United States Forest National Forests in North Carolina 160 ZILLICOA ST STE A Department of Service Supervisor’s Office ASHEVILLE NC 28801-1082 Agriculture 828-257-4200

File Code: 1950-2 Date: February 24, 2009

Dear Interested Parties:

The Decision Notice for the Nantahala and Pisgah National Forests Non-Native Invasive Plant Environmental Assessment (EA) was signed on February 23, 2009. I have chosen to implement Alternative 3 of the EA. The selected alternative proposes up to 1,100 acres of non-native invasive plant treatment across the Nantahala and Pisgah National Forests. Treatments will include an integrated combination of herbicide, manual, mechanical, and fire methods to treat identified infestations.

A copy of the Decision Notice (DN) and Finding of No Significant Impact (FONSI) is enclosed. The DN and FONSI discuss the decision in detail and rationale for reaching that decision. I am also enclosing a copy of the Environmental Assessment for this project.

This decision is subject to appeal pursuant to 36 CFR 215.11. A written appeal, including attachments, must be postmarked or received within 45 days after the date this notice is published in The Asheville Citizens Times. The Appeal shall be sent to USDA, Forest Service, ATTN: Appeals Deciding Officer, 1720 Peachtree Rd, N.W., Suite 811N, Atlanta, Georgia 30309-9102. Appeals may be faxed to (540) 265-5145. Hand-delivered appeals must be received within normal business hours of 8:00 a.m. to 4:30 p.m. Appeals may also be mailed electronically in a common digital format to [email protected]

Appeals must meet content requirements of 36 CFR 215.14. For further information on this decision, contact Gary Kauffman, Forest Botanist, at 828-257-4861.

If no appeal is received, implementation of this decision may occur on, but not before, five business days from the close of the appeal filing period. If an appeal is received, implementation may not occur for 15 business days following the date of appeal disposition. (36 CFR 215.9). Thank you for your continued interest in management of the Nantahala and Pisgah National Forests.

Sincerely,

/s/ Marisue Hilliard

MARISUE HILLIARD Forest Supervisor

Enclosures

Caring for the Land and Serving People Printed on Recycled Paper Decision Notice, Finding of No Significant Impact & Project-Specific, United States Non-Significant Forest Plan Department of Agriculture Amendment #23 Forest Service

February 2009 Nantahala and Pisgah National Forest Non-Native Invasive Plant Control

Nantahala National Forest: Graham, Swain, Jackson, Macon, Cherokee, and Clay Counties, North Carolina

Pisgah National Forest: Haywood, Madison, Avery, Burke, Caldwell, McDowell, Buncombe, Henderson, Mitchell, Transylvania, and Yancey Counties, North Carolina Nantahala and Pisgah National Forests Non-Native Invasive Plant Control

Decision Notice, Finding of No Significant Impact, & Non-Significant Forest Plan Amendment #23 Nantahala and Pisgah National Forests Non-Native Invasive Plant Control USDA Forest Service Nantahala and Pisgah National Forests, North Carolina

Decision and Rationale for with a string trimmer, chainsaw, brush blade, the Decision or mower. = Use of a propane weed torch to spot-burn Decision targeted invasive plants. The weed torch Based upon my review of the alternatives, I have works not by starting a ground fire but by decided to select Alternative 3 of the Non- using the torch’s flame to burn the target Native Invasive Plant Environmental Assessment plant. The weed torch would only be used (EA) on the Nantahala and Pisgah National during times of low fire danger. Its use would Forests (NPNFs). The Selected Alternative primarily be within plant communities that includes: have a low potential to carry fire, such as Southern Appalachian bogs or rich cove = Annual treatment of up to 1,100 acres of forest communities. non-native invasive plants (NNIPs) using an = integrated combination of manual, Amendment to the Forest Plan (see Forest mechanical, cultural, and chemical control Plan Consistency below). treatment methods. Rationale = Use of herbicides to control NNIP One of the goals of the Nantahala and Pisgah infestations where manual or mechanical Land and Resource Management Plan (Forest means would be cost-prohibitive or result in Plan) is to maintain and enhance the diversity of excessive soil disturbance or other resource plant and animal communities of the Southern damage. All herbicides would be used Appalachians, favoring plant and animal according to manufacturer’s label direction communities that warrant special attention for rates, concentrations, exposure times, and (Forest Plan Amendment 5 p. III-1). Given the application methods. Herbicides would be current distribution of NNIP infestation sites on directly applied to the target plants (i.e., the the NPNFs, there is a need to implement a NNIP species) using spot treatment. comprehensive and integrated program of NNIP Techniques that could be used include control to protect the integrity of natural plant spraying foliage using a hand-held wand or communities. backpack sprayer, basal bark and stem I selected Alternative 3 because it accomplishes treatments using spraying or painting these objectives and meets the purpose and need (wiping) methods, cut surface treatments for action. (spraying or wiping), and woody stem injections. Other Alternatives Considered = Manual or mechanical methods to control small spot infestations. Examples of hand In addition to the Selected Alternative, I tools that might be used include shovels, considered two other alternatives in detail: saws, axes, loppers, hoes, or weed-wrenches. Alternative 1 – Proposed Action and Alternative Mechanical methods could include cutting 2 – No Action. A comparison of these

Decision Notice and FONSI 2 Nantahala and Pisgah National Forests Non-Native Invasive Plant Control alternatives can be found in Section 2.4 of the project to cover more of the Nantahala National EA. Forest. Alternative 1 Finding of No Significant Impact Alternative 1 was similar to the selected alternative, except that it failed to After considering the environmental effects comprehensively address NNIPs on the described in the EA, I have determined that Nantahala National Forest and proposed up to these actions will not have a significant effect on 550 acres annually. The most consistent the quality of the human environment comment that was received on the proposed considering the context and intensity of impacts action was that it did not include treatment of (40 CFR 1508.27). Thus, an environmental NNIPs on the Nantahala National Forest. Many impact statement will not be prepared. I base my of the design features and treatment protocols finding on the following: from this alternative were carried forward in 1. The action will not violate Federal, State, and Alternative 3. local laws or requirements for the protection Alternative 2 – No Action of the environment. Applicable laws and regulations were considered in the EA. The Under Alternative 2, current management plans action with its project-specific Forest Plan would continue to guide management of the amendment is consistent with the Nantahala project area. This alternative was not selected and Pisgah National Forests Land and because it would not respond to the immediate Resource Management Plan (Forest Plan) threat that NNIPs pose to our native forest (EA, Section 1.1.1 and 1.6). ecosystem. 2. The actions of this project are consistent In addition, populations of T&E and rare species with the Forest Plan because mitigation on the NPNFs are at risk of being locally measures for impacts have been fully applied extirpated by NNIPs if they are left untreated in in the planned actions. The project is feasible this alternative. and reasonable, and will result in applying Other Alternatives Considered but Eliminated from management practices that meet the Forest Detailed Study Plan overall direction of protecting the environment while producing goods and Section 2.5 of the EA addressed a non-herbicide services. alternative that was considered but eliminated from detailed study. Since this alternative was 3. There will be no significant effects on public not considered in detail in the EA, it was not health and safety (EA, Section 3.4.3). considered in the range of alternatives for my 4. The actions will not have any detrimental decision. effects on any unique characteristics of the area such as park lands, prime farmlands, Public Involvement wetlands, wild and scenic rivers, or ecologically critical areas in the project area. The proposal was first listed in the Schedule of It may have positive effects in maintaining Proposed Actions on April 1, 2007. A scoping ecologically or culturally important areas in letter explaining the project proposal was mailed their current condition. (EA, Chapter 3). to 90 interested and affected parties on January 30, 2007. In addition, a legal notice for public 5. Based on public involvement and analyses, comment was published in the Asheville Citizen the effects on the quality of the human Times on February 2, 2007. Comments were environment are not likely to be highly received from ten individuals and organizations. controversial (EA, Chapter 3). Alternative 3 was developed in response to public comments that asked for expansion of the

Decision Notice and FONSI 3 Nantahala and Pisgah National Forests Non-Native Invasive Plant Control

6. The actions do not involve highly uncertain, NNIPs are already within or immediately unique, or unknown environmental risks to adjacent to these habitats and individual PETS. the human environment. (EA, Chapter 3). We could not meet the objective of protecting these plants and habitats without treating NNIPs 7. The action is not likely to establish a inside of the 60-foot buffer. Amendment 23 precedent for future actions with significant would allow this. effects, because the project is site specific and effects are expected to remain localized and short-term (EA, Chapter 3). Determination That Project-Specific, Forest Plan Amendment #23 Is Not 8. The cumulative effects of the proposed actions have been analyzed and no significant Significant Under NFMA effects are anticipated (EA, Chapter 3). I have determined this amendment is not a 9. The action will have no effect on districts, significant amendment under the National Forest sites, highways, structures, or objects listed in Management Act (NFMA) implementing or eligible for listing in the National Register regulations [36 CFR 219.10(f)]. In reaching this of Historic Places (EA, Section 1.6). The conclusion, I considered the following factors action will also not cause loss or destruction from Forest Service Handbook 1909.12, section of significant scientific, cultural, or historical 5.32, Process to Amend a Forest Plan. resources (EA, Section 3.4.2). Timing 10. The actions of this project have met all A change is less likely to result in a significant requirements of the Endangered Species Act plan amendment if the change is likely to take and all agreements with the State Natural place after the plan period (first decade). The Heritage Program. The impacts to Proposed, Forest Plan last had a significant amendment in Endangered, Threatened, or Sensitive species 1995 and this plan amendment (Amendment (PETS) or critical habitat for these species #23) will be implemented beginning in 2009. are minor in scope and will not affect the population viability of any PETS species. Location and Size 11. My conclusion is based on a review of the The smaller the area affected, the less likely the record that shows a thorough review of change is to be a significant change to the Forest relevant scientific information, a Plan. The Selected Alternative will require an consideration of responsible opposing views, amendment to allow spraying herbicide and the acknowledgment of incomplete or immediately adjacent to non-target vegetation, unavailable information, scientific including PETS. This has a potential to be at a uncertainty, and risk. very maximum 1,100 acres annually. This amounts to less than one tenth of one percent of Forest Plan Consistency the total Nantahala and Pisgah National Forest land. Project-Specific Forest Plan Amendment #23 Goals, Objectives, and Outputs My decision to implement the Selected An action is more likely to be a significant Forest Alternative includes a Project-Specific Forest Plan amendment if it alters the long-term Plan amendment (EA, Section 1.3). This relationship between levels of goods and services amendment is needed to accomplish the projected by the Forest Plan and particularly if it objectives of the proposed action, specifically the will forego the opportunity to achieve an output need to protect rare, sensitive habitats and in later years. Amendment 23 is part of my threatened, endangered, proposed, or sensitive decision to allow manual, mechanical, cultural plants (PETS) from NNIPs. The Forest Plan and chemical treatment of NNIPs. The proper calls for no herbicide use within a 60-foot buffer implementation of mitigation measures will around PETS. Due to the current conditions, ensure that PETS are protected from herbicide

Decision Notice and FONSI 4 Nantahala and Pisgah National Forests Non-Native Invasive Plant Control drift, manual disturbances, and fire treatments of this legal notice. Appeals may be faxed to (EA, Section 2.3). In fact, in areas where (404) 347-5401. Hand-delivered appeals must be populations of PETS are being encroached upon received within normal business hours of 8:00 by NNIPs, the successful treatment of NNIPs is a.m. to 4:30 p.m. Appeals may also be mailed essential to their persistence. electronically in a common digital format to: Management Prescription [email protected] A change is more likely to require a significant Those who meet requirements of 36 CFR 215.11 amendment if it will apply to future decisions may appeal this decision. Appeals must meet throughout the planning area. Amendment 23 is content requirements of 36 CFR 215.14. For just for this project. The changes should not further information on this decision, contact affect future actions. Thus, the lack of change of Gary Kauffman, Forest Botanist, 160 A Zillicoa prescription beyond this project indicates non- Street, Asheville, North Carolina 28801, Phone: significance for the amendment. 828-257-4861; or Heather Luczak, Assistant Forest Planner, 160 A Zillicoa Street, Asheville, Administrative Review and Contacts North Carolina 28801, Phone: 828-257-4817. This decision is subject to appeal pursuant to 36 Implementation Date CFR 215.11. A written appeal, including attachments, must be postmarked or received As per 36 CFR 215.9, if no appeal is received, within 45 days after the date the legal notice is implementation of this decision may occur on, published in The Asheville Citizen-Times. The but not before, the 5th business day following the appeal shall be sent to USDA, Forest Service, close of the appeal-filing period (215.15). When ATTN: Appeals Deciding Officer, 1720 an appeal is filed, implementation may occur on, Peachtree Rd, N.W., Suite 811 N, Atlanta, but not before the 15th business day following the Georgia 30309-9102, within 45 days of the date date of appeal disposition (36 CFR 215.2).

_/s/ Marisue Hilliard______February 23,2009______Marisue Hilliard Date Forest Supervisor National Forests in North Carolina

Decision Notice and FONSI 5 United States Department of Environmental Agriculture

Forest Assessment Service February 2009 Nantahala and Pisgah National Forests Non-Native Invasive Plant Control

Nantahala National Forest: Graham, Swain, Jackson, Macon, Cherokee, and Clay Counties, North Carolina

Pisgah National Forest: Haywood, Madison, Avery, Burke, Caldwell, McDowell, Buncombe, Henderson, Mitchell, Transylvania, and Yancey Counties, North Carolina

Responsible Official Marisue Hilliard Forest Supervisor National Forests in North Carolina

For Information Contact: Gary Kauffman 160 A Zillicoa Street, Asheville, NC 828-257-4200

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contract USDA’s TARGET Center at 202-720-2600 (voice and TDD). To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call 800-795-3272 (voice) or 202-720-6382 (TDD). Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Table of Contents Summary ...... 1 Chapter 1 – Purpose and Need ...... 1 1.1 DOCUMENT STRUCTURE ...... 1 1.1.1 Project Record ...... 2 1.1 PURPOSE & NEED FOR ACTION...... 2 1.2 PROPOSED ACTION ...... 4 1.3 PROJECT-SPECIFIC FOREST PLAN AMENDMENT...... 7 1.4 DECISION TO BE MADE ...... 7 1.5 PUBLIC INVOLVEMENT...... 7 1.6 ISSUE IDENTIFICATION...... 8 Chapter 2 Alternatives...... 9 2.1 ALTERNATIVES...... 9 2.2 MONITORING ...... 9 2.3 MITIGATION MEASURES...... 10 2.4 COMPARISON OF ALTERNATIVES...... 11 2.5 ALTERNATIVES NOT CONSIDERED IN DETAIL ...... 12 Chapter 3 – Affected Environment and Environmental Consequences ...... 13 3.1 INTRODUCTION...... 13 3.2 PHYSICAL ENVIRONMENT ...... 13 3.2.1 Air Quality...... 13 3.2.2 Soils and Hydrology ...... 14 3.3 BIOLOGICAL RESOURCES...... 15 3.3.1 Vegetation...... 15 3.3.2 Wildlife and Management Indicator Species...... 23 3.3.3 Threatened, Endangered, and Sensitive Species – Wildlife...... 29 3.3.4 Threatened, Endangered, and Sensitive Species – Aquatics...... 36 3.3.5 Threatened, Endangered, and Sensitive Species – Botanical...... 39 3.4 SOCIAL RESOURCES ...... 41 3.4.1 Recreation and Scenery ...... 41 3.4.2 Cultural Resources...... 43 3.4.3 Human Health and Safety...... 43 3.4.4 Socio-economics...... 44 3.4.5 Environmental Justice...... 44 Chapter 4 List of preparers and References...... 44

Appendices Appendix A: Descriptions of common species and associated treatment methods Appendix B: Soil activity of proposed herbicides Appendix C: Nantahala and Pisgah National Forests Non-Native Invasive Plant Control, Comment Analysis Appendix D: Implementation Checklist for the Treatment of NNIP Species Appendix E: Rare Aquatic Species Appendix F: Rare plant species Appendix G: Biological Assessment

Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Summary

The Nantahala and Pisgah National Forests (NPNFs) are proposing a multi-year project to control infestations of non-native invasive plants on the NPNFs. The project area is located in western North Carolina and includes infested areas across the NPNFs. This action is needed because invasive species have been identified by the Forest Service as one of four principal threats to the nation’s forests and grasslands. Without intervention, weed infestations will continue to expand exponentially and impacts to environmental and social resources will intensify annually. The proposed action that was jointly scoped and issued for 30-day Notice and Comment in 2007, includes manual, mechanical, cultural and chemical treatments on the Pisgah National Forest and limited sites on the Nantahala National Forest. In response to both internal and public comments, an alternative that includes sites across the Nantahala National Forest was developed and is analyzed in this environmental assessment.

Chapter 1 – Purpose and Need ______

1.1 DOCUMENT STRUCTURE

The Forest Service has prepared this Environmental Assessment (EA) in compliance with the National Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. This EA discloses direct, indirect, and cumulative environmental effects that would result from the proposed action and alternatives. The document is organized into five parts: Z Chapter 1 – Purpose and Need: This section includes information on the history of the project proposal, the purposed of and need for the project, and the agency’s proposal for achieving that purpose and need. This section also details how the Forest Service informed the public of the proposal. Z Chapter 2 – Alternatives: This section provides a detailed description of alternative methods fro achieving the stated purpose as well as the no-action alternative. These alternatives were developed based on significant issues raised by the public and other agencies. This discussion also includes a project mitigation measures and a summary of the environmental consequences associated with each alternative. Z Chapter 3 – Affected Environment and Environmental Consequences: This section describes the environmental effects of implementing the proposed action and other alternatives. Within each section, the affected environment is described first, followed by the effects of the proposed actions on the individual resources. Z Chapter 4 – Preparers and References: This section provides a list of preparers and literature that was used to support this analysis. Z Appendices: The appendices provide more detailed information to support the analyses presented in the EA.

1 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

1.1.1 Project Record This EA tiers (40 CFR 1502.20) to the Final Environmental Impact Statement (FEIS) for the Nantahala and Pisgah National Forest Plan. This EA also incorporates by reference (40 CFR 1502.21) the project record. The project record contains technical documentation used to support the analysis and conclusions in this EA. This EA incorporates by reference the Nantahala and Pisgah Management Indicator Species (MIS) Report. This report along with the Monitoring and Evaluation Reports for the National Forests in North Carolina contains the most current information about forest population trends for MIS species.

1.1 PURPOSE & NEED FOR ACTION

The Chief of the U.S. Forest Service (USFS) has identified non-native invasive species as one of the four critical threats to USFS ecosystems. In the United States, invasive species are reported to be the second-most critical threat to conservation of biodiversity (Wilcove et al. 1998). Non- native plants are known to occur across Southern Appalachian forests, accounting for 15-20% of the documented flora. While not all non-native species are known to disrupt native ecosystems, of particular concern are those that are successful at invading and rapidly spreading through natural habitats. As defined in Executive Order 13112 issued February 3, 1999, an invasive species is one that meets the following two criteria: “1) it is nonnative to the ecosystem under consideration and, 2) its introduction causes or is likely to cause economic or environmental harm or harm to human health.” The purpose of this project is to protect native populations of plants and animals through the timely treatment of non-native invasive plant (NNIP) infestations and to prevent or reduce the spread of NNIP infestations to high quality natural habitats. One of the goals of the Nantahala and Pisgah Land and Resource Management Plan (Forest Plan) is to maintain and enhance the diversity of plant and animal communities of the Southern Appalachians, favoring plant and animal communities that warrant special attention (Forest Plan Amendment 5 p. III-1). Given the current distribution of NNIP infestation sites on the NPNFs, there is a need to implement a comprehensive and integrated program of NNIP control to protect the integrity of natural plant communities. The integrity of natural communities on the NPNFs will be compromised if NNIP infestations are allowed to continue to spread and invade previously unaffected areas. In addition, management of NNIP infestations sites will help slow the spread of NNIPs in the Southern Appalachians by minimizing the degree to which the NPNFs are a source of infestations for surrounding lands, both public and private. To fulfill the goals of Executive Order 13112, this invasive treatment proposal is intended to be adaptive in nature and allow the use of integrated methods for the future treatment of invasive plant infestations.

A list of the high priority invasive plant species across the Nantahala and Pisgah National Forests has been developed from both botanical surveys completed during the past 15 years and NNIP inventories that were conducted in 2002-2003 across selected watersheds (Table 1.1). Thousands of acres are known to have some outbreaks of these 17 species; however, the exact infested acreage within the NPNFs is unknown and changes annually. Most of the 17 species identified in Table 1.1 are prevalent across the region and are continuing to spread, actively impacting biodiversity. NNIP inventories conducted in 2002-2003 recorded spot occurrences of one or more of the 17 species on over 70% of plots along roadsides. These species were assigned a

2 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control relative priority for treatment based on their known impacts on rare species and communities, their ability to rapidly spread, and their ability to persist in the forest. These species have been identified as the highest priority species on the NPNFs at the present time but the list will be updated as needed, based on new information regarding species’ spread and infestation characteristics.

Table 1.1 Priority non-native invasive plant species on the NPNFs.

Scientific Name Common Name Priority Treatment Celastrus orbiculatus Oriental bittersweet High Paulownia tomentosa Princess tree High Spiraea japonica Japansese meadowsweet High Polygonum cuspidatum Japanese knotweed High Microstegium vimineum Japanese stiltgrass High Ligustrum sinense/vulgare Chinese/European privet High Miscanthus sinensis Chinese silver grass High Rosa multiflora Multiflora rose High Elaeagnus umbellate/pungens Autumn/Thorny olive Medium Lonicera japonica Japanese honeysuckle Medium Alliaria petiolata Garlic mustard Medium Centaurea petiolata Spotted knapweed Medium Tussilago farfara Coltsfoot Medium Albizia julbrissin Silk-tree Medium Ailanthus altissima Tree of heaven Medium Pueraria montana var. lobata Kudzu Medium Dioscorea oppositifolia Chinese yam Medium

The 2002-2003 inventories also identified specific infestation areas where NNIPs are impacting rare species or rare habitats (Table 1.2). These areas are examples of where treatment is a high priority due to the immediate risk to rare native communities.

Table 1.2 High priority treatment areas within the Nantahala & Pisgah National Forests

Approximate Species/Com- NNIP Species to Acreage Ranger District Site munity at Risk Control Needing Treatment Nolichucky Appalachian RD Virginia spiraea Japanese Knotweed 20 Gorge

3 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Approximate Species/Com- NNIP Species to Acreage Ranger District Site munity at Risk Control Needing Treatment Roan Bittersweet, Appalachian RD Grassy bald 20 Mountain Coltsfoot Linville Rim Mountain golden Grandfather RD east of Princess Tree 500 heather Wilderness Pisgah RD Pink Beds Swamp pink Privet 5 Foster Creek Southern Pisgah RD Japanese Stilt Grass 3 Bog Appalachian bog Kudzu, Oriental Cheoah RD Cheoah River Virginia spiraea 10 Bittersweet Buck Creek Serpentine barren Tusquitee RD Serpentine Kudzu 5 community Barrens Whiteoak Nantahala RD Virginia spiraea Japanese Knotweed 5 Creek Nantahala Nantahala RD Noonday Snail Kudzu 10 River Appendix E lists additional areas where infestations have been documented on the NPNFs.

1.2 PROPOSED ACTION

The original proposed action, which was scoped in January 2007, is to treat up to 550 acres of non-native invasive plant (NNIP) infestations across the Pisgah National Forest and within four sites on the Nantahala National Forest, using an integrated combination of manual, mechanical, cultural, and chemical control treatment methods. The treatments would begin in the spring of 2009, and are estimated to occur over a five-year period. Proposed treatments would be implemented on infestation sites on National Forest System lands and would be limited to:  Approximately 300 acres of land-applied, licensed herbicide application per year.  Approximately 200 acres of manual or mechanical treatments per year (such as hand- pulling, hand-cutting, digging, or mowing).  Approximately 50 acres of spot treatments with a propane weed torch per year. Proposed Manual and Mechanical Methods: Manual or mechanical methods would be the principle method for controlling small spot infestations. Examples of hand tools that might be used include shovels, saws, axes, loppers, hoes, or weed-wrenches. Mechanical methods could include cutting with a string trimmer, chainsaw, brush blade, or mower. Proposed Spot Treatments Using Propane Weed Torch: A propane weed torch would be used to spot-burn targeted invasive plants. The weed torch works not by starting a ground fire but by using the torch’s flame to burn the target plant. The weed torch would only be used during times

4 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control of low fire danger. Their use would primarily be within plant communities that have a low potential to carry fire, such as Southern Appalachian bogs or rich cove forest communities. The weed torch is known to be effective with some invasive shrubs but would be tested on other high-priority invasive plants as an alternative to herbicide use. Proposed Chemical (Herbicide) Methods: The objectives of herbicide use would be to control NNIP infestations where manual or mechanical means would be cost-prohibitive or result in excessive soil disturbance or other resource damage. All herbicides would be used according to manufacturer’s label direction for rates, concentrations, exposure times, and application methods. Herbicides would be directly applied to the target plants (i.e., the NNIP species) using selective treatment. Selective treatments would consist of various techniques for applying herbicides to target plants with minimal impact to desirable vegetation and other non-target organisms, including humans. Herbicide drift would be greatly reduced with selective treatments (relative to broad-scale or aerial application). Techniques that could be used include spraying foliage using a hand-held wand or backpack sprayer, basal bark and stem treatments using spraying or painting (wiping) methods, cut surface treatments (spraying or wiping), and woody stem injections. No herbicides would be applied aerially. Only formulations approved for aquatic-use would be applied in or adjacent to wetlands, lakes, and streams, in accordance with label direction.

Treatment Protocol The project proposal is intended to be adaptive in nature and allow the use of integrated methods for the future treatment of invasive plant infestations. The Forest Service understands that treatment options may change as new science is developed and the project will adapt to new scientific research and incorporate future supplements to this EA as needed. Areas identified in Table 1.2 have been identified as high priority areas due to the presence of rare species or communities. Additional areas across the NPNFs will be identified by Forest staff to determine other NNIP infestations to be treated, and which methods would be used, based on the guidelines set forth in this proposal. The determination of treatments would follow the following guidelines: 1. Areas listed in Table 1.2 would receive a high priority for treatment. For these high- priority areas, order of site treatment and methods would be determined by threat to rare species, threat to natural areas, NNIP species biology (including rate of spread), location, practicality of control, and degree of infestation. 2. Additional areas for treatment will be identified by resource specialists based on impacts to rare native communities, impacts to sites of high public interest, the relative localized extent of the infestation, and the opportunity to accomplish treatments through partnerships. 3. Species highlighted in Table 1.1 are the primary targets for treatment, however, additional NNIPs will be considered if they are determined to require treatment at high priority locations. 4. Herbicide use would be used for infestations where manual or mechanical means would be cost-prohibitive or result in excessive soil disturbance or other resource damage. 5. Prior to any treatments, actions covered by this EA would be reviewed by forest resource specialists in the areas of wildlife biology, botany, aquatics, soils, recreation, and heritage resources. A site specific implementation checklist of required reviews (Appendix D)

5 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

would be used to ensure that potential environmental impacts are within the scope of the impacts disclosed in this NEPA document. No treatments would occur in congressionally designated Wilderness areas and Wilderness study areas. Specific herbicides that could be used in the project area are listed below. Detailed descriptions of these chemicals including comprehensive risk assessments for each can be found at: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml (USDA 2007a).  Gyphosate A non-selective, broad spectrum, systemic herbicide that is used to control many grasses, forbs, vines, shrubs, and trees. Specific formulations of glyphosate have been labeled for aquatic application. Formulations labeled for aquatic sites can be effective on both emergent aquatics and shoreline vegetation. This chemical is a growth inhibitor that can be applied through direct foliar application, stem injection, and cut- surface application. It has been proven effective on a wide variety of NNIP species. Commercial brand names include but are not limited to, AccordTM and RodeoTM.  Triclopyr A selective herbicide that controls invasive, broadleaf herbaceous and woody plants, but has little to no effect on grasses. This chemical acts as a growth regulator and can be applied as a direct foliar application, stem injection, or cut-surface treatment. Specific formulations of triclopyr have been labeled for aquatic application. Formulations labeled for aquatic sites can be effective on both emergent aquatics and shoreline vegetation. It has been proven effective on a wide variety of NNIP species. Commercial brand names include but are not limited to, Garlon 3ATM, Garlon 4TM, and Pathfinder IITM.  Clopyralid A selective herbicide affecting broadleaf herbs, primarily legumes, composites, and smartweeds. This chemical acts as a growth regulator and is typically applied as a direct foliar application. With selectivity to legumes, this chemical is particularly useful in the control of kudzu, mimosa, and lespedeza. Commercial brand names include but are not limited to, TranslineTM.  Imazapic A selective herbicide primarily used to control cool season grasses. Warm season grasses, many wildflower species, and legumes are resistant, while many cool season grasses and broadleaf weeds are susceptible. Commercial brand names include but are not limited to, PlateauTM.  Metsulfuron methyl A systemic herbicide that is selective to woody species, broadleaf species, and many annual grasses. It has been proven to be effective in the control of lespedeza, Japanese honeysuckle, kudzu, and multiflora rose. Commercial brand names include but are not limited to, EscortTM.  Dicamba A somewhat selective herbicide that controls most annual and perennial broadleaf herbs and some woody species. Care must be taken as it can damage or kill hardwood and pine seedlings, but has little to no effect on grasses. This chemical is known to be effective in the control of autumn olive. Commercial brand names include but are not limited to VanquishTM and OverdriveTM.

6 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

1.3 PROJECT-SPECIFIC FOREST PLAN AMENDMENT

This proposed action includes a project-specific Forest Plan amendment to the Land and Resource Management Plan for the Nantahala and Pisgah National Forests. The proposed amendment specific to this action would exempt approximately 956,842 acres of national forest land from protocols #80 and #82 of Amendment 2, “Requirements for Vegetation Management in the Appalachian Mountains” (see Appendix I of the Forest Plan Amendment 5). These protocols are: (80) No soil-active herbicide is applied within 30 feet of the drip line of non-target vegetation (e.g., den trees, hardwood inclusions, adjacent stands) within or next to the treated area. Side pruning is allowed, but movement of herbicide to the root systems on non-target plants must be avoided. Buffers are clearly marked before treatment so applicators can easily see and avoid them. (82) No herbicide is aerially applied within 300 feet, nor ground-applied within 60 feet, of any known threatened, endangered, proposed, or sensitive plant. Buffers are clearly marked before treatment so applicators can easily see and avoid them. The acres treated through implementation of this decision will be subject to the following protocol: “When applying herbicide, protect non-target vegetation, especially threatened, endangered, proposed, or sensitive plants by employing a physical barrier between them and the area being treated. The physical barrier must be sufficient to protect the non-target vegetation from herbicide drift and flow.” This amendment is needed to accomplish the objectives of the proposed action, specifically the need to protect rare, sensitive habitats and threatened, endangered, proposed, or sensitive plants (PETS) from NNIP. Due to the current conditions, NNIPs are already within or immediately adjacent to these habitats and individual PETS. We could not meet the objective of protecting these plants and habitats without treating NNIPs inside of the 60-foot buffer.

1.4 DECISION TO BE MADE

Following review of this environmental assessment, a decision will be made on whether the National Forests in North Carolina should implement this proposed action or an alternative approach to control NNIP within the areas proposed across the Nantahala and Pisgah National Forests.

1.5 PUBLIC INVOLVEMENT

The proposal was first listed in the Schedule of Proposed Actions on April 1, 2007. A scoping letter explaining the project proposal was mailed to 90 interested and affected parties on January 30, 2007. In addition, a legal notice for public comment was published in the Asheville Citizen Times on February 2, 2007. Comments were received from ten individuals and organizations.

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1.6 ISSUE IDENTIFICATION

Issues are defined as a point of debate, dispute or disagreement regarding anticipated effects of the proposed action. The Forest Service separated the issues into two groups: significant and non-significant issues. Significant issues were defined as those directly or indirectly caused by implementing the proposed action. Non-significant issues were identified as those: 1) outside the scope of the proposed action; 2) already decided by law, regulation, Forest Plan, or other higher level decision; 3) irrelevant to the decision to be made; or 4) conjectural and not supported by scientific or factual evidence. The Council for Environmental Quality (CEQ) NEPA regulations require this delineation in Sec. 1501.7, “…identify and eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review (Sec. 1506.3)…” Identified significant issues determine the scope (40 CFR 1508.25) of the environmental analysis. The disposition of comments received during the scoping period is found in Appendix C to this EA. All letters received are contained in the project file. Ten comment letters were received, all of which support the proposed action. The most consistent comment received was to expand the proposed action to include the entire Nantahala National Forest, in contrast to the four sites originally proposed. Based on these comments the interdisciplinary team identified the following as the one significant issue that was then used to develop an alternative to the proposed action. Alternatives to the proposed action are described in detail in Chapter 2.

Issue 1: The limited scope of the proposed action does not adequately address NNIP species infestations on the Nantahala National Forest.

In addition to issues generated by the public or internally there are several Federal laws, which require the consideration of certain effects. Laws such as the Clean Water Act, the Clean Air Act, the Endangered Species Act, and the Antiquities Act all require the protection of certain resources and the analysis of anticipated effects.

Applicable Laws and Executive Orders Shown below is a partial list of federal laws and executive orders pertaining to project-specific planning and environmental analysis on Federal lands.

 Multiple-Use Sustained-Yield Act of 1960  National Historic Preservation Act of 1966 (as amended)  Wild and Scenic Rivers Act of 1968, amended 1986  National Environmental Policy Act (NEPA) of 1969 (as amended)  Clean Air Act of 1977 (as amended)  Endangered Species Act (ESA) of 1973 (as amended)  Forest and Rangeland Renewable Resources Planning Act (RPA) of 1974 (as amended)  National Forest Management Act (NFMA) of 1976 (as amended)  Clean Water Act of 1977 (as amended)  American Indian Religious Freedom Act of 1978  Archaeological Resources Protection Act of 1979  Executive Order 11593 (cultural resources)  Executive Order 11988 (floodplains)

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 Executive Order 11990 (wetlands)

Chapter 2 Alternatives ______

2.1 ALTERNATIVES

There are three alternatives being considered for this proposal. Alternatives include the proposed action (Alternative 1), a no action alternative (Alternative 2) and an additional action alternative that expands the scope of the proposed action to include the entire Nantahala National Forest excluding Wilderness and Wilderness study areas (Alternative 3).

Alternative 1 - Proposed Action The proposed action is to treat non-native invasive plant (NNIP) infestations on up to 550 acres across the Pisgah National Forest and within four sites on the Nantahala National Forest, using an integrated combination of manual, mechanical, cultural, and chemical control treatment methods. The treatments would begin in the spring of 2009, and are estimated to occur over a five-year period. High priority treatment areas are summarized in Table 1.2. The proposed action is described in detail in Chapter 1.

Alternative 2 - No Action Under the no action alternative, there would be no treatment of NNIP infestations. Existing NNIP populations would continue to spread, and new infestations would continue to become established.

Alternative 3 Alternative 3 proposes treatments similar to the proposed action and responds to public comment by expanding the scope to include sites across the entire Nantahala and Pisgah National Forests, excluding Wilderness and Wilderness study areas. Alternative 3 also proposes an additional 550 acres of treatment, with a maximum of 1,100 acres proposed for treatment annually. To allow more flexibility of treatment options, Alternative 3 proposes using any combination of mechanical, cultural, and chemical methods to accomplish the 1,100 acres of treatment. While sites listed in Table 1.2 will receive high priority for treatment, all other areas on the NPNFs will be prioritized according to the following criteria: risk to federally threatened and endangered species, threat to rare species, threat to natural areas, NNIP species biology (including rate and mode of spread), location, practicality of control, and degree of infestation. Treatments would begin in the spring of 2009, and are estimated to occur until changed conditions require a new analysis. Like Alternative 1, Alternative 3 would also include the project specific Forest Plan amendment that is described in Chapter 1.

2.2 MONITORING

Weed infestations are rarely eradicated, or even controlled, with a single treatment. Monitoring is essential to implementing a long-term adaptive management strategy from three perspectives:

9 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control implementation, treatment effectiveness, and environmental effects. Current regional policy requires that monitoring is completed on fifty percent of the total acres treated in any given year. Implementation monitoring will evaluate whether we did what we said we were going to do and to ensure that all label requirements and mitigation measures are being followed. All projects associated with this proposal would be monitored to ensure that herbicide application occurs only under the supervision of a certified herbicide applicator. Treatment effectiveness monitoring will help us to determine when it is appropriate for action to be taken and whether that action is effective. Sites would be monitored, as required by regional policy, to ensure that control of NNIP populations has been accomplished. It is anticipated that many infested sites would require multiple treatments over several years to gain the desired level of control. Treatment effectiveness monitoring would be a necessary component in determining the frequency and type of successive treatments. Environmental effects monitoring would be done to ensure that treatments are having only the anticipated effects as analyzed in this environmental assessment. Should any new information be published regarding the environmental effects of the proposed chemicals, treatments will be modified accordingly, with the appropriate level of environmental analysis.

2.3 MITIGATION MEASURES

All action alternatives would adhere to Forest Plan management direction, established mitigation measures, herbicide labels, and assigned monitoring. The following is a summary of additional mitigation measures that would be implemented under all action alternatives. 1) All guidelines and mitigation measures presented in Forest Manual 2150, Pesticide-Use Management and Coordination, and Forest Service Handbook 2109.14, Pesticide Use Management and Coordination Handbook, would be followed. 2) Equipment, boots, and clothing would be cleaned thoroughly before moving from treatment sites to ensure that seeds or other propagules are not transported to other sites. 3) Fueling or oiling of mechanical equipment would occur away from aquatic habitats. 4) Applicators would use barriers (loosely secured silt fence) along stream edges and banks prior to any application of herbicides. If a silt fence can not be easily secured on steep rocky banks one member of an applicator team will maintain a mobile barrier (such as a large cardboard sheet about 3 by 3 feet in size) between the herbicide application and the stream during the application. 5) NNIP parts capable of starting new plants (seeds, rhizomes, etc.) need proper disposal. Plants may be piled and burned on site or bagged and moved off site. Bagged plants would either be incinerated or would receive standard garbage disposal. For large woody bushes that would be difficult to move, treatments will be scheduled prior to seed set as practical. 6) All NNIP species within 10 feet of any federally listed species would be cut back to within 6 inches of the ground for woody stems and to expose the root crown for vining stems. 7) A barrier (such as an appropriately sized cardboard sheet) would be placed between the targeted NNIP and any federally listed species in the immediate vicinity.

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8) Herbicide applications would be applied to cut stems with a small wick applicator if possible or with a small spray bottle to minimize herbicide drift onto non-target vegetation. 9) Use of mowing as a NNIP control method should be timed to avoid spreading seeds (e.g. before seed set). 10) When work is conducted in areas containing rare or sensitive plant species, those plants would be flagged or marked to avoid spraying. A physical barrier would be used to protect non-target species when they occur immediately adjacent to the treatment area. 11) Retain native vegetation and limit soil disturbance as much as possible. 12) Prior to any treatments, actions covered by this EA would be reviewed by forest resource specialists in the areas of wildlife biology, botany, aquatics, soils, recreation, and heritage resources. An implementation checklist of required reviews (Appendix D) would be used to ensure that potential environmental impacts are within the scope of the impacts disclosed in this NEPA document. 13) The forest archaeologist would consult with the Eastern Band of Cherokee on areas identified for treatment. 14) Following NNIP treatments, exposed soils would be promptly revegetated to avoid re- colonization by NNIP or potential soil erosion. Only approved seed mixtures and weed seed-free mulch would be used. 15) The weed torch would only be used after consulting with the Forest Fire Management Officer to determine fire danger and needed protection measures.

2.4 COMPARISON OF ALTERNATIVES

The following table presents a comparison of the proposed alternatives by resource effects. The effects are more completely discussed in Chapter 3.

Table 2.1 Comparison of Alternatives

Effects of Proposed Treatment Resource Alt. 1 Alt. 2 Alt. 3 Maximum acres treated 550 acres 0 1100 acres annually Percent of project area 0.1% of Pisgah 0% 0.1% of Nantahala and treated National Forest Pisgah National Forests Improved native forage Decreased quality of Improved native forage Wildlife- Terrestrial would benefit wildlife in native forage would benefit wildlife long term in long term Improved habitat Could impact local Improved habitat Wildlife – T&E and conditions would benefit populations with conditions would Viability Concern these species in the long extirpations as a benefit these species in term worst case the long term Vegetative Increased native diversity Decreased native Increased native Communities over time diversity diversity over time

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Effects of Proposed Treatment Resource Alt. 1 Alt. 2 Alt. 3 Native riparian habitats Impacts to riparian Native riparian habitats would improve over time habitats would would improve over time continue to be Aquatic Habitats and adverse as native aquatic T&E riparian vegetation communities continue to degrade Improved habitat Potential negative Improved habitat Management Indicator conditions would benefit effects as habitat conditions would Species these species in the long quality decreases benefit these species in term the long term Impacts to water and soil Impacts to water and Impacts to water and resources are beneficial soil would continue soil resources are as native riparian to be adverse as beneficial as native Water and Soil vegetation reestablishes native riparian riparian vegetation Resources and streambanks vegetation reestablishes and stabalize communities streambanks stabilize continue to degrade Long term benefit to Potential decrease in Long term benefit to scenic values as natural scenic vallues where scenic values as natural Scenery and Recreation viewsheds are restored NNIP dominate the viewsheds are restored landscape The natural environment Structural historical The natural would be improved over sites could be environment would be Cultural Resources the long term by impacted by improved over the long restoring native encroaching NNIP term by restoring native vegetation infestations vegetation Civil Rights None None None Human Health and Impacts to public health None Impacts to public health Safety and safety are negligible and safety are negligible

2.5 ALTERNATIVES NOT CONSIDERED IN DETAIL

A non-herbicide alternative was not considered because non-herbicide methods (hand or mechanical clearing, fire only, or use of grazing animals only, such as goats) are not likely to be effective and therefore would not accomplish the project purpose and need. Manual treatments are not as effective because of resprouting from persistent rootstocks and because some of these areas cover fairly large acreages. In addition, costs would be higher for using only mechanical or manual methods compared to integrating the use of chemical methods for control.

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Chapter 3 – Affected Environment and Environmental Consequences ______

3.1 INTRODUCTION

This chapter summarizes the physical, biological, and social environments of the affected project area and the potential changes to those environments due to implementation of the alternatives. It also presents the scientific and analytical basis for the comparison of alternatives presented in Table 2.1. For the purpose of effects analysis, alternatives one and three will generally be analyzed together because both alternatives propose similar treatments that differ primarily in geographic scope.

3.2 PHYSICAL ENVIRONMENT

3.2.1 Air Quality Affected Environment Treatments are only proposed in Class II air sheds (non Wilderness areas) on the NPNFs. Ambient air quality monitors in the proposed treatment areas show attainment with National Ambient Air Quality Standards for ozone and fine particulates. Direct and Indirect Effects of Alternatives 1 and 3 The proposed manual and mechanical methods of treating NNIP infestations would have little to no direct and indirect effects on air quality. Most manual and mechanical treatments would consist of cutting, pulling, or digging up invasive plants and would not produce any air emissions. Plowing, disking, or blading could occur in some already disturbed sites such as gravel pits and would leave temporary areas of bare soil that could generate minor short term wind-borne soil particles. Vehicles, saws, line trimmers, mowers, and other motorized equipment would generate minor amounts of exhaust emissions. Minimal emissions of nitrogen oxides, particulate matter, and volatile organic compounds are anticipated from the combustions of any fossil fuels. The proposed use of fire is restricted to localized infestations of NNIP using a weed torch and will result in only minimal, localized, short term effects to air quality. Most of the herbicides proposed for use under these alternatives are not volatile; that is, they are unlikely to vaporize and be carried by wind (drift) to unintended locations. The exceptions are certain ester formulations of triclopyr which can drift if applied inappropriately (Kansas State University 2001). In order to minimize drift, weather will be monitored prior to treatment and application of herbicides will be suspended if temperature, humidity, or winds become unfavorable (Management requirement 68, Forest Plan Amendment 5, p. I-12). Cumulative Effects of Alternatives 1 and 3 Due to the limited and dispersed nature of the proposed treatments, the amount of herbicide drift and air pollution emissions are considered to be small to negligible. Proposed treatments would therefore contribute little or no incremental increase in affects to air quality when combined with other present and reasonably foreseeable herbicide applications and sources of air pollution.

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Direct and Indirect Effects of Alternative 2 The no action alternative would pose no direct or indirect impacts on air quality. NNIP species do not generally affect air quality, therefore failure to achieve their control would not be expected to affect air quality. Cumulative Effects of Alternative 2 There would be no cumulative effects of the no action alternative on air quality.

3.2.2 Soils and Hydrology Affected Environment The existing condition of soils and water varies depending on site-specific treatment areas. The potential affected soil and water environment ranges from well-drained upland sites to wetlands. Direct and Indirect Effects of Alternatives 1 and 3 All treatments undertaken would conform to policy, laws, and regulations, including the NC Forest Practice Guidelines Related to Water Quality and the NC Best Management Practices for Forestry in the Wetlands of NC, and the Soil and Water protection standards in the FEIS – Vegetation Management in the Mountainous Region. Mitigation measures listed in Chapter 2 of this EA would additionally minimize soil and water contamination by herbicides. Effects and associated risks of all herbicides proposed for use have been assessed by Syracuse Environmental Research Associates, Inc. (SERA 2003a, 2003b, 2004a, 2004b, 2004c, 2004d, 2004e, 2005). The complete text of these documents can also be found at: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml. Direct effects to soil and water resources may include some limited drift from fine mists during application. Once in the soils, herbicides can migrate via gravity, leaching, and surface runoff to other soils, groundwater, or surface water. To determine the level of risk for accumulation of herbicide residues on soils and possible contamination of ground and surface water, factors such as persistence (measured in half-life), mobility, and mechanisms for degradation have been reviewed (Appendix B). However, many of the herbicide treatments would be applied directly to targeted species and relatively little herbicide would make contact with the soil. Due to the limited acreage and dispersed extent of the areas, and the short half-lives of the chemicals proposed for use, the effects would be temporary and minor. Indirect effects for the chemical treatments are typically some loss in ground cover as the treated vegetation dies and decomposes. Because herbicides kill but do not physically remove plants and their root systems, herbicide use would not increase the potential for soil erosion. The dead plants would be expected to provide short-term soil stabilization until native plants revegetate the area. On individual sites, local soil erosion may occur with the use of manual and mechanical treatments; however, water quality should not be affected because the material is not expected to reach stream channels. Spot burning that is proposed for NNIP treatment would expose very little mineral soil and any potential for accelerated erosion would primarily be associated with construction of fire lines. The type of burning proposed would change soil infiltration and porosity very little from preexisting conditions and therefore would have relatively little, if any, impact on soils in the treatment area.

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Since the proposed actions would restore native vegetation to riparian, streamside, and floodplain areas, the direct and indirect effects of Alternatives 1 and 3 would be beneficial to the soil and water resources. Cumulative Effects of Alternatives 1 and 3 With expected mitigation measures and application rates and methods, no herbicide is expected to leave the analysis area boundaries, and none is expected to enter the analysis area from other projects. Any effects of past herbicide use on other lands within the affected watersheds will likely have dissipated. The impacts from the proposed treatment activities are negligible and would contribute little or no incremental effect when combined with impacts of other past, present, or reasonably foreseeable future activities. Consequently, they are not expected to contribute to any measurable increase in cumulative degradation to soil or hydrological resources. Direct and Indirect Effects of Alternative 2 The no action alternative would change the existing soil and water conditions by exacerbating current degrading trends where invasive species dominate streamside areas. Riparian areas occupied by invasive plant populations would continue to have degraded native plant communities, resulting in less healthy stream ecosystems. Where deep rooted native vegetation is replaced by shallow rooted invasive plants, bank protection would continue to provide inadequate erosion protection. Cumulative Effects of Alternatives 2 No action would occur with the implementation of Alternative 2, so degrading trends to water quality would continue and would contribute to adverse cumulative effects in the associated watersheds.

3.3 BIOLOGICAL RESOURCES

3.3.1 Vegetation Affected Environment The NPNFs consist of a diversity of landscapes, defined by approximately 16 ecological zones. Ecological zones represent units of land that support specific plant communities or plant community groups. Each community is defined by ecological factors such as moisture gradients, elevation, geological formations, annual average precipitation, distance to streams and local relief. While a complete plant community survey across the NPNFs has not been completed, ecological zones have been modeled and mapped across the landscape. These maps are a useful tool in predicting the likelihood of NNIP infestations in different ecological communities.

There are approximately 1,040,000 acres on the NPNFs. Table 3.1 lists the relative abundance of 16 ecological communities across the two forests. Mesic oak-hickory forest is the most abundant ecological community, covering slightly more than 25% of the landscape. Acidic cove forest is the second most common ecological community, occurring on slightly less than 25% of the landscape. Two other communities each represent approximately 10% of the forest coverage, pine –oak/heath forests and rich cove forests.

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Table 3.1 Comparison of ecological communities (EC) across the Nantahala and Pisgah National Forests, and the potential treatment areas (PTA)1 for Alternatives 1 and 3.

Alternative 1 Alternative 3 NPNF % of Ecological Acres in NPNF in Communities (EC) Approx. Approx. EC EC % of PTA % of PTA PTA PTA in EC in EC (acres) (acres) Rich Cove 102,890 9.9% 4,357 4.2% 11,374 11.1% Alluvial Cove 12,889 1.2% 798 6.2% 4,071 31.6% Acidic Cove 229,610 22.1% 10,668 4.6% 54,054 23.5% Mixed Oak/Heath 94,850 9.1% 3,545 3.7% 9,037 9.5% Northern Hardwood Cove 28,945 2.8% 1,086 3.8% 4,047 14.0% Northern Hardwood Slope 11,978 1.2% 148 1.2% 477 4.0% High Elevation Red Oak 79,636 7.7% 2,156 2.7% 8,379 10.5% Mesic Oak-Hickory 279,497 26.9% 7,625 2.7% 19,056 6.8% Dry Mesic Oak- Hickory 25,790 2.5% 2,499 9.7% 3,301 12.8% Pine-Oak/Heath 132,746 12.8% 6,171 4.6% 9,263 7.0% Shortleaf Pine-Oak 13,423 1.3% 508 3.8% 2,119 15.8% Shortleaf-Pine- Oak/Heath 2,165 0.2% 158 7.3% 153 7.1% Chestnut Oak/Heath 8,019 0.8% 242 3.0% 376 4.7% Spruce - Fir 17,899 1.7% 4,097 22.9% 4,176 23.3% Grassy Bald 403 0.0% 155 38.5% 147 36.5% Heath Bald 92 0.0% 3 3.3% 11 12.0% Totals 1,040,832 44,216 130,041 1 Potential treatment area (PTA) include wildlife openings, road corridors, riparian zones, trails, prescribed burn areas, and natural areas (including Special Interest Areas and proposed NC Natural Heritage sites).

Table 3.1 shows that about 47% of the NPNFs is dominated by oak hardwood types, primarily oaks, 37% is dominated by mesic hardwoods with or without a hemlock component, 14% is dominated by mixed yellow pine-oak types, and less than 2% is spruce and fir. The remaining types, such as grassy bald and heath bald are much less common across the NFNFs, and are therefore difficult to map and model on the landscape. Other less common ecological communities, such as bogs and rock outcrops, were impossible to model and are incorporated within other ecological communities. The following pages describe each ecological community and the potential for NNIPs to occur within those communities.

Rich Cove and Alluvial Cove Forest Communities Rich cove forests occur in concave slopes across the Southern Appalachians. This ecological community is best developed on the most protected slopes such as those that face east or north. Many hardwood species persist in the overstory, with tulip poplar as the most dominant species. A diverse deciduous shrub and herbaceous layer persists within the open understory. The best examples of this ecological community occur in high nutrient soils and typically have a high potential for NNIP infestations. Sixteen of the seventeen priority NNIP species have been recorded in this ecological community (Table 3.2).

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Alluvial forests are present across the NPNFs, but are less abundant since they typically occur along large floodplains. The forested examples are often dominated by sycamore (Platanus occidentalis), tulip poplar, muscle wood (Carpinus caroliniana), and black birch (Betula lenta). Some areas have an open shrub layer, others are dominated by deciduous or evergreen shrubs, while others are dominated by an herbaceous layer. A diversity of herbaceous species occurs within this ecological community, including many NNIP species (Table 3.2). Acidic Cove and Mixed Oak/Heath Communities Acidic cove forests occur across a wide range of elevations, typically on steep slopes and along streams. These communities are dominated by tulip poplar and other acidic loving tree species such as black birch (Betula lenta), red maple, Fraser’s magnolia (Magnolia fraseri), and Canadian hemlock (Tsuga canadensis). This ecological community also includes forests dominated by Canadian hemlocks on gentle to moderate alluvial flats and colluvial slopes. These areas are also known to occur on extensive portions of the Highlands plateau. A dense shrub layer of rhododendron and doghobble is often present within these types. Herbaceous diversity varies from extremely sparse in heavy shrub cover to moderate diversity where there are gaps in the shrub cover. Given the dense evergreen shrub layer, only a few NNIP species have been recorded in these two forest types (Table 3.2). Another oak forest type also dominated by evergreen shrubs is mixed oak/rhododendron forest. Typically this occurs upslope of acidic cove forests on steep north-facing slopes. Both red oak and chestnut oak are often present in the canopy. The dense rhododendron layer prevents much infestation of NNIPs, however small populations of NNIPs have been recorded in this forest type. Northern Hardwood Community Northern hardwood cove forests and northern hardwood slope forests typically occur across the more exposed slopes. Northern hardwood cove forests typically occur on low mesic, concave upper slopes and are dominated by yellow birch (Betula alleghaniensis), sugar maple (Acer saccharum), and a variety of other hardwood and conifer species. This forest type has an open herbaceous understory with shrubs generally uncommon. Northern hardwood slope forests have many of the same canopy species as the northern hardwood cove forests with a smaller sugar maple component. The herbaceous layer is less rich and primarily dominated by Pennsylvania sedge, (Carex pensylvanica). Many of the 17 priority NNIPs are known to occur within northern hardwood cove forests (Table 3.2), whereas the northern hardwood slope forests have much less recorded occurrences of NNIPs, potentially due to drier site conditions. Mesic Oak Forest Communities The mesic oak-hickory forest type is the most variable forest type across the NPNFs. Dominant species includes red oak, (Quercus rubra var. borealis) at the highest elevations, and co- dominants of white oak (Quercus alba), mountain chestnut oak (Quercus Montana) and various hickory species. High elevation red oak forests, found primarily on upper ridges, have overstories dominated by red oak, with more mesic hardwood co-dominant species, such as yellow birch, buckeye (Aesculus octandra), and beech (Fagus grandifolia). Red oak forests have varying densities of

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evergreen and deciduous shrub layer as well as herbs and sedges. The forest is generally more vulnerable to infestation of NNIPs when the understory is open. Mesic oak-hickory forest is the most nutrient rich of the oak types and resembles rich cove forest in species richness on some sites (Schafale and Weakley, Petterson 1992). Generally white oak, tulip poplar, and red oak are co-dominants. A diversity of tree and herbaceous species occurs within this community, particularly in areas with less recent disturbance. A variety of NNIP species have been documented with in this community type (Table 3.2). The dry-mesic oak-hickory forest generally has a very dense deciduous shrub layer of bear huckleberry and is typically not as vulnerable to infestation by NNIPs given the drier site conditions. Xeric Pines and Xeric Oak Forest Communities Several pine ecological communities including pine-oak/heath, shortleaf pine-oak, and shortleaf pine-oak/heath, and chestnut oak/heath have been combined within this group since they tend to occupy similar exposed landscape positions and have similar ecological functions. These community types differ primarily in major species composition across their wide range of elevations. Most of the types occur on steep ridge crests and side slopes on southern and southwestern exposures. Pitch pine (Pinus rigida), is co dominant, with xeric oaks such as scarlet oak and chestnut oak also present. Table mountain pine (Pinus pungens), may occur and is typically the dominant species at higher elevations. At lower elevations, generally below 2300 feet, shortleaf pine dominates the canopy with southern red oak in the sub canopy. This forest type may be dominated by all three yellow pine species and occurs in less exposed landscape positions. The density of the heath layer provides variance in these types. Heath shrubs are often dominant in sites that have had no recent fire disturbances. Due to the dense shrub layer, these sites generally have low herbaceous diversity. In fire-maintained landscapes herbaceous diversity can be high. Frequently burned sites with an open grassy habitat are particularly vulnerable to infestation of fire tolerant or fire-loving NNIPs such as princess tree, spotted knapweed, tree-of- heaven, and Chinese silvergrass. Spruce-Fir Community The spruce-fir ecological community is restricted to the highest mountain tops, away from low base sedimentary and metamorphic rock. It occurs near stream heads in high rainfall areas. These forests are commonly affected by wind disturbance and lightning fire. Because of the shallow soils and extreme wind exposure, these forests are susceptible to large blowdowns, particularly in areas damaged by the balsam woolly adelgid and ice events. Even with relatively frequent disturbances, there are no recorded infestations of NNIPs. Grassy Bald Community Grassy balds occur on the uppermost slopes, ridges and domes of the highest mountains. They are dominated by herbaceous species with scattered shrubs and small trees. These primarily mesic sites are subject to high rainfall, fog deposition, high winds, and low temperatures. The high elevations generally discourage invasion by the most common NNIP species. The four species that have been documented within this community are listed on Table 3.2.

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Heath or Shrub Bald Community This community occurs scattered at high-elevations throughout the Southern Appalachians, typically on exposed knobs, steep ridges and extremely steep slopes. The community has a dense shrub layer with a few stunted xeric-loving tree species and very few herbaceous species. Dominant shrubs are most commonly members of the heath family. Soils are typically much more acidic than surrounding forested soils. None of the 17 priority NNIP species have been documented within this community. NNIP occurrence and Patch Size There is incomplete information on the amount of NNIS infestations present across the NPNFs. An invasive plant inventory was completed on 1,181 permanent plots across randomly selected watersheds on the NPNFs in 2002 and 2003. In addition, a more general inventory across the two forests from 2000 to the present, has detailed the most invasive species, the level of infestations, and those plant communities most at risk. Not all of the ecological communities described above have the same level of infestations. Table 3.2 lists the priority species that have been documented within similar ecological community groups. Mesic cove communities such as alluvial forests and rich cove forests have the highest recorded number of NNIP species.

Table 3.2 Number of NNIP species that have been documented in each of the ecological communities, or assemblages of communities

High Invasive Plant Acidic Northern Mesic Oak- Dry-Mesic Xeric Spruce- Grassy Heath Cove1 Elevation Species Cove 2 Hardwoods 3 Hickory Oak Hickory Pine 4 Fir Bald Bald Red Oak

Trees Ailanthus altissima 1 0 0 0 1 1 1 0 0 0 Paulownia tomentosa 1 0 0 0 1 1 1 0 0 0 Albizia julibrissin 1 0 0 0 1 1 0 0 0 0 Shrubs Ligustrum sinense/vulgare 1 1 0 0 0 0 0 0 0 0 Reynoutria japonica 1 0 1 0 0 0 0 0 0 0

Rosa multiflora 1 1 1 1 1 0 0 0 1 0 Spiraea japonica 1 0 1 0 1 0 0 0 0 0 Elaeagnus umbellata 1 0 1 1 1 1 0 0 1 0 Vines

Celastrus orbiculatus 1 1 1 0 1 0 0 0 1 0 Lonicera japonica 1 1 1 0 1 1 0 0 0 0 Pueraria lobata 1 0 0 0 1 1 0 0 0 0 Dioscorea oppositifolia 1 1 1 0 1 0 0 0 0 0 Herbaceous Alliaria petiolata 1 0 1 0 0 0 0 0 0 0 Microstegium vimineum 1 1 1 0 1 0 0 0 0 0 Tussilago farfara 1 0 1 1 1 0 0 0 1 0 Miscanthus sinensis 1 0 1 0 1 1 1 0 0 0 Centaurea biebersteinii 0 0 0 0 1 1 1 0 0 0 Total Species 16 6 11 3 14 8 4 0 4 0 1 Cove = Rich Cove and Alluvial Cove Forests

19 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

2 Acidic Cove = Acidic Cove and Mixed Oak/Heath Forests 3 Northern Hardwoods = Northern Hardwood Cove and Northern Hardwood Slope Forests 4 Xeric Pine = Pine-Oak/Heath, Shortleaf Pine-Oak, Shortleaf Pine-Oak/Heath, and Chestnut Oak/Heath Forests

For the purposes of this environmental analysis potential treatment areas (PTAs) are those areas that are known to have NNIP infestations or are likely to be affected by NNIPs. These areas include wildlife openings, roads, riparian zones, trails, prescribed burn areas, and natural areas (including Special Interest Areas and proposed NC Natural Heritage sites). While dense NNIP infestations can occur anywhere on the forest, the highest densities of infestations often occur in recently disturbed areas and travel corridors such as wildlife openings, roadsides, riparian communities, and trails. Table 3.3 shows that the highest numbers of priority species occur in wildlife openings and travel corridors, with relatively fewer species occurring on prescribed burn sites.

Table 3.3 Number of recorded priority NNIPs in potential treatment areas and the relative risk of spread to adjacent areas

Number of Level of Risk Treatment Areas Invasive Species (from Table 1.1) of Spread Wildlife Openings 16 Highest Roads 16 High Riparian Community 16 High Trails 14 Lower Natural Areas1 12 Lower Prescribed Burns 5 Lowest 1-Natural Areas include special interest areas (LRMP management area 13) and proposed NC Natural Heritage sites

Direct and Indirect Effects of Alternative 1 A maximum of 550 acres will be annually treated across the Pisgah National Forest. Over a 10- year period between 25-30% of the most vulnerable mesic habitats and fire-maintained dry habitats will have NNIP control projects. The reduction in NNIPs would benefit associated native plants. This alternative would help to restore native plant communities to their natural associated species assemblage. Where rare species populations are prioritized for NNIP treatment, the benefits would ensure continued viability of these rare species across the Southern Appalachians. Herbicide treatments may result in effects to non-target vegetation. However these effects would be minimal since all treatments will be applied with either hand-held or backpack spray equipment. Any direct adverse affects to non targeted plants would be localized and temporary. Most of the herbicides that are proposed for use have short half-lives, are readily bound to soil particles, and are relatively target specific. For these reasons, effects to nearby native plant species would be minimal. Use of a weed torch would primarily occur in stilt grass infestations in bogs and wetlands. Most bog species are able to persist with recurrent fire and some bogs (e.g. Dulany Bog) are annually burned to arrest woody plant invasion.

20 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Direct and Indirect Effects of Alternative 2 The no action alternative would not result in any direct effects to alluvial forests, rich cove forests, and mesic oak-hickory forests which are thought to be the most vulnerable plant communities to NNIP infestations. Alternative 2 should not result in any direct effects to spruce- fir forests or heath balds since no NNIP have been identified within these types. However, if future NNIP infestations were identified, the no action alternative would not provide any opportunity for treatment in these areas. Within those communities with varying degrees of shade tolerance, species such as oriental bittersweet, stilt grass, garlic mustard, Chinese yam, privet, and mimosa would persist and continue to spread further degrading the native plant diversity. Infestations of these NNIP species would rapidly increase following natural disturbances such as tree fall, wind throw or ice storms. Between 2-5% of the most vulnerable plant communities occur in areas that have been harvested in the last ten years. While some control efforts have been implemented in recent timber harvest areas, often NNIPs have not been controlled in the riparian communities. Infestations are typically denser in riparian areas and are expected to expand from these areas to the adjacent timber harvest areas. In areas that are experiencing the loss of Canadian hemlocks to the hemlock woolly adelgid, untreated infestations of NNIP are expected to persist and expand into new openings created by the opening of the canopy. The presence of a typically dense rhododendron layer in these areas may serve to discourage the spread of shade tolerant NNIP species. There will be indirect effects to associated species in the plant communities with NNIP infestations. Most native species will be negatively affected by the increased competition from NNIP for light, moisture, and nutrients. Rare plant species, often with small population sizes, would be most at risk. Unmodeled rare plant communities, such as Southern Appalachian bogs, may have the highest number of associated species impacted since the community is particularly vulnerable to stiltgrass which can have very large infestations in mesic partially open sites. See the additional discussion on threatened, endangered, sensitive, and forest concern species within Section 3.3.3. It is possible that a few species may benefit from a large NNIP infestation. For example, when oriental bittersweet reduces the mid canopy layer, native shrubs such as buffalo-nut may expand in the gap left by the midstory trees. Thus, for most communities with uncontrolled NNIP infestations shifts in species composition are likely, but complete removal of native vegetation is highly unlikely. Direct and Indirect Effects of Alternative 3 Alternative 3 would result in similar direct and indirect effects as Alternative 1. The primary difference between the two action alternatives is the distribution and extent of the treatment areas as well as the proposed acreage treated annually. In Alternative 3, the proposed treatment areas would be dispersed across slightly more than 1,000,000 acres, whereas in Alternative 1, treatment areas are dispersed across slightly less than 500,000 acres. Both alternatives propose treating less than 1% of the NPNFs.

21 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Cumulative Effects of All Alternatives Past and present timber harvest and prescribed burning activities on the NPNFs have affected the invasion and spread of NNIPs. These activities will continue in the future and could result in the continued spread of uncontrolled NNIP infestations. From 1994 to 2000 timber management activities on the NPNFs have been on a downward trend (MIS report 2001). In 1994, timber harvest and timber stand improvements ranged from 3,300 to 5,000 acres annually and averaged around 4,400 acres per year. Since 2000, these activities have stabilized around 4,400 acres annually. Without specific operational mitigation measures, current and future timber management activities could result in the spread of existing NNIP infestations. The communities most at risk are alluvial forests, rich cove forests, and mesic oak-hickory forests as they currently have the highest recorded number of priority NNIP species and are typically the most frequently harvested areas. Some control efforts have been implemented in recent timber harvest areas, however, these treatments have not been consistent across all the NPNFs, nor have treatments occurred in areas adjacent to harvest units. As a result, the potential for reinvasion of NNIP after treatment is likely, particularly in areas with recent timber harvest disturbances. Prescribed fire is used on the Nantahala and Pisgah National Forests to restore open conditions for rare plant species and plant communities. Following implementation of the LRMP in 1994, approximately 1,000 acres per year were burned on the NPNFs. In recent years, prescribed burning has increased to about 6,000 acres per year. With continuing emphasis on restoring fire adapted ecosystems, these burned acres are expected to increase in size over the next 5 years (Sharp 2008, personal communication). Prescribed fire has also been used since 1990 on approximately 5 acres of the Pisgah National Forest to restore open conditions and maintain viable populations of mountain golden heather (Hudsonia montana), a federally threatened species. The size of these burns is expected to increase in the future to help maintain open conditions from a recent wildfire. A large population of princess tree is dispersed across thousands of acres within and outside the Linville Gorge Wilderness. A separate environmental analysis will be completed to control the outbreak in the Wilderness area, however, any delays in implementation of control would resultin an increase in the princess tree infestation. Both Alternatives 1 and 3 would implement control of NNIP infestations within prescribed burn areas and would minimize any cumulative effects from past, present, and reasonably foreseeable prescribed burning actions. Alternative 1 would not be as comprehensive as Alternative 3 because only limited treatments would occur on the Nantahala National Forest. Control of NNIP on the NPNFs will continue to be affected by NNIP infestations on adjacent private and public lands. The longer the time between implementation of control efforts on the forests and implementation of similar measures on adjacent lands, the less likely is the success of either Alternatives 1 or 3. An active coordinated NNIP control program is being implemented across both the Blue Ridge Parkway and the Great Smoky Mountains National Park. The Cherokee NF (Tennessee), Sumter NF (South Carolina) and the Tallulah Ranger District in the Chattahoochee NF (Georgia) are implementing control efforts on prioritized sites. On private lands, control efforts tend to be isolated and across small tracts of land, typically on lands managed by land trusts.

22 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Table 3.4 Cumulative effects to plant communities and associated native species Impacts to most vulnerable plant Persistence of native species on the Alternative communities on the NPNFs and NPNFs that are being impacted by throughout the Southern Appalachians NNIP 1 – Primary Pisgah Reduction in NNIP infestations to Persistence of native species on 25- National Forest Control scattered occurrences in the most 30% of NNIP infested sites across vulnerable communities on the Pisgah the Pisgah NF. In untreated areas a NF; native species diversity and structure reduction in population size of plant maintained across 25-30% of the most species most vulnerable to NNIP vulnerable NNIP potentially infested sites invasions may result. Impacts would (20,000 acres) on the Pisgah NF. Habitat be widespread across the Nantahala patterns highly altered on the Nantahala NF and the Southern Appalachians. NF and throughout the Southern Local extirpation of native species is Appalachians with periodic infestations possible in untreated areas. and reinvasions on the Pisgah NF from adjacent untreated lands. 2 – No Action Greatest impact to mesic communities Reduction in diversity of plant with open forests (cove and mesic oak- species on sites with NNIP hickory) with a less severe impact to fire- infestations, especially moist open maintained dry habitats (pine dominated). forests and dry, fire-maintained Potential negative affects to plant forests. Disturbance events would community ecological processes across continue to contribute to the spread about 46,000 acres on the Forests. of NNIPs and could result in local extirpations of native species. 3 – Nantahala and Pisgah Reduction in NNIP infestations to Persistence of native species within National Forest Control scattered occurrences in most vulnerable 25-30% of NNIP infested sites across Efforts communities, native species diversity and the NPNFs. In untreated areas, a structure maintained across 25-30% of the reduction in population size of plant most vulnerable NNIP potentially species most vulnerable to NNIP infested sites (46,000 acres). Habitat invasions may result. Local patterns highly altered throughout the extirpation of native species is Southern Appalachians with periodic possible in untreated areas. infestations and reinvasions on the NPNFs from adjacent untreated private lands.

3.3.2 Wildlife and Management Indicator Species Affected Environment Management indicator species (MIS) are used to evaluate the effects of proposed actions on specific habitats across the national forests. The Forest Plan designates six aquatic wildlife species, four plant species, and eight terrestrial wildlife species as MIS, each associated with a particular community or special habitat component (Table 3.5). Only MIS associated with communities or habitats that may be affected by the proposed treatments were further analyzed for effects. Seven communities and special habitat components were excluded from further analysis because proposed treatment areas were considered very small compared to the extent of the habitat on the forest. This occurred when the maximum proposed treatment acres over the analysis area were less than 5% of the community or habitat extent. For example, rich cove forests and their associated MIS, ginseng, were excluded from further analysis because the NPNFs contain approximately 280,000 acres of this community type; treating 550-1100 acres of non-native, invasive species growing under rich cove conditions annually for ten years would represent < 4% of this community on the national forests, a negligible amount. In addition, three

23 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control aquatic communities and their six associated MIS were excluded from further analysis because all chemical treatments will be used in accordance with their label specifications and the LRMP direction for use of herbicides near water. These precautions should eliminate any direct or indirect effects to aquatic habitats. As a result, seven terrestrial communities/habitat components and their associated MIS were analyzed for effects (Table 3.6).

Table 3.5 Biological communities (LRMP EIS, Table III-8), special habitat components (LRMP EIS, Table III-9) and their associated management indicator species (MIS). Estimated Analyzed Biological Community/ Extent of Population Further/ Special Habitat Community/ Associated MIS Trend Evaluation Component Habitat on Criteria* NPNFs Fir-dominated high 12,000 ac Fraser fir Stable Yes elevation forests Northern hardwood 50,000 ac Ramps Stable Yes forests Carolina hemlock bluff N/A Carolina hemlock Decreasing Yes forests Rich cove forests 281,000 ac Ginseng Decreasing No2 Xeric yellow pine forests 30,000 ac Pine warbler Stable Yes Riparian forests 257,000 ac Acadian flycatcher Increasing No2 Reservoirs 36,000 ac Largemouth bass Stable No1 Coldwater streams 2100 mi Brook, brown, rainbow All species No1 trout; blacknose dace stable Warmwater streams 100 mi Smallmouth bass Stable No1 Old forest communities 166,000 ac Black bear Increasing No2 (100+ years old) Early successional forest 90,000 ac Rufous-sided (eastern) Decreasing Yes (0-10 yrs) towhee Early successional forest 46,000 ac Ruffed grouse Stable Yes (11-20 yrs) Soft mast-producing 600,000 ac Ruffed grouse Stable No2 species (<40 yrs) Hard mast-producing 600,000 ac Black bear Increasing No2 species (>40 yrs) Large contiguous areas N/A Black bear Increasing No2 with low levels of human disturbance Large contiguous areas of N/A Ovenbird Decreasing No2 mature deciduous forest Permanent grass/forb 3000 ac White-tailed deer Stable Yes openings Downed woody debris 1.8 x 108 kg Ruffed grouse Stable No2 Snags 1,250,000 Pileated woodpecker Increasing No2

1- Although potentially present in the proposed treatment areas, the community/habitat component and its associated species will be protected in accordance with LRMP standards and guidelines; therefore, this community

24 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control will not be affected by any of the action alternatives. Given no effects to the community/habitat, the proposed actions will not cause changes to forest-wide trends or changes in population trends of the associated MIS. 2- Although potentially present in proposed treatment areas, treatment effects will be negligible due to the relatively small amount of potential treatment area compared to the extensive and wide-ranging nature of the community/ habitat and its associated MIS.

Table 3.6 Summary of terrestrial wildlife management indicator species (MIS) selected for effects analysis. Associated MIS Reason for Selection Habitat Components Carolina Hemlock Carolina hemlock bluff Project activities may affect forests hemlock bluffs. Fraser Fir Fir-dominated high Project activities may affect elevation forests high elevation forests. Ramps Northern hardwood forests Project activities may affect northern hardwood forests. Pine Warbler Yellow pine forests Project activities may affect yellow pine forests. Rufous-sided Towhee 0 – 10 year old forest Project activities may affect 0-10 year old forest Ruffed Grouse 11-20 year old forest, Project activities may affect downed woody debris, 11-20 year old forest. soft-mast producing species White-tailed Deer Grass/forb habitat, hard Project activities may affect mast species grass/forb habitat. Population Trends for Selected MIS Detailed information about forest-wide MIS habitats and population trends is contained in the Management Indicator Species Report (USFS 2004). Due to infestation by hemlock woolly adelgid, populations of Carolina hemlock are decreasing across the forests, and this trend is likely to continue for the foreseeable future. Fraser fir populations appear to be stable on both a range-wide and forest-wide basis. Long-term persistence of this species on the forests is likely given current population trends and management standards identified in the forest plan. Ramp populations appear to be stable on both a range-wide and forest-wide basis. Long-term persistence of this species on the forests is likely given current population trends and management standards identified in the Forest Plan. Pine warbler populations appear to be stable on both a range-wide and forest-wide basis. Long- term persistence of this species in the forests is likely given current population trends and proactive management standards identified in the Forest Plan. Rufous-sided towhee populations appear to be decreasing range-wide, including those in the national forests. Early successional habitat across the forests is also declining, so the population decline is expected to continue. Ruffed grouse populations are considered low and are apparently declining. In addition, their habitat, young forest 11-20 years old, is relatively uncommon across the forests. Due to limited

25 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control creation of young forest, ruffed grouse populations are likely to continue declining on the national forests. White-tailed deer populations show a declining trend in some areas of the forests due to insufficient management for hard mast producing species and grass/forb habitat. High recreation use can also detract from deer habitat. In some areas adjacent to private lands, however, deer populations may be increasing in response to new food supplies on private lands, such as grass lawns, fruit trees and shrubbery.

Direct and Indirect Effects of Alternatives 1 and 3 Because the proposed herbicide treatments would be performed manually by technicians and contractors targeting specific NNIPs, direct effects to wildlife MIS are highly unlikely. Wildlife will either leave the target area during the treatments, or the operators will avoid spraying them. With manual or mechanical treatments or use of a weed torch, direct effects to wildlife MIS are extremely unlikely because the MIS will likely leave the immediate vicinity of the treatment area. Risk assessments prepared for the Forest Service by Syracuse Environmental Research Associates, Inc. (SERA 2003a, 2003b, 2004a, 2004b, 2004c, 2004d, 2004e, 2005), suggest that the toxic effects of the herbicides proposed for this project are short-lived, and unlikely to negatively affect any wildlife MIS that may venture into the proposed treatment areas following herbicide treatments, or any plant MIS that may recolonize the areas after treatment. Direct effects to plant MIS such as ramps and ginseng, are more likely because NNIPs may grow in close proximity to targeted species. As a result, some individual MIS plants may be killed by the proposed treatments. However, the effects to nontarget vegetation would be minimal and any loss of plants would be unlikely to affect the current population trends on MIS species across the forest. For those areas undergoing physical removal or direct burning, negative indirect effects to wildlife MIS are highly unlikely because the treatments will have ended before the wildlife return to the area. Any reduction of NNIPs would indirectly improve habitat for both plant and wildlife MIS by encouraging the establishment and growth of native plant species through the increased availability of nutrients, water, space and light. This, in turn, should enhance opportunities for wildlife foraging, nesting and brooding. Reducing populations of NNIPs would also decrease the potential for invasion into new sites.

Cumulative Effects of Alternatives 1 and 3 Estimating the number of infested acres across the NPNFs is difficult nevertheless it is reasonable to assume 25,000 acres of NNIPs and to assume an increase from 500 to 1,000 acres per year (2-4% increase annually). Alternatives 1 and 3 would treat an estimated 550-1100 acres per year of NNIP. As a result, the cumulative effect of Alternative 1 over a ten year period would be the net loss of approximately 23,850 – 29,000 acres to NNIPs (Table 3.7). With a higher acreage of proposed treatment, Alternative 3 would result in the net loss of approximately 17,800-22,380 acres to NNIP. Cumulative effects to wildlife MIS over this same period would therefore be the net gain of 6000 - 6800 acres of native habitat for Alternative 1, and 12,000-13,200 acres for Alternative 3, distributed proportionately among the evaluated species.

26 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Table 3.7 Projected annual increases in NNIPs on the NPNFs over a ten year period. The estimated increases assume an initial infestation of 25,000 acres Alternative 1 Alt. 2 (No Action) Alternative 3 2-4% increase (acres) Project Year 2-4% increase (acres) less 550 acres of 2-4% increase (acres) less 1,100 acres of annual treatment annual treatment Year 1 24,450 25,000 23,900 Year 2 24,389-24,878 25,500-26,000 23,278-23,756 Year 3 24,327-25,323 26,010-27,040 22,644-23,606 Year 4 24,263-25,786 26,530-28,122 21,996-23,451 Year 5 24,199-26,267 27,061-29,246 21,336-23,289 Year 6 24,133-26,768 27,602-30,416 20,663-23,120 Year 7 24,065-27,289 28,154-31,633 19,976-22,945 Year 8 23,997-27,830 28,717-32,898 19,276-22,763 Year 9 23,926-28,394 29,291-34,214 18,561-22,573 Year 10 23,855-28,979 29,877-35,583 17,833-22,376

Cumulative Effects of Alternatives 1 and 3 on Population Trends The declining population trend for Carolina hemlock is driven primarily by hemlock woolly adelgid infestation, not by invasive plant species; therefore the declining population trend for Carolina hemlock should remain unchanged. Fraser fir habitat occurs primarily at high-elevations and most NNIPs occur at low to mid- elevations, therefore, Fraser fir habitat contains relatively few NNIPs, and the stable population trend for Fraser fir should remain unchanged. Although proposed treatments should improve habitat conditions for ramps and pine warblers on a few thousand acres, these gains represent a relatively small percentage of their habitats. Stable population trends for these species should remain unchanged. Treatment areas will most likely occur in early successional habitats, thus improving habitat conditions for both rufous-sided towhees and ruffed grouse. However, the proposed treatments would not be expected to reverse declining population trends for these species to the extent that is needed. Treated areas will likely improve mast conditions and grass/forb habitat for deer, but not to the extent needed to reverse declining population trends for this species.

Direct and Indirect Effects of Alternative 2 NNIPs often rapidly invade disturbed areas and other forest openings, although several invasive species, such as bittersweet, English ivy, browntop and privet tolerate shady conditions, and can survive and spread without canopy disturbance. Once established, non-native, invasive plant species often have a competitive advantage over native vegetation, reducing native biodiversity through competitive exclusion.

27 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

In the absence of treatment, NNIPs are expected to spread at their current rates of 2-4% annually. Competition with native species would continue and become increasingly prevalent. Both soil- disturbing management activities, as well as natural events such as flooding, wind throw, and forest infestations would continue to promote the spread of invasive species by disturbing the seedbed and increasing the amount of light that reaches the forest floor. NNIPs have little direct effects on wildlife MIS because invasive plants do not compete for the same resources as most animal species. However, indirect effects to terrestrial wildlife MIS include an expected decline in populations over time with the loss of high quality, native habitats. The displacement of native plant species by NNIPs would reduce native diversity, mast- producing species, native grass and forb forage, and nesting opportunities. NNIPs also threaten investments in wildlife openings, ponds and restoration activities, by lowering the efficacy of these resources.

Cumulative Effects of Alternative 2 The past effects of NNIPs on wildlife MIS must be estimated using the current condition of the National Forests. Estimating the number of acres infested with invasive species is difficult, because the density of the infestation is both site and species specific. Kudzu, for example, forms dense, discrete patches, while isolated princess trees may form diffuse populations over hundreds of acres. We have chosen to define infested acres based on the presence or absence of the invasive species, regardless of their density. Suitable conditions for invasive species are often associated with the disturbance resulting from road construction (Trombulak and Frissell 2000). As of 2000, the NPNFs contained approximately 2,700 miles of road under Forest Service jurisdiction (USFS 2005, p. 115). Historically, each mile of road can be correlated with approximately 0.4 acres of invasive plants. As a result, the 2,700 miles of roads on the National Forests translates into approximately 1,000 acres of NNIPs along road corridors. In addition to roadside infestations, some invasive species, such as privet, bittersweet, princess tree, kudzu and Japanese honeysuckle, are associated with abandoned home sites, old pastures, riparian zones, wildfire and adjacent land uses. These additional infestations are estimated at 24,000 acres across the NPNFs (Gary Kauffman, personal communication). Combined with the roadside infestations, invasive species occupy an estimated total of 25,000 acres on the NPNFs. No trend information is available for NNIPs, but field surveys by Forest Service botanists suggest that existing populations of NNIPs are increasing at a rate of 2 - 4 % per year, producing an estimated annual increase for non-native, invasive plant species between 500 and 1000 acres (Table 3.7). Although annual increases in NNIPs are reported here as additional acres, some of this increase may be increased density of invasive species in acres already considered infested. In general, however, the annual increase in NNIP reported by Forest Service botanists refers to new acres invaded by non-native species.

The cumulative impact of the no action alternative over a ten year period would be an increase to approximately 29,900 – 35,600 acres of NNIPs. Cumulative effects to the evaluated MIS, over this same period would be the loss of 29,900 – 35,600 acres of native habitat, distributed proportionately among the species.

28 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Cumulative Effects of Alternative 2 on Population Trends The declining population trend for Carolina hemlock is driven primarily by hemlock woolly adelgid infestation, not by invasive plant species, therefore the declining population trend for Carolina hemlock should remain unchanged. Fraser fir habitat occurs primarily at high-elevations and most NNIPs occur at low to mid- elevations, therefore, Fraser fir habitat contains relatively few NNIPs, and the stable population trend for Fraser fir should remain unchanged. Although NNIPs may degrade habitat conditions for ramps and pine warblers on a few thousand acres, these acres represent a relatively small percentage of their overall habitats. Stable population trends for these species should remain unchanged. NNIPs are especially likely to invade and degrade early successional forests and grass/forb habitats that are used by rufous-sided towhees, ruffed grouse and deer. Therefore these populations may decline in response to NNIP infestations, exacerbating the declining population trends for these species.

3.3.3 Threatened, Endangered, and Sensitive Species – Wildlife Affected Environment This analysis examines effects of the proposed action on federally threatened or endangered species (T&E), Region 8 Regional Forester’s Sensitive, and NPNFs Forest Concern (locally rare) terrestrial wildlife species. The Land and Resource Management Plan (LRMP) for the NPNFs includes practice standards for the forests including wildlife habitat for MIS. The standards are intended to protect, manage, and where possible, enhance wildlife resources. This analysis will focus on the potential effects of the proposed activities that would most likely affect wildlife resources. Species Evaluated and Rationale Seven federally T&E, 39 Region 8 sensitive and 56 forest concern (locally rare) terrestrial wildlife species were originally considered from the NPNF rare species list. Of these 102 species, six federally T&E, 14 sensitive, and 17 forest concern species have been documented either on the Nantahala or Pisgah National Forests. Detailed risk assessments of individual herbicides were prepared for the Forest Service by Syracuse Environmental Research Associates, Inc (SERA 2003a, 2003b, 2004a, 200b, 2004c, 2006). Because rare species specific information on exposure to herbicides is generally lacking and there do not appear to be significant differences among separate species evaluated within a group, the following analysis groups the terrestrial wildlife species by life type to analyze possible direct and indirect effects. Cumulative effects are summarized for all species at the end of this section. For the purposes of this analysis, Alternatives 1 and 3 are analyzed together as they differ primarily only in geographic scope of the analysis and the proposed number of acres for treatment. Alternative 1 proposes 550 acres per year, across the Pisgah National Forest, while Alternative 3 proposes 1,100 acres over an area almost twice the size. The percent of total forest treated in either alternative is less than 1%.

29 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Mammals There are five T&E, four Region 8 sensitive, and two forest concern species that occur or have the potential to occur on the NPNFs. Eight of these species have been documented on one or both of the two forests (see the bold highlighted species listed in the table below).

Table 3.8 T&E, sensitive, and forest concern mammal species on the NPNFs Scientific Name Common Name G-Rank Forest Status Forest Corynorhinus townsendii Virginia Big-eared Bat G4T2 Endangered N/P virginianus Felis concolor Eastern Cougar G1 Endangered N/P cougar Glaucomys Carolina Northern G5T1 Endangered N/P sabrinus coloratus Flying Squirrel Myotis grisescens Gray bat G3 Endangered Pisgah Myotis sodalis Indiana Bat G2 Endangered Nantahala Corynorhinus Rafinesque's big- G3G4 Sensitive N/P rafinesquii eared bat Microtus chrotorrhinus Southern rock vole G4T3 Sensitive N/P carolinensis Eastern small-footed Myotis leibii G3 Sensitive N/P bat Sorex palustris Southern water G5T3 Sensitive N/P puntculatus shrew Forest Neotoma magister Allegheny woodrat G3G4 Pisgah Concern Forest Sorex dispar Rock shrew G4 N/P Concern

Direct and Indirect Effects of Alternatives 1 and 3 It us unlikely there will be any direct effects to mammal species since they are highly mobile. These species would most likely leave or avoid the treatment area for the short-term while the applicators are applying herbicides, cutting or pulling vegetation, or spot burning NNIP infestations. This might result in rare bats moving from one roost tree to another suitable roost tree. When an animal returns to a treated site, the herbicide should have dried on the vegetation, reducing the likliehood of dermal exposure when brushing by vegetation or during grooming activities. These rare mammals are not known to ingest or roost on any NNIP species, thus reducing the likliehood of any additional direct effects. Any direct adverse impacts caused by treatment activities in habitats would be relatively small and temporary. Follow up treatments may be necessary in certain areas, however, the time between treatments will not be less than three months so there should not be any permanent avoidance by mammals in these areas. The three targeted NNIP tree species, princess tree, mimosa, and tree-of-heaven, are not known to provide roost or nest habitat for any rare mammals such as Indiana bats or Northern Flying Squirrels. By removing the NNIP species, the associated native vegetation could become reestablished and the associated native plant communitiy restored. A restored native plant community would provide a higher diversity habitat and food source for rare mammals in the treated areas. These

30 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control indirect effects of the treatments are expected to provide long-term benefits to native wildlife populations. Direct and Indirect Effects of Alternative 2 The no action alternative will not result in any known direct effects to rare mammals on the NPNFs. Indirectly, this alternative will result in further decline of high quality native habitat. While it is commonly understood that NNIP outcompete and often displace native vegetation, few studies have empirically demonstrated how NNIP species alter specific ecological processes within a plant community. One recent study demonstrated a disruption in the mutalistic association between native tree species and arbiscular mycorrhizal fungi caused by Alliaria petiolatea, garlic mustard (Stinson etal. 2006). It is understood that the presence of a NNIP infestation would result in declines in habitat components important for associated flora and fauna including rare mammal species.

Birds There are four sensitive and eleven forest concern bird species that occur or have the potential to occur on the NPNFs. All species are listed in the table below with those species known to occur on both forests, highlighted in bold.

Table 3.9 T&E, sensitive, and forest concern bird species on the NPNFs Scientific Name Common Name G-Rank Forest Status Falco peregrinus Peregrine Falcon G4 Sensitive Haliaeetus leucocephalus Bald Eagle G4 Sensitive Lanius ludovicia migrans Migrant loggerhead shrike G5T3Q Sensitive Thryomanes bewickii altus Appalachian Bewick's G5T2Q Sensitive wren Accipiter striatus Sharp-shinned hawk G5 Forest Concern Northern saw-whet owl- Forest Concern Aegolius acadicus pop. 1 So. Appal. G5T? Catharus guttatus Hermit thrush G5 Forest Concern Coccyzus erythropthalmus Black-billed cuckoo G5 Forest Concern Contopus cooperi Olive-sided flycatcher G5 Forest Concern Dendroica cerulea Cerulean warbler G4 Forest Concern Dendroica magnolia Magnolia warbler G5 Forest Concern Epidonax alnorum Alder flycatcher G5 Forest Concern Pooecetes gramineus Vesper sparrow G5 Forest Concern Sphyrapicus varius Appalachian yellow- appalachiensis bellied sapsucker G5T? Forest Concern Vermivora pinus Blue-winged warbler G5 Forest Concern

Direct and Indirect Effects of Alternatives 1 and 3 As discussed with the mammal species, it is assumed that birds will temporarily leave the immediate vicinity and leave their nests when treatments are occurring. However, the human disruption would be temporary in duration and only result in minimal effects. The treatment of various NNIP species with abundant fruit (such as Oriental bittersweet and multiflora rose) may reduce the local quantities of soft mast available for birds. However, over time native vegetation should re-establish, providing increased quantities of soft mass as well as improving habitat for

31 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control diverse prey, such as insects. It is possible that individual birds may ingest herbicide contaminated insects resulting in a negative indirect effect. The possibility of contaminating insects would be minimal and short term. All of the proposed herbicides have a low toxicity to birds. Direct and Indirect Effects of Alternative 2 The no action alternative would result in no known direct effects to rare birds on the NPNFs. Indirectly, this alternative would result in further decline of high quality native habitat and shifts in native plant diversity and abundance. A study by Klaus and Keyes, 2007, documented a decline greater than 40% in bird species richness and abundance when comparing non-invaded stands with invaded stands on the Georgia Piedmont. It is possible that the presence of NNIP infestations on the NPNFs would result in similar declines in bird species present in the Southern Appalachians.

Insects There is one endangered species, 21 sensitive species, and 18 forest concern insect species that occur or have the potential to occur across the NPNFs. Of these, nine have been documented on the NPNF. All species are listed in the table below with those species known to occur on both forests, highlighted in bold.

Table 3.10 T&E, sensitive, and forest concern inspect species on the NPNFs Scientific Name Common Name G-Rank Forest Microhexura montivaga Spruce-fir Moss Spider G1 Endangered Callophrys irus Frosted elfin G3 Sensitive Cicindela A tiger beetle G3 Sensitive ancocisconensis Hypochilus coylei A cave spider G3? Sensitive Hypochilus sheari A lampshade spider G2G3 Sensitive Melanoplus divergens Divergent Melanoplus G2G3 Sensitive Melanoplus serrulatus Serrulate Melanoplus G1G3 Sensitive Nesticus cooperi Lost Nantahala Cave spider G1? Sensitive Nesticus crosbyi a cave spider G1? Sensitive Nesticus mimus Cave spider G2 Sensitive Nesticus sheari Cave spider G2? Sensitive Nesticus silvanus Cave spider G2? Sensitive Scudderia Northern Bush Katydid G3? Sensitive septentrionalis Semiothisa fraserata Fraser Fir Angle G2? Sensitive Speyeria diana Diana fritillary G3 Sensitive Speyeria idalia Regal fritillary G3 Sensitive Trechus carolinae A ground beetle G1? Sensitive Trechus luculentus A ground beetle G2T2? Sensitive unicoi Trechus mitchellensis A ground beetle G1? Sensitive Trechus rosenbergi A ground beetle G1? Sensitive Trechus satanicus A ground beetle G1? Sensitive Trimerotropis saxatilis Rock-loving grasshopper G2G3 Sensitive Autochton cellus Golden banded skipper G4 Forest Concern

32 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Direct and Indirect Effects of Alternatives 1 and 3 Most insects have the opportunity to temporarily leave a treated area. Ground beetles would be more limited in their capacity to escape, however any acute herbicide exposure should be minimal since they are ground dwellers and would not be in the direct patch of the herbicide. Honey bees generally are used as the standard representative test organism for invertebrates on herbicide bioassays. The results for the selected herbicides to be used in treatments indicate a low toxicity to honey bees. The treatments would favor native species ultimately increasing native species richness and abundance which should increase the diversity of potential host plants for rare insects present within treatment areas.

Direct and Indirect Effects of Alternative 2 The no action alternative would result in no known direct effects to rare insects on the NPNFs. Indirectly, this alternative would result in further decline of high quality native habitat and shifts in native plant diversity and abundance. It is possible that the presence of NNIP infestations would result in similar declines in insect species including rare species present in the Southern Appalachians.

Amphibians

There are five sensitive and four forest concern amphibian species that occur or have the potential to occur across the NPNFs. Of these, five have been documented on the NPNF. All ten species are listed in the table below with those species known to occur on both forests, highlighted in bold.

Table 3.11 T&E, sensitive, and forest concern amphibian species on the NPNFs Scientific Name Common Name G-Rank Forest Desmognathus santeetlah Santeetlah dusky salamander G3Q Sensitive Eurycea junaluska Junaluska salamander G3Q Sensitive Plethodon aureolus Tellico salamander G2G3Q Sensitive

Plethodon teyahalee Southern Appalachian salamander G2G3Q Sensitive Plethodon welleri Weller's salamander G3 Sensitive Ambystoma talpoideum Mole salamander G5 Forest Concern Aneides aeneus Green salamander G3G4 Forest Concern Eurycea longicauda longicauda Long-tailed salamander G5T5 Forest Concern Plethodon ventralis Southern zigzag salamander G4 Forest Concern

Direct and Indirect Effects of Alternatives 1 and 3 Most salamanders have the ability to escape the immediate vicinity during treatments. Toxicity studies vary on impacts to this group of terrestrial animals. Generally the chemical of most concern is the surfactant sometimes used with glyphosate. SERA studies indicate glyphosate is no more toxic to salamanders than to fish, and the effects are minimal. However, a study in an experimental riparian community found that glyphosate (with surfactant) did have a short-term impact to select amphibians (Relyea 2005). These impacts resulted in a 70% reduction in one species of tadpole. The negative impacts were short-lived (two weeks) and may have not been so deleterious if an aquatic approved form of glyphosate was utilized. Any herbicide treatments in wetlands or within 30 feet of live water would only be implemented with aquatic approved

33 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control herbicides, such as Rodeo or Garlon 3A. It is possible that removal of NNIP infestations would result in beneficial long-term effects on suitable habitat for amphibians by increasing the competitiveness of associated native flora within mesic communities. Direct and Indirect Effects of Alternative 2 The no-action alternative would not result in known adverse impacts to any rare salamanders. Many amphibians live in the most mesic portions of the landscape where NNIP infestations have the potential to be denser. Taking no action would eventually result in native species shifts within these communities which could result in changes in ecological processes that could negatively impact amphibian species. Mollusks There is one T&E, four sensitive and 24 forest concern snail species that occur or have the potential to occur across the NPNFs. Of these, four have been documented on the NPNFs. All 29 species are listed in the table below with those species known to occur on both forests, highlighted in bold.

Table 3.12 T&E, sensitive, and forest concern mollusk species on the NPNFs

Scientific Name Common Name G-Rank Forest Mesodon clarki nantahala Noonday Globe G2T1 Endangered Helicodiscus triodus Tallus coil G2 Sensitive Pallifera hemphilli Black mantleslug G3 Sensitive Paravitrea placentula Glossy supercoil G3 Sensitive Ventridens coelaxis Bidentate dome G3 Sensitive Appalachina chilhoweensis Queen crater G?[G2] Forest Concern Discus bryanti Saw-tooth disc G?[G3] Forest Concern Fumonelix orestes Engraved covert G?[G2] Forest Concern Glyphalinia vanattai Honey glyph G?[G2] Forest Concern Glyphyalinia clingmani Fragile glyph G?[G1] Forest Concern Glyphyalinia junaluskana Dark glyph G?[G3] Forest Concern Glyphyalinia pentadephia (Pink glyph) G?[G3] Forest Concern Haplotrema kendeighi Blue-footed lancetooth G?[G2] Forest Concern Helicodiscus bonamicus Spiral coil G?[G2] Forest Concern Helicodiscus fimbriatus Fringed coil G?[G3] Forest Concern Inflectarius ferrissi Smokey mountain covert G?[G2] Forest Concern Inflectarius subpalliatus Velvet covert G?[G2] Forest Concern Paravitrea andrewsae High mountain supercoil G?[G3] Forest Concern Paravitrea lacteodens Ramp cove supercoil G?[G1Q] Forest Concern Paravitrea lamellidens Lamellate supercoil G?[G3] Forest Concern Paravitrea ternaria Sculpted supercoil G?[G2] Forest Concern Paravitrea varidens Roan supercoil G?[G2] Forest Concern Paravitriea umbilicaris Open supercoil G?[G3] Forest Concern Patera clarki clarki Dwarf proud globe G?[G2] Forest Concern Triodopsis fulciden Dwarf threetooth G?[G2] Forest Concern Triodopsis tennesseensis Budded threetooth G4 Forest Concern Ventridens collisella Sculptured dome G4 Forest Concern Ventridens lasmodon Hollow dome G4 Forest Concern Zonitoides patuloides Appalachian gloss G?[G2] Forest Concern

34 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Direct and Indirect Effects of Alternatives 1 and 3 Snails do not have the ability to rapidly leave a treatment area. However they occur underneath moist leaf litter which minimizes any potential direct effects from off target herbicides. There are no known toxicity reviews for herbicide applications to rare snails. However, in a study completed across a riparian community, there were no direct effects to identified snails when glyphosate was applied to associated herbaceous vegetation (Relyea 2005). Flame throwers would target above ground growth only to scattered shrub species which should result in minimal impacts to the leaf litter except for directly underneath the targeted NNIP species.

Snails require moist leaf litter on wooded hillsides in which to move about and reproduce. The rarest mollusk with suitable habitat nearby known NNIP infestations is noonday globe. In the Nantahala Gorge a large kudzu infestation (covering 5-10 acres) is adjacent to suitable habitat for this federally listed species. The likelihood of any direct affects on noonday globe snails from off-target herbicide is unlikely given the previous habitat alteration that allowed the invasion of kudzu resulted in generally unsuitable habitat for this species. Furthermore mollusks, including the noonday globe, appear to be most active during wet weather. Herbicides are not applied during wet weather. With typical applications during times of dry weather the layer of leaf litter should buffer rare mollusks from any offsite herbicide.

Generally suitable habitat for these species, mid to older successional forests in the acidic cove and rich cove ecological zones, is not known to harbor dense infestations of NNIPs. If control efforts remove selected herbs, shrubs and trees within suitable habitat, the amount of sunlight reaching the forest floor would be localized and not result in a major changes to habitat conditions. In general, there would be a beneficial indirect effect on suitable habitat for the snail by increasing the diversity and abundance of native vegetation within mesic communities. Direct and Indirect Effects of Alternative 2 The no action alternative would result in no known direct effects to rare snails on the NPNFs. Indirectly, this alternative would result in further declines of high quality native habitat and may shift native plant diversity and abundance. It is possible that the presence of a NNIP infestation could result in similar declines in snail species including rare species present in the Southern Appalachians. In the Nantahala Gorge a large kudzu infestation (covering 5-10 acres) is adjacent to suitable habitat for the Noonday snail. There is potential for expansion of this patch into the edge of the critical habitat thereby potentially affecting the existing Noonday snail population in the Nantahala Gorge. Reptiles There is one sensitive and one forest concern reptile species that occur or could occur on the NPNFs. Southern bog turtle, a regional sensitive species while not formally listed is treated as federally threatened due to similarity of appearance of the northern bog turtle. Treating this species as federally listed facilitates protection of listed northern bog turtles. Bog turtles have been documented on the NPNFs.

Table 3.13 Sensitive, and forest concern reptile species on the NPNFs

Scientific Name Common Name G-Rank Forest Clemmys muhlenbergii Bog turtle G3 Sensitive Sternotherus minor Loggerhead musk turtle G5 Forest Concern

35 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Direct and Indirect Effects of Alternatives 1 and 3 Bog turtles typically occur in mucky soils of Southern Appalachian bogs and the musk turtle, in streams. Herbicide application in bogs will be minimal and only chemicals approved for aquatic use will be used in these areas. Likewise, herbicide application along streams will only be done with aquatic approved herbicides. Therefore, direct effects on either turtle species are highly unlikely. Japanese stiltgrass, (Microstegium vimineum), will probably be treated using a flame thrower in select bog habitats. This localized treatment should result in no effect on the bog turtle given its habitat deep in the muck. Controlling NNIP species within occupied rare reptile habitat could have a long-term benefit to individual species by restoring the natural vegetation community, although this might be debatable with bog turtles since they have also been located in highly disturbed cattle grazed habitats with various invasive plant species (G. Kauffman, personal observation). Direct and Indirect Effects of Alternative 2 The no action alternative will result in no known direct effects to rare reptiles on the NPNFs. Indirectly this alternative would result in further declines of high quality native habitat and shifts in native plant diversity and abundance although it is uncertain if this would have any negative effect on the sensitive species bog turtle.

Cumulative Effects for All Wildlife Groups Past and present timber harvest and prescribed burning activities on the NPNFs, as well as on- going existing NNIP treatments on public and private lands have altered habitats suitable for some of the rare terrestrial animal species known to occur on the NPNFs. These activities will continue in the future and the cumulative effects from treatment of NNIP infestations across the NPNFs is not expected to result in an increase of negative impacts to rare terrestrial wildlife species. For most terrestrial wildlife species there is an expected benefit with an anticipated increase in the native flora diversity after successful treatment in an area. Perhaps the greatest impact to terrestrial wildlife species would be to selected amphibian species. Prior to any implementation on the ground, a checklist with analysis of the area would be completed by resource specialists to minimize any negative cumulative effects to rare wildlife species.

Determination of Effect Implementation of either action alternative is not likely to adversely affect noonday globe snail. Neither action alternative will have no negative effect on any federally threatened or endangered wildlife species. The action alternatives are not likely to result in a trend towards federal listing of sensitive species since there will be no impact to sensitive species or the species may benefit from the proposed action. Implementation of the action alternatives may have a beneficial impact on select forest concern species. Consultation with the U.S. Fish and Wildlife Service is not required.

3.3.4 Threatened, Endangered, and Sensitive Species – Aquatics Affected Environment

36 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Three federally threatened or endangered (T&E), 17 Southern Region sensitive, and 70 forest concern (locally rare) aquatic wildlife species were originally considered from the NPNFs rare species list (Appendix E) Of these 90 species, three federally threatened or endangered, 10 sensitive and 24 forest concern species have been documented either on the Nantahala or Pisgah National Forests. Detailed risk assessments of individual herbicides were prepared for the Forest Service by Syracuse Environmental Research Associates, Inc (SERA 2003a, 2003b, 2004a, 200b, 2004c, 2006). The analysis of risk assessments of individual herbicides does not specifically address rare aquatic species located in the Southern Appalachians. In general most risk assessments address fish species, which are considered to be representative of the aquatic ecosystem. The following analysis will address effects of the project proposal based on the complete aquatic ecosystem which separate mollusks from other species because mollusks are less mobile and more likely to be directly impacted by herbicide application. The aquatics analysis includes the following specific mitigation measures: 1) Only herbicides labeled for use in or near aquatic systems would be used within 30 feet of water and 2) Applicators would use barriers (loosely secured silt fence) along stream edges and banks prior to any application of herbicides. If a silt fence can not be easily secured on steep rocky banks one member of an applicator team would maintain a mobile barrier (such as a large cardboard sheet about 3 by 3 feet in size) between the herbicide application and the stream during the application.

Direct and Indirect Effects of Alternatives 1 and 3 Direct effects to aquatic species from herbicide drift will be minimized by following the above mitigations. When aquatic approved herbicides are applied according to label directions they are diluted (680 ppm) and are further diluted upon entering the receiving stream (SERS 2003). Furthermore, the implementation of a streamside barrier to reduce any drift into the stream diminishes the risk. Risk assessments of the proposed herbicides on fish and invertebrates indicate low sensitivity, however this is less certain for mussels. A study on the toxicity of glyphosate to mussels revealed larval glochidia and earliest life stages are sensitive (Bringolf et. al. 2007). For that reason it is important for NNIP treatments to reduce any risk of off-site applications when these glochidia are unattached to their fish hosts and more vulnerable. This is particularly true if herbicide applications are made within the stream channel near potential mussel habitat. It is conceivable there may be treatments in riparian areas, however the only project presently identified near mussel habitat occurs along the Cheoah River where an infestation of kudzu is completely overtopping a backwater stream channel occurrence of Virginia spiraea, a federally threatened rare plant. A small population of the federally endangered mussel, Appalachian elktoe, may be present within the vicinty of this kudzu outbreak. In this location and in any other treatment areas with occuppied habitat for federally T&E, sensitive, and forest concern species the following control measures would be implemented: 1) An aquatic rated formulation of triclopyr would be applied; this herbicide is not known to be toxic to mussels; 2) The infestation would be mechanically cut to expose root crowns(for kudzu) or cut stems (woody trees and shrubs) to reduce the amount of herbicide applied near the mussel habitat; and

37 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

3) A barrier such a cardboard sheet would be placed between targeted vegetation and potential mussel suitable habitat such as sand bars and rocky shoals, to prevent any herbicide from adhering to the sand. With implementation of these control measures the risk of impacts to rare mussels would be greatly reduced. It is unlikely that flame throwers would be used near streams given the moist conditions. A weed wrench is a mechanical tool that is very succesful in extracting entire shrub root balls. It would be utilized for dispersed occurrences of certain NNIP such as privet and autumn olive in riparian systems. In riparian areas where large NNIP infestations would be treated, it may be necessary to replant native stream bank vegetation in order stabilize the soil. Elimination of the NNIPs may result in localized short-term sedimentation sources.

It is likely that removal of NNIPs would allow native vegetation to become reestablished in the riparian areas. It is generally assumed that restoring native vegetation would result in a greater diversity of habitat components that may be important for rare aquatic species. These indirect effects of the treatments would provide long-term benefits to the aquatic community.

Direct and Indirect Effects of Alternative 2

Taking no action to control NNIP riparian vegetation would not result in any direct effects to aquatic organisms. Indirectly it would result in further decline of high quality native riparian habitat and shifts in native plant diversity and abundance. It is assumed that the presence of NNIP infestations would also result in declines in habitat components important for associated aquatic fauna.

Cumulative Effects to Aquatic Species Riparian habitats are protected by standards and guides in the LRMP for the Nantahala and Pisgah National Forests. As a result, impacts to the riparian ecosystem are limited primarily to stream crossings. Prescribed burns do not typically alter mesic areas adjacent to streams and rivers. Over the last 10 years, riparian associated projects have increased downed woody debris, separated sedimentation sources from receiving streams, removed select barriers to trout migration, and re-established native fauna. With the continued decline of Canadian hemlock across the NPNFs there will be a reduction in shading to streams, an increase in stream temperatures, and an increase in large woody debris. The cumulative effects from treatment of NNIP infestations across NPNFs are not expected to result in an increase in negative impacts to aquatic habitats and rare aquatic wildlife species. There would be a benefit with the anticipated increase in native vegetation after a successful NNIP treatment. The greatest potential impact to aquatic wildlife species would be to selected mussel species. For that reason, the mitigations detailed above will be implemented whenever a control project is adjacent or near occupied rare mussel habitat. Prior to any implementation on the ground, a checklist with analysis of the area will be completed by specialists to minimize any negative cumulative effects to rare species. Critical mussel habitat would be identified during this review period. Determination of Effect

38 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Implementation of either action alternative will follow mitigations to protect occupied rare mussel habitat and therefore is not likely to adversely affect Appalachian elktoe. Neither action alternative would have a negative effect on any other federally threatened or endangered aquatic wildlife species. The action alternatives are not likely to result in a trend towards federal listing of sensitive species since there will be no impact to sensitive species. Implementation of the action alternatives should have no impact on forest concern species. Consultation with the U.S. Fish and Wildlife Service is not required.

3.3.5 Threatened, Endangered, and Sensitive Species – Botanical Affected Environment Four hundred forty-four rare plant species are either known to occur, or may occur on the NPNFs (Appendix F). These species include seven federally listed endangered plant species and seven federally listed threatened species. One hundred and forty-five are regionally-listed sensitive plant species. Sixty-nine of the sensitive plant species are non-vascular mosses, lichens, hornworts, and liverworts. The remaining 285 species are forest concern plant species, 69 of which are non-vascular. Regional sensitive species are believed to have viability concerns throughout the Southern Region and generally exhibit a global rank of G3 or T3 or lower, or a national rank of N3 or lower. Forest concern plant species are less globally restricted species but typically grow at the periphery of their range in North Carolina or disjunct from their main range. The complete list of 444 plant species includes species that are known from the mountains of North Carolina only from historical records (> 20 years since last observed), and records from both private and public lands. Of the 444 rare plant species, nine federally T&E, 104 sensitive, and 212 forest concern species have been documented either on the Nantahala or Pisgah National Forests. The following analysis provides a synopsis of the effects analysis for the rare plant species that have the potential to occur within the proposed project area.

Direct and Indirect Effects of Alternatives 1 and 3 Project treatment areas have been prioritized by whether NNIPs are affecting natural communities or rare plant habitats. There are 25 rare plant species with occurrences documented across the NPNFs that have small to large patches of NNIP species affecting them. These sites would receive high priority for control due to the immediate threat posed by the NNIPs. It is conceivable that there are additional undocumented sites with rare plant species across the NPNFs that presently have NNIP infestations. As such, it is difficult to know which rare plant species would be affected by either proposed treatments or the no action alternative. Herbicide applications are planned for the majority of the treatment sites with rare plant species. The intended purpose of herbicide application is to kill target vegetation and some proposed herbicides are somewhat selective and can be more efficaceous at eradicating woody plant species, broad leaf species, members of the legume family, or primarily cool season grasses. The majority of the impacted rare plant species are herbaceous, while only three are woody shrub species. If possible, treatments in herbaceous rare plant occuppied sites will utililize triclopyr. In general this herbicide is most effective against woody plants although specific impacts to rare herbaceous species are not known.

39 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

In order to reduce non-target herbicide impacts to rare plant populations, a USFS botanist would visit the site with applicators (USFS personnel or private contractors) prior to any treatment. The goal is to train the applicators on identification of the rare plant species as well as provide any site-specific application techniques. Treatment areas would be surveyed by the USFS botanist prior to any implementation and as a part of the specialist checklist procedure.

Three known sites with two federally listed plant species are currently being impacted by kudzu, Japanese knotweed, privet, and bittersweet. The following mitigations would be followed at these sites to reduce any non-target herbicide drift onto federally listed species:

1) All NNIP species within 10 feet of any federally listed species will be cut back to within 6 inches of the ground for woody stems and to expose the root crown for vining stems, 2) A barrier (such as an appropriately sized cardboard sheet) will be placed between the targeted NNIP and the federally listed species, and 3) Herbicide applications will be applied to cut stems with a small wick applicator if possible or with a small spray bottle that minimizes non-target herbicide drift. These control measures would greatly reduce the risk of impacts to any of the federally rare plant species. Manual treatment methods would not result in any impacts to known rare plant populations. Japanese stiltgrass (Microstegium vimineum) would likely be treated with weed torches in select bog habitats where they are invading rare communities and impacting rare species. Impacts of the weed torch on adjacent rare sedges is unknown but suspected to be inconsequential since many wetland sedges are known to be fire tolerant. Direct and Indirect Effects of Alternative 2 The no action alternative would result in continued impacts to rare plant species as NNIP species continue to spread. Although there is no quantitative monitoring information, two Virginia spiraea occurrences, one larger subpopulation on the Cheoah River and an entire small population on Whiteoak Creek, have been observed to be in decline over the past five years and could eventually become locally extirpated. Other sites with rare plant populations are not as densely impacted at present, but could conceivably decline as NNIP infestations expand.

Cumulative Effects to Botanical Species Past and present timber harvest and prescribed burning activities on the NPNFs have affected the invasion and spread of NNIP species. These activities will continue in the future and could result in the cumulative spread of uncontrolled NNIP infestations across the landscape. The cumulative effects of the no-action alternative is a reduction in diversity of plant species in sites with NNIP infestations, especially moist open forests and dry fire-maintained forests where NNIP proliferate. Disturbance events and forest management activities would continue to spread NNIP infestations and may result in local extirpations of native species. The absence of NNIP treatments could ultimately affect the eight sensitive plant species and the 11 forest concern plant species. Implementation of either action alternative would reduce impacts to rare plant species as those sites would receive high priority for treatment. It would also be possible to treat areas with rare plant populations if other vegetation management projects were being implemented nearby.

40 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

While implementation of the action alternatives is an effort to control NNIP infestations on the NPNFs, neither proposal would control all known infestations or those located in remote locations. The cumulative effects from treatment of NNIP infestations across the NPNFs are not expected to result in an increase in negative impacts to rare plant species. Prior to any implementation on the ground, a checklist with analysis of the area will be completed by specialists in the field to minimize any negative cumulative effects to rare plant species (Appendix D).

Determination of Effect Implementation of either action alternative, with mitigations, is not likely to adversely affect either Virginia spiraea (Spiraea virginiana) or swamp pink (Helonias bullata). Implementation of either action alternative would have no effect on any other federally listed species. The implementation of either alternative may impact populations of Region 8 sensitive plant species but is not likely to result in a trend to federal listing of any of these species. These proposed actions should be beneficial for all Region 8 sensitive plant species. Implementation of the action alternatives would have a long-term beneficial impact on eleven forest concern plant species although some individuals may be impacted while treating the infestations. Informal consultation with the U.S. Fish and Wildlife Service (USFWS) is required and has been completed. Implementation of the No-action alternative could lead to extirpation of one population and one subpopulation of Virginia spiraea and impact individuals of one population of swamp pink. Formal consultation with USFWS would be required if the no action alternative is selected. Implementation of the no-action alternative may impact populations of Region 8 sensitive plant species but is not expected to result in a viability concern for any of these species across the NPNFs. Implementation of the no-action alternative may negatively impact eleven populations of forest concern plant species.

3.4 SOCIAL RESOURCES

3.4.1 Recreation and Scenery Affected Environment Many of the NNIP targeted for treatment in this proposal were introduced as ornamental species for their aesthetic qualities. These trees, shrubs and vines that are known for their attractive flowers and/or ability to form hedges or ground covers include silk tree (mimosa), autumn olive, privet, honeysuckle, princess tree, multiflora rose, and oriental bittersweet. Since their introduction to the United States, these species have become a noticeable component of the forest landscape. The spread of many of these species is accelerated at recreation areas and along trails and roads where people act as dispersers of seeds. Scenery resources on the Nantahala and Pisgah National Forests are managed with use of assigned Visual Quality Objectives (VQO) as referenced in the LRMP and FS Visual Management System Handbook. These VQO’s include Preservation, Retention, Partial Retention and Modification; and are determined by various Management Area, Sensitivity Level and Distance Zone combinations. Visible management activities must meet the assigned VQO immediately for Preservation, within one growing season for Retention, two for Partial

41 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Retention, and three for Modification. Definitions of Visual Management System terminologies can be found in the LRMP, Appendix G. Direct and Indirect Effects of Alternatives 1 and 3 There would be a short term visual impact of seeing dead vegetation that has been treated with herbicides. These effects would be short term as the target vegetation would quickly deteriorate and the native vegetation would revegetate the treatment area. Compliance with assigned VQO’s is measured by the degree of visual deviation from a natural landscape condition; NNIPs are not natural elements of the landscape and detract from scenic quality. A reduction in NNIPs through mechanical or herbicide treatments would restore natural conditions and move landscapes closer to the assigned VQO within the required timeframes. Long term visual effects of herbicide application would be positive since areas targeted for treatment would kill invasive plants that have overgrown native vegetation. Native plant diversity would increase once the NNIP vegetation is eliminated and native vegetation reoccupies the available growing space. In addition, the physical impediment posed by some of these invasive plants (especially in riparian areas) would be eliminated allowing easier access on and off of trails. Forest standards require the public be informed of treatments in specific areas to reduce impacts and to avoid contact with recently treated areas (Forest Service Hanbook 7109.11). These actions would minimize adverse effects to the recreating public from herbicide application and exposures. Some manual and mechanical treatments may interfere with developed recreation for a short period of time. Ground-disturbing activities such as mowing, disking, or blading could temporarily alter the physical appearance of treated areas. However, any such activities would be limited to areas of prior physical disturbance such as roadsides and wildlife clearings. Cumulative Effects of Alternatives 1 and 3 The proposed treatments are intended to slow the spread of NNIP species and minimize the impacts to native plant populations. Due to proximity of private land adjacent to the forest and the ease at which the NNIP species spread, there will continue to be new infestations across the NPNFs. The proposed treatments will positively move the scenic and recreation resources towards a desired landscape condition comprised of native plant communities. Direct and Indirect Effects of Alternative 2 Taking no action to treat NNIP would have no immediate adverse impacts on recreation, however, failure to effectively control NNIP will result in the establishment of dense thickets of exotic vegetation that could interfere with hiking, birding, and other recreation in forested areas. Over time, the spread of NNIPs that would occur with a no-action alternative may result in a reduction of acres having the desired “natural condition” and prevent assigned VQO’s from being met in many areas of the Forest. Cumulative Effects of Alternative 2 Over the long term dense invasive vegetation could hinder physical movement especially in riparian areas but this effect would be isolated to relatively small areas and is not considered substantial.

42 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

3.4.2 Cultural Resources Direct and Indirect Effects of Alternatives 1 and 3 Mechanical control methods that disturb the soil surface, such as hand-pulling or digging, have the potential to permanently disturb surface and subsurface archaeological resources occurring in the upper six to twelve inches of the soil profile. However, mitigation measures outlined in Chapter 2 specify that all treatments would be reviewed by a cultural resource specialist before soil disturbance and any needed protective measures would be implemented. Manual application of herbicides would have negligible potential to disturb cultural resources. Application personnel or equipment could cause slight soil compaction or disturbance but would not substantially alter the spatial distribution of subsurface resources. Proposed locations would be discussed with the Eastern Band of Cherokee Indians prior to treatment. Cumulative Effects of Alternatives 1 and 3 Elimination of NNIPs would result in a more realistic environmental condition associated with archaeological sites and potential traditional cultural areas. Direct and Indirect Effects of Alternative 2 The no action alternative will have no potential to directly disturb known cultural resource sites on the NPNF. Some invasive shrubs may cover up heritage sites in non-forested areas, but this would be similar to other natural vegetation encroachment. There is a potential that increased infestations of NNIPs may speed up the collapse of historic structures and cemetery markers. Cumulative Effects of Alternative 2 There would be no cumulative effects of the proposed action on the cultural resource.

3.4.3 Human Health and Safety Affected Environment Effects and associated risks of all herbicides listed in the proposed action for this project have been assessed by Syracuse Environmental Research Associates, Inc. (SERA 2003a, 2003b, 2004a, 2004b, 2004c, 2004d, 2004e, 2005). The complete text of these documents can be found at: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml. Direct and Indirect Effects of Alternatives 1 and 3 Manual and mechanical treatment methods would pose relatively little safety risk to workers or the public. The public would be excluded from all treatment areas while work is in progress. Risk assessments for the herbicides proposed for use were completed as part of the Vegetation Management in the Appalachian Mountains Environmental Impact Statement (USDA 1989 Citation). These risk assessments are based on a range of possible application rates, including the maximum application rates allowed under the label. Many of the commonly used herbicides for control of invasive plants are applied at rates below the maximum label rate. Application of herbicides at these lower rates further reduces the potential human and environmental effects. Direct and Indirect Effects of Alternative 2 The no action alternative would have no direct or indirect effects on the health and safety of humans. Cumulative Effects

43 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

There would be no cumulative effects from any of the proposed alternatives on human health and safety.

3.4.4 Socio-economics Direct and Indirect Effects of Alternatives 1 and 3 Because of the limited size of the proposed treatments, this alternative would result in little or no effect on local or regional social conditions or infrastructure requirements. Opportunities of local contract for herbicide application may be created, but this would present only a minor increase in employment or revenue generation. Direct and Indirect Effects of Alternative 2 There would be no substantial direct or indirect effects on social conditions, local or regional employment, or revenue generated as a result of taking no action. However, failure to effectively control the spread of NNIP species might result in a long-term detrimental economic impact as a result of a reduction in local recreational activities and associated revenue. Additionally, failure to take appropriate action at this time, could result in an accelerated invasion of NNIP species, which might result in the need for more expensive control measures in the future. Cumulative Effects There would be no cumulative effects of any of the alternatives on the socio-economics in the area.

3.4.5 Environmental Justice

Executive Order 12898, titled Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, mandates that federal agencies take the appropriate steps to identify, address, and mitigate all disproportionately high and adverse impacts of federally funded projects on the health and socioeconomic condition of minority and low-income populations. Ethnic minorities are defined as African Americans, American Indian and Alaska Natives, Asian, Hispanic or Latino, and Native Hawaiian and other Pacific Islanders. Low income persons are defined as people with incomes below the federal poverty level.

The action alternatives described in the EA are limited to Forest Service managed lands. Adverse impacts resulting from these activities would either not affect or would have limited short-term effects on residents bordering the Forest Service lands. The mitigation measures outlined in Section 2.3, including short-term closures during herbicide applications, should ensure that the proposed activities would have no impact on the health of minorities or low income individuals.

Chapter 4 List of preparers and References______

The Forest Service consulted the following individuals, Federal, state and local agencies, tribes and non-Forest Service persons during the development of this environmental assessment:

ID TEAM MEMBERS:

44 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

Gary Kauffman, USDA Forest Service, NFsNC, Botanist Dave Danley, USDA Forest Service, Pisgah National Forest, Zone Botanist Duke Rankin, USDA Forest Service, Nantahala National Forest, Zone Botanist Brady Dodd USDA Forest Service, NFsNC, Hydrologist Rodney Snedeker USDA Forest Service, NFsNC, Archaeologist Sheryl Bryan USDA Forest Service, NFsNC, Wildlife Biologist Steve Hendricks, USDA Forest Service, FsNC, Recreation Planner-Wilderness Eric Crews, USDA Forest Service, NFsNC, Landscpe Architect Heather Luczak, USDA Forest Service, NFsNC, Assistant Forest Planner

OTHER PERSONS OR AGENCIES, OR GOVERNMENTS CONSULTED: USDI Fish and Wildlife Service North Carolina Division of Environment and Natural Resources North Carolina State Historic Preservation Officer Eastern Band of Cherokee

REFERENCES:

Bringolf, Robert B., W. Gregory Cope, Shad Mosher, M. Chris Barnhart, and Damian Shea. 2007. Acute and chronic toxicity of gloposhate compounds to glochidia and juveniles of Lampsilis siliiquoidea. Environmental Toxicology and and Chemistry. 26:2094-2100.

Evans, C.W., Moorhead, D.J., Bargeron, C.T. and G.K. Douce. 2006. Invasive Plant Responses to Silvicultural Practices in the South. The University of Georgia Bugwood Network, Tifton, GA. BW-2006-03.

Kansas State University, Research & Extension. 2001. Horticulture Newsletter No. 7, Herbicide Drift. http://www.oznet.ksu.edu/dp_hfrr/hnewslet/2001/welcome.htm.

Klaus, Nathan and Tim Keyes. 2007. Effect of two native tree species on upland pine breeding bird communities in Georgia. The Wilson journal of Ornithology. 119(4):737-741.

Relyea, Rick A. 2005. The impact of insecticides and herbicides on the biodiversity and productivity of aquatic communities. Ecological Applications. 15(2):618-627.

Schafale, Michael .P. and Alan S. Weakley. 1990. Classification of the Natural Communities of North Carolina: Third Approximation. North Carolina Natural Heritage Program, Raleigh, North Carolina.

SERA. 2003a. Glyphosate – Human Health and Ecological Risk Assessment Final Report. Syracuse Environmental Research Associates, Inc. SERA TR 02-43-09-04a.

SERA. 2003b. Triclopyr – Human Health and Ecological Risk Assessment Final Report. Syracuse Environmental Research Associates, Inc. SERA TR 02-43-13-03b.

45 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control

SERA. 2004a. Dicamba – Human Health and Ecological Risk Assessment Final Report. Syracuse Environmental Research Associates, Inc. SERA TR 04-43-17-06d.

SERA. 2004c. Metasulfuron-methyl – Human Health and Ecological Risk Assessment Final Report. Syracuse Environmental Research Associates, Inc. SERA TR 04-43-17-01b.

SERA. 2004e. Imazapic – Human Health and Ecological Risk Assessment Final Report. Syracuse Environmental Research Associates, Inc. SERA TR 04-43-17-04b.

Stinson, Kristina A., Stuart A. Campbell, Jeff R. Powell, Benjamin E. Wolfe, Ragan M. Callaway, Giles C. Thelen, Steven G. Hallett, Daniel Prati, and John N. Klironomos. Invasive plant suppresses the growth of native tree seedlings by disrupting belowground mutualisms. PLoS Biology 4(5): e140. DOI: 10.1371/journal.pbio.0040140.

Trombulak, S. C, C. A. Frissell. 2000. Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology 14: 18-30.

USDA Forest Service. 1998. “Stemming the Invasive Tide: Forest Service Strategy for Noxious and Nonnative Invasive Plant Management.”

United States Forest Service. 2004. Management Indicator Species Habitat and Population Trends, Nantahala and Pisgah National Forests. Draft Internal Document, National Forests in North Carolina, Asheville, NC.

USDA Forest Service. 2004a. National Strategy and Implementation Plan for Invasive Species Management. FS-805.

USDA Forest Service. 2007. Four Threats – Quick Facts. http://www.fs.fed.us/projects/four- threats/facts/invasive-species.shtml.

USDA Forest Service. 2007a. Forest Health Protection Website: Herbicide Risk Assessments. http://www.fs.fed.us/foresthealth/pesticide/risk.shtml.

Wilcove, D.S., D. Rothstein, J. Dublow, A. Phillips, and E. Losos. 1998. Quantifying threats to imperiled species in the United States. Bioscience 48:607-615.

46 Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Appendix A: Descriptions of common species and associated treatment methods

Information drawn extensively from Evans et al. 2006, SE-EPPC 2004, and Miller 2003.

Ailanthus altissima Tree-of-heaven Ecology: This deciduous tree is originally from China and was introduced to the U.S. in the late 1700’s as an ornamental species. Tree of heaven can grow up to 80 feet in height and spreads rapidly by root sprouts forming dense colonies. This species is a prolific seeder capable of producing upwards of 300,000 winged seeds per plant that are readily transported long distances both by wind and water. Tree of heaven is extremely tolerant of poor soil and drought conditions and readily invades roadsides, forest openings, and other disturbed areas. This species re-sprouts vigorously after being cut or burned and is also alleopathic, enhancing its ability to displace other species and rapidly invade disturbed areas. Proposed treatment methods: Cutting, girdling, and hand-pulling would provide some control of this species, however, it re-sprouts aggressively and would require continuous follow-up treatments. Mechanical methods are best used in conjunction with chemical treatments. Tree of heaven readily re-sprouts after fire, thus prescribed fire is not considered to be a viable control option for this species. For large trees apply 20-50% stem injections of triclopyr, glyphosate, or imazapyr, or fell the trees and treat cut stumps immediately with the same herbicides. Treatment for saplings and seedlings could include mechanical removal with a weed wrench or handpulling, and/or application of triclopyr as a 20% solution to young bark. Direct foliar applications to seedlings and re- sprouts using a 1% solution of or imazapyr, a 2% solution of glyphosate or triclopyr, or a 1 ounce/acre application of metsulfuron-methyl could also be used.

Albizia julbrissin Silk Tree, Mimosa Ecology: This deciduous tree was introduced from Asia in the late 1700’s as an ornamental species. Mimosa is a small, sprawling, multi-stemmed tree that ranges from 10-50’ in height. It produces numerous, long-lived seeds that are typically dispersed by animals or water, but also reproduces by root sprouts and is capable of rapidly forming dense colonies. This species is tolerant of both wet and dry conditions and while it flourishes in open conditions it is also tolerant of shade. Mimosa can invade most any disturbed site and becomes persistent once established due to the ability to sprout rapidly and produce numerous seeds that are persistent in the seedbank. Effects of fire on this species are unknown. Proposed treatment methods: Cutting, girdling, and hand-pulling would provide some control of this species, however, it re-sprouts aggressively and would require continuous follow-up treatments. Mechanical methods are best used in conjunction with chemical treatments. The effectiveness of the use of fire as a control option for this species is unknown. For large trees apply 20-50% stem injections of triclopyr, glyphosate, or imazapyr, or fell the trees and treat cut stumps immediately with the same herbicides. Treatment for saplings and seedlings could include mechanical removal with a weed wrench or hand-pulling, and/or application of triclopyr as a 20% solution to young bark. Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Direct foliar applications to seedlings and re-sprouts using a 2% solution of triclopyr or glyphosate, or a 0.2% -0.4% solution of clopyralid could also be used.

Alliaria petiolata Garlic Mustard Ecology: This cool season biennial forb was first introduced from Europe in the 1800s. The basal rosettes of leaves persist over the winter and the erect stems are among the first plants to flower in the spring. A single plant can produce hundreds of seeds which are dispersed up to a few yards around the parent plant. Due to its prolific growth, garlic mustard displaces many native spring wildflowers such as spring beauty (Claytonia virginica), wild ginger (Asarum canadense), bloodroot (Sanguinaria canadensis), Dutchman's breeches (Dicentra canadensis), toothworts (Dentaria species) and trilliums (Trillium species) that occur in the same habitat. Proposed treatment methods: Manual pulling of this plant is effective with small scattered populations. However, the seeds of garlic mustard persist in the soil for many years so effective management requires a long term commitment. Several herbicides are effective in controlling garlic mustard.

Celastrus orbiculatus Oriental Bittersweet Ecology: This woody vine was introduced from Asia in the 1800’s as an ornamental species. Oriental bittersweet can climb upwards of 60 feet forming thickets in tree canopies and sometimes girdling or completely covering smaller trees. It produces clusters of attractive fruits that are eaten by birds and other wildlife species and are collected by people for decorative wreaths, resulting in widespread seed dispersal. Oriental bittersweet poses a serious threat to native plant communities due to its high reproductive rate, long range dispersal, ability to root sucker, and rapid growth rate. Climbing oriental bittersweet vines severely damage native vegetation by constricting and girdling stems. Vines can shade, suppress, and ultimately kill native vegetation. Proposed treatment methods: Cut climbing or trailing vines as close to the root collar as possible to control small populations. Cutting would prevent seed production and strangulation of surrounding woody vegetation, however Oriental bittersweet can aggressively re-sprout unless cut so frequently that its root stores are exhausted. Digging or pulling can also be effective for small populations. Fire is not considered to be a control option for this species due to its ability to rapidly re-sprout from underground roots. Chemical control can be achieved using direct foliar application of glyphosate or triclopyr as a 2% solution, or for stems too tall for foliar application, basal bark treatments of triclopyr as a 20% solution with a surfactant. Large stems can also be cut at the base and treated with a 25% solution of glyphosate or triclopyr to prevent re- sprouting. All treatments are more effective when applied prior to fruiting.

Centaurea biebersteinii Spotted Knapweed Ecology: Spotted Knapweed was introduced unintentionally from Eurasia as a contaminant of alfalfa and from soil used as ship ballast. It poses a threat to natural communities such as barrens, fields, meadows and forest edges because it captures moisture and nutrients, forms a deep taproot and spreads rapidly through seed. Several Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices insect species are being used as biological control agents. It grows in disturbed, dry, gravelly, or sandy soils, especially along roadsides and in openings. Proposed treatment methods: Plants can be pulled by hand in small infestations, ensuring removal of the entire crown and taproot. Several herbicides are effective but require repeat applications. Shoes and clothing should be thoroughly cleaned when leaving infested areas.

Dioscorea oppositifolia Chinese Yam Ecology: Chinese yam is an herbaceous climbing vine, native to China that was introduced to the U.S. in the 1800s as an ornamental and edible food crop. This climbing vine can reach up to 5 meters in one growing season and tolerates dry, rocky soils and all but the darkest shade conditions. Spreading occurs through underground tubers and large tubers that form in the leaf axils and are covered with adventitious buds capable of forming new plants and spreading the species. Proposed treatment methods: Manual and mechanical removal of plants is appropriate for small populations but care should be taken to remove all palnt parts as any portions of the root system not removed will potentially resprout. Juvenile plants can be hand pulled depending on soil conditions and root development. Large infestations are most effectively treated with the use of herbicides. The most effective time to treat plants is after the leaves are fully expanded but before the aerial tubers are ripe. Glyphosate and Triclopyr are effective at treating Chinese yam when applied at a 4% solution in late summer.

Elaeagnus umbellulata/pungens Autumn/Thorny Olive Ecology: This deciduous shrub was introduced from China and Japan in the 1800’s and was widely and actively promoted by many state and federal agencies for erosion control, mine reclamation, and wildlife habitat, and was also widely marketed as an ornamental prior to being recognized as a threat to native ecosystems. Autumn olive is a prolific producer of fruit and can produce over 30,000 seeds per plant per year that are readily consumed by birds and small mammals. This species is also a nitrogen fixer and thus is able to colonize nutrient poor sites giving it an advantage in areas with infertile soils. Autumn olive re-sprouts vigorously after being cut or burned and can form dense thickets that can rapidly displace native vegetation if left unchecked. Proposed treatment methods: Cutting, girdling, and hand-pulling would provide some control of this species, however, it re-sprouts aggressively and would require continuous follow-up treatments. Mechanical methods are best used in conjunction with chemical treatments. Autumn olive readily re-sprouts after fire, thus prescribed fire is not considered to be a viable control option for this species. Large stems can be pulled with a weed wrench or cut and treated with a 10% solution of imazapyr or a 20% solution of glyphosate directly on the cut-surface. Other chemical control options include applying direct foliar application of a 1% solution of dicamba, imazapyr, or triclopyr, or for stems too tall for foliar application, basal bark treatments of triclopyr as a 20% solution with a surfactant. Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Ligustrum sinense/vulgare Chinese/European Privet Ecology: Several species of privet native to Asia, Europe, and North Africa have been introduced to the U.S., primarily as a hedge in landscaping. They are difficult to distinguish and include common privet (L. vulgare), Chinese privet (L. sinense), and Japanese privet (L. japonicum). All easily escape cultivation to invade adjacent areas and since the fruits are eaten by birds, seeds can be spread to great distances. Privet is an aggressive invasive, often forming dense thickets, particularly in bottomlands, riparian areas, and along fencerows. Privet is an aggressive sprouter after damage and spreads both through seed dispersal and abundant root sprouts. Proposed treatment methods: Mowing or cutting can be effective for small populations or environmentally sensitive areas where herbicides cannot be used. Repeated mowing or cutting can provide some control to the spread of privet, but would not eradicate it. Stems should be cut at least once per growing season as close to ground level as possible. Privet is effectively controlled by manual removal of young seedlings. Plants should be pulled as soon as they are large enough to grasp but before they produce seeds. Seedlings are best pulled after a rain when the soil is loose. Larger stems can be removed using a weed wrench or similar uprooting tools. The entire root must be removed since broken fragments may re-sprout. Privet responds by sprouting after fire damage, but repeated fire has been shown to afford some control for this species. Mechanical methods are most effective when used in conjunction with the following chemical treatments. Apply direct foliar treatments of glyphosate (3-5% solution) during the dormant season, a 1% solution of imazapyr, or a 1.0 ounce per acres solution of metsulfuron- methyl. For stems too tall for foliar application apply basal bark treatments of triclopyr as a 20% solution with a surfactant. Cut-surface or stem injection treatments of glyphosate or triclopyr (20% solution) are also effective on larger stems.

Lonicera japonica Japanese Honeysuckle Ecology: This woody vine was introduced from Japan in the early 1800’s as an ornamental and has since been widely planted for erosion control and wildlife (deer) forage. Japanese honeysuckle can climb to heights of over 80 feet, but also forms sprawling mats over shrubs, rocks, and on the ground. It is probably the most commonly encountered NNIP species in the southeastern states and is adapted to wide range of ecological conditions, occurring in floodplains and dry ridges, and within the full shade of mature forests, to open areas in full sunlight. Japanese honeysuckle spreads rapidly through root-sprouts and fast growing vines that root at the nodes. Seeds are readily dispersed by animals that feed on the numerous fruits. The slender twining vines can girdle shrubs and small trees, and the dense mats rapidly shade out native vegetation resulting in a dramatic reduction in native biodiversity in heavily infested areas. Proposed treatment methods: For small patches, repeated pulling or digging of entire vines and root systems may be effective. Cut and remove twining vines to prevent them from girdling and killing shrubs and other plants. Mowing large patches of honeysuckle may be useful if repeated regularly (twice a year) but is most effective when combined with herbicide applications to reduce re-sprouting. Prescribed burning removes the above ground vegetation and can sever vines but does not kill the underground rhizomes, which would continue to sprout. Foliar applications of glyphosate (2% solution), metsulfuron- Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

methyl (2.0 ounces per acre), or triclopyr (3-5% solution) would provide control for this species, or for larger vines, cut and treat the cutsurface immediately with a 20% solution of glyphosate or triclopyr. Typically, at least two treatments are needed for effective control.

Microstegium vimineum Japanese Stilt Grass Ecology: Nepal grass is native to temperate and tropical Asia and was first identified in the U.S. at Knoxville, Tennessee in 1919. It apparently spread rapidly from there, and by 1972, it had been identified in 14 eastern states. Nepal grass is an annual, shade tolerant grass that is colonial in nature, rooting from the nodes, and may form dense monotypic stands. Each plant may produce from 100-1,000 seeds that remain viable in the soil for five or more years. Seed dispersal is primarily by animals, flooding, and deposition with fill dirt. This plant spreads rapidly into disturbed areas but can also invade undisturbed areas when seeds “hitch-hike” into pristine area on the fur of animals, car or bicycle tires, hiker’s boots, or flooding. On fertile, mesic sites Nepal grass can replace competing ground vegetation within three to five years. Proposed treatment methods: Mowing plants as close to the ground as possible using a weedeater or similar grass cutting tool can be effective in reducing seed production. Treatments should be made when plants are in flower and before seeds are produced. Treatments made earlier may result in plants producing new seed heads in the axils of lower leaves. Hand-pulling could be effective for small patches, but is usually not a feasible control option given the extent of infestations. Prescribed fire is also effective in eliminating seasonal growth, but is difficult to implement in the mesic sites where this species often occurs and it quickly re-establishes on disturbed ground from seed. For chemical control apply a 2% foliar treatment of glyphosate in late summer. Two applications is more effective than one and treatments over three years are more effective at treating the seed bank.

Miscanthus sinensis Chinese Silver Grass Ecology: This grass was introduced from Asia in the late 1800’s for ornamental purposes. It is a densely-bunched grass that can reach heights up to 12 feet tall. It escapes ornamental plantings and invades disturbed sites, displacing native vegetation. The predominate means of spread is airborne seed or from seeds in the soil (seed bank). Proposed treatment methods: The most effective control would be achieved through use of a foliar application of glyphosate in the fall or in the late spring. Lower rates are required in the fall since translocation to the rhizome is occurring at that time. It is unknown how cutting prior to application would affect effectiveness during either season. Burning is not a recommended control method unless it is followed up by chemical treatment, as burning enhances seed set.

Paulownia tomentosa Princess Tree Ecology: This deciduous tree is native to China and was introduced to the U.S. as an ornamental in the early 1800’s. The showy purple flowers have made it popular as a landscaping tree and the wood of mature trees is also valuable in many overseas markets. Princess tree is an extremely fast grower and can reproduce from seed or from root Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices sprouts. Sprouts can grow to over 15 feet in a single season. Each tree produces numerous clusters of seed pods each with four compartments that contain as many as 2,000 tiny winged seeds. It has been estimated that one tree is capable of producing twenty million seeds that are easily transported in water or wind. Princess tree tolerates drought and low soil fertility, allowing it to invade almost any habitat from rich riparian areas to vacant city lots. It is most often found on roadsides, stream banks, and disturbed areas, and its ability to sprout prolifically allows it to survive fire, cutting, and even bulldozing in construction areas. Proposed treatment methods: Cutting, girdling, and hand-pulling can provide some control of this species, however, it re-sprouts aggressively and would require continuous follow-up treatments. Mechanical methods are best used in conjunction with chemical treatments. Princess tree readily re-sprouts after fire, thus prescribed fire is not considered to be a viable control option for this species. For large trees apply 20-50% stem injections of glyphosate or imazapyr, or fell the trees and treat cut stumps immediately with the same herbicides. Treatment for saplings and seedlings could include mechanical removal with a weed wrench or handpulling, and/or application of triclopyr as a 20% solution to young bark with a penetrant. Direct foliar applications to seedlings and re-sprouts using a 1% solution of or imazapyr, or a 2% solution of glyphosate or triclopyr could also be used.

Polygonum cuspidatum Japanese Knotweed Ecology: This semi-woody shrub is native to Japan and was introduced to the U.S. in the 1800’sas a landscape plant and for erosion control. It forms dense thickets that can reach heights of three to ten feet and is easily recognizable by its “bamboo-like” stems and large, ovate leaves. Japanese knotweed spreads rapidly from stout rhizomes forming dense clonal stands. Seeds and rhizome fragments are distributed by water in floodplains and transported with fill dirt. Once established, populations are quite persistent and can rapidly out-compete existing vegetation. Proposed treatment methods: Digging, plowing, or hand-pulling can be effective if care is taken to remove the entire plant including all roots and runners. Any portions of the root system not removed would potentially re-sprout. All plant parts, including mature fruit, should be bagged and disposed to prevent re-establishment. The effects of prescribed fire on this plant are unknown, though the dry, hollow stems of the previous seasons’ growth should burn rapidly. Cutting or mowing may prevent seasonal reproduction, but would not provide effective control unless used in combination with chemical treatments. For chemical control apply a 2% foliar treatment of either glyphosate or triclopyr, or cut stems and apply a 25% solution of the same herbicides directly to the cut surface.

Pueraria montana var. lobata Kudzu Ecology: This woody vine is native to Japan and China and was introduced into the U.S. in the late 1800’s as an inexpensive livestock forage. The Soil Conservation Service distributed approximately 85 million seedlings starting in 1933 in an effort to control agricultural erosion. Kudzu was listed by USDA as a common weed of the south in 1970 and it is now estimated that kudzu covers over seven million acres in the southeast. This aggressive vine can grow up to a foot per day forming a continuous cover of foliage that Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices chokes out competing native vegetation. Kudzu grows well under a wide range of environmental conditions and can grow in nearly any type of soil, resulting in large-scale alteration of biotic communities. Kudzu has large, tuberous roots that reach depths of up to five meters making it extremely difficult to eradicate with any method other than a systemic herbicide. Proposed treatment methods: Plowing, digging, mowing, and pulling (young plants) all can have some effect on controlling spread of smaller patches, but it is extremely difficult to eradicate without resorting to the use of chemicals. Like the previous mechanical treatments, prescribed fire can reduce above ground biomass, but the plant rapidly re- sprouts from the deep-seated roots and re-establishes rapidly. To treat chemically apply a 0.5% foliar spray of clopyralid, a 2% foliar solution of glyphosate or triclopyr, or a 3.0- 5.0 ounce per acre foliar treatment of metsulfuron-methyl. Treat the bark of larger vines with a 20% solution of triclopyr with a penetrant, or cut stems and immediately treat the cut surface with a 25% solution of glyphosate or triclopyr for additional control.

Rosa multiflora Multiflora Rose Ecology: Multiflora rose was introduced from Asia in the late 1800’s as an ornamental species and was subsequently used for wildlife plantings and windbreaks. In some states, it was even planted as a crash barrier along highways. Plants produce long, arching, vine- like stems that form sprawling clumps and often climb high into the branches of nearby trees. Multiflora rose reproduces by seed and also spreads rapidly from root sprouts and by rooting from the tips of arching branches. Its fruits are eaten by birds and other small animals that then disperse the seeds great distances. Seeds may remain viable in the soil for 10-20 years. Multiflora rose can tolerate a wide range of environmental conditions and once established, grows rapidly forming dense, impenetrable thickets. Proposed treatment methods: Mowing and cutting can be effective at controlling the spread of small populations or environmentally sensitive areas where herbicides cannot be used, but would not eradicate it. Stems should be cut at least once per growing season and as close to ground level as possible. Hand cutting of established clumps is extremely difficult due to the long arching stems and prolific thorns. Prescribed burning can reduce above ground biomass and seems to have some benefit as a control measure, though more information is needed on long term effectiveness of this treatment option. The best control is achieved though the use of chemical treatments. For large stems, cut and immediately treat the cut surface with a 20% solution of glyphosate or a 10% solution of imazapyr. Stems can also be treated with a basal application of a 20% solution of triclopyr with a penetrant. Cut stem treatments are most effective during the dormant seasonDirect foliar applications can also be made using a 1% solution of imazapyr, a 2% solution of glyphosate, or a 1.0 ounce per acre application of metsulfuron-methyl.

Spiraea japonica Japanese Meadowsweet Ecology: Japanese spiraea is a perennial shrub native to Japan that was introduced to the U.S. in the late 1800’s as an ornamental species. Spiraea can tolerate a wide range of ecological conditions but is most commonly encountered along streams or roads in moist soils. It grows well in full sun but may endure partial shade. It can grow in almost any disturbed habitat including riparian areas, successional fields, roadsides, power line Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices rights-of-way, and forest edges. Once established, spiraea grows rapidly forming dense stands that may invade canopy gaps of adjacent woodlands. Each plant produces hundreds of small seeds that can be dispersed by water and deposited along stream banks, or easily transported in fill dirt or by vehicle tires along roadways. Proposed treatment methods: Mowing, cutting, and hand-pulling are appropriate for small populations or environmentally sensitive areas where herbicides cannot be used. Repeated mowing or cutting may control the spread of spiraea, but would not eradicate it. Stems should be cut at least once per growing season prior to seed production and as close to ground level as possible. The use of weed wrenches or hand-pulling of seedlings can effectively control small populations. The effects of prescribed fire are not well documented for Japanese spiraea. Related species are top-killed, but re-sprout after fire. Because this species often occurs in riparian areas or other mesic habitats, prescribed fire is probably not an option as a control method. For chemical control apply a 2% foliar solution of glyphosate or triclopyr, or cut stems and immediately treat the cut surface with a 25% solution of the same herbicides.

Tussilago farfara Coltsfoot Ecology: Coltsfoot is a perennial, herbaceous plant that invades disturbed areas throughout much of the eastern United States. The basal leaves are heart-shaped, slightly toothed and up to 6 in. (15.2 cm) wide. The dandelion-like flowers are bright yellow in color and emerge before the leaves in early spring. Coltsfoot invades moist, open, disturbed areas such as stream banks, ditches and fields. It readily spreads both by seed and rhizomes, allowing it to form large colonies, which can displace native species. Coltsfoot is native to Europe and was probably introduced into the United States by early settlers for medicinal purposes. Proposed treatment methods: Small initial infestations may be controlled by hand pulling though care must be taken to remove the entire root. Foliar treatments with glyphosate or triclopyr are appropriate for controlling large populations or where hand pulling is impractical. Treatments should be done in the summer when the leaves are fully developed. Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Appendix B: Soil activity of proposed herbicides Table A.1 Mobility and Persistence of Herbicides in Soil Characteristics Herbicide Mechanisms of degradation Average half- Mobility life in soil Glyphosate Degradation primarily due to 47 days Extremely high ability to bind to soil microbes. soil particles, preventing it from being mobile in the environment. Triclopyr Rapidly degraded to tricloypr 30 days Ester formulation binds readily acid by photolysis, microbes in with the soil, giving it low the soil, and hydrolysis. mobility. The salt formulation binds only weakly in soil, giving it higher mobility. However, both formulations are rapidly degraded to triclopyr acid, which has an intermediate adsorption capacity, thus limiting mobility. Clopyralid Degraded by soil microbes. 40 days Does not bind strongly to soils, During the first few weeks, there is a strong potential for leaching and possible contamination of groundwater, but adsorption may increase over time. Imazapic Degradation primarily due to 120 days Imazapic shows moderate to high soil microbes. mobility in the environment, with a moderate potential to leach through soils and contaminate groundwater. Metasulfuron Breaks down in ultraviolet light 30 days Runoff is negligible in sandy or methyl loam soils, but high in clay soils. Dicamba Rapid metabolism by soil <14 days Low to medium leaching potential microbes (slower in anaerobic under (mobile in soil but degrades soil conditions), slow photo- conditions rapidly) (WSSA 2002). degradation (WSSA 2002) amenable to rapid metabolism Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Appendix C: Nantahala and Pisgah National Forests Non-Native Invasive Plant Control, Comment Analysis

A scoping letter with a detailed proposed action was mailed out to 90 interested and affected parties on January 30, 2007. In addition, a legal notice for public comment was published in the Asheville Citizen Times on February 2, 2007. Comments were received from ten individuals and organizations. The following is a summary of the comments and the Forest Service response to those comments.

Support Scoping of Comments/Concerns FS Response Respondent Project Treatment carefully supervised Site specific reviews will occur NC Natural near PETS plant species. prior to treatments and mitigations Yes Heritage Program will be followed to minimize the harm to PETS. Concern over the treatment of FS recognizes that these species Autumn olive and honeysuckle as have been valuable wildlife these species are important wildlife species but have become invasive food and cover species. There is no and displace native vegetation in NC Wildlife proposed plan for replacement of some areas. Resources Yes these species. Commission Would like to see project expanded Alt. 3 addresses this concern by to treat any wildlife openings or including areas across the plantings in the Nantahala and Nantahala and Pisgah NFs. Pisgah NF. US Fish and Would like to see project expanded Alt. 3 addresses this concern by Wildlife Service to treat areas across the Nantahala including areas across the and Pisgah NF. Nantahala and Pisgah NFs. Yes Control Miscanthus sinensis within The scope of this proposal does Linville Gorge and Linville not include treatment in Wilderness Wilderness or Wilderness study areas. Post signs along AT prior to any Notice signs will be clearly Appalachian Trail Yes chemical control efforts along the posted, with special care taken in Conference trail areas of anticipated visitor use. Treatment should be carefully Site specific reviews will occur supervised by FS botanists and prior to treatments and mitigations biologists near PETS plant species will be followed to minimize the and other state ranked species as harm to PETS. FS recognizes that well as other native species that some non target native vegetation Western North Yes have important wildlife, may be impacted. A discussion of Carolina Alliance recreational, educational, or these impacts is included in the aesthetic value. Environmental Assessment. Garlic mustard and tree-of-heaven Infestations will be prioritized should be listed as high priority based on the criteria listed in the species. Environmental Assessment. Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Would like to see project expanded Alt. 3 addresses this concern by to treat areas across the Nantahala including areas across the and Pisgah NF. Nantahala and Pisgah NFs. Include plantings of native species Following NNIP treatment, in control areas where large exposed soils will be revegetated patches of invasive plants were to avoid recolonization by NNIP Western North Yes removed. or potential soil erosion. Only Carolina Alliance approved seed mixtures and weed seed free mulch will be used. Place more emphasis on long term Monitoring will occur to control with monitoring along determine effectiveness of roads and within wildlife openings. treatment, and what follow up treatments may be needed. Would like to see project expanded Alt. 3 addresses this concern by to treat areas across the Nantahala including areas across the and Pisgah NF. Nantahala and Pisgah NFs. Cooperate with adjacent The Forest Service is cooperating landowners including adjacent NFs with the Appalachian Trail as well as other agencies. Conservancy, Western North Carolina Alliance, Equinox Environmental, NC Department of Transportation to develop cooperative weed management Southern areas. Appalachian Yes Biodiversity Establish adaptive procedures for This project is intended to be Conference reprioritizing sites for control. adaptive and includes a protocol Incorporate an inventory and for identifying priority sites. monitoring program. Inventory and monitoring of invasives will continue across the forests. Utilize the best science for Effects on wildlife species are chemical control, particularly in discussed in chapter 3 of the EA. regards to the effects of glyphosate All herbicide labels will be on amphibians. followed as well as Forest Service mitigations concerning the applications of herbicides. Southern Would like to see project expanded Alt. 3 addresses this concern by Appalachian Yes to treat areas across the Nantahala including areas across the Forest Coalition and Pisgah NF. Nantahala and Pisgah NFs. Cooperate with adjacent The Forest Service is cooperating landowners, work with volunteer with the Appalachian Trail groups. Conservancy, Western North Carolina Alliance, Equinox Environmental, NC Department of Transportation to develop cooperative weed management areas. Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

High priority should be given for This project is intended to be treatments with densely infested adaptive and includes a protocol areas as well as small infestations for identifying priority sites. adjacent to rare species and natural areas. Have flexibility to prioritize sites that can be easily controlled, and are along roads and wildlife openings. Inventory to detect new sites, This project is intended to be particularly near new proposed adaptive and includes a protocol projects. Establish ongoing for identifying priority sites. monitoring program that provides Inventory and monitoring of for adaptive framework for invasives will continue across the prioritizing control. forests. Would like to see project expanded Alt. 3 addresses this concern by to treat areas across the Nantahala including areas across the and Pisgah NF. Nantahala and Pisgah NFs. Jack Ramney Yes Need to develop an invasive plant Inventory and monitoring of rapid response team. invasives will continue across the forests. Place tree-of-heaven at high Treatment of a specific species priority for control vs. medium will be prioritized according to priority. criteria outlined in the treatment protocol section of the Environmental Assessment.

Jack Ramney Yes Surfactants that are used with Only product formulations foliar application are often of more (herbicide plus surfactant) that are concern than the herbicide itself. low in toxicity and approved for Analysis should address effects of aquatic use will be used in surfactants on forest resources. riparian zones. RoundupTM , which has been criticized for its toxic surfactant, will not be used. Would like to see project expanded Alt. 3 addresses this concern by to treat areas across the Nantahala including areas across the and Pisgah NF. Nantahala and Pisgah NFs. Place Japanese honeysuckle, garlic Treatment of a specific species mustard, and tree-of-heaven at will be prioritized according to high priority for control vs. criteria outlined in the treatment medium priority. protocol section of the Environmental Assessment. Josh Kelly Yes Roads and recently logged areas Treatment of a specific species should be prioritized focus. will be prioritized according to criteria outlined in the treatment protocol section of the Environmental Assessment. Opposed to large proposed burn This is outside the scope of this surrounding Snooks Nose and project. Laurel Knob in the Curtis Creek area. Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Would like to see project expanded Alt. 3 addresses this concern by to treat areas across the Nantahala including areas across the and Pisgah NF. Nantahala and Pisgah NFs. Ensure contractors clean all Equipment, boots, and clothing equipment and place potential seed would be cleaned thoroughly sources into secure trash before moving from treatment Kevin Caldwell containers. sites to ensure that seeds or other (Equinox Yes propagules are not transported to Environmental) other sites. Additional comments regarding These comments are outside the logging on public lands, limit scope of this project. operations and logging to least impact times of year, no logging in old growth or within rare communities. Jane Hargreaves Yes Encourage cooperation with The Forest Service is cooperating neighbors. with the Appalachian Trail Conservancy, Western North Carolina Alliance, Equinox Environmental, NC Department of Transportation to develop cooperative weed management areas. Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Appendix D: Implementation Checklist for the Treatment of NNIP Species

NRIS Site ID:______Species name:______Lat/Long in decimal degrees: N______W______GIS Acres:______(calculated from GIS) Percent of site infested______% Data Collected by:______Infested adjacent (non NFS) land *YES NO List other NNIP species present at site:

Treatment method (list methods, chemicals used, date to be treated, by whom, etc.)

Botanist Review: (Describe any special circumstances including the presence of TES species and rare or unique communities. List all recommended mitigations below.)

Wildlife Biologist Review: (Describe any special circumstances including potential impacts to forage and wildlife investments. List all recommended mitigations below.)

Aquatic Biologist Review (only required when treating sites within riparian areas): (Describe any special circumstances including the presence of aquatic TES species. List all recommended mitigations below.)

Hydrologist/Soils Review: (Describe any special circumstances regarding potential impacts to water quality. List all recommended mitigations below.) Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Recreation Specialist Review: (Describe any special circumstances regarding recreation activities in the area that may be affected. List all required mitigations below.)

Archaeologist Review: (Describe any special circumstances regarding historical or cultural significance. List all recommended mitigations below.)

Signatures and Date:

______Botanist/Ecologist Wildlife Biologist Aquatic Biologist ______Hydrologist Archaeologist

*If adjacent non NFS land is infested with NNIP species consider the use of a Wyden Amendment to treat. Treatments on adjacent land would only occur if consistent with Wyden Amendment. Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Appendix E: Nantahala and Pisgah National Forests Rare Aquatic Species. Species highlighted in bold type are known to be present in one of the forests. NC US Global Group Designation* Scientific Name Common Name Status Status Rank Mollusk Endangered Alasmidonta raveneliana Appalachian elktoe E E G1 Mollusk Endangered Pegias fabula little-wing pearlymussel E E G1 Fish Threatened Hybopsis (Cyprinella) monacha spotfin chub T T G2 Crayfish Sensitive Cambarus chaugaensis Oconee stream crayfish SR(PSC) G2 Crayfish Sensitive Cambarus georgiae Little Tennessee River crayfish SR(PSC) G1 Crayfish Sensitive Cambarus parrishi Hiwassee headwaters crayfish SR(PSC) FSC G1 Crayfish Sensitive Cambarus reburrus French Broad crayfish G3 Crustacean Sensitive Caecidotea carolinensis Bennett's Mill cave water slater SR FSC G1G2 Crustacean Sensitive Stygobromus carolinensis Yancey sideswimmer SR FSC G1G2 Dragonfly Sensitive Macromia margarita mountain river cruiser SR FSC G2G3 Dragonfly Sensitive Ophiogomphus edmundo Edmund's snaketail SR FSC G1G2 Dragonfly Sensitive Ophiogomphus howei pygmy snaketail SR FSC G3 Fish Sensitive Etheostoma acuticeps sharphead darter T G3 Fish Sensitive Etheostoma vulneratum wounded darter SC G3 Fish Sensitive Percina burtoni blotchside darter E G2 Fish Sensitive Percina macrocephala longhead darter SC FSC G3 Fish Sensitive Percina squamata olive darter SC FSC G3 Mussel Sensitive Alasmidonta varicosa brook floater T(PE) FSC G3 Mussel Sensitive Fusconaia barnesiana Tennessee pigtoe E G2G3 Mussel Sensitive Lasmigona holstonia Tennessee heelsplitter E FSC G3 Amphibian Locally rare Cryptobranchus alleganiensis hellbender SC FSC G4 Amphibian Locally rare Necturus maculosus common mudpuppy SC G5 Caddisfly Locally rare Ceraclea slossonae a caddisfly SR G? Caddisfly Locally rare Matrioptila jeanae a caddisfly SR G? Caddisfly Locally rare Micrasema burksi a caddisfly SR G? Caddisfly Locally rare Micrasema sprulesi a caddisfly SR G? Caddisfly Locally rare Palaeagapetus celsus a caddisfly SR G? Caddisfly Locally rare Rhyacophila amicus a caddisfly SR G? Caddisfly Locally rare Rhyacophila vibox a caddisfly SR G? Crustacean Locally rare Ascetocythere cosmeta Grayson crayfish ostracod SR FSC G? Crustacean Locally rare Cymocythere clavata Oconee crayfish ostracod SR FSC G? Crustacean Locally rare Dactylocythere prinsi Whitewater crayfish ostracod SR FSC G? Crustacean Locally rare Skistodiaptomus carolinensis Carolina skistodiaptomus SR FSC G? Crustacean Locally rare Waltoncythere acuta Transylvania crayfish ostracod SR FSC G? Dragonfly Locally rare Aeshna tuberculifera black-tipped darner SR G4 Dragonfly Locally rare Aeshna verticalis green-striped darner SR G5 Dragonfly Locally rare Cordulia shurtleffii American emerald SR G5 Dragonfly Locally rare Gomphus adelphus moustached clubtail SR G4 Dragonfly Locally rare Gomphus consanguis Cherokee clubtail SR FSC G2G3 Dragonfly Locally rare Gomphus descriptus harpoon clubtail SR G4 Dragonfly Locally rare Gomphus lineatifrons splendid clubtail SR G4 Dragonfly Locally rare Neurocordulia yamaskanensis stygian shadowdragon SR G5 Dragonfly Locally rare Ophiogomphus aspersus brook snaketail SR G3G4 Dragonfly Locally rare Ophiogomphus mainensis Maine snaketail SR G4 Dragonfly Locally rare Somotochlora elongata ski-tailed emerald SR G5 Dragonfly Locally rare Stylurus scudderi zebra clubtail SR G4 Fish Locally rare Aplodinotus grunniens freshwater drum T G5 Fish Locally rare Clinostomus funduloides ssp 1 Little Tennessee River rosyside dace SC G5T3Q Fish Locally rare Cottus carolinae banded sculpin T G5 Fish Locally rare Cyprinella zanema (population 1) Santee chub (piedmont population) SR G4T3Q Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

NC US Global Group Designation* Scientific Name Common Name Status Status Rank Fish Locally rare Erimystax insignis blotched chub SR FSC G3G4 Fish Locally rare Etheostoma inscriptum turquoise darter SC G4 Fish Locally rare Hiodon tergisus mooneye SC G5 Fish Locally rare Hybopsis rubrifrons rosyface chub T G4 Fish Locally rare Ichthyomyzon bdellium Ohio lamprey SR G3G4 Fish Locally rare Lampetra appendix American brook lamprey T G4 Fish Locally rare Luxilus chrysocephalus striped shiner T G5 Fish Locally rare Micropterus coosae redeye bass SR G5 Fish Locally rare Moxostoma species 1 sicklefin redhorse SR FSC G2G3Q Fish Locally rare Notropis lutipinnis yellowfin shiner SC G4Q Fish Locally rare Noturus flavus stonecat E G5 Fish Locally rare Percina caprodes logperch T G5 Fish Locally rare Percina nigrofasciata blackbanded darter SR G5 Fish Locally rare Percina sciera dusky darter E G5 Fish Locally rare Polydon spathula paddlefish E FSC G4 Fish Locally rare Sander (Stizostedion) canadensis sauger SR G5 Mayfly Locally rare Baetopus trishae a mayfly SR G1 Mayfly Locally rare Barbaetis benfieldi Benfield's bearded small minnow mayfly SR G2 Mayfly Locally rare Drunella longicornis a mayfly SR G5 Mayfly Locally rare Ephemerella berneri a mayfly SR G3 Mayfly Locally rare Habrophlediodes spp a mayfly SR G? Mayfly Locally rare Homoeneuria cahabensis Cahaba sand-filtering mayfly SR G2 Mayfly Locally rare Macdunnoa brunnea a mayfly SR G2 Mayfly Locally rare Serratella spiculosa spicilose serratellan mayfly SR G2 Mussel Locally rare Alasmidonta viridis slippershell mussel E G4G5 Mussel Locally rare Elliptio dilatata spike SC G5 Mussel Locally rare Lampsilis fasciola wavy-rayed lampmussel SC G4 Mussel Locally rare Pleurobema oviforme Tennessee clubshell SR FSC G3 Mussel Locally rare Villosa constricta notched rainbow SR(PSC) G3 Mussel Locally rare Villosa delumbis Eastern creekshell SR G4 Mussel Locally rare Villosa iris rainbow SC G5 Mussel Locally rare Villosa trabilis Cumberland bean SR E G1 Mussel Locally rare Villosa vanuxemensis mountain creekshell T G4 Snail Locally rare Elimia (Goniobasis) interrupta knotty elimnia E G1 Snail Locally rare Leptoxis virgata smooth mudalia SR FSC G2 Stonefly Locally rare Attaneuria ruralis a stonefly SR G4 Stonefly Locally rare Bolotoperla rossi a stonefly SR G4 Stonefly Locally rare Isoperla frisoni a stonefly SR G5 Stonefly Locally rare Megaleuctra williamsae Williams' rare winter stonefly SR G2 Stonefly Locally rare Zapada chila a stonefly SR G2

* Endangered (E), Threatened (T), or Proposed (PE, PT): as listed by the U.S. Fish and Wildlife Service Sensitive (S): as listed by the U.S. Forest Service (Region 8, 2001) Locally Rare (LR) = Forest Concern: as listed by the National Forests in North Carolina, must meet at least one of the following: Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Appendix F. Nantahala and Pisgah National Forests Rare Plant Species. Species highlighted in bold type are known to be present in one of the forests. Global State Species Common Name Rank Rank Forest Status Geum radiatum Cliff Avens G2 S2 Endangered Gymnoderma lineare Rock Gnome Lichen G2 S2 Endangered Houstonia montana Mountain Bluet G2 S2 Endangered Sagittaria fasciculata Bunched Arrowhead G2 S2 Endangered Sarracenia jonesii Mountain Sweet Pitcher Plant G4T2 S1 Endangered Sarracenia oreophila Green Pitcher Plant G2 S1 Endangered Sisyrinchium dichotomum White Irisette G2 S2 Endangered Helonias bullata Swamp Pink G3 S2 Threatened Hexastylis naniflora Dwarf-flowered Heartleaf G3 S3 Threatened Hudsonia montana Mountain Golden-heather G1 S1 Threatened Isotria medeoloides Small Whorled Pogonia G2 S2 Threatened Liatris helleri Heller's Blazing Star G2 S2 Threatened Solidago spithamaea Blue Ridge Goldenrod G1 S1 Threatened Spiraea virginiana Virginia Spiraea G2 S2 Threatened Aconitum reclinatum Trailing Wolfsbane G3 S3 Sensitive Acrobolbus ciliatus A Liverwort G3? S1 Sensitive Allium cuthbertii Striped Garlic G4 S2 Sensitive Aneura maxima A Liverwort G1 S1 Sensitive Anzia americana A Foliose Lichen G2 S1 Sensitive Aspiromitus appalachianus A Hornwort G1 S1 Sensitive Asplenium x ebenoides Scott's Spleenwort G? S1 Sensitive Bazzania nudicaulis A Liverwort G2G3 S2 Sensitive Berberis canadensis American Barberry G3 S2 Sensitive Boechera patens Spreading Rockcress G3G4 S1 Sensitive Brachydontium trichodes Peak Moss G2 S1 Sensitive Bryocrumia vivicolor Gorge Moss G2 SH Sensitive Buckleya distichophylla Piratebush G2 S2 Sensitive Buxbaumia minakatae Hump-backed Elves G2G3 SH Sensitive Calamagrostis cainii Cain's Reedgrass G1 S1 Sensitive Campylopus paradoxus Paradoxical Campylopus G3? S1 Sensitive Cardamine clematitis Mountain Bittercress G3 S2 Sensitive Carex biltmoreana Biltmore Sedge G3 S3 Sensitive Carex communis var. amplisquama Fox Mountain Sedge G5T3 S1 Sensitive Carex misera Miserable Sedge G3 S3 Sensitive Carex radfordii Radford's Sedge G2 S1 Sensitive Carex roanensis Roan Sedge G2G3 S2 Sensitive Cephalozia macrostachya ssp. australis A Liverwort G4T1 S1 Sensitive Cephaloziella massalongi A Liverwort G3G5 S1 Sensitive Cheilolejeunea evansii A Liverwort G1 S1 Sensitive Chelone cuthbertii Cuthbert's Turtlehead G3 S3? Sensitive Cleistes bifaria Small Spreading Pogonia G4 S2? Sensitive Coreopsis latifolia Broadleaf Coreopsis G3 S3 Sensitive Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Global State Species Common Name Rank Rank Forest Status Danthonia epilis Bog Oatgrass G3G4 S3 Sensitive Delphinium exaltatum Tall Larkspur G3 S2 Sensitive Desmodium ochroleucum Creamy Tick-trefoil G1G2 SH Sensitive Diervilla rivularis Riverbank Bush-honeysuckle G3 S1 Sensitive Diplophyllum apiculatum var. taxifolioides A Liverwort G5T1Q S1 Sensitive Diplophyllum obtusatum A Liverwort G2? S1 Sensitive Ditrichum ambiguum Ambiguous Ditrichium G3? S1 Sensitive Drepanolejeunea appalachiana A Liverwort G2? S1 Sensitive Entodon concinnus Lime Entodon G4G5 S1 Sensitive Ephebe americana A Fructicose Lichen G2G3 S1 Sensitive Euphorbia purpurea Glade Spurge G3 S2 Sensitive Eurybia avita Alexander's Rock Aster G3 SX Sensitive Fissidens appalachensis Appalachian Pocket Moss G2G3 S2S3 Sensitive Fothergilla major Large Witch-alder G3 S3 Sensitive Frullania appalachiana A Liverwort G1? S1? Sensitive Frullania oakesiana A Liverwort G3? S1S2 Sensitive Gentiana austromontana Appalachian Gentian G3 S2? Sensitive Geum geniculatum Bent Avens G1G2 S1S2 Sensitive Geum lobatum Lobed Barren-strawberry G2 S1 Sensitive Glyceria nubigena Smoky Mountain Mannagrass G2 S2 Sensitive Hasteola suaveolens Sweet Indian-plantain G3G4 SH Sensitive Helianthus glaucophyllus Whiteleaf Sunflower G3 S3 Sensitive Heuchera longiflora Long-Flower Alumroot G4 S2 Sensitive Hexastylis contracta Mountain Heartleaf G3 S1 Sensitive Hexastylis rhombiformis French Broad Heartleaf G2 S2 Sensitive Homaliadelphus sharpii Sharp's Homaliadelphus G3 S1 Sensitive Hygrohypnum closteri Closter's Brook-hypnum G3 S1 Sensitive Hymenophyllum tayloriae Gorge Filmy Fern G2 S1S2 Sensitive Hypericum graveolens Mountain St. John's-wort G3 S2S3 Sensitive Hypericum mitchellianum Mitchell's St. John's-wort G3 S2S3 Sensitive Hypotrachyna virginica A Foliose Lichen G1G3 S1S2 Sensitive Ilex collina Long-stalked Holly G3 S1 Sensitive Juglans cinerea Butternut G3 S2S3? Sensitive Juncus caesariensis Rough Rush G2 S1 Sensitive Lejeunea blomquistii A Liverwort G1G2 S1 Sensitive Grandfather Mountain Leptodontium excelsum Leptodontium G2 S1 Sensitive Leptohymenium sharpii Mount Leconte Moss G1 S1 Sensitive Liatris turgida Shale-barren Blazing Star G3 S1S2 Sensitive Lilium grayi Gray's Lily G3 S3 Sensitive Lophocolea appalachiana A Liverwort G1G2 S1 Sensitive Lysimachia fraseri Fraser's Loosestrife G3 S3 Sensitive Malaxis bayardii Appalachian Adder's-mouth G1G2 S1 Sensitive Mannia californica A Liverwort G3? S1 Sensitive Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Global State Species Common Name Rank Rank Forest Status Large-flowered Barbara's Marshallia grandiflora Buttons G2 SH Sensitive Marshallia trinervia Broadleaf Barbara's Buttons G3 SH Sensitive Marsupella emarginata var. latiloba A Liverwort G5T1T2 S1 Sensitive Megaceros aenigmaticus A Hornwort G2G3 S2S3 Sensitive Metzgeria furcata var. setigera A Liverwort G4T1 S1 Sensitive Metzgeria temperata A Liverwort G2Q S1S2 Sensitive Metzgeria uncigera A Liverwort G3 S1 Sensitive Micranthes caroliniana Carolina Saxifrage G3 S3 Sensitive Micropolypodium nimbatum West Indian Dwarf Polypody G4? S1 Sensitive Monotropsis odorata Sweet Pinesap G3 S3 Sensitive Nardia lescurii A Liverwort G3? S? Sensitive Packera millefolium Divided-leaf Ragwort G2 S2 Sensitive Pellia appalachiana A Liverwort G1Q S1? Sensitive Peltigera venosa An Aquatic Lichen G3 S2 Sensitive Penstemon smallii Small's Beardtongue G3 S3 Sensitive Philonotis cernua Dwarf Apple Moss G3? S1 Sensitive Physcia pseudospeciosa A Foliose Lichen G1? S1 Sensitive Plagiochasma intermedium A Liverwort G3? S1 Sensitive Plagiochasma wrightii A Liverwort G3? S1 Sensitive Plagiochila austinii A Liverwort G3 S1S2 Sensitive Plagiochila caduciloba A Liverwort G2 S1 Sensitive Plagiochila echinata A Liverwort G2 S1 Sensitive Plagiochila sharpii A Liverwort G2G3 S2 Sensitive Plagiochila sullivantii var. spinigera A Liverwort G2T1 S1 Sensitive Plagiochila sullivantii var. sullivantii Sullivant's Leafy Liverwort G2T2 S2 Sensitive Plagiochila virginica var. caroliniana A Liverwort G3T2 S1 Sensitive Plagiochila virginica var. virginica A Liverwort G3T3 S1 Sensitive Plagiomnium carolinianum Carolina Star-moss G3 S2 Sensitive Platanthera integrilabia White Fringeless Orchid G2G3 SH Sensitive Platyhypnidium pringlei Pringle's Eurhynchium G2 S1 Sensitive Poa paludigena Bog Bluegrass G3 S1 Sensitive Polytrichum appalachianum Appalachian Haircap Moss G3 S3 Sensitive Porella japonica ssp. appalachiana A Liverwort G5?T1 SNRSensitive Porella wataugensis A Liverwort G2 S1 Sensitive Porpidia diversa A Crustose Lichen G2G3 S1 Sensitive Porpidia herteliana A Crustose Lichen G2G3 S1? Sensitive Prenanthes roanensis Roan Rattlesnakeroot G3 S3 Sensitive Pycnanthemum beadlei Beadle's Mountain-mint G2G4 SNR Sensitive Pycnanthemum torrei Torrey's Mountain-mint G2 S1 Sensitive Radula sullivantii A Liverwort G3 S2 Sensitive Radula voluta A Liverwort G3 S1 Sensitive Rhachithecium perpusillum Budding Tortula G3? S1S2 Sensitive Rhododendron vaseyi Pink-shell Azalea G3 S3 Sensitive Riccardia jugata A Liverwort G1G2 S1? Sensitive Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Global State Species Common Name Rank Rank Forest Status Robinia hartwegii Hartweg's Locust G2 S2 Sensitive Robinia viscosa var. viscosa Clammy Locust G3T3 S3 Sensitive Pinnate-lobed Black-eyed Rudbeckia triloba var. pinnatiloba Susan G5T3 S1 Sensitive Rugelia nudicaulis Rugel's Ragwort G3 S3 Sensitive Sabatia capitata Cumberland Rose Gentian G2 SNR Sensitive Sceptridium jenmanii Alabama Grape Fern G3G4 S2 Sensitive Schlotheimia lancifolia Highlands Moss G2 S1 Sensitive Scopelophila cataractae Agoyan Cataract Moss G3 S1 Sensitive Scutellaria ovata ssp. rugosa var. 1 Appalachian Skullcap G2?Q SH Sensitive Scutellaria saxatilis Rock Skullcap G3 S1 Sensitive Shortia galacifolia var. brevistyla Northern Oconee Bells G2G3T2 S2 Sensitive Shortia galacifolia var. galacifolia Southern Oconee Bells G2G3T2T S2 Sensitive Silene ovata Mountain Catchfly G3 S3 Sensitive Solidago simulans Granite Dome Goldenrod G2 S2 Sensitive Sphagnum flavicomans A Peatmoss G3? SH Sensitive Sphenolobopsis pearsonii A Liverwort G2 S2 Sensitive Splachnum pennsylvanicum Southern Dung Moss G2? SH Sensitive Stachys clingmanii Clingman's Hedge-nettle G2Q S1 Sensitive Sticta limbata A Foliose Lichen G3G4 S1 Sensitive Taxiphyllum alternans Japanese Yew-moss G3? S1 Sensitive Thalictrum macrostylum Small-leaved Meadowrue G3G4 S2 Sensitive Thaspium pinnatifidum Mountain Thaspium G2G3 S1 Sensitive Thermopsis fraxinifolia Ash-leaved Gloden-banner G3? S2? Sensitive Tortula ammonsiana Ammon's Tortula G2? S1 Sensitive Trillium pusillum var. ozarkanum Alabama Least Trillium G3T3 S1 Sensitive Trillium rugelii Southern Nodding Trillium G3 S2? Sensitive Trillium simile Sweet White Trillium G3 S2 Sensitive Tsuga caroliniana Carolina Hemlock G3 S3 Sensitive Viola appalachiensis Appalachian Violet G3 S2 Sensitive Xanthoparmelia monticola A Foliose Lichen G2 S2? Sensitive Adlumia fungosa Climbing Fumitory G4 S2 Locally Rare Agastache nepetoides Yellow Giant-hyssop G5 S1 Locally Rare Agrostis mertensii Arctic Bentgrass G5 S1 Locally Rare Alnus viridis ssp crispa Green Alder G5T5 S1 Locally Rare Amelanchier sanguinea Roundleaf Serviceberry G5 S2 Locally Rare Anaptychia setifera A Foliose Lichen G3G4 S1 Locally Rare Anastrophyllum saxicola A Liverwort G3G4 S1 Locally Rare Anticlea glauca White Camas G5T4T5 S1 Locally Rare Arabis pycnocarpa var. adpressipilis Hairy Rockcress G5T4Q S1 Locally Rare Arethusa bulbosa Bog Rose G4 S1 Locally Rare Arisaema triphyllum ssp. stewardsonii Bog Jack-in-the-Pulpit G5T4 S1 Locally Rare Asclepias purpurascens Purple Milkweed G5? S1? Locally Rare Asplenium bradleyi Bradley's Spleenwort G4 S2 Locally Rare Asplenium monanthes Single-Sorus Spleenwort G4 S1 Locally Rare Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Global State Species Common Name Rank Rank Forest Status Asplenium pinnatifidum Lobed Spleenwort G4 S1 Locally Rare Asplenium ruta-muraria Wall-rue G5 S1 Locally Rare Barbilophozia barbata A Liverwort G4? S1 Locally Rare Barbilophozia hatcheri A Liverwort G5 S1 Locally Rare Betula cordifolia Mountain Paper Birch G5 S1 Locally Rare Botrychium lanceolatum var. angustisegmentum Lance-leaf Moonwort G5TNR S1 Locally Rare Botrychium matricariifolium Daisy-leaf Moonwort G5 S1 Locally Rare Botrychium simplex var. simplex Least Moonwort G5T5 S2 Locally Rare Brachyelytrum aristosum Northern Shorthusk G4G5 S3 Locally Rare Brachymenium andersonii Anderson's Melon-moss GH SH Locally Rare Brachymenium systylium Mexican Melon-moss G5 S1 Locally Rare Brachythecium populeum Matted Feather Moss G5 SH Locally Rare Brachythecium rotaeanum Rota's Feather Moss G3G4 S1 Locally Rare Bromus ciliatus Fringed Brome G5 S1 Locally Rare Bryoerythrophyllum ferruginascens A Moss G4 S1 Locally Rare Bryoerythrophyllum inaequalifolium A Moss G4? S1 Locally Rare Bryoxiphium norvegicum Sword Moss G3G4 S1 Locally Rare Bryum riparium Riverside Bryum G? SH Locally Rare Buchnera americana American Bluehearts G5? SH Locally Rare Buxbaumia aphylla Bug-on-a-stick G4 SH Locally Rare Calamagrostis canadensis Canada Reedgrass G5 S1 Locally Rare Calamagrostis porteri Porter's Reedgrass G4 S1 Locally Rare Caltha palustris Marsh Marigold G5 S1 Locally Rare Campanula aparinoides Marsh Bellflower G5 S2 Locally Rare Campanula rotundifolia Bluebells G5 S1 Locally Rare Campylopus atrovirens var. atrovirens Black Fish Hook Moss G4G5TNR S1? Locally Rare Canoparmelia amabilis Worthy Shield Lichen G1 S1 Locally Rare Cardamine rotundifolia Mountain Watercress G4 S2 Locally Rare Carex barrattii Barratt's Sedge G4 SH Locally Rare Carex bushii Bush's Sedge G4 S1 Locally Rare Carex buxbaumii Brown Bog Sedge G5 S2 Locally Rare Carex careyana Carey's Sedge G4G5 S1 Locally Rare Carex cherokeensis Cherokee Sedge G4G5 S1 Locally Rare Carex cristatella Small-crested Sedge G5 SH Locally Rare Carex deflexa A sedge G5 S1 Locally Rare Carex eburnea Bristle-leaf Sedge G5 S1 Locally Rare Carex hitchcockiana Hitchcock's Sedge G5 S1 Locally Rare Carex leptonervia A Wood Sedge G4 S2 Locally Rare Carex oligocarpa Few-fruited Sedge G4 S2? Locally Rare Carex oligosperma Few-seeded Sedge G5? S1 Locally Rare Carex pedunculata Longstalk Sedge G5 S2 Locally Rare Carex projecta Necklace Sedge G5 S1 Locally Rare Carex purpurifera Purple Sedge G4? S2 Locally Rare Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Global State Species Common Name Rank Rank Forest Status Carex tetanica Rigid Sedge G4 S1 Locally Rare Carex trichocarpa Hairy-fruit Sedge G4 SHLocally Rare Carex trisperma Three-seeded Sedge G5 S1 Locally Rare Carex utriculata Beaked Sedge G5 S1 Locally Rare Carex verrucosa Warty Sedge G4 S2 Locally Rare Carex woodii Wood's Sedge G4 S2 Locally Rare Caulophyllum giganteum Northern Blue Cohosh G4G5Q S1 Locally Rare Celastrus scandens American Bittersweet G5 S2? Locally Rare Cephalozia pleniceps var. carolinana A Liverwort G5T1 S1 Locally Rare Cephalozia pleniceps var. pleniceps A Liverwort G5T5 SH Locally Rare Cephaloziella spinicaulis A Liverwort G3G4 S1 Locally Rare Cetraria arenaria A Foliose Lichen G4 S2 Locally Rare Cetrelia cetrarioides A Foliose Lichen G3 S2 Locally Rare Chamerion platphyllum Purple Willowherb G5 S1 Locally Rare Cheilanthes alabamensis Alabama Lip-fern G4G5 S1 Locally Rare Cheilolejeunea myriantha A Liverwort G3G4 SHLocally Rare Chelone obliqua Red Turtlehead G4 S2 Locally Rare Chenopodium simplex Giant-seed Goosefoot G5 S1 Locally Rare Chiloscyphus muricatus A Liverwort G5 S1 Locally Rare Cirriphyllum piliferum A Moss G5 S1 Locally Rare Cirsium carolinianum Carolina Thistle G5 S2 Locally Rare Cladium mariscoides Twig-Rush G5 S3 Locally Rare Clematis catesbyana Coastal Virgin's-bower G4G5 S2 Locally Rare Clematis occidentalis Mountain Clematis G5 S1 Locally Rare Coeloglossum viride var. virescens Long-bracted Frog Orchid G5T5 S1 Locally Rare Conioselinum chinense Hemlock-parsley G5 S1 Locally Rare Corallorhiza wisteriana Spring Coral-root G5 S2 Locally Rare Coreopsis grandiflora var. grandiflora Large-flowered Tickseed G5T4T5 S1 Locally Rare Corydalis micrantha ssp. micrantha Slender Corydalis G5T4 S1 Locally Rare Crocanthemum bicknellii Plains Sunrose G5 S1 Locally Rare Crocanthemum propinquum Creeping Sunrose G4 S1 Locally Rare Croton monanthogynus Prarie-tea Croton G4 S1 Locally Rare Cypripedium parviflorum var. parviflorum Small Yellow Lady's-slipper G5T3T5 S1S2 Locally Rare Cystopteris fragilis Fragile Fern G5 S1 Locally Rare Cystopteris tennesseensis Tennessee Bladder-fern G5 S1 Locally Rare Cystopteris tenuis Upland Bladder-fern G4G5 S1 Locally Rare Dalibarda repens Robin Runaway G5 S2 Locally Rare Dendrolycopodium dendroideum Tree Ground-pine G5 S2 locally Rare Deschampsia cespitosa ssp. glauca Tufted Hairgrass G5T5 S1 Locally Rare Diarrhena americana Eastern Beakgrass G4? S1 Locally Rare Dicentra eximia Bleeding Heart G4 S2 Locally Rare Dichodontium pellucidum A Moss G4G5 S2 Locally Rare Dicranella varia Variable Fork Moss G5 S1? Locally Rare Dicranum undulatum Bog Broom-moss G5 S1 Locally Rare Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Global State Species Common Name Rank Rank Forest Status Diplophyllum taxifolium var. mucronatum A Liverwort G5T1 S1 Locally Rare Ditrichum rhynchostegium Golden Tread Moss G3G5 S1? Locally Rare Dodecatheon meadia var. meadia Eastern Shooting Star G5T5 S2 Locally Rare Draba ramosissima Branching Draba G4 S2 Locally Rare Echinacea purpurea Purple Coneflower G4 S1 Locally Rare Elymus trachycaulus ssp. trachycaulus Slender Wheatgrass G5T5 S1 Locally Rare Encalypta procera Extinguisher Moss G4G5 S1 Locally Rare Entodon compressus Ftattened Entodon G4 S1 Locally Rare Entodon sullivantii Sullivant's Entodon G3G4 S2 Locally Rare Ephebe lanata A Fructicose Lichen G5 S1 Locally Rare Ephebe solida A Fructicose Lichen G3G4 S1 Locally Rare Epilobium ciliatum Purpleleaf Willowherb G5 S2 Locally Rare Eucladium verticillatum Lime-seep Eucladium G5 S1 Locally Rare Eupatorium godfreyanum Godfrey's Throughwort G4 S2 Locally Rare Euphorbia commutata Cliff Spurge G5 S1 Locally Rare Filipendula rubra Queen-of-the-Prairie G4G5 S1 Locally Rare Fleischmannia incarnata Pink Throughwort G5 S2 Locally Rare Fontanalis sphagnifolia A Water Moss G3G5 S1? Locally Rare Frasera caroliniensis Columbo G5 S2S3 Locally Rare Gentianopsis crinita Fringed Gentian G5 S1 Locally Rare Geum aleppicum Yellow Avens G5 S1 Locally Rare Geum laciniatum var. trichocarpum Rough Avens G5T3T5 S1 Locally Rare Glyceria laxa Lax Mannagrass G5 S1 Locally Rare Gymnocarpium appalachianum Appalachian Oak Fern G3 S1 Locally Rare Hackelia virginiana Virginia Stickseed G5 S1S2 Locally Rare Helenium brevifolium Littleleaf Sneezeweed G3G4 S1 Locally Rare Helianthus occidentalis var. dowellianus Naked-stem Sunflower G2G3 SX Locally Rare Herzogiella turfacea Flat Stump Moss G4G5 S1? Locally Rare Heterodermia appalachensis A Foliose Lichen G2G4 S1S2 Locally Rare Heuchera pubescens Downy Alumroot G4? S1 Locally Rare Hexalectris spicata Crested Coralroot G5 S2 Locally Rare Hierochloe odorata Holy Grass G5 S1 Locally Rare Homalia trichomanoides Lime Homalia G5 S1 Locally Rare Houstonia longifolia var. glabra Granite Dome Bluet G4G5T2Q S3 Locally Rare Huperzia porophila Rock Fir Clubmoss G4 S2 Locally Rare Hydrastis canadensis Goldenseal G4 S2 Locally Rare Hydrophyllum macrophyllum Largeleaf Waterleaf G5 S2 Locally Rare Hylocomiastrum umbratum Shaded Feather Moss G5 S1? Locally Rare Hymenocallis occidentalis Hillside Spider-lily G4? SH Locally Rare Hypotrachyna sinuosa A Foliose Lichen G5 S1 Locally Rare Jeffersonia diphylla Twin Leaf G5 S1 Locally Rare Juncus trifidus Highland Rush G5 S1 Locally Rare Juniperus communis var. depressa Dwarf Juniper G5T5 S1 Locally Rare Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Global State Species Common Name Rank Rank Forest Status Leptodontium flexifolium Pale-margined Leptodontium G5 S1 Locally Rare Leptoscyphus cunefolius A Liverwort G4G5 S2 Locally Rare Liatris aspera Rough Blazing Star G4G5 S1 Locally Rare Liatris microcephala Small-head Blazing Star G3G4 S1 Locally Rare Liatris squarrulosa Earle's Blazing Star G4G5 S2 Locally Rare Lilium canadense ssp. canadense Yellow Canada Lily G5T4? S1 Locally Rare Lilium canadense ssp. editorum Red Canada Lily G5T4 S1 Locally Rare Lilium philadelphicum var. philadelphicum Wood Lily G5T4T5 S2 Locally Rare Liparis loeselii Fen Orchid G5 S1 Locally Rare Lobaria scrobiculata Textured Lungwort G3G4 S2? Locally Rare Lonicera canadensis American Fly-honeysuckle G5 S2 Locally Rare Lophozia excisa A Liverwort G5 S1 Locally Rare Lophozia heterocolpos A Liverwort G5 S1 Locally Rare Lycopodiella inundata Bog Clubmoss G5 S1 Locally Rare Lysimachia hybrida Lowland Loosestrife G5 S1 Locally Rare Macrocoma sullivantii G3G5 S2 Locally Rare Marsupella funckii A Liverwort G4G5 S1 Locally Rare Meehania cordata Meehania G5 S2 Locally Rare Melanelia stygia A Foliose Lichen G4G5 S1S2 Locally Rare Melica nitens Three-flowered Melica G5 S1 Locally Rare Micranthes pensylvanica Swamp Saxifrage G5 S1 Locally Rare Milium effusum Millet-grass G5 SH Locally Rare Minuartia groenlandica Greenand Sandwort G5 S2 Locally Rare Monarda media Purple Bee-balm G4? S1? Locally Rare Muhlenbergia glomerata Bristly Muhly G5 S1 Locally Rare Muhlenbergia sobolifera Rock Muhly G5 SH Locally Rare Mylia tayorii A Liverwort G5 S1 Locally Rare Nardia scalaris ssp. scalaris A Liverwort G5T5 S1 Locally Rare Oenothera perennis Perennial Sundrops G5 S1 Locally Rare Orotrichum strngulatum Drummond Moss G4 SH Locally Rare Orthodontium pellucens Translucent Orthodontium G4 S1 Locally Rare Packera paupercula Balsam Ragwort G5 S1? Locally Rare Packera plattensis Prairie Ragwort G5 S1 Locally Rare Packera schweinitziana Schweinitz's Ragwort G5? S2 Locally Rare Palamocladium leskeoides Palamocladium G3G5 S1 Locally Rare Panicum lithophilum Flatrock Panic Grass G2G3Q S1 Locally Rare Pannaria conoplea A Foliose Lichen G3G4 S1 Locally Rare Large-leaved Grass-of- Parnassia grandifolia parnassus G3 S2 Locally Rare Parthenium auriculatum Glade Wild Quinine G3G4 S2 Locally Rare Pedicularis lanceolata Swamp Lousewort G5 S1 Locally Rare Phegopteris connectilis Northern Beech Fern G5 S2 Locally Rare Phlox subulata Moss Pink G5 S1 Locally Rare Pilosium chlorophyllum A Moss GNR S1? Locally Rare Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Global State Species Common Name Rank Rank Forest Status Plagimnium rostratum Long-beaked Thread Moss G5 S1? Locally Rare Plagiochila corniculata A Liverwort G5 S2 Locally Rare Plagiochila ludoviciana A Liverwort G5 S1 Locally Rare Plagiomnium ellipticum Marsh Magnificent Moss G5 S1? Locally Rare Platanthera flava var. herbiola Northern Green Orchid G4T4Q S1? Locally Rare Platanthera grandiflora Large Purple-fringed Orchid G5 S2 Locally Rare Platanthera peramoena Purple Fringeless Orchid G5 S2 Locally Rare Long-beaked Water Feather Plathynidium riparioides Moss G4 S1? Locally Rare Platydicta confervoides Alga-like Matted-moss G4G5 S1 Locally Rare Poa palustris Swamp Bluegrass G5 S1 Locally Rare Poa saltuensis A Bluegrass G5 S1 Locally Rare Pogonatum dentatum Hair-like Hair-cap G3G5 S1? Locally Rare Pohlia lescuriana Spherical Bulb Nodding Moss G4? S1? Locally Rare Pohlia melanodon Pink-fruited Thread Moss G4? S1? Locally Rare Polygala senega Seneca Snakeroot G4G5 S2 Locally Rare Polytrichastrum alpinum Alpine Hair Moss G4G5 S1? Locally Rare Prenanthes alba White Rattlesnake Root G5 S2? Locally Rare Ptilidium ciliare A Liverwort G5 S1 Locally Rare Pycnanthemum virginianum Virginia Mountain-mint G5 S1 Locally Rare Quercus prinoides Dwarf Chinqupin Oak G5 S1 Locally Rare Racomitrium aciculare Dark Mountain Fringe Moss G3G5 S1 Locally Rare Ranunculus fascicularis Early Buttercup G5 S1 Locally Rare Rhabdoweisia creulata Himalayan Ribbed-weissia G3G4 S1 Locally Rare Rhodiola rosea Roseroot G5 S1 Locally Rare Rhododendron cumberlandense Cumberland Azalea G4? S1 Locally Rare Rhododendron prinophyllum Early Azalea G5 S1 Locally Rare Rhynchospora alba Northern White Beaksedge G5 S2 Locally Rare Rhytidadelphus subpinnatus A Moss GU S1? Locally Rare Rhytidium rugosum Golden Tundra-moss G5 S2 Locally Rare Robinia hispida var fertilis Fruitful Locust G5T1Q S1 Locally Rare Robinia hispida var kelseyi Kelsey's Locust G5T1 S1 Locally Rare Rubus idaeus ssp. strigosus Red Raspberry G5T5 S2? Locally Rare Ruellia purshiana Pursh's Wild-petunia G3 S2 Locally Rare Scapania mucronata ssp. mucronata A Liverwort G5 S1 Locally Rare Sceptridium multifidum Leathery Grape Fern G5 S1 Locally Rare Sceptridium oneidense Blunt-lobed Grape Fern G4Q S2 Locally Rare Scopelophila ligulata Copper Moss G5? S1 Locally Rare Scutellaria galericulata Hooded Skullcap G5 SHLocally Rare Sedum glaucophyllum Cliff Stonecrop G4 S2 Locally Rare Smilax hugeri Huger's Carrion-flower G4 S2 Locally Rare Smilax lasioneura Blue Ridge Carrion-flower G5 S1 Locally Rare Solidago rigida var. rigida Prairie Bold Goldenrod G5T5 S1 Locally Rare Solidago squarrosa Squarrose Goldenrod G4? SH Locally Rare Solidago uliginosa Bog Goldenrod G4G5 S1S2 Locally Rare Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Global State Species Common Name Rank Rank Forest Status Solidago ulmifolia Elm-leaf Goldenrod G5 S1? Locally Rare Spartina pectinata Freshwater Cordgrass G5 S1 Locally Rare Sphagnum angustifolium Narrowleaf Peatmoss G5 S1 Locally Rare Sphagnum capillifolium Northern Peatmoss G5 S1 Locally Rare Sphagnum fallax Pretty Peatmoss G5 S1 Locally Rare Sphagnum flexuosum Flexuous Peatmoss G5Q S1 Locally Rare Sphagnum fuscum Brown Peatmoss G5 S1 Locally Rare Sphagnum pylaesii Simple Peatmoss G4 S1 Locally Rare Sphagnum russowii Russow's Peatmoss G5 S1 Locally Rare Sphagnum squarrosum Squarrose Peatmoss G5 S1 Locally Rare Sphagnum subsecundum Orange Peatmoss G5T4 S1 Locally Rare Sphagnum tenellum Delicate Peatmoss G5 S1 Locally Rare Spigelia marilandica Pink root G4 S1 Locally Rare Spiranthes lacera var. lacera Northern Slender Ladies-tresses G5T5 SH Locally Rare Spiranthes lucida Shining Ladies'-tresses G5 S1 Locally Rare Spiranthes ochroleuca Yellow Ladies'-tresses G4 SH Locally Rare Sporobolus heterolepis Prairie Dropseed G5 S1 Locally Rare Stachys cordata Heartleaf Hedge-nettle G5? S1 Locally Rare Stachys eplingii Epling's Hedge-nettle G5 S1 Locally Rare Stenanthium leimanthoides Pinebarren Death-camas G4Q S1 Locally Rare Stewartia ovata Mountain Camellia G4 S2 Locally Rare Streptopus amplexifolius White Mandarin G5 S1 Locally Rare Symphyotrichum oblongifolium Aromatic Aster G5 S1 Locally Rare Symphyotrichum rhiannon Rhiannon's Aster G1 S1 Locally Rare Symphyotrichum shortii Short's Aster G5 SH Locally Rare Synandra hispidula Synandra G4 SH Locally Rare Taxus canadensis Canada Yew G5 S1 Locally Rare Thelypteris simulata Bog Fern G4G5 S1 Locally Rare Thermopsis mollis Appalachian Gloden-banner G3G4 S2 Locally Rare Torreyochloa pallida Pale Mannagrass G5 S1 Locally Rare Tortula fragilis Fragile Tortula G5 S1 Locally Rare Tortula papillosa Papillose Tortula G5 S1 Locally Rare Triantha glutinosa Sticky Bog Asphodel G4G5 S1 Locally Rare Trichomanes boschianum Appalachian Filmy-fern G4 S1 Locally Rare Trichomanes petersii Dwarf Filmy-fern G4G5 S2 Locally Rare Trichophorum cespitosum Deerhair Bulrush G5 S2S3 Locally Rare Trichostema brachiatum Glade Bluecurls G5 S1 Locally Rare Trichostema setaceum Narrowleaf Bluecurls G5 S2 Locally Rare Trientalis borealis Starflower G5 S1 Locally Rare Trillium discolor Mottled Trillium G4 S1 Locally Rare Trillium flexipes Bent White Trillium G5 SH Locally Rare Trillium recurvatum Prairie Trillium G5 S1 Locally Rare Trisetum spicatum Soft Trisetum G5 SX Locally Rare Tritomaria exsectiformis ssp. exsectiformis A Liverwort G5T5 SH Locally Rare Environmental Assessment Nantahala and Pisgah National Forests Non-native Invasive Plant Control Appendices

Global State Species Common Name Rank Rank Forest Status Turritis glabra Tower Mustard G5 S1 Locally Rare Usnea angulata Old Man's Beard G3G5 S1 Locally Rare Utricularia cornuta Horned Bladderwort G5 S1S2 Locally Rare Utricularia minor Small Bladderwort G5 SH Locally Rare Vaccinium macrocarpon Cranberry G4 S2 Locally Rare Veronica americana American Speedwell G5 S2 Locally Rare Viola walteri Prostrate Blue Violet G4G5 S1 Locally Rare Warnstorfia fluitans Floating Sickle-moss G5 S1 Locally Rare Woodsia appalachiana Appalachian Cliff Fern G4 S1 Locally Rare Woodsia ilvensis Rusty Cliff Fern G5 S1 Locally Rare Biological Assessment Nantahala and Pisgah National Forests Non-Native Invasive Plant Control

I. INTRODUCTION The Nantahala and Pisgah National Forests (NPNFs) are proposing a multi-year project to control infestations of non-native invasive plants on the NPNFs. The project area is located in western North Carolina and includes infested areas across the NPNFs. This action is needed because invasive species have been identified by the Forest Service as one of four principal threats to the nation’s forests and grasslands. Without intervention, weed infestations will continue to expand exponentially and impacts to environmental and social resources will intensify annually. This Biological Assessment (BA) was prepared to address potential project-related impacts to species listed as proposed, threatened, or endangered by the United States Fish and Wildlife Service (Service). It was prepared in accordance with USFS manual 2671.44 and 2672.42 and regulations set forth in Section 7(a) (2) of the Endangered Species Act.

II. PROPOSED ACTION The proposed action is to treat non-native invasive plant (NNIP) infestations across the Nantahala and Pisgah National Forests, using an integrated combination of manual, mechanical, cultural, and chemical control treatment methods. The treatments would begin in the spring of 2009, and will potentially occur until changed conditions require a new analysis. The proposed treatments would be implemented on infestation sites, up to 1100 acres annually, across the Nantahala and Pisgah National Forests, excluding Wilderness and Wilderness study areas. Any combination of the following mechanical, cultural, and chemical methods could be annually accomplished across 1,100 acres of treatment. Proposed Manual and Mechanical Methods: Manual or mechanical methods would be the principle method for controlling small spot infestations. Examples of hand tools that might be used include shovels, saws, axes, loppers, hoes, or weed-wrenches. Mechanical methods could include cutting with a string trimmer, chainsaw, brush blade, or mower. Proposed Spot Treatments Using Propane Weed Torch: A propane weed torch would be used to spot-burn targeted invasive plants. The weed torch works not by starting a ground fire but by using the torch’s flame to burn the target plant. The weed torch would only be used during times of low fire danger. Their use would primarily be within plant communities that have a low potential to carry fire, such as southern Appalachian bogs or rich cove forest communities. The weed torch is known to be effective with some invasive shrubs but would be tested on other high-priority invasive plants as an alternative to herbicide use. Proposed Chemical (Herbicide) Methods: The objectives of herbicide use would be to control NNIP infestations where manual or mechanical means would be cost-prohibitive or result in excessive soil disturbance or other resource damage. All herbicides would be used according to manufacturer’s label direction for rates, concentrations, exposure times, and application methods. Herbicides would be directly applied to the target plants (i.e., the NNIP species) using spot treatment. Spot treatments would consist of various techniques for applying herbicides to target plants with minimal impact to desirable vegetation and other non-target organisms, including humans. Herbicide drift would be greatly reduced with spot treatments (relative to broad-scale or aerial application). Techniques that could be used include spraying foliage using a hand-held wand or backpack sprayer, basal bark and stem treatments using spraying or painting (wiping) methods, cut surface treatments (spraying or wiping), and woody stem injections. No herbicides would be applied aerially. Only formulations approved for aquatic-use would be applied in or adjacent to wetlands, lakes, and streams, in accordance with label direction. Herbicides that potentially could be utilized include the following:  Glyphosate A non-selective, broad spectrum, systemic herbicide that is used to control many grasses, forbs, vines, shrubs, and trees. Specific formulations of glyphosate have been labeled for aquatic application. Formulations labeled for aquatic sites can be effective on both emergent aquatics and shoreline vegetation. This chemical is a growth inhibitor that can be applied through direct foliar application, stem injection, and cut-surface application. It has been proven effective on a wide variety of NNIP species. Commercial brand names include but are not limited to, AccordTM and RodeoTM.  Triclopyr A selective herbicide that controls invasive, broadleaf herbaceous and woody plants, but has little to no effect on grasses. This chemical acts as a growth regulator and can be applied as a direct foliar application, stem injection, or cut- surface treatment. Specific formulations of triclopyr have been labeled for aquatic application. Formulations labeled for aquatic sites can be effective on both emergent aquatics and shoreline vegetation. It has been proven effective on a wide variety of NNIP species. Commercial brand names include but are not limited to, Garlon 3ATM, Garlon 4TM, and Pathfinder IITM.  Clopyralid A selective herbicide affecting broadleaf herbs, primarily legumes, composites, and smartweeds. This chemical acts as a growth regulator and is typically applied as a direct foliar application. With selectivity to legumes, this chemical is particularly useful in the control of kudzu, mimosa, and lespedeza. Commercial brand names include but are not limited to, TranslineTM.  Imazapic A selective herbicide primarily used to control cool season grasses. Warm season grasses, many wildflower species, and legumes are resistant, while many cool season grasses and broadleaf weeds are susceptible. Commercial brand names include but are not limited to, PlateauTM.  Metsulfuron methyl A systemic herbicide that is selective to woody species, broadleaf species, and many annual grasses. It has been proven to be effective in the control of lespedeza, Japanese honeysuckle, kudzu, and multiflora rose. Commercial brand names include but are not limited to, EscortTM.  Dicamba A somewhat selective herbicide that controls most annual and perennial broadleaf herbs and some woody species. Care must be taken as it can damage or kill hardwood and pine seedlings, but has little to no effect on grasses. This chemical is known to be effective in the control of autumn olive. Commercial brand names include but are not limited to VanquishTM and OverdriveTM. The proposed treatments will be concentrated along areas with the greatest potential for infestations: 1) road corridors, 2) trail corridors, 3) stream corridors, 4) wildlife openings, 5) registered NC Natural Heritage Program natural areas (management area 13), 6) other natural areas with rare species or rare plant communities, and 7) prescribed burns. Control projects will be prioritized for known infestations affecting federally listed species or suitable habitat for that species.

A list of the 17 highest priority invasive plant species across the Nantahala and Pisgah National Forests has been developed from both botanical surveys completed during the past 15 years and NNIP inventories that were conducted in 2002-2003 across selected watersheds (Table 1). NNIP inventories conducted in 2002-2003 recorded spot occurrences of one or more of the 17 species on over 70% of plots along roadsides. These species were assigned a relative priority for treatment based on their known impacts on rare species and communities, their ability to rapidly spread, and their ability to persist in the forest. These species have been identified as the highest priority species on the NPNFs at the present time but the list will be updated as needed, based on new information regarding species’ spread and infestation characteristics.

III. EXISTING CONDITION The proposed action has potential treatment areas dispersed across a wide variety of landscapes. All the major plant communities on the NPNFs potentially could be within a treatment area and most could be impacted by NNIP. No complete plant community survey has been completed across the NPNFs. Forest types have mostly been mapped across the two forests however the combining of certain types, such as Acidic Cove Forests and Rich Cove Forests, makes its usefulness for predicting the likelihood of NNIP difficult. The 2nd approximation of a model of common ecological zones across the southern Appalachians was recently completed by Simon (2008). Ecological zones represent a unit of land delineating the environment that can support a specific plant community or plant community group. Identifying types by environmental factors such as moisture gradients, elevation, geological formations, annual average precipitation, distance to streams and local relief can be useful for predicting landscapes susceptible to NNIP outbreaks. Table 1. Priority non-native invasive plant species on the NPNFs.

Scientific Name Common Name Priority Treatment

Celastrus orbiculatus Oriental bittersweet High Paulownia tomentosa Princess tree High

Spiraea japonica Japansese meadowsweet High Polygonum cuspidatum Japanese knotweed High Microstegium vimineum Japanese stiltgrass High Ligustrum sinense/vulgare Chinese/European privet High Miscanthus sinensis Chinese silver grass High Rosa multiflora Multiflora rose High Elaeagnus umbellate/pungens Autumn/Thorny olive Medium Lonicera japonica Japanese honeysuckle Medium Alliaria petiolata Garlic mustard Medium Centaurea petiolata Spotted knapweed Medium Tussilago farfara Coltsfoot Medium Albizia julbrissin Silk-tree Medium

Ailanthus altissima Tree of heaven Medium Pueraria montana var. lobata Kudzu Medium Dioscorea oppositifolia Chinese yam Medium

Table 2. Comparison of ecological zones across the Nantahala and Pisgah National Forests, within the potential treatment areas. Activity % Potential Treatment Zone on Ecological Types NP Acres % on NP Area Alternate 3 Forest Mesic Oak-Hickory Forest 279497 26.9% 19056 6.8% Acidic Cove Forest 229610 22.1% 54054 23.5% Pine-Oak/Heath Forest 132746 12.8% 9263 7.0% Rich Cove Forest 102890 9.9% 11374 11.1% Mixed Oak/Rhododendron Forest 94850 9.1% 9037 9.5% High Elevation Red Oak Forest 79636 7.7% 8379 10.5% Northern Hardwood Cove Forest 28945 2.8% 4047 14.0% Dry-Mesic Oak-Hickory Forest 25790 2.5% 3301 12.8% Spruce - Fir Forest 17899 1.7% 4176 23.3% Shortleaf Pine-Oak Forest 13423 1.3% 2119 15.8% Alluvial Forest 12889 1.2% 4071 31.6% Northern Hardwood Slope Forest 11978 1.2% 477 4.0% Chestnut Oak/Heath Forest 8019 0.8% 376 4.7% Shortleaf-Pine-Oak/Heath Forest 2165 0.2% 153 7.1% Grassy Bald 403 <0.1% 147 36.5% Heath Bald 92 <0.1% 11 12.0% Totals 1040832 130041 There are about 1,040,000 acres in the NP. Table 2 lists the 16 ecological zones with their abundance across the two forests. Mesic Oak-Hickory Forest is the most abundant ecological zone covering slightly greater than 25% of the landscape. Acidic Cove Forest is the second most common ecological zone occurring over slightly less than 25% of the landscape. Two other zones represent slightly more than or just less than 10% of the forest coverage, Pine –Oak/Heath Forest and Rich Cove Forest, respectively. This database shows that about 47% of the NP is dominated by hardwood types, primarily oaks, 37% is dominated by mesic hardwoods with or without a hemlock component, another 14% is dominated by mixed yellow pine-oak types, and less than 2% by spruce and fir. The remaining types, such as Grassy Bald and Heath Bald are much less common across the NPNFs. As a result, they are difficult to map or model. Other even more uncommon types, such as bogs or rock outcrops, were impossible to model and would be embedded within the other zones.

Table 3. Number of NNIP that have been located within ecological zones or groups of ecological zones.

High Acidic Northern Elevation Mesic Oak- Dry-Mesic Xeric Grassy Heath Fraser Invasive Plant Species Cove1/ Cove 2/ Hardwoods 3/ Red Oak Hickory Oak Hickory Pine 4/ Bald Bald Fir Trees Ailanthus altissima 1 0 0 0 1 1 1 0 0 0 Paulownia tomentosa 1 0 0 0 1 1 1 0 0 0 Albizia julibrissin 1 0 0 0 1 1 0 0 0 0 Shrubs Ligustrum sinense/vulgare 1 1 0 0 0 0 0 0 0 0 Polygonum cuspidatum 1 0 1 0 0 0 0 0 0 0

Rosa multiflora 1 1 1 1 1 0 0 1 0 0 Spiraea japonica 10 1 0 1 0 0 0 0 0 Elaeagnus umbellata 1 0 1 1 1 1 0 1 0 0 Vines

Celastrus orbiculatus 11 1 0 1 0 0 1 0 0 Lonicera japonica 1 1 1 0 1 1 0 0 0 0 Pueraria lobata 1 0 0 0 1 1 0 0 0 0 Dioscorea oppositifolia 1 1 1 0 1 0 0 0 0 0 Herbaceous Alliaria petiolata 1 0 1 0 0 0 0 0 0 0 Microstegium vimineum 1 1 1 0 1 0 0 0 0 0 Tussilago farfara 10 1 1 1 0 0 1 0 0 Miscanthus sinensis 1 0 1 0 1 1 1 0 0 0 Centaurea biebersteinii 00 0 0 1 1 1 0 0 0 Total Invasion 16 6 11 3 14 8 4 4 0 0

1/ Cove = Rich Cove and Montane Alluvial Cove Forests 2/ Acidic Cove = Acidic Cove and Mixed Oak/Heath Forests 3/ Northern Hardwoods = Northern Hardwood Cove and Northern Hardwood Slope Forests 4/ Xeric Pine = Pine-Oak/Heath, Shortleaf Pine-Oak, Shortleaf Pine-Oak/Heath, and Chestnut Oak/Heath Forests There is incomplete information on the amount of NNIS infestations present across the NP. An invasive plant inventory was completed within 1181 permanent plots across randomly selected watersheds within the NP in 2002 and 2003. In addition, a more general inventory across the two forests from 2000 to the present has detailed the most frequently encountered invasive species, the level of infestations, and those plant communities most at risk. Not all Ecological Zones have the same level of infestations. Table 3 lists the species have been documented within similar ecological zone groups. Mesic cove zones such as Alluvial Forest and Rich Cove Forest are the most susceptible to invasions.

While dense infestations can occur within each treatment area the level of infestation (density and number of species) commonly decreases from wildlife openings to road corridors to riparian areas to natural areas, trails, and recently burned sites as displayed in the following table:

Table 4. Number of recorded NNIP in potential treatment areas and risk of spread within separate areas. Treatment Areas Level of Risk Invasive Species Wildlife Openings Highest 16 Roads High 16 Riparian Zone High 16 Trails Lower 14 Natural Areas Lower 12 Prescribed Burns Lowest 5

Even though the number of targeted NNIP species recorded within most of the treatment areas may not vary, the patch size of an outbreak is much greater within wildlife openings and along roads. Patch sizes can vary greatly within infestations from as large a 5-10 acre kudzu patch in a road corridor to a 10 square feet patch of wild yam along a riparian zone in a older cove forest.

IV. SPECIES CONSIDERED AND EVALUATED All federally threatened or endangered plant or animal species that occur or could occur on the NPNFs were initially considered in this analysis. The list of federally listed species was compiled by (1) reviewing U.S. Fish & Wildlife Service county occurrence records for known and potential species, (2) reviewing element occurrence (EO) records of federally listed species as maintained by the North Carolina Natural Heritage Program, (3) reviewing U.S. Forest Service rare plant and animal inventory records, and (4) consulting with individuals both in the public and private sector who are knowledgeable of the area and its flora or fauna. A single wildlife species, the southern bog turtle is federally listed as threatened due to similarity of appearance and section 7 regulations are not applicable. This analysis was based on the best available science at the present time.

The initial list included 14 plants and 12 wildlife species (Table 2). Of these 26 species, sixteen have been documented on National Forests in North Carolina lands (bold highlight in Table 5). There are 9 plant species (3 endangered, 6 threatened), 1 aquatic species (endangered), and 6 terrestrial widlife species ( 4 endangered, 1 threatened, and 1 threatened because of similarity of appearance). Table 5. Occurrence and status of federally endangered and threatened species on the Nantahala and Pisgah National Forests. Highlighted species are those that have been documented within either the Nantahala or Pisgah National Forest. Scientific Name Common Name Status Lifetype NP Occurrence Alasmidonta raveneliana Appalachian Elktoe Endangered Mollusk Occurs Pegias fabula Littlewing Pearlymussel Endangered Mollusk May Occur Erimonax monacha Spotfin Chub Threatened Fish May Occur Mesodon clarki nantahala Noonday Globe Threatened Mollusk Occurs Nicrophorus americanus American Burying Beetle Endangered Insect NC Extirpated Microhexura montivaga Spruce-fir Moss Spider Endangered Arachnid Occurs Felis concolor cougaur Eastern Cougar Endangered Mammal NC Extirpated Glaucomys sabrinus coloratus Northern Flying Squirrel Endangered Mammal Occurs Myotis grisescens Gray Bat Endangered Mammal Occurs Myotis sodalis Indiana Bat Endangered Mammal Occurs Corynorhinus townsendii virginianus Virginia Big-eared Bat Endangered Mammal May Occur Clemmys muhlenbergii Southern Bog Turtle Threatened Reptile Occurs (Similarity of appearance) Gymnoderma lineare Rock Gnome Lichen Endangered Lichen Occurs Geum radiatum Spreading Avens Endangered Vascular Plant Occurs Helonias bullata Swamp Pink Threatened Vascular Plant Occurs Hexastylis naniflora Dwarf-leaved Heartleaf Threatened Vascular Plant May Occur Houstonia montana Roan Mountain Bluet Endangered Vascular Plant Occurs Hudsonia montana Mountain Golden Heather Threatened Vascular Plant Occurs Isotria medeloides Small whorled Pogonia Threatened Vascular Plant Occurs Liatris helleri Heller’s Blazing Star Threatened Vascular Plant Occurs Sagittaria fasciculata Bunched Arrowhead Endangered Vascular Plant May Occur Sarracenia jonesii Mountain Sweet Pitcher Plant Endangered Vascular Plant May Occur Sarracenia oreophila Green Pitcher Plant Endangered Vascular Plant May Occur Sisyrinchium dichotomum White Irisette Endangered Vascular Plant May Occur Solidago spithamea Blue Ridge Goldenrod Threatened Vascular Plant Occurs Spiraea virginiana Virginia Spiraea Threatened Vascular Plant Occurs

A geographic information system was used to examine the distribution of EOs on the two forests and general vicinity. These records and distribution maps were reviewed to determine areas of known populations of rare species within the proposed project area. Based on these information sources the potential affected rare species list for control of invasive plants was filtered to derive those species with the greatest likelihood of occurrence (Table 6). Species were eliminated based on range information such as only occurring in the foothills at lower elevations in NC. Previous surveys on the closest NPNFs have not located these species in suitable habitat. Other species were excluded from further analysis because occupied habitat, such as High Elevation Rocky Summits, are not known to have invasive plant infestations and the risk of potential invasion is low. Various animal species were eliminated if they are readily mobile that allow them to escape for the duration of control activities or they occur in microhabitat, such as muck, that would buffer any negative impacts. Indiana bats are not known to roost in targeted NNIP trees, such as princess tree or silktree. Furthermore the Indiana Bat BO on activities across the NPNFs recommends control of NNIP trees to improve suitable habitat for the bat. Some species were eliminated since there range across the forest is relative well-known and either the species occurs off the NPNFs (spotfin chub and littlewing pearlymussel), or infestations are not known on occupied or formerly occupied sites. Finally two species, eastern cougar and burying beetle, were dropped from further consideration since it is believed to be extirpated from the Southern Appalachians. It is acknowledged new populations could be located in the future. T&E impacts not addressed in this BA (new location of T&E species or new NNIP invading known T&E occurrence[s]) will require reinitiation with USFWS.

Table 6. Preferred habitat and analysis for federally endangered and threatened species listed on or near the Nantahala and Pisgah National Forests. Scientific Name Status Preferered Habitat Analysis

Alasmidonta raveneliana Endangered Riffles, runs, and pools relatively free of silt 1 Pegias fabula Endangered Riffles, runs, and pools relatively free of silt 4 Erimonax monacha Threatened Clear water over gravel, bedrock, or boulders in moderate current streams in Little Tennessee River 4 drainage Mesodon clarki nantahala Threatened Wet rock cliffs in Nantahala Gorge 1 Nicrophorus americanus Endangered Small vertebrate carrion 6 Microhexura montivaga Endangered In moss of Spruce-Fir forests 3 Felis concolor cougaur Endangered Extensive forests, remote areas 6 Glaucomys sabrinus coloratus Endangered High elevation forests, northern hardwoods and 2 spruce-fir Myotis grisescens Endangered Caves (roosting), feeds over water 2, 3 Myotis sodalis Endangered Roots in hollow trees or under loose bark (warmer 2 months), in caves (winter). Corynorhinus townsendii Endangered Caves (roosting) 2,3 virginianus Clemmys muhlenbergii Threatened (S/A) Bogs, wet pastures, wet thickets 2 Gymnoderma lineare Endangered High Elevation Rocky Summit, Moist Rock Outcrop 3 in Acidic Cove in Gorge Geum radiatum Endangered High elevation rocky summit 3 Helonias bullata Threatened Southern Appalachian Bog, Swamp Forest-Bog 1 Complex Hexastylis naniflora Threatened Rich deciduous forest, bluffs , ravines 5 Houstonia montana Endangered High elevation rocky summit, grassy bald 3 Hudsonia montana Threatened Quartzite outcrops 4 Isotria medeloides Threatened Mesic forests, often with white pine and diverse 4 orchid assemblage Liatris helleri Threatened High elevation rocky summit 3 Sagittaria fasciculata Endangered Low elevation cool water streams, bogs 5 Sarracenia jonesii Endangered Southern Appalachian Bog 5 Sarracenia oreophila Endangered Low elevation seepage bog 5 Sisyrinchium dichotomum Endangered Woodlands primarily over amphibolite rock 5 Solidago spithamea Threatened High elevation rocky summit 3 Spiraea virginiana Threatened Riverside scour zone 1 1 - Requires further analysis, species is known to occur within the vicinity of infestation(s) and could be potentially impacted by proposed activities. 2 – Dropped, suitable habitat for the species occurs in the analysis area, but potential management activities will not affect the species. 3 – Dropped, suitable habitat for the species present outside known project activity area and habitat unlikely to be infested by invasive plant species. 4 – Dropped, the analysis area is within range of the species, but species distribution on the forest is well known and either no invasive outbreaks are known or infestations are outside (Linville Gorge Wilderness) the proposed activity area. 5 - Dropped, the analysis area is within range of the species, but species distribution is fairly well known with no occurrences on the Nantahala or Pisgah NFs. 6- Dropped, the best available science indicates this species is extirpated. The final filtered list of federally listed species that might be affected by the proposed control activites includes four species, Alasmidonta raveneliana (Appalachian Elktoe), Mesodon clarki nantahala (Noonday globe), Spiraea virginiana (Virginia spiraea), and Helonias bullata (Swamp pink). The effects to these rare species are discussed by species within the next section.

V. EFFECTS ANALYSIS 1---Alasmidonta raveneliana (Appalachian Elktoe) A) Species Biology and Distribution The Appalachian elktoe is a medium-sized mussel reaching up to about 3.2 inches in length. Its shell is thin, but not fragile, kidney shaped, and 1 inch in width. Appalachian elktoe is endemic to the upper Tennessee river system in western North Carolina and eastern Tennessee and was once a more widespread species. Historical records indicate the mussel was more widespread than presently known. There are seven extant element occurrence records for the Appalachian elktoe in North Carolina (figure 1). Documented occurrences in Tulula Creek, Swannanoa River, and the French Broad River-main stem are not known to be currently present. In Tennessee, the species is known only from its present range in the main stem of the Nolichucky River. During the last 10 years, the species was located in several rivers where it was thought to have been extirpated; the West Fork of the Pigeon, Little River, Mills River, and the Cheoah River. The Nantahala National NF includes portions of the Cheoah River with occupied habitat, while the Pisgah NF contains headwater streams, but not the sites where the Appalachian elktoe mussel occurs (figure 1). Because of its rarity, little is known about the autecology of the species. It has been reported from relatively shallow medium-sized creeks and rivers with cool, well- oxygenated, and moderate – to fast-flowing water. It has been observed in gravelly substrate, often mixed with cobble and boulders; in cracks in bedrock; and occasionally in relatively silt-free, coarse, and sandy substrata. Like other freshwater mussels, the Appalachian elktoe feeds by filtering food particles from the water column.

The decline of this species throughout its range has been attributed to several factors, including siltation resulting from past logging, mining, agricultural, and construction activities; the run-off and discharge of organic and inorganic pollutants; habitat alterations associated with impoundments, channelization, and dredging; and other natural and human- related factors that adversely modify the aquatic environment. Land- clearing and other land disturbance activities carried out without proper sedimentation control pose a significant threat to freshwater mussels (US Fish and Wildlife Service 1996). Figure 1. Range of Appalachian elktoe in North Carolina including two rivers on either the Nantahala or Pisgah Nation Forest with known invasive plant infestations.

B) Direct and Indirect Effects Direct effects are those occurring at the same time and place in the proposed action area. Indirect effects are those caused by the action, which occur after the activity has taken place or occur at a distance from the action area. Direct effects to Appalachian elktoes can occur with NNIP control projects from herbicide drift, or from sedimentation increase resulting from vegatation removal. The single population on NFsNC lands from the Cheoah River has been documented with numerous nearby NNIP infestations. Mussel searches conducted by Pennington and Associates, Inc. (PAI) in the Cheoah River in 2000 found one live specimen of the elktoe. The live individual was located just downstream of the confluence with Gladdens Creek, in a shallow run with a substrate of silt and sand flanked by aquatic vegetation. A single relic shell of the Appalachian elktoe was found at a beaver dam just downstream from the confluence of Cochran Creek.

In August 2002, the North Carolina Department of Transportation (NCDOT) in conjunction with the USFS and the USFWS conducted a mussel survey of the Cheoah River in preparation for the planned replacement of Bridge Number 70, which crosses the Cheoah River on Joyce Kilmer Road. The NCDOT survey found 10 live specimens and 5 relic shells in several different locations in the river. U.S. Fish and Wildlife Service personnel surveyed sections of the river in 2003 and 2004 and found Appalachian elktoe in two sections of the river (NC Natural Heritage Program Biotics 2008). The population between Gladdens Branch and Cochran Creek was well established with “lots of mussels” present. Another site between Half Mile Creek and the bridge at River Mile 1.8 had “some mussels” present

Manual removal of NNIP species along the Cheoah River will be minimal given the diversity and extent of NNIP species occurrences. Application of flame throwers are not planned for use on selected NNIP species on the banks of the Cheoah River. However downstream of occupied habitat along NC 129 still within the northern extent of Appalachian elktoe critical habitat a dense kudzu infestation may be prescribed burned (west of the road to the river) during the dormant season to reduce the above ground growth. Herbicide applications across this area would be restricted to root crowns with emerging foliage. It may be necessary to replant native stream bank vegetation in order to stabilize the soil in sections of this area. This would be completed to minimize any off-site sedimentation, however the elimination of the kudzu may result in localized short-term sedimentation. This sedimentation may reduce the quality of spawning gravel and/or embed larger substrate near the rivers edge. The duration of the effect depends upon the storm runoff magnitude and frequency. During a large storm event these sediments would likely be dissapated throughout the river channel. Effects from the prescribed burning and herbicide activity would be immeasurable to the designated critical habitat of the Cheoah River because these activities should only result in small sedimentation releases, would be dispersed during high flow events, and would be minimized with native planting such as Virginia wild rye.

For any herbicide applications for control of NNIP infestations within the riparian zones across the NPNFs the following specific mitigation measures will be implemented: 1) Only herbicides labeled for use in or near aquatic systems would be used within 30 feet of water and 2) Applicators would use barriers (loosely secured silt fence) along stream edges and banks prior to any application of herbicides. If a silt fence can not be easily secured on steep rocky banks one member of an applicator team would maintain a mobile barrier (such as a large cardboard sheet about 3 by 3 feet in size) between the herbicide application and the stream during the application.

Thus any direct effects to Appalachian elktoe from herbicide drift for control along the stream banks within the occuppied habitat will be minimized by following the above mitigations. When aquatic approved herbicides are applied according to label directions they are diluted (680 ppm) and are further diluted upon entering the receiving stream (SERS 2003). Furthermore, the implementation of a streamside barrier to reduce any drift into the stream diminishes the risk. The greatest risk to occupied habitat occurs near the south of the bridge at river mile 1.8 where an infestation of kudzu is completely overtopping a backwater stream channel occurrence of Virginia spiraea. In this location herbicide application will occur over open water. Risk assessments of the proposed herbicides on fish and invertebrates indicate low sensitivity, however this is less certain for mussels. A study on the toxicity of glyphosate to mussels revealed larval glochidia and the earliest life stages are sensitive (Bringolf et. al. 2007). For that reason it is important for NNIP treatments to reduce any risk of off-site applications when these glochidia are unattached to their fish hosts and more vulnerable. For that reason the following control measures will be implemented at this site and any other open water site within occupied state or federally listed rare mussel habitat: 1) An aquatic rated formulation of triclopyr (Garlon 3A brand name formulation) would be applied; this herbicide is not known to be toxic to mussels; 2) The infestation would be mechanically cut to expose root crowns(in the case of kudzu) or cut stems (woody trees and shrubs) to reduce the amount of herbicide applied near the mussel habitat; and 3) A barrier such a cardboard sheet would be placed between targeted vegetation and potential mussel suitable habitat such as sand bars and rocky shoals, to prevent any herbicide from adhering to the sand.

It is likely that removal of NNIPs would allow native vegetation to become reestablished in the riparian areas. It is generally assumed that restoring native vegetation would result in a greater diversity of habitat components that may be important for rare aquatic species. This could indirectly improve the existing habitats where the species occurs and may provide more suitable conditions on the NPNFs for future recovery of Appalachian elktoe.

C) Cumulative Effects Cumulative effects are those resulting from incremental impacts of the proposed action when added to other past, present and reasonably foreseeable future actions. Cumulative effects can result from individually minor, but collectively significant actions that take place over a period of time.

The greatest impact to Appalachian elktoe habitat within the Cheoah River is the interruption of normal hydrological processes from the operation of Santeetlah Dam since its construction in the mid 1900s. Recent actions or disturbances along the Cheoah River (both on USFS lands as well as private lands) include an increased flow regime, construction of a rafting put-in, construction of a parking lot on Alcoa lands near Santeetlah Dam, construction of a parking lot on private property north of the intersection of NC 129 and secondary road (SR) 1147, clearing of land downstream of periodic whitewater rafting events during short-term higher flow rates, and gravel augmentation. Previous actions within the Cheoah River watershed include timber and salvage projects between 1996 and 2000. These sales included timber harvest (clear cutting, shelterwood, two-aged regeneration, salvage cutting, and intermediate thinning), as well as associated road construction or reconstruction, pre-harvest herbicide treatments, herbicide site preparation, prescribed fire, large woody debris placement to improve fish habitat, and recreational trail improvements.

Planned actions along the Cheoah River within Appalachian elktoe critical habitat includes replacement of bridge # 70 on Joyce Kilmer Road, construction of a wheelchair accessible river trail up to 9 miles in length, additional gravel augmentation, continued whitewater rafing events with higher flow water releases, periodic clearing (manual cutting and/or herbicide application) of in-stream woody vegetation less than 3 inches in diameter that obstruct whitewater rafters, and construction of other facilities. Other vegetation management projects are planned on the eastern slopes of the Cheoah River watershed including timber harvest, wildlife habitat improvements, road construction and reconstruction, and a joint burn across 1000 acres on USFS and Land Trust for Little Tennessee lands.

Previous projects were implemented to minimize any impacts to the riparian resource and minimize any sedimentation. All the projects were previously reviewed by the Asheville field office of the USFWS. Some actions, specifically the construction of the whitewater rafting put-in and woody plant cutting within the main channel of the river, were not implemented as described in the proposed action or did not implement all the terms and conditions with previous concurrence letters or Biological Opinions. While this analysis does not intend to minimize the previous implementation problems, it is thought none of the recent activities resulted in impacts to any Appalachian elktoe individuals (personal communication, John Fridell, USFWS biologist). Discussions on the breakdown of the analysis and the implementation process between personnel from the Asheville field office of the USFWS, Cheoah Ranger District, and Supervisors office of the NFsNC in 2008 were conducted to address implementation resource concerns. The intent in the future is to resolve any implementation breakdowns and insure all the terms and conditions of a specific BO is tracked and completed as planned.

For all the upcoming projects on USFS lands best management practices, forest plan standards specific to riparian corridors and mitigation measures (design features) specific to Appalachian elktoe will be implemented. Consequently there should be no measurable adverse effects occurring to Appalachian elktoe habitat aquatic resources in the Cheoah River. The effects of gravel augmentation and minimum flows will likely have long-term effects on the Cheoah River and its aquatic community (primarily positive effects). Implementation of this project therefore “is not likely to adversely affect” the Appalachian elktoe mussel (Alasmidonta raveneliana) or adversely modify its critical habitat.

2 --- Mesodon clarki nantahala (Noonday Globe Snail) A) Species Biology and Distribution Noonday globe snail is a moderately sized terrestrial snail. Its shiny reddish shell has a slightly depressed spire and a prominent blade-like tooth at the base of its aperture (USFWS 1984). The species is endemic to the north-facing slopes of the Nantahala Gorge in Swain County (NCNHP Biotics 2008). It is only known to occur along about a 2-mile length of the gorge. Almost the entire occupied and suitable habitat for the species is managed by the Nantahala National Forest. Noonday globe snail habitat includes the moist forested slopes scattered with calcareous outcrops. The snail was federally listed as threatened in 1978 partly in response to the threat from a proposed road widening (USFWS 1978).

B) Direct and Indirect Effects A kudzu infestation is adjacent to and envelops a portion of the northernmost extent of suitable habitat for this snail in the Nantahala Gorge (figure 2). Noonday globe snail has never been located within the vicinity of this kudzu infestation although the habitat appears comparable to occupied habitat around Blowing Spring (John Fridell, USFWS biologist). Application of the herbicide clopyralid (brand name Transline) and/or triclopylor (for any use in the riparian zone) is proposed for control of this vine.

Direct affects to rare snail species are unknown if there is direct exposure of the snail to droplets of any herbicide. There are no known toxicity reviews for herbicide applications to rare snails. However in a study completed across a riparian community, there were no direct effects to identified snails when either glyphosate or 2, 4-D were applied to associated herbaceous vegetation (Relyea 2005). The likelihood of any direct affects on noonday globe snails from off-target herbicide is unlikely given the previous habitat alteration that allowed the invasion of kudzu resulted in generally unsuitable habitat for this species. Furthermore the species appears to be most active, on vegetation, during wet weather during conditions when herbicide applications would not be applied. Generally the species occurs underneath a layer of leaf litter which further would buffer any offsite herbicide.

Snails require moist leaf litter in which to move about and reproduce. Effective control of the kudzu infestation will result in indirect affects with an increase in sunlight on the leaf litter layer thereby desiccating it as well as lowering the relative humidity at the ground layer. These short-term conditions will reduce the suitability of the habitat for noonday globe snails. Eventually the reinvasion of native vegetation including the forest canopy should expand existing suitable habitat for this species within the Nantahala Gorge.

C) Cumulative Effects Previous activities across habitat for this species within USFS lands in the Nantahala Gorge include construction of recreational facilities along the Nantahala River, construction of a sewage drain field for the Ferebee recreational facility, and relocation of the Appalachian Trail. There are no future projects on the NPNF that are anticipated to affect this snail. These previous activities are not known to have adversely affected any Noonday globe snail individuals. In the past 10-20 years there has been an increase in recreational use on the river within this section of the Nantahala River. These recreational trends are anticipated to continue in the future. However given the steep sites in suitable habitat will tend to restrict visitation and thereby should not result in trampling impacts to this snail. The cumulative affects from these past and future actions on Mesodon clarki nantahala within the corridor are not anticipated to result in any measurable loss of this species.

Figure 2. Occurrence of Kudzu within Nantahala River Gorge adjacent or within critical habitat for Noonday snail.

3 --- Spiraea virginiana (Virginia Spiraea) Spiraea virginiana is a clonal perennial shrub 1-3 meters in height. Its root structure and vegetative characteristics allow it to establish in new sites under appropriate disturbance regimes (Ogle 1991b). Flowering occurs in June and July. Virginia spiraea has been recently documented or relocated along the Appalachian Mountains from Ohio and West Virginia south to northwestern Georgia (Natureserve 2008). The shrub is only known historically from Alabama and Pennsylvania (Natureserve 2008). Spiraea virginiana has been recently documented in three river basins (New, Nolichucky, and Little Tennessee) in North Carolina. It is historically known from the French Broad river basin (NC Natural Heritage Program Biotics 2008). Three populations are known from the NPNFs, on the Cheoah River, Whiteoak Creek, and the Nolichucky River. Numerous subpopulations have been documented on NPNFs land on the Cheoah and Nolichucky Rivers. Spiraea virginiana is found in disturbed areas along high gradient sections of rivers and streams or braided features of lower reaches. Recurrent flood scouring events are essential to this plant’s survival because flooding inhibits arboreal competition and washes away many competing herbs and vines. Virginia spiraea can also be found along slow changing, dependable riparian areas such as meander scrolls and point bars, natural levees, and braided features of lower stream reaches. The plant prefers open areas with direct sunlight. Competition from surrounding vegetation including NNIPs, inundation, and clearing vegetation in the riparian area are major threats to this species (USFWS The shrub was federally listed as threatened in 1990 (USFWS).

B) Direct and Indirect Effects All three populations on the NPNFs are being impacted by a variety of NNIP species. A small population on Whiteoak Creek, one of the larger subpopulations on the Cheoah River, and at least one subpopulation on the Nolichucky River are the most affected since they are either completely overtopped or crowded out by either kudzu or Japanese knotweed. Although there is no quantitative monitoring information, sites on the Cheoah River and Whiteoak Creek have been observed to be in decline during the past 5 years and could eventually become locally extirpated.

Herbicide applications will be prioritized for implementation within these three sites however all the documented subpopulations are known to have some nearby NNIP infestation and will require herbicide applications for control. Off target herbicide application could result in death of Virginia spiraea individuals particularly since the preferrred aquatic herbicide is generally lethal to woody plant species.

In order to reduce offsite herbicide impacts to Virginia Spiraea population/subpopulations a USFS botanist (Pisgah, Nantahala, or National Forests in NC) will visit the site with applicators (USFS personnel or private contractors) prior to any treatment. The goal is to train the applicators on identification of Spiraea virginiana as well as ensure the implementation of any site-specific application techniques. These areas will have been surveyed by a USFS botanist prior to any implementation and as a part of the specialist checklist procedure. In addition the following specific guidelines will be established at these sites to reduce any offsite application to Spiraea virginiana or any other federally listed species:

1) All NNIP species within 10 feet of any federally listed species will be cut back to within 6 inches of the ground for all woody stems (vines and shrubs) or will expose the root crown for all vining herbaceous stems, 2) A barrier (such as an appropriately sized cardboard sheet) will be placed between the targeted NNIP and the federally listed species prior to any herbicide application, and 3) Herbicide applications will be applied to cut stems with a small wick applicator if possible or with a small spray bottle that reduces the possibility of any off-target drift. These control measures will greatly reduce the risk of impacts to Spiraea virginiana with the proposed control work. The goal is to have no measurable impacts from any treatment.

Figure 3. Range of Spiraea virginiana in North Carolina including three 3 sites across 2 river basins on either the Nantahala or Pisgah Nation Forest.

If we assume the lack of control of any of the invading NNIP species currently overtopping or occurring nearby Virginia spiraea populations, declines in the vigor and/or abundance of the shrub will be significant. Thus the indirect effects of eliminating or reducing the spread of select NNIPs surrounding Spiraea virginiana should be beneficial by restoring suitable habitat for the federally listed species and may result in the expansion of this species at selected sites.

C) Cumulative Effects Within the Cheoah River drainage previous and proposed activities are addressed in the discussion for Appalachian Elktoe. As with Appalachian elktoe, there were implementation concerns with previous projects. A previously unknown subpopulation of Spiraea virginiana was cut during construction of a temporary put-in site and some subpopulations were cut with a long-arm mower by the NC Department of Transportation (NCDOT) during periodic cut-bank maintenance along NC 129. Discussions between the USFWS, USFS and NCDOT have been conducted to ensure these impacts will not occur in the future as a result of ongoing maintenance or proposed projects. It is uncertain if the previous cutting resulted in loss of any Spiraea virginiana individuals along the Cheoah River since there was no baseline monitoring for the affected subpopulations. Most of the subpopulations were monitored in 2008 and will be periodically monitored to address subpopulation trends. This information will be helpful in the future to determine any impacts.

The small population along Whiteoak Creek was negatively impacted by bridge maintenance in 2006. Two desiccated shoots with rhizomes were located during a survey by Carolyn Wells, USFWS botanist and Gary Kauffman, USFS botanist. No other proposed or recently implemented projects are known for Whiteoak Creek. There are no recent implemented or proposed projects that could affect the subpopulations within the Nolichucky River Gorge. A wildfire in 2007 on the upper slopes of the gorge did not impact habitat for this species.

Standards in the Nantahala and Pisgah Land and Resource Management Plan provide protection to riverine habitats that could support Virginia spiraea, and mitigation measures specific to this shrub will be implemented. Implementation of this project will ultimately protect and enhance populations of Virginia spiraea that are located in the immediate vicinity of NNIPs by eliminating the competing NNIP population. The lack of implementation within the one kudzu infested subpopulation on the Cheoah River, the population along Whiteoak Creek, and one subpopulation on the Nolichucky River will eventually result in an indirect negative affect on Virginia spiraea individuals including the possible extirpation from these sites. Therefore implementation of this NNIP control project is “not likely to adversely affect” Virginia spiraea (Spiraea virginiana) and is likely to benefit the species. Ongoing monitoring of portions of the subpopulations across the forest will help to ensure this determination is true.

3 --- Helonias bullata (Swamp Pink) Swamp pink is a perennial obligate wetland species with a thick stocky rhizome (USFWS 1991). Its leaves form an evergreen basal rosette. Swamp pink is currently known from seven states with over 100 records (Natureserve 2008). The species is believed to be extirpated from New York. Populations vary widely in size and habitat quality, from a few individual rosettes to many more than 10,000 clusters of rosettes. While only one meta-population, in the Pink Beds, is known from the National Forests in North Carolina it is probably the largest known range-wide population (figure 3). Within the last two years nine subpopulations have been relocated and their numbers estimated or counted. Multiple tens of thousands of clumps can be conservatively estimated within these visited subpopulations. Helonias bullata is known to occur within Dulany Bog in Jackson County, which is partially owned by the Nantahala NF. All the documented swamp pink individuals occur only within the portion of the bog owned and managed by the Highlands Biological Foundation.

Figure 4. Range of Helonias bullata in North Carolina including three 3 sites across 2 river basins on either the Nantahala or Pisgah Nation Forest.

Swamp pink occurs along streams and seepage areas in freshwater swamps and other wetland habitats. The groundwater influenced wetlands supporting the species are perennially saturated. In the Pink Beds and Dulany Bog, swamp pink occurs primarily along meandering streams in Southern Appalachian Bogs or Swamp Forest complexes. On these sites, the water table is at or very near the surface and fluctuates only slightly during spring and summer months (Sutter 1982).

The major threat to the species is loss and degradation of its wetland habitat due to encroaching development, sedimentation, pollution, succession, and wetland drainage (USFWS 1991). Many Southern Appalachian bogs have been destroyed by drainage and development, particularly for industrial sites and recreational resorts. Declines in plant numbers have also been noted in the Pink Beds following accelerated down cutting of a stream caused by adjacent road runoff. Habitat near the stream was degraded through a localized lowering of the water table such that it could no longer support the species (Sutter 1982). B) Direct and Indirect Effects Within the Pink Beds two of the larger subpopulations are known to have nearby infestations of privet (personal communication, David Danley, USFS botanist). Herbicide applications are the preferred treatment within the Pink Beds since mechanical removal of larger individuals or clusters could result in sediment movement into the nearby streams. Pulling seedlings should not result in any sedimentation into the streams. As for Spiraea virginiana, the aquatic rated herbicide of choice is Garlon 3A. Nothing is known on the impacts of this herbicide to Helonias bullata, nevertheless it is assumed it will kill or seriously impact Helonias bullata individuals.

In order to reduce offsite herbicide impacts to swamp pink subpopulations a USFS botanist will visit the site with the applicators training them on identifying Helonias bullata prior to any herbicide treatment in the vicinity. In areas that are proposed for chemical treatments where there is a presence of swamp pink, a physical barrier will be utilized to sufficiently protect non-target vegetation from herbicide drift and flow. In addition herbicides will only be applied to privet cut surfaces thereby reducing the applied quantities and the risk of drift. Implementation of this project should reduce the likelihood of privet overtopping swamp pink individuals and thereby indirectly improve suitable habitat for the species.

C) Cumulative Effects During the past 15 years the Pink Bed swamp pink subpopulations may have been impacted by down-cutting from a flooding event, dropping of trees overtop individuals either by USFS personnel or from wind events, and any change in the hydrological regime from construction of facilities at the Cradle of Forestry. It is uncertain about the extent of any decline since baseline monitoring data was either imprecise or not conducted across affected subpopulations. In 2008 two demographic plots have been installed within the subpopulation near the recently constructed amphitheater. Other estimates of clumps have been recently completed across the majority of the subpopulations. These plots plus additional monitoring activities will help to ensure trends can be tracked for population/subpopulation(s) and changes can be implemented if significant declines are detected. The measures to control invading privet should improve habitat for any affected Pink Beds subpopulations by reducing competition. Implementation of this project is therefore “not likely to adversely affect” Swamp Pink (Helonias bullata). VII. DETERMINATION OF EFFECT The proposed activities associated with treatment of non-native invasive plants on the Nantahala and Pisgah National Forests has the greatest potential to affect four federally listed species, Alasmidonta raveneliana (Appalachian Elktoe), Mesodon clarki nantahala (Noonday globe), Spiraea virginiana (Virginia spiraea), and Helonias bullata (Swamp pink). Control measures detailed above for each species will be implemented. As a result the proposed project is “not likely to adversely affect” Spiraea virginiana, Helonias bullata, Mesodon clarki nantahala, Alasmidonta raveneliana or its critical habitat. The project is not expected to have an affect on any other federally listed species.

Prepared By: Gary Kauffman, National Forests in NC Botanist Ecologist

Date: January 22, 2009

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