photography, environmental education and interpretation, hunting, and fishing. Levels of compatible wildlife-dependent recreation would be similar under both alternatives. Any decline in wildlife viewing and wildlife photography opportunities would likely not be realized under Alternative B with the limited nature of the proposed hunts, hunt areas, and timing of the hunts. Additionally, the areas proposed to be opened to alligator hunting are accessible only by boat and have very little public use. As future refuge parcels were to be acquired, these areas would be evaluated for compatible public-use activities, potentially resulting in an increase in all priority public uses. Hunting activities would continue to be separated from other use activities through temporal and spatial separation. Although public use levels would likely increase through time, conflicts between user groups most likely would not occur given the difficulty in accessing areas open to alligator hunting. Any conflicts that might arise would be mitigated or resolved by providing competing interest groups with alternative access opportunities. The areas being proposed for alligator hunting would experience very little public use with a negligible increase in use by hunters. Harvest of incidental species would take place only during hunts already open under Alternative A. No conflicts have arisen since the implementation of the 2016 Hunt Plan and none would be anticipated under Alternative B. The estimated increase in hunter use days would be 56 for alligator hunting and 149 for the incidental species, which would represent a less than 1% increase in the hunting use on the refuge. The Service would expect the number of alligator hunters to be fewer than 15 individuals. The low number of expected individuals may not represent an increase given the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting under state law.

Table EA-3. Affected Cultural Resources and Anticipated Impacts of the Alternatives Cultural Resources Although consultation with the pertinent State Historic Preservation Office and federally recognized Native Direct and Indirect Impacts American Tribes is not required, the Regional Historic Preservation Officer and Regional Archaeologist reviewed this plan and determined that implementing any of the proposed alternatives would result in no Alternative A (No Action Alternative) impacts to cultural resources. The proposed changes to the refuge hunt program would not pose any threat to Under this alternative, there would be no anticipated direct or indirect impacts to the cultural environment, as cultural resources on the refuge. Hunting meets only one of the two criteria used to identify an “undertaking” current conditions would be maintained, and no ground disturbance would occur under Alternative A.

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that triggers a federal agency’s need to comply with Section 106 of the National Historic Preservation Act. These criteria, which are delineated in 36 CFR Part 800, state: Alternative B (Proposed Action Alternative)  An undertaking is any project, activity, or program that can alter the character or use of an Under Alternative B, there would be no anticipated direct or indirect impacts to the cultural environment, as archaeological or historic site located within the “area of potential effect” and current conditions would be maintained, and no ground disturbance would occur.  The project, activity, or program must also be either funded, sponsored, performed, licensed, or have received assistance from the agency.

Table EA-4. Affected Refuge Management and Operations Resources and Anticipated Impacts of the Alternatives Refuge Management and Operations Land Use Direct and Indirect Impacts The Service defines facilities as, “Real property that serves a particular function such as buildings, roads, utilities, water control structures, raceways, etc.” Under the Proposed Action, those facilities most utilized by Alternative A (No Action Alternative) hunters would be parking areas, roads, and trails. Hunters are permitted to access the refuge by foot, boat, and Under this alternative, there would be no anticipated direct or indirect impacts to land use or the bicycle; no additional maintenance or improvements of existing refuge facilities would be required and administrative burden, since no change would take place. Annual maintenance or improvements of existing existing boat ramps are located off the refuge. facilities could cause minimal short-term impacts to localized soil, water, and wildlife habitat. Facility maintenance and improvement activities periodically are conducted to accommodate daily refuge Administration management operations and general public uses such as wildlife observation and wildlife photography. The Savannah NWR currently consists of 17 staff members making up general refuge management, biology, When these activities are necessary, they would be scheduled to cause the least amount of disturbance to fire, maintenance, and law enforcement. The Savannah NWR budget is approximately $2 million per year and wildlife and other users of the refuge. covers administration of 7 NWRs in the area. Many of the annual hunt administration costs including salary, equipment, boundary signs, and maintenance are associated with general management of the refuge and are Alternative B (Proposed Action Alternative) required whether hunting is permitted or not. Printing hunt brochures, purchasing replacement boundary signs, No additional impacts to land use would be incurred under Alternative B. No or negligible adverse impacts and providing law enforcement are the primary costs directly associated with hunting. Immediately prior to and would be anticipated for the administrative burden under Alternative B. during the active hunting season, one full-time employee is devoted to conducting hunt-related administrative activities.

Table EA-5. Affected Socioeconomic Resources and Anticipated Impacts of the Alternatives Socioeconomics Local and Regional Economies Direct and Indirect Impacts The Savannah NWR is located approximately 5 miles from the city of Savannah, Georgia with a population of 145,000. The refuge is split with approximately half in Georgia and half in South Carolina. Several other small Alternative A (No Action Alternative) towns are also within thirty to ninety miles of the refuge. The predominant land uses near the refuge vary Negligible to minor beneficial impacts to local and regional economies would be anticipated under between Georgia and South Carolina. Land use near the refuge in South Carolina is predominately large tracts Alternative A. of land (>500 acres) used mainly for hunting and conservation purposes. Although, a large tract adjacent to the eastern boundary of the refuge is being developed for warehouses associated with the Savannah Harbor. Alternative B (Proposed Action Alternative) Georgia, however, is composed primarily of smaller tracts (<100 acres) used for a variety of purposes Negligible to minor beneficial impacts to local and regional economies would be anticipated under including, but not limited to, farming and small-scale timber production. The Savannah Chamber of alternative B. Alligator hunting visitation would be anticipated to result in less than 15 visits to the refuge Commerce lists the refuge as one of the area’s main attractions. The refuge had about 391,000 recreational with each visit representing less than $200.00 in expenditures, including license purchase. Total visits in 2017, which contributed to the economic effect of the refuge in the local economies; non-consumptive expenditures associated with 15 visits associated with alligator hunting would total approximately $3,000.00. recreation accounted for about 375,000 visits with residents comprising 53 percent of refuge visitation Table These revenues represent a negligible impact in the context of the Effingham County and Jasper County 5.1). economies, which are dominated by business, shipping, and real estate. Harvest of the incidental species

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Table EA-5.1. Savannah NWR: 2017 Recreation Visits would be anticipated to have no effect on local and regional economies, since these species would only be Activity Residents Non-Residents Total added to existing hunting opportunities with no new seasons or limits being proposed. Non-Consumptive Pedestrian 24,292 36,438 60,730 Auto Tour 109,287 109,287 218,574 Boat Trail/Launch 6,960 773 7,733 Bicycle 1,749 437 2,186 Photography 38,250 16,393 54,643 Interpretation 395 44 439 Other Recreation 6,239 693 6,932 Visitor Center 7,166 16,722 23,888 Hunting Big Game 990 990 1,980 Small Game 130 33 163 Migratory Birds 220 146 366 Fishing 12,425 1,381 13,806 Total Visitation 208,103 183,337 391,440

Regional Economic Analysis The economic area for the refuge is the three-county area of Chatham and Effingham counties in Georgia and Jasper County in South Carolina. It is assumed that visitor expenditures occur primarily within these counties. Visitor recreation expenditures for 2017 are shown in Table 5.2. Total expenditures in 2017 were $5.9 million with non-residents accounting for $5.0 million or 81 percent of total expenditures. Expenditures on non- consumptive activities in 2017 accounted for 94 percent of all expenditures. Spending in the local area generates and supports economic activity within the three-county area (Table 5.3). The contribution of recreational spending in local communities in 2017 was associated with about 79 jobs, $2.7 million in employment income, $514,000 in total tax revenue, and $8.8 million in economic output.

Table EA-5.2. Savannah NWR: Visitor Recreation (2017, $,000) Expenditures Activity Residents Non-Residents Total Non-Consumptive $951.7 $4,932.5 $5,884.2 Hunting $31.2 $83.9 $115.2 Fishing $212.2 $31.0 $243.2 Total Expenditures $1,195.2 $5,047.4 $6,242.6

Table EA-5.3. Savannah NWR: Local Economic Contributions Associated with Recreation Visits (2017 $,000) Residents Non- Total Residents Economic Output $1,717.4 $7,131.7 $8,849.0 Jobs 16 63 79 Job Income $530.9 $2,142.6 $2,673.5 State and Local Tax Revenue $97.2 $416.7 $513.9

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Climate Change and Local Weather Changing climate, whether it results from anthropogenic or natural sources, is expected to affect a variety of Direct and Indirect Impacts natural processes and associated resources. The complexity of ecological systems within the Savannah estuary points to a tremendous amount of uncertainty about the impact climate change will actually have. In particular, Alternative A (No Action Alternative) the localized effects of climate change are still a matter of much debate. The Savannah River watershed drains Under Alternative A, there would be no anticipated impacts to climate change or local weather events within 10,500 mi2 along the 330-mile long river. Localized weather events in virtually any part of the drainage basin the basin. can affect the estuary, and these events can vary dramatically. For example, the upper basin can experience drought while the estuary can experience flooding from intense local thunderstorms produced by its close Alternative B (Proposed Action Alternative) proximity to the ocean. Under Alternative B, there would be no anticipated impacts to climate change or local weather events within the basin. Humaneness and Animal Welfare Concerns All methods of take for both Georgia and South Carolina have been developed with the objective of humanely Direct and Indirect Impacts dispatching the animal. The South Carolina Alligator Hunting Guide for 2019 details various methods in dispatching alligators and must be followed by hunters in South Carolina (SCDNR 2019). The same methods Alternative A (No Action Alternative) for dispatching animals are used in Georgia. Approved hunts, including dates, time, and method of take, while Hunting would continue in accordance with the 2016 Hunt Plan (USFWS 2016) with no changes. Under involving the killing of individuals, are developed with humaneness and animal welfare concerns. this Alternative, legal harvest by legal means of individual animals would continue to occur on areas of the refuge that are currently open to hunting according to the 2016 Hunt Plan. Under this Alternative, there would be no anticipated impacts to alligators, since the refuge would remain closed to alligator hunting. While the killing of individual animals would continue to occur under Alternative A, hunts would continue to be developed with humaneness and animal welfare concerns.

Alternative B (Proposed Action Alternative) Under Alternative B, hunting would continue under the 2016 Hunt Plan (USFWS 2016) with the addition of alligator hunting and with the addition of incidental hunting of armadillo, beaver, opossum, and raccoon to approved hunts. Under this Alternative, there would be minimal adverse impact since very few, less than 15, visits would be anticipated on the refuge for alligator hunting. No effects would be anticipated with the addition of the incidental species. While the killing of individual animals would occur under Alternative B, proposed hunts were developed with humaneness and animal welfare concerns. Environmental Justice Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low- Direct and Indirect Impacts Income Populations, requires all Federal agencies to incorporate environmental justice into their missions by identifying and addressing disproportionately high or adverse human health or environmental effects of their Alternative A (No Action Alternative) programs and policies on minorities and low-income populations and communities. The Order also is intended Under this Alternative, negligible to minor beneficial impacts to minority or low-income populations and to promote nondiscrimination in federal programs substantially affecting human health and the environment, communities would be anticipated. and to provide minority and low-income communities’ access to public information and participation in matters relating to human health or the environment. There are several rural communities adjacent to the Alternative B (Proposed Action Alternative) refuge that meet some part or all of the criteria identified and protected by Executive Order 12898. With Under this Alternative, increased public hunting opportunities would offer another mechanism for low- respect to impacts that may adversely affect minority or low-income populations in the affected area, this EA income and under-served hunters to enjoy this compatible form of wildlife-based recreation, while also does not include any adverse environmental or human health effects specific to any of the alternatives. In fact, supplementing food resources. Under Alternative B, negligible to minor beneficial impacts to minority and public hunting opportunities, such as those offered at Savannah NWR, are often the only mechanism for low- low-income populations and communities would be anticipated. income and under-served hunters to enjoy this compatible form of wildlife-based recreation, while also supplementing food resources.

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Table EA-6. Anticipated Cumulative Impacts of the Alternatives Natural Resources Neither alternative would be anticipated to have adverse or beneficial cumulative impacts to the human environment, including natural resources. Under both alternatives, no adverse or beneficial cumulative impacts would be anticipated for species proposed to be hunted (i.e., American alligator, armadillo, beaver, opossum, and raccoon), species currently hunted (i.e., white-tailed deer, wild turkey, rabbit, squirrel, migratory birds, coyote, and feral hog), non-target species, vegetation, air quality, and water resources. Population estimates of huntable species are developed at a regional, state, and continental scale. Hunting frameworks and take limits are set based upon these estimates. By maintaining hunting regulations that are the same as or more restrictive than the state, individual refuges ensure that they are maintaining seasons which are supportive of management on a more regional basis. Such an approach also provides consistency with large-scale population status and objectives.

Species Proposed to be Hunted No beneficial or adverse cumulative impacts would be anticipated for populations of species proposed to be hunted under either alternative.

American Alligator – No beneficial or adverse cumulative impacts would be anticipated for the American alligator population under the No Action Alternative. Under the Proposed Action, the addition of hunting on the refuge would be anticipated to have no beneficial or adverse cumulative impacts on the American alligator population. The states of Georgia and South Carolina regulate the take of alligators in their respective states. Very few hunters would be anticipated to participate in alligator hunting on the refuge. The proposal would be expected to increase hunter use days an estimated 56 days for alligator hunting with an estimated change in the harvest level of less than one percent. The anticipated increase in hunters for the proposed alligator hunting would represent less than 1% of total annual refuge visitation (approximately 0.004%). The Service would expect the number of alligator hunters to be fewer than 15 individuals. The low number of expected individuals may not represent an increase given the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting under state law. The alligator harvest would be anticipated to be between five and 17 individuals in any given year, however, this may not represent an increase in the overall alligator harvest given that the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting under state law.

Armadillo, Beaver, Opossum, and Raccoon – No beneficial or adverse cumulative impacts would be anticipated for the armadillo, beaver, opossum, and raccoon populations under the No Action Alternative. Under the Proposed Action, the addition of hunting on the refuge would be anticipated to have no beneficial or adverse cumulative impacts on the armadillo, beaver, opossum, and raccoon populations. The state of Georgia regulates the take of armadillo, beaver, opossum, and raccoon populations. Under the Proposed Action, the Service believes the incidental take of these species would be negligible on a local and regional scale. All these species are considered nuisance and can cause substantial damage to property. Very few beavers are observed in the Savannah River estuary. Only one beaver has been observed by refuge staff; it was a road kill. Raccoons are very adaptable, are found throughout the refuge in both upland and wetland habitats, and are widely dispersed across the refuge. Armadillos and opossums occur on the refuge, but most likely in minimal numbers. Impacts to these populations from hunting would be anticipated to be negligible. Road kill mortality of these species would be anticipated to be higher than the proposed hunting. The proposal would be expected to increase hunter use days an estimated 149 days for the incidental species with an estimated change in the harvest level of less than one percent. The Service would not anticipate the number of hunters to increase with the addition of hunting the incidental species; rather, existing hunters would have the opportunity to take additional species. Any increase in the number of hunters would be expected to be negligible to minor.

Non-Hunted Species No beneficial or adverse cumulative impacts would be anticipated to non-hunted species under either alternative. As outlined above, Alternative B would represent a small increase (less than 1%) in the total visitation to the refuge. Implementing either alternative would result in minimal direct disturbance to non-hunted species. Hunting in areas and during seasons when shorebird, wading bird, and wintering waterfowl numbers are generally the greatest would be strictly limited. Limiting hunting in these areas to short duration hunts during times when non-hunted species are minimal in numbers would also ensure negligible disturbance. Hunters may encounter reptiles (non-alligator) and amphibians during the hunting season, but these encounters would occur during the non-breeding season and at a time of relatively high water compared to spring and early summer levels. Water conditions and hunter interactions should not have cumulative negative impacts on (non-alligator) and populations. Invertebrates also are not active during cold weather and would have few interactions with hunters during the hunting season. Refuge regulations would further mitigate possible disturbance by hunters to non-hunted wildlife. Vehicles would be restricted to roads and the harassment or taking of any wildlife other than the game species legal for the season would not be permitted under either alternative. Visitor Use and Experience Neither alternative would be anticipated to have adverse or beneficial cumulative impacts to the human environment, including visitor use and experience.

Under Alternative A, there would be no anticipated adverse or beneficial cumulative impacts; visitor use and experience would remain the same. No adverse or beneficial cumulative impacts would be anticipated on neighboring public or private lands under either alternative.

Approval of Alternative B, the Proposed Action, would result in a net gain of public hunting opportunities with no adverse or beneficial cumulative impacts to the general public, nearby residents, and refuge visitors. The refuge would expect increased visitation and tourism to bring additional revenues to local communities, however, anticipated numbers would be low and thus have negligible associated beneficial impacts. Community support would likely increase for refuge management activities, including land acquisition, habitat management, and public use funding. Traditional uses, such as hunting, have been a way of life for many of the rural

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communities near the refuge. In recent years, land use changes around the refuge have eliminated many areas that were traditionally leased by hunters. Commercial timberlands have been sold to commercial and residential developers. Providing additional hunting opportunities would continue these traditional uses and would have a negligible positive economic impact on local communities. The Service would anticipate very few hunters participating in the proposed alligator hunt and no other hunting season is open during this time except for a potential short overlap with archery deer season. Little to no conflict would result with anglers as well. Anglers would continue to be concentrated along the open water of the Savannah River that is already open to alligator hunting. The proposal would be anticipated to increase hunter use days by an estimated 56 days for alligator hunting and an estimated 149 days for hunting of the incidental species. The increase in hunters under the proposal would represent less than 1% of total annual refuge visitation. Additionally, over 99% of the visitation on Savannah NWR is concentrated along the Laurel Hill Wildlife Drive and Visitor Center areas. These areas are closed to hunting and would remain closed under Alternative B. The Service would not anticipate an increase in conflicts between user groups under the proposal. The Service would not anticipate the number of hunters to increase with the addition of hunting the incidental species; rather, existing hunters would have the opportunity to take additional species. Any increase in the number of hunters for the incidental species would be expected to be negligible to minor. The alligator harvest would be anticipated to be between five and 17 individuals in any given year, however, this may not represent an increase in the overall alligator harvest given that the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting under state law.

Road and Trail Development and Use Under either alternative, no additional roads or trails would be developed, thus there would be no anticipated beneficial or adverse associated cumulative impacts. The anticipated and limited increase in use would be access by boat, which would not require further infrastructure development. All the boat ramps that are currently available for hunters are also available for other wildlife-dependent recreational users. Additionally, the boat ramps are located off-refuge and are not maintained by refuge staff. These would continue under both alternatives. The proposal would be expected to increase hunter use days an estimated 56 days for alligator hunting with an estimated change in the harvest level of less than one percent. The anticipated increase in hunters for the proposed alligator hunting (estimated at 15) would represent less than 1% of total annual refuge visitation.

Use of Lead Ammunition/Tackle Under Alternative A, there would be no anticipated beneficial or adverse cumulative impacts related to the use of lead ammunition of tackle. Under Alternative B for proposed alligator hunting, lead weights could be attached to snatch hooks; however, non-toxic shot would be required to be used in handguns and bangsticks to dispatch alligators. The Service believes the potential increase in lead from snatch hooks would be negligible. Under Alternative B, raccoons, armadillos, opossums, and beavers could only be dispatched according to the Small Game regulations on the Savannah NWR, which requires the use of non-toxic shot. Under Alternative B, there would be no anticipated beneficial or adverse cumulative impacts related to the use of lead ammunition of tackle. Cultural Resources Neither alternative would be anticipated to have adverse or beneficial cumulative impacts to the human environment, including cultural resources.

Under each alternative, impacts to cultural resources on the refuge would be similar with no adverse or cumulative impacts anticipated for cultural resources. None of the public uses under each alternative would increase opportunities for impacts to cultural resources. Hunting, regardless of method or species targeted, is a public use activity that would not pose any additive threat to cultural resources that may be found on the refuge. Development of any future infrastructure, such as access roads or parking areas, could potentially impact historic properties and would require review by the Regional Archaeologist and compliance with Section 106 of the National Historic Preservation Act. Refuge Management and Operations Neither alternative would be anticipated to have adverse or beneficial cumulative impacts to the human environment, including refuge management and operations.

Impacts of each of the alternatives on refuge management and operations would be similar with no adverse or cumulative impacts anticipated. Under each alternative, the majority of areas that would be open to hunting are seldom visited by the non-hunting public. Maintenance or improvement of facilities (e.g., roads, trails, and parking areas) would be the same under each alternative, as each would have similar, minimal, short-term impacts on those facilities. Facility maintenance and improvement activities are periodically conducted to accommodate daily refuge management operations and general public uses, such as wildlife observation and photography. When these activities are necessary, they would be conducted at times to cause the least amount of disturbance to wildlife, as well as hunters and other users. There are no additional facilities needed for administering the hunt program. All-terrain vehicles and other off road vehicles are not allowed on refuge roads or trails. These would continue under Alternative B. Under each alternative, no adverse or beneficial cumulative impacts to existing facilities would be occur. The proposal would be expected to increase hunter use days an estimated 56 days for alligator hunting with an estimated change in the harvest level of less than one percent. The anticipated increase in hunters for the proposed alligator hunting (estimated at 15) would represent less than 1% of total annual refuge visitation. Socioeconomics and Other Topics Neither alternative would be anticipated to have adverse or beneficial cumulative impacts to the human environment, including socioeconomics, climate change, humaneness and animal welfare concerns, environmental justice, and Indian Trust Resources.

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Socioeconomics No adverse or beneficial cumulative socioeconomic impacts would be anticipated under either alternative. Approval of Alternative B, the Proposed Action, would result in a net gain of public hunting opportunities with no adverse or beneficial cumulative impacts to the general public, nearby residents, and refuge visitors. The refuge would expect increased visitation and tourism to bring additional revenues to local communities, however, anticipated numbers would be low and thus negligible associated beneficial impacts would be anticipated. Community support would likely increase for refuge management activities, including land acquisition, habitat management, and public use funding. Traditional uses, such as hunting, have been a way of life for many of the rural communities near the refuge. In recent years, land use changes around the refuge have eliminated many areas that were traditionally leased by hunters. Commercial timberlands have been sold to commercial and residential developers. Providing additional hunting opportunities would continue these traditional uses and would have a negligible positive economic impact on local communities. The proposal would be expected to increase hunter use days an estimated 56 days for alligator hunting with an estimated change in the harvest level of less than one percent. The anticipated increase in hunters for the proposed alligator hunting (estimated at 15) would represent less than 1% of total annual refuge visitation.

Climate Change Under each alternative, there would be no adverse or beneficial impacts to climate change; climate change factors would remain unaffected by either alternative.

Humaneness and Animal Welfare Concerns No adverse or beneficial cumulative impacts to humaneness and animal welfare concerns would be anticipated under either alternative. All methods of take for both Georgia and South Carolina have been developed with the objective of humanely dispatching the animal. The South Carolina Alligator Hunting Guide for 2019 details various methods in dispatching alligators and must be followed by hunters in South Carolina (SCDNR 2019). The same methods for dispatching animals are used in Georgia. Approved hunts, including dates, time, and method of take, while involving the killing of individuals, are developed with humaneness and animal welfare concerns.

Environmental Justice No adverse or beneficial cumulative impacts to environmental justice would be anticipated under either alternative.

Indian Trust Resources No adverse or beneficial cumulative impacts to Indian Trust Resources would be anticipated under either alternative.

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Summary of Analysis

This EA briefly provides sufficient evidence and analysis for determining whether to prepare an Environmental Impact Statement (EIS) or a FONSI.

Alternative A – No Action Alternative As described above, no changes to the current Hunt Plan would take place. The current Hunt Plan was implemented in 2016 and has been in effect for the past three years (USFWS 2016). Hunting of white-tailed deer, wild turkey, rabbit, squirrel, migratory birds, coyote, and feral hog would continue under Alternative A. Under Alternative A, no impacts to threatened and endangered species would be anticipated, with a previous Section 7 finding of “not likely to adversely affect.” No impacts would be anticipated under Alternative A for air quality, water resources, cultural resources, refuge management and operations, or climate change or local weather. Negligible to minor adverse impacts would be anticipated under Alternative A for vegetation. Negligible to minor beneficial impacts would be anticipated under Alternative A for visitor use and experience and local and regional economies. Approved hunts, including dates, time, and method of take, while involving the killing of individuals, would continue to be developed with humaneness and animal welfare concerns.

Alternative B – Proposed Action Alternative As described above, the Proposed Action would continue the current Hunt Plan (USFWA 2016) with the hunting of white-tailed deer, wild turkey, rabbit, squirrel, migratory birds, coyote, and feral hog, and would add hunting of American alligator and incidental hunting of armadillo, beaver, opossum, and raccoon in accordance with the proposed Hunt Plan (USFWS 2020a) and proposed compatibility determination (USFWS 2020b). Under Alternative B, no impacts to threatened and endangered species would be anticipated, with a draft Section 7 finding of “not likely to adversely affect.” No impacts would be anticipated under Alternative B for air quality, water resources, cultural resources, refuge management and operations, or climate change or local weather. Negligible to minor adverse impacts would be anticipated under Alternative B for vegetation. Negligible to minor beneficial impacts would be anticipated under Alternative B for visitor use and experience and local and regional economies. Approved hunts, including dates, time, and method of take, while involving the killing of individuals, would continue to be developed with humaneness and animal welfare concerns. The alligator harvest would be anticipated to be between five and 17 individuals in any given year, however, this may not represent an increase in the overall alligator harvest given that the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting under state law. The annual harvest of these incidental species would be anticipated to be zero to 15 each for armadillo, opossum, and raccoon and zero to three for beaver.

As described above, the Proposed Action Alternative would have very little impact to visitor use from both hunters and non-hunters. Alligator hunting would be open only on refuge lands north of I-95 and accessible only by boat. The Service would expect the number of alligator hunters to be fewer than 15 individuals. The low number of expected individuals may not represent an increase given the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting under state law. The navigable waterways open to hunting include the Savannah River in both Georgia and South Carolina and the Abercorn, Little Abercorn, and Big

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Collis creeks in Georgia. The Middle, Back, and Little Back rivers would remain closed to alligator hunting as these are located south of I-95 and are not being proposed for opening. The refuge anticipates the majority of hunters would remain in the navigable waterways with very few, if any, venturing into the interior tributaries. These tributaries are tidal and extremely difficult to access. The Service would not anticipate the number of hunters to increase with the addition of hunting the incidental species; rather, existing hunters would have the opportunity to take additional species. Any increase in the number of hunters for incidental species would be expected to be negligible to minor.

No conflict with other user groups would be expected. The only potential overlap with other hunting seasons would be with the Savannah NWR white-tailed deer archery season. Depending on the dates for both hunts, the potential overlap may 2 to 3 weeks. However, habitat types and access would naturally segregate alligator hunters and deer hunters. No conflict between these user groups would be anticipated. In addition, no conflict between alligator hunters and the non- hunting public would be anticipated. Access to remote interior parts of the refuge would also segregate these groups. The only potential conflict would be anglers using the navigable waterways and tributaries; however, these conflicts would be anticipated to be low. Although the Banking with Nature 2018 report shows over 13,000 recreational visits for fishing, the refuge believes these numbers to be hyper-inflated with these counts coming from boat launches off- refuge and anglers using waters off-refuge (USFWS, unpublished, preliminary data). No conflict would be expected with opening hunting to incidental species; these species would be taken during open seasons for other, already established hunting seasons on the refuge.

The 2011 Comprehensive Conservation Plan (CCP) and associated EA for the Savannah Coastal Refuge Complex addressed future management of the refuge and included a recommendation to create additional public hunting opportunities (USFWS 2010, 2011a). This EA evaluates opportunities and impacts that could be reasonably expected by revising the current hunt program to add hunting of American alligator and incidental hunting of armadillo, beaver, opossum, and raccoon. The NWRSAA of 1966 as amended by the NWRSIA of 1997 provides authority for the Service to manage the refuge and its wildlife populations. In addition, the NWRSIA declares that compatible wildlife-dependent public uses are legitimate and appropriate uses of the NWRS and that they are to receive priority consideration in planning and management. There are six wildlife-dependent public uses: hunting, fishing, wildlife observation, wildlife photography, environmental education, and interpretation that are specifically named in the NWRSIA. It further directs Refuge Managers to increase recreational opportunities, particularly family oriented hunting and fishing opportunities, on NWRs when compatible with both the purposes for which the refuge was established and the mission of the NWRS.

Based on the description of alternatives and analysis of impacts, the Service identified that the Proposed Action Alternative (Alternative B) best serves the identified purpose and need. The Proposed Action would provide additional wildlife-dependent recreation opportunities on the refuge with little to no conflict with existing programs, as well as little to no burden on refuge operations and management. The Service has developed a draft compatibility determination, which outlines the proposed hunting of American alligator and the incidental hunting of armadillo, beaver, opossum, and raccoon on Savannah NWR (USFWS 2020b).

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Monitoring

Monitoring of all existing and future hunting activities on the Savannah NWR would be through law enforcement contacts with individual hunters, as well as through state reporting requirements.

4.0 List of Sources, Agencies, and Persons Consulted

References

Chatham County. 2005. Chatham County, Georgia "Annual Budget - Fiscal year 2005/2006." http://www.chathamcounty.org/FY2005Budget/016-intro-backgroundinfo.pdf.

Bradley, K. 2018. At-risk plant occurrences on National Wildlife Refuges with the South Carolina Lowcountry and Savannah complexes. U.S. Fish and Wildlife Service Final Report, Inventory and Monitoring Program. 41 pp.

Bradley, K. 2019. Floristic inventories of National Wildlife Refuges within the South Carolina Lowcountry and Savannah complexes. U.S. Fish and Wildlife Service Final Report, Inventory and Monitoring Program. 229 pp.

Georgia Department of Natural Resources. 2019. Georgia Alligator Hunting Season Summary 2019 (Preliminary Report 11/4/2019). 2 pp. https://georgiawildlife.com/sites/default/files/wrd/pdf/harvest- summaries/alligator/Alligator%20Harvest%20Summary%202019.pdf

Georgia Department of Natural Resources. 2018. Georgia alligator hunting season report 2018. https://georgiawildlife.com/sites/default/files/wrd/pdf/harvest- summaries/alligator/Alligator%20Harvest%20Summary%202018.pdf

Georgia Department of Natural Resources. 2016a. Wildlife Resources Division "Deer Fact Sheet." https://georgiawildlife.com/DeerFacts.

Georgia Department of Natural Resources. 2016b. Wildlife Resources Division "Wild Turkey Fact Sheet." http://georgiawildlife.com/node/492.

Georgia Wildlife Web. 2016. "The University of Georgia Museum of Natural History." http://fishesofgeorgia.uga.edu/gawildlife/index.php?page=speciespages/species_page&key% 20=sscrofa.

Raftovich, R.V., S. C. Chandler, and K.A. Wilkins. 2015. Migratory bird hunting activity and harvest during the 2013-14 and 2014-15 hunting seasons. U.S. Fish and Wildlife Service, Laurel, Maryland.

Seamans, M. E. 2015. Mourning dove population status, 2015. U.S. Department of the Interior, Fish and Wildlife Service, Division of Migratory Bird Management, Washington, D.C.U.S.

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South Carolina Department of Natural Resources. 2017. Alligator hunting season report 2017. F&AP Report 18-01. 19 pp.

South Carolina Department of Natural Resources. 2019. South Carolina alligator hunting guide for 2019. F&AP Publication 19-02. 26 pp.

U.S. Climate Data. "Climate Savannah - Georgia." http://www.usclimatedata.com/climate/savannah/georgia/united-states/usga1191.

U.S. Fish and Wildlife Service. 2020a. Draft Savannah National Wildlife Refuge American Alligator, Armadillo, Beaver, Opossum, and Raccoon Hunt Plan. January 2020. Hardeeville, SC. 13 pp.

U.S. Fish and Wildlife Service. 2020b. Savannah National Wildlife Refuge Draft Compatibility Determination: Hunting of American Alligator, Armadillo, Beaver, Opossum, and Raccoon. January 2020. Hardeeville, SC. 9 pp.

U.S. Fish and Wildlife Service. 2016. Savannah National Wildlife Refuge Big Game, Small Game, Migratory Bird, Coyote, and Feral Hog Hunt Plan. October 2016. 20 pp.

U.S. Fish and Wildlife Service. 2015. Visitor Services Plan: Savannah National Wildlife Refuge. Department of the Interior, Fish and Wildlife Service, Savannah Coastal Refuges Complex, Hardeeville, South Carolina.

U.S. Fish and Wildlife Service. 2013. Cumulative Impacts Report 2013-2014 National Wildlife Refuge Proposed Hunting Openings

U.S. Fish and Wildlife Service. 2011a. Savannah Coastal National Wildlife Refuges Complex Comprehensive Conservation Plan. Blackbeard Island, Harris Neck, Pinckney Island, Savannah, Tybee, and Wassaw National Wildlife Refuges. U.S. Department of the Interior, Fish and Wildlife Service, Southeast Region. September 2011. Atlanta, GA. 357 pp. https://catalog.data.gov/dataset/savannah-coastal-national-wildlife-refuges-complex- comprehensive-conservation-plan

U.S. Fish and Wildlife Service. 2011b. Waterfowl Population Status, 2011. Division of Migratory Bird Management, Laurel, Maryland. 80 pp.

U.S. Fish and Wildlife Service. 2010. Draft Comprehensive Conservation Plan and Environmental Assessment for Savannah Coastal Refuge Complex. Blackbeard Island, Harris Neck, Pinckney Island, Savannah, Tybee, and Wassaw National Wildlife Refuges. U.S. Department of the Interior, Fish and Wildlife Service, Southeast Region. September 2010. Atlanta, GA. 545 pp.

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List of Preparers

 Chuck Hayes, Supervisory Wildlife Biologist, Savannah Coastal Refuges Complex, South Atlantic-Gulf and Mississippi Basin Unified Regions, U.S. Fish and Wildlife Service, Hardeeville, SC  Wayne Harris, Wildlife Biologist, Savannah National Wildlife Refuge, South Atlantic-Gulf and Mississippi Basin Unified Regions, U.S. Fish and Wildlife Service, Hardeeville, SC.  Shaw Davis, Acting Project Leader, Savannah Coastal Refuges Complex, South Atlantic- Gulf and Mississippi Basin Unified Regions, U.S. Fish and Wildlife Service, Hardeeville, SC.  Rick Kanaski, Regional Archaeologist, South Atlantic-Gulf and Mississippi Basin Unified Regions, U.S. Fish and Wildlife Service, Hardeeville, SC

State Coordination The Service sent letters regarding the proposed Hunt Plan, compatibility, regulations, and EA to the states of Georgia and South Carolina on December 30, 2019.

Tribal Consultation The Service sent letters on November 4, 2019 for all potential 2020-21 hunt packages for the South Atlantic-Gulf and the southern portion of the Mississippi Basin unified regions, including the proposed hunting at Savannah NWR, to: -Coushatta Tribe of , Alabama- Quassarte Tribal Town, Kialegee Tribal Town, Muscogee (Creek) Nation, Poarch Band of Creek Indians, Indian Tribe of , Seminole Nation of , and Thlopthlocco Tribal Town.

5.0 Public Outreach

The Environmental Assessment; draft Hunt Plan; and draft Compatibility Determination were made available for public review and comment for 30 days in early 2020. Notice was posted at the Savannah NWR Visitor Center, all refuge kiosks, refuge website ((http://www.fws.gov/refuge/savannah), and refuge Facebook page (http://www.facebook.com/SavannahCoastalRefugesComplex). Further, a public informational bulletin announcing the availability of the documents for public review and comment was provided to the following newspapers: Beaufort Gazette, Bluffton Today, Bryan County News, Connect Savannah, Effingham Herald, Island Packet, Jasper Sun Times, Savannah Morning News, and Spirit Newspaper.

6.0 Determination Note: This section will be filled out upon completion of any public comment period and at the time of finalization of the Environmental Assessment.

☐ The Service’s action will not result in a significant impact on the quality of the human environment. See the attached “Finding of No Significant Impact”.

☐ The Service’s action may significantly affect the quality of the human environment and the Service will prepare an Environmental Impact Statement.

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Preparer Signature: ______Date:______

Name/Title/Organization: ______

______

Reviewer Signature: ______Date:______

Name/Title: ______

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Section C. Appendices

Appendix A. Other Key Applicable Statutes, Executive Orders, and Regulations

STATUTES, EXECUTIVE ORDERS, AND REGULATIONS Cultural Resources

American Indian Religious Freedom Act, as amended, 42 U.S.C. 1996 – 1996a; 43 CFR Part 7 The Proposed Action includes no ground- disturbing activities, or other activities Antiquities Act of 1906, 16 U.S.C. 431-433; 43 that might disturb undocumented CFR Part 3 paleontological, archaeological, or historic sites. The Regional Archaeologist Archaeological Resources Protection Act of 1979, has reviewed this EA. 16 U.S.C. 470aa – 470mm; 18 CFR Part 1312; 32 CFR Part 229; 36 CFR Part 296; 43 CFR Part 7

National Historic Preservation Act of 1966, as amended, 16 U.S.C. 470-470x-6; 36 CFR Parts 60, 63, 78, 79, 800, 801, and 810

Paleontological Resources Protection Act, 16 U.S.C. 470aaa – 470aaa-11

Native American Graves Protection and Repatriation Act, 25 U.S.C. 3001-3013; 43 CFR Part 10

Executive Order 11593 – Protection and Enhancement of the Cultural Environment, 36 Fed. Reg. 8921 (1971)

Executive Order 13007 – Indian Sacred Sites, 61 Fed. Reg. 26771 (1996) Fish & Wildlife

Bald and Golden Eagle Protection Act, as amended, 16 U.S.C. 668-668c, 50 CFR 22 No changes are proposed to current refuge-specific hunting regulations for Endangered Species Act of 1973, as amended, 16 migratory birds and upland game birds. U.S.C. 1531-1544; 36 CFR Part 13; 50 CFR Parts

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10, 17, 23, 81, 217, 222, 225, 402, and 450 There are six known federal threatened or endangered species on or in adjacent Fish and Wildlife Act of 1956, 16 U.S.C. 742 a-m waters near the refuge. Alligators are considered threatened by similarity of Lacey Act, as amended, 16 U.S.C. 3371 et seq.; 15 appearance with other crocodilians. CFR Parts 10, 11, 12, 14, 300, and 904 However, no other species of crocodilian is present on the refuge. Migratory Bird Treaty Act, as amended, 16 U.S.C. 703-712; 50 CFR Parts 10, 12, 20, and 21

Executive Order 13186 – Responsibilities of Federal Agencies to Protect Migratory Birds, 66 Fed. Reg. 3853 (2001) Natural Resources

Clean Air Act, as amended, 42 U.S.C. 7401-7671q; The Service previously evaluated the 40 CFR Parts 23, 50, 51, 52, 58, 60, 61, 82, and 93; suitability of the Savannah National 48 CFR Part 23 Wildlife Refuge for wilderness designation and concluded that the refuge Wilderness Act, 16 U.S.C. 1131 et seq. does not meet the basic criteria for inclusion into the National Wilderness Wild and Scenic Rivers Act, 16 U.S.C. 1271 et seq. Preservation System. The Service has evaluated the eligibility Executive Order 13112 – Invasive Species, 64 Fed. of streams on Savannah National Wildlife Reg. 6183 (1999) Refuge for wild and scenic river designation and concluded no streams meet the basic criteria for inclusion into the National Wild and Scenic Rivers System The proposed action would have no anticipated impacts to air quality. The proposed action is consistent with Executive Order 13112 because stipulations in permits would be designed to prevent the introduction of invasive species. Water Resources

Coastal Zone Management Act of 1972, 16 U.S.C. There would be no impacts of the 1451 et seq.; 15 CFR Parts 923, 930, 933 proposed action on water quality or water resources. Federal Water Pollution Control Act of 1972 The refuge contains no drinking water (commonly referred to as Clean Water Act), 33 sources and does not supply drinking

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U.S.C. 1251 et seq.; 33 CFR Parts 320-330; 40 water to any community. CFR Parts 110, 112, 116, 117, 230-232, 323, and The proposed action is consistent with 328 Executive Order 11990 because implementation of the proposed Hunt Rivers and Harbors Act of 1899, as amended, 33 Plan would protect existing wetlands. U.S.C. 401 et seq.; 33 CFR Parts 114, 115, 116, 321, 322, and 333 The proposed action is consistent with Executive Order 11988, because Safe Drinking Water Act of 1974, 42 U.S.C. 300f implementation of the proposed Hunt et seq.; 40 CFR Parts 141-148 Plan would not result in the modification or destruction of floodplains. Executive Order 11988 – Floodplain Management, 42 Fed. Reg. 26951 (1977)

Executive Order 11990 – Protection of Wetlands, 42 Fed. Reg. 26961 (1977)

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Appendix B. Draft Compatibility Determination

SAVANNAH NWR DRAFT COMPATIBILITY DETERMINATION

Use: Hunting of American Alligator, Armadillo, Beaver, Opossum, and Raccoon

Refuge Name: Savannah National Wildlife Refuge

Date Established: April 6, 1927

Establishing and Acquisition Authority: Savannah National Wildlife Refuge (NWR, refuge) was established by Executive Order 4626 on April 6, 1927, in Jasper County, South Carolina, on 2,352 acres of land owned by the United States near the Savannah River. Numerous other Executive Orders, presidential proclamations, and congressional acts added acreage to the refuge and determined the authority of the U.S. Fish and Wildlife Service (USFWS, Service) to manage these lands.

Refuge Purposes:

“…as a refuge and breeding ground for birds and wild animals subject to future use in navigation if necessary and to valid existing rights if any” (Executive Order 5748, April 6, 1927)

“…for lands acquired under the Migratory Bird Conservation Act “for use as an inviolate sanctuary, or for any other management purpose, for migratory birds” (16 U.S.C. §715d)

“…for lands acquired under the Refuge Recreation Act for “(1) incidental fish and wildlife- oriented recreational development, (2) the protection of natural resources, (3) the conservation of endangered species or threatened species” (16 U.S.C. §460k)

“…for “the conservation of the wetlands of the Nation in order to maintain the public benefits they provide and to help fulfill international obligations contained in various migratory bird treaties and conventions” (16 U.S.C. §3901(b), 100 Stat. 3583, Emergency Wetlands Resources Act of 1968)

“…for the development, advancement, management, conservation, and protection of fish and wildlife resources” (16 U.S.C. §742f(a)(4))

“…for the benefit of the United States Fish and Wildlife Service, in performing its activities and services. Such acceptance may be subject to the terms of any restrictive or affirmative covenant, or condition of servitude” (16 U.S.C. §742f(b)(1), Fish and Wildlife Act of 1956)

National Wildlife Refuge System Mission:

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The mission of the National Wildlife Refuge System (NWRS), as defined by the National Wildlife Refuge System Improvement Act of 1997, is:

...to administer a national network of lands and waters for the conservation, management, and where appropriate, restoration of the fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans.

Description of Use: Hunting of American Alligators, Armadillos, Beavers, Opossum, and Raccoons on the Savannah National Wildlife Refuge

What is the use? The proposed use is the public hunting of American alligator (Alligator mississippiensis), armadillo (Dasypus novemcinctus), beaver (Castor canadensis), opossum (Didelphis virginiana), and raccoon (Procyon lotor) on Savannah NWR as outlined in the Draft Savannah National Wildlife Refuge American Alligator, Armadillo, Raccoon, Opossum, and Beaver Hunt Plan (USFWS 2020a) and analyzed in the accompanying Environmental Assessment (USFWS 2020b). The USFWS considers hunting a priority public use, as stated in the National Wildlife Refuge System (NWRS) Improvement Act of 1997. The existing hunt program for the refuge includes white-tailed deer (Odocoileus virginianus), turkey (Meleagris gallopavo), squirrel (Sciurus carolinensis), rabbit (Sylvilagus floridanus), waterfowl, mourning dove (Zenaida macroura), coyote (Canis latrans), and feral hog (Sus scrofa). This compatibility determination would add to the species hunted on the refuge.

Where is the use conducted? All hunting of American alligators, armadillo, beaver, opossum, and raccoon would occur in the areas delineated on the refuge’s Hunt Map. Alligator hunting would be allowed on the refuge on 11,648 acres in Georgia and South Carolina. Incidental hunting of armadillos, beavers, opossum, and raccoons on the refuge would occur on 15,066 acres in Georgia. Refuge signs and brochures identify hunt areas.

When is the use conducted? Hunting would occur during the general, limited, and quota refuge hunting seasons that fall within State hunting seasons established by the Georgia and South Carolina Departments of Natural Resources. Alligator hunting would be permitted in August, September, and October.

How is the use conducted? The incidental taking of armadillo, beaver, opossum, and raccoon would be permitted during all refuge hunts with firearms and bows legal for those hunts and only in Georgia. All non- quota general and limited public hunts would be open to all hunters who possess appropriate and valid state hunting licenses and a current annual refuge hunt permit ($25 permit fee in 2019). Youth hunters age 15 and under are exempt from this license and permit requirement, but youth hunters must be accompanied by an adult supervisor at all times. There are no check- in/check-out requirements for these hunts. These requirements would also apply to the proposed hunting.

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Why is the use being proposed? Hunting is a priority public use of the NWRS and can be an important recreational activity as well as necessary management tool. The USFWS recognizes hunting as a healthy, traditional outdoor pastime, deeply rooted in American heritage. Hunting can instill a unique understanding and appreciation of wildlife species, their behavior, and their habitat needs. Hunting programs can promote understanding and appreciation of natural resources and their management on lands and waters throughout, not just within the refuge. The Service coordinated with the states of Georgia and South Carolina to better align hunt on Savannah NWR with Georgia and South Carolina hunts, resulting in this proposed compatibility determination.

Availability of Resources: Many of the annual hunt administration costs including salary, equipment, boundary signs, and maintenance are associated with general management of the refuge and are required whether hunting is permitted or not. Printing hunt brochures and conducting other hunt-related administrative activities are the primary costs directly associated with hunting. Total costs are approximately $5,000.00 per year. These costs would be expected to remain unchanged with implementation of the proposed Hunt Plan (USFWS 2020a).

Anticipated Impacts of the Use: The Environmental Assessment for the proposed Hunt Plan analyzed the use and the associated impacts (USFWS 2020b). A summary discussion of the impacts is provided here; no significant impacts would be anticipated.

Disturbance to native wildlife species would be expected to be negligible, although some mortality would be expected to occur in hunted species. During the fall, winter, and early spring months, waterfowl and other migratory birds are concentrated on the managed wetlands, which would be closed to all hunting except for three days of youth waterfowl hunting and two days of deer hunting for mobility impaired hunters. Threatened and endangered species that could potentially be impacted through recreational hunting include the West Indian manatee (Trichechus manatus) and wood stork (Mycteria americana). Manatees occur infrequently in the Savannah River estuary during summer and fall months and would not generally be in the area of the proposed alligator hunts. Wood primarily feed within the managed wetlands during summer and early fall. Impacts from hunting would be minimal and similar to those posed by other recreational users. A refuge requirement that non-toxic shot be used while hunting American alligators, armadillos, beavers, opossum, and raccoons would ensure that deposited shot does not impact wood storks or any other wildlife species.

Refuge personnel would coordinate hunting on the refuge with other compatible non-hunting public uses to minimize conflicts between different user groups. These potential conflicts would be minimized by temporal and spatial separation. The majority of non-hunting public use activities occur within the area of the Laurel Hill Wildlife Drive. This drive meanders through 1,500 acres of actively managed wetlands and offers hiking trails for excellent wildlife viewing opportunities. In addition to the Laurel Hill Wildlife Drive, many non-hunting visitors frequent

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the Tupelo Trail and associated spur trails that lie north of SC 170. Conflicts between hunting and non-hunting users would be unlikely to occur because these trails generally are not within preferred alligator habitat. Additionally, hunting armadillos, beavers, opossum, and raccoons would not be allowed in South Carolina where all the trails are located.

Short-Term and Long-Term Impacts: The Service completed the Comprehensive Conservation Plan (CCP) in 2011 for Savannah NWR (USFWS 2011). The CCP resulted from an all-encompassing public process through which the Service examined past and present management plans and then determined top management priorities to set the course for future management decisions. Within this document, all existing and proposed public uses were evaluated by using the decision process directed by the National Environmental Policy Act (NEPA), including completing an Intra-Service Section 7 Biological Evaluation, Wilderness Review, and a Finding of No Significant Impact. In addition to NEPA guidance, the CCP also included public use reviews, which are required by the NWRS Improvement Act. The Service completed a Finding of Appropriateness of a Refuge Use and Compatibility Determinations for each public use, including hunting, before final approval of all of the proposed refuge uses contained within the 2011 CCP.

The CCP and associated EA for the Savannah Coastal Refuge Complex addressed future management of the refuge and included a recommendation to create additional public hunting opportunities. This CD addresses adding species to the list of those that are currently open to hunting to create more opportunities. The NWRS Administration Act of 1966 as amended by the NWRS Improvement Act of 1997 (Improvement Act) provides authority for the Service to manage the refuge and its wildlife populations. In addition, the Improvement Act declares that compatible wildlife-dependent public uses are legitimate and appropriate uses of the NWRS and that they are to receive priority consideration in planning and management. Hunting is a priority legitimate and appropriate use.

The addition of the hunting of American alligators and incidental species would be anticipated to have very little, if any, adverse impacts. Alligator hunting would be open only on refuge properties north of I-95 and accessible only by boat. The refuge expects the number of alligator hunters to be fewer than 15 individuals with the take of alligators even fewer [Georgia Department of Natural Resources (GADNR) 2010, 2017, 2018, 2019; South Carolina Department of Natural Resources (SCDNR) 2016, 2017, 2019]. The low number of expected individuals may not represent a change given that the navigable waterways within the boundaries of the Savannah NWR already are open to alligator hunting. The navigable waterways open to hunting include the Savannah River in both Georgia and South Carolina and the Abercorn, Little Abercorn, and Big Collis creeks in Georgia. The Middle, Back, and Little Back rivers would remain closed to alligator hunting as these are located south of I-95 and would not being proposed for opening. The Service anticipates that the majority of hunters would remain in the navigable waterways with very few, if any, venturing into the interior tributaries. These tributaries are tidal and extremely difficult to access.

No conflict with other user groups would be expected. The only potential overlap with other hunting seasons would be with the Savannah NWR archery season. Depending on the dates for

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both hunts, the potential overlap may be only up to two weeks. However, habitat types and access would naturally segregate alligator hunters and deer hunters. No conflicts between these user groups would be anticipated (USFWS 2020a, 2020b). In addition, no conflicts between alligator hunters and the non-hunting public would be anticipated. Access to remote interior parts of the refuge would segregate these groups as well. The only potential conflict would be anglers using the navigable waterways and tributaries. Although preliminary reporting to the Banking on Nature 2018 (USFWS, unpublished, preliminary data) shows over 13,000 recreational visits for fishing to the Savannah NWR, the refuge believes these numbers to be hyper-inflated with these counts coming from boat launches off-refuge and anglers using waters off-refuge. No impacts, both short and long-term, would be expected with opening hunting to the incidental species. These species would be taken during open seasons for other species on the refuge. We anticipate roadway mortality would be higher than hunting mortality for these species.

Cumulative Impacts: No beneficial or adverse cumulative impacts would be expected from the proposed hunting. Reports show that less than 6% of the alligators taken in Georgia are along the Savannah River near the Savannah NWR (GADNR 2019). This has been a trend for several years (GADNR 2017, 2018, 2019). A similar trend of low harvest rates along the lower Savannah River also is evident in South Carolina (SCDNR 2016, 2017, 2019).

Only local and short-term impacts would be likely to occur from deer hunting on the refuge and those impacts are generally considered beneficial. Deer harvest on the refuge is estimated at 30- 40 per season (USFWS 2020b). An active deer-hunting program on all areas open to hunting is necessary at Savannah NWR to provide and maintain quality habitat for breeding, migrant, and resident birds. The overall health and welfare of the refuge deer herd is also maintained or improved through an active hunting program. Once a species that was almost extinct in the U.S in the early 1900s, the wild turkey is now numerous and widely distributed due to reintroduction programs, active management, and regulated hunting. Both Georgia and South Carolina have monitored wild turkey populations throughout each state since the 1980s, and have actively restored populations in all historic ranges. The harvest for turkeys is expected to be less than 30 birds. Other hunted species including rabbits, squirrels, migratory birds, coyotes, and feral hogs would be expected to have no impact on or from the additional opening of alligators and incidental species because of differences in habitat requirements, extremely low numbers (e.g., beavers), and temporal separation of open seasons.

Public Review and Comment: The Environmental Assessment; draft Hunt Plan; and draft Hunting of American Alligator, Armadillo, Beaver, Opossum, and Raccoon Compatibility Determination were made available for public review and comment for 30 days. Notice was posted at the Savannah NWR Visitor Center, all refuge kiosks, refuge website ((http://www.fws.gov/refuge/savannah), and refuge Facebook page (http://www.facebook.com/SavannahCoastalRefugesComplex). Further, a public informational bulletin announcing the availability of the documents for public review and comment was provide to the following newspapers: Beaufort Gazette, Bluffton Today, Bryan County News, Connect Savannah, Effingham Herald, Island Packet, Jasper Sun Times,

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Savannah Morning News, and Spirit Newspaper.

Summary of Comments Received: The Service will review all comments submitted in developing a final decision.

Determination:

___ Use is Not Compatible

X Use is Compatible with Following Stipulations

Stipulations Necessary to Ensure Compatibility: The listed stipulations would be implemented and/or maintained to ensure compatibility.

1. This use must be conducted in accordance with State and Federal regulations, and special refuge regulations published in the hunt regulations brochure. Refuge-specific regulations are reviewed annually.

2. The length of hunting seasons can be modified, if needed.

3. This use is subject to modification if on-site monitoring by refuge personnel or other authorized personnel identifies unanticipated adverse impacts, including to natural communities, wildlife species, or habitats.

4. Non-toxic shot is required for hunting of American alligators, armadillo, beaver, opossum, and raccoon on Savannah NWR.

5. Hunting of armadillo, beaver, opossum, and raccoon would not occur in the South Carolina portion of the refuge, which is where all the non-hunting public use trails are located.

Justification: The Refuge Recreation Act of 1962 (16 U.S.C. §460K) authorizes the Secretary of the Interior to administer refuges, hatcheries, and other conservation areas for recreational use. The Refuge Recreation Act requires: 1) that any recreational use permitted will not interfere with the primary purpose for which the area was established and 2) that funds are available for the development, operation, and maintenance of the permitted forms of recreation.

Fundamental to the management of lands within the NWRS is the NWRS Improvement Act of 1997 (Public Law 105-57), an amendment to the NWRS Administration Act of 1966. The NWRS Improvement Act of 1997 provides a mission for the NWRS and clear standards for its management, use, planning, and growth. The NWRS Improvement Act of 1997 recognized that wildlife-dependent recreational uses, including hunting, fishing, wildlife observation and

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photography, and environmental education and interpretation, can be allowed when determined to be compatible with the mission of the NWRS and purposes of the refuge. These top six compatible wildlife-dependent recreational uses (known as the “Big 6”) are the priority general public uses of the NWRS and shall receive priority consideration in planning and management over other uses. Hunting is a Big 6 wildlife-dependent recreational use and the law states that as such, it “shall receive priority consideration in National Wildlife Refuge planning and management.” The Secretary of Interior may then permit hunting on a refuge if it is determined that the use is compatible and does not materially interfere with the primary purpose for which Savannah NWR was established. The final words of the USFWS mission statement, “for the continuing benefit of the American people”, will depend on continued public support, including both hunters and non-hunters. The Service will continue to provide opportunities for all who are interested in quality wildlife-oriented recreation. Allowing this use would help further the mission of the NWRS by providing renewable resources for the benefit of the American public, while conserving fish, wildlife, and plant resources on Savannah NWR.

The proposed hunt plan and compatibility determination would support the CCP for the refuge, notably implementing Objective 3.6.d (Savannah NWR – Hunting: Over the 15-year life of this CCP, maintain, and where possible, expand current hunting opportunities). The proposal would also support refuge management objectives 1.5.d and 2.11.d (Other Fish, Wildlife, and Plants), 2.12.d (Invasive Species), 2.13.d (Wildlife Disease), 4.3.d (Law Enforcement). (USFWS 2011)

The Service's policy is to provide opportunities for wildlife-oriented recreation when compatible and consistent with refuge purposes and the NWRS mission. The stipulations outlined above would help ensure that the use continues to be compatible at Savannah NWR. Hunting, as outline in this compatibility determination, would not conflict with the national policy to maintain the biological diversity, integrity, and environmental health of the refuge. Based on available science and best professional judgement, the Service has determined that hunting at Savannah NWR, in accordance with the stipulations provided here, would not materially interfere with or detract from the fulfillment of the NWRS mission or the purposes of the refuge.

NEPA Compliance for Refuge Use Description:

___ Categorical Exclusion without Environmental Action Statement

___ Categorical Exclusion and Environmental Action Statement

X Environmental Assessment and Finding of No Significant Impact

___ Environmental Impact Statement and Record of Decision

Literature Cited:

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Georgia Department of Natural Resources. 2019. Georgia Alligator Hunting Season Summary 2019 (Preliminary Report 11/4/2019). https://georgiawildlife.com/sites/default/files/wrd/pdf/harvest- summaries/alligator/Alligator%20Harvest%20Summary%202019.pdf

Georgia Department of Natural Resources. 2018. Georgia Alligator Hunting Season Report 2018. https://georgiawildlife.com/sites/default/files/wrd/pdf/harvest- summaries/alligator/Alligator%20Harvest%20Summary%202018.pdf

Georgia Department of Natural Resources. 2017. Annual Performance Report: Alligator Harvest and Hunt Data in Georgia. July 1, 2017 – June 30, 2018. 12pp.

Georgia Department of Natural Resources. 2010. Georgia's Alligator Management Plan. Game Management Section Alligator Committee. 35 pp.

South Carolina Department of Natural Resources. 2019. South Carolina Alligator Hunting Guide for 2019. F&AP Publication 19-02. 26 pp.

South Carolina Department of Natural Resources. 2017. Alligator Hunting Season Report 2017. F&AP Report 18-01. 19 pp.

South Carolina Department of Natural Resources. 2016. Alligator Hunting Season Report 2016. F&AP Report 16-05. 19 pp.

U.S. Fish and Wildlife Service. 2020a. Draft Savannah National Wildlife Refuge American Alligator, Armadillo, Beaver, Opossum, and Raccoon Hunt Plan. March 2020. Hardeeville, SC. 13 pp.

U.S. Fish and Wildlife Service. 2020b. Environmental Assessment for American Alligator, Armadillo, Beaver, Opossum, and Raccoon Hunt Plan for Savannah National Wildlife Refuge. March 2020. Hardeeville, SC. 46 pp.

U.S. Fish and Wildlife Service. 2011. Savannah Coastal Refuges Complex Comprehensive Conservation Plan. Department of the Interior, Fish and Wildlife Service, Southeast Regional Office, Atlanta, Georgia.

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Approval of Compatibility Determination

Refuge Manager/Project Leader ______Savannah NWR Signature Date

Refuge Supervisor ______Area III, Southeast Region Signature Date

Regional Compatibility ______Coordinator, Southeast Region Signature Date

David Viker, ______Regional Refuge Chief Signature Date National Wildlife Refuge System Southeast Region

Mandatory 15-year Re-evaluation Date: ______

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Appendix C. Section 7

SOUTHEAST REGION INTRA-SERVICE SECTION 7 BIOLOGICAL EVALUATION FORM [Federally endangered, threatened, and candidate species]

Originating Person: Chuck Hayes, Savannah Coastal Refuges Complex Telephone Number: 912.210.7366 E-Mail: [email protected] Date: 10/24/2019

PROJECT NAME: Savannah National Wildlife Refuge: American Alligator, Armadillo, Raccoon, Opossum, and Beaver Hunt Plan

I. Service Program: Self-explanatory ___ Ecological Services ___ Federal Aid ___ Clean Vessel Act ___ Coastal Wetlands ___ Endangered Species Section 6 ___ Partners for Fish and Wildlife ___ Sport Fish Restoration ___ Wildlife Restoration ___ Fisheries _X_ Refuges/Wildlife

II. State/Agency: Georgia and South Carolina, U.S. Fish and Wildlife Service

III. Station Name: Savannah National Wildlife Refuge

IV. Description of Proposed Action (attach additional pages as needed): The proposed action would allow implementation of the 2019 Hunt Plan which would 1) open selected areas on the Savannah NWR for limited hunting of American alligator; 2) add additional species for harvest that includes armadillo, beaver, opossum, and raccoon.

The Refuge hunting season framework would generally fall within the South Carolina Department of Natural Resources and Georgia Department of Natural Resources guidelines but in various instances would be more conservative than state seasons and regulations. Refuge management and objectives may require occasional modifications to the hunting program based on harvest data, public use demands, and other Refuge programs. Use of quota hunts for special management purposes may be necessary to meet Refuge specific objectives. All or parts of the Refuge may be closed to hunting by the Refuge Manager at any time, if necessary for public safety, to provide wildlife sanctuary for trust species, or for essential management actions.

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V. Pertinent Species and Habitat:

A. Include species/habitat occurrence map: See Attachments 1 & 2.

B. Complete the following table:

SPECIES/CRITICAL HABITAT STATUS1 Wood Stork (Mycteria Americana) T West Indian Manatee (Trichechus manatus) E

1STATUS: E=endangered, T=threatened, PE=proposed endangered, PT=proposed threatened, CH=critical habitat, PCH=proposed critical habitat, C=candidate species

VI. Location (attach map):

A. Ecoregion Number and Name: 75i (Floodplains and Low Terraces) and 75j (Sea Islands/Coastal Marsh)

B. County and State: Chatham and Effingham Counties, Georgia. Jasper County, South Carolina.

C. Section, township, and range (or latitude and longitude): All sites within Refuge boundary. 32o12’54”N -81o07’50”W

D. Distance (miles) and direction to nearest town: Port Wentworth, GA - <3 miles.

E. Species/habitat occurrence:

Wood storks do not currently nest on the Refuge. They use refuge lands for foraging and loafing during the breeding season.

West Indian Manatees are occasionally found in the Savannah River, Middle River, and Little Back River as well as sometimes in the canals adjacent to the impoundments on the Refuge. Sightings are very rare.

VII. Determination of Effects:

A. Explanation of effects of the action on species and critical habitats in item V. B (attach additional pages as needed):

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SPECIES/ IMPACTS TO SPECIES/CRITICAL HABITAT CRITICAL HABITAT Wood Stork (Mycteria None expected Americana) West Indian Manatee None expected (Trichechus manatus)

B. Explanation of actions to be implemented to reduce adverse effects:

SPECIES/ ACTIONS TO MINIMIZE IMPACTS CRITICAL HABITAT Wood Stork (Mycteria Methods used to hunt alligators will preclude taking of wood americana) storks. Although wood storks may use areas open to alligator hunters, very few have been observed foraging or loafing in areas where alligator hunting will occur. Additionally, for armadillo, beaver, opossum, and raccoon, most hunting will occur during months of the year when wood storks are not present. Hunting at times of the year when wood storks are present generally will not be in wetland areas. Hunters are required to use non-toxic shot when hunting small game, turkey, and migratory birds to negate lead poisoning. West Indian Manatee The open waters of the refuge (i.e. navigable waters) already are (Trichechus manatus) open to alligator hunting. Areas where manatees are usually observed on the refuge will continue to be closed to alligator hunting. Hunters accessing hunt areas in the fall by boat will be advised to watch for manages to minimize the potential for boat motor strikes.

VIII. Effect Determination and Response Requested:

SPECIES/ DETERMINATION1 RESPONSE1 CRITICAL HABITAT NE NA AA REQUESTED Wood Stork (Mycteria americana) NA Concurrence West Indian Manatee (Trichechus NA Concurrence manatus) 1DETERMINATION/ RESPONSE REQUESTED: NE = no effect. This determination is appropriate when the proposed action will not directly, indirectly, or cumulatively impact, either positively or negatively, any listed, proposed, candidate species or designated/proposed critical habitat. Response Requested is optional but a AConcurrence@ is recommended for a complete Administrative Record.

NA = not likely to adversely affect. This determination is appropriate when the proposed action is not likely to adversely impact any listed, proposed, candidate species or designated/proposed critical habitat or there may be beneficial effects to these resources. Response Requested is a@Concurrence@.

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AA = likely to adversely affect. This determination is appropriate when the proposed action is likely to adversely impact any listed, proposed, candidate species or designated/proposed critical habitat. Response Requested for listed species is AFormal Consultation@. Response requested for proposed and candidate species is AConference@.

Enter the Species, the Determination, and the Response Requested.

No effect/no adverse modification. For listed, proposed, or candidate species. Make this conclusion if the proposed action and its interrelated and interdependent actions will not directly or indirectly affect listed species or destroy/adversely modify designated critical habitat. Response Requested action would be the optional written concurrence is encouraged to facilitate a complete administrative record.

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May Affect, but is not likely to adversely affect species/adversely modify critical habitat. This conclusion is appropriate when effects to the species or critical habitat will be beneficial, discountable, or insignificant. Beneficial effects are contemporaneous positive effects without any adverse effects to the species or habitat. Insignificant effects relate to the size of the impact (and should never reach the scale where take occurs), while discountable effects are those that are extremely unlikely to occur. Based on best judgment, a person would not: (1) be able to meaningfully measure, detect, or evaluate insignificant effects; or (2) expect discountable effects to occur. If the Ecological Services Office concurs in writing with the Project Leader's determination of "is not likely to adversely affect" listed species or critical habitat, the intra-Service section 7 consultation process is completed.

May affect, and is likely to adversely affect species/adversely modify critical habitat. This conclusion is reached if any adverse effect to listed species or critical habitat may occur as a direct or indirect result of the proposed Service action or its interrelated or interdependent actions, and the effect is not discountable or insignificant (see definition of "is not likely to adversely affect". In the event the overall effect of the proposed action is beneficial to the listed species or critical habitat, but may also cause some adverse effect on individuals of the listed species or segments of the critical habitat, then the determination should be "is likely to adversely affect." Such a determination requires formal section 7 consultation.

Example: A refuge proposes prescribed burning for a prairie remnant to improve the habitat for the endangered Karner blue butterfly. The burn will substantially improve the habitat for the species and promote its recovery in subsequent years. However, individual Karner blue butterfly eggs and larvae will be killed during the burn. Even though the net effect of the burn will be highly beneficial to the listed species, the burn must be considered to have an adverse effect. A finding of "is likely to adversely affect" is necessary.

Is likely to jeopardize proposed species/adversely modify proposed critical habitat. For proposed species and proposed critical habitats, the Service is required to evaluate whether the proposed Service action is likely to jeopardize the continued existence of the proposed species or adversely modify an area proposed for designation as critical habitat. If you reach this conclusion, a section 7 conference is required. If you reach this conclusion, intra-Service conference is required.

Is likely to jeopardize candidate species. For candidate species, the Service is required to evaluate whether the proposed Service action is likely to jeopardize the continued existence of the candidate species. If this conclusion is reached, intra-Service section 7 conference is required.

______Signature (originating station) date

Supervisory Wildlife Biologist Title

Insert the following two paragraphs for actions that require a “concurrence.” This analysis resulted in a determination that no “take” of a federally listed species would occur. If any of the following occur, then there must be reinitiation on this action: (1) any incidental take occurs (2) new information reveals effects of the Service’s action that may affect listed species or critical habitat in a manner or to an extent not considered in this opinion; (3) the Service’s action is later modified in a manner that causes an effect to the listed species or critical habitat not considered in this opinion; or (4) a new species is listed or critical habitat designated that may be affected by the action.

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In instances where any incidental take occurs, the operations causing such take must cease until reinitiation.

IX. Reviewing Ecological Services Office Evaluation:

A. Concurrence ______Nonconcurrence ______

B. Formal consultation required ______

C. Conference required ______

D. Informal conference required ______

E. Remarks (attach additional pages as needed):

______Signature date ______Title office

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