United States Department of Agriculture Non-Native Invasive Plant Control Project

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Biological Evaluation United States Department of Agriculture Non-native Invasive Plant Control Project

Hiawatha National Forest Forest Service Eastern March 2007 Region

Hiawatha National Forest

Spotted knapweed, Centaurea maculosa (Photo: Jim Story)

Biological Evaluation Non-native Invasive Plant Control Project Hiawatha National Forest

March 2007

Prepared By: ______Prepared By: ______Kirk Piehler Marjory Brzeskiewicz, Forest Wildlife Biologist contract Plant Ecologist

Date: ______Date: ______

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Cover Photograph Credit: Jim Story, Montana State University

This document was printed on recycled paper.

Table of Contents

Executive Summary ...... 4 Summary of Determinations ...... 5 Introduction ...... 6 Purpose and Decision 6 Species Considered and Evaluated 7 Background and Project Description 7 Alternative 1: No Change 8 Alternative 2: Manual/Mechanical, Chemical, and Biological Control of NNIP 8 Treatment Methods 10 Protocol 10 Design Criteria 12 Findings by Species ...... 19 Federally Listed Species 20 Plants 21 American Hart's tongue fern (Phillitus scolopendrium v. americanum) 21 Pitcher's thistle (Cirsium pitcheri) 23 Lakeside daisy (Hymenoxys herbacea) 26 Dwarf lake Iris (Iris lacustris) 29 Houghton's goldenrod (Solidago houghtonii) 31 Michigan monkey-flower (Mimulus glabratus var. michiganensis) "likely to occur" 34 Animals 35 Bald eagle (Haliaetus leucocephalus) 43 Canada lynx (Lynx canadensis) 47 Gray wolf (Canis lupus) 51 Hine’s emerald dragonfly (Somatochlora hineana) and proposed critical habitat 55 Kirtland’s warbler (Dendroica kirtlandii) 62 Piping plover (Charadrius melodus) and piping plover critical habitat 66 Regional Forester Sensitive Species 74 Plants 74 RFSS Plants – Aquatic Habitats 74 RFSS Plants – Open / Wet Habitats 77 RFSS Plants – Open / Dry and Beach Habitats 79 RFSS Plants – Shaded / Wet Habitats 81 RFSS Plants – Shaded Habitats 84 Animals 87 RFSS Birds 87 RFSS Reptile 107 RFSS Fish 110 RFSS Mollusks 113 RFSS Insects 118 Summary of Determinations ...... 131 Monitoring ...... 133 Literature Cited ...... 134 Appendix A: Species Considered ...... 140 Appendix B: Location of Project...... 145

EXECUTIVE SUMMARY

The Hiawatha National Forest (HNF) proposes to implement a five-year project to control non- native invasive plants (NNIP) at approximately 135 sites (Table I-2), and at new sites found. An interdisciplinary team of resource specialists designed an integrated management program that would use manual/mechanical, chemical and biological methods to reduce and control infestations of invasive plants. Overall, the goal of the project is to slow the spread of NNIP on the Forest. The HNF 2006 Forest Plan includes direction for management of all threatened, endangered and sensitive (TES) species. A key Forest-wide guideline directs that NNIP within occurrences of TES should be eliminated or controlled. The 2006 Forest Plan guidance for NNIP control is consistent with the Forest Service national policy of prevention, early detection, rapid response, control and management (USDA 2004).

The project area for the HNF NNIP Control Environmental Assessment (EA) encompasses the Forest Service owned acres within the proclamation boundary and totals approximately 895,000 acres, most of which is forested. We have proposed two alternatives. Under Alternative 1 (No Change), the HNF would not implement an integrated program of treatments to control NNIP infestations. Limited manual/mechanical treatment of NNIP infestations may still occur through separate decisions, not associated with this EA. We anticipate approximately 30-50 acres would be treated annually through manual/mechanical methods, as is the current practice. If the maximum 50 acres was treated annually, for the anticipated five-year duration of the project, the total acreage (250) would represent approximately 0.03 percent of the land on the HNF. Under Alternative 2, an average of approximately 40-70 acres a year, with up to approximately 200 acres a year, would be treated using a combination of manual/mechanical, chemical and biological (insect releases). If the maximum 200 acres was treated annually, the five-year total, 1000 acres, would represent approximately 0.12 percent of the land on the HNF.

The findings of the biological evaluation (BE) are included in the next section (Tables ES-1 and ES-2, p. 5). The BE documents the effects to TES species, including Federal Threatened and Endangered Species (T&E), and Regional Forester Sensitive Species (RFSS), from activities proposed in the NNIP Control project EA. In the BE, the two alternatives were analyzed, effects disclosed, and determinations made. The document provides information to support the determinations on how the alternatives would affect TES species.

Non-native invasive plants are established and widespread on the HNF, but most sites are currently located in disturbed areas (e.g. roadsides) and are small in coverage. Therefore, at present, we are sure of only a few TES plants and animal (e.g. piping plover) currently being affected. Alternative 1 would have no effects for most TES animals, since it represents no change from current practices, and proposes no NNIP control activities. Under Alternative 1 we assummed attempts would be made to treat NNIP infestations within affected TES occurrences because that is the Forest Plan management direction. Thus, many TES determinations are either “no effect” (T&E) or “no impact” (RFSS). We determined that for some groups of RFSS plants, manual treatment and the current treatment acreage would be insuffient and adverse effects would occur over time under Alternative 1 (e.g. aquatic plants). Alternative 2 proposes the use of multiple methods for NNIP control. There is some risk to plants and animals from these activities because people would be conducting NNIP removal and control, which could result in death and injury to TES. While there is some risk from NNIP control treatments, Alternative 2 design criteria and protocols would minimize impacts to TES. Over the long term, Alternative 2 would provide the most benefits to TES by enabling the NNIP program manager with options, not available under Alternative 1, for decreasing the spread of NNIP and controlling infestations. Thus, under Alternative 2, for most species, the “not likely to adversely affect” (NLAA) determinations for T&E, and the ”may affect” (MINT) determinations for RFSS represent the beneficial effects of enhanced NNIP control. 4 SUMMARY OF DETERMINATIONS

Table ES-1. Federally-listed Threatened and Endangered Species (T&E) – Summary of Determinations of Effects

ALTERNATIVE 1 ALTERNATIVE 2 SPECIES EVALUATED PLANTS Dune thistle NLAA NLAA Lakeside daisy NLAA NLAA Dwarf lake iris NLAA NLAA Hart's tongue fern NLAA NLAA Houghton's goldenrod NLAA NLAA ANIMALS Bald eagle NE NLAA Canada lynx NE NLAA Gray wolf NE NLAA Hine's emerald dragonfly NE NLAA Hine's emerald dragonfly critical habitat* NE NLAA Kirtland's warbler NE NLAA Piping plover NLAA NLAA Piping plover critical habitat NE NLAA NE - No effect; NLAA - May affect, not likely to adversely affect; LAA - May affect, likely to adversely affect * - This is proposed critical habitat - the USFWS has not published the final decision on critical habitat as of 3/2007.

Table ES-2. Regional Forester Sensitive Species (RFSS) and Likely to occur RFSS (LRFSS) - Determinations of Effects

ALTERNATIVE 1 ALTERNATIVE 2 SPECIES or GROUP EVALUATED PLANTS Aquatic plant habitat MINT MINT Open/wet habitat MINT MINT Open/dry & Beach habitat MINT MINT Shaded/wet habitat MINT MINT Shaded habitat MINT MINT ANIMALS Mammal Gray wolf* NI MINT Birds Raptors NI MINT Wetland birds NI MINT Grassland/Shrub birds NI MINT Black-backed woodpecker NI MINT Connecticut warbler NI MINT Bald eagle* NI MINT Reptile Blanding’s turtle NI MINT Fish Lake Sturgeon NI MINT Mollusks Mollusks NI MINT Insects Lake Huron locust MINT MINT Northern blue (butterfly) MINT MINT Dragonflies NI MINT NI - No Impact; BI - Beneficial Impact; MINT - May impact individuals but not likely to cause a trend to federal listing or loss of viability; MILT - May impact individuals but likely to cause a trend toward federal listing or loss of viability. * - bald eagle and gray wolf were also evaluated as RFSS due to the likelihood of removal from the T&E list

5 INTRODUCTION

Purpose and Decision The purpose of this biological evaluation (BE) is to document the likely effects of the activities proposed in the Non-native Invasive Plant (NNIP) Control Project to Federally threatened and endangered species (T&E), and to Regional Forester sensitive species (RFSS) on the HNF. The BE is a supplement to the Environmental Assessment (EA), and provides the Deciding Official with the necessary information to make an informed decision regarding the potential risks and benefits posed by the project to threatened, endangered, and sensitive (TES) plant and animal species and their habitats.

Federal legislation, such as Section 7 of the Endangered Species Act (ESA), the National Forest Management Act (NFMA), and the National Environmental Policy Act (NEPA), define national policy to preserve and protect T&E species and RFSS when managing public lands. To meet the intent of such legislation, biological evaluations are required as part of the environmental analysis for all planned, funded, or permitted Federal activities.

Within Forest Service guidelines (Forest Service Manual (FSM) 2672.41) biological evaluations are the means we use to review projects and to document findings in order to:

. Ensure Forest Service actions do not contribute to loss of viability of any native or desired non-native plant or animal or contribute to a trend toward Federal listing of any species.

. Comply with the requirements of the ESA that actions of Federal agencies not jeopardize or adversely modify critical habitat of Federally listed species.

. Provide a consistent process to ensure that TES species receive full consideration in the decision-making process.

Determinations of effect result from the process carried out in the BE. The ESA requires the Forest Service to make determinations for T&E species that describe the impacts of the project alternatives. For T&E species, the determination of effect specifically utilizes the judgment of Forest Service biologists on which of three conditions are most likely to be met1: No effect (NE): conclusion resulting when an agency determines its proposed action will not affect listed species or critical habitat. May affect, not likely to adversely affect (NLAA): conclusion resulting when effects on listed species are expected to be discountable, insignificant, or completely beneficial. Beneficial effects have contemporaneous positive effects without any adverse effects to the species. Insignificant effects are small in size and should not reach the scale where take occurs. Discountable effects are extremely unlikely to occur. May affect, likely to adversely affect (LAA): conclusion resulting when any adverse effects to listed species may occur as a direct or indirect result of the proposed action or its interrelated or interdependent actions, and the effect is not discountable, insignificant, or beneficial. A combination of beneficial and adverse effects is still “likely to adversely affect,” even if the net effect is neutral or positive.

1 Source of definitions: U.S. Fish and Wildlife Service, Final ESA Section 7 Consultation Handbook, March 1999, pg. 3-12-3-13

The FSM requires the Forest Service to address the viability of RFSS to avoid any impacts that may cause a trend towards listing. For RFSS, the determination of effect specifically utilizes the judgment of Forest Service biologists on which of four conditions are most likely met from the impacts of the alternatives. These include: No impact (NI): when proposed action will not have an affect. Beneficial impact (BI): when proposed alternative is determined to be wholly beneficial without potential negative impacts. May impact individuals, but is not likely to cause a trend to federal listing or loss of viability (MINT): when the proposed alternative may cause some negative effects, even if overall effects to species may be beneficial. May impact individuals and likely to result in a trend to federal listing or loss of viability (MILT): where effects are expected to be detrimental and substantial. Species Considered and Evaluated Table A-1 in Appendix A lists the T&E species and critical habitat that were evaluated. The U.S. Fish and Wildlife Service maintains a list of endangered and threatened species and critical habitat designated under the Endangered Species Act of 1973. A letter from the East Lansing Office Field Supervisor (Czarnecki 2006) confirmed the species and critical habitat we should evaluate for projects conducted on the HNF. The HNF Forest wildlife biologist contacted Jessica Hogrefe, Endangered Species Biologist of the U.S. Fish and Wildlife Service in November 2006 regarding the federal species in the project area, based on information presented in the initial public scoping. Biologists also discussed whether or not to analyze Michigan monkey flower, a species not currently found within the Hiawatha. The decision was made to analyze it as a "likely to occur" species in the event it would be found in the future. Hiawatha botanists have looked for Michigan monkey flower in appropriate habitat for many years and none has been found. While not required, we also evaluated proposed Hine’s emerald dragonfly critical habitat in the BE. A proposal to designate Hine’s emerald dragonfly critical habitat over a multi-state area, which includes Michigan and the HNF, has been published (USFWS 2006b). However, the area of critical habitat for the species had not been finalized when we were drafting the BE.

Table A-2 in Appendix A lists the Regional Forester Sensitive Species (RFSS) that were evaluated (USDA 2007). The Regional Forester designates RFSS plants and animals for which population viability is a concern on the Forest (FSM 2670.5). When the Eastern Region of the Forest Service revised its RFSS list in 2000, additional direction was given to consider those species that are "Likely to Occur" if their range includes the Hiawatha, their preferred habitat is present, and there are occurrences near the Forest. Table A-3 in Appendix A lists RFSS that are likely to occur based on range and habitat, but currently lack verified sites on the Forest. More information regarding the RFSS evaluation process is available on the web site at: http://www.fs.fed.us/r9/wildlife/tes/.

Background and Project Description Non-native invasive plants (NNIP) can be aggressive invaders of disturbed habitats and native plant communities. When left untreated, some NNIP may become the dominant component of the vegetative community, thus reducing native plant diversity and impacting wildlife habitat, visual resources and future management of infested sites. Aggressive, non-native shrubs in the forest can also reduce growth rates of native overstory trees (Hartman and McCarthy 2007).

The HNF has identified NNIP present within or near the Forest boundaries that have the ability to invade native plant communities (Table I-1). Although most of the species occur in disturbed sites (e.g. roadsides, skid trails, parking areas and utility corridors) (USDA 2006d, p. 3-66), and are not a severe problem at this time, some of them are well established on the HNF, and are physically and economically impractical to control manually. Examples of such plants include leafy spurge, garlic mustard and purple loosestrife. There are many other species of plants in Michigan that are not native to North America (e.g. food plants) and the majority of these cause little, if any, environmental harm (Czarapata 2005, p. 4). Any plants having potential to be invasive are of concern to the HNF. As a result, our NNIP list is likely to change in the future.

This BE analyzes the effects of the two alternatives described in the HNF Non-native Invasive Plant (NNIP) Control Project EA, as briefly summarized below:

Alternative 1: No Change Under the Alternative 1, the U.S. Forest Service would not implement an integrated NNIP Control Program on the HNF. We have called it the “No Change” alternative because it is likely limited mechanical and manual treatment of infestations of NNIP would still take place through separate decisions, as is the current practice. For the last several years, the HNF has accomplished approximately 30-50 acres of NNIP treatments each year. In the effects analysis for Alternative 1, we assumed that the Forest would continue to accomplish similar annual NNIP control treatments, focusing some of that effort in habitat for TES. Where NNIP threaten Federal species or RFSS, we made the assumption, due to explicit management direction for protection of TES (USDA 2006a, pp. 2-16 to 2-20), the Forest would continue to use mechanical and manual methods to control the threat at any sites that develop, since these are very high priority sites. We projected these assumptions out through a 5-year span of time, similar to the 5-year duration of integrated NNIP program under Alternative 2, for the purpose of estimating potential impacts of NNIP infestations.

Alternative 2: Manual/Mechanical, Chemical, and Biological Control of NNIP The HNF is proposing to implement a 5-year, Forest-wide NNIP Control Program, using a combination of control methods on roughly 135 known sites, and at any new sites found through monitoring (Table I-2). The program would be implemented on HNF lands within the Forest’s proclamation boundary. A map of the HNF is included in Appendix B. Approximately 40-70 acres a year would be treated, and possibly up to 200 acres per year, if funding allows. Follow up monitoring would evaluate the success of treatments and determine whether additional control measures were necessary. Treatments would occur across the HNF wherever NNIP are identified. Most control efforts would occur within disturbed, upland habitats, such as along roads, trails, and utility corridors, and in openings, forested stands, gravel pits and recreation sites. However, treatments could also occur in non-disturbed areas, such as forest understory, the Great Lakes shoreline, and along or within wetlands, which are among the locations where infestations have the potential to affect habitat for TES animals and plants.

Table I-1 shows the priority NNIP species on the HNF. Hound’s tongue (Cynoglossum officinale) has been added to the HNF list since scoping was completed. It is designated as a new species for the Forest with an “N” in the “Priority” column. Another species, giant hogweed (Heracleum mantegazzianum), has been identified as a “watch list” plant for the Forest (watch list species are plants present on adjacent forests but have not been found on the HNF). The number of currently known locations and the area these species occupy is summarized in Table I-2. The proposed treatment methods are summarized in Tables I-3, I-4, and I-5. We are not proposing to use prescribed surface fires as a control method.

Table I-1. Non-native Invasive Plants - Hiawatha National Forest Habitats Priority Common Name Scientific Name Invaded H Eurasian water milfoil Myriophyllum spicatum aquatic H Purple loosestrife Lythrum salicaria aquatic & open/wet H Marsh (swamp) thistle Cirsium palustre open/wet H Reed canary grass Phalaris arundinacea open/wet Common reed (non-native open/wet H Phragmites australis genotype) H Spotted knapweed Centaurea biebersteinii open H Diffuse knapweed Centaurea diffusa open H Canada thistle Cirsium arvense open H Bull thistle Cirsium vulgare open H White sweet clover Melilotus alba open H Yellow sweet clover Melilotus officinalis open H Leafy spurge Euphorbia esula open N Hound's tongue Cynoglossum officinale open H Wild parsnip Pastinaca sativa open H Common St. Johnswort Hypericum perforatum open M Smooth brome Bromus inermis open M Crown vetch Coronilla varia open M Common tansy Tanacetum vulgare open W Giant hogweed Heracleum mantegazzianum open M Common burdock Arctium minus open & shade M Scotch pine Pinus sylvestris open & shade H Honeysuckle Hybrids Lonicera X bella shade & open H Morrow honeysuckle Lonicera morrowii shade & open H Tartarian honeysuckle Lonicera tatarica shade & open H Glossy buckthorn Rhamnus frangula shade & open H Common buckthorn Rhamnus cathartica shade & open H Japanese barberry Berberis thunbergii shade H Garlic mustard Alliaria petiolata shade Priority: H = high; M = medium; W = watch list N = new invasive found on the HNF since scoping.

Table I-2. Known abundance of some NNIP - Hiawatha National Forest, April 2006 Number of Common Name Total Known Infested Acres Sites Garlic mustard 6 0.6 Common burdock 4 0.4 Smooth brome 1 1.0 Spotted knapweed 22 21.5 Non-native thistles 15 1.5 Leafy spurge 15 2.4 Common St. Johnswort 27 26.3 Purple loosestrife 27 28.8 Eurasian water milfoil 2 Not documented White sweet clover 3 3.0 Wild parsnip 6 1.2 Reed canary grass 4 2.0 Scotch pine 1 0.1 Common buckthorn 1 0.5 Hound's tongue 1 10.0 TOTAL 135 99.3 Note: Approximately 500 additional sites exist; however, the site location information was not sufficiently complete to include them at this time. When surveys identify precise locations, these sites would be incorporated into the NNIP control program.

Treatment Methods Protocol Alternative 2 is programmatic in nature to allow the use of integrated methods for the treatment of existing invasive plant infestations and those found in the future. A botanist would manage this additional aspect of the Forest’s NNIP program. Forest staff would determine which NNIP infestations to treat, methods and timing to use based on the listed protocol and design criteria.

1. The high-priority species listed in Table 1-1 would receive first consideration for treatment.  Of these high-priority species, the order of site treatment and methods would be determined by infestation size, location sensitivity, potential to spread, treatment urgency, and other factors. 2. High priority NNIP sites would be considered for treatment when infestations are identified as a resource concern.  Examples include infestations at active gravel pits, trailheads, recreation sites, and high- quality natural areas. 3. All control treatments would be designed to be effective based on the species biology and life history, yet minimize impacts on non-target plants, wildlife, water, recreation, and other resources 4. Prior to any treatments:  Forest staff in the areas of wildlife biology, botany, aquatics, soils, and heritage resources would review the proposed actions covered in this EA.  Treatments would be designed to minimize effects to associated resources and implement Forest Plan management direction.  The District Ranger for the corresponding sites would approve treatment actions pursuant to this EA. This could be accomplished in an annual treatment plan format, completed on an out-year basis.  Areas to receive ground disturbance would be surveyed to ensure protection of heritage resources. If any heritage resource sites were located, then appropriate protection measures would be implemented.  Areas to be treated would be reviewed by district wildlife and botany staff to ensure that survey requirements for TES specified in the 2006 Forest Plan are satisfied. 5. All treatments would be designed to minimize undesired impacts on native vegetation.  Retain native vegetation and limit soil disturbance as much as possible. If exposed soil results from NNIP control actions, revegetate exposed soils promptly to avoid re- colonization by NNIP.  Use only approved seed mixtures and weed free mulch.  Field personnel involved in NNIP treatment actions must be able to distinguish target NNIP from non-target native plants. 6. Equipment, boots, and clothing would be cleaned thoroughly before moving to another treatment site to ensure that NNIP seeds and parts capable of starting new plants are not spread. 7. Mechanical/manual control activities:  Mowing would be limited to roadsides or disturbed areas and timed to avoid spreading seeds.  Use of weed torches would be limited to times of low fire danger and when native vegetation is dormant, or only in areas that are already heavily disturbed. Wildland firefighters would be on site, as determined applicable after discussion with the Zone Fire Management Officer.  Manual or mechanical methods would be the principal approach for shallow-rooted species, but single deep-rooted plants such as purple loosestrife, leafy spurge, or glossy buckthorn could be considered for herbicide treatments.

8. Herbicide use:  Herbicide use could be indicated for infestations where manual or mechanical means would be cost-prohibitive or result in excessive soil disturbance or other resource damage.  When herbicide treatment is indicated, spot treatments, such as a sponge, glove or wick applicator, would be used whenever possible over broadcast spraying and as required for circumstances specified in design criteria (pp. 12-13).  Herbicide label directions would be followed. This could include temporary closure of treatment areas for public health and safety.  Only formulations approved for aquatic-use would be applied in or adjacent to wetlands, lakes, and streams.  Notices would be posted near all areas that have recently been treated with herbicides.  Herbicide application would only occur when wind speeds were less than 10 mph, or according to label direction, to minimize herbicide drift.  All private landowners, residents, and lake associations of affected lakes would be notified in advance of plans for aquatic herbicide application.  One option to minimize impacts to non-target vegetation would be to spray foliar applications when native vegetation is dormant. However, few NNIP (e.g. garlic mustard) are actively growing when native non-target plants are not growing.  If treating NNIP within 45 feet of a TES plant population, use a precise application technique, such as a herbicide applicator wick, sponge, glove or other spot treatment or manual method, such as pulling or cutting.  Set herbicide sprayers to a fairly large droplet size. 250-350 microns is best (Fischer 2006). Use a Drift Control additive according to label directions. Use a marker die, as necessary, to distinguish if herbicide spray hits non-target organisms or objects (quality control).  Buffer distance in design criteria (#11) below would be followed for herbicide not formulated to be used in or near waterways or areas with saturated ground conditions. 9. Biological Control:  The use of biological control could be indicated for infestations where eradication would be difficult due to costs or undesirable effects of alternative control methods.  Adjacent landowners would be contacted before the release of biological agents at a site. 10. The HNF NNIP Strategy is one document guiding implementation of this project. The strategy indicated priorities and methods and addresses Prevention, Education, and Cooperation. 11. Follow Forest and Regional Invasive Species strategies regarding public education to prevent invasions. 12. Determination of coastal zone consistency will be completed for all activities occurring within one-quarter mile from the Great Lakes high water mark

Design Criteria

These criteria apply to every invasive plant site.

General 1. All treatments would be designed to ensure that they do not negatively impact threatened, endangered, or sensitive plants and animals (TES). 2. Surveys for Federal threatened and endangered species (T&E) and Regional Forester Sensitive Species (RFSS) would be conducted as needed to meet 2006 Forest Plan management direction. Existing information, suitability of habitat and extent of treatment would be considered before implementing surveys. 3. If any T&E or RFSS species are observed during implementation of NNIP control activities (other than raptors flying by overhead), work would stop until the District wildlife biologist is consulted. Treatments would be revised as necessary to avoid impacts to the subject species. 4. When work is conducted in areas containing T&E or RFSS plants, those plants would be flagged or marked, and operators would be trained to visually recognize them. Where NNIP control activities occur within T&E plant sites a botanist would be present during treatments. 5. If new information such as survey data, observations by Forest Service employees, the public, or other reputable source indicates TES species are present at the sites to be treated, the effects analysis in the BE and design criteria/protections would be reviewed for adequacy.

Raptors 6. No treatments would be conducted within 1320 feet of known nests occupied by a bald eagle during the breeding season (February 14 – October 1). This distance includes all protection zones in the Northern States Bald Eagle Recovery Plan (NSBERP) (USFWS 2006, pp. 227-228). 7. No treatments would be conducted within 650 feet of known nests occupied by the northern goshawk, red-shouldered hawk, and short-eared owl during the breeding season (March 1 to August 31). 8. Should it be necessary to treat NNIP infestations using physical or chemical methods in the vicinity of a peregrine falcon nest, a wildlife biologist would be consulted for site specific recommendations to protect the nest. Generally, there are two protection zones around peregrine nest sites (eyries): a primary zone extending 660 feet from the cliff edge and below the nest and a secondary zone extending to 1,320 feet.

Wetlands/Shoreline/Dunes 9. Aquatic areas would be inspected for the presence of TES aquatic plant species before treatments are initiated in those areas. If TES plants are found the District botanist would be consulted prior to initiating treatments. 10. A wildlife biologist and botanist would review treatments proposed along or within calcareous wetlands, along Great Lakes shorelines, dunes, inland lakes and any riparian zones. These personnel would stop treatment if harm to TES species could result.

11. Buffer strips would be designated around water bodies (e.g. lakes, ponds, stream, wetlands, bogs, etc) inside of which no chemical would be used that is not registered for aquatic use. The following table, based on topography, would be used to determine the appropriate width of a buffer strip.

SLOPE OF LAND ABOVE WATER MINIMUM WIDTH OF STRIP BODY (%) (FEET) 0-10 100 10-20 115 20-30 135 30-40 155 40-50 175 50+ >175 – activity not advised Based on information in the Michigan Water Quality Management Practices on Forest Land (MDNR 1994)

12. No NNIP control would be conducted where piping plovers are present in order to protect adults, nests and young. 13. No treatments would be conducted in Hine’s emerald dragonfly habitat (i.e. wet meadows, fens, other wetlands) from the beginning of the second week in June through the end of August, and for RFSS dragonfly habitat from the beginning of the second week in April to the end of August. This would protect the dragonflies during their adult flight period. 14. When conducting control activities in known or potential Hine’s emerald dragonfly or RFSS dragonfly habitats, movement and disturbance activities would be minimized. 15. Riparian habitats suitable for use by Blanding’s turtle would be inspected by a wildlife biologist before NNIP treatments begin. Personnel working in riparian habitats would be trained to recognize Blanding’s turtles and this species nests and eggs in order to avoid trampling or disturbing them. NNIP treatments would not be conducted between May 10 and June 30 in riparian areas occupied by Blanding’s turtle. 16. Prior to initiating treatments in non-forested wetlands and lakes, check for the presence of black terns and trumpeter swans. The District Wildlife Biologist would be notified if the species are observed prior to treatment. Adjustments to treatments would be made to preclude harm to the species. 17. No treatments would be performed within 650 feet of active black tern or trumpeter swan nests during the breeding season (April 1 to August 1). 18. For protection of RFSS snails, prior to NNIP treatments, a wildlife biologist should be consulted for sites suspected of having suitable habitats, such as wetland sites, including tamarack-sedge wetlands, white cedar wetlands, fens and marl flats, and cliff or exposed rock outcrops. 19. The District wildlife biologist would be consulted prior to any treatments within areas known to be inhabited by Lake Huron locust, northern blue or suitable habitat for either species, such as dunes or Great Lakes shoreline, and open/dry beach areas. Any treatment in these habitats would be conducted by people who have been briefed about how to identify the insects and associated rare plants. 20. In order to protect northern blue and Lake Huron locust, in suitable or occupied habitat, herbicide use would be restricted to spot applications with such methods as glove application and sponge, and only after the area has been surveyed for these species.

Open Areas/Thickets 21. Treatments proposed for permanent openings in proximity to known and historic leks would be reviewed by a wildlife biologist prior to being implemented.

22. To protect nesting birds using thickets of NNIP, such as exotic honeysuckle and Japanese barberry, treatments would occur after August 1. Individual shrubs may be treated at any time if an inspection shows no nesting bird on or below the shrub. 23. NNIP treatments within or immediately adjoining jack pine stands occupied by Kirtland’s warblers would not be accomplished during the breeding season (May 1 – September 15).

Proposed Manual and Mechanical Methods The manual and mechanical control methods proposed for the NNIP is project are described in Table I-3. These methods are preferred, and would be most effective, when an infestation covers a small area.

Table I-3. Manual/mechanical control methods to be used under Alternative 2 Method Description of Action Hand-pull or dig up with a shovel the entire plant including roots – usually herbaceous plants. Leave plants on site, burn with a weed torch in a controlled area, or bag and remove if they Pull have mature flowers or fruit. Normally used for shallow-rooted individual plants or small patches. This technique may be used for, but is not limited to, garlic mustard, knapweed, St. Johnswort, and white sweet clover. Clip with pruning or lopping shears; cut with a saw, ax, brush cutter, weed whip, or mower; Cut girdle bark, disking, blading, plowing, etc. - used alone or following sponge-applied systemic herbicide. Normally used for such plants as honeysuckle, buckthorn, and Japanese barberry. Root Cut root just below ground level with narrow spade or similar tool. Plants are usually left on Stab site. Normally used for individual plant and small patches such as wild parsnip and thistles. Use the flame of a propane weed torch to scorch or wilt green leaves. This is normally done either early or late in the growing season when NNIP are green and native perennials are Scorch mostly below ground. Scorching would kill one year’s growth of annual and biennial weeds. It (flame) does not start a surface fire. This technique is especially useful for garlic mustard, sprouts of buckthorn, or similar NNIP.

Proposed Chemical (Herbicide) Methods To avoid negative impacts on non-target species, timing and herbicide type would be tailored to specific sites. All herbicides would be applied according to label directions. Potential herbicides were selected based on their effectiveness and low toxicity to non-target organisms. Table I-4 summarizes the chemicals proposed for use and their intended targets.

Herbicides are to be hand-applied by one of several methods: dabbing the chemical on the cut stump or basal bark with a brush, sponge, or roller; wand or glove application wiped on foliage; backpack or hand-held apparatus that directs a narrow spray.

Off-site drift can contact non-target organisms but every herbicide label must carry statements describing how to reduce this effect (Task Force 1990). Backpack sprayers should be set for a droplet size of 250-350 microns for best results (Fischer 2006). These large drops fall quickly (1-2 seconds), but given the highest wind speed allowed in this project, 10 mph (see protocol, p. 12), a Figure 1. Example of targeted spot spray of herbicide smaller 100-micron droplet could drift as (dark areas in center) on Garlic mustard in spring. much as 45 feet. A 350 micron droplet would only drift 7 feet with a 10 mph wind (SERA 2004a, p. 4-16). Spray drift is also affected by surrounding vegetation that would slow the wind (SERA 2004c, p. 4-22).

Herbicides would not be applied using airplanes or any other device where controlled spot application or coverage is not possible. Generally, there would be one chemical application per site per year with follow-up monitoring in subsequent years.

Table I-4. Herbicides proposed for use on various NNIP species under Alternative 2. Application Method Chemical Common Examples of Trade Examples of Targeted NNIP & Chemical Name Names Species Selectivity Stump and/or basal Buckthorn, barberry, Garlon3A, Brush-B- bark treatment, foliar triclopyr honeysuckle, wild parsnip, Gone Habitat, Vine-X spot spray; broadleaf- crown vetch selective Stump treatment or shrubs, garlic mustard, wild Roundup Pro, glyphosate foliar spray; non- parsnip, St. Johnswort, crown Roundup, Accord selective vetch, hound's tongue Purple loosestrife, swamp Foliar treatment, glyphosate (aquatic thistle, reed canary grass, Rodeo weeds near open formulation) common reed grass, and any water; non-selective species near open water Banvel, Clarity, Foliar treatment; Knapweed, leafy spurge, thistle, dicamba Vanquish broadleaf selective tansy Plateau, Plateau Eco- Foliar treatment; non- imazapic Leafy spurge Pak, Cadre selective Canada thistle, swamp thistle, Transline, Stinger, Foliar spray; clopyralid spotted knapweed, common Confront broadleaf-selective burdock, crown vetch

Table I-5. Potential for of-site movement of herbicides Application method Off-Site Drift Runoff* Leaching Foliar sprayer 45 to 3 feet with Very low chance for low potential - due to small droplet size 100 - 400 wind 10 mph damaging exposure at an amounts used - also see microns (virtually no drift Avg. application rate of Table I-6 (soil mobility) with wind 0 mph) 1lb/acre, and avg rainfall in MI of 32"/year Brush, roller, no drift insignificant volume would low potential due to low sponge reach ground to run off volume to cut stem or trunk Sources: SERA 2003a (glyphosate), SERA 2003b (triclopyr), SERA 2004a (dicamba), SERA 2004b (clopyralid), SERA 2004c (imazapic); (Tu et al. 2001, 2003, 2004); (Schulte 2006); In general, the primary hazard to non-target terrestrial plants associated with the application of herbicides is unintended direct deposition by spray drift or runoff; *design criteria No. 11 is directed at minimizing off-site movement of chemicals

Table I-6. General information for herbicides that could be used to control NNIP 1,2 Herbicide Application rate Soil Average Soil Water half-life mobility half-life glyphosate 2 lb a.e./acre (average rate), 7 lb low 47 days 12 days to 10 weeks a.e./acre (maximum rate) glyphosate 2 lb a.e./acre (average rate), 7 lb low 47 days 12 days to 10 weeks (aquatic a.e./acre (maximum rate) formulation) triclopyr (salt 1 lb a.e./acre (average rate), 10 lb moderate 30 days 4 days (hours in formulation) a.e./acre (maximum rate) -high sunlight) imazapic 0.10 lb a.e./acre(average rate), low 120-140 days <8 hours 0.1875 lb a.e./acre (maximum rate) Dicamba2 2 lb a.i./acre (foliar application), 1.5 lb high 14-28 7 days a.i./acre (cut surface application) clopyralid 0.1 lb a.e./acre (typical rate), mod-high 40 days 8-40 days 1.0 lb a.e./acre (maximum rate) Sources: 1Tu et al. 2001, 2003, 2004 and 2SERA 2004a (dicamba); application rates: SERA 2003a (glyphosate), SERA 2003b (triclopyr), 2SERA 2004a (dicamba), SERA 2004b (clopyralid), SERA 2004c (imazapic)

Proposed Biological Control Methods Biological control of NNIP involves releasing insects that feed on or parasitize specific plant species. The insects are typically native to parts of the world where the target plant occurs naturally, but have been approved for release in the United States by the United States Department of Agriculture. Biological control insects suppress host NNIP populations, but may not contain or eradicate them. Biological control of plants is a common practice on state, tribal, county, and private land in Michigan, Minnesota, and Wisconsin. Galerucella beetles to control purple loosestrife were released in Michigan as early as 1995 (Landis et al. 2003).

The use of biological control would be considered for infestations where eradication is difficult to achieve due to costs or where undesirable effects to non-target species could result from alternative control methods. Release of biological control agents (Table I-7) could take place following site analysis wherever there is a NNIP infestation on the HNF. However, this is only appropriate for invasive plant sites that are large enough to support a population of insects (Van Driesche et al. 2002). Studies indicated a minimum of at least one acre of purple loosestrife (OFAH 2003), two acres of leafy spurge with moderately dense patches (60-90 stems per square yard) (TEAM 2003), and two acres of spotted knapweed (Wilson & Randall 2005) are required for a successful release. HNF inventory data lists about 8 loosestrife sites over 1 acre in size that could support the Galerucella beetles. Other suitable insect release sites may be found in the future.

Integrated invasive plant management relies on a combination of control technologies. These include biological, mechanical, chemical, and cultural applications. Biological control organisms have found a niche in being effective on large infestations were long-term control is needed. Herbicides and manual/mechanical control provide a short-term control of small infestations and isolated plants, but may be not be practical against large, chronic infestations (Van Driesche et al. 2002, pp. 1-2).

Figure 2. lesser knapweed flower weevil (Photo: USDA ARS Archives) Biological control techniques take advantage of the fact that many non-native plants have arrived without be accompanied by their natural enemies. The identification of these specialized

insect predators and pathogens is the premise behind biological control of NNIP. The 1940’s is considered the beginning of classical biological plant control efforts in the United States.

As stated in Van Driesche et al. 2002 in the introduction to the book, “Biological control is the science of reconnecting invasive plants with the specialized natural enemies that often limit their density in their native ranges. This process consists of surveys in the plant’s area of origin to discover candidate natural enemies, studies on their biology and host specificity and release and evaluation of their impacts on the target plant. The U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) is responsible for controlling introductions of species brought into the United States for biological control of plants, in accordance with the requirements of several plant quarantine laws, the National Environmental Policy Act, and the Endangered Species Act. Petitions for release of plant biological control agents are judged by a Technical Advisory Committee (TAG), which represents the interests of a diverse set of federal and other agencies.” Figure 2 shows an example of a biological control insect, the lesser knapweed flower weevil. This is a small insect as evidenced by the human figure to the left in the picture. It feeds exclusively on its host plant, knapweed. All of the biological control insects proposed for NNIP on the HNF (Table I-7) have been used successfully in Michigan and/or other states in the U.S., and approved for use by APHIS and TAG. For the HNF, the list includes biological control insects for purple loosestrife (Van Driesche et al. 2002, pp. 149-157, Wilson et al. 2005); spotted knapweed (Van Driesche et al. 2002, pp. 169-180); Eurasian watermilfoil (Van Driesche et al. 2002, pp. 79-90); and leafy spurge (Van Driesche et al. 2002, pp. 79-90).

Table I-7. Biological control agents (insects) that could be used to control infestations of NNIP

Biological Control Insect3 Scientific Name Target Plant

Black-margined loosestrife beetle Galerucella calmariensis Purple loosestrife Golden loosestrife beetle Galerucella pusilla Purple loosestrife Loosestrife root weevil Hylobius transversovittatus Purple loosestrife Knapweed root weevil Cyphocleonus achates Spotted knapweed Lesser knapweed flower weevil Larinus minutus Spotted knapweed Copper leafy spurge flea beetle Aphthona flava Leafy spurge Brown-legged leafy spurge flea beetle Aphthona lacertosa Leafy spurge Black dot leafy spurge flea beetle Aphthona nigriscutis Leafy spurge Milfoil weevil Euhrychiopsis lecontei Eurasian water milfoil 3 Note: Entries in this table are examples only. Other more effective biological agents may become available in the future and would be considered as appropriate.

18 FINDINGS BY SPECIES

Methods

Information Review We performed the following tasks in order to determine pertinent information for this project analysis:

Reviewed findings from recent surveys conducted on the Forest Reviewed documents related to the 2006 Forest Plan Revision, such as the Biological Opinion (BO) (USFWS 2006) and Biological Assessment (USDA 2005) Conferred with Forest Service specialists and private individuals with knowledge to the NNIP control project and the HNF Discussed threatened and endangered species with U.S. Fish and Wildlife Service personnel

We reviewed the following data sources to identify known sensitive species locations in the project area and to help analyze effects of the project on TES species

Michigan Natural Features Inventory MNFI species viability evaluation database Habitat maps, vegetation maps, National Wetlands Inventory wetlands maps, and aerial photographs Conservation Assessments Internet sources such as NatureServe Explorer Journal articles, field guides, books and recent environmental analyses performed for other projects on the HNF

Forest Plan protective measures (Alternatives 1 and 2) See the HNF 2006 Forest Plan, Chapter 2 (especially, pp. 2-17 to 2-20) for Goals, Objectives, Standards, and Guidelines for management of all Threatened, Endangered, and Sensitive (TES) species. Generally, the HNF would contribute to the conservation and recovery of TES species (USDA 2006a, p. 2-20). . All known populations of federally threatened and endangered species would be protected. . Adverse impacts to Regional Forester Sensitive species would be avoided or mitigated. . Federal Recovery Plans and Regional Conservation Approaches would be implemented. . Non-native invasive plants within element occurrences of threatened and endangered and RFSS should be eliminated or controlled.

Framework for analyzing all listed species (Alternative 2): . Treatment sites would be surveyed for TES as determined appropriate through coordination with district wildlife staff and the NNIP program manager. . The NNIP Control Project Protocols (p. 10-11) and Design Criteria (p. 12-14) would be implemented. . Where TES are present, control methods would be tailored to protect them. . The intent of all control methods is to avoid harm to non-target plants, soil, insects, etc. . NNIP currently exist in relatively small patches scattered across the Forest and infestations are in an early stage.

Framework for analysis - Plants: We assumed a qualified botanist or biologist would manage the HNF integrated pest management program. The project actions vary by weed species, time of year, and by the restrictions outlined in the design criteria and protocol (pp. 10-14). The actions would depend on what weed is being treated. The current invasive plant inventory on the Forest is not sufficiently complete to know if there are TES plants at the NNIP sites. However, in the presence of TES plants, actions would be tailored to protect the rare plant. In a hypothetical example, if the methods to treat garlic mustard are hand pulling or application of glyphosate, these are still the choices of treatment despite the presence of green spleenwort. Using the methods in the project design we would not step on spleenwort, accidentally pull it, or spray it with glyphosate. After surveying, every effort would be made to protect non-target plants. The result in this example is that effects to non-target plants are expected to be minimal and insignificant.

We anticipate the effects of this project would be similar at any treatment site including those found in the future. The highest risk of negative effects of the HNF NNIP project, beside trampling or cutting non-target plants, would be the potential for herbicide spray to drift onto non-target plants. The herbicide drift potential for the purpose of this project is defined by the maximum distance (45 feet) of potential off-site drift and run-off of herbicide. Because off-site drift is more or less a physical process that depends on droplet size and meteorological conditions, rather than the specific properties of the herbicide, estimates of off-site drift can as determined based on the physical properties of liquids (SERA 2004a, p. 4-16)(Table I-6). Drift could vary from practically zero for spray with 400-micron size droplets and no wind, to a maximum of 45 feet for 100-micron droplets and 10 mph wind (Table I-6). Run-off would be virtually zero because of the small volume of mixture used on any one site and targeted application methods.

Framework for analysis - Animals: We assumed a qualified botanist or biologist would manage the HNF integrated pest management program, and that Forest Plan management direction and the design criteria and protocol (pp. 10-14) would be implemented. Other assumptions and effects are included by species or groups of species, as appropriate.

Federally Listed Species

Consultation with U.S. Fish and Wildlife Service (USFWS)

The Forest Service is initiating informal consultation with the Fish and Wildlife Service seeking concurrence with the determinations of effects in this BE. We concluded the proposed actions in Alternatives 1 and 2 may affect, but are not likely to adversely affect the following plants: American hart’s tongue fern, Pitcher’s thistle, lakeside daisy, dwarf lake iris, and Houghton’s goldenrod. We concluded the proposed actions in Alternatives 2 may affect, but are not likely to adversely affect the following animals: bald eagle, Canada lynx, gray wolf, Hine’s emerald dragonfly, Kirtland’s warbler, piping plover, and piping plover critical habitat.

We concluded actions under Alternative 1 would have no effect to the following animals and critical habitat: bald eagle, Canada lynx, gray wolf, Hine’s emerald dragonfly, Kirtland’s warbler, piping plover, piping plover critical habitat and proposed Hine’s emerald dragonfly critical habitat. We concluded actions under Alternative 2 would have no effect to the following critical

habitat: proposed Hine’s emerald dragonfly critical habitat. There is no concurrence required for these determinations.

In addition to consultation for bald eagle, Canada lynx, gray wolf, Hine’s emerald dragonfly, Kirtland’s warbler, and piping plover requested for this project, programmatic consultation was recently undertaken for Forest Plan revision. The history of this consultation is documented in the Programmatic Biological Assessment (BA) for the 2006 HNF Forest Plan (USDA 2005, p. 2) and associated Programmatic Biological Opinion (BO) (USFWS 2006). The relevance of program-level consultation to this project includes those agreements between the Forest Service and the Fish and Wildlife Service reached on defining elements of species’ ecology and biology, risk factors and general effects, analysis parameters, monitoring, and management direction in the revised Forest Plan. The HNF NNIP Control project BE provides more specific information on how relevant information in the programmatic BA is incorporated into the analysis. Additionally, other factors relevant to this project not discussed in detail in programmatic consultation would be discussed in greater detail in this BE. It is critical to note that the NNIP Control BE is closely connected to and can only be viewed in concert with both the programmatic BA and BO.

We documented consultation specific to the HNF NNIP Control EA in the project file. It includes emails and telephone calls between November 2007 and the submission of the BA to the FWS.

Plants

American Hart's tongue fern (Phillitus scolopendrium v. americanum) Occurrences on Forest: 6 sites. Federally Threatened. These populations have been counted approximately every two years during the last six years. There are about 30 occurrences in the United States. It is locally abundant but listed rare in Ontario. A recovery plan was signed for the species (USFWS 1993) that provides management guidance for “restoring and/or protecting” Hart’s tongue fern.

Habitat and Biology: Populations of Hart's tongue fern on the HNF grow on the sides of dolomite boulders or in grikes (solution cracks) in limestone or dolomite pavement known as alvar - itself a rare community (USFWS 1993; Albert 2006). Relatively young maple hardwoods with 91-96% canopy cover dominate the forest. The 2006 HNF Forest Plan BA has a more detailed biology and habitat description for this plant (USDA 2005, p. 307).

Threats by NNIP: Hart's tongue fern habitat is subject to infestation by invasive species, such as garlic mustard, buckthorn, Japanese barberry, burdock, and honeysuckle that can grow in shade. Although there no known NNIP threatening viability of individual Hart’s tongue fern plants at this time, a few species are known to be in the vicinity or within the element occurrences (USDA 2005, p. 311, USFWS 2006, p. 53). American Hart's tongue fern is slightly protected by its position on the sides of low boulders. However, it may be possible for garlic mustard to germinate there.

Factors related to the conservation of the species: The BA for the 2006 Forest Plan lists the following factors as important for the conservation of American Hart's tongue fern on the Forest (USDA 2005, pp. 308-311): 1. Timber harvest 2. NNIP competition 3. Collection

Forest Plan Direction specific to American Hart's tongue fern (USDA 2006a, Chapter 2)

Alternatives Forest Plan Guideline in or Standard1 Compliance Management Activity Notes/Specifics S-2600: Implement Yes Alt. 1 – NNIP control: current Alt. 1 – no change from recovery plan program current NNIP control Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) S-2600: Protect known Yes Alt. 1 – NNIP control: current Alt. 1 – no change from TE populations program current NNIP control Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Eliminate or Yes Alt. 1 – NNIP control: current Alt. 1 – no change from control NNIS in TE program current NNIP control occurrences Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Survey prior Yes Alt. 1 – NNIP control: current Alt. 1 – no change from to implementing program current NNIP control management Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Give Yes Alt. 1 – NNIP control: current Alt. 1 – no change from deference to listed program current NNIP control species where there Alt. 2 – NNIP control: integrated using Forest Plan are conflicts with manual/mechanical, herbicides, Alt. 2 – NNIP Control unlisted species biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Manage the Yes Alt. 1 – NNIP control: current Alt. 1 – no change from Niagara Escarpment to program current NNIP control protect American hart's Alt. 2 – NNIP control: integrated using Forest Plan tongue fern manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) 1GL-guideline; S-standard.

Analysis of Effects - American Hart's tongue fern - Alternative 1 (No Change)

Direct and Indirect Effects Implementing Alternative 1 would have minimal short-term direct effect on Hart's tongue fern. The federally threatened plant sites are monitored with some regularity and are considered "high Priority" for NNIP control. If invasive plants are controlled at these sites, there is already a protocol in place to pull NNIP manually. The indirect threat of degradation of fern habitats by NNIP is low at this time because there are few NNIP at the fern sites (USDA 2005, p. 311).

Cumulative Effects

Because the risk of effects is so small as to be discountable, Alternative 1 would not add to any effects of past, present, or reasonably foreseeable future activities.

Analysis of Effects - American Hart's tongue fern - Alternative 2 (Proposed Action)

Direct and Indirect Effects There would be minimal direct effects to Hart's tongue fern. There are limited NNIP present in proximity or within some of the six fern populations (USDA 2005, p. 311). Therefore, few control actions would take place over the short term. NNIP occur on the roads nearby and could become an indirect threat. If NNIP are found during future monitoring of plant sites, project designs used during treatment would minimize effects to were they are discountable. Indirectly, there would be a beneficial effect of controlling NNIP in occupied or unoccupied habitats.

Mechanical or manual method of treatment - There is a risk of damaging ferns while removing invasive plants with manual methods. Hand-pulling herbaceous weeds or cutting shrubs would be the manual methods in this forest habitat. In the event NNIP would be treated near Hart's tongue fern in the future, project design criteria and protocol (especially No. 7) would minimize any risk to where it is negligible. Walking around in a site to pull weeds has no greater impact than monitoring activities that already take place.

Chemical Treatment - Herbicide has the potential for contacting non-target plants if sprayed. The result might be mortality or injury to the non-target plant. The design criteria for herbicide use ensure an insignificant risk to listed rare plants due to buffer zones and careful spot spray treatment or direct dabbing of the chemical. Herbicide would not be applied where it could contact any rare plants. Herbicides proposed to treat NNIP that would occur in forest habitat are glyphosate and triclopyr. Both have short half-lives (average less than 50 days) and low leach potential. Therefore, they would have insignificant non-target effects (Tu et al. 2001).

Biological Control - Biological control insects are host-specific and only feed on the target weeds (APHIS 1994). It is unlikely that biological control insects would be used at, or in proximity to, the Hart’s tongue fern sites since there are no known NNIP threats. However, should biological control be indicated as an appropriate treatment, there is no risk to this non-target plant from the insects listed in Table I-7.

Cumulative Effects Because the risk of effects is so small as to be discountable, the Alternative 2 would not add to any effects of past, present, or reasonably foreseeable future activities. The removal of NNIP from near and within suitable unoccupied Hart's tongue fern habitat may improve habitat in the long-term.

Determination Alternative 1 – May affect, not likely to adversely affect Alternative 2 – May affect, not likely to adversely affect

The Endangered Species Act (ESA) requires a determination of “may affect, not likely to adversely affect", when the effects are expected to be discountable, insignificant or completely beneficial. Insignificant effects are small in size and should not reach the scale where take occurs. Discountable effects are extremely unlikely to occur.

Pitcher's thistle (Cirsium pitcheri) Occurrences on Forest: 2 sites. Federally Threatened

The two sites on the Forest are both in Mackinac County. There are about 38 occurrences in the Upper Peninsula of Michigan and 173 range-wide. A recovery plan was signed for this species that provides management guidance for “restoring and/or protecting” Pitcher's thistle (USFWS 2002).

Habitat and Biology: Pitcher's thistle is endemic to the unforested sand dunes of the western Great Lakes and requires active sand dune processes to maintain its early successional habitat (USFWS 2002, p. 39).

Threats by NNIP: Pitcher's thistle habitat is threatened by invasive species that grow in full sun and can stabilize the shifting sand that it requires. Invasive plants such as sweet clover, spotted knapweed, leafy spurge, bull thistle, and baby's breath (Gypsophila paniculata) can also crowd it out. According to field surveys, Scotch pine and several other NNIP are present at the two pitcher's thistle occurrences. However, currently the numbers of NNIP are low at both HNF sites and have been removed manually since 2000 (USDA 2005, p. 290, USFWS 2006, pp. 75- 76). Highway U.S. 2 runs through one of the Pitcher's thistle sites and could introduce or re- introduce NNIP.

Factors related to the conservation of the species: The BA for the 2006 Forest Plan lists the following factors as important for the conservation of Pitcher's thistle on the Forest (USDA 2005, pp. 288-290): 1. NNIP competition 2. Impacts from road management 3. Dune stabilization 4. Recreation use

Forest Plan Direction specific to Pitcher's thistle (USDA 2006a, Chapter 2)

criteria (pp. 10-14) GL-2600: Give Yes Alt. 1 – NNIP control: current Alt. 1 – no change from deference to listed program current NNIP control species where there Alt. 2 – NNIP control: integrated using Forest Plan are conflicts with manual/mechanical, herbicides, Alt. 2 – NNIP Control unlisted species biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Manage the Yes Alt. 1 – NNIP control: current Alt. 1 – no change from Great Lakes shoreline program current NNIP control to protect Pitcher's Alt. 2 – NNIP control: integrated using Forest Plan thistle manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Use bio- Yes Alt. 1 – NNIP control: current Alt.1 – no biological control of NN thistles if program control proposed they will not negatively Alt. 2 – NNIP control: integrated Alt. 2 – no biological impact Pitcher's thistle manual/mechanical, herbicides, control insects targeting biological (insects) thistle species 1GL-guideline; S-standard.

Analysis of Effects - Pitcher's thistle - Alternative 1 (No Change)

Direct and Indirect Effects Implementing Alternative 1 would have no short-term direct effect on Dune thistle. Invasive plants are currently present at the two sites and are considered an indirect risk. The "No Change" alternative would likely result in manual methods to control NNIP at these location. Threatened plant sites, are considered "high priority" for NNIP control and some manual pulling has occurred (LeBlanc 2006). Therefore, implementing this alternative would likely continue that process, providing protection for these sites. Thus, loss of individuals from NNIP infestations would pose a minimal risk.

Cumulative Effects Because the effects of implementing Alternative 1 would be minimal, they would have little or no incremental effect when combined with the effects of past, present, or reasonably foreseeable future activities.

Analysis of Effects - Pitcher's thistle - Alternative 2 (Proposed Action)

Direct and Indirect Effects Direct effects to Pitcher's thistle would be discountable. Invasive plants exist at the two pitchers' thistle sites (USDA 2005, p. 290). However, the NNIP have been manually pulled with no negative effects to the Pitcher’s thistle. Additional control actions at these sites would have the potential to kill or damage Pitcher’s thistle (see below), but project design (p. 12) would minimize effects to where that outcome would be extremely unlikely. Removal of NNIP within Pitcher's thistle habitat would decrease competition pressure and provide an indirect benefit.

Mechanical or manual method of treatment - There would be a risk of damaging plants while removing NNIP by pulling, but this method has been used over the past few years with no negative effects. Mowing species like spotted knapweed would generally be used on roadsides or solid patches, locations where Pitcher’s thistle is not present. Design criteria and protocol (pp. 10-12) would further minimize any risk to where it would be negligible by requiring Pitcher’s thistle habitat to be surveyed and plant occurrences marked prior to any treatments.

Chemical Treatment - The design criteria for herbicide use, such as buffer distances from rare plants, would ensure a very low risk to non-target plants from careful spot treatment. Herbicide would not be sprayed in such a manner that it would drift onto Pitcher's thistle.

Biological Control - It is unlikely that bio-control insects would be used at the Pitcher's thistle sites, as the NNIP populations are currently too small to support a population of the insects. The only biological control agents that would be considered include knapweed root weevil and flower weevil. These two insects are specific feeders on knapweed and would not harm thistles (APHIS 1994).

Cumulative Effects Because the risk of effects is so small as to be discountable, the Action alternative would not add to any effects of past, present, or reasonably foreseeable future activities. The removal of NNIP from near and within suitable unoccupied Pitcher's thistle habitat may improve viability in the long-term.

Determination Alternative 1 – May affect, not likely to adversely affect Alternative 2 – May affect, not likely to adversely affect

Lakeside daisy (Hymenoxys herbacea) Occurrences on Forest: 1 site. Federally Threatened. This population of lakeside daisy occurs on two sides of a county road within the Forest boundary on federal and state land. It is a Great Lakes endemic with less than 10 occurrences in the U. S. (Michigan, Ohio, and Illinois) and about 20 sites in southern Ontario (NatureServe 2006). A recovery plan was signed for this species (USFWS 1990) that provides management guidance for “restoring and/or protecting” lakeside daisy.

Habitat and Biology: Lakeside daisy habitat is restricted to barren dolomite and limestone outcrops typical of alvar and limestone prairie on shorelines of the Great Lakes The 2006 HNF Forest Plan BA has a more detailed biology and habitat description for this plant (USDA 2005, p. 229).

Threats by NNIP: The known occurrences of lakeside daisy were surveyed in June 2005. No NNIP were observed in the immediate vicinity of the Lakeside daisy. However, several NNIP, including spotted knapweed, wild parsnip, and orchard grass, were found along the roadside in proximity to the occurrences (USDA 2005, p. 233, USFWS 2006, p. 64). Some manual control of roadside NNIP has been done in the past. Other threats include damage by OHV recreation and construction vehicles. Michigan Department of Transportation has signed the road right-of- way in the immediate vicinity of the lakeside daisy population as a protected area.

Factors related to the conservation of the species: The BA for the 2006 Forest Plan lists the following factors as important for the conservation of lakeside daisy on the Forest (USDA 2005, pp. 232-234): 1. Genetics/Natural disturbance/Stochastic events 2. Road and utility maintenance

3. Timber harvest 4. Collection 5. NNIP competition/Ecological changes 6. Off highway vehicle use

Forest Plan Direction specific to lakeside daisy (USDA 2006a, Chapter 2)

Alternatives Forest Plan Guideline in or Standard1 Compliance Management Activity Notes/Specifics S-2600: Implement Yes Alt. 1 – NNIP control: current Alt. 1 – no change from recovery plan program current NNIP control Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) S-2600: Protect known Yes Alt. 1 – NNIP control: current Alt. 1 – no change from TE populations program current NNIP control Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Eliminate or Yes Alt. 1 – NNIP control: current Alt. 1 – no change from control NNIS in TE program current NNIP control occurrences Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Survey prior Yes Alt. 1 – NNIP control: current Alt. 1 – no change from to implementing program current NNIP control management Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Give Yes Alt. 1 – NNIP control: current Alt. 1 – no change from deference to listed program current NNIP control species where there Alt. 2 – NNIP control: integrated using Forest Plan are conflicts with manual/mechanical, herbicides, Alt. 2 – NNIP Control unlisted species biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Manage the Yes Alt. 1 – NNIP control: current Alt. 1 – no change from Alvar community to program current NNIP control protect lakeside daisy Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) 1GL-guideline; S-standard.

Analysis of Effects - Lakeside daisy - Alternative 1 (No Change)

Direct and Indirect Effects Implementing Alternative 1 would have no short-term direct effect on lakeside daisy. Documented invasive plants on road edges near this occurrence pose a minimal indirect threat at this time (USDA 2005, p. 233), as they are not located within the general area of the plants. Threatened plant sites are considered "high priority" for NNIP control and some manual pulling

has occurred (LeBlanc 2006). Therefore, implementing this alternative would likely continue that process, providing protection for these sites. Thus, loss of individuals from NNIP infestations would pose a minimal risk.

Analysis of Effects - Lakeside daisy - Alternative 2 (Proposed Action)

Direct and Indirect Effects There would be no direct effects to lakeside daisy under this alternative. Control actions at these sites would have the potential to kill or damage lakeside daisy but project design (p. 12) would minimize effects to where that outcome would be extremely unlikely to occur. Removal of NNIP within lakeside daisy habitat would decrease competition pressure and provide an indirect benefit. Removal of NNIP if found within lakeside daisy habitat would prove beneficial by decreasing the chance of negative effects of invasive plants.

Mechanical or manual method of treatment - There is currently no risk of damaging or killing lakeside daisy plants while removing NNIP with manual methods as no invasive plants are in the immediate vicinity of the occurrences (USDA 2005, p. 233). If control within the population becomes necessary, design criteria would afford protection, so that risks would be minimal. Michigan DOT placed signs on the road to protect plants from inadvertent mowing and other maintenance work.

Chemical Treatment - Methods of applying herbicide such as sponge or glove application (protocol and design criteria, pp. 10-12) would reduce the chance of hitting a non-target plant to virtually zero. Herbicide would not be sprayed where it can drift to lakeside daisy. Thus there would be no adverse effects from herbicide use.

Biological Control – Biological control insects are host-specific and only feed on the target weeds (APHIS 1994). It is unlikely that bio-control insects would be used at, or in proximity to, the lakeside daisy site as populations of knapweed on the HNF may not be large enough to support the insects (Wilson & Randall 2005). Furthermore, if insects were used for knapweed they would have no effect on lakeside daisy due to the host specific nature of the insects proposed for use in Table I-7.

Cumulative Effects Because the risk of effects is so small as to be insignificant, the Action alternative (Alternative 2) would not add to any effects of past, present, or reasonably foreseeable future activities. The removal of NNIP from near and within suitable unoccupied Lakeside daisy habitat may improve viability for lakeside daisy in the long-term.

Determination Alternative 1 – May affect, not likely to adversely affect Alternative 2 – May affect, not likely to adversely affect

Dwarf lake Iris (Iris lacustris) Occurrences on Forest: 3 sites. Federally Threatened. The known locations of Dwarf lake iris on the HNF are on Round Island Wilderness and within two candidate Research Natural Areas (Wedens Bay and Pointe aux Chenes) (USDA 2005, pp. 246-247, USFWS 2006, p. 102). There are 70 sites in Michigan. Dwarf lake iris was listed as threatened in 1988. As of March 2007, there was no federal Recovery Plan for the species.

Habitat and Biology: Dwarf lake iris is endemic to the northern shores of Lake Huron and Lake Michigan, and restricted to the ancient and modern shorelines with calcareous rock or soils. Habitat is beach ridges and stabilized dunes, limestone ledges, forest gaps and edges often with northern white cedar (Thuja occidentalis) and roadsides. The 2006 HNF Forest Plan BA has a more detailed biology and habitat description for this plant (USDA 2005, pp. 245 - 246).

Threats by NNIP: Non-native honeysuckles were found in 2000 at the site in Round Island Wilderness. NNIP are thought to be established in low numbers at the Wedens Bay and Pointe aux Chenes cRNAs sites (USDA 2005, p. 248, USFWS 2006, p. 102).

Factors related to the conservation of the species: The BA for the 2006 Forest Plan lists the following factors as important for the conservation of dwarf lake iris on the Forest (USDA 2005, pp. 247-248): 1. NNIP competition 2. Human disturbance

Forest Plan Direction specific to dwarf lake iris (USDA 2006a, Chapter 2)

GL-2600: Give Yes Alt. 1 – NNIP control: current Alt. 1 – no change from deference to listed program current NNIP control species where there Alt. 2 – NNIP control: integrated using Forest Plan are conflicts with manual/mechanical, herbicides, Alt. 2 – NNIP Control unlisted species biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Manage the Yes Alt. 1 – NNIP control: current Alt. 1 – no change from Great Lakes shoreline program current NNIP control to protect dwarf lake iris Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) 1GL-guideline; S-standard.

Analysis of Effects - Dwarf lake iris - Alternative 1 (No Change)

Direct and Indirect Effects Implementing Alternative 1 would have minimal short-term direct effect on Dwarf lake iris. Honeysuckle at the Round Island site may cast shade onto dwarf lake iris or have an allelopathic effect. This might cause death or decreased viability of the plant, but is considered a minimal risk. NNIP at the other 2 sites also present minimal risk, because the numbers of invasive plants are low. Threatened plant sites are considered "high priority" for NNIP control and are monitored with some regularity (LeBlanc 2006). Therefore, implementing this alternative would likely continue that process, supplementing surveys with manual NNIP control as needed. Thus, loss of individuals from NNIP infestations would pose a minimal risk.

Cumulative Effects Because the effects of implementing Alternative 1 would be minimal and discountable, they would have little or no incremental effect when combined with the effects of past, present, or reasonably foreseeable future activities.

Analysis of Effects - Dwarf lake iris - Alternative 2 (Proposed Action)

Direct & Indirect Effects Implementing the proposed action would have no measurable direct effect on dwarf lake iris. Project design would minimize direct effects to iris plants to where they are discountable. Indirectly, removal of NNIP within dwarf lake iris habitat would be beneficial.

Mechanical or manual method of treatment - There is a risk of damaging iris plants while removing invasive plants with manual methods. Honeysuckle can be cut, not dug next to iris. Design criteria and protocol (pp. 10-12) would result in minimal risk of mortality and injury to the species. Where dwarf lake iris is present during NNIP treatment a botanist would be present, a factor that further minimizes the risk to the species during manual control.

Chemical Treatment – It would be possible for herbicide to contact dwarf lake iris during treatment, causing injury or death of the non-target plant. However, the protocol and design criteria for herbicide use, such as establishing buffer distances from rare plants, flagging locations of T&E plants and having botany overseeing the program ensure a very low risk to non-target plants from careful spot treatment (pp 10-12). Herbicide would not be sprayed where it can drift to lakeside daisy. Thus, considering the mitigations and protections under Alternative 2, the risk of damage to dwarf lake iris plants from herbicide is minimal and discountable.

Biological Control – Biological control insects are host-specific and only feed on the target weeds (APHIS 1994). There are no biological control methods to treat honeysuckle. If knapweed or leafy spurge were found in the future at the dwarf lake iris sites, it is unlikely biological control insects would be used because the prospects that populations of host weeds would be large enough to support the insects is unlikely. For example, patches of spotted knapweed must be at least 2 acres in size to support bio-control insects (Wilson & Randall 2003). Furthermore, if insects were used for knapweed they would have no effect on dwarf lake iris because the insects are host specific.

Cumulative Effects Because the risk of effects under Alternative 2 would be so small as to be insignificant, it would not add to any effects of past, present, or reasonably foreseeable future activities. The removal of NNIP from near and within suitable unoccupied dwarf lake iris habitat may improve viability in the long-term.

Determination Alternative 1 – May affect, not likely to adversely affect Alternative 2 – May affect, not likely to adversely affect

Houghton's goldenrod (Solidago houghtonii) Occurrences on Forest: 9 sites. Federally Threatened The recovery plan lists eight Houghton's goldenrod occurrences on the HNF (USDA 2005, p. 263). One additional site is listed in the MNFI database (USFWS 2006, p. 90). A federal Recovery Plan was signed in 1997 (USFWS 1997a).

Habitat and Biology: Houghton's goldenrod is endemic to the north shores of Lake Huron and Lake Michigan (USDA 2005, p. 261). It is found in open situations where there is relatively little competing vegetation. Occurrences are found in interdunal wetlands paralleling the shore, on sandy or cobble beach flats, and on seasonally wet limestone pavements. The HNF has two atypical occurrences at the edge of marl ponds on ancient shorelines or lakebeds now located inland from the present shores of the Great Lakes (USFWS 1997a, p. 10). The 2006 HNF Forest Plan BA has a more detailed biology and habitat description for this plant (USDA 2005, pp. 261-262).

Threats by NNIP: In addition to competing for nutrients and space, weeds can also stabilize dune slopes and prevent the dynamic movement of sand by the wind that creates and renews suitable habitat for Houghton’s goldenrod. The 2006 HNF Forest Plan BA indicates that a few NNIP species are present in low numbers at all sites. The text refers to knapweeds, sweet clover, and baby’s breath as being present (USDA 2005, p. 265, USFWS 2006, p. 90).

Factors related to the conservation of the species: The BA for the 2006 Forest Plan lists the following factors as important for the conservation of Houghton’s goldenrod on the Forest (USDA 2005, pp. 262-264): 1. NNIP competition 2. Human disturbance 3. Interruption of dune processes

Forest Plan Direction specific to Houghton’s goldenrod (USDA 2006a, Chapter 2)

Alternatives Forest Plan Guideline in or Standard1 Compliance Management Activity Notes/Specifics S-2600: Implement Yes Alt. 1 – NNIP control: current Alt. 1 – no change from recovery plan program current NNIP control Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) S-2600: Protect known Yes Alt. 1 – NNIP control: current Alt. 1 – no change from TE populations program current NNIP control Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Eliminate or Yes Alt. 1 – NNIP control: current Alt. 1 – no change from control NNIS in TE program current NNIP control occurrences Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Survey prior Yes Alt. 1 – NNIP control: current Alt. 1 – no change from to implementing program current NNIP control management Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Give Yes Alt. 1 – NNIP control: current Alt. 1 – no change from deference to listed program current NNIP control species where there Alt. 2 – NNIP control: integrated using Forest Plan are conflicts with manual/mechanical, herbicides, Alt. 2 – NNIP Control unlisted species biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Manage the Yes Alt. 1 – NNIP control: current Alt. 1 – no change from Great Lakes shoreline program current NNIP control to protect Houghton's Alt. 2 – NNIP control: integrated using Forest Plan goldenrod manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) 1GL-guideline; S-standard.

Analysis of Effects - Houghton's goldenrod - Alternative 1 (No Change)

Direct and Indirect Effects Implementing Alternative 1 would have no short-term direct effect on Houghton's goldenrod. Threatened plant sites are considered "high priority" for NNIP control and are monitored with some regularity (LeBlanc 2006). Therefore, implementing this alternative would likely continue that process, supplementing surveys with manual NNIP control as needed. Thus, loss of individuals from NNIP infestations would pose a minimal risk.

Cumulative Effects

Because the effects of implementing Alternative 1 would be minimal and insignificant, they would have little or no incremental effect when combined with the effects of past, present, or reasonably foreseeable future activities.

Analysis of Effects - Houghton's goldenrod - Alternative 2 (Proposed Action)

Direct and Indirect Effects Direct effects to Houghton's goldenrod would be discountable. Invasive plants are known from all sites. However, there are few species, which occur in low numbers (USDA 2005, p. 265). Control actions have the potential to cause harm by killing or damaging plants. However, protocols and project design under Alternative 2 (pp. 10-12) would minimize effects to where direct effects are extremely unlikely. Removal of NNIP within Houghton's goldenrod habitat would decrease competition pressure and provide an indirect benefit.

Mechanical or manual method of treatment - Manual pulling would be a preferred method of invasive control immediately adjacent to rare plants. There is a risk of damaging or killing Houghton’s goldenrod plants while removing invasive plants with manual methods. Design criteria and protocol (pp. 10-12) would result in minimal risk of mortality and injury to the species. Where Houghton’s goldenrod is present during NNIP treatment a botanist would be present, a factor that further minimizes the risk to the species during manual control.

Chemical Treatment - Herbicide has the potential for contacting non-target plants if sprayed. This could result in the damage to the non-target plant or death. The protocol for herbicide use (p. 11), such as buffer distances from T&E plants ensures a very low risk to non-target plants from careful spot treatment. Herbicide would not be sprayed where it could drift to Houghton's goldenrod. Thus the risk of damage to goldenrod plants from herbicide control techniques would be minimal and discountable.

Biological Control – Biological control insects are host-specific and only feed on the target weeds (APHIS 1994). It is unlikely that biological control insects would be used at the Houghton's goldenrod sites, because the prospects that populations of host weeds would be large enough to support the insects is unlikely. For example, patches of spotted knapweed must be at least 2 acres in size to support biological control insects (Wilson & Randall 2003). Furthermore, if insects were used for knapweed they would have no effect on Houghton’s goldenrod because the insects are host specific.

Cumulative Effects Under Alternative 2 the risk of effects would be so small as to be insignificant. Thus, Alternative 2 would not add to any effects of past, present, or reasonably foreseeable future activities. The removal of NNIP from near and within suitable unoccupied Houghton's goldenrod habitat may improve viability in the long-term.

Determination Alternative 1 – May affect, not likely to adversely affect Alternative 2 – May affect, not likely to adversely affect

Michigan monkey-flower (Mimulus glabratus var. michiganensis) "likely to occur" Occurrences on Forest: None. Federally Endangered There are no occurrences of Michigan monkey-flower on the HNF but there is suitable habitat (Leblanc 2006). We are analyzing potential effects of this project in the event that monkey- flower is discovered. Hiawatha National Forest botanists and others have searched likely habitats over the past 15 years with no success. There are currently 15 extant occurrences Michigan with some close to the Forest boundary. A federal Recovery Plan was signed in 1997 (USFWS 1997b).

Habitat and Biology: The global range of Michigan monkey-flower is restricted to 6 counties of Michigan, where it occurs in the Grand Travers and Straits of Mackinac regions (Voss 1996). Habitat is cold, flowing spring seepages and alkaline streams (does best in gaps in the canopy of northern white cedar swamps at the base of steep bluffs (USFWS 1997b, p. 10-11)

Threats by NNIP: The Recovery Plan does not list NNIP as a threat (USFWS 1997b) but glossy buckthorn could invade this species habitat in the future. The greatest conservation need is protection of habitat (MNFI 2006).

Analysis of Effects - Michigan monkey-flower - Alternative 1 (No Change)

Direct, Indirect and Cumulative Effects There are no occurrences on the HNF, so there would be no direct, indirect or cumulative effects. If it is discovered, and NNIP need to be controlled, effects would be similar to other federally listed plants for Alternative 1.

Analysis of Effects - Michigan monkey-flower Alternative 2 (Proposed Action)

Direct, Indirect and Cumulative Effects Since there are no occurrences on the HNF, there would be no direct, indirect or cumulative effects. If it is discovered, and NNIP need to be controlled, effects would be similar to other federally listed plants above because the actions would be the same. Protecting essential habitat is the primary conservation measure, so it follows that prevention and control of invasive plants would work toward that objective. None of the biological control agents chosen would feed on this family of plants (figwort family).

Determination Alternative 1 – No determination is appropriate - this species does not occur on the HNF Alternative 2 – No determination is appropriate - this species does not occur on the HNF

General Summary for T&E Plants Alternative 2 would provide the most benefits to T&E plants. While Alternative 1 would likely provide for a limited acreage of manual control around high priority sites, such as T&E occurrences, Alternative 2 would be most likely to exceed historic treatment acres (approximately 30-50 acres each year), since it would be a 5-year program with a decision in place. The greater maximum treatment acreage (200) under Alternative 2 would provide the botany program manager with options not available under Alternative 1 for adapting management methods to changing circumstances over the ensuing five years. Incorporating manual/mechanical, herbicides and biological (insect releases) with prevention and education strategies would give managers maximum flexibility to design an annual plan to target NNIP, protect TES species, and deal with sites and extensive coverage that may be beyond the capabilities of manual treatments.

Animals

Tables E-1, E-2, and E-3 provide herbicide information for all of the animals and groups analyzed in this BE. Thus, they preface the effects analysis.

Table E-1 presents mammalian toxicity data from the 2006 edition of the Herbicide Handbook (WSSA 2006) for each of the five herbicides selected for use in the proposed program. The data reflect the potential for toxicity to terrestrial mammalian wildlife exposed to areas treated with the herbicides. The data consist of LD50, LC50, and NOEL values. A LD50 (Lethal Dose50) represents the dose (amount supplied orally) to a test animal species in a controlled laboratory experiment that causes 50 percent mortality. An LC50 (Lethal Concentration50) represents the concentration causing 50 percent mortality when a test animal species is externally exposed to the chemical in a controlled laboratory experiment. A NOEL (No Observed Effects Level) represents the highest dose or concentration (expressed as mg per kg body weight per day) observed not to cause noticeable effects in a test animal in a controlled laboratory experiment. For all three parameters, a higher value indicates a safer (less toxic) chemical.

Data are presented for two categories of toxicity: acute and chronic. Acute toxicity results from exposure to the chemical for a short time, for example when an animal enters an area immediately after herbicide application when the foliage is still wet. Chronic toxicity results from continuous exposure to the chemical over an extended time, for example should an animal inhabit an area that is repeatedly sprayed with a herbicide at regular intervals over multiple years. Because the proposed program would consist mostly of single applications, or at most, an initial application and one to three subsequent applications, the acute toxicity data is most relevant. For each herbicide, we presented separate rows of data in Table E-1 for the technical product (unformulated active ingredient) and for several common formulations. How a product is formulated can significantly affect its toxicity. Because it is the formulations and not the technical product that are used in the field, formulation data are more relevant, if available. While data based on exposure of mammalian test organisms are a useful predictor of toxicity to mammalian wildlife, they are less useful as a predictor of toxicity to birds, fish, and other wildlife whose physiology substantially differs from that of mammals.

Table E-2 presents toxicity data generated specifically for these other types of wildlife. Because mammalian toxicity data are also useful in assessing toxicity to humans, they are usually more widely available. However, when data based on other animals is available, they are more useful for assessing potential impacts to those animals and associated groups of animals.

Table E-3 includes information related to minimum, average and maximum application rates, when available, for the chemicals included in the proposed actions. The table presents ecological risk assessments summarized from Forest Service publications and Cornell University publications for the proposed herbicides. The ecological risk assessments consider not only the potential toxicity of herbicides to ecological receptors but also the likelihood of exposure of receptors to the herbicides. Thus, they provide a more realistic assessment of risk to ecological receptors from herbicide use than do toxicity data alone.

Herbicides on the market today are generally regarded as safe to both humans and to wildlife if used in accordance with the manufacturer label. For purposes of comparison against data in Table E-1, the oral LD50 for rats exposed in their diet to table salt (sodium chloride) is reported at 3,000 mg/kg body weight (BW) (Mallinckrodt Baker Inc. 2004), which is somewhat lower (less safe) than the oral rat LD50 values for most formulations of glyphosate and clopyralid.

Furthermore, the oral LD50 data suggests that most of the other herbicide formulations are not substantially more toxic than table salt. For purposes of comparison against aquatic toxicity metrics in Table E-2, the reported 48-hour LC50 for Daphnia pulex exposed to table salt is 1,470 milligrams per liter (mg/L) (Salt Institute 2004); this value is lower (less safe) than the corresponding values for most herbicide formulations reported in the table. Values for many of the formulations do not greatly differ from this value.

Table E-1. Mammalian toxicity data for herbicides proposed for non-native invasive plant (NNIP) control on the HNF as part of the proposed action (Alternative 2) Herbicide Acute Toxicity Chronic Toxicity (Technical product unless Oral Dermal 4-Hour Skin Skin Eye 24-Month 24-Month 12-Month specific formulation noted) LD50 LD50 Inhalation Irritation Sensitization Irritation Dietary Dietary Dietary (rat) (rabbit) LC50 (rabbit) (guinea pig) (rabbit) NOEL NOEL NOEL (rat) (mouse) (rat) (dog) mg/kg BW mg/L mg/kg BW/day Glyphosate Glyphosate acid 5600 >5000 NA None No Slight 4500 400 500 Glyphosate >5000 >5000 NA None No Slight Chronic toxicity data available isopropylamine salt only for technical glyphosate acid Glyphosate trime- 748 >2000 >5.18 Mild Mild Mild thylsulfonium salt (unspec.) ROUNDUP >5000 >5000 3.2 None No Moderate RODEO >5000 >5000 1.3 None No None Imazapic Imazipic acid >5000 >5000 NA None No Slight Long-term dietary administration produced no adverse effects in mice and rats. Imazipic ammonium salt >5000 >5000 2.4 None No None Chronic toxicity data available PLATEAU >5000 >5000 2.4 None No None only for technical imazipic acid CADRE >5000 >5000 2.4 None No None (rat) Triclopyr Triclopyr acid 713 >2000 NA None Positive Mild 5.3 (22mo) 3 NA GARLON 3A 2574 >5000 >2.6 NA NA Severe Chronic toxicity data available (unspec.) only for technical triclopyr acid GARLON 4 1581 >2000 >5.2 Moderate Positive Slight (unspec.) Clopyralid Clopyralid acid >5000 >2000 >1.3 V. Slight No Severe 500 (18mo) 50 100 (unspec.) (mouse) (rat) (dog) STINGER >5000 NA NA NA NA NA Chronic toxicity data available only for technical clopyralid acid Dicamba Dicamba acid 1707 >2000 9.6 Slight Possible Extreme 115 (18mo) 125 60 BANVEL 2629 >2000 >5.4 Moderate No Extreme Chronic toxicity data available BANVEL 720 2500 NA NA NA NA NA only for technical dicamba acid BANVEL SGF 6764 >20000 >20.23 Slight N/A Minimal WEEDMASTER >5000 >20000 >20.3 Minimal N/A Minimal Dicamba+2,4-D Source: Herbicide Handbook (WSSA 2006), Greenbook (2006); NA = Not Available

Table E-2. Toxicity data for other types of wildlife for herbicides proposed for non-native invasive plant (NNIP) control on the HNF as part of the proposed action (Alternative 2) Herbicide Avian Receptors Terrestrial Aquatic Receptors Formulation Invertebrates (Technical product Bobwhite Quail Mallard Duck Earth- Honeybee Daphnia Bluegill Rainbow Trout unless specific worm formulation noted) Oral LD50 8-day Oral LD50 8-day LC50 Topical LD50 48-hour 96-hour 96-hour dietary LC50 dietary LC50 LC50 LC50 LC50 mg/kg ppm mg/kg BW ppm ppm ug/bee Mg/L (in water) BW (in food) (in food) (in soil) Glyphosate Glyphosate acid >4640 >4640 4640 >100 780 120 86 Glyphosate >5000 950 >5000 >62.1 71 3500 1800 trimethylsulfo-nium salt ROUNDUP >5000 >100 5.3 5.8 8.2 RODEO 930 >1000 >1000 Imazapic Imazapic Acid >2150 >5000 >2150 >5000 100 32 Triclopyr Triclopyr acid 2934 1698 >5620 >100 133 148 117 Triclopyr butoxyethyl 5401 >5401 >100 1.7 0.36 0.65 ester Triclopyr triethylamine >10000 3176 >10000 >100 775 891 613 salt Clopyralid Clopyralid acid >4640 1465 >4640 1000 >0.1 232 125 104 Dicamba Dicamba acid 216 >10000 1373 >10000 110 135 135 (TL50) (TL50) (TL50) BANVEL >4640 >2510 >4640 1600 >1000 1000 BANVEL SGF >10000 >4640 >10000 38.1 706 558 WEEDMASTER >4640 >4640 >4640 >1800 >1000 >1000 Dicamba+2,4-D LD50 = Lethal Dose 50; LC50 = Lethal Concentration 50; TL50 = Threshold Level 50. Data is from 2006 PNW Weed Management - Weed Science Society of America (WSSA 2006) and associated product Material Safety Data Sheets (MSDS); Tu et al. (2001); Tu et al. (2004); Tu et al. (2004); Cornell (1993).

Table E-3. Risk assessment information for herbicides proposed for non-native invasive plant (NNIP) control on the HNF as part of the proposed action (Alternative 2)

Risk Terrestrial Mammals Birds Insects Fish & Other Aquatic Assessment Receptors Application Rate Glyphosate (Source: SERA 2003a; Tu et al. 2001) 2 lb a.e./acre Effects resulting from Effects resulting from Effects resulting from Effects resulting from (average rate) average application rate are average application rate are average application rate are average application rate are minimal. Some risk exists for minimal. Some risk exists for minimal. Some risk from minimal. Some risks exists to 7 lb a.e./acre large mammals consuming small birds consuming maximum application rate to fish near areas treated with (maximum foliage for an extended insects for an extended bees exposed to direct spray. maximum application rate rate) period of time in areas period of time from areas using some of the more toxic treated with maximum treated with maximum formulations not labeled for application rate. application rate. use in aquatic settings. Imazipic (Source: SERA 2004c, Tu et al. 2004) 0.100 lb a.e. No substantial risk to small No substantial risk at No substantial risk at No substantial risk at /acre mammals at maximum rates. maximum rates. maximum rates. Non-toxic to maximum rates. However, (average rate) Some risk exists for large bees limited toxicological data mammals, if consumed over available. Potential for risk to 0.1875 lb/acre long period (i.e. 2 years). aquatic plants from maximum (maximum rates is borderline. rate) Triclopyr (Source: SERA 2003b, Tu et al. 2003) 1 lb a.e./acre No substantial risk at No substantial risk at No substantial risk to No substantial risk when (average rate) average rate. Some risk for average rate. Some risk for terrestrial vertebrates and triethylamine (TEA) salt mammals exposed via direct large bird exposed via direct invertebrates from salt and formulations are applied at 10 lb a.e./acre spray or consuming sprayed spray or consuming sprayed ester formulations. Risk to average rate. Some risk to (maximum vegetation when applied at vegetation when applied at aquatic invertebrates when if aquatic species when rate) maximum rate. maximum rate. exposed to the butoxyethyl butoxyethyl ester (BEE) ester (BEE) formulation. formulations are applied at average rate. Substantial risk when BEE formulations applied at maximum rate.

Risk Terrestrial Mammals Birds Insects Fish & Other Aquatic Assessment Receptors Application Rate Clopyralid (Source: SERA 2004b, Tu et al. 2001) 0.1 lb a.e./acre Reported to be relatively non- Reported to be relatively non- Reported to be relatively non- Reported to be relatively non- (typical rate) toxic, with little potential for toxic, with little potential for toxic to bees, with little toxic, with little potential for adverse effects. adverse effects. potential for adverse effects. adverse effects. 1.0 lb a.e./acre Low toxicity to soil (maximum invertebrates and microbes. rate) Dicamba (as Vanquish, the diglycolamine salt of dicamba) (Source: SERA 2004a, Cornell 1993) 2 lb a.i./acre No plausible and substantial No plausible and substantial Reported to be non-toxic to No plausible and substantial (foliar hazard under normal hazard under normal bees. hazard under normal application) conditions of Forest Service conditions of Forest Service conditions of Forest Service use. use. use. 1.5 lb a.i./acre (cut surface application)

(VANQUISH)

Some forms of the herbicides specified are more toxic to fish and other aquatic life than others (Table E-2). One herbicide, glyphosate, is essentially non-toxic to fish as a trimethylsulfonium salt. However, certain product formulations utilizing glyphosate, such as Roundup®, is modified with tallow amine, a surfactant, that results in greater toxicity. For this reason, the Roundup formulation is not labeled for use in aquatic areas. Instead, the Rodeo formulation would be used when the treatment benefits of glyphosate are needed in aquatic or wetland settings. The aquatic receptor LC50 values for Rodeo are substantially safer than Roundup, and the Rodeo formulation is labeled for use in aquatic areas

There is contradictory information in the available literature regarding toxicity to aquatic organisms from adjuvants (i.e. additives such as surfactants and dyes) included in glyphosate formulations (Relyea 2005, Thompson et al. 2006, Wojtaszek et al. 2004, Howe et al. 2004, Langeland 2006). Based on our review of this information we have determined the listed herbicides can be used safely on the HNF by incorporating buffers around wetland areas (design criteria No. 11, p. 13). Design criteria address this risk by specifying varying widths of buffer strips (i.e. untreated land or vegetation), inside which only formulations of herbicides approved for aquatic use (example: Rodeo®) could be employed. The specified buffers are based on guidance included in the Michigan Water Quality Best Management Practices (MDNR 1994) for non-point source pollution. Literature indicates that buffers are effective in reducing herbicides movement from treated sites by decreasing runoff and drift (USDA 2000, p. 6-9).

Sensitivity of Animals to Herbicides - Even for herbicide formulations regarded as toxicologically and environmentally safe, proper application in strict accordance with the manufacturer label is critical to ensure safety to the applicator and the environment. Not only is it important to ensure that labeled application rates are not exceeded, but application must take place using properly maintained equipment and under proper weather conditions. Use of improperly maintained equipment can result in leaks and localized high concentrations of chemicals, and application in the wind can result in spray drifts that contact non-target areas (USEPA 1999, pp. 2-3). When herbicides are applied prior to heavy rainfall, they can be carried in runoff to non-target areas. As a protection measure we have specified upland buffers around wet areas were only those products labeled for aquatic use could be used. The minimum buffer width is 100 feet (p. 13). Herbicides would only be applied on the HNF by persons possessing a pesticide applicator’s license or (for unrestricted over-the-counter herbicides) under the supervision of a licensed applicator. Herbicide application would follow the directions provided by the product labels. For that reason, the Typical Application Rate results displayed in Table E-3 provide the more accurate estimation of toxicity to animals should they be in contact with the herbicide. Highest rates of application (based on label direction) are unlikely to be used, particularly because the application methods would focus on the target plants, not merely the target area. Spot application, rather than broadcast applications would be the normal course of operation when herbicide treatment is determined to be preferable over manual and biological methods. Acute exposure to birds and mammals would be unlikely to occur because the application methods would be on a small scale (hand pumps, wand or wick application). No aerial application (plane, helicopter, aerial boom) would be used. Also, since the applications will occur at such a small scale, drift will be minimized thus reducing herbicide exposure to non-target vegetation and animals (refer to design criteria and protocols, pp. 10-14).

 Chronic exposure is unlikely for several reasons: o Herbicide applications are expected to be at most, annual. o In the case of an animal eating vegetation, treated vegetation would be dead and would not represent a long-term food source.

o In the case of animals eating contaminated animals (insects or small mammals), contaminated prey items represent an ephemeral resource due to the infrequency of herbicide application. o While some sites would require follow-up treatments, the treatment method may not be herbicide application each year.

For these reasons, the likelihood of repeated exposure to herbicides for any individual animal would be further reduced.

The plant portion of this BE uses 45 feet as the area of influence, the maximum distance over which drift of herbicides might occur, and any sensitive plant species found beyond that distance can be considered unaffected by treatment. Evaluations for RFSS animal species consider the effects of treatments to the habitats of the animals because for most species their mobility enables them to avoid the NNIP treatment site while activities occur. For this reason, acute exposure to herbicides is unlikely for most of the RFSS animal species. Further, due to the limited extent of the proposed treatment (most of the NNIP documented thus far are one acre or less) (Table 2), even if the treatment occurs in the species’ habitat, the amount of habitat affected is relatively minute when compared to the total habitat available to the animal.

Finally, none of the proposed herbicides is related to carbamate and organophosphate insecticides, which inhibit cholinesterase enzymes and have been known to cause bird mortality. None of our herbicides contain chemicals such as DDT, a class of chemical that are implicated in causing raptor egg-shell thinning.

Bald eagle (Haliaetus leucocephalus) Status of the species: Federally Threatened Bald eagles are present on the Forest as breeders and occasionally as winter residents. National Forest biologists on the HNF and Michigan DNR biologists monitor nesting activity. The numbers of eagles nesting on the Forest has been increasing to stable since the 1970’s. The USFWS has a signed recovery plan for the species, the Northern States Bald Eagle Recovery Plan (NSBERP) (USDI 1983). The USFWS Biological Opinion for the 2006 Forest Plan includes detailed information regarding species status and natural history information for the bald eagle (USFWS 2006, pp. 225-229). The Biological Assessment for the 2006 Forest Plan includes comparable information (USDA 2005, pp. 8-10). As of March 2007, there had been no change in the status of this species. There is a possibility that the bald eagle will be removed from the threatened species list in 2007. Should this occur the species would be listed as a RFSS for the Forests on which they occur for not less than 5 years (USDA 2001, FSM 2670, p. 3). Conservation measures associated with current species protection would be extended over the time the species is on the RFSS list, and are expected to remain the same as those developed in the Forest Plan or Recovery Plan. The bald eagle would still be protected by the "Bald Eagle and Golden Eagle Protection Act" and "Migratory Bird Treaty Act" (S. Mighton, personal communication, 2007).

Habitat and biology: Bald eagles typically inhabit areas near lakes and large rivers which contain their primary prey (fish and waterfowl). Eagles feed primarily on live fish, and to a lesser extent on waterfowl and carrion (e.g. deer carcasses in the Upper Peninsula). Bald eagles build nests in the top of a large, tall tree, usually within a short distance of a large river or lake that is used for foraging by the adults. Waterbodies containing abundant fish are common across the HNF, and many of these waters have suitable nest trees surrounding them. Detailed life history can be found in documents associated with the 2006 Forest Plan (USFWS 2006, pp. 225-229; USDA 2005, pp. 8-10).

Threats by NNIP: The level of NNIP infestation anticipated in the foreseeable future is not expected to constitute a threat to the species.

Factors related to the conservation of the species: The BA for the 2006 Forest Plan lists the following factors and indicators as important for the conservation of bald eagles on the HNF (USDA 2005, pp. 11-15): 1. Terrrestrial habitat – Indicator is acres of nesting habitat 2. Aquatic habitat – There are no indicators for this factors 3. Environmental contaminants - There are no indicators for this factor 4. Human disturbance – The indicators are (a) miles of designated OHV trails, (b) miles of designated snowmobile trails, and (c) percentage of inland lakes managed for motorized access

Forest Plan Direction specific to bald eagle (USDA 2006a, Chapter 2)

biological (insects) protocol and design criteria (pp. 10-14) S-2600: Protect known Yes Alt. 1 – NNIP control: current Alt. 1 – no change from TE populations program current NNIP control Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) S-2300: Cross country N/A Alt. 1 – NNIP control: current Both Alts. – proposed OHV travel is prohibited program activities not associated except in the Alt. 2 – NNIP control: integrated with OHVs designated OHV area program S-2300: Roads will be N/A Alt. 1 – NNIP control: current Both Alts. – proposed closed to OHVs unless program activities not associated designated/posted Alt. 2 – NNIP control: integrated with roads and OHVs open program GL-2500: No Aspen N/A Alt. 1 – NNIP control: current Both Alts. – proposed regeneration within 500 program activities not associated feet of indicated cool- Alt. 2 – NNIP control: integrated with aspen regeneration and coldwater systems program GL-2600: Survey prior Yes Alt. 1 – NNIP control: current Alt. 1 – no change from to implementing program current NNIP control management Alt. 2 – NNIP control: integrated using Forest Plan program Alt. 2 – NNIP Control protocol and design criteria (pp. 10-14) GL-2600: Closure N/A Alt. 1 – NNIP control: current Both Alts. – proposed orders may be used to program activities not associated protect known TE Alt. 2 – NNIP control: integrated with closure orders – breeding areas, nests program species protections in and denning sites place GL-2600: Give Yes Alt. 1 – NNIP control: current Alt. 1 – no change from deference to listed program current NNIP control species where there Alt. 2 – NNIP control: integrated using Forest Plan are conflicts with program Alt. 2 – NNIP Control unlisted species protocol and design criteria (pp. 10-14) 1GL-guideline; S-standard; N/A – not applicable to the NNIP Control EA

Analysis of Effects - Bald eagle - Alternative 1 (No Change)

Direct and Indirect Effects Implementing Alternative 1 would have no effect on bald eagle over the period covered by this EA. Some NNIP sites identified would be allowed to persist or increase in size. However, we know of no bald eagle nesting or foraging areas currently being adversely affected, or in future danger, by NNIP infestations. The Forest would likely continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical means only, using individual project decisions not associated with this EA. This, however, would have no effect on the bald eagle over the 5-year period of the NNIP project EA.

Cumulative Effects Because there are no direct or indirect effects on bald eagle associated with Alternative 1, there would be no cumulative effects to combine with the effects of past, present, or reasonably foreseeable future activities in the project area.

Analysis of Effects - Bald eagle - Alternative 2 (Proposed Action)

Mechanical or manual method of treatment – Mechanical or manual method of treatment – At the approximate maximum of 200 acres, annually, actions to reduce NNIP would result in minimal effects relative to the factors identified as related to the conservation of bald eagles. Noise from manual and mechanical treatments, such as use of the weed torch, brush cutter and saw in the immediate vicinity of nesting sites could disturb bald eagles. Disturbances would be brief, occur generally once and be localized in impacts. While the risk is considered very low due to the small acreage of treatment anticipated, NNIP treatment would not be conducted within 1320 feet of a known bald eagle nesting sites during the breeding season (design criteria No. 6, p. 12). This distance includes all of the protection zones (primary nest zone, secondary zone and tertiary zone) described in the NSBERP (USDA 1983) and would be implemented for bald eagle as a Federal threatened species or Regional Forester Sensitive Species (RFSS) should it be removed from the ESA list. Observance of the nest protection zones would avoid any potential disturbance that could cause nest abandonment or other changes in activity patterns that may affect reproduction.

Human disturbance in eagle foraging habitat would be minimal because most applications would not require the use of motorized equipment. There may be some increase in noise and movement in proximity to eagle habitat, but these impacts would be of short duration, temporary, localized and distant, due to protections in place for species conservations. These protections would be implemented for the entire five-year duration of the project, regardless of species status: Federal threatened or RFSS. In either case, no measurable response would be expected to occur. Eagles nest in large trees, such as red and white, supercanopy trees. No such trees would be felled or subject to physical damage in this alternative. Invasive understory, such as buckthorns and honeysuckle would be cut, grubbed, burned using the weed torch, and/or sprayed manually in forested areas without disturbance to overstory trees.

Chemical Treatment – The data summarized in Table E-1 and Table E-2 indicate that the herbicides proposed for use in eagle habitats are not highly toxic to mammals and birds or to the fish species that form the chief prey of many raptor species. Bald eagles do not spend much time on or near the ground. Thus, are very unlikely to experience direct contact with chemical sprays

Ecological risk assessments conducted for several of the proposed herbicides; including glyphosate, imazapic, triclopyr, clopyralid, and dicamba; suggest that use of the studied herbicides at rates commonly used by the Forest Service pose little or no risk to birds (Table E-2). Some forms of the herbicides specified are more toxic to fish and other aquatic life than others (Table E- 2). However, based on a review of this information, we have determined the listed herbicides could be used safely on the HNF by incorporating buffers around wetland areas (project design criteria No. 11, p. 13) (see p. 41, above, for more information on glyphosate and spray adjuvants). Design criteria address this risk by specifying varying widths of buffer strips (i.e. untreated land or vegetation), inside which only formulations of herbicides approved for aquatic use (example: Rodeo®) could be employed. The specified buffers are based on guidance included in the Michigan Water Quality Best Management Practices (MDNR 1994) for non-point source pollution. Literature indicates that buffers are effective in reducing herbicides movement from treated sites by decreasing runoff and drift and facilitating (USDA 2000, p. 6-9).

None of the proposed herbicides are related to carbamate and organophosphate insecticides, which inhibit cholinesterase enzymes and have been known to cause bird mortality. None of our herbicides contain chemicals such as DDT, a class of chemical that are implicated in causing raptor egg-shell thinning. Considering protections, and the small acreage anticipated in proximity to wetlands, no adverse impact to bald eagle prey are expected from use of listed chemicals.

Biological Control – Releases of biological control agents would be performed manually from the road, away from any eagle habitat. None of the proposed biological control agents target canopy tree species used as nests or roosts bald eagles. Insects used as biological control agents (Table I-7) are neither competitors nor prey of bald eagles and their abundance or absence would have no effect on bald eagles. Bald eagles do not utilize any of the NNIP or the plant species that they displace. Therefore, use of biological controls would pose no detrimental impacts to bald eagles.

All NNIP Control Methods - We determined there are no additional effects relative to the factors and indicators important for the conservation of bald eagles on the Forest (see Factors related to the conservation of the species, above).

Summary – Direct and Indirect Effects – Alternative 2 Considering the design criteria and small magnitude of anticipated impacts, any response to bald eagles from exposure to project activities would be minimal. This conclusion is consistent with the 2006 Forest Plan Biological Opinion (USFWS 2006, p. 232 and Appendix K). It is anticipated the protocol and design criteria specified for this EA and protections in the Forest Plan would be implemented for the entire five-year duration of the project regardless of species status: Federal threatened or RFSS. In either case, effects to bald eagle would be minimal. Non-native invasive plants are not known to be adversely affecting bald eagle habitat on the HNF. We do not expect the condition to change over the period covered by this EA. However, over a longer period of NNIP control, the expected result of NNIP control is a more diverse vegetative community on the Forest, a condition that theoretically could provide improved food and cover for bald eagle prey species, and result in higher productivity. This is consistent with the information provided by the USFWS for the 2006 Forest Plan (USFWS 2006, p. 232 and Appendix K).

Cumulative Effects Because the risk of effects is so small as to be insignificant, implementing Alternative 2 would not add to any effects of past, present, or reasonably foreseeable future activities in the project area. The removal of NNIP from near and within suitable bald eagle habitat may increase productivity over the long-term.

Determination Alternative 1 – No effect Alternative 2 – May affect, not likely to adversely affect

Canada lynx (Lynx canadensis) Status of the species: Federally Threatened A Canada lynx was confirmed on the HNF in Mackinac County in November 2003. This was the first verified sighting in Michigan in approximately 20 years. Hiawatha National Forest biologists monitor for lynx activity through winter track surveys. The USFWS has no recovery plan for the species. The USFWS Biological Opinion for the 2006 Forest Plan includes detailed information regarding species status and natural history information for the Canada lynx (USFWS 2006, pp. 159-169). The Biological Assessment for the 2006 Forest Plan includes comparable information (USDA 2005). As of March 2007, there had been no change in the status of this species.

Habitat and biology: Snowshoe hare are the primary prey of lynx, especially in the winter. Canada lynx populations are closely aligned with those of snowshoe hare, which primarily occupy areas receiving and maintaining deep snow and habitats replete with conifers and a dense shrub layer. Canada lynx are physiologically adapted to hunting snowshoe hare in deep snow having a loose or powdery consistency. Detailed life history can be found in documents associated with the 2006 Forest Plan (USFWS 2006, pp. 160-163).

Threats by NNIP: The impact of NNIP on plant species diversity may be a concern in certain parts of the range for lynx (USDA 2005, p. 92). However, the level of NNIP infestation anticipated in the foreseeable future is not expected to constitute a threat to the species on the HNF.

Factors related to the conservation of the species: The BA for the 2006 Forest Plan lists the following factors and indicators as important for the conservation of bald eagles on the Forest (USDA 2005, p. 75): 1. Lynx habitat – The indicators are (a) acres of snowshoe hare habitat (b) acres of red squirrel habitat, (c) acres of denning habitat, (d) acres of connectivity, and (e) acres of quality connectivity 2. Human disturbance – The indicators are (a) miles of designated snowmobile trails, (b) miles of ML2-5 roads open to snowmobile use, and (c) cross-county snowmobile use 3. Competition from other carnivores - The indicators are the same as 2.

Forest Plan Direction specific to Canada lynx (USDA 2006a, Chapter 2)

Alternatives Forest Plan Guideline in or Standard1 Compliance Management Activity Notes/Specifics S-2600: Protect known Yes Alt. 1 – NNIP control: current Alt. 1 – no change from TE populations program current NNIP control Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) S-2300: Cross country N/A Alt. 1 – NNIP control: current Both Alts. – proposed OHV travel is prohibited program activities not associated except in the Alt. 2 – NNIP control: integrated with OHVs designated OHV area program S-2300: Roads will be N/A Alt. 1 – NNIP control: current Both Alts. – proposed closed to OHVs unless program activities not associated designated/posted Alt. 2 – NNIP control: integrated with roads and OHVs open program

GL-2600: Structural N/A Alt. 1 – NNIP control: current Both Alts. – proposed guidelines implemented program activities not associated for reserve trees/snags Alt. 2 – NNIP control: integrated with reserve trees/snags program GL-2600: Survey prior Yes Alt. 1 – NNIP control: current Alt. 1 – no change from to implementing program current NNIP control management Alt. 2 – NNIP control: integrated using Forest Plan program Alt. 2 – NNIP Control protocol and design criteria (pp. 10-14) – survey as appropriate for site being treated GL-2600: Maintain Yes Alt. 1 – NNIP control: current Alt. 1 – no change from habitat connectivity to program current NNIP control allow for lynx dispersal Alt. 2 – NNIP control: integrated using Forest Plan – over program long term connectivity maintained Alt. 2 – NNIP Control protocol and design criteria (pp. 10-14) – over the long term NNIP control may maintain/enhance connnectivity GL-2600: After natural N/A Alt. 1 – NNIP control: current Both Alts. – proposed disturbance >20 acres program activities not associated retain minimum of 10% Alt. 2 – NNIP control: integrated with natural disturbances of the area on NFS program – sites not likely to be >20 acres GL-2600: If adding N/A Alt. 1 – NNIP control: current Both Alts. – proposals not designated trails for program associated with winter winter activities in lynx Alt. 2 – NNIP control: integrated activities habitat minimize program impacts GL-2600: In lynx habitat N/A Alt. 1 – NNIP control: current Both Alts. – proposals not reduce compacted program associated with route density if >2 miles Alt. 2 – NNIP control: integrated compacted route density per square mile (at the program and winter activities LTA scale) w/closures, decommissioning GL-2600: Maintain N/A Alt. 1 – NNIP control: current Both Alts. – proposals denning habitat in program would not affect denning patches > 5 ac. Alt. 2 – NNIP control: integrated habitat over the planned comprising at least 10 program EA duration percent of lynx habitat on project area GL-2600: Closure N/A Alt. 1 – NNIP control: current Both Alts. – proposed orders may be used to program activities not associated protect known TE Alt. 2 – NNIP control: integrated with closure orders – breeding areas, nests program species protections in and denning sites place GL-2200: Grazing N/A Alt. 1 – NNIP control: current Both Alts. – proposed should not occur program activities not associated Alt. 2 – NNIP control: integrated with grazing program

GL-2600: Give Yes Alt. 1 – NNIP control: current Alt. 1 – no change from deference to listed program current NNIP control species where there Alt. 2 – NNIP control: integrated using Forest Plan are conflicts with program Alt. 2 – NNIP Control unlisted species protocol and design criteria (pp. 10-14) 1GL-guideline; S-standard; N/A – not applicable to the NNIP Control EA

Analysis of Effects - Canada lynx - Alternative 1 (No Change)

Direct and Indirect Effects Implementing Alternative 1 would have no effect on Canada lynx over the period covered by this EA. Some NNIP sites identified would be allowed to persist or increase in size. However, we know of no infestations of NNIP that are currently, or have potential to, adversely affect Canada lynx on the Forest. The HNF would likely continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical means only, using individual project decisions not associated with this EA. It is possible that failure to control the spread of NNIP species into potentially suitable habitat could eventually result in a prevalence of degraded habitats. These habitats are less favorable to the Canada lynx and more favorable to competing predators, such as coyotes and bobcats, species known to be habitat generalists. However, this change would occur over a period of time greater than the 5-year span covered by this EA.

Cumulative Effects Because there are no direct or indirect effects on Canada lynx associated with Alternative 1, there would be no cumulative effects when combined with the effects of past, present, or reasonably foreseeable future activities in the project area.

Analysis of effects - Canada lynx - Alternative 2 (Proposed Action)

Mechanical or manual method of treatment – Manual and mechanical methods to reduce NNIP at the acreage specified would have minimal impacts relative to the factors identified as related to the conservation of lynx. Human disturbance would be minimal because most applications would not require the use of motorized equipment. There may be some increase in noise and movement in proximity to lynx habitat, but these impacts would be of short duration, temporary, localized and very small relative to the amount of available habitat. Canada lynx do not utilize any of the NNIP species or the plant species that they displace, and the magnitude of change in vegetation would have minimal impact on lynx. For example, 200 acres of treatment would represent 0.04 percent of the available snowshoe hare habitat on the Forest (USDA 2005, p. 94). This level of treatment would not affect a top carnivore, such as Canada lynx. Due to the rarity of lynx, we anticipate that the likelihood of NNIP control occurring in proximity to a den site is very low. However, the implementation of Forest Plan direction and recovery plan guidelines for the species would protect all known den sites

Chemical Treatment – Due to the rarity of Canada lynx on the HNF, there is little potential for direct or indirect adverse effects, whether toxicological or due to alteration of habitat. Any physical disturbances to habitat would be temporary and so minimal as to be non-detectable. Any lynx on

the Forest would likely avoid human presence and would not be found in the immediate vicinity of ongoing physical or chemical treatments, and would therefore not be subject to injury or direct chemical exposure. The low toxicity of the herbicides (Tables E-1 and E-3) suggests that adverse effects on mammalian prey sources are unlikely; and even if the herbicides were toxic to prey, the small areas subject to treatment each year would ensure that only minimal and non-detectable effects on prey quantities would occur. Herbicides would be carefully applied to target vegetation in a manner consistent with the label, thereby avoiding drift or runoff that might otherwise contaminate drinking water sources for the lynx (design criteria No. 11, p. 13).

Biological Control – Insects used as biological control agents (Table I-7) for leafy spurge, purple loosestrife, spotted knapweed and Eurasian water milfoil are neither competitors nor prey of Canada lynx. Thus, their abundance or absence would have no effect on lynx. Releases of biological control agents would be performed manually from the road, minimizing disturbance in more secluded lynx habitat. Therefore, use of biological controls would pose no detrimental impacts to this species. Any lynx response from exposure to control activities would be minimal and non-detectable. This is consistent with the assessment for the species in the Biological Opinion (USFWS 2006, p. 176, Appendix H).

All NNIP Control Methods - None of the proposed treatment methods would result in further fragmentation or elimination of Canada lynx habitat. We determined there are no additional effects relative to the factors and indicators important for the conservation of Canada lynx on the Forest (see Factors related to the conservation of the species, above).

Non-native invasive plants are not known to be adversely affecting lynx habitat on the HNF. We do not expect the condition to change over the period covered by this EA. However, over a longer period of NNIP control, the result would be a more diverse vegetative community on the Forest, a condition that theoretically could provide improved food and cover for Canada lynx, and increase survival rates for the species. This is consistent with the information provided by the USFWS for the 2006 Forest Plan (USFWS 2006, p. 176 and Appendix H). Supporting information is provided in the Federal Interagency Canada Lynx Conservation Assessment and Strategy (Ruediger et al. 2000). The author suggests that while there is no documentation of the magnitude of effects from NNIP infestations specifically on Canada lynx habitat in the United States, the potential exists for NNIP to cause large-scale alteration of specialized habitat. Therefore, controlling NNIP infestations could indirectly benefit habitat for lynx, and hence the Canada lynx itself, should it become established on the HNF in the future.

Summary – Direct and Indirect Effects – Alternative 2 Considering the design criteria and small magnitude of anticipated impacts, any impacts to Canada lynx from exposure to project activities would be minimal and insignificant. This conclusion is consistent with the 2006 Forest Plan Biological Opinion (USFWS 2006, p. 176 and Appendix H).

Cumulative Effects Because the risk of effects is so small as to be insignificant, implementing Alternative 2 would not add to any effects of past, present, or reasonably foreseeable future activities in the project area. The removal of NNIP from near and within suitable Canada lynx habitat may increase productivity over the long-term.

Determination Alternative 1 – No effect Alternative 2 – May affect, not likely to adversely affect

Gray wolf (Canis lupus) Status of the species: Federally Endangered The listing history for gray wolf has been convoluted as of late. Due to lawsuits files in Oregon and Vermont and subsequent court rulings, Michigan gray wolves were returned to the endangered status. This has occurred in spite of the documented increase in the number of wolves in Michigan’s Upper Peninsula (USFWS 2006, p. 140). The species is present on the HNF. National Forests biologists and Michigan DNR biologists monitor for wolf activity through winter track surveys and other techniques. The USFWS has a signed recovery plan for the species. The USFWS Biological Opinion for the 2006 Forest Plan includes detailed information regarding species status and natural history information for the gray wolf (USFWS 2006, p. 138-142). The Biological Assessment for the 2006 Forest Plan includes comparable information (USDA 2005). As of March 2007, there had been no change in the status of this species. There is a possibility the gray wolf (Western Great Lakes Distinct Population Segment (DPS)) will be removed from the threatened species list in 2007. Should this occur, the species would be listed as a RFSS for the Forests on which they occur for not less than 5 years (USDA 2001, FSM 2670, 3). Conservation measures associated with current species protection would be extended over the time the species is on the RFSS list, and are expected to remain the same as those developed in the Forest Plan or Recovery Plan (S. Mighton, personal communication, 2007).

Habitat and biology: Wolves are pack animals and tend to be habitat generalists with ties to preferred prey (white-tailed deer and beaver), rather than vegetation type and age. Detailed life history can be found in documents associated with the 2006 Forest Plan (USFWS 2006, p. 140-41).

Threats by NNIP: The current level of NNIP infestation and anticipated level in the foreseeable future does not constitute a threat to the gray wolf on the HNF.

Factors related to the conservation of the species: The BA for the 2006 Forest Plan lists the following factors and indicators as important for the conservation of gray wolf on the Forest (USDA 2005, p. 36-40): 1. Human access and disturbance – The indicators are (a) miles of designated snowmobile trails, (b) miles of ML2-5 roads open to snowmobile use, (c) cross-county snowmobile use, (d) cross-county OHV use, (e) miles of designated OHV trails, and (f) miles of ML2-5 roads open to OHV use 2. Habitat management for prey species – The indicators are (a) acres and percent of early- age aspen/birch, and (b) acres and percent of eastern white cedar

Forest Plan Direction specific to gray wolf (USDA 2006a, Chapter 2)

Alternatives Forest Plan Guideline in or Standard1 Compliance Management Activity Notes/Specifics S-2600: Implement Yes Alt. 1 – NNIP control: current Alt. 1 – no change from federal recovery plan program current NNIP control Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) S-2600: Protect known Yes Alt. 1 – NNIP control: current Alt. 1 – no change from TE populations program current NNIP control Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) S-2300: Cross country N/A Alt. 1 – NNIP control: current Both Alts. – proposed OHV travel is prohibited program activities not associated except in the Alt. 2 – NNIP control: integrated with OHVs designated OHV area program S-2300: Roads will be N/A Alt. 1 – NNIP control: current Both Alts. – proposed closed to OHVs unless program activities not associated designated/posted Alt. 2 – NNIP control: integrated with roads and OHVs open program GL-2600: Survey prior Yes Alt. 1 – NNIP control: current Alt. 1 – no change from to implementing program current NNIP control management Alt. 2 – NNIP control: integrated using Forest Plan program Alt. 2 – NNIP Control protocol and design criteria (pp. 10-14) – survey as appropriate for site being treated GL-2600: Closure N/A Alt. 1 – NNIP control: current Both Alts. – proposed orders may be used to program activities not associated protect known TE Alt. 2 – NNIP control: integrated with closure orders – breeding areas, nests program species protections in and denning sites place GL-2600: Give Yes Alt. 1 – NNIP control: current Alt. 1 – no change from deference to listed program current using Forest Plan species where there Alt. 2 – NNIP control: integrated Alt. 2 – NNIP Control are conflicts with program protocol and design unlisted species criteria (pp. 10-14) 1GL-guideline; S-standard; N/A – not applicable to the NNIP Control EA

Analysis of Effects - Gray wolf - Alternative 1 (No Change)

Direct and Indirect Effects Implementing Alternative 1 would have no effect on gray wolf over the period covered by this EA. Some NNIP sites identified would be allowed to persist or increase in size. While NNIP infestations do exist in wolf habitat, the Forest is in the early stage of NNIP spread. Consequently, we know of no NNIP infestations (current or anticipated in the future period covered by this EA) adversely affecting gray wolf on the HNF. The Forest would likely continue to remove approximately 30-50

acres of invasive weeds through manual and mechanical methods, using individual project decisions not associated with this EA. It is possible that failure to control the spread of NNIP species into potentially suitable habitat could eventually result in a prevalence of degraded habitats less favorable to wolves and their prey. However, this would occur over a period greater than the 5- year span covered by this EA.

Cumulative Effects Because there are no direct or indirect effects on gray wolf associated with Alternative 1, there would be no cumulative effects when combined with the effects of past, present, or reasonably foreseeable future activities in the project area.

Analysis of Effects - Gray wolf - Alternative 2 (Proposed Action)

Direct and Indirect Effects Under Alternative 2, we would use a combination of mechanical, chemical and biological control methods to reduce or eradicate NNIP on an average of approximately 40-70 acres a year with a potential for up to 200 acres a year if funding allowed.

Mechanical or manual method of treatment – Physical or chemical treatments would require brief periods of human access to infested areas. However, since most sites identified thus far are associated with recreation site and disturbed areas, it is unlikely treatments would occur in the remote habitats frequented by wolves. Treatment periods could range from a few hours to treat very small infestation sites to a few days for the largest sites. Personnel might have to return to previously treated areas for brief times for monitoring and follow-up NNIP treatments, but the program would not permanently increase the human presence in any areas of the HNF. Some physical treatments using motorized equipment such as string trimmers or chain saws or chemical treatments using mechanized spray equipment would generate brief periods of engine noise that could frighten wolves and cause them to temporarily alter behavior patterns and vacate areas. However, wolves are generally tolerant of human activity as long as they are not deliberately persecuted (USDI FWS 2004a). In Minnesota, wolves are reported to live in areas with higher road and human densities than previously considered to be suitable (USDI FWS 2004b). Because of the presence of human operators, wolves would not remain present in areas where the weed torch is in use. They would therefore not be subject to burns or other injury from the torch. The burned plant tissue would cool almost immediately, before the human operators vacate the area, and thus not be capable of burning or otherwise injuring wolves. We also anticipate that the likelihood of NNIP control occurring in proximity to a den site is very low. However, should this be proposed, the implementation of Forest Plan direction, recovery plan guidelines or RFSS conservation directives for the species, including restriction on timing and distances, any risks of direct or indirect effects would be reduced to a minimum level (USDA 2005, p. 47-48).

Chemical Treatment – The mammalian toxicological data presented in Table E-1 suggests that the toxicity of the proposed herbicides to wolves (and other mammals) would be low. Wolves are carnivorous and thus do not normally graze foliage, thus the oral LD50 data are not generally relevant. Wolves could experience dermal toxicity by brushing against recently treated NNIP foliage. However, as evidenced by the dermal LD50 data in Table E-1, the dermal exposure pathway is generally less hazardous than the oral exposure pathway. Furthermore, wolves would be expected to avoid treatment areas until the crews depart for the day, giving the sprayed foliage a chance to dry and thus be less likely to rub off on wolves. Because herbicides would be applied directly to target foliage in a manner that prevents drift or runoff, the herbicides would not be capable of contaminating drinking waters sources for wolves. Ecological risk assessments conducted for several of the proposed herbicides; including glyphosate, imazapic, triclopyr,

clopyralid, and dicamba; suggest that use of the studied herbicides at rates commonly used by the Forest Service pose little or no risk to terrestrial mammals (Tables E-1 and E-3).

Biological Control – There is no available evidence that the insects proposed for use as biological control agents are harmful to wolves or other mammals. None are biting or stinging insects. All have a record of safe use in the Midwestern United States. Releasing biological control agents does not require the use of motorized equipment other than a vehicle for basic transportation. In most cases release would likely take place close to existing roads decreasing risk of a minor physical disturbance in remote habitat. The agent would be expected to spread on its own to remote areas. Insects used as biological control agents (Table I-7) for leafy spurge, purple loosestrife, spotted knapweed and Eurasian water milfoil are neither competitors nor prey of gray wolf and thus their abundance or absence would have no effect on wolf.

All NNIP Control Methods - Gray wolves do not utilize any of the NNIP weed species or the plant species that they displace. None of the NNIP treatments would fragment habitat corridors for the gray wolf. No permanent human intrusions would result from the NNIP control program. The low level of vegetation change in suitable wolf habitat would have no detectable impact on this species. We determined there are no additional effects relative to the factors and indicators important for the conservation of gray wolf on the Forest (see Factors related to the conservation of the species, above).

Summary – Direct and Indirect Effects – Alternative 2 Non-native invasive plants are not known to be adversely affecting gray wolf on the HNF. We do not expect that condition to change over the period covered by this EA. Any adverse impacts caused by implementing treatments in Alternative 2 in and near gray wolf habitats would be temporary, minimal, and insignificant. However, the long-term beneficial impacts from controlling NNIP infestations through an integrated program across the Forest could be permanent. Although the benefits would be most direct and immediate to lower food chain elements such as plants and herbivores (wildlife that feed on plants), it is ultimately expected that even the highest trophic-level wildlife, such as wolves would indirectly benefit from the improved condition of their habitat and prey populations. Over the long term, this could lead to increases in individual wolf fitness and greater productivity. This is consistent with the information provided by the USFWS for the 2006 Forest Plan (USFWS 2006, p. 150 and Appendix G).

Cumulative Effects Because the risk of effects is minimal, implementing Alternative 2 would not add to any effects of past, present, or reasonably foreseeable future activities in the project area. The removal of NNIP from near and within suitable habitat for gray wolf may increase productivity over the long-term.

Determination Alternative 1 – No effect Alternative 2 – May affect, not likely to adversely affect

Hine’s emerald dragonfly (Somatochlora hineana) and proposed critical habitat Status of the species: Federally Endangered The species is present on the Forest. There are currently 12 known occupied sites in the Upper Peninsula, all within the proclamation boundary of Eastside of the Forest. The USFWS Biological Opinion for the 2006 Forest Plan includes detailed information regarding species status and natural history information for the Hine’s emerald (USFWS 2006, pp. 206-213). The Biological Assessment for the 2006 Forest Plan includes comparable information (USDA 2005). As of March 2007, there had been no change in the status of this species. A proposal to designate critical habitat on the HNF and several other areas has been published (USFWS 2006b). The Hine’s Emerald Dragonfly (HED) Recovery Team provided a draft list of primary constituent elements for the species (USFWS 2006b). As of March 2007, the list had not been finalized. The following features are included in the draft:  Physical and Biological features essential for Hine’s emerald dragonfly egg deposition and larval growth and development consist of the following: . Shallow, organic soils (histosols, or with organic surface horizon) overlying calcareous substrate (predominantly dolomite and limestone bedrock); . Calcareous water from intermittent seeps and springs that form shallow, small, slow flowing streamlet channels, rivulets, and/or sheet flow within fens; . Emergent herbaceous and woody vegetation for emergence facilitation and refugia; . Occupied, maintained crayfish burrows for refugia; and . Sufficient prey base of macroinvertebrates.  Physical and biological features essential for Hine’s emerald dragonfly adult foraging, roosting, reproduction, and refugia should consist of the following: . Natural habitat near the breeding/larval habitat

Habitat and biology: On the HNF, Hine’s emerald dragonflies occupy calcareous fens. Sites are located in groundwater-fed, alkaline habitats underlain by shallow dolomite. Detailed life history can be found in documents associated with the 2006 Forest Plan (USFWS 2006, pp. 207-210; USDA 2005, pp. 185-186).

Threats by NNIP: NNIP have not been identified as a risk to Hine’s emerald dragonfly habitat on the HNF. Although the recovery plan for the species does indicate that invading species could displace native wet prairie, sedge meadows, cattail marshes and other habitats known to be important for the species (Zercher et al. 2001). Invasive weeds, such as purple loosestrife, may be transported into suitable habitat as a result of road construction or use. If these weeds become established, they might native vegetation, which is potentially more suitable to the Hine’s emerald (USFWS 2006, p. 219). Activities that reduce the spread and infestation of NNIP are thought to be of benefit for the species by maintaining native plant diversity, which might enhance reproductive success and survival rates (USFWS 2006, p. 219).

Factors related to the conservation of the species: The BA for the 2006 Forest Plan lists the following factors and indicators as important for the conservation of Hine’s emerald dragonfly on the Forest (USDA 2005, pp. 190-191): 1. Calcareous fen habitat – No indicators were identified 2. Transportation/Recreation – No indicators were identified

Forest Plan Direction specific to Hine’s emerald dragonfly (USDA 2006a, Chapter 2)

Alternatives Forest Plan Guideline in or Standard1 Compliance Management Activity Notes/Specifics S-2600: Implement Yes Alt. 1 – NNIP control: current Alt. 1 – no change from federal recovery plan program current NNIP control Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) S-2600: Protect known Yes Alt. 1 – NNIP control: current Alt. 1 – no change from TE populations program current NNIP control Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) S-2600: Known Hine’s Yes Alt. 1 – NNIP control: current Alt. 1 – no change from emerald breeding sites program current NNIP control will be protected Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) S-2500: Wetland roads N/A Alt. 1 – NNIP control: current Both Alts. – proposed or trail crossings will program activities not associated preserve cross Alt. 2 – NNIP control: integrated with trail crossings drainage program S-2300: Cross country N/A Alt. 1 – NNIP control: current Both Alts. – proposed OHV travel is prohibited program activities not associated except in the Alt. 2 – NNIP control: integrated with OHVs designated OHV area program S-2300: Roads will be N/A Alt. 1 – NNIP control: current Both Alts. – proposed closed to OHVs unless program activities not associated designated/posted Alt. 2 – NNIP control: integrated with roads and OHVs open program GL-2600: Closure N/A Alt. 1 – NNIP control: current Both Alts. – proposed orders may be used to program activities not associated protect known TE Alt. 2 – NNIP control: integrated with closure orders – breeding areas, nests program species protections in and denning sites place GL-2600: Eliminate or Yes Alt. 1 – NNIP control: current Alt. 1 – no change from control NNIS in TE program current NNIP control occurrences Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Survey prior Yes Alt. 1 – NNIP control: current Alt. 1 – no change from to implementing program current NNIP control management Alt. 2 – NNIP control: integrated using Forest Plan program Alt. 2 – NNIP Control protocol and design criteria (pp. 10-14) – survey as appropriate for site being treated GL-2600: Give Yes Alt. 1 – NNIP control: current Alt. 1 – no change from

deference to listed program current NNIP control species where there Alt. 2 – NNIP control: integrated using Forest Plan are conflicts with program Alt. 2 – NNIP Control unlisted species protocol and design criteria (pp. 10-14) GL-2500: Implement MI Yes Alt. 1 – NNIP control: current Alt. 1 – no change from water quality best program current NNIP control management practices Alt. 2 – NNIP control: integrated using Forest Plan (BMPs) program Alt. 2 – NNIP Control protocol and design criteria (pp. 10-14) GL-2500: Clearcutting N/A Alt. 1 – NNIP control: current Both Alts. – proposed should not occur program activities not associated adjacent to woodland Alt. 2 – NNIP control: integrated with timber management ponds program GL-2500: The number N/A Alt. 1 – NNIP control: current Both Alts. – proposed of road and trail stream program activities not associated crossings should be Alt. 2 – NNIP control: integrated with road and trail stream minimized program crossings 1GL-guideline; S-standard; N/A – not applicable to the NNIP Control EA

Analysis of Effects - Hine’s emerald dragonfly and proposed critical habitat - Alternative 1 (No Change)

Direct and Indirect Effects Implementing Alternative 1 would no adverse effects on Hine’ emerald dragonfly over the period covered by this EA. Some NNIP sites would be allowed to persist or increase in size under Alternative 1. However, no Hine’s emerald sites have been identified that are currently being adversely affected by NNIP infestations. There are no known sites in imminent danger of future infestations that would result in adverse impacts to the species. Invasive weeds, such as purple loosestrife, may, however, be transported into suitable habitat as a result of road construction, road use or a number of other vectors. If these weeds become established, they might displace native vegetation, which is potentially more suitable to the Hine’s emerald (USFWS 2006, p. 219). Activities that reduce the spread and infestation of NNIP are thought to be of benefit for the species by maintaining native plant diversity, which might enhance reproductive success and survival rates (USFWS 2006, p. 219). The HNF would likely continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical means only, using individual project decisions not associated with this EA. There are no known infestations threatening areas proposed for listing as critical habitat. However, it is possible there are infestations in suitable and occupied Hine’s habitat and in proposed critical habitat, which are unknown. It is likely there would be a high priority placed on eradicating infestations with potential to adversely affect T&E should that circumstance develop on the Forest. We anticipate that due to Forest Plan direction, Hine’s emerald sites being threatened by NNIP would be treated, and the threat abated. Implementing Alternative 1 would not change the primary constituent elements of critical habitat: organic soils, hydrology, emergent vegetation; crayfish burrows, prey base, or other physical or biological features. Changes to emergent vegetation would not be anticipated to occur over the 5-year period of the EA, since there are no known infestations, and few are expected. Combined with no known NNIP threats to Hine’s emerald dragonfly and Forest Plan direction for protecting breeding habitat for Hine’s, we have determined that implementing Alternative 1 would have no effect on the species and proposed critical habitat.

Cumulative Effects for Hine’s emerald dragonfly

Because there would be no effects on Hine’s emerald dragonfly associated with implementation of Alternative 1, there would be no cumulative effects when combined with the effects of past, present, or reasonably foreseeable future activities in the project area.

Cumulative Effects for proposed Hine’s emerald dragonfly critical habitat Because there would be no direct or indirect effects to primary constituent elements, there would be no cumulative effects to proposed Hine’s emerald dragonfly critical habitat.

Analysis of Effects on Hine’s emerald dragonfly and proposed critical habitat - Alternative 2 (Proposed Action)

Mechanical or manual method of treatment – Noise from manual and mechanical treatments, such as use of the weed torch, brush cutter and saw in the immediate vicinity of breeding and foraging sites would not disturb Hine’s emerald. Human disturbance is discussed below.

Chemical Treatment – The data for chemical treatment methods are summarized in Table E-1, Table E-2 and Table E-3. Table E-3 presents a qualitative assessment of risk to organisms from information from several sources. The most relevant toxicological data for assessing impacts to insect species is the noted effect or risk to honeybees, as this animal is commonly used to evaluate toxicity for invertebrates. In Table E-2, the topical LD50 data for honeybees represent the quantities of active ingredient contacting the exterior surface of the honeybee that result in 50 percent mortality. An approach for estimating exposure of an insect that happens to fly under a hand-held spray boom at the time of application would be to assume that the top surface of the insect is roughly 1 square inch. If glyphosate is sprayed at a rate of 3.75 lb active ingredient per acre, a rate commonly used for general vegetation control (WSSA 2006), the insect would be exposed to roughly 6 X 10-6 lb (270 μg) of active ingredient. The estimated exposures exceed the corresponding topical LD50 values in Table E-1. When uncertainties whether honeybee data actually reflects the assessed species, it is clear that insects directly contacted by herbicide spray could be adversely affected, causing death of injury to a Hine’s emerald. Insects that contact wet foliage immediately after spraying could be similarly affected. Once the spray dries, it is unlikely that insects would be exposed to such high topical concentrations, even if they briefly land on treated foliage. The ecological risk assessments summarized in Table E-3 also suggest that insects directly contacted by spray streams could be affected, but that the herbicides proposed for use, in general, pose little risk to invertebrates. However, conservatively, we concluded that herbicide treatments may impact individuals of Hine’s emerald dragonfly and that contact could cause death or injury. However, a number of considerations reduce the level to minimal risk.

First, protections and mitigation are built into the HNF NNIP Control project: 1) All treatments proposed for Hine’s emerald habitat (wet meadows, fens, bogs, riparian sites, and other wet areas) would be reviewed by a wildlife biologist (design criteria No. 10, p. 12); activities would be stopped and/or modified if it is determined that harm could result to T&E species. 2) Design criteria No. 14 (p. 13) directs that movement in Hine’s emerald habitat should be minimized if treatment is determined necessary through the wildlife biologist’s review; 3) No treatment would occur in Hine’s emerald habitat from the second week in June to the end of August (This corresponds to approximately two weeks before and two weeks after the adult flight period) (criteria No. 13, p. 13);

4) There are also buffers required around wet areas to ensure that only those herbicides with formulations approved for aquatic use can be used (criteria No. 11, p. 13) (It is based on guidance in Michigan BMPs (MDNR 1994) - The minimum upland buffer is 100 feet in width); and, 5) Spot herbicides treatments are to be used over broadcast spraying (protocol 8, p. 11).

Second, since most NNIP infestations are along roadsides, upland openings and other disturbed areas, we anticipate limited acreage of wetlands would be sprayed with herbicides under Alternative 2. Also, purple loosestrife, a species that could invade Hine’s emerald habitat on the HNF can be treated with other methods, such as biological control. Therefore, we anticipate infrequent circumstances for use of herbicide in occupied Hine’s emerald dragonfly habitat or in critical habitat for this species.

Biological Control - The biological control agents proposed for use on the HNF are insects (Table I- 7), and thus might be expected to compete with native insects for food and other resources. However, all of the agents have a proven record of use without adverse impacts on native insect populations (Van Driesche et al. 2002). All feed preferentially on the target NNIP species, thus obtaining food from plants that are generally not attractive to native insects. All are beetles or weevils in the Order Coleoptera, with distinctively different ecological niches than insects in the Orders Odonata (includes the dragonflies). The risk of adverse effects through competition with the rare native insects described above is therefore discountable, even if the target NNIP species is eradicated. Furthermore, releases of biological control agents would be performed manually from the road, away from any Hine’s habitat, eliminating the need to walk into habitat and risk physical disturbance. There are several insects specified that are effective against purple loosestrife, a potential NNIP that could adversely impact Hine’s habitat in the future. Activities that reduce the spread and infestation of NNIP are thought to be of benefit for the species by maintaining native plant diversity, which might enhance reproductive success and survival rates (USFWS 2006, p. 219). We conclude that use of biological controls would pose no detectable adverse impacts to Hine’s emerald dragonflies and proposed critical habitat.

All NNIP Control Methods - There might some level of human disturbance in the form of noise and movement associated with manual, mechanical and herbicide treatments. However, it would be minimal. Most treatments would not require the use of motorized equipment. Trampling of larvae or eggs could also occur, but we consider of low risk considering the limited amount of treatment anticipated in this species habitat and protections in the design criteria. For all treatments, work in areas of suitable or occupied habitat would be limited. They would also be reviewed by a wildlife biologist prior to being implemented (see design criteria). Impacts would be of short duration, temporary and localized. For the manual/mechanical, chemical, and biological treatment methods, we conclude that the overall impacts to individuals would be insignificant. We determined there are no additional effects relative to the factors and indicators important for the conservation of Hine’s emerald dragonfly on the HNF (see Factors related to the conservation of the species, above).

Regarding impacts to Hine’s emerald critical habitat, a total of approximately 13,000 acres have been proposed by the USFWS. The total 200-acre maximum would represent 1.5 percent of that acreage. The more likely 10 acres of annual treatment in wetlands across the Forest would represent .08 percent of all areas proposed as critical habitat (assuming all of the wetland treatment occurred in Hine’s critical habitat, an unlikely possibility). Thus, implementing Alternative 2 could possibly change the vegetation component of proposed Hine’s critical habitat. However, the change would likely be beneficial, since NNIP would be removed and native plant species would become established on the sites. Changes to emergent vegetation would be small in magnitude over the 5-year period of the EA, since there are no known infestations, and few are expected. Should treatments occur, the most likely scenario is for minimal vegetation to be disturbed.

Vegetation that is removed would be rapidly replaced by colonizing species. Finally, a wildlife biologist would review every proposal for NNIP treatment in Hine’s emerald dragonfly habitat. The treatment would be disapproved if harm could result to Hine’s emerald dragonfly or proposed critical habitat (design criteria No. 10, p. 12). Implementing Alternative 2 would not potentially change any of the other primary constituent elements (PCEs) of critical habitat: organic soils, hydrology crayfish burrows, prey base, or other physical or biological features.

Summary – Direct and Indirect Effects – Alternative 2 While any adverse effects from implementation of control methods would be temporary and so minimal as to be insignificant or undetectable, beneficial effects to Hine’s emerald dragonfly from eliminating NNIP species from its habitat (or protecting habitat from future infestation) would be long term. Protections in the form of design criteria adequately reduce risk of death and injury to individuals to a level we have determined to be insignificant. Over the long term, there would be benefits associated with implementing this alternative. The benefit would be in the long term prospect that proactive treatment of NNIP, before they invade Hine’s emerald dragonfly habitat or critical habitat, would reduce risks to the species from infestations. This would maintain or enhance this species habitat and possibly result greater productivity and survival of Hine’s emerald dragonfly. This view is comparable to information contained in the 2006 Forest Plan Biological Opinion (USFWS 2006, p. 219 and Appendix J). Implementing Alternative 2 could possibly change the emergent vegetation PCE of proposed Hine’s emerald critical habitat. This could occur if NNIP are treated then replaced by native plant species. This would be a beneficial change for the species. Due to the small acreage anticipated to be treated in proposed critical habitat, the beneficial effect would likely be small.

Cumulative Effects for Hine’s emerald dragonfly The adverse effects from implementing Alternative 2 would be so small as to be undetectable, discountable or insignificant. Because there would be no detectable effects or effects are insignificant or beneficial, there would be no cumulative effects to Hine’s emerald dragonfly.

Cumulative Effects for Hine’s emerald dragonfly critical habitat The effects from implementing Alternative 2 would be beneficial or so small as to be undetectable, discountable or insignificant. Because there would be no detectable effects or effects are insignificant or beneficial, there would be no cumulative effects to proposed Hine’s emerald dragonfly critical habitat.

Determination for Hine’s emerald dragonfly

Determination Alternative 1 – No effect Alternative 2 – May affect, not likely to adversely affect

Determination for proposed Hine’s emerald dragonfly critical habitat

Determination Alternative 1 – No effect Alternative 2 – May affect, not likely to adversely affect

Kirtland’s warbler (Dendroica kirtlandii) Status of the species: Federally Endangered The species is present on the Forest during the nesting season. Management efforts for Kirtland’s warbler (KW) on the HNF generally began in the mid-1990s. Nesting populations have fluctuated from the 1990s to the present. In 2006, 18 of the 21 singing males counted in the Upper Peninsula (U.P.) were observed on the HNF. Nine females were also observed during the U.P. census, all on the HNF (Sjogren 2006). The recent low number of documented males (4) occurred in 2002 (USFWS 2006, p. 192). The USFWS has a signed recovery plan for the species. The USFWS Biological Opinion for the 2006 Forest Plan includes detailed information regarding species status and natural history information for the KW (USFWS 2006, pp. 186-191). The Biological Assessment for the 2006 Forest Plan includes comparable information (USDA 2005). As of March 2007, there had been no change in the status of this species.

Habitat and biology: The species typically occupies jack pine stands greater than 80 acres, with a stocking density of 1,089 or more trees per acre, and scattered small openings. Detailed life history can be found in documents associated with the 2006 Forest Plan (USFWS 2006, pp. 187-190).

Threats by NNIP: NNIP have not been identified as a risk to KW or KW breeding habitat. The level of NNIP infestation anticipated in the near future is not expected to constitute a threat to the species on the HNF (USDA 2005, p. 210).

Factors related to the conservation of the species: The BA for the 2006 Forest Plan lists the following factors and indicators as important for the conservation of Kirtland’s warbler on the Forest (USDA 2005, pp. 204-207): 1. Availability of breeding habitat – No indicators were identified 2. Human activity and disturbance – No indicators were identified 3. Nest parasitism by brown-headed cowbird – No indicators were identified

Forest Plan Direction specific to Kirtland’s warbler (USDA 2006a, Chapter 2)

opening guideline may be exceeded by harvesting adjacent blocks after the appropriate stocking density (determined with FWS) is achieved and after the third-year stocking review GL-2600: Closure N/A Alt. 1 – NNIP control: current Both Alts. – proposed orders may be used to program activities not associated protect known TE nest Alt. 2 – NNIP control: integrated with closure orders – sites program species protections in place GL-2600: In areas N/A Alt. 1 – NNIP control: current Both Alts. – proposed managed for KW, strive program activities not associated to regenerate jack pine Alt. 2 – NNIP control: integrated with timber management stands with the program appropriate stem density and openings in consultation with FWS GL-2600: Pre- N/A Alt. 1 – NNIP control: current Both Alts. – proposed commercial thinning or program activities not associated release of jack pine Alt. 2 – NNIP control: integrated with timber management should not occur in program areas managed for Kirtland's warbler prior to vegetation before or during suitable period unless activity maintains or enhances KW as determined with FWS GL-2600: Reserves for N/A Alt. 1 – NNIP control: current Both Alts. – proposed even-aged managed program activities not associated stands on: ELTs 10/20, Alt. 2 – NNIP control: integrated with timber management method A and/or B, or a program or reserve trees combination of both should be used. For all other ELTs, either method A or method B should be used. 2-4 live trees with diameters greater than or equal to the average stand diameter per acre should be reserved. - Preference should be given to live den trees Variable size reserve islands or clumps that total up to 1/2-acre for every 10 acres should be reserved GL-2600: For reserve N/A Alt. 1 – NNIP control: current Both Alts. – proposed snag and down logs in program activities not associated

managed stands: Alt. 2 – NNIP control: integrated with timber management, 2-10 snags per acre manual/mechanical, herbicides, snags or downed logs should be reserved, biological (insects) except where additional snags would be beneficial to rare species or unless presenting a safety concern or interfere with mechanical site prep. Additional snags should be recruited from live trees where there are fewer than 2 snags/ac Snags felled for safety reasons should be left as coarse woody debris 2 or more down logs per acre = or > to 10 inches in diameter and 8 feet long, should be maintained. In stands where tree diameters are less than 10 inches, down log diameters = or > than the average stand diameter should be provided GL-2600: Survey prior Yes Alt. 1 – NNIP control: current Alt. 1 – no change from to implementing program current NNIP control management Alt. 2 – NNIP control: integrated using Forest Plan program Alt. 2 – NNIP Control protocol and design criteria (pp. 10-14) – survey as appropriate for site being treated GL-2600: Give Yes Alt. 1 – NNIP control: current Alt. 1 – no change from deference to listed program current NNIP control species where there Alt. 2 – NNIP control: integrated using Forest Plan are conflicts with program Alt. 2 – NNIP Control unlisted species protocol and design criteria (pp. 10-14) 1GL-guideline; S-standard; N/A – not applicable to the NNIP Control EA

Analysis of Effects - Kirtland’s warbler - Alternative 1 (No Change)

Direct and Indirect Effects Implementing Alternative 1 would have no effect on Kirtland’s warbler (KW) over the period covered by this EA. Some NNIP sites identified would be allowed to persist or increase in size. However, there are no known infestations of NNIP currently adversely affecting KW habitat on the HNF. We do not anticipate infestations of sufficient level to adversely affect KW over the period covered by this EA. The HNF would likely continue to remove approximately 30-50 acres of invasive weeds

through manual and mechanical means only, using individual project decisions not associated with this EA. It is possible that failure to control the spread of NNIP species into potentially suitable habitat could eventually result in a prevalence of degraded habitats that are less favorable to KW. The more aggressive upland NNIP, such as Japanese barberry, leafy spurge, or spotted knapweed could slow the establishment of jack pine saplings, and thus theoretically be an adverse indirect impact to the Kirtland’s warbler. However, even these NNIP species are unlikely to thrive on the xeric soils typical of jack pine to an extent that they would influence seedling growth. In the unlikely event this would occur on sites across the Forest, a period of time much greater than the 5-year span covered by this EA would have to elapse.

Cumulative Effects Because there are no direct or indirect effects on Kirtland’s warbler associated with Alternative 1, there would be no cumulative effects when combined with the effects of past, present, or reasonably foreseeable future activities in the project area.

Analysis of Effects - Kirtland’s warbler - Alternative 2 (Proposed Action)

Direct and Indirect Effects Mechanical or manual method of treatment - Methods to reduce NNIP at the acreage specified would have minimal effects relative to the factors identified as related to the conservation of KW. Human disturbance would be minimal because most applications would not require the use of motorized equipment. There may be some increase in noise and movement from weed cutters and saws in proximity to KW habitat as treatment is conducted, but these impacts would be of short duration, temporary, and localized. The approximately 200 acres of manual treatment would not affect a highly habitat specialized species, such as KW, since most applications would be focused on invasive plants that are not prevalent in jack pine (e.g. garlic mustard, spotted knapweed, buckthorn, barberry).

The potential for direct impacts to the Kirtland’s warbler would be limited to work performed in jack pine stands, an upland habitat that constitutes less than 6 percent of the HNF. As for most birds, human activity and use of noise-generating equipment in the immediate vicinity of nests could interfere with nesting or cause abandonment of the nest. Design criteria No. 23 would preclude treatment within and adjacent to stands occupied by KW. This would serve to reduce impacts to Kirtland’s warblers to a level we determine to be insignificant.

Chemical Treatment - The data summarized in Tables E-2 and E-3 suggest that the herbicides proposed for use would pose little risk to avian species. Proposed activities would likely employ spot treatments and would not damage jack pine trees, which constitute nesting and foraging habitat. Direct contact of Kirtland’s warbler by herbicides is unlikely, since design criteria No. 23 would preclude treatment within and adjacent to stands occupied by KW during the breeding season. Overall, few treatments would be expected to occur in potential habitat for this species, since only approximately, 6 percent of the forested lands on the HNF are jack pine that may be suitable for KW; there are few jack pine sites threatened by NNIP that are priority locations for treatment. Using anticipated application rates pose little risk to terrestrial invertebrates, a primary prey of KW. The risk assessment for glyphosate concludes that small birds who consume insects from areas treated with the maximum application rate for an extended period could experience adverse effects (USDA Forest Service 2003a). However, we consider that a very unlikely scenario for the HNF due to small acreage anticipated to be treated overall, and the location of most anticipated treatment sites outside of KW habitat. As mentioned previously, design criteria No. 23 would be implemented. Thus, to be exposed to treated insects, KW would have to fly from their breeding stands, and stands adjacent to breeding stands, to reach those stands that might have

received a small NNIP treatment. We consider this to be a highly unlikely scenario. It is also likely that the small acreages to be treated would be accomplished at the noted average rates for Forest Service projects that pose little risk, rather than the maximum rates for these products (Table E-3). Furthermore, project protocol directs that manual/mechanical treatments be considered first for applicable NNIP, and that spot treatments be employed, rather than broadcast applications (protocols, pp. 10-11). These measures further reduce the risk to this species. None of the proposed herbicides are related to carbamate and organophosphate insecticides, which inhibit cholinesterase enzymes and have been known to cause bird mortality. Therefore, considering all of the above, adverse impacts to Kirtland’s warbler from use of listed chemicals would be insignificant.

Biological Control - The biological control agents proposed for use in the program do not target NNIP species that are likely to infest dense jack pine thickets, although leafy spurge and spotted knapweed could infest areas at the edges of the thickets or gaps in the thickets. Each of the proposed biological control agents has a record of successful and safe application within Midwestern areas similar to that of the HNF. Insects used as biological control agents (Table I-7) for leafy spurge, purple loosestrife, spotted knapweed and Eurasian water milfoil are neither competitors nor prey of KW. Thus, their abundance or absence would have no effect on KW. Therefore, use of biological controls would pose no adverse effects to Kirtland’s warbler.

Summary – Direct and Indirect Effects – Alternative 2 Any KW response from exposure to control activities for NNIP would be minimal and would have no detectable impacts. This statement is consistent with information in the BO (USFWS 2006, p. 197, Appendix I). Over the period anticipated for control under this EA, there would be minimal beneficial impacts afforded to Kirtland’s warbler from the decrease in NNIP (USDA 2005, p. 210). However, over a longer period, not considered in this document, detectable beneficial results could accrue (USFWS 2006, Appendix I). Due to the small acreage proposed for treatment, the short duration of anticipated control measures for NNIP, minimal human disturbance, unlikelihood of treatment in KW habitat, and protections in the design criteria, implementing Alternative 2 would result in insignificant and discountable effects KW.

Cumulative Effects Because the direct and indirect effects on Kirtland’s warbler are minimal or discountable, no cumulative effects would occur if Alternative 2 were implemented.

Determination Alternative 1 – No effect Alternative 2 – May affect, not likely to adversely affect

Piping plover (Charadrius melodus) and piping plover critical habitat Status of the species: Federally Endangered The species is present on the Forest as a breeder. In recent years, the Great Lakes piping plover population has increased on the HNF. Surveys indicated 8 pairs of piping plovers fledged 12 young on the HNF at Pointe aux Chenes (Great Lakes Piping Plover Call 2006) during the 2006 breeding season. The species has expanded south and east in Michigan and west to Wisconsin (USFWS 2006, p. 115). A signed recovery plan exists for the species. The USFWS Biological Opinion for

the 2006 Forest Plan includes detailed information regarding species status and natural history information for the piping plover (USFWS 2006, pp. 113-117). The BA for the 2006 Forest Plan includes comparable information (USDA 2005). There are shoreline areas on both the Eastside and Westside of HNF that are focal points for management (USFWS 2006, p. 116). On the HNF, approximately 1.2 miles of Lake Michigan shoreline was designated as piping plover critical habitat (USDA 2005). As of March 2007, there had been no change in the status of piping plover.

Habitat and biology: Piping plovers are shorebirds, breeding in sparsely vegetated beaches, cobble pans and sand spits of glacially-formed sand dune ecosystems along the Great Lakes. Foraging occurs along the shoreline. Nests are shallow depressions in the sand lined with pebbles, shells and driftwood. Detailed life history can be found in documents associated with the 2006 Forest Plan (USFWS 2006, pp. 111-113).

Threats by NNIP: NNIP have been identified as a risk to piping plover breeding habitat on the HNF (USDA 2005, p. 156; USFWS 2006, p. 121). Recent observations suggest as the water level in Lake Michigan decreases, NNIP are encroaching into shoreline areas that have suitable piping plover breeding habitat (Ekstrum, personal communication, 2007). On the HNF at Indian Point, white sweet clover, a high priority NNIP, has been identified in piping plover habitat (Ekstrum, personal communication, 2007).

Factors related to the conservation of the species: The BA for the 2006 Forest Plan lists the following factors and indicators as important for the conservation of piping plover on the HNF (USDA 2005, pp. 154-157): 1. Nest protection – No indicators were identified 2. Human disturbance – No indicators were identified 3. Predators – No indicators were identified 4. Habitat management – No indicators were identified 5. Critical habitat primary constituent elements (PCEs) – No indicators were identified

Forest Plan Direction specific to piping plover (USDA 2006a, Chapter 2)

S-2300: Cross country N/A Alt. 1 – NNIP control: current Both Alts. – proposed OHV travel is prohibited program; activities not associated except in the Alt. 2 – NNIP control: integrated with OHVs designated OHV area program S-2300: Roads will be N/A Alt. 1 – NNIP control: current Both Alts. – proposed closed to OHVs unless program activities not associated designated/posted Alt. 2 – NNIP control: integrated with roads and OHVs open program GL-2600: Closure N/A Alt. 1 – NNIP control: current Both Alts. – proposed orders may be used to program activities not associated protect known TE Alt. 2 – NNIP control: integrated with closure orders – breeding areas, nests program species protections in and denning sites place GL-2600: Eliminate or Yes Alt. 1 – NNIP control: current Alt. 1 – no change from control NNIS in TE program current NNIP control occurrences Alt. 2 – NNIP control: integrated using Forest Plan manual/mechanical, herbicides, Alt. 2 – NNIP Control biological (insects) protocol and design criteria (pp. 10-14) GL-2600: Survey prior Yes Alt. 1 – NNIP control: current Alt. 1 – no change from to implementing program current using Forest Plan management Alt. 2 – NNIP control: integrated Alt. 2 – NNIP Control program protocol and design criteria (pp. 10-14) – survey as appropriate for site being treated GL-2600: Give Yes Alt. 1 – NNIP control: current Alt. 1 – no change from deference to listed program current NNIP control species where there Alt. 2 – NNIP control: integrated using Forest Plan are conflicts with program Alt. 2 – NNIP Control unlisted species protocol and design criteria (pp. 10-14) GL-2600: Recreation N/A Alt. 1 – NNIP control: current Both Alts. – proposed activities should be program activities not associated discouraged near active Alt. 2 – NNIP control: integrated with recreation and historic piping program plover nesting sites GL-2500: Implement MI Yes Alt. 1 – NNIP control: current Alt. 1 – no change from water quality best program current using Forest Plan management practices Alt. 2 – NNIP control: integrated Alt. 2 – NNIP Control (BMPs) at minimum program protocol and design criteria (pp. 10-14) GL-2500: Yes Alt. 1 – NNIP control: current Alt. 1 – no change from Determination of program current NNIP control coastal zone consis- Alt. 2 – NNIP control: integrated using Forest Plan tency will be completed program Alt. 2 – NNIP Control for all activities protocol (pp. 10-14) occurring within 1/4 mile from the Great Lakes high water mark 1GL-guideline; S-standard; N/A – not applicable to the NNIP Control EA

Analysis of Effects – Piping plover and critical habitat - Alternative 1 (No Change)

Direct and Indirect Effects

Implementing Alternative 1 would likely have some adverse effects on piping plover, but not on critical habitat, over the period covered by this EA. While some NNIP sites identified would be allowed to persist or increase in size, it is likely that the Forest would conduct manual removal of NNIP should they threaten a section of shoreline were nesting has occurred, as has been accomplished in the past. There are infestations in and near piping plover and the species critical habitat. However, these infestations have not reached the level that nesting is precluded. Rather, failure of nests in certain Great Lakes shoreline locations have been attributed to activity of predators and unauthorized use of OHV. The Forest would likely continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical means only, using individual project decisions not associated with this EA, some of which would occur in nesting habitat, as well as critical habitat. It is possible that failure to control the spread of NNIP species into occupied and suitable habitat could eventually result in some degraded habitats that are less favorable to piping plover. Recent information from field observations by USFS employees indicate that the decreasing water level in Lake Michigan have combined with beach succession and the presence of NNIP in the expanding shoreline to a level that is exceeding the capabilities of manual control (J. Ekstrum, personal communication, 2007). As this condition progresses over the next 5 years, the amount of suitable habitat for piping plovers would not increase with the expanding shoreline. Rather, it would remain constant or decrease in acreage and quality due to the presence of NNIP and succession of beach vegetation. Over time, this could affect individual piping plovers on the HNF and lead to lower annual productivity. However, under Alternative 1, it is plausible that the Forest would likely make NNIP treatments in these piping plover areas an annual priority, thereby reducing the risk of decreased productivity.

Vegetation on shoreline habitat might change over time under Alternative 1. We expect the change to be minimal and insignificant within the 1.2-mile section of critical habitat on the HNF under the current program. Critical habitat would be likely to be treated under Alternative 1 because it is one of the highest priorities. While decreasing water levels might impact the structural character of critical habitat, implementing the NNIP actions under Alternative 1 would not change physical aspects of beach habitat, slope, length of beach, dune development, distance from tree line or amount of sand and cobble.

Cumulative Effects for Piping plover The cumulative effects area for this species are the lands within the proclamation boundary of the HNF. This is the area that the USFS monitors and has a level of certainty regarding the movements of this species over the breeding season. Once piping plover nesting activity is initiated in the spring, the adults maintain nesting and foraging areas within the local beach habitat, unless the nest fails. In the event a nests fails, the adults might move many miles from the original nesting location. Cumulative effects include the combined effects of any future State, local, or private actions that are reasonably certain to occur within the action area. Future Federal actions that are unrelated to the proposed action are not considered in this section because they require separate consultation pursuant to section 7 of the Act.

Piping plovers may be affected by activities in the areas of private ownership on the Forest. Population growth is expected to occur in the eastern Upper Peninsula in the future. Mackinac County and Chippewa County are expected to increase by 34.7% and 29.6%, respectively, through 2020 (USFS 2005a). Human activities, including development, recreation, and roads to the shoreline are present and may be expected to continue in these areas. Human disturbance and lack of nest protection measures in piping plover habitat on private lands could have adverse effects to piping plover. Piping plover nests on private land may not be protected unless they are reported. Shoreline areas are highly sought after as sites for vacation homes or resorts and are

highly vulnerable to ongoing shoreline development and intensive recreation. Development on private lands would reduce available habitat.

Many of the dune areas within the Forest boundary, however, are protected as “critical dunes” under the Michigan Sand Dunes Protection and Management Program, part of 353 of the Natural Resources and Environmental Protection Act, 1994 PA 451. Part 353 establishes protective standards on dunes considered to be the most sensitive. Such areas are protected from most development, which should provide substantial protection for piping plover habitat.

U.S. Highway 2 runs along much of the piping plover habitat on the Lake Michigan shores. This busy road has several picnic areas and access points along the stretch of Lake Michigan, which increases human access and activity. Impacts from recreational uses include dune erosion and introduction of NNIS. Road maintenance activities, including emergency repairs on eroding shoreline areas, herbicide application, mowing, road salting, shoulder grading, snow removal, and tree removal, may affect piping plover. The Michigan Department of Transportation is trying to stabilize the blowing sand from the dunes, but the movement of sand still occurs. Sand dune stabilization desired for U.S. Highway 2 corridor may affect the dune habitats suitable for piping plovers. Regarding herbicide application, the Forest Service would coordinate with MIDOT annually to determine areas proposed for spraying, acreage and chemicals to be applied. This would provide communication that would help to ensure that only those herbicides with non-toxic or low toxicity to piping plovers and other plants and wildlife are used.

Anticipated increases in OHV use, noise, pedestrian traffic, personal watercraft and other noise- producing activities, possible development of a Great Lakes water-trail, and other activities anticipated along shorelines within the proclamation boundary may increase disturbances to piping plover. This may cause a loss of eggs or individuals, overall reducing nesting success. Increases in shoreline recreation facilities and shoreline residential developments are also likely to increase human disturbance. This could increase the potential for predation and harassment by domestic animals or predators. However, the degree of impact to plovers is difficult to predict. In recent years, piping plover populations have increased along with increased recreation use. While this does not suggest a cause-effect relationship, it is important to note that a potentially complex relationship of factors is involved in the increase in the piping plover population in the Great Lakes area.

Water level fluctuations may affect piping plovers. During periods of high water there is a reduction in the amount of beach habitat available for nesting plovers. Over the past 80 years, maximum Great Lake water levels were in 1973 and 1985; minimum Great Lakes water levels were 1926, 1934 and 1936 (US Army Corp Engineers 2004). Water level fluctuations will continue to occur in the Great Lakes, increasing the potential for destruction of lost piping plover nests during periods of high water. In 2004, water levels rose from the 2003 level in Lake Michigan, causing the loss of some piping plover nesting areas early in the nesting season. During periods of high water, less shoreline habitat would be available as nesting habitat. During periods of low water, beach succession would occur, a condition that would also reduce the amount of nesting habitat available to piping plover.

Cumulative Effects for Piping plover critical habitat There are no direct or indirect effects associated with Alternative 1. Because there are no direct or indirect effects, there are no cumulative effects to piping plover critical habitat.

Analysis of Effects - Piping plover - Alternative 2 (Proposed Action)

Mechanical or manual method of treatment – Mechanical methods to reduce NNIP at the acreage specified would have minimal effects to piping plover, since control activities would only be conducted when plovers are not present (design criteria No. 12, p. 13). Therefore, piping plovers would not be exposed to human disturbance associated with NNIP control activities.

Chemical Treatment - Direct exposure to chemicals would not occur since plovers would not be present when control activities would be conducted (see design criteria No. 12, p. 13). Due to the proximity of shoreline areas to water, only those herbicides approved for aquatic use would be used in piping plover habitat or within a predetermined upland buffer (see design criteria No. 11, p. 13). Glyphosate has a short soil half-life and a very low toxicity to invertebrates. Triclopyr (salt formulation and ester formulation) also have short half-lives and low risk to invertebrates. Both of these herbicides have formulations approved for use in wet areas. Therefore, assuming design criteria would be followed, there would be minimal risk from chemical treatments in piping plover habitat.

Biological Control - Each of the proposed biological control agents has a record of successful and safe application within Midwestern areas similar to that of the HNF. Insects used as biological control agents (Table I-7) for leafy spurge, purple loosestrife, spotted knapweed and Eurasian water milfoil are neither competitors nor prey of piping plover. Thus, their abundance or absence would have no effect on piping plover. Therefore, use of biological controls would pose no effects on piping plover.

All NNIP Control Methods - All invasive plant species control, regardless of method, would be conducted when plovers are not present. Therefore, piping plovers would not be exposed to human disturbances associated with NNIP control activities. There would be no other effects related to factors important for the conservation of the species and critical habitat under this alternative.

Implementing Alternative 2 would result in some benefits to critical habitat on the HNF. The Recovery Plan for the Great Lakes Piping Plover (USDI 2003) indicates that critical habitat for the species consists of sparsely vegetated sand beaches associated with wide, unforested systems of dunes or inter-dune wetlands. Controlling NNIP under design criteria of Alternative 2 would help maintain the sparse vegetation component of critical habitat on the HNF. There would be no adverse effects to critical habitat from implementing the manual/mechanical, herbicide or biological control methods under Alternative 2.

Summary – Direct and Indirect Effects – Alternative 2 The adverse effects to piping plover from implementing Alternative 2 would be minimal, and therefore, insignificant. For piping plover, implementing Alternative 2 would provide beneficial effects. The greater maximum treatment acreage and variety of treatments would provide options for responding to NNIP infestations along the Lake Michigan shoreline. As the water level has decreased, the expanding shoreline and beach succession have resulted in infestations no longer completely treatable with hand pulling and other manual methods. Alternative 2 would provide the options to use herbicide and biological methods to control NNIP and create the sparse shoreline vegetation associated with habitat favored by piping plovers for nesting. A greater area of potential habitat could accommodate more nesting pairs, and increased success rate of nesting attempts. It is unlikely shoreline habitat would be completely void of vegetation after NNIP control treatment

because the plants tend to occur in patches and other vegetative species, both native and non- native, are present. Using design criteria for Alternative 2, native and desirable non-native plants could be retained, while NNIP would be removed. Thus, regardless of NNIP treatment employed, a sparsely vegetated habitat would result. Anticipated NNIP control activities outside of beach areas would also benefit the species by slowing or stopping the movement of weeds into piping plover habitat that is not infested or minimally infested. Long-term NNIP control would sustain habitat for piping plover in the future, increasing or maintaining breeding populations on the HNF. Comparable information is presented in the BO (USFWS 2006, p. 125, Appendix F).

Cumulative Effects for Piping plover There would be benefits associated with implementing Alternative 2 that may offset some other direct and indirect affects from non-federal activities within the action area (see cumulative effects discussion for Alternative 1). Because there are no detectable effects or effects are discountable or beneficial under this alternative, there would be no cumulative effects to piping plover.

Cumulative Effects for Piping plover critical habitat There would be benefits to critical habitat associated with implementing Alternative 2 that may offset some other direct and indirect affects from non-federal activities within the action area (see cumulative effects discussion for Alternative 1). Because there are no detectable effects or effects are discountable or beneficial under this alternative, there would be no cumulative effects to piping plover critical habitat.

Determination for Piping plover

Determination Alternative 1 – May affect, not likely to adversely affect Alternative 2 – May affect, not likely to adversely affect

Determination for Piping plover critical habitat

Determination Alternative 1 – No effect Alternative 2 – May affect, not likely to adversely affect

General Summary for T&E Animals Alternative 2 would provide the most benefits to T&E animals. While Alternative 1 would likely provide for a limited acreage of manual control around high priority sites, such as T&E occurrences, Alternative 2 would be most likely to exceed historic treatment acres (approximately 30-50 acres each year), since it would be a 5-year program with a decision in place. The greater maximum treatment acreage (200) under Alternative 2 would provide the botany program manager with options not available under Alternative 1 for decreasing the spread of NNIP, eradicating infestations and controlling infestations, as circumstances unfold over the ensuing five years. Incorporating three treatment methods: manual/mechanical, herbicides and biological (insect releases) would

give managers maximum flexibility to design an annual plan to target NNIP, protect TES species, and deal with sites and extensive coverage that may be beyond the capabilities of manual treatments. For piping plover, the selection of Alternative 2 would be beneficial by increasing the likelihood of habitat maintenance and improvements through NNIP control. Improvements in piping plover critical habitat would be expected to occur, since the treatments would result in a greater area of sparse, native vegetation, which are important elements in the species breeding habitat. Over the short term, Alternative 2 would possibly create habitat conditions that would result in greater numbers of breeding pairs on the HNF. Long-term NNIP control would sustain habitat for piping plover in the future, increasing or maintaining breeding populations on the HNF.

Regional Forester Sensitive Species Forest-wide Plan direction for Regional Forester Sensitive Species (RFSS) is found in the Hiawatha Forest Plan (USDA 2006 pg 2-17). These protection measures apply to all Regional Forester Sensitive Species, including future additions to this list. (Further direction can be found in the Plan for individual species, as noted in the analysis.) . Goal 2. Contribute to the conservations of RFSS and work cooperatively with state and federal agencies to complete and implement conservation assessments and strategies. . Guideline 1. Conservation approaches for RFSS should be implemented. . Guideline 2. Non-native invasive plants within element occurrences of RFSS should be eliminated or controlled. . Guideline 3. Adverse impacts to known occurrences of RFSS should be avoided or mitigated. . Guideline 4. Prior to implementing management activities, surveys should be conducted for RFSS where suitable habitat exists.

Unless otherwise noted, the analysis area for cumulative effects is the entire Hiawatha National Forest, and private, State, and Tribal lands within its boundaries.

Plants Framework for analysis of effects on RFSS plants

To study the effects of this project on RFSS plants, species were grouped by some very general habitat conditions. While the invasive plants in Table I-1 and I-2 (p. 9) have their own habitat requirements, they are aggressive enough to invade over a broad range of habitat conditions. For every habitat favored by RFSS, there are non-native plants that can invade it, so it made sense to discuss their effects to rare plants in more general terms (aquatic, open/wet, open, shade, and shade/wet). The list of RFSS plants analyzed can be found in Appendix A, Tables 1 and 4.

More information on biology, life history, distribution, and habitat associations for each species can be found in the BE for the HNF Forest Plan (USDA 2006b).

RFSS Plants – Aquatic Habitats

RFSS Habitat associations: The rare plants in this group (box at left) each Autumnal water-starwort have very specific water chemistry requirements as to acidity, and Algal pondweed hardness. Habitats include edges of lakes or streams, marshes, American shore-grass and spring-fed seeps. Bottom substrates range from sand and Alternate leaved water milfoil gravel/cobble to organic sands and muck. Algal pondweed prefers Lake cress more acidic water while the others grow in waters that are more Likely RFSS alkaline to neutral in pH. Yellow pond lily Invasive Plants Hill's pondweed Threats by NNIP: Eurasian water milfoil, Awlwort - Eurasian water milfoil Farwell's water milfoil Purple loosestrife, and other possible NNIP yet undetected on the HNF are - Purple loosestrife more tolerant of various growing conditions and can invade most of these

aquatic habitats. Eurasian water milfoil grows in lakes with some nutrients and at least a thin organic substrate and can germinate successfully on substrates with a wide range of pH (Hoffman and Kearns 1997, p. 68). Milfoil occurs at Steuben Lake and East Lake (Luce Co. MI). Purple loosestrife grows in moist soils of lake edges, marshes, stream margins, sedge meadows, and roadside ditches. Established plants can tolerate drier conditions for it has a wide tolerance of physical and chemical conditions (Hoffman and Kearns 1997). Hiawatha National Forest data lists 27 sites of purple loosestrife.

Forest Plan Direction specific to this habitat: Watershed management Objective: 6. Treat 10 acres per year for non-native invasive species in riparian areas (USDA 2006a, p. 2-14)

Analysis of Effects - Aquatic Habitat - Alternative 1 (No-Change) Under this alternative, there would be only limited efforts to control invasive plants on the forest. Prevention and public education efforts will still take place.

Direct and Indirect Effects There will be no direct impacts on aquatic plants under Alternative 1. Indirectly, RFSS aquatic plants may be impacted over the long term because they occupy habitats subject to infestation by Eurasian water milfoil and purple loosestrife (perhaps others yet undetected). Aggressive action to control NNIP would be required to reduce the risk of future reductions in RFSS populations due to competition. Since Forest Plan direction states that NNIP within element occurrences of RFSS should be eliminated or controlled, we assume some treatments would be accomplished. However, due to the limited treatment acres likely to occur, and the reliance on manual control, some NNIP may spread and new infestations might occur, increasing the risk to this group in the future.

Cumulative Effects As discussed above for direct and indirect impacts, existing infestations of several aggressive non- native plants may continue to spread and out compete native plants. Failure to control NNIP on the HNF, when combined with failure of some other land managers to control NNIP could indirectly result in increasing regional dominance of invasive plants and future adverse impacts on aquatic communities. However, this scenario would likely occur beyond the 5-year period of the NNIP Control EA. State DNR or others such as Lake Associations may choose to control aquatic invasive plants on some lakes, reducing the risk of spread somewhat.

Analysis of Effects - Aquatic Habitat - Alternative 2 (Proposed Action)

Direct and Indirect Effects Mechanical or manual method of treatment - Eurasian water milfoil can be cut and removed manually or by using an aquatic harvester. Manual pulling or cutting would be more selective. A harvester would pull all plants including non-target. Thus, RFSS plants could be killed or damaged using this method. Design criteria (Nos. 9, p. 12) and protocol No. 4 (p. 10) would ensure that additional analysis by a botanist would occur before using manual or mechanical controls wthin a lake or wetland with known populations of an RFSS plant. However, digging or pulling purple loosestrife can be effective and is the preferred control method on small infestations. Individuals conducting any treatment would be trained to recognize RFSS plants to prevent accidental digging or pulling when they occur near purple loosestrife (design criteria 4, p. 12).

Chemical Treatment - Chemical application in water would have a direct negative effect if it contacts the RFSS species above. This could result in injury or death of RFSS plants. It would be nearly impossible to apply herbicide in an aquatic system and only affect target species. Design criteria (Nos. 4 and 9) and protocol (pp. 10-11) would prevent the use of herbicide directly on RFSS plants.

There could conceivably be a scenario when Eurasian milfoil invades a lake with an open-water RFSS plant population such as algal pondweed. It may be advantageous to use herbicide on the NNIP before it dominates the lake, but in doing so, some portion of the RFSS population may be killed. There would not be a loss of viability if the sensitive plant had colonies in other parts of the lake to repopulate. Herbicides can be applied to patches of milfoil and only a portion of a lake treated at one time. Chemicals for use in water lose effectiveness and rapidly degrade so they don’t spread to other parts of the lake (Tu et al. 2001, p. 7). Timing of application can be in early spring before native plants are as active as the non-native Eurasian water milfoil. Whole lake treatments with herbicide are rare and require a comprehensive Lake Management Plan (MI DEQ 2006b, p. 4). Triclopyr can be used in water to treat purple loosestrife. It has the advantage of being broadleaf-selective; hence will not kill grass-like plants on shore (sedges, rushes, irises, cattails) and it degrades fairly rapidly (Petty et al. 2003). It will affect any broadleaf plant it contacts including RFSS. An aquatic formulation of triclopyr can also be used on Eurasian water milfoil in Michigan (MI DEQ 2006a). Glyphosate formulated for use near (but not in) open water is wiped on purple loosestrife plants using a saturated glove or sponge wand (very targeted). If sprayed, the glyphosate need only contact 25% of the foliage (Tu et al. 2001). The HNF Forest Plan includes direction for implementing Michigan Water Quality Best Management Practices on Forest Land (MDNR 1994). Direction in this document reiterates closely following the label directions for safe application of chemicals (MDNR 1994, p. 30-31). Michigan has a list of herbicides that can be used in aquatic habitats (MI DEQ 2006a). Use of chemicals in lakes would be a rare occurrence.

Biological Control - There will be no direct impact from this method. Three species of insect are proposed as predators of purple loosestrife (Table I-7). These insects selectively feed on purple loosestrife and will not harm other organisms (OFAH 2003). Complete eradication of loosestrife by insects is unlikely. The goal in using this method is to reduce numbers of the target plant to lessen its ability to displace native vegetation, which will have an indirect beneficial impact. One insect is proposed to treat Eurasian water milfoil. Eurhychiopsis lecontei weevils, native to North America, will feed on the Eurasian milfoil and seem to prefer it to the native species (Tu et al. 2001, p. 70). Biological control poses less risk to aquatic communities than physical or chemical means. Indirectly there would be a beneficial impact from the improvement of invaded aquatic ecosystems. Michigan does not require a permit for use of bio-control agents to control aquatic plants such as Eurasian water milfoil and purple loosestrife (MI DEQ 2006b).

Cumulative Effects There is a slight risk of killing individual lake and river aquatic RFSS plants like the pondweeds and milfoils using mechanical and chemical methods. The chance of this is very low due to small numbers of infested lakes. This would contribute marginal adverse cumulative effects to other past present or reasonably foreseeable negative actions in aquatic habitats, such as pollution or spread of NNIP by recreational use. However, this needs to be evaluated against an overall beneficial effect to RFSS and lake ecosystems from reducing the negative effects of invasive plants. Because of incrementally small negative impacts, actions would not reduce viability of the aquatic RFSS in this group.

Determination Alternative 1 – May impact individuals; not likely to cause trend to listing or loss of viability Alternative 2 – May impact individuals; not likely to cause trend to listing or loss of viability

The Forest Service Manual requires a determination of “may impact individuals but not likely to cause a trend to federal listing or loss of viability” when the proposed alternative may cause some negative effects, even if the overall effects to the species may be beneficial.

RFSS Plants – Open / Wet Habitats

RFSS Habitat associations: The rare plants in the open/wet habitat group Fir clubmoss occupy a broad range of wetland conditions where they receive Satiny willow nearly full sun all day. These include fen, bog, lakeshore, stream Bulrush sedge bank, interdunal wetland, marsh, moist rock, and moist alvar. Each Hyssop-leaved fleabane has specific soil and nutrient requirements but generally, Flattened spike-rush temperature restricts their ranges. Most of these species have the Wiegand’s sedge center of their range in Canada where these types of habitats and Moor rush Mat muhly cooler temperatures are more common. Northern prostrate Dwarf raspberry clubmoss so far is found only in Michigan. There is some Sweet-coltsfoot crossover in habitat between this grouping and the open/dry and Vasey’s rush beach group following. For example, the milk-vetches could be Torrey’s bulrush place here because they prefer slightly moister sand. Butterwort American sloughgrass Threats by NNIP: The NNIP on the right English sundew are found in a number of open/wet Invasive plants Northern prostrate club moss situations including lakeshore, stream and Purple loosestrife Likely RFSS riverbank, bog, disturbed marsh, and Screwstem Marsh (swamp) thistle Many-headed sedge roadside ditches competing with native Reed canary grass Slender spike-rush vegetation for resources. Reed canary Common reed Mountain fir clubmoss grass, often ignored due to its already Glossy buckthorn widespread occurrence in North America, is able to invade almost any wet to mesic open habitat. Swamp thistle, of European origin, is a problem unique to the northeastern U.S. Common reed is indigenous to North America, but this new, more invasive genotype was introduced from the old world relatively recently (TNC 1997).

Forest Plan Direction specific to this habitat: Watershed management Objective: 6. Treat 10 acres per year for non-native invasive species in riparian areas (USDA 2006a, p. 2-14)

Analysis of Effects - Open / Wet Habitat - Alternative 1 (No-Change)

Direct and Indirect Effects There will be no forest-wide integrated pest management program under the No-Change alternative so there will be no direct or indirect impact from these types of actions. Indirectly, the unchecked expansion of NNIP populations could negatively affect wetland plants by altering the habitat through shading, competition for nutrients, or allelopathy. Since Forest Plan direction states that NNIP within element occurrences of RFSS should be eliminated or controlled, we assume some treatment would be accomplished. However, due to the limited treatment acres likely to occur, and the reliance on manual control, some infestations may spread and new infestations might occur, increasing the risk to this group in the future.

Cumulative Effects Alternative 1 would have no direct effects to add cumulatively to other actions. There would be no widespread efforts to control invasive plants under Alternative 1, and combined with failure of some land managers to control them could indirectly result in increasing regional dominance of wetland invasive plants and future adverse impacts on RFSS plants. However, this scenario would likely occur beyond the 5-year period of the NNIP Control EA. State DNR or others, such as hunting

groups, may choose to control invasive plants in some adjacent wetlands, reducing the risks somewhat.

Analysis of Effects - Open / Wet Habitat - from Alternative 2 (Proposed Action)

Direct and Indirect Effects Any adverse direct effects from proper implementation of control methods would be relatively small and temporary. Indirectly, the removal of NNIP populations would benefit wetland habitat and RFSS populations.

Mechanical or manual method of treatment - Direct impacts of manual and mechanical actions could include a slight risk of inadvertent trampling or cutting of individual RFSS plants but design criteria would ensure that this risk would be very low. Risk of damage by hand pulling is no greater than the similar activities of inventory and monitoring populations (walking through an area and stepping on plants is the greatest risk). Populations have been monitored in the past with no negative effects. Design criteria (No. 9, p. 12) and protocol No. 4 (p. 10) would ensure that additional analysis by a botanist would occur before using manual or mechanical controls within a lake or wetland. Individuals conducting any treatment would be trained to recognize RFSS plants to prevent accidental digging or pulling when they occur near purple loosestrife (design criteria 4, p. 12).

Chemical Treatment - When using herbicide with a spray application method, there is a potential for contacting non-target plants. This could result in injury or death of RFSS plants. Design criteria (Nos. 4 and 9) and protocol No. 8 (p. 11) would prevent the use of herbicide directly on RFSS. Furthermore, application sites are small, and therefore, spot spraying of herbicides could efficiently be used to treat NNIP occurrences, reducing risk to RFSS plants. Using the cautions in the project design, such as buffers (design criteria 11, p.13), and spot spraying (protocol No. 8, p. 11), herbicides can be applied selectively without damaging adjoining native vegetation. In addition, a broadleaf-selective herbicide (Table I-4) can be used that generally would not harm grasses, sedges, or rushes (SERA 2003b; 2004a; 2004b). Only herbicides formulated for use near open water would be used adjacent to open water habitat (protocol No. 8, p. 11 and criteria 11, p. 13). Timing of application, as well as, concentration and exposure time can be manipulated to limit impact to non-target species. The HNF Forest Plan includes direction for implementing Michigan Water Quality Best Management Practices on Forest Land (MDNR 1994). Direction in this document reiterates closely following the label directions for safe application of chemicals (MDNR 1994, p. 30-31). Therefore, there would be minimal or no direct or indirect effect from chemical treatment. The efficacy of chemical methods allows for more rapid indirect beneficial effect to species in this habitat group.

Biological Control - There would be no direct impact from this method. Three species of insect are proposed against purple loosestrife and one weevil for Eurasian water milfoil (Table I-7); they would not harm other organisms (OFAH 2003; Tu et al. 2001, p. 70). Biological control poses less risk to aquatic communities than physical or chemical means. Indirectly there would be a beneficial impact from the improvement of invaded aquatic ecosystems. Michigan does not require a permit for use of bio-control agents to control aquatic plants such as Eurasian water milfoil and purple loosestrife (MI DEQ 2006b).

Cumulative Effects No measurable negative impacts exist to add cumulatively to past present or reasonably foreseeable actions in open/wet habitats. Overall, there would be a beneficial impact to RFSS from reduced negative effects of invasive plants. This control effort, if coordinated with state, county and

other landowners, would reduce or eradicate invasive plants. Failure of other landowners to control NNIP could counteract this somewhat.

RFSS Plants – Open / Dry and Beach Habitats

Habitat associations: The plants in the box on the left are found in a variety of open, sunny habitats (see Appendix A, Table 2). Most of them have only one or two RFSS occurrences on the HNF, but may be more widespread throughout their Canada milk-vetch range. Some, such as Richardson's sedge, prairie moonwort, prairie Cooper’s milk-vetch dropseed and Hill's thistle, favor calcareous limestone or alvar. Pine Richardson sedge barrens and dry prairie support Canada rice-grass, downy sunflower, Veiny meadow rue dwarf bilberry, foam lichen and ternate Invasive plants Blue wild-rye grapefern. Several species, such as long- Spathulate moonwort stalked stitchwort, blue wild-rye, and lake -Spotted knapweed Dune grass Huron tansy, require disturbance such as that -Diffuse knapweed Long-stalked stitchwort provided by shifting sand of dunes and -Canada thistle Prairie moonwort beaches. -Bull thistle Lake Huron tansy -Smooth brome Black crowberry -Crown vetch Canada rice-grass Threats by NNIP: The NNIP on the right prefer -Common tansy Downy sunflower full sunlight and do not survive well under a -Giant hogweed Dwarf bilberry forest canopy. They are aggressive, produce -White sweet clover Pale moonwort many seeds, and reproduce abundantly. Many -Yellow sweet clover Foam lichen of them produce seeds carried by wind so they -Leafy spurge Ternate grapefern can colonize an area some distance from the -Hound's tongue Prairie dropseed parent plants. Seed can also be transported -Wild parsnip Michigan moonwort on vehicles, clothing and animal fur. A -Common St. Johns-wort Plains Ragwort possible threat in dune habitats is NNIP might -Common burdock LRFSS -Scotch pine Northern reed-grass stabilize the dunes, allowing other plants to Hill's thistle colonize, thus out-competing the RFSS (USDA Rock witlow-grass 2006b). Cladonia wainoi lichen Forest Plan Direction Specific to Dwarf bilberry: Guideline 1. Bacillus thuringiensis (BT) should not be sprayed in the vicinity of dwarf bilberry populations due to the host relationship with northern blue butterfly. (Note: BT is a naturally-occurring bacterium that specifically targets lepidopteran insect pests, such as gypsy moth.). Goals: 2800 Minerals and Geology 4.Non-native invasive species are controlled in gravel pits.

Analysis of Effects - Open/Dry and Beach Habitats - from Alternative 1 (No-Change)

Direct and Indirect Effects

There will be no additional NNIP control under the No-Change alternative so there would be no direct impacts. Indirectly, over time, the unchecked expansion of NNIP populations as stated in the Forest Plan, could negatively affect dune, alvar, and beach plants through shading, nutrient use, or dune stabilization. Since Forest Plan direction states that NNIP within element occurrences of RFSS should be eliminated or controlled, we assume some treatment would be accomplished. However, due to the limited treatment acres likely to occur, and the reliance on manual control, some infestations may spread and new infestations might occur, increasing the risk to this group in the future.

Cumulative Effects Alternative 1 would have no direct effects to add cumulatively to other actions. There would be no widespread efforts to control NNIP under Alternative 1, although we assume some treatments would occur. Combined with failure of some land managers to control them could indirectly result in increasing regional dominance of invasive plants and future adverse impacts on rare plants. However, this scenario would likely occur beyond the 5-year period of the NNIP Control EA. State DNR, watershed organizations, or others, such as hunting groups, may choose to control invasive plants in some locations, reducing the risks somewhat. Control efforts by some adjacent landowners could also slow the spread of NNIP that might affect species in this group.

Analysis of Effects - Open/Dry and Beach Habitats - from Alternative 2 (Proposed Action)

Direct and Indirect Effects Any direct adverse effects from proper implementation of control methods would be relatively small and temporary. Indirectly, the removal of NNIP populations would benefit these sand dune, alvar, and beach habitats and any RFSS populations by reducing competition in occupied or unoccupied habitats and by allowing the natural dune and beach successional processes to continue.

Mechanical or manual method of treatment - Direct impacts of manual and mechanical actions could include a slight risk of inadvertent trampling or cutting of individual RFSS plants. Design criteria (No. 9, p. 12) and protocol No. 4 (p. 10) would ensure that additional analysis by a botanist would occur before using manual or mechanical controls within shoreline, beach or dune habitats. Individuals conducting any treatment would be trained to recognize RFSS plants to prevent accidental digging or pulling when they occur near NNIP (design criteria 4, p. 12). Mowing or brush cutting would be used for the most part in highly disturbed areas such as roadsides where RFSS do not usually occur, so there would be no direct or indirect effect from this method.

Chemical Treatment - When using herbicide with a spray application method, there is a slight potential for contacting non-target species. This could result in injury or death of RFSS plants. Design criteria (Nos. 4 and 9) and protocol No. 8 (p. 11) would prevent the use of herbicides directly on RFSS. Furthermore, application sites are likely to be small, and therefore, spot spraying of herbicides could efficiently be used to treat NNIP occurrences, reducing risk to RFSS plants. Using the cautions in the project design, such as buffers (design criteria 11, p.13), and spot spraying (protocol No. 8, p. 11), herbicides can be applied selectively without damaging adjoining native vegetation. Both vascular plants and lichens are affected to some degree by herbicides. A broadleaf-selective herbicide (Table I-4) can be used that generally would not harm grasses, sedges, or rushes (SERA 2003b; 2004a; 2004b). Timing of application, as well as, concentration and exposure time can be manipulated to limit impact to non-target species. The HNF Forest Plan includes direction for implementing Michigan Water Quality Best Management Practices on Forest Land (MDNR 1994). Direction in this document reiterates closely following the label directions for safe application of chemicals (MDNR 1994, p. 30-31). Therefore, there would be minimal or no

direct or indirect effect from chemical treatment. The efficacy of chemical methods allows for more rapid indirect beneficial effect to species in this habitat group.

Biological Control - There would be no direct impact from this method. Insects proposed against spotted knapweed and leafy spurge (Table I-7) would not harm other organisms (OFAH 2003; APHIS 1994, p. 13). Three species of insect are proposed against purple loosestrife and one weevil for Eurasian water milfoil (Table I-7); they would not harm other organisms (OFAH 2003; Tu et al. 2001, p. 70). Controlling NNIP would remove the potential for competition and therefore have an indirect beneficial impact on open/dry and beach habitats.

Cumulative Effects No measurable negative impacts exist to add cumulatively to past present or reasonably foreseeable actions in open/dry and beach habitats. Any adverse effects of manual/mechanical or herbicide use would be small, temporary and very localized. Overall, there would be a beneficial effect to RFSS from reduced negative effects of invasive plants. This control effort coordinated with state, county and other landowners would reduce, control or eradicate invasive plants. Failure of other landowners to control NNIP could counteract this somewhat.

RFSS Plants – Shaded / Wet Habitats

Habitat associations: These RFSS Invasive plants RFSS plants require the lower light and Limestone oak fern higher moisture condition found in Round-leaved orchis -Glossy buckthorn White adder’s mouth older cedar swamp or hardwood -Exotic Honeysuckles Lapland buttercup swamp. However, some can grow in -Common burdock Frullania selwyniana lichen the partial shade of forest edges. Eastern candlewax lichen Auricled twayblade and spongy gourd moss grow on the edges of Spongy gourd moss streams under a canopy. Limestone oak fern requires calcareous Auricled twayblade soils as found in the Niagara Escarpment. There are no biological Calypso orchid control insects proposed for invasive plants in this type of habitat. Hudson Bay sedge Small firedot lichen Threats by NNIP: Shaded and wet habitats, such as cedar swamps, Ram’s head lady slipper hardwood swamp and stream banks within forests can be threatened Likely RFSS Schweinitz’s sedge by buckthorn and honeysuckle and burdock to a lesser degree. The shrubs can grow in sun or shade and can form dense thickets. Buckthorn leaf litter is high in nitrogen that increases microbial activity. The increase causes rapid decomposition of the litter layer, making it less favorable for native plant species adapted to thick humus (Heneghan 2006).

Forest Plan Direction specific to this habitat: Watershed Management Guideline: 1. Small forest seeps and springs should be protected from ground-disturbing activities (USDA 2006a, p. 2-14)

Analysis of Effects - Shaded/Wet Habitats - from Alternative 1 (No-Change)

Direct/Indirect Effects There would be no additional NNIP control under the No-Change alternative so there will be no direct impacts. The known RFSS sites would be monitored for invasive plants. Indirectly, the unchecked expansion of NNIP populations could negatively affect shaded/wet habitats through nutrient use, alteration of soil chemistry, or allelopathy. Since Forest Plan direction states that NNIP within element occurrences of RFSS should be eliminated or controlled, we assume some treatment would be accomplished. However, due to the limited treatment acres likely to occur, and the reliance on manual control, some infestations may spread and new infestations might occur, increasing the risk to this group in the future.

Analysis of Effects on - Shaded/Wet Habitats - from Alternative 2 (Proposed Action)

Direct and Indirect Effects Any direct adverse effects from proper implementation of control methods would be relatively small, temporary, and very localized due to current small infestation sizes. Since all NNIP sites would be surveyed by a botanist prior to treatment, RFSS plants can easily be avoided. Therefore, the risk of damage would be minimal and insignificant. Indirectly, the removal of NNIP populations would benefit shaded/wet habitats and any RFSS populations present there by preventing competition from NNIP.

Mechanical or manual method of treatment - Direct effects of manual and mechanical actions could include a slight risk of inadvertently pulling up an individual RFSS plant while prying out a larger invasive. Alternative methods would be used in close proximity to RFSS. Design criteria (Nos. 4 and 9, p. 12) and protocol No. 4 (p. 10) would ensure that additional analysis by a botanist would occur before using manual or mechanical controls within shaded/wet habitats. Individuals conducting any treatment would be trained to recognize RFSS plants to prevent accidental digging or pulling when they occur near NNIP (design criteria 4, p. 12).

Chemical Treatment - When using herbicide with a spray application method, there is a slight potential for contacting non-target species. This could result in injury or death of RFSS plants. The most effective method to treat non-native shrubs is not to spray but treat the stump or basal bark with the chemical. Burdock has easy to distinguish leaves that could be spot sprayed. These actions are very targeted and the risk to other plants is very low. Design criteria (Nos. 4 and 9) and protocol No. 8 (p. 11) would prevent the use of herbicides directly on RFSS. Furthermore, application sites are likely to be small, and therefore, spot spraying of herbicides could efficiently be used to treat NNIP occurrences, reducing risk to RFSS plants. Using the restrictions in the project design criteria, such as buffers (design criteria 11, p.13), and spot spraying (protocol No. 8, p. 11), herbicides can be applied selectively without damaging adjoining native vegetation. Timing of

application, as well as, concentration and exposure time can be manipulated to limit impact to non- target species. The HNF Forest Plan includes direction for implementing Michigan Water Quality Best Management Practices on Forest Land (MDNR 1994). Direction in this document reiterates closely following the label directions for safe application of chemicals (MDNR 1994, p. 30-31). Both vascular plants and lichens are affected to some degree by herbicides. A broadleaf-selective herbicide (Table I-4) can be used that generally would not harm grasses, sedges, or rushes (SERA 2003b; 2004a; 2004b). Overall, there would be minimal or no direct or indirect effect from chemical treatment. The efficacy of chemical methods allows for more rapid indirect beneficial effects to species in this habitat group.

Biological Control - There would be no direct impact from this method. None of the biological control insects in Table I-7 above have target NNIP that grow in shaded/wet conditions.

Cumulative Effects No measurable negative impacts exist to add cumulatively to past present or reasonably foreseeable actions in shaded/wet habitats. Any adverse effects of manual/mechanical or herbicide use would be small, temporary and very localized. Overall, there would be a beneficial effect to RFSS from reduced negative effects of invasive plants. This control effort coordinated with state, county and other landowners would reduce, control or eradicate invasive plants. Failure of other landowners to control NNIP could counteract this somewhat.

RFSS Plants – Shaded Habitats

Habitat associations: This is a large, diverse group of RFSS RFSS plants, but all require shade and the higher moisture generally Little Georgia moss found under a canopy of trees. Many of these rare plants have Beauty sedge their home range farther north and occur here in Michigan at the Pine drops Laurentian bladder fern southern edge of where they can survive. These rare species vary Douglas’s Hawthorn in soil moisture and nutrient requirements, but the habitats are Northern three-lobed bedstraw potentially threatened by the same NNIP. The Niagara Goblin moonwort escarpment provides calcareous rock and soils where Laurentian Spreading wood fern bladderfern, slender cliffbrake and climbing fumitory reside. Male fern Schistostega moss and little Georgia moss grow in crevices of Northern wild licorice rock. Porthole and dotted line lichen are found on trees in mesic Butternut forest. Most of these RFSS have only a few known sites on the Slender cliff brake fern forest (see Appendix A, Table 2). There are no biological control Woodland cudweed insects proposed for the invasive plants that threaten this type of Small flowered wood rush Climbing fumitory habitat. Walking fern Schistostega moss Threats by NNIP: The non-native Invasive plants Blunt-lobed grapefern plants in the box are potential

New England sedge threats to shady habitats found -Common buckthorn Northern wild comfrey under the canopy of forest trees. -Glossy buckthorn Green spleenwort These exotics establish quite -Japanese barberry Porthole lichen readily in sun or shade. Buckthorn, -Garlic mustard Dotted line lichen honeysuckle, and garlic mustard -Exotic Honeysuckles Likely RFSS have chemical properties that can -Common burdock Purple clematis -Scotch pine Little shinleaf alter soil fungi and bacteria. This in

Large tooth-wort turn reduces tree productivity and Walking sedge makes the soil unfavorable for many native herbaceous plants Forked liverwort and germinating tree seedlings. In forest stands already impacted Felt lichen by exotic earthworms, invasion by NNIP is more likely and can Yellow speckleberry lichen compound the negative effects (Hale 2006). Methuselah’s beard lichen Forest Plan Direction specific to this habitat: Objective 2: In this planning period, establish at least one new population of Douglas hawthorn (USDA 2006a, p. 2-17). The Hiawatha has agreed to implement the Regional Conservation Approach written for Botrychium mormo (goblin moonwort) (USDA 2006a, p. 2-17; USDA 2002).

Analysis of Effects - Shaded Habitats- from Alternative 1 (No-Change)

Direct and Indirect Effects There would be no additional NNIP control under the No-Change alternative so there will be no direct impacts. The known RFSS sites would be monitored for NNIP. Indirectly, the unchecked expansion of NNIP populations could negatively affect shaded forest habitats through nutrient use, alteration of soil chemistry, or allelopathy. Since Forest Plan direction states that NNIP within element occurrences of RFSS should be eliminated or controlled, we assume some treatment would be accomplished. However, due to the limited treatment acres likely to occur, and the reliance on manual control, some infestations may spread and new infestations might occur, increasing the risk to this group in the future.

Cumulative Effects Alternative 1 would have no direct effects to add cumulatively to other actions. There would be no widespread efforts to control NNIP under Alternative 1, although we assume some treatments would occur. Combined with failure of some land managers to control them could indirectly result in increasing regional dominance of invasive plants and future adverse impacts on RFSS plants. However, this scenario would likely occur beyond the 5-year period of the NNIP Control EA. State DNR, watershed organizations, or others, such as hunting groups, may choose to control invasive plants in some locations, reducing the risks somewhat. Control efforts by some adjacent landowners could also slow the spread of NNIP that might affect species in this group.

Analysis of Effects - Shaded Habitats- from Alternative 2 (Proposed Action)

Mechanical or manual method of treatment - Direct effects of manual and mechanical actions could include a slight risk of inadvertently pulling up an individual RFSS plant while prying out a larger invasive. This could result in injury or death of RFSS plants. Alternative methods would be used in close proximity to RFSS. Design criteria (Nos. 4, and 9, p. 12) and protocol No. 4 (p. 10) would ensure that additional analysis by a botanist would occur before using manual or mechanical controls within shaded forest habitats. Individuals conducting any treatment would be trained to recognize RFSS plants to prevent accidental digging or pulling when they occur near NNIP (design criteria 4, p. 12). The flame of a weed torch used on garlic mustard or other NNIP could harm non- target plants if it touches them. The weed torch is most effective on garlic mustard and buckthorn sprouts in early spring while most native plants are still dormant so harm to RFSS is unlikely.

Chemical Treatment - When using herbicide with a spray application method, there is a slight potential for contacting non-target species. This could result in injury or death of RFSS plants. Both vascular plants and lichens are affected to some degree by herbicides. A broadleaf-selective herbicide (Table I-4) could be used to avoid harm to non-target grasses or sedges (SERA 2003b; 2004a; 2004b). The risk of inadvertently exposing non-target plants and soil to herbicide is low because we will make very targeted applications. Herbicide application on garlic mustard can be made in early spring prior to emergence of most native plants making it extremely unlikely it would affect non-target plants. The most effective method to treat non-native shrubs is not to spray but treat the stump or basal bark with the chemical. Burdock has easy to distinguish leaves that could be spot sprayed. These actions are very targeted and the risk to other plants is very low. Design criteria (pp. 12-13) and protocol No. 4 (p. 10) and No. 8 (p. 11) would help prevent the use of herbicides directly on RFSS. Furthermore, application sites are likely to be small, and therefore, spot spraying of herbicides could efficiently be used to treat NNIP occurrences, reducing risk to RFSS plants. Using the cautions in the project design, such as spot spraying (protocol No. 8, p. 11), herbicides can be applied selectively without damaging adjoining native vegetation. Timing of application, as well as, concentration and exposure time can be manipulated to limit impact to non- target species. The HNF Forest Plan includes direction for implementing Michigan Water Quality Best Management Practices on Forest Land (MDNR 1994). Direction in this document reiterates closely following the label directions for safe application of chemicals (MDNR 1994, p. 30-31). Both vascular plants and lichens are affected to some degree by herbicides. A broadleaf-selective herbicide (Table I-4) can be used that generally would not harm grasses, sedges, or rushes (SERA 2003b; 2004a; 2004b). Overall, there would be minimal or no direct or indirect effect from chemical

treatment. The efficacy of chemical methods allows for more rapid indirect beneficial effects to species in this habitat group.

Biological Control - There would be no direct impact from this method. None of the biological control insects in Table I-7 above have target NNIP that grow in forested conditions. The permit process for insects to control garlic mustard is being initiated in 2007 but insects may not be widely available in the next few years.

Cumulative Effects No measurable negative impacts to RFSS are anticipated to add to any impacts of past, present or reasonably foreseeable actions. Manual/mechanical control activities would have little or no incremental effect. Herbicide as used according to the design criteria would contribute insignificant adverse effect and consequently is not expected to result in substantial increase in adverse cumulative effects to non-target species. Overall, removing invasive plants from these shaded forest habitats will improve and protect habitat for sensitive species and provide a beneficial effect.

Animals RFSS Birds RFSS Birds American peregrine falcon Birds are the largest grouping of RFSS on the Forest. Seventeen Black-backed woodpecker bird species are included on the most recent list of RFSS for the HNF Black-crowned night-heron (USDA 2007). Four of the species (northern goshawk, peregrine Black tern falcon, red-shouldered hawk, and short-eared owl) are raptors (i.e. Caspian tern Common loon birds of prey) that feed on fish, small mammals, or other birds. Eight Common tern of the species (black tern, yellow rail, trumpeter swan, common loon, Connecticut warbler black-crowned night-heron, Caspian tern, common tern and Le Le Conte’s sparrow Conte’s sparrow) are associated with wetlands. Grasslands, barrens Migrant loggerhead shrike and shrub cover constitute habitat for three species (sharp-tailed Northern goshawk grouse, prairie warbler and migrant loggerhead shrike). The final two Prairie warbler species, Connecticut warbler, and black-backed woodpecker, have Red-shouldered hawk habitat requirements not readily fitting into any of the groups. Sharp-tailed grouse Separate effects discussions are provided for raptors, wetland birds, Short-eared owl grassland/shrub birds, Connecticut warbler and black-backed Trumpeter swan Yellow rail woodpecker.

Raptors Descriptions of all RFSS raptor species on the HNF are provided first, followed by potential effects from each of the two proposed alternatives. Threats by NNIP: At present, there are no specific NNIP concerns related to this species group or their habitats. Most of the NNIP infestations occur in disturbed sites (e.g. roadsides, skid trails, parking areas and utility corridors) (USDA 2006d, p. 3-66).

Northern Goshawk (Accipiter gentilis) The northern goshawk is an aggressive, area-sensitive raptor that can be found in a variety of forest types, such as coniferous stands, deciduous stands, mixed stands, riverine forests, and conifer plantations. The species prefers large tracts of forest with an intermediate amount of canopy closure, relatively free of dense understory, which allows them to maneuver in and below the canopy. In addition to forest cover, habitat features important to goshawks include habitat for prey species. The diet of goshawks consists of moderate sized birds and mammals with ruffed grouse, snowshoe hare and red squirrel common prey species in the Great Lakes states (USDA 2006b, pp. 63-64). The primary threat to this species in Michigan is habitat alteration and destruction due to timber harvest, road construction, and residential development. Habitat manipulation directly impacts the species by alteration of suitable structure around the nest site and indirectly by influencing the abundance, distribution, and vulnerability of prey species. Fragmentation of mature forest stands and the creation of larger openings favor the immigration of nest competitors and predators such as the red-tailed hawk (Buteo jamaicensis) and great-horned owl (Bubo virginianus). Standard HNF nest protection measures (Piehler 2006) are available in the project folder and apply to all existing and future northern goshawk or red-shouldered hawk nests within the project area (USDA 2006b, pp. 63-64).

Peregrine Falcon (Falco peregrinus)

Peregrine falcons were formerly listed under the federal Endangered Species Act, but were de- listed in 1999. The restoration of the peregrine falcon in North America has been one of the most extensive and successful of all endangered species programs. Population growth has continued since delisting. Peregrines nest on rock cliffs, bluffs and vertical escarpments, ranging in elevation from small rock outcrops to 200 feet in elevation above the surrounding terrain and use rock formations as small as a single rock outcrop to cliffs over 500 feet long (USFWS, 1979). Nests are commonly placed on ledges or cavities on a cliff face or escarpment and consist of a shallow scrape in soil or other loose material. The cliff faces chosen usually have a commanding view of the surrounding countryside and are often located over or close to lakes or rivers. Suitable habitat is very limited on the HNF. However, in 1999, peregrine falcons nested successfully at two U.P. locations, one on the HNF at Grand Island. Nesting has occurred primarily on the northwest and northeastern areas of the Island, where the cliffs are at their greatest heights. Nest sites are frequently near open habitats, such as wetlands or riparian zones, which concentrate small birds or other prey, and offer good open-air hunting. Peregrines feed primarily on other birds. Vertebrates that constitute food items might include robins, doves, jays, northern flickers, gulls and some species of shorebird, fish and at times small mammals. Risks to the species include human disturbance and loss of habitat. (USDA 2006b, pp. 22-23)

Red-Shouldered Hawk (Buteo lineatus) The distribution of breeding red-shouldered hawks has apparently shifted from their historical range in the southern Lower Peninsula to their present concentration in the northern Lower Peninsula. There is a limited population in the Upper Peninsula. The red-shouldered hawk is migratory along the northern edge of its range and generally returns to Michigan in late February to early March, moving north with the retreating snow. In Michigan, red-shouldered hawks utilize mature forested floodplain habitat. However, the majority of nests in Michigan have been found in large (usually >300 acres.), relatively mature deciduous or mixed forest complexes (medium to well-stocked pole or saw timber stands) (USDA 2006b, pp. 92-93). Typically, these forest complexes have wetland habitats nearby or wetlands interspersed among these forested habitats. Wetland areas, such as beaver ponds, wet meadows and lowland forests, are used primarily for foraging purposes. Nest sites tend to be located in dense stands of timber with a closed canopy structure and near wetland habitat (typically within 1/8 mile). The most commonly cited risk for this species is loss of nesting habitat across eastern and central North America. Fragmentation of mature forest stands and the creation of larger openings favor the immigration of nest competitors and predators such as the red- tailed hawk and great-horned owl. Standard HNF nest protection measures (Piehler 2006) are available in the project folder and apply to all existing and future northern goshawk or red- shouldered hawk nests within the project area.

Short-eared Owl (Asio flammeus) The short-eared owl is a migratory species in the Upper Peninsula. Short-eared owls require large (typically > 250 ac) open grassland or emergent wetland habitats such as prairie, hayfields, fallow fields, small grain stubble, and marshes for breeding habitat. However, smaller grassland/wetland fragments, as small as 75 ac., can be utilized. Nest sites are placed on the ground and consist of a bowl-shaped depression. Their diet is primarily composed of small mammals, particularly voles, with smaller percentages of the diet encompassing various openland/wetland bird species. The primary threat to this species in Michigan is alteration and destruction of habitat due to development, intensive agriculture, and successional changes. Habitat manipulation and destruction directly impacts the species by alteration of suitable nesting habitat, and indirectly, by influencing abundance, distribution, and vulnerability of prey species. Fragmented openland habitats increase the likelihood of nest destruction from predators, such as skunks, raccoons, foxes, and coyotes. (USDA 2006b, pp. 107-108)

Forest Plan Direction specific to RFSS Raptors and this project Guideline: American Peregrine Falcon – Design management activities to protect active and historic nest sites and to minimize disturbance in the primary and secondary zones (USDA 2006a, p. 2-18) Guideline: Northern Goshawk and Red-shouldered Hawk – Best available science recognized by Forest biologists, should be used to protect active and historic breeding territories, nesting areas and post-fledging habitat. (USDA 2006a, p. 2-19) Guideline: Non-native invasive plants within element occurrences of threatened and endangered and Regional Forester Sensitive Species should be eliminated or controlled. (USDA 2006a, p. 2-17) Guideline: Adverse impacts to known occurrences of Regional Forester Sensitive Species should be avoided, minimized or mitigated. (USDA 2006a, p. 2-17)

Analysis of Effects – Raptors – Alternative 1 (No-Change)

Direct and Indirect Effects Implementing Alternative 1 would have no impacts on the RFSS raptors on the HNF over the period covered by this EA. Some NNIP sites identified would be allowed to persist or increase in size. However, we know of no RFSS raptor nesting or foraging areas currently being adversely affected or suspected to be in future danger by NNIP infestations. We anticipate the spread of NNIP into raptor habitat would be patchy over the 5-year period of this EA, and have no effect on habitat for species in this group. The Forest would likely continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical means only, using individual project decisions not associated with this EA. This, however, would likely have no impact on RFSS raptors over the 5- year period of the NNIP project EA. Due to Forest Plan management direction, we anticipate that a high priority would be placed on eradicating infestations with potential to adversely affect RFSS should such circumstances develop on the HNF. Consequently, there would be no effect to species in this group from implementing Alternative 1.

Cumulative Effects Because there are no direct or indirect effects on RFSS raptors associated with Alternative 1, there would be no cumulative effects to combine with the effects of past, present, or reasonably foreseeable future activities in the project area.

Analysis of Effects – Raptors – Alternative 2 (Proposed Action)

Direct and Indirect Effects Mechanical or manual method of treatment - Noise from manual and mechanical treatments, such as use of the weed torch, brush cutter and saw in the immediate vicinity of nesting sites could possibly disturb raptors. Disturbances would be brief, occur generally once and be localized in impacts. However, there is a slight chance that brief periods of high noise very close to nests could possibly result in nest abandonment. While the risk is considered to be very low due to the small acreage of treatment anticipated, NNIP control would not be conducted within 650 feet of a known RFSS raptor sites during the breeding season (design criteria Nos. 7 and 8, p. 12). These protections would be implemented for the five-year duration of the project. Human disturbance in raptor foraging habitat would be minimal because most applications would not require the use of motorized equipment. There may be some increase in noise and movement in proximity to some areas of suitable habitat, but these impacts would be of short duration, temporary and localized. Northern goshawks and red-shouldered hawks nest in large trees. No such trees would be felled or subject to physical damage in this alternative. Invasive understory, such as buckthorns and honeysuckle, would be cut, grubbed, burned using the weed torch, and/or sprayed manually in forested areas without disturbance to overstory trees.

Chemical Treatment - The data summarized in Table E-1, E-2 and E-3 suggest that the herbicides proposed for use in raptor habitats are not hazardous to mammals and birds or to the fish species that form the primary prey of RFSS raptor species on the HNF. Northern goshawk, red-shouldered hawk and peregrine falcon do not spend much time on or near the ground. Thus, they are very unlikely to experience direct contact with chemical sprays. For the short-eared owl, a species found in open habitat and at ground level more often than the other raptors, direct contact is also unlikely, since the bird would leave the area during treatment. Furthermore, spraying would occur in such small areas of available habitat as to represent minimal risk for the species. For all RFSS raptors, herbicide control would not be used within 650 feet of a known RFSS raptor sites during the breeding season (design criteria Nos. 7 and 8, p. 12).

Ecological risk assessments conducted for several of the proposed herbicides; including glyphosate, imazapic, triclopyr, clopyralid, and dicamba; suggest that use of the studied herbicides at rates commonly used by the Forest Service poses little or no risk to birds (Table E-2 and Table E-3). Refer to the effects analysis for bald eagle in this BE (pp. 45-46) for more information regarding the evaluation of chemicals proposed for use. None of the proposed herbicides are related to carbamate and organophosphate insecticides, which inhibit cholinesterase enzymes and have been known to cause bird mortality. None of the herbicides we propose to use contain chemicals such as DDT, a class of chemical that are implicated in causing raptor egg-shell thinning. Considering protections and the small acreage anticipated in proximity to wetlands, no adverse impacts to RFSS raptors are expected from use of listed chemicals.

Biological Control - Insects used as biological control agents (Table I-7) are neither competitors nor prey of RFSS raptors on the Forest. Furthermore, the abundance or absence of these agents would have no effect on the specified raptors. None of the proposed biological control agents target canopy tree species used as nests or roosts for raptors. Each of the biological control agents encompassed under this proposal have a record of successful and safe application within Midwestern areas similar to that of the HNF. Therefore, use of biological controls would pose no detrimental impacts to these raptors.

All NNIP Control Methods - For all treatment methods, manual/mechanical, chemical and biological, the low level of vegetation change from NNIP treatments in occupied or suitable habitat would have no detectable impact on HNF raptors. None of the RFSS raptors utilizes any of the NNIP species or the plant species that they displace. The 200-acre, annual maximum for NNIP control is for the Forest, across all areas. We anticipate that the majority of the treatments would occur in upland, disturbed areas, such as roadsides, temporary roads, and parking areas, rather than in habitats used by RFSS raptors. Nesting areas would be protected with buffers (criteria Nos. 7 and 8). General design criteria (Nos. 1, 2, 3, and 5, p. 12) and protocol No. 4, p. 10, would provide additional protections for the species in this group. The criteria require that a variety of protections be met, such as designing treatments to ensure RFSS are not harmed, stopping and reviewing treatments if RFSS are observed, and surveying suitable prior to treatment. Over the period anticipated for control under this EA, there would likely be minimal benefits afforded to RFSS raptors from the decrease in NNIP, primarily because infested areas constitute a small portion of the available habitat. However, benefits would accrue over a longer period of NNIP control, since spread of NNIP would be controlled and larger areas of suitable habitat would remain free of NNIP. The result is expected to be a more diverse vegetative community on the Forest, a condition that theoretically would maintain and enhance food and cover for raptor prey species, and ultimately raptors themselves. The USFWS reached a similar conclusion for bald eagle (USFWS 2006, 232 and Appendix K). It would be reasonable to extend the assessments of benefits to other large raptors using the HNF. For RFSS raptors, Alternative 2 would be more beneficial than Alternative 1

because it has a greater annual NNIP treatment threshold, possibly achieving control over a shorter period. Alternative 2 provides the ability to use three methods to control infestations, giving managers more options to design treatments that optimize control of NNIP and minimize effects to RFSS. Thus, the risks of NNIP treatments would be low, and there would be minimal adverse effects on species in this group.

Summary – Direct and Indirect Effects – Alternative 2 Considering the protocols, design criteria and small magnitude of anticipated impacts, any response by RFSS raptors from exposure to project activities would be minimal. Over the period anticipated for control under this EA, there would be minimal beneficial impacts afforded to RFSS raptors from the decrease in NNIP. However, over a longer period of NNIP control, Alternative 2 would be more effective than Alternative 1 at controlling infestations for RFSS raptors.

Cumulative Effects We consider the effects of Alternative 2 would be minimal and insignificant. Consequently, they would have little or no incremental effect when combined with the effects of past, present, or reasonably foreseeable future activities.

Determination Alternative 1 – No impact Alternative 2 – May impact individuals; not likely to cause trend to listing or loss of viability

Wetland Birds

Descriptions of RFSS birds with wetlands or other aquatic area as a primary component of their habitats on the HNF are provided first, then followed by potential effects from each of the two proposed alternatives.

Threats by NNIP: At present, there are no specific NNIP concerns related to this species group or their habitats. Most of the NNIP infestations occur in disturbed sites (e.g. roadsides, skid trails, parking areas and utility corridors) (USDA 2006d, p. 3-66). There are three NNIP species identified as primary invaders of this habitat, including Eurasian water milfoil, purple loosestrife and reed canary grass. Purple loosestrife has been identified at 27 sites on the HNF, encompassing approximately 30 acres.

Black Tern (Chlidonias niger) In Michigan, black terns typically arrive in late April or early May. Breeding occurs in freshwater marshes and wet meadows, with prime habitat consisting of dense emergent vegetation surrounding small pools. They are semi-colonial birds and prefer relatively large wetlands. However smaller wetlands, which are part of a larger wetland complex, can be used. Both sexes build the nest, which consists of either a heap of floating vegetation in water anchored by growing plants, or on mats of floating aquatic vegetation or piles of fallen herbage (e.g. old muskrat houses, old grebe/coot nests, or floating wood). In northern Michigan, peak egg laying occurs in late May and early June. Primary foods are insects and fish. Black terns are present on the HNF during the breeding season. Breeding Bird Atlas records for the black tern indicated confirmed breeding for 4

townships, probable for 6 townships, and possible for 3 townships that the encompass the HNF (USDA 2006b, p. 40-41). At present, there are no specific NNIP concerns related to this species or its habitat.

Yellow Rail (Coturnicops noveboracensis) Yellow rails typically arrive in Seney NWR during the last week of April or first week of May. Pair formation probably occurs on breeding grounds. The species breeds in open bog and sedge meadow heavily dominated by Carex lasiocarpa, a tall mat-forming sedge. Some consider this species a semi-colonial nester, since it is more typical to find groups of birds nesting together than it is to find single pairs. The nest is a thick cup of woven fine grasses and sedges concealed in a natural hollow and covered with a canopy of dead vegetation. Average clutch size is 8 with a range of 5-10. Incubation is by the female alone and lasts for 16-18 days. The male may remain near the nest during incubation. Primary foods taken include small snails (most important), aquatic insects, and seeds. Yellow rails depart Minnesota and Michigan in September, with Michigan birds passing through the Lower Peninsula into late October. Although the species is widely distributed in North America during the breeding season, its presence is local. Historical and current abundance in Michigan is not well known. The species is probably more common and widespread historically than the few records indicate, due to the yellow rail's secretive nature and infrequently visited habitat. The yellow rail has always had a widely scattered and poorly known distribution in Michigan, with few confirmed breeding records. Loss of wetlands due to human activity is probably the most important factor affecting yellow rail populations range-wide. However, federal and state agencies and private landowner’s protect the few known breeding sites in Michigan. The encroachment of woody vegetation into known breeding sites reduces suitability for yellow rails, so management may be required (i.e. burning, water level management, etc) to maintain these sites. Invasive plants such as purple loosestrife may also pose a threat to yellow rail habitats. However, no known or suspected breeding habitats on the Forest are threatened by NNIP. (USDA 2006b, pp. 114-115)

Le Conte’s Sparrow (Ammodramus leconteii) The species is a breeding season resident in Michigan (NatureServe 2006, Brewer et al. 1991). Habitat for Le Conte’s sparrow is typically emergent wetlands of sedges and rushes. Nests usually are found on the edge of large areas of sedge, grass and rush. The species appears to select for dense litter in which to locate nests. In Michigan and neighboring Minnesota, Le Conte’s sparrows prefer areas free of shrubs and other woody vegetation. Adults feed on insects and forb and grass seeds. Insects comprise the entire diet of nestlings (NatureServe 2006). Brewer et al. (1991) includes confirmed breeding in three counties, including Chippewa, Schoolcraft and Keweenaw.

Trumpeter Swan (Cygnus buccinator) Once confined mainly to Alaska, western Canada, and Red Rock Lakes National Wildlife Refuge in Montana, this species has made a remarkable recovery due to restoration programs. In Michigan, such a program was conducted on the HNF in 1991 with the release of six juvenile swans on Grassy Lake in Schoolcraft County. Since the time of the reintroduction, the swans have done well on the Forest. Trumpeter swans use small lakes and ponds for foraging and resting. Nests are large masses of vegetation, up to 18 inches in height and a diameter of 6 to 9 feet, often placed on an island or muskrat or beaver lodge. They mainly feed on submerged and emergent aquatic vegetation, although they may include a small percentage of invertebrates in their diet. Large areas with shallow water and emergent vegetation comprise the optimal feeding habitat. During the winter months, they may feed on crops grasses, or supplemental feed of wheat, corn, and commercial poultry food. Depending on the population, trumpeter swans may migrate long distances, migrate locally, or not migrate at all. Midwestern and reestablished populations tend to be locally migrant or non-migratory, as long as open water is available. Those that do migrate typically leave mid- October to late-November as the water begins to freeze. Arrival on the breeding grounds usually

occurs in April, before the ice clears from the water. Non-breeding flocks may occur on large lakes and reservoirs in the summer. (USDA 2006b, pp. 110-112)

Common Loon (Gavia immer) Common loons usually arrive in Michigan as soon as ice on inland lakes melts, which usually equates to late March and April. Breeding habitat generally consists of lakes (ranging from 4 ha to thousands of hectares in area), having a reasonable abundance of fish, a large proportion of shoreline unoccupied by humans, a small island or bog mat for nesting, and freedom from disturbance. Nest building occurs in May and June by both sexes and eggs are laid soon after completion. Nest sites are typically located on raised ground at the water's edge, usually on a bare high point, island or small island mound, and rarely at the edge of a marsh or on a muskrat house or mass of floating vegetation. The nest consists of a slight hollow scrape with little nest material, or occasionally a large heap of vegetation in marshy areas. Incubation is done by both parents and lasts an average of 28 days. Both parents tend young, which are semi-precocial and dependent on parents for food. Young may ride on parents' backs during first 2 to 3 weeks, are able to feed themselves at about 8 weeks, and fledge between 11 and 13 weeks. Primary food is live fish. Peak of southward migration occurs in September and thousands of common loons use the Great Lakes as a stopover in October and November. The oldest banded common loon recovered was 7 years 10 months. Forty-nine of the 62 occurrences known for the forest have been observed since 1990. Occurrences consisted of a breeding pair at minimal, and often a nest or flightless young. The Michigan Breeding Bird Atlas (1983-1988) confirmed breeding in 20 townships, observed probable breeding in 7 townships, and recorded possible breeding evidence in 9 townships that overlap with the Forest boundaries.(USDA 2006b, pp. 47-48)

Black-crowned night heron (Nycticorax nycticorax) The black-crowned night heron is medium-sized wading bird that is a migrant and a non-migrant in different parts of its range. Michigan birds are migrant, arriving in April and leaving again in September or October. The species is a colonial nester. Habitats consist of a variety of wetland and riparian types including swamps, streams, rivers, ponds, lakes, lagoons, pool margins, reservoirs, wet agricultural fields and tidal marshes. Territories are established near marshes, lakes, wooded streams. All the confirmed nesting sites of this species in Michigan have been along Great Lakes shoreline. Nests are constructed of sticks in shrubs and small trees 2 to 6 meters in height. They are crepuscular or nocturnal feeders (immature birds may feed by day), preying mostly on fish but also insects, amphibians, eggs, young birds, small mammals. This heron’s farthest northward limit is currently two colonies near the Straits of Mackinac, and a confirmed nest in Delta County along the Lake Michigan shoreline near Gladstone. Michigan birds show a preference for islands where there are fewer disturbances to nesting areas. Sensitive to disturbance, degradation and habitat destruction, especially during and before egg laying. (USDA 2006b, pp. 37-38)

Caspian Tern (Sterna caspia) Caspian terns breed in wetland-open water habitats, and unvegetated islands appear to be preferred. They usually return to the general area of hatching, but first-time breeders tend to nest at other colonies. They can nest singly, but typically are in colonies consisting of several hundred or several thousand pairs. Eggs are laid in a shallow depression (scrape) in the ground on open pebbly or sandy beaches or in nests lined with grasses, seaweeds, or mosses. The nest is frequently within a few feet of its neighbor’s nest. Clutch size is 1-4, laid from May to July, and both sexes incubate for 20-22 days. One brood is produced per year, and both parents tend the young. The diet of Caspian tern is almost exclusively fish with lesser quantities of aquatic invertebrates. Two species of introduced fish, the alewife and American smelt, are important prey for Caspian terns in the Great Lakes. Foraging habitat may be almost any large body of water. Since 1960, numbers have more than tripled, possibly in response to large increases in alewives and smelt.

Caspian terns in the area of the HNF are incurring increased predation risks from high gull and cormorant populations. On the west side, there are no data confirming breeding on forest shoreline, but it is presumed to occur. On the east side, 1 or 2 occurrences have been reported, on habitat within a cRNA. Overall, the birds are rare on the Hiawatha. Caspian terns are threatened by interactions with other species through predation, competition, and nest parasitism. They are also threatened by human presence that results in trampling of plants or disruption of activity. (USDA 2006b, pp. 43-44)

Common Tern (Sterna hirundo) Common terns arrive in Michigan in early May. Nesting usually begins soon after arrival. Common tern colonies occur on sparsely vegetated sand and gravel beaches of islands and peninsulas, and are also known to use artificial islands created from dredged material and abandoned wooden piers. The species breeds in colonies, typically with tens or hundreds of pairs, which allows for cooperative defense against competitors and predators. A common tern nest consists of a hollow that is unlined or variably lined with nearby plant material and odd feathers. Nest building is usually started by the male as a form of territorial advertising and is then finished by the female. The female does most of the brooding and both parents feed the young. Primary food is small fish between 1 and 3 inches long. Fall migration occurs in Michigan from late August through October. Four element occurrences are known from the HNF. One occurrence is from the East Unit on the shore of Pointe aux Chenes Bay. An occurrence is also known just outside of the East Unit boundary from Naomikong Island. Three records occur in the Westside of the Forest: 1) peninsula point (last observed in 1985); 2) Sand Bay (last observed in 1996); and 3) St. Vital Island (last observed in 1985). Common terns were observed in 11 townships that overlap with the forest during breeding bird atlas surveys. Two of these townships were in the West Unit, while the remaining 9 were in the East Unit. Breeding was confirmed in 6 townships (2 in West Unit), 1 township had probable breeding, and 4 townships had possible breeding evidence. All but one of these townships was located along the Lake Michigan and Superior shorelines. Two occurrences from Mackinac County were noted in the USFS Conservation Assessment; however, no information about these records was provided. Displacement of common terns from nesting sites and predation by herring and ring- billed gulls is a primary limiting factor. A variety of mammalian, avian, and reptilian predators can also impact reproductive success. Shoreline and island development can destroy nesting habitat and increase human disturbance (e.g. beach users and off-road vehicles). Common tern nesting sites are vulnerable to water level fluctuations, both long-term changes in Great Lakes levels and extreme flooding caused by storms. (USDA 2006b, pp. 55-56)

Forest Plan Direction specific to RFSS Wetland birds and this project Guideline: Black Tern, Common Loon and Trumpeter Swan – Inland lakes should have seasonal restrictions to protect active black tern, loon and trumpeter swan nests. (USDA 2006a, p. 2-18) Guideline: Yellow rail – Graminoid/sedge marshes are maintained or improved to provide suitable habitat conditions. (USDA 2006a, p. 2-18) Guideline: Non-native invasive plants within element occurrences of threatened and endangered and Regional Forester Sensitive Species should be eliminated or controlled. (USDA 2006a, p. 2-17) Guideline: Adverse impacts to known occurrences of Regional Forester Sensitive Species should be avoided, minimized or mitigated. (USDA 2006a, p. 2-17) Guideline: The state of Michigan “Water Quality Management Practices on Forest Land” (BMPs) should be implemented as a minimum standard for managing forest resources on Forest System land. (USDA 2006a, p. 2-14)

Analysis of Effects – Wetland Birds – Alternative 1 (No-Change)

Direct and Indirect Effects

Implementing Alternative 1 would have no adverse effects on RFSS species in this group over the period covered by this EA. The HNF would likely continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical means only, using individual project decisions not associated with this EA. Some NNIP sites would be allowed to persist or increase in size under Alternative 1. However, no sites of importance to the species in this group have been identified as currently being adversely affected by NNIP infestations. There are no known sites in imminent danger of future infestations that would result in adverse impacts to the species. We anticipate the spread of NNIP would be patchy over the 5-year period of this EA and have no effect on habitat for species in this group. Due to Forest Plan management direction, we anticipate that it is likely a high priority would be placed on eradicating infestations with potential to adversely affect RFSS should such a circumstance develop on the Forest. Consequently, there would be no impacts to species in this group from implementing Alternative 1.

Cumulative Effects Because there are no direct or indirect effects on the wetland birds group associated with Alternative 1, there would be no cumulative effects to combine with the effects of past, present, or reasonably foreseeable future activities in the project area.

Analysis of Effects – Wetland Birds – Alternative 2 (Proposed Action)

Direct and Indirect Effects Mechanical or manual method of treatment – Under Alternative 2, there would be a potential for a greater level of NNIP control activities than under Alternative 1. Even at the maximum of 200 acres, annually, across the HNF, there would be minimal impacts expected. Manual and mechanical treatments of aquatic species, such as Eurasian water milfoil, or emergent species, such as purple loosestrife, could temporarily create disturbance in nesting habitat for these species. Noise from manual and mechanical treatments, such as use of the weed torch, brush cutter and saw in the immediate vicinity of breeding and foraging sites could cause birds to temporarily leave the area, but is unlikely to cause nest abandonment or anything more that a brief change in activity.

Chemical Treatment - Only herbicide formulations labeled for use in aquatic habitats would be used in wetlands, including the habitats potentially used by our RFSS wetland birds (protocol 8, p. 11 and design criteria No. 11, p. 13). The herbicides most likely to be used include glyphosate and triclopyr. The data summarized in Table E-2 and Table E-3 indicate that glyphosate (Rodeo formulation) and triclopyr (triethylamine salt formulation) pose little risk to avian (bird) receptors or to invertebrates that constitute prey for many species in this group. Ecological risk assessments conducted for those herbicides suggest that use at rates commonly used by the Forest Service pose little or no risk to birds (Table E-3), including all of the species included in the wetland group. Furthermore, direct contact of any RFSS bird species in the wetland group by herbicides is unlikely, as the birds would likely vacate the treated area while human activity is ongoing. Most birds in this group feed on aquatic invertebrates and fish and would not be feeding directly on any treated foliage. The trumpeter swan feeds on submerged and emergent vegetation, but would not likely feed on treated vegetation or in the stages of wilt from treatment. In the unlikely event treated vegetation was consumed it would pose no risk to individual swans because the chemicals approved for use in and near water are essentially non-toxic to birds (Table E-2 and Table E-3). Additionally, treated foliage is expected to represent only a very small proportion (if any at all) of any individual’s diet over a very brief period, an occurrence that further minimizes the risk. LeConte’s sparrows have a diet that includes seeds and forbs. There is a potential for this species to consume seeds that might have been treated. Since Le Conte’s sparrows are not known to favor the NNIP proposed to be targeted (Table I-1), it is unlikely they would consume treated seeds or other vegetative parts. The risk assessment for glyphosate (Table E-3) concludes that small birds

who consume insects from areas treated with the maximum application rate for an extended period of time could experience adverse effects (USDA Forest Service 2003a). However, we consider that to be an unlikely scenario for the HNF due to the location of most treatments sites outside of habitat for Le Conte’s sparrow, and the protections in protocols and design criteria (pp. 10-14). It is also likely that the small acreages to be treated would be accomplished at the noted average rates for Forest Service projects that pose little risk, rather than the maximum rates for these products. Project protocol directs that spot treatments be employed, rather than broadcast applications (protocol No. 8, p. 11). This measure further reduce the risk to this group of species. Design criteria No. 11 would provide protection for this group of species with the minimum 100-foot buffer upland buffer around all wet areas, inside of which only herbicides with label approved aquatic use could be applied. Due to the emphasis on spot spray, rather than broadcast spraying, treated foliage and seeds would represent only a very small proportion of any individual’s diet over a very brief time. Thus, overall, it would be very unlikely for the aquatic formulations of the herbicides we have proposed to cause adverse impacts to this group of birds.

Equipment used to apply herbicides could cause temporary disturbances, similar to those mentioned for manual treatments. However, these impacts would be of short duration (typically measured in minutes or hours) and localized (most less than ¼ acre). This could cause birds to leave a treatment area temporarily, but is unlikely to cause nest abandonment or anything more that a brief change in activity.

Biological Control - Insects used as biological control agents (Table I-7) are neither competitors nor prey of RFSS wetland birds on the Forest. Furthermore, the abundance or absence of these agents would have no effect on the specified birds in this group. Each of the biological control agents encompassed under this proposal have a record of successful and safe application within Midwestern areas similar to that of the HNF. Biological control agents targeting purple loosestrife or Eurasian water milfoil (i.e. NNIP expected in this group’s habitat) would be released at the edges of wetlands used as habitat by RFSS, eliminating human disturbance within habitat. Therefore, use of biological controls would not pose detrimental impacts on this group of species.

All NNIP Control Methods - For all treatment methods, manual/mechanical, chemical and biological, the low level of vegetation change anticipated because of NNIP treatments would have no detectable impact on wetland birds. We anticipate that over the 5-year period of this project, most of the treatments would occur in upland, disturbed areas, such as roadsides, temporary roads, and parking areas, rather than in habitats used by RFSS wetland birds. Thus, the risks of NNIP treatments would be low. Because all proposed treatments for areas likely to be used by these species must be reviewed by a wildlife biologist (protocol 4, p. 10), the potential for adverse impacts to nests or individuals would be very low. In the event NNIP treatment were proposed on a lake with a black tern or trumpeter swan nest present, it would be necessary to avoid working in the immediate vicinity of the nests (see design criteria No. 16 and No. 17, p. 13). Design criteria Nos. 1, 2, 3, 5, and 10 on p. 12, and protocol No. 4, p. 10 would protect these species and others in this group. The criteria require that a variety of protections be met, such as avoiding known nesting areas during any treatments and checking for presence of RFSS birds in wetlands prior to initiating treatments in potential habitat. Over the period anticipated for control under this EA, there would be small beneficial impacts afforded to RFSS wetland birds from NNIP control activities. This would be expected to occur over time as control activities slow or stop the spread of NNIP into areas not currently infested. However, over a longer period of NNIP control, the result is expected to be a more diverse vegetative community on the Forest, a condition that theoretically could provide improved food and cover for this species. Alternative 2 would theoretically provide a greater level of benefits than Alternative 1 due to the greater treatment acreage. In addition, the ability to use three

treatment methods would enable the NNIP program manager with options, not available under Alternative 1, for decreasing the spread of NNIP and controlling infestations.

Summary – Direct and Indirect Effects – Alternative 2 Considering the design criteria and small magnitude of anticipated impacts, any response by RFSS wetland birds from exposure to project activities should be minimal and insignificant. Benefits to this group of RFSS species may occur over the short term, but would accrue in greater magnitude over a longer period of NNIP control. Alternative 2 would provide a higher level of benefits than Alternative 1 due to the greater treatment acreage, and the ability to use three treatment methods for decreasing the spread of NNIP and controlling infestations.

Cumulative Effects We consider the effects of Alternative 2 are minimal. Consequently, they would have little or no incremental effect when combined with the effects of past, present, or reasonably foreseeable future activities.

Determination Alternative 1 – No impact Alternative 2 – May impact individuals; not likely to cause trend to listing or loss of viability

Grassland/Shrub Birds

Descriptions of RFSS birds with grassland and shrubs as a primary component of their habitats on the HNF are provided first, and then followed by potential effects from each of the two proposed alternatives.

Threats by NNIP: There have been infestations identified in habitat for this group of species. However, there are no specific adverse impacts to species in this group or their habitats known to have resulted from NNIP infestations. To date, most of the NNIP infestations occur in disturbed sites (e.g. roadsides, skid trails, parking areas and utility corridors) (USDA 2006d, p. 3-66), rather than habitat for RFSS grassland/shrub birds.

Prairie Warbler (Dendroica discolor) Spring migrants sometimes reach Michigan in the first few days of May, but most arrive about the middle of May in the Lower Peninsula. Breeding activity usually occurs from late May through early July. Breeding occurs in a variety of upland shrub habitats associated with poor soils, including dune/lakeshore communities, fallow fields with scattered trees, etc. The nest is a compact cup of plant fibers, small dead leaves, grasses, bud scales, fern and seed down, bound with spiders' webs, lined with hair and/or feathers and placed in a shrub or sapling 1-10 feet above ground. Egg laying occurs in June. Young are fed primarily caterpillars; adults eat a variety of small invertebrates and glean insects and spiders from vegetation. It will occasionally take prey mid-air. Currently, the populations of prairie warbler in Michigan are small and scattered, though much suitable habitat appears to be available (USDA 2006b, pp. 88-89). This observation has led some researchers to believe that the prairie warbler’s habitat requirements may be more confined than originally thought. Beneficial practices include prescribed burning, allowing natural succession in fields, creating large

cut-over areas, maintenance of large thickets in agricultural areas, and the establishment of young pine forests (USDA 2001b).

Sharp-tailed Grouse (Tympanuchus phasianellus) Sharp-tailed grouse (also “sharptails”) are an early successional species occupying habitat that includes large upland grass/forb and brushy openings and non-forest wetlands. Large blocks of a variety of openlands, such as agricultural lands, pine barrens, savannas, shrubby grasslands, young pine stands and open wetlands are used. Sharp-tailed grouse are considered a non- migratory species but may, depending on weather conditions, move short distances on a seasonal basis. In the U.P. of Michigan, birds move from open habitat in the summer to areas with a considerable shrub/tree component. As early as mid-March, both sexes congregate at leks and males begin displaying, from dawn to an hour or so after sunrise. Clutches average 10-12 eggs, and only the female participates in rearing. The females escort their broods to shrub and open woodland habitats. Intensive agriculture and forest plantings have adversely impacted many populations of sharptails. Declines and extirpations of local populations can be attributed primarily to habitat loss through degradation and fragmentation. (USDA 2006b, pp. 99-100)

Migrant Loggerhead Shrike (Lanius ludovicianus migrans) In Michigan, loggerhead shrikes arrive at breeding grounds between mid-March and mid-April. Males arrive before females, and nearly half the males may reoccupy the same nesting area and the same nest tree or shrub as the previous year. Loggerhead shrike habitat consists of grasslands and open, agricultural areas, characterized by short vegetation and scattered trees, shrubs or hedgerows and bare ground for nesting cover and hunting and lookout perches. Suitable nest trees and perches from which to locate prey are essential components of this species’ breeding habitat. Loggerhead shrikes nest in a variety of trees and shrubs, but seem to prefer trees and shrubs with thorns or dense branches, probably to provide protection and concealment from predators. The loggerhead shrike preys on insects, small mammals, birds, amphibians and reptiles. During the summer, this bird feeds primarily on insects, mostly grasshoppers, crickets and beetles. However, during the winter and early spring, vertebrate prey, primarily small mammals, make up most of its diet. Loggerhead shrikes prey on small birds, such as sparrows and warblers, opportunistically, and occasionally take larger birds, such as northern cardinals (Cardinalis cardinalis) and mourning doves (Zenaida macroura). The loggerhead shrike also feeds on roadkills and carrion. (USDA 2006b, pp. 68-69)

Forest Plan Direction specific to RFSS Grassland/Shrub birds and this project Guideline: Sharp-tailed Grouse – Maintain permanent openings within vegetation goals for habitat suitable for sharp-tailed grouse. (USDA 2006a 2-20) Guideline: Non-native invasive plants within element occurrences of threatened and endangered and Regional Forester Sensitive Species should be eliminated or controlled. (USDA 2006a 2-17) Guideline: Adverse impacts to known occurrences of Regional Forester Sensitive Species should be avoided, minimized or mitigated. (USDA 2006a 2-17)

Analysis of Effects – Grassland/Shrub Birds – Alternative 1 (No-Change)

Direct and Indirect Effects Implementing Alternative 1 would have no effect on the RFSS grassland/shrub birds on the HNF over the period covered by this EA. Some NNIP sites identified would be allowed to persist or increase in size. However, we know of no RFSS grassland/shrub bird nesting or foraging habitats currently infested to a level of adverse impacts, or do we suspect any RFSS sites to be in future danger by NNIP infestations. We anticipate the spread of NNIP into this group’s habitat would be patchy over the 5-year period of this EA and have no effect on habitat. The Forest would likely

continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical means only, using individual project decisions not associated with this EA. This, however, would likely have minimal impact on these RFSS birds over the 5-year period of the NNIP project EA. Due to Forest Plan management direction, we anticipate that a high priority would be placed on eradicating infestations with potential to adversely affect RFSS should such circumstances develop on the Forest. Consequently, there would be no impact to grassland/shrub species from implementing Alternative 1.

Cumulative Effects Because there are no direct or indirect effects on RFSS grassland/shrub birds associated with Alternative 1, there would be no cumulative effects to combine with the effects of past, present, or reasonably foreseeable future activities in the project area.

Analysis of Effects – Grassland/Shrub Birds – Alternative 2 (Proposed Action)

Direct and Indirect Effects Mechanical or manual method of treatment - This mode of treatment would involve the use of various equipment, such as weed cutters, chainsaws, and pruning shears. These devices create noise that might disturb birds in this group and cause them to temporarily leave an area. Human disturbance would be minimal because most applications would not require the use of motorized equipment. Movement on foot through habitat could also cause some disturbances. However, these impacts would be of short duration (typically measured in minutes or hours), localized and occur only once during the growing season. Thus, we anticipate minimum impacts from these methods.

Chemical Treatment - The data summarized in Tables E-1, E-2 and E-3 suggest that the herbicides proposed for use pose little risk to species in this group. Direct contact of any grassland/shrub bird species by herbicides is unlikely, as the birds would likely vacate the treated area while human activity is ongoing. Using anticipated application rates pose little risk to small mammals, reptiles, and amphibians that constitute the primary prey of loggerhead shrike. The same data tables indicate that proposed herbicides pose little risk to terrestrial invertebrates, the primary prey of prairie warbler. Sharptails consume some invertebrates in the summer, but mainly eat seeds, buds, berries, and vegetation. Since sharptails are not known to favor any of the weeds proposed to be targeted (Table I-1), it is unlikely they will directly consume treated vegetation. Ecological risk assessments conducted for proposed herbicides suggest that use at rates commonly used by the Forest Service poses little or no risk to birds (Tables E-2 and E-3). The risk assessment for glyphosate concludes that small birds who consume insects from areas treated with the maximum application rate for an extended period could experience adverse effects (USDA Forest Service 2003a). However, we consider that an unlikely scenario for the HNF due to small acreage anticipated to be treated and the location of most treatments sites outside of habitat for these species. It is also likely that the small acreages to be treated would be accomplished at the noted average rates for Forest Service projects that pose little risk, rather than the maximum rates for these products. Furthermore, project protocol directs that manual/mechanical treatments be considered first and that spot treatments be employed, rather than broadcast applications (protocol, p. 10). These measures further reduce the risk to this group of species.

None of the proposed herbicides are related to carbamate and organophosphate insecticides, which inhibit cholinesterase enzymes and have been known to cause bird mortality. None of our herbicides contain chemicals such as DDT, a class of chemical that are implicated in causing raptor egg-shell thinning. Considering protections and the small acreage anticipated in proximity to habitat, minimal adverse impacts to RFSS grassland/shrub birds are expected from use of listed chemicals.

Biological Control - Insects used as biological control agents (Table I-7) are neither competitors nor prey of RFSS grassland/shrub birds on the Forest. Furthermore, the abundance or absence of these agents would have no effect on the specified species. Each of the biological control agents encompassed under this proposal have a record of successful and safe application within Midwestern areas similar to that of the HNF. Biological control agents targeting spotted knapweed (i.e. NNIP expected in this group’s habitat) would be released at the edges of wetlands used as habitat by RFSS, eliminating human disturbance within habitat. Therefore, use of biological controls would not pose detrimental impacts on this group of species.

All NNIP Control Methods - For all treatment methods (mechanical/manual, chemical and biological), human disturbance would be minimal because most applications would not require the use of motorized equipment. There may be some increase in noise and movement in proximity to grassland and shrub habitats associated with equipment such as weed cutters, chainsaws, and back-back spraying units, but are expected to be of minimal impact because all treatments would be temporary, localized and of short duration. Because nests are built near the ground or in small trees and shrubs, they are vulnerable to trampling or disturbance by personnel with equipment performing treatments. It is also possible that nests might be concealed in patches of NNIP shrubs such as honeysuckles and buckthorns targeted for treatment, and thus subject to inadvertent injury. Therefore, to protect nesting birds, including prairie warbler and loggerhead shrike, design criterion No. 22 (p. 14) would require that thickets of invasive shrubs, such as exotic honeysuckle and Japanese barberry, to only be treated after August 1. Individual shrubs may be treated at any time if an inspection shows no nesting bird on or below the shrub. For the sharptail, a wildlife biologist would review treatments proposed for large permanent openings in proximity to known and historic leks prior to being implemented (see design criteria No. 21, p. 13). This would further minimize the risk of physical disturbance, since areas of known nesting would be avoided. General design criteria (Nos. 1, 2, 3, and 5, p. 12) and protocol No. 4, p. 10, would provide additional protections for the species in this group. The criteria require that a variety of protections be met, such as designing treatments to ensure RFSS are not harmed, stopping and reviewing treatments if RFSS are observed, and surveying suitable prior to treatment. Thus, the risks of NNIP treatments would be low, and there would be minimal adverse effects on species in this group.

For all treatment methods the low level of vegetation change from NNIP treatments would have no detectable impact on RFSS grassland/shrub birds. There would be a potential for a greater level of activity associated with Alternative 2, than with Alternative 1, but even at the maximum of 200 acres, annually, across the Forest, there would be minimal impacts expected. We anticipate that over the 5-year period of this project, the majority of the treatments would occur in upland, disturbed areas, such as roadsides, temporary roads, and parking areas, rather than in habitats used by the species in this group. Over the period anticipated for control under this EA, there would be some beneficial impacts afforded to this group of birds from the decrease in NNIP. The benefit over the 5- year period of this EA is expected to be small as control activities slow or stop the spread of NNIP into areas not currently infested. However, over a longer period of NNIP control, the result is expected to be a more diverse vegetative community on the HNF. This condition could theoretically result in improved food and cover for grassland bird prey and ultimately higher levels of productivity and survivability in the RFSS birds. Alternative 2 would theoretically provide a greater level of benefits than Alternative 1 due to the greater treatment acreage. In addition, the ability to use three treatment methods would enable the NNIP program manager with options, not available under Alternative 1, for decreasing the spread of NNIP and controlling infestations.

Summary – Direct and Indirect Effects – Alternative 2 Considering the design criteria and small magnitude of anticipated impacts, any response by RFSS grassland/shrub birds from exposure to project activities should be minimal and insignificant.

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Benefits to this group of RFSS species may occur over the short term, but would accrue in greater magnitude over a longer period of NNIP control. Alternative 2 would provide a greater level of benefits than Alternative 1 due to the greater treatment acreage, and the ability to use three treatment methods for decreasing the spread of NNIP and controlling infestations.

Determination Alternative 1 – No impact Alternative 2 – May impact individuals; not likely to cause trend to listing or loss of viability

Other Birds

Black-backed Woodpecker (Picoides arcticus) The black-backed woodpecker is closely associated with boreal forests. The species is widespread but occurs locally and uncommonly in the Upper Peninsula. Black-backed woodpeckers do not migrate south in winter, unless in response to insect outbreak. In Michigan, they occur in black spruce-tamarack bogs, cedar swamps, jack pine plains, burned areas with standing snags and conifer clearcuts. Disturbances that provide a mosaic of openings and an abundance of downed and standing dead timber are preferred foraging areas. Courtship and nesting begin in early to mid- May. The nest is a hole excavated in a partially dead conifer or live tree with dead heartwood, or hard snag, utility pole, or fence post. Typically, a new nest cavity is excavated each year, by both sexes. Clutch size is two to six, with only one clutch produced per breeding season. Incubation, by both sexes, lasts 12-14 days. Young are altricial, tended by both parents, and fledge in about 25 days. Both adults feed the fledglings for several weeks after they leave the nest. Diet consists mainly of the larvae of wood-boring beetles, but also ants, insects, spiders, vegetable matter, wild fruits, mast, and cambium. Most foraging takes place on upright or downed dead trees, sometimes far from its nesting territory. Pecking is the most common way of obtaining food, followed by gleaning from the tree trunks and then by feeding from the ground. (USDA 2006b, pp. 30-31)

Black-backed woodpeckers have suffered declines due to fire suppression, removal of dead and insect damaged trees and loss of mature and old growth habitat. Management needs include restoring natural fire regimes, retaining snags and cavity-capable trees, leaving insect damaged trees, fallen logs, and preserving areas of mature to old growth trees. (USDA 2006b, pp. 30-31)

Threats by NNIP: There are no specific adverse impacts to black-backed woodpeckers known to have resulted from NNIP infestations. To date, most of the NNIP infestations occur in disturbed sites (e.g. roadsides, skid trails, parking areas and utility corridors) (USDA 2006d, p. 3-66), rather than habitat for this species.

Forest Plan Direction specific to black-backed woodpecker and this project

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Guideline: Black-backed woodpecker – Patches of mature forest should be retained around known breeding sites. (USDA 2006a, p. 2-18) Guideline: Non-native invasive plants within element occurrences of threatened and endangered and Regional Forester Sensitive Species should be eliminated or controlled. (USDA 2006a, p. 2-17) Guideline: Adverse impacts to known occurrences of Regional Forester Sensitive Species should be avoided, minimized or mitigated. (USDA 2006a, p. 2-17)

Analysis of Effects – Black-backed woodpecker – Alternative 1 (No-Change)

Direct and Indirect Effects Implementing Alternative 1 would likely have no effect on the black-backed woodpecker on the HNF over the period covered by this EA. Some NNIP sites identified would be allowed to persist or increase in size. However, we are not aware of any black-backed woodpecker habitat currently infested to a level of adverse impacts. We do not suspect any HNF sites encompassing occupied habitat to be in future danger from NNIP infestations. We anticipate the spread of NNIP into suitable habitat would be patchy over the 5-year period of this EA and have no effect on the species. The Forest would likely continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical means only, using individual project decisions not associated with this EA. This, however, would likely have minimal impact on this species over the 5-year period of the NNIP project EA. Due to Forest Plan management direction, we anticipate that infestations with potential to adversely affect RFSS would be controlled should such circumstances develop on the Forest. Consequently, there would be no impact to black-backed woodpecker from implementing Alternative 1.

Cumulative Effects Because there are no direct or indirect effects on black-backed woodpecker associated with Alternative 1, there would be no cumulative effects to combine with the effects of past, present, or reasonably foreseeable future activities in the project area.

Analysis of Effects – Black-backed woodpecker – Alternative 2 (Proposed Action)

Direct and Indirect Effects Mechanical or manual method of treatment – This mode of treatment would involve the use of various equipment, such as weed cutters, chainsaws, and pruning shears. These devices create noise that might disturb black-backed woodpecker. Human disturbance would be minimal because most applications would not require the use of motorized equipment. Movement on foot through habitat could also cause some disturbances. However, these impacts would be of short duration (typically measured in minutes or hours), localized and occur only once during the growing season. Therefore, we anticipate minimum impacts from these methods. Black-backed woodpeckers nest in cavities in snags or live trees with heartwood that can be excavated. No such trees would be felled or subject to physical damage in this alternative. Invasive understory, such as buckthorns and honeysuckle, would be cut, grubbed, burned using the weed torch, and/or sprayed manually in forested areas without disturbance to overstory trees or snags.

Chemical Treatment - The data summarized in Table E-2 and E-3 suggest that the herbicides proposed for use pose little risk to avian species. Direct contact of black-backed woodpecker by herbicides is unlikely, as the birds would likely vacate the treated area while human activity is ongoing. Additionally, few treatments would be expected to occur in potential habitat for this species. It is also an uncommon species, a circumstance that adds to the unlikely potential for direct contact. Using anticipated application rates pose little risk to terrestrial invertebrates, the

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primary prey of prairie warbler. Ecological risk assessments conducted for proposed herbicides suggest that use at rates commonly used by the Forest Service poses little or no risk to birds (Table E-3). The risk assessment for glyphosate concludes that small birds who consume insects from areas treated with the maximum application rate for an extended period could experience adverse effects (USDA Forest Service 2003a). However, we consider that an unlikely scenario for the HNF due to small acreage anticipated to be treated overall, and the location of most treatments sites outside of potential habitat for black-backed woodpecker. It is also likely that the small acreages to be treated would be accomplished at the noted average rates for Forest Service projects that pose little risk, rather than the maximum rates for these products. Furthermore, project protocol directs that manual/mechanical treatments be considered first and that spot treatments be employed, rather than broadcast applications (protocols, No. 8, p. 11). These measures further reduce the risk to this species.

Biological Control – Insects used as biological control agents (Table I-7) are neither competitors nor prey of black-backed woodpecker on the Forest. Furthermore, the abundance or absence of these agents would have no effect on this species. Thus, use of biological controls would pose no adverse impacts.

All NNIP Control Methods - For all treatment methods, manual/mechanical, chemical and biological, a low level of vegetation change from NNIP treatments is anticipated. There would be a potential for a greater level of activity associated with Alternative 2, than Alternative 1, but even at the maximum of 200 acres, annually, across the Forest, there would be minimal impacts expected in forested habitats used by black-backed woodpeckers. This is because known infestations are not common in this species habitat on the HNF. We anticipate that the majority of the treatments would occur in upland, disturbed areas, such as roadsides, temporary roads, and parking areas, rather than in habitats used by black-backed woodpecker. Human disturbance would be minimal because most applications would not require the use of motorized equipment. There may be some increase in noise and movement in proximity to this species breeding and foraging habitats. However, the activity is expected to be of minimal impact because the few treatments that might occur would be temporary, localized and of short duration. General design criteria (Nos. 1, 2, 3, and 5, p. 12) and protocol No. 4, p. 10, would provide additional protections for this species. The criteria require that a variety of protections be met, such as designing treatments to ensure RFSS are not harmed, stopping and reviewing treatments if RFSS are observed, and surveying suitable prior to treatment. Thus, the risks of NNIP treatments would be low, and there would be minimal adverse effects on this species. Over the period anticipated for control under this EA, there would likely be minimal beneficial impacts afforded to black-backed woodpeckers from the decrease in NNIP. However, over a longer period of NNIP control, the result is expected to be a more diverse vegetative community on the Forest, a condition that theoretically could provide improved food and cover for prey species, and ultimately black-backed woodpeckers. This could result in higher levels of productivity and survivability for this species. Alternative 2 would theoretically provide a greater level of benefits than Alternative 1 due to the greater treatment acreage. In addition, the ability to use three treatment methods would enable the NNIP program manager with options, not available under Alternative 1, for decreasing the spread of NNIP and controlling infestations.

Summary – Direct and Indirect Effects – Alternative 2 Considering the design criteria and small magnitude of anticipated impacts, any response by black- backed woodpecker from exposure to project activities should be minimal. Any indirect beneficial effects resulting from NNIP control by improving vegetation diversity, cover, and sources of prey for this group of species could theoretically be greater under Alternative 2 because more treated acres would be possible.

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Determination Alternative 1 – No impact Alternative 2 – May impact individuals; not likely to cause trend to listing or loss of viability

Connecticut Warbler (Oporornis agilis) The Connecticut warbler is an uncommon, elusive neotropical migrant. They are one of the latest of spring migrants, arriving on their breeding grounds in Michigan in mid-May to early-June. The U.P. of Michigan is near the southern edge of the Connecticut warbler’s breeding range; 85% of breeding range is in Canada. Distribution is spotty in the U.P., even in suitable habitat. The species uses a multitude of habitat types in Great Lakes states, breeding in habitats from black spruce bogs, young-pole size jack pine, mixed hardwoods, dry uplands, lowlands, sedge meadows and a dozen other types. A well-developed shrub-understory layer may be more important than the forest type in determining habitat suitability for this species, described as a ericaceous understory (heath family). The habitat Connecticut warblers occupy on the HNF is local, even though suitable areas appear to be abundant. The species exists at low abundance on the HNF (USDA 2006b, pp. 60- 61). The Connecticut warbler feeds primarily on insects, including gleaning insects off foliage, and to a lesser extent on berries.

Threats by NNIP: There are no specific adverse impacts to Connecticut warbler known to have resulted from NNIP infestations. To date, most of the NNIP infestations occur in disturbed sites (e.g. roadsides, skid trails, parking areas and utility corridors) (USDA 2006d, p. 3-66), rather than habitat for this species.

Forest Plan Direction specific to Connecticut warbler and this project Guideline: Non-native invasive plants within element occurrences of threatened and endangered and Regional Forester Sensitive Species should be eliminated or controlled. (USDA 2006a, p. 2-17) Guideline: Adverse impacts to known occurrences of Regional Forester Sensitive Species should be avoided, minimized or mitigated. (USDA 2006a, p. 2-17)

Analysis of Effects – Connecticut warbler – Alternative 1 (No-Change)

Direct and Indirect Effects Implementing Alternative 1 would likely have no effect on the Connecticut warbler on the HNF over the period covered by this EA. Some NNIP sites identified would be allowed to persist or increase in size. However, we are not aware of any Connecticut warbler habitats currently infested to a level of adverse impacts. We do not suspect any Forest sites encompassing occupied habitat to be in future danger from NNIP infestations. We anticipate the spread of NNIP into suitable habitat would be patchy over the 5-year period of this EA and have no effect on the species. The Forest would likely continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical means only, using individual project decisions not associated with this EA. This,

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however, would likely have minimal impact on this species over the 5-year period of the NNIP project EA. Due to Forest Plan management direction, we anticipate that it is likely a high priority would be placed on eradicating infestations with potential to adversely affect RFSS should such circumstances develop on the Forest. Consequently, there will likely be no impact to Connecticut warbler from implementing Alternative 1.

Cumulative Effects Because there are no direct or indirect effects on Connecticut warbler associated with Alternative 1, there would be no cumulative effects to combine with the effects of past, present, or reasonably foreseeable future activities in the project area.

Analysis of Effects – Connecticut warbler – Alternative 2 (Proposed Action)

Direct and Indirect Effects Mechanical or manual method of treatment - Manual/mechanical treatment would involve the use of various equipment, such as weed cutters, chainsaws, and pruning shears. These devices create noise that might disturb birds in this group. Movement on foot through habitat could also cause some disturbances. However, these impacts would be of short duration (typically measured in minutes or hours) and localized. Most treatments associated with this project would not occur in this species habitat, rather they are anticipated to occur primarily in gravel pits, road ditches and other disturbed sites. Therefore, we anticipate minimum impacts to Connecticut warbler.

Chemical Treatment - The data summarized in Tables E-1, E-2 and E-3 suggest that the herbicides proposed for use pose little risk to species in this group. Direct contact with this warbler by herbicides is unlikely, as the birds would likely vacate the treated area while human activity is ongoing. Using anticipated application rates pose little risk to terrestrial invertebrates that constitute the primary prey of Connecticut warbler. To a lesser extent, this warbler will feed on berries. Connecticut warblers are not known to favor any of the weeds proposed to be targeted (Table I-1), it is unlikely they would directly consume treated vegetation. Ecological risk assessments conducted for proposed herbicides suggest that use at rates commonly used by the Forest Service poses little or no risk to birds (Table E-2 and E-3). The risk assessment for glyphosate concludes that small birds who consume insects from areas treated with the maximum application rate for an extended period could experience adverse effects (USDA Forest Service 2003a). However, we consider that an unlikely scenario for the HNF due to small acreage anticipated to be treated in habitat that might be suitable for Connecticut warbler. It is also likely that the small acreages to be treated would be accomplished at the noted average rates for Forest Service projects that pose little risk, rather than the maximum rates for these products. Furthermore, project protocol directs that manual/mechanical treatments be considered first and that spot treatments be employed, rather than broadcast applications (protocol No 8, p. 11). These measures further reduce the risk to this species from herbicide treatments.

Biological Control - Insects used as biological control agents (Table I-7) are neither competitors nor prey of Connecticut warbler. Furthermore, the abundance or absence of these agents would have no effect on the specified species, since they are not consumed as a food source or function as a predator. The likelihood for release of biological agents in Connecticut warbler habitat is low, since the species targeted by the control agents are not known to commonly occur in suitable habitat. Thus, use of biological controls would pose no adverse impacts to Connecticut warbler under Alternative 2.

All NNIP Control Methods - For all treatment methods, manual/mechanical, chemical and biological, a low level of vegetation change from NNIP treatments is anticipated. There would be a potential for

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a greater level of activity associated with Alternative 2, than Alternative 1, but even at the maximum of 200 acres, annually, across the Forest, there would be minimal impacts expected in habitats used by Connecticut warbler. This is because known infestations are not common in this species habitat on the HNF. We anticipate that the majority of the treatments would occur in upland, disturbed areas, such as roadsides, temporary roads, and parking areas, rather than in habitats used by black-backed woodpecker. Human disturbance associated with Alternative 2 would be minimal because most applications would not require the use of motorized equipment. There may be some increases in noise and movement, in proximity to suitable habitats, associated with equipment such as weed cutters, chainsaws, and back-back spraying units, but they are expected to be of minimal impact because all treatments would be temporary, localized and of short duration. Because nests are built near the ground or in small trees and shrubs, they are vulnerable to trampling or disturbance by personnel with equipment performing treatments. However, we believe the risk to be small considering the limited treatments planned under this alternative and the rarity of the species on the Forest. It is also possible that nests might be concealed in patches of NNIP shrubs such as honeysuckles and buckthorns targeted for treatment, and thus subject to inadvertent injury. Thus, to protect nesting RFSS birds, such as Connecticut warble, design criterion No. 22 (p. 14) calls for thickets of invasive shrubs, such as exotic honeysuckle and Japanese barberry, to only be treated after August 1. General design criteria (Nos. 1, 2, 3, and 5, p. 12) and protocol No. 4, p. 10, would provide additional protections for the species in this group. The criteria require that a variety of protections be met, such as designing treatments to ensure RFSS are not harmed, stopping and reviewing treatments if RFSS are observed, and surveying suitable prior to treatment. Thus, the risks of NNIP treatments would be low, and there would be minimal adverse effects on this species. Over the period anticipated for control under this EA, there would possibly be some beneficial impacts afforded to Connecticut warbler from the decrease in NNIP. This would be expected to occur over time as control activities slow or stop the spead of NNIP into areas not currently infested. The benefit over the 5-year period of this EA is expected to be small. However, over a longer period of NNIP control, the result is expected to be a more diverse vegetative community on the Forest, a condition that theoretically could provide improved food and cover for this species. Alternative 2 would provide a greater level of benefits than Alternative 1 due to the greater treatment acreage and the ability to use three treatment methods, not available under Alternative 1, for decreasing the spread of NNIP and controlling infestations.

Summary – Direct and Indirect Effects – Alternative 2 Considering the design criteria and small magnitude of anticipated impacts, any response by Connecticut warbler from exposure to project activities should be minimal and insignificant. Any indirect beneficial effects resulting from NNIP control by improving vegetation diversity, cover, and sources of prey for this species could theoretically be greater under Alternative 2.

Determination Alternative 1 – No impact Alternative 2 – May impact individuals; not likely to cause trend to listing or loss of viability

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RFSS Reptile One reptile species is included on the most recent list of RFSS for the HNF. RFSS Reptiles Description of Blanding’s turtle habitat and ecology on the HNF is provided first, then followed by potential effects from each of the two proposed Blanding’s turtle alternatives.

Threats by NNIP: There are three NNIP species identified as primary invaders of habitat that could be used by Blanding’s turtle, including Eurasian water milfoil, purple loosestrife and reed canary grass. Purple loosestrife has been identified at 27 sites on the HNF, encompassing approximately 30 acres. At present, there are no specific NNIP concerns related to Blanding’s turtle. To date, most of the NNIP infestations occur in disturbed sites (e.g. roadsides, skid trails, parking areas and utility corridors) (USDA 2006d, p. 3-66), rather than habitat for Blanding’s turtle.

Blanding’s Turtle (Emydoidea blandingii) Blanding’s turtles inhabit productive, clean, shallow waters with abundant aquatic vegetation and soft muddy bottoms over firm substrates. This species is found in ponds, marshes, swamps, bogs, wet prairies, river backwaters, embayments, sloughs, slow-moving rivers, protected coves, and lake shallows and inlets. Blanding’s turtles also occupy terrestrial habitats in the spring and summer, during the mating and nesting seasons, and in the fall, to a lesser extent. They prefer to nest in open, sunny areas with moist but well-drained sandy or loamy soil. Blanding’s turtles are active as early as late March or April. During the active season, they are often seen basking on muskrat lodges, stumps, logs, sedge or cattail clumps, or steep banks of dikes and ditches. At night, these turtles are found in or under aquatic vegetation. During the summer and fall, when shallow water habitats start to dry, some Blanding’s turtles migrate overland to new bodies of water, while others aestivate on land, burrowing under roots, mud, or plants. Blanding's turtles typically enter hibernation sites between September and late November. They usually hibernate underwater in deeper water bodies, often buried in organic substrate. Mating can occur anytime during the active season (late March/April - November) but occurs primarily from March through May. Mating occurs in shallow to deep water in wetland habitats. Females leave the wetlands to excavate nests in upland, open, often disturbed sandy areas adjacent to or near wetlands. Blanding’s turtles are omnivorous. They feed predominantly on crayfish and aquatic insects but also consume small fish, earthworms, snails, leeches, tadpoles, frogs and aquatic plants. They feed primarily under water, and generally forage along the substrate. Raccoons, foxes, and skunks are the primary predators of Blanding’s turtle eggs, hatchlings and juveniles. (USDA 2006b, p. 120-122)

The distribution of this species is generally spotty with some widely disjunct populations. Up until 2005, MNFI had no element occurrence records for Blanding's turtle within the HNF. The first verified occurrence was within the boundary in Delta County in 2005. Before that event, Jim Harding reported that Blanding's turtles do occur in the HNF but must be very rare. Blanding’s turtles are threatened across their range, by habitat loss and degradation. Blanding’s turtles require clean, shallow water with abundant aquatic vegetation, and appear to be sensitive to habitat alteration. (USDA 2006b, p. 120-122)

Forest Plan Direction specific to Blanding’s turtle and this project Standard: Wetland roads and trails crossings will preserve cross drainage. (USDA 2006a, p. 2-14) Guideline: The State of Michigan “Water Quality Management Practices on Forest Land” (BMPs) should be implemented as a minimum standard. (USDA 2006a, p. 2-14) Guideline: Yellow rail – Graminoid/sedge marshes are maintained or improved to provide suitable habitat conditions. (USDA 2006a, p. 2-18) – would benefit Blanding’s turtle

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Guideline: Non-native invasive plants within element occurrences of threatened and endangered and Regional Forester Sensitive Species should be eliminated or controlled. (USDA 2006a, p. 2-17) Guideline: Adverse impacts to known occurrences of Regional Forester Sensitive Species should be avoided, minimized or mitigated. (USDA 2006a, p. 2-17)

Analysis of Effects – Blanding’s turtle – Alternative 1 (No-Change)

Direct and Indirect Effects Implementing Alternative 1 would likely have no adverse effects on Blanding’s turtle over the period covered by this EA. The HNF would likely continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical means only, using individual project decisions not associated with this EA. Some NNIP sites would be allowed to persist or increase in size under Alternative 1. However, no sites of importance to the species to Blanding’s turtle have been identified as currently being adversely affected by NNIP infestations. There are no known sites in imminent danger of future infestations that would result in adverse impacts to the species. We anticipate the spread of NNIP would be patchy over the 5-year period of this EA. Due to Forest Plan management direction, we anticipate that it is likely a high priority would be placed on eradicating infestations with potential to adversely affect important habitat for Blanding’s turtle should such a circumstance develop on the Forest. Consequently, there would be no impacts to the species from implementing Alternative 1.

Cumulative Effects Because there are no direct or indirect effects on the Blanding’s turtle associated with Alternative 1, there would be no cumulative effects to combine with the effects of past, present, or reasonably foreseeable future activities in the project area.

Analysis of Effects – Blanding’s turtle – Alternative 2 (Proposed Action)

Direct and Indirect Effects Mechanical or manual method of treatment – Manual and mechanical treatments of aquatic species, such as Eurasian water milfoil, or emergent species, such as purple loosestrife, could temporarily create disturbance in foraging and nesting habitats. Equipment used to apply herbicides could cause similar temporarily disturbances. However, these impacts would be of short duration (typically measured in minutes or hours) and localized. Manual/mechanical treatments would be unlikely to cause injury or mortality, since individual turtles would leave the area when work is ongoing. Treatments would cause a temporary change in activity patterns, but nothing more.

Chemical Treatment - Only herbicide formulations labeled for use in aquatic habitats would be used in wetlands and in the buffer surrounding the wet areas (see design criteria, No. 11, p. 13), which would include the most habitats potentially used by Blanding’s turtle. The herbicides likely to be used include glyphosate and triclopyr. The data summarized in Table E-2 and E-3 indicate that glyphosate (Rodeo formulation) and triclopyr (triethylamine salt formulation), the formulation used in aquatic areas and within the specified upland buffers pose little risk to the invertebrates and amphibians that constitute a portion of the prey for Blanding’s turtle. The species is also known to consume a small amount of aquatic vegetation. There is no evidence that Blanding’s turtle favors any of the weed species on the HNF NNIP list (Table I-1). The likelihood that Blanding’s turtle would consume treated vegetation, green or wilted, would be low, since they would represent only a small amount of total vegetation available at any given time.

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Chemical control treatments in Blanding’s turtle habitats could result in direct exposure of the turtles to herbicides. We view this to be unlikely considering the majority of treatments areas would not occur in potential habitat for this species. Furthermore, herbicides used in potential Blanding’s turtle habitat and the upland buffer are unlikely to harm this species at the label specified rates of application. The physiology of reptiles is generally understood to be more similar to birds than fish or mammals. Reptiles are not commonly used as laboratory test subjects in toxicological studies. The data summarized in Table E-2 and the ecological risk assessments in Table E-3 suggest these herbicides pose little risk to birds and therefore reptiles. Blanding’s turtle eggs, which typically are underground in sparsely vegetated areas, are unlikely to be exposed to herbicides or be affected indirectly by the herbicides specified for use in wet areas and the upland buffers.

Biological Control - Biological control agents targeting purple loosestrife or Eurasian water milfoil would be released at the edges of wetlands used as habitat by Blanding’s turtle and thus avoid the potential for physical habitat disturbance. Furthermore, the abundance or absence of these agents would have no effect on the specified species, since they are not consumed as a food source or function as a predator. Each of the biological control agents encompassed under this proposal have a record of successful and safe application within Midwestern areas similar to that of the HNF. Therefore, use of biological controls would not pose adverse impacts to Blanding’s turtle.

All NNIP Control Methods - For all treatment methods, manual/mechanical, chemical and biological, a low level of vegetation change from NNIP treatments is anticipated. There would be a potential for a greater level of activity associated with Alternative 2, than Alternative 1, but even at the maximum of 200 acres, annually, across the Forest, there would be minimal impacts expected in habitats used by Blanding’s turtles. This is because known infestations are not common in this species habitat on the HNF. We anticipate that the majority of the treatments would occur in upland, disturbed areas, such as roadsides, temporary roads, and parking areas, rather than in habitats used by this species. For all proposed treatments in wetlands, a review must be completed by a wildlife biologist (see design criteria, No. 10, p. 12), and treatments could be stopped if conditions might result in harm to Blanding’s turtle. Human disturbance would be minimal because most applications would not require the use of motorized equipment. There may be some increase in noise and movement in proximity to this species breeding and foraging habitats when removing or cutting vegetation manually or when treating vegetation with herbicides. However, the activity is expected to be of minimal impact because it would be temporary, localized and of short duration. Blanding’s turtle nests would not likely be disturbed by treatments because the eggs are buried in areas of open sand. Foot travel through an area would not disturb the buried eggs. In the event eggs were dislodged, they could be replaced in the nest without harm. However, this would be a very uncommon occurrence for a nest to be disturbed, considering the rarity of the species on the HNF and the buried nature of the nests. Specific design criteria (No. 15, p. 13) would require NNIP workers to be trained to recognize Blanding’s turtle and its nest and eggs. This would help ensure protections in the design criteria are implemented. General design criteria (Nos. 1, 2, 3, and 5, p. 12) and protocol No. 4, p. 10, would provide additional protections for this species. Thus, the risks of NNIP treatments would be low, and there would be minimal adverse effects on this species. Over the period anticipated for control under this EA, there would be small beneficial impacts afforded to Blanding’s turtle from NNIP control activities. This would be expected to occur over time as control activities slow or stop the spread of NNIP into areas not currently infested. However, over a longer period of NNIP control, the result is expected to be a more diverse vegetative community on the Forest, a condition that theoretically could provide improved food, cover and quality nesting sites for this species. Alternative 2 would theoretically provide a greater level of benefits than Alternative 1 due to the greater treatment acreage. In addition, the ability to use three treatment methods would enable the NNIP program manager with options, not available under Alternative 1, for decreasing the spread of NNIP and controlling infestations.

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Summary – Direct and Indirect Effects – Alternative 2 Considering the design criteria and small magnitude of anticipated impacts, any response by Blanding’s turtle from exposure to project activities should be minimal and insignificant. Benefits to Blanding’s turtle may occur over the short term, but would accrue in greater magnitude over a longer period of NNIP control. Alternative 2 would provide a higher level of benefits than Alternative 1 due to the greater treatment acreage, and the ability to use three treatment methods for decreasing the spread of NNIP and controlling infestations.

Determination Alternative 1 – No impact Alternative 2 – May impact individuals; not likely to cause trend to listing or loss of viability

RFSS Fish One fish species is included on the most recent list of RFSS for the HNF. RFSS Fish Description of lake sturgeon ecology on the HNF is provided first, then followed by potential effects from each of the two proposed alternatives. At Lake sturgeon present, there are no specific NNIP concerns related to lake sturgeon or its habitats.

Threats by NNIP: There are two NNIP species identified as primary invaders of habitat that could be used by lake sturgeon, including Eurasian water milfoil and purple loosestrife. Purple loosestrife has been identified at 27 sites on the HNF, encompassing approximately 30 acres. At present, there are no specific NNIP concerns related to lake sturgeon. To date, most of the NNIP infestations occur in disturbed sites (e.g. roadsides, skid trails, parking areas and utility corridors) (USDA 2006d, p. 3-66), rather than habitat for Blanding’s turtle.

Lake Sturgeon (Acipenser fulvescens) The lake sturgeon inhabits larger rivers and lakes. They spawn in water 2 to 15 feet deep and in areas of swift water or rapids with a larger rocky or cobble substrate, often even at the foot of low falls that prevent further migration. Great Lakes populations are known to spawn in wave action over rocky areas or ledges along shorelines and islands. Occurrences on the HNF are from the 1970s and 1980s through 2003. The most recent observations of the species are from Indian Lake in 2003 (C. Bassett, personal communication 2007). The species was widespread historically, with many occurrences in the Great Lakes and Midwest river systems, particularly in northern Michigan. River and lake systems with significant populations include the Sturgeon River (Houghton and Baraga Co.), Auer, Burt, Mullet and Black Lakes in the Cheboygan River system, the Menominee River (Menominee Co.), Indian Lake and the Indian River. Lake Michigan populations have historically spawned along shorelines near Ganges, Pier Cove and Saugatuck (Allegan Co.); New Buffalo (Berrien Co.); Pentwater and Big Sable Point (Mason Co.); North and South Fox Island

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(Leelanau Co.); and South Haven (Van Buren Co.). Lake sturgeon have also been reported in small numbers in Grand Traverse Bay, although no spawning areas have been documented. Three major obstacles to rehabilitating sturgeon worldwide are physical barriers to migration, loss of spawning and nursery areas, and fishing pressures. Declining water quality, sea lamprey parasitism, zebra mussel colonization of spawning habitats, predation of eggs by round gobies, and contaminants are additional threats in the Great Lakes. Spawning stream management and restoration can be promoted through conservation practices such as sand trapping, introduction of spawning gravel and cobble, riparian buffer management, and lowered levels of non point source pollution. (USDA 2006b, pp.131-132)

Forest Plan Direction specific to lake sturgeon and this project Standard: Wetland roads and trails crossings will preserve cross drainage. (USDA 2006a, p. 2-14) Guideline: The State of Michigan “Water Quality Management Practices on Forest Land” (BMPs) should be implemented as a minimum standard. (USDA 2006a, p. 2-14) Guideline: Non-native invasive plants within element occurrences of threatened and endangered and Regional Forester Sensitive Species should be eliminated or controlled. (USDA 2006a, p. 2-17) Guideline: Adverse impacts to known occurrences of Regional Forester Sensitive Species should be avoided, minimized or mitigated. (USDA 2006a, p. 2-17)

Analysis of Effects – Lake sturgeon – Alternative 1 (No-Change)

Direct and Indirect Effects Implementing Alternative 1 would likely have no effect on lake sturgeon on the HNF over the period covered by this EA. Some NNIP sites identified would be allowed to persist or increase in size. However, we know of no lake sturgeon habitat currently infested to a level of adverse effect, or do we suspect any sites to be in future danger by NNIP infestations. We have no evidence to suspect that NNIP will spread into this species habitat over the 5-year period of this EA. The Forest would likely continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical means only, using individual project decisions not associated with this EA. This, however, would likely have minimal impact on lake sturgeon over the 5-year period of the NNIP project EA. Due to Forest Plan management direction for rare species protection, we anticipate that it is likely a high priority would be placed on eradicating infestations with potential to adversely affect RFSS should such circumstances develop on the Forest. Consequently, there will likely be no impact to lake sturgeon from implementing Alternative 1.

Cumulative Effects Because there are no direct or indirect effects on lake sturgeon associated with Alternative 1, there would be no cumulative effects to combine with the effects of past, present, or reasonably foreseeable future activities in the project area.

Analysis of Effects – Lake sturgeon – Alternative 2 (Proposed Action)

Direct and Indirect Effects Mechanical or manual method of treatment – There are no known NNIP sites currently threatening this species. Over the 5-year period of this EA, few treatments are expected in the aquatic habitats suitable for this species. However, manual cutting of Eurasian water milfoil, or similar aquatic NNIP, especially if performed using mechanized tools, could conceivably harm fish if the fish are present in the milfoil stands at the time of treatment. This is a minimal risk because the fish would disperse from the stands of NNIP before being injured.

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Chemical Treatment - Chemical treatment of waters inhabited by the lake sturgeon would directly expose the fish to herbicides. Formulations of triclopyr and glyphosate, which are labeled for use in aquatic settings, could also be used. When applied for aquatic vegetation control, triclopyr triethylamine salt has an 96-hour LC50 of 891 Mg/L, which is of low toxicity to aquatic receptors (Table E-2). The Rodeo formulation of glyphosate has an 96-hour LC50 of 891 Mg/L, which also is of low toxicity to aquatic receptors (Table E-2). Generally, aquatic formulations of the herbicides we have chosen show minimal risk to aquatic species, including fish (Table E-3). A special concern when treating aquatic vegetation, such as Eurasian water milfoil is to avoid rapid die-off of large quantities of vegetation, the decomposition of which could lead to localized depression of dissolved oxygen levels, suffocating fish. This would be of low probability, considering the low level of treatment anticipated in this species habitat.

Fish could also be exposed to other herbicides entering their habitats from adjacent wetlands or in runoff from uplands. The ecological risk assessments described in Table E-3 suggests that proper use of the other herbicides, especially at average rather than maximum rates, would pose little risk to fish in nearby waterways. Only those formulations of glyphosate and other herbicides labeled for use in aquatic areas would be used in wetlands. The use of upland buffer strips, where only herbicide formulations approved for aquatic use would be applied, provides additional protections for this species (design criteria No. 11, p. 13 and protocol No. 8, p. 11). Considering the limited amount of treatments in lake sturgeon habitat and the protections designed into the project, the risk of adverse impacts from chemical treatments are minimal under Alternative 2.

Biological control agents targeting Eurasian water milfoil could be released from shore roads without potentially disrupting fish or their habitats. Insects used as biological control agents (Table 5) are neither competitors nor prey of lake sturgeon. Biological control agents would be expected to affect the Eurasian water milfoil more slowly than herbicides, reducing the potential for rapid die-off of vegetation and consequent depression of dissolved oxygen levels. Each of the biological control agents encompassed under this proposal have a record of successful and safe application within Midwestern areas similar to that of the HNF. Therefore, use of biological controls would have no impacts on lake sturgeon.

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vegetative community on the Forest, a condition that theoretically could provide improved food, cover and quality nesting sites for this species. Alternative 2 would theoretically provide a greater level of benefits than Alternative 1 due to the greater treatment acreage and the ability to use three treatment methods. This would enable the NNIP program manager with options, not available under Alternative 1, for decreasing the spread of NNIP and controlling infestations.

Summary – Direct and Indirect Effects – Alternative 2 Considering the design criteria and the small magnitude of impacts from NNIP treatments, any response by lake sturgeon from exposure to project activities should be minimal and insignificant. Benefits to Blanding’s turtle may occur over the short term, but would accrue in greater magnitude over a longer period of NNIP control. Alternative 2 would provide a higher level of benefits than Alternative 1 due to the greater treatment acreage, and the ability to use three treatment methods for decreasing the spread of NNIP and controlling infestations.

Determination Alternative 1 – No impact Alternative 2 – May impact individuals; not likely to cause trend to listing or loss of viability

RFSS Mollusks Seven mollusks are included on the most recent list of RFSS for the RFSS Mollusks HNF. All are included as one group due to similarities in applicable Catinella exile Forest Plan protections and design criteria for the NNIP project (e.g. Euconulus alderi Planogyra asteriscus design criteria No. 18, p. 13). Descriptions of habitat and ecology Vallonia gracilicosta albula appear first, followed by potential effects from each of the two Vertigo bollesiana proposed alternatives. There is limited information available Vertigo morsei regarding these species, and there are very few occurrences for Vertigo paradoxa each species. Generally, habitat is patchy across the landscape, outcrops of the Niagara escarpment occur in a narrow band and are not continuous across the Forest. Much habitat remains to be surveyed, and not all suitable habitat on the Forest is occupied. Threats to this group include anthropogenic disturbances (highway corridors, railroad right-of-ways) that alter ground water flow; development, agriculture and forestry management practices (changes to canopy closure, road building); trail construction and maintenance; ATV use, quarrying (USDA 2006b, pp. 139-142), as well as specific threats noted by species, below. Some of the species have been found in or near wilderness areas (MA 5.1) and candidate research natural areas (MA 8.1).

Threats by NNIP: At present, there are no specific NNIP concerns related to known RFSS mollusk sites on the HNF. To date, most of the NNIP infestations occur in disturbed sites (e.g. roadsides, skid trails, parking areas and utility corridors) (USDA 2006d, p. 3-66), rather than habitat for RFSS mollusks. Gravel pits are potential habitat for mollusks and many of them do have infestations of

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NNIP. Observations made by Forest Service personnel indicate that NNIP are widespread in the gravel pits, from the stockpiles to the banks and surrounding areas of the pits (J. Stuntebeck, personal communication, 2007).

Catinella exile This species utilizes limestone bedrock beach with seepage areas, shallow pools, and a ground cover dominated by various Carex species; it is found in association with cobble beach with Carex turf in open marl flats (USDA 2006b, p. 139). Catinella exile has also been found at a fen in the U.P. (Kudell-Ekstrum 2003a, p. 5). Threats to the species include anthropogenic activity (e.g. highway corridors, railroad right-of-ways), hydrologic regime alterations, agriculture and forest management. Acid rain may also be a threat. On the HNF, this species is known from only one location. The site is a candidate research natural area, a designation that will provide protection from motorized use and vegetation management (Kudell-Ekstrum 2003a, p. 8).

Euconulus alderi This species has been found at ten sites in the Upper Peninsula including 2 fens, 1 cobble beach, 3 tamarack-sedge wetlands, and 3 white cedar wetlands. These sites are limited to the vicinity of the Lake Michigan-Lake Huron shore. It is most frequently encountered in tamarack-sedge communities within its distribution where it is consistently co-occurs with Vertigo elatior and Vertigo nylanderi (USDA 2006b, p. 139). Threats to the species include anthropogenic activity (e.g. highway corridors, railroad right-of-ways), hydrologic regime alterations, agriculture and forest management. Acid rain may also be a threat (Kudell-Ekstrum 2003b, p. 8). On the HNF, this species is known from only three locations. One site is a candidate research natural area, a designation that will provide protection from motorized use and vegetation management. The other two sites are near a wilderness (Kudell-Ekstrum 2003a, p. 8).

Planogyra asteriscus Of the ten occurrences recorded in the Michigan Natural Features Inventory (MNFI), six of the sites had an occurrence of cedar (Thuja occidentalis) described as acidic white cedar/black spruce swamp forest to open marl flats; remnant white cedar swamp; cedar-tamarack swamp forest with interdigitation of tamarack-sedge wetland and rich cedar forest; white cedar swamp with abundant speckled alder. Other habitat descriptions were associated with limestone outcrops: dry, upland hemlock forest over shallow limestone adjacent to cobble beach; low moist north-facing limestone ridge with water seepage present; sandy upland woods on steep west-facing bank with seepages at base and rich undisturbed swamp forest. Threats were not listed in the references that were checked. However, it is likely they would be similar to other terrestrial gastropods in this group and include anthropogenic activity (e.g. highway corridors, railroad right-of-ways), hydrologic regime alterations, agriculture and forest management. All occurrences in Michigan are in the Upper Peninsula of Michigan. These include Delta County (1 occurrence), Chippewa County (1 occurrence), Mackinac County (5 occurrences), Schoolcraft County (1 occurrence) and Keweenaw County (2 occurrences). All of these observations were made in 1998 when surveys for the Terrestrial Gastropod Inventory of the Niagarian Escarpment Keweenaw Volcanic Belt were conducted. One occurrence in Mackinac County is on the HNF (Kudell-Ekstrum 2006).

Vallonia gracilicosta albula This species inhabits dry carbonate cliffs over 5 meters in height that are wooded, most often with Thuja occidentalis (USDA 2006b, p. 139). The species is known from only 8 locations in the U.P. of Michigan. Threats associated with this species are lack of scientific knowledge and forestry practices. Since V. gracilicosta albula require cool, moist conditions, canopy removal will result in dryer microhabitat conditions unsuitable for this species.

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Vertigo bollesiana In the U.P. of Michigan all locations for this species have been associated with carbonate cliffs, igneous outcrops and lakeshore ledge habitat. Most frequently, it is found at north-north-west exposed limestone outcrops with dense growth of Thuja occidentalis, Tsuga canadanesis and Acer saccharum and occasionally Betula lutea. It has also been found to inhabit basalt cliffs, algific slopes and manderate cliffs in other geographic areas (Kudell-Ekstrum 2006c, p. 3) (USDA 2006a, p. 139). Threats are the same regardless of whether occupied habitat is mandate cliffs or algific site. They include physical filling of upland sinks with soil or trash, discharge of agricultural pollution (e.g. pesticides, herbicides and fertilizers), grazing, human traffic, removal of vegetation, road building, and quarrying (Kudell-Ekstrum 2006c, p. 6). Collecting and research pressures are a substantial problem on more fragile sites (Kudell-Ekstrum 2006c, p. 6). The following counties in the U.P. of Michigan had observations in 1998: Chippewa, Delta, Gogebic, and Ontonagon (Kudell- Ekstrum 2003c, p. 5).

Vertigo morsei This species is found in calcareous open wetlands and fens, and usually associated with the margins of those features. In Mackinac County, MI, this species was found in calcareous fens with organic-rich soil overlaying marl (Kudell-Ekstrum 2003d). Since 1986, 5 occurrences have been found in calcareous fen habitat in Wisconsin and Iowa (USDA 2006b, p. 139). Threats to V. morsei have been listed generally as: human development, highway corridors, agriculture, forest management and other disturbances (Kudell-Ekstrum 2003d). Other threats might include quarrying, rock climbing, spelunking and ATV use. In area with populations of land snails, forest clearing has negative impacts, as well as any activities that may alter groundwater flow (Kudell- Ekstrum 2003d). The two occurrences of V. morsei, during the 1998 inventory, that are on the HNF include: along the boundary of a wilderness area, and another site near a state highway. In the U.P. two counties are listed as having occurrences, including Chippewa and Mackinac (Kudell-Ekstrum 2003d).

Vertigo paradoxa This species is found on: carbonate outcrops and near Lake Superior on basalt outcrops; leaf-litter in upland woods; limestone cliffs with, but not limited to, the following species: Thuja occidentalis, Acer saccharum, Tsuga canadensis and either Betula lutea or B. papyrifera and occasionally Pinus strobus. (USDA 2006b, p. 139). Ground cover includes Carex spp. and ferns. Threats to V. paradoxa include habitat modification, such as timber harvesting, mining, grazing and other activities that decrease floral diversity. Examples of other threats include fire suppression, road construction and maintenance, pond construction, etc. Noxious weed treatment was also listed as a threat (Kudell-Ekstrum 2003e; NatureServe 2007). On the HNF, two locations are noted as important for the species (Kudell-Ekstrum 2003e).

Forest Plan Direction specific to this species Guideline: "management within the Niagara escarpment community should be designed to protect Hart's tongue fern element occurrences (USDA 2006a, p. 2-20). Note: might confer protection on Vertigo bollesiana, Vallonia gracilicosta and Vertigo paradoxa, species that are found mostly associated with cliff habitat associated with the Niagara escarpment. Guideline: Non-native invasive plants within element occurrences of threatened and endangered and Regional Forester Sensitive Species should be eliminated or controlled. (USDA 2006a, p. 2-17) Guideline: Adverse impacts to known occurrences of Regional Forester Sensitive Species should be avoided, minimized or mitigated. (USDA 2006a, p. 2-17) Guideline: The state of Michigan “Water Quality Management Practices on Forest Land” (BMPs) should be implemented as a minimum standard for managing forest resources on Forest System land. (USDA 2006a, p. 2-14)

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Analysis of Effects - Mollusks - Alternative 1 (No-Change)

Direct and Indirect Effects Implementing Alternative 1 would have no adverse effects on RFSS mollusks on the HNF over the period covered by this EA. Some NNIP sites would be allowed to persist or increase in size under Alternative 1. However, these terrestrial gastropods have been observed only on a few sites within the HNF, none of which have been identified as currently being adversely affected by NNIP infestations. There are also no known sites in imminent danger of future infestations that would result in adverse impacts to the species. Activities that reduce the spread and coverage of NNIP are not known to specifically benefit this group of species. However, information in Kudell-Ekstrum 2003d indicates that for V. paradoxa, activities that decrease floral diversity are a risk to the species. Thus, it might be reasoned that activities serving to increase floral diversity, such as NNIP control, might benefit the species over the long term. However, there are many uncertainties due to limited survey data across the Forest. The HNF would likely continue to remove approximately 30- 50 acres of invasive weeds through manual and mechanical means, using individual project decisions not associated with this EA. Due to Forest Plan management direction for wetland habitat, dune and shoreline habitat and TES management, we anticipate that it is likely a high priority would be placed on eradicating infestations with potential to adversely affect RFSS should circumstances dictate on the Forest. Surveys would be conducted in suitable habitat to identify occurrences and identify protections, both of which are consistent with the 2006 Forest Plan direction. Consequently, there would be no adverse impacts to RFSS mollusks from implementing Alternative 1.

Cumulative Effects Because the effects of implementing Alternative 1 on RFSS mollusks are considered to be minimal, the alternative would have no incremental effect when combined with the effects of past, present, or reasonably foreseeable future activities.

Analysis of Effects – Mollusks - Alternative 2 (Proposed Action)

Chemical Treatment – The data for chemical treatment methods are summarized in Table E-1, Table E-2 and Table E-3. Table E-3 presents a qualitative assessment of risk to organisms from information from several sources. There are no data specifically related to mollusks. Consequently, data from other organisms were referenced. The ecological risk assessments summarized in Table E-3 suggest that organisms directly contacted by spray streams could be affected, but that the herbicides proposed for use, in general, pose little risk to vertebrates and invertebrates. Mollusks could also be exposed to other herbicides entering their habitats from adjacent wetlands or in runoff from uplands. Design criteria No. 11 (p. 13) would render that threat a low risk by requiring a minimum 100-foot upland buffer in which only those herbicides labeled for aquatic use could be used. Table E-2 indicates that aquatic habitat compatible formulations of glyphosate (Rodeo) and

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triclopyr (triethylamine salt) are of low toxicity to daphnia, bluegill and rainbow trout and insects (Table 3). However, conservatively, we concluded that herbicide treatments may impact individuals of RFSS mollusks. Due to the design criteria (Nos. 1,2, 3, 5, 10, and 18, pp. 12-13) and protocol (No. 8, p. 11) that provide for oversight by the FS District biologist, parameters for herbicide application, surveys in suitable habitats, and the limited treatments anticipated for the habitats utilized by these species, the overall risks to RFSS mollusks from herbicide treatment is low.

Biological Control - All of the biological control insects have a proven record of use without adverse impacts on native insect populations (Van Driesche et al. 2002). All feed preferentially on the target NNIP species. Furthermore, releases of the insects would be performed manually from the road, away from any RFSS mollusks, eliminating the need to walk into habitat and risk physical disturbance. Consequently, the risk to RFSS mussels from this type of NNIP treatment is minimal.

All NNIP Control Methods - For all treatment methods (mechanical/manual, chemical and biological) human disturbance associated with Alternative 2 would be minimal because most applications would not require the use of motorized equipment. There may be some increases in noise and movement, in proximity to suitable habitats, but they are expected to be of minimal impact because all treatments would be temporary, localized and of short duration. Noise would not adversely impact the RFSS mollusks on the HNF. However, mollusks could be injured or killed by foot travel. Design criteria minimize the overall risk to this group. Other than the NNIP treatments in some gravel pits, there would be a low level of treatment in areas that constitute habitat for this group of species. It is possible that gravel pits have been disturbed to a level that they no longer constitute habitat for RFSS mussels. However, prior to NNIP treatment, a wildlife biologist would review treatment proposals to determine if surveys are warranted in gravel pits and other sites that constitute RFSS mollusk habitat (design criteria Nos. 2, 10 and 18, pp. 12-13)

Summary – Direct and Indirect Effects – Alternative 2 Over the period anticipated for control under this EA, we are unsure if beneficial effects would be realized by this group of species. There is, however, a slight risk of mortality to individuals from foot travel when using manual/mechnical and chemical methods. Design criteria under Alternative 2 would reduce this risk to the level that we consider to be very low.

Cumulative Effects The species in this group are relatively immobile and generally restricted to wetlands and exposed rock formations, depending upon the species. Thus, the cumulative effects area is determined to be the boundary of the HNF. The use of ATVs has the potential to negatively affect this group of species. Enforcement of current motorized use regulations and the completion of the motorized recreation use plan should help to identify areas were unauthorized use should be monitored. Rare mollusk sites with unauthorized ATV use located near private property have a greater likelihood of sustaining damage. Focused enforcement in these locations might decrease the threat. Protection of cobble beaches for piping plover may help certain species in this group. In certain areas, rock climbing, rappelling and other recreation use might threaten mollusks sites. But the extent of that threat is unknown. Vertigo bollesiana does not tolerate disturbances and appears limited to sites that have not been disturbed for at least 100 years and not highly impacted by management actions (Kudell-Ekstrum 2003c, p. 5). However, this species could be negatively impacted by rock-climbers and rappelling. Vertigo bollesiana, Vallonia gracilicosta albula and Vertigo paradoxa are found mostly associated with cliff habitat associated with the Niagara escarpment. Although some of the habitat for these species is within candidate Research Natural Areas and Wilderness, habitat possibly exists elsewhere that could be impacted by timber management, ATV use, trail construction, road construction, quarrying, rappelling or rock climbing. Vertigo morsei, Catinella exile and Euconulus alderi are found associated with a variety of wetland sites including tamarack-

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sedge wetlands, white cedar wetlands, fens and marl flats. A variety of management practices could occur in or near habitat for these species. Motorized recreation use, vegetation management and road construction may negatively affect habitat for RFSS mollusks. On the HNF, effects to watersheds would be reduced by implementing Forest Plan standards and guidelines. Impacts along certain roads and highways might change drainage patterns and affect Vertigo morsei, Catinella exile and Euconulus alderi, species that are associated with a variety of wetland sites. The Michigan DOT practices for road maintenance could possibly be affecting species in this group. Various construction projects by the public and others could also be affecting RFSS mussel. However, the extent of that threat is unknown.

Determination Alternative 1 – No impact Alternative 2 – May impact individuals; not likely to cause trend to listing or loss of viability

RFSS Insects Six insects are included on the most recent list of RFSS for the HNF. Four RFSS Insects of the species (green-faced clubtail, warpaint emerald, ebony boghaunter, and ringed boghaunter) are dragonflies. Of the remaining two species in Lake Huron locust Northern blue this group, one is a butterfly (Nabokov’s or northern blue) and one a locust Green-faced clubtail (Lake Huron locust). For the effects discussions, all of the dragonflies were Warpaint emerald grouped. Separate effects discussions are provided for northern blue and Ebony boghaunter Lake Huron locust. In all of the effects analyses, description of habitat and Ringed boghaunter ecology on the HNF appears first, and is followed by potential effects from each of the two proposed alternatives.

Lake Huron Locust (Trimerotropis huroniana) The Lake Huron locust is strictly ground dwelling, essentially never climbing on foliage or other supports (Rabe 1999, p. 1, Cuthrell 2003). On sunny, windless days, locusts are most common on sparsely vegetated sands, where they are evenly distributed with territories of several feet in diameter. In windy, overcast weather, individuals are densely distributed within the heavy dune grass cover, apparently seeking shelter. Host plant use by the Lake Huron locust is not restricted to grasses, although these probably make up a large portion of the diet. Dune grasses are among the most preferred species, but several dune forbs apparently are included in the diet. Three plant species were common to all sites with Lake Huron locusts, dune grass (Calamovilfa longifolia), beach grass (Ammophila breviligulata) and wild wormwood (Artemisia campestris). Other plant species may be important to the locust if it employs diet mixing as a nutritional strategy as do many other locusts. Frass (fecal) pellets have been analyzed by researchers to confirm that Lake Huron locust nymphs were feeding on four vascular plant species, including beach grass, wild wormwood, dune grass, and wheatgrass (Agropyron dasystachyum). Significant among the acceptable forbs is Pitcher’s thistle (Cirsium pitcheri), a federally protected species restricted to the dunes. It is thought that locust nymphs scavenge dead insects to supplement the nitrogen intake in their diet. Nitrogen is widely recognized as the most common limiting nutrient for herbivorous insects. The locust appears to be fairly randomly distributed in dune habitat with respect to plant species and seemed to eat most acceptable host plants, virtually at random, although some preference was shown for beach grass. Host plant specialization is not thought to be a factor limiting this species to shoreline

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dune habitats at this time. Lake Huron locusts do show significant preference for dry, loose sand substrates characteristic of shoreline dune habitats and not stabilized, wooded dunes or most inland habitats. The biological reason for this preference is not known. The largest, apparently most stable populations of the locust are associated with areas of extensive, wide dunes. Shorelines that are one mile or more in length with at least two sets of dunes containing blowout areas are ideal. The locust occurs along the Lake Michigan shoreline, including the offshore islands, from Mason to Emmet and Mackinac to Schoolcraft counties; the Lake Huron shoreline from Iosco to Cheyboygan and Mackinac to Chippewa counties; and the Lake Superior shoreline from Chippewa to Alger County (NatureServe 2007, USDA 2006b, pp. 152-154). Rabe (1999) indicates that Lake Huron locust can persist with low to medium levels of human disturbance, as long as the basic dune structure remains intact. Scholtens et al. (2005) surveys of lakeshore dunes on Lakes Michigan, Huron and Superior in Michigan indicate the species is fairly tolerant of disturbance and is “secure in Michigan” at present.

Threats by NNIP: Although we are aware of no Lake Huron locust populations being threatened, there are locations on the Forest where NNIP are present in proximity to Pitcher's thistle plants. Lake Huron locust is sometimes found in areas where this is present. Invasive plants such as sweet clover, spotted knapweed, leafy spurge, Canada thistle, bull thistle, and baby's breath have been identified as NNIP in Lake Michigan shoreline/dune habitat. The NNIP there, currently established in low numbers, have been removed manually since 2000 (USDA 2006b, p. 700).

Forest Plan Direction specific to this species Guideline: Management in the Great Lakes shoreline sand, dune/sand beach communities should be designed to protect Pitcher's thistle element occurrences. (USDA 2006a, p. 2-20). Guideline: The biological controls used to control non-native thistles should not be used unless it is determined that they have no negative effect on Pitcher's thistle (USDA 2006a, p. 2-20). Note: there are no biological control insects targeting thistles proposed in this project. Guideline: Non-native invasive plants within element occurrences of threatened and endangered and Regional Forester Sensitive Species should be eliminated or controlled. (USDA 2006a, p. 2-17) Guideline: Adverse impacts to known occurrences of Regional Forester Sensitive Species should be avoided, minimized or mitigated. (USDA 2006a, p. 2-17)

Analysis of Effects – Lake Huron locust - Alternative 1 (No Change)

Direct and Indirect Effects Implementing Alternative 1 would likely have minimal effect on Lake Huron locust over the period covered by this EA. Two Pitcher’s thistle sites, with occurrences of NNIP, are also suitable for Lake Huron locust. We anticipate the spread of NNIP into suitable habitat for Lake Huron locust would be patchy over the 5-year period of this EA and have minimal effect on the species. The Forest would likely continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical methods, using individual project decisions not associated with this EA. Some of this would likely occur near Pitcher’s thistle populations if NNIP were judged a threat. Due to Forest Plan management direction for dune and shoreline habitat and TES species management, we anticipate that it is likely a high priority would be placed on eradicating infestations with potential to adversely affect RFSS, such as Lake Huron locust, should such circumstances develop on the Forest. Consequently, there would be minimal adverse impacts to Lake Huron locust from implementing Alternative 1.

Cumulative Effects

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Because the effects of implementing Alternative 1 on Lake Huron locust are considered to be minimal, it would have little or no incremental effect when combined with the effects of past, present, or reasonably foreseeable future activities.

Analysis of Effects – Lake Huron locust - Alternative 2 (Proposed Action)

Mechanical or manual method of treatment - There is a risk of trampling individuals while removing moving about and pulling or cutting plants. Design criteria Nos. 10 and 19 (pp. 12-13), would serve to mitigate risks by requiring consultation with the local FS wildlife biologist, and required people conducting the treatments to be trained in identification of the species.

Chemical Treatment - The data for chemical treatment methods are summarized in Table E-1, Table E-2 and Table E-3. Table E-3 presents a qualitative assessment of risk to organism from information from several sources. The most relevant toxicological data for assessing impacts to insect species is the noted effect or risk to honeybees, as this animal is commonly used to evaluate toxicity for invertebrates. In Table E-2, the topical LD50 data for honeybees represent the quantities of active ingredient contacting the exterior surface of the honeybee that result in 50 percent mortality. A crude approach for estimating exposure of an insect that happens to fly under a hand- held spray boom at the time of application would be to assume that the top surface of the insect is roughly 1 square inch. If glyphosate is sprayed at a rate of 3.75 lb active ingredient per acre, a rate commonly used for general vegetation control (WSSA 2002), the insect would be exposed to roughly 6 X 10-6 lb (270 μg) of active ingredient. The estimated exposures exceed the corresponding topical LD50 values in Table E-1. Especially when uncertainties whether honeybee data actually reflects the assessed species, it is clear that insects directly contacted by herbicide spray could be adversely affected. Insects that contact wet foliage immediately after spraying could be similarly affected. Once the spray dries, it is unlikely that insects could be exposed to such high topical concentrations, even if they briefly land on treated foliage. The ecological risk assessments summarized in Table E-3 also suggest that insects directly contacted by spray streams could be affected, but that the herbicides proposed for use, in general, pose little risk to invertebrates. However, conservatively, we concluded that herbicide treatments may impact individuals of Lake Huron locust. The design criteria for herbicide use, such as buffer distances from rare plants, ensure a very low risk to non-target plants from careful spot treatment. Herbicide will not be sprayed in such a manner that it will drift onto Pitcher's thistle. This rare plant is associated with suitable Lake Huron locust habitat, so the insect would benefit from the protection. More importantly, design criteria Nos. 1, 2, 3, 5, 9, 10, 11, 19 and 20 (pp. 12-13) and protocol No. 8 (p. 11) provide for review and oversight by the FS district biologist, parameters for herbicide application and RFSS survey requirements, further reduce the overall risks to Lake Huron locust from herbicide treatment to a level we consider minimal.

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different ecological niches than insects in the Orders Orthoptera (includes locusts). Currently, on the HNF in shoreline and dune habitat, the NNIP populations are too small to support a population of the insects. In the event biological control insects were used, releases of the insects would be performed manually from the road, away from any Lake Huron locust habitat, eliminating the need to walk into habitat and risk physical disturbance. Thus, we conclude that use of biological controls would pose no risk of adverse impacts to Lake Huron locust.

Summary – Direct and Indirect Effects – Alternative 2 While any adverse effects from implementation of control methods would be relatively small and temporary, any beneficial effects from eliminating NNIP species from Lake Huron locust habitat (or protecting its habitat from being invaded) would be long term. Over the period anticipated for control under this EA, beneficial effects would be the primary impact to Lake Huron locust due to the potential for decrease in NNIP. This is because Lake Huron locust prefers open, sparely vegetated dunes (Cuthrell 2003, Rabe 1999). This would be expected to occur over time as control activities slow or stop the spead of NNIP into areas not currently infested. The benefit over the 5- year period of this EA is expected to be small. However, over a longer period of NNIP control, the result is expected to be a more diverse vegetative community on the Forest, and the spread of beneficial native plants, such as Pitcher’s thistle, both condition that theoretically could result in increased numbers of Lake Huron locusts.

Considering the design criteria and small magnitude of adverse impacts, any response by Lake Huron locust is likely to be positive. Any indirect beneficial effects resulting from NNIP control by improving vegetation diversity, cover, and sources of prey for this species could theoretically be greater under Alternative 2 because more treated acres would be possible. Under Alternative 2, NNIP control activities would have a higher level of certainty to be accomplished, since three methods of treatment could be employed to combat infestations. Potential adverse direct impacts from human disturbance and direct exposure to pesticide spray have been addresses with specific design criteria that decrease the risk to a level we consider minimal.

Cumulative Effects Because the risk of adverse impacts is minimal, implementing Alternative 2 will not add to any effects of past, present, or reasonably foreseeable future activities. The removal of NNIP from near and within suitable unoccupied dune and shoreline habitats may improve viability for Lake Huron locust in the long-term and offset adverse impacts elsewhere in suitable habitats. Great lakes shoreline development,, such as home construction, may have a negative effect on this species and reduce available habitat. Increased recreation use, such as OHV use, on the Great Lakes shoreline may also negatively affect this species. Shoreline habitat is unsuitable for most management activities, but illegal OHV use can potentially impact Lake Huron Locust habitat. Highway U.S. 2 runs through one of the Pitcher's thistle sites and could introduce or re-introduce NNIP into suitable or occupied habitat for Lake Huron locust (USDA 2006b, p. 699). Coordination with MI DOT is an important aspect of NNIP control on the HNF. It would continue under Alternative 2.

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Nabokov's or northern blue (Lycaeides idas nabokovi) The species has a one-year life cycle. Adults are found starting from late-june in southern areas and persist through July. Males patrol open areas of the host plant, Vaccinium caespitosum and other Vaccinium, and atempt to mate with females. Females lay eggs singly on the host plant or underneath the plant on other debris or vegetation. Eggs overwinter, and the larvae hatch in May and pupate in June, possibly slightly later in upper Michigan Adults of both sexes feed on a variety of nectar-bearing plants such as clovers, yarrow, Potentilla, harebells, and others. Larvae feed only on the host plant. Larvae and pupae are usually tended by Formica sp. ants. Resting adults show little preference for roosting plants. Forest habitats around the breeding locations are often pine with shrubs, and occasionally upland black spruce. Bracken fern is often present at the forested edge of the openings. Other vegetation includes various Vaccinium, lichens, mosses, Carex pennsylvanic and Viola pubescens. The host plant requires natural or manmade openings on poor soils. This may be sand or thin soils over bedrock. Vegetative encroachment, both woody and herbaceous, and conifer plantings threatens these sites. Manual removal is often preferable to poorly planned burnings to maintain openings, because all phase of the life cycle of L. i. nabakivi are sensitive to fire, and V. caespitosum is susceptible to excessive fire. Parasitism of eggs is a major source of annual mortality, but it has not been established whether the parasites are native or introduced. Exotic plants may colonize disturbed areas and outcompete V. caespitosum. On the HNF, the northern blue butterfly population depends on dwarf bilberry abundance. Dwarf bilberry is a RFSS, and measures will be taken to prevent adverse impacts. These protection measures will also help protect the northern blue butterfly. (NatureServe 2007, USDA 2006b, pp. 143-145)

Threats by NNIP: We are aware of no northern blue butterfly populations being adversely affected by NNIP on the HNF.

Forest Plan Direction specific to this species Guideline: Bacillus thuringiensis (BT) should not be sprayed in the vicinity of dwarf bilberry populations due to the host relationship with the northern blue butterfly. (USDA 2006a, p. 2-17) Guideline: Non-native invasive plants within element occurrences of threatened and endangered and Regional Forester Sensitive Species should be eliminated or controlled. (USDA 2006a, p. 2-17) Guideline: Adverse impacts to known occurrences of Regional Forester Sensitive Species should be avoided, minimized or mitigated. (USDA 2006a, p. 2-17)

Analysis of Effects – Northern blue - Alternative 1 (No Change)

Direct and Indirect Effects There are no known NNIP infestations threatened to result in adverse impacts to northern blue or its host plant, dwarf bilberry (pp. 79-81, open/dry beach habitat). We anticipate the spread of NNIP into suitable habitat for dwarf bilberry and northern blue would be patchy over the 5-year period of this EA. The Forest would likely continue to remove approximately 30-50 acres of invasive weeds

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through manual and mechanical means, using individual project decisions not associated with this EA. Some of this would likely occur near dwarf bilberry (a plant RFSS) populations if NNIP were judged a threat. Due to Forest Plan management direction for protecting sensitive habitat and TES, we anticipate that it is likely a high priority would be placed on controlling infestations with potential to adversely affect RFSS should such circumstances develop on the Forest. Consequently, we have determined there would be minimal adverse impacts to northern blue from implementing Alternative 1.

Cumulative Effects There would be no measurable adverse effects to add cumulatively to past present or reasonably foreseeable actions that would affect northern blue. The control effort, if coordinated with state, county and other landowners would reduce invasive plants, but not likely as efficiently and rapidly as Alternative 2. Failure of other landowners to control NNIP could counteract gains on the HNF. Fire management is an important aspect of this species biology. Continued management of prescribed fire by the USFS, MDNR and other landowners would benefit the species. Great lakes shoreline and dune development such as home construction may have a negative effect on this species and reduce available habitat. Increased recreation use such as OHV use on the Great Lakes shoreline and in dunes may negatively affect this species. If these conditions become realized, conservation effects on the HNF would assume greater importance.

Analysis of Effects – Northern blue - Alternative 2 (Proposed Action)

Direct and Indirect Effects Under Alternative 2, a combination of mechanical, chemical and biological control methods would be used to reduce or eradicate NNIP on an average of approximately 40-70 acres a year with a potential for up to 200 acres a year if funding allowed. The primary impacts from controlling NNIP infestations would be beneficial for northern blue butterfly on the HNF, especially in perpetuating the host plant, dwarf bilberry. The program would help prevent the degradation of open/dry beach habitat favored by northern blue. Design criteria, project protocol and 2006 Forest Plan management direction combine to create guidance that would lessen risk of adverse impacts.

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be similarly affected. Once the spray dries, it is unlikely that insects could be exposed to such high topical concentrations, even if they briefly land on treated foliage. The ecological risk assessments summarized in Table E-3 also suggest that insects directly contacted by spray streams could be affected, but that the herbicides proposed for use, in general, pose a little risk to invertebrates. However, conservatively, we concluded that herbicide treatments may impact individuals of northern blue butterfly. The design criteria for herbicide use, such as buffer distances from rare plants, ensure a very low risk to non-target plants from careful spot treatment. Herbicide will not be sprayed in such a manner that it will drift onto dwarf bilberry. This rare plant is the larval host plant for northern blue butterfly, so the insect would benefit from its protection. Furthermore, design criteria Nos. 1, 2, 3, 5, 9, 10, 11, 19 and 20 (pp. 12-13) and protocol No. 8 (p. 11) provide for review and oversight by the FS district biologist, parameters for herbicide application and RFSS survey requirements, further reduce the overall risks to northern blue from herbicide treatment to a level we consider minimal.

Biological Control - The biological control agents proposed for use on the HNF are vegetation eating insects (Table I-7). There is no evidence to suggest they would compete with native insects, including northern blue butterfly adults and larvae for plant food and other resources. All of the agents have a proven record of use without adverse impacts on native insect populations (Van Driesche et al. 2002). All feed preferentially on the target NNIP species, thus obtaining food from plants that are generally not attractive to native insects. All are beetles or weevils in the Order Coleoptera, with distinctively different ecological niches than insects in the Order Lepidoptera (includes the butterflies). In the event biological control insects were used, releases of the insects would be performed manually from the road, away from any northern blue butterfly habitat, eliminating the need to walk into habitat and risk physical disturbance. Thus, we conclude that use of biological controls would pose no risk of adverse impacts to northern blue butterfly.

Summary – Direct and Indirect Effects – Alternative 2 While any adverse effects from implementation of control methods would be relatively small and temporary, any beneficial effects from eliminating NNIP species from this insect’s habitat (or protecting habitat from being invaded) would be long term. Over the period anticipated for control under this EA, beneficial effects would be the primary impact to northern blue due to the potential for a decrease in NNIP. This is because northern blue prefers open habitats (Cuthrell 2001, USDA 2006b, pp. 143-145). Treatments inside and outside of habitat for this species would have benefits over time as control activities slow or stop the spread of NNIP into areas not currently infested. The benefit over the 5-year period of this EA is expected to be small. However, over a longer period of NNIP control, the result is expected to be a more diverse vegetative community on the Forest, and the spread of beneficial native plants, such as dwarf bilberry, both conditions that theoretically could result in increased numbers of this rare insect.

Considering the design criteria and small magnitude of adverse impacts, any response by northern blue butterfly is likely to be positive. Any indirect beneficial effects resulting from NNIP control by

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improving vegetation diversity, cover, and sources of prey for this species could theoretically be greater under Alternative 2 because more treated acres would be possible. Under Alternative 2, NNIP control activities would have a higher level of certainty to be accomplished, since three methods of treatment could be employed to combat infestations. Potential adverse direct impacts from human disturbance and direct exposure to pesticide spray have been addresses with specific design criteria that decrease the risk to a level we consider minimal.

Cumulative Effects Direct and indirect effects are minimal under Alternative 2. There would be no measurable adverse effects to add cumulatively to past present or reasonably foreseeable actions that would affect northern blue. Any adverse effects of manual/mechanical, herbicide and biological control methods would be small, temporary and very localized. Overall, there would be benefits gained for this species from reduced negative effects of invasive plants. The control effort, if coordinated with state, county and other landowners would reduce, control or slow encroachment of NNIP. Failure of other landowners to control NNIP could counteract gains on the HNF. Fire management is an important aspect of this species biology. Continued management of prescribed fire by the USFS, MDNR and other landowners would benefit the species. Great lakes shoreline and dune development such as home construction may have a negative effect on this species and reduce available habitat. Increased recreation use such as OHV use on the Great Lakes shoreline and in dunes may negatively affect this species. If these conditions occur, conservation effects on the HNF would assume greater importance.

Dragonflies

Most of the rare insects on the HNF are dragonflies. With the possible exception of the green-faced clubtail, all of the rare dragonflies on the HNF prefer bog/fen habitat, with adults also foraging in edge and openings nearby. The green-faced clubtail utilizes streams and rivers with rocky substrate. Both boghaunter species and the warpaint emerald are found in the same areas and appear to use similar habitat. All of the dragonflies are grouped in this BE due to commonality that all occupy wet areas. Two major threats for this group are vehicular traffic and changes to the water table or hydrology.

Green-faced clubtail dragonfly (Gomphus viridifrons/Hylogomphus viridifrons) Habitat consists of rocky streams with high quality oxygenated water associated with high and moderate gradient medium-sized rivers and medium to large sized clean streams. Others list habitat as clear rocky rivers and streams with a mixture of gravelly sand and silt among rocks. Away from the water, this species rests on foliage of trees or herbaceous plants; occasionally perch on rocks in water or on “shoreside bushes” (Langstaff, 2006). This dragonfly is apparently sensitive to pollution, siltation and/or low levels of dissolved oxygen. Threats include impoundments, channelization, dredging, siltation, agricultural non- point pollution and industrial and municipal pollution (NatureServe 2006). As with other species in the genus Gomphus, this species larva are

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sediment burrowers, their feeding strategy is lie-in- wait for prey from their burrows. Sediment in amounts that do not alter habitat for their invertebrate prey may be tolerable to this species. In general, the Upper Peninsula provides extensive habitat and less risk than habitat elsewhere in the state of Michigan. The 2001 University of Michigan Odonta Survey Master Database contains 1 previous Michigan record of this species, this observation is questionable and needs to be verified Dragonfly surveys in 2003 revealed one known occurrence in the Upper Peninsula, west unit of the Hiawatha NF. Wetland protections in the Forest Plan and in State BMP’s reduce risk to habitat (Langstaff, 2006).

Warpaint emerald (Somatochlora incurvata) This species is also known by the common name, incurvate emerald. Warpaint emerald dragonflies use bog/fen habitat throughout the eastside of the HNF. This species has three life stages (egg, larva, and adult). The egg and larva stage occur in bog/fen habitat, but, as an adult, the species forages in a variety of openings including roadways (NatureServe 2005). It is a rarely encountered species in part because its boggy habitat is difficult and unpleasant to sample during the adult flight season, and extremely difficult to sample for larvae. There are undoubtedly additional, undiscovered occurrences on the forest. Surveys several miles north of Trout Lake in 2001 discovered the species at numerous locations in a large block of mostly contiguous bog and black spruce-jack pine bog forest. This species has been considered uncommon throughout its range, but is probably more common than is thought. It was originally discovered and described from Michigan’s Upper Peninsula, and has since been found in only a half-dozen states and several provinces. Recent surveys are finding it in more locations, both locally and internationally. Peat mining and disturbance to the water and water table are the major threats. Wetland loss is a threat. Roadkill occurs and is of unknown threat magnitude. Enhancing waterfowl habitats by flooding may destroy habitat for this species. (NatureServe 2005; USDA 2006b, pp. 147-148)

Ebony Boghaunter (Williamsonia fletcheri) The ebony boghaunter dragonfly uses bog/fen habitat throughout the eastside of the HNF. The egg and larva stages occur in bog/fen habitat within forested lands. Adults forage in a variety of openings, locations which can include roadways. Sunlit clearings in the forest are used by adults in territorial flights, especially near breeding habitat, which makes forest clearing and fragmentation potentially deleterious to species viability (NatureServe 2006). Williamsonia fletcheri is small and very dark with bright rings at base of abdomen. Flight is early and very short. The species is not very active and has been observed to perch on the ground or on dead branches. The species ranges across northern tier of U.S. from Maine to Minnesota and north in to Canada. The 2006 University of Michigan Odonata Survey Master Database contains 22 Michigan records of the species, with 18 records for the U.P. Seven of the records are inside the proclamation boundary of the HNF in Chippewa County. In 1991, the first specimen from the HNF on the Eastside of the Forest were identified The next observations of the species also occurred on the Eastside in Chippewa County in 2003, when multiple individuals were seen and one voucher specimen was taken. Since then, at least four more specimens have been collected from different sites on the HNF. The species is difficult to survey since the bog habitat is often in remote locations and it can be difficult to time the survey correctly to find target individuals in flight. It may be quite common in Michigan, but currently there is little supporting documentation. Michigan water quality BMP’s and wetland protections are in place to reduce risks to habitat. The amount of potential habitat on the HNF for W. fletcheri is substantial, and is estimated at greater than 4,000 acres (Langstaff 2006b).

Ringed Boghaunter (Williamsonia lintneri) The ringed boghaunter dragonfly uses bog/fen habitat, as well as openings on the HNF. The egg and larva stages occur in bog/fen habitat, but, as an adult, the species forages in open woods. Characteristic habitats for ringed boghaunter are shallow bog pools and acid fens with sparse

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shrub cover and wiry sedges(Langstaff 2006c). Adults are usually found in adjacent woodlands either basking on the ground in openings or on tree trunks, while the larvae cling to vegetation or other organic substrate in open pools. The current known distribution of the species is throughout the coastal New England states (Maine, New Hampshire, Massachusetts, Rhode Island, and Connecticut) with isolated populations known from Michigan and Wisconsin (NatureServe, 2006). Dragonfly surveys for sensitive species have been conducted on the HNF since the late 1990’s, but Williamsonia lintneri was not considered a target species until 2003. Until this time, no individuals had been observed on the HNF(Langstaff 2006c). During the 2003 surveys, two sites for W. lintneri were found on the HNF, one in Chippewa County and one in Delta County. These were the first records for the species in the Upper Peninsula of Michigan. Two additional sites have been found in Chippewa County since then (Langstaff 2006c). The bog habitat that this species uses requires considerable effort to access, and it can be difficult to time the surveys correctly to find individuals in flight. Clearing forested uplands, filling in wetland habitats, use of pesticides, pollution, ditching, and water-level manipulations are the main threats to the species. On the Hiawatha National Forest, Michigan state BMP’s and wetland protections reduce risks to key habitats. Since timber harvest is a common management practice on the HNF, residual forested buffer strips must be maintained adjacent to occupied and potential habitat (Langstaff 2006c).

Threats by NNIP: We are aware of RFSS dragonfly populations being adversely affected by NNIP on the HNF.

Forest Plan Direction specific to RFSS Dragonflies and this project Guideline: Yellow rail – Graminoid/sedge marshes are maintained or improved to provide suitable habitat conditions. (USDA 2006a 2-18) Note: indirectly benefits RFSS dragonflies Guideline: Non-native invasive plants within element occurrences of threatened and endangered and Regional Forester Sensitive Species should be eliminated or controlled. (USDA 2006a 2-17) Guideline: Adverse impacts to known occurrences of Regional Forester Sensitive Species should be avoided, minimized or mitigated. (USDA 2006a 2-17) Guideline: The state of Michigan “Water Quality Management Practices on Forest Land” (BMPs) should be implemented as a minimum standard for managing forest resources on Forest System land. (USDA 2006a 2-14)

Analysis of Effects - Dragonflies - Alternative 1 (No-Change)

Direct and Indirect Effects Implementing Alternative 1 would have no adverse effects on RFSS dragonflies on the HNF over the period covered by this EA. Some NNIP sites would be allowed to persist or increase in size under Alternative 1. However, no RFSS dragonfly sites have been identified that are currently being adversely affected by NNIP infestations. There are also no known sites in imminent danger of future infestations that would result in adverse impacts to the species. Invasive weeds, such as purple loosestrife, may, however, be transported into suitable habitat as a result of road construction, road use or a number of other vectors. If these weeds become established, they might displace native vegetation, which is potentially more suitable habitat. Activities that reduce the spread and infestation of NNIP are thought to be of benefit for Hine’s emerald dragonfly by maintaining native plant diversity (USFWS 2006, p. 219). This suggests that other dragonflies having similar ecology and habitats might benefit also, and possibly realize enhanced reproductive success and survival rates. The HNF would likely continue to remove approximately 30-50 acres of invasive weeds through manual and mechanical means, using individual project decisions not associated with this EA. Due to Forest Plan management direction for wetland habitat and rare species management, we anticipate that it is likely a high priority would be placed on eradicating infestations with potential

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to adversely affect RFSS, such as the HNF TES dragonflies should such circumstances develop on the Forest. Consequently, there would no adverse impacts to RFSS dragonflies from implementing Alternative 1.

Cumulative Effects Because there are no effects from implementing Alternative 1 on RFSS dragonflies there would be no incremental effect when combined with the effects of past, present, or reasonably foreseeable future activities.

Analysis of Effects – Dragonflies - Alternative 2 (Proposed Action)

Direct and Indirect Effects Under Alternative 2, a combination of mechanical, chemical and biological control methods would be used to control, reduce or eradicate NNIP on an average of approximately 40-70 acres a year with a potential for up to 200 acres a year if funding allowed. The primary impacts from controlling NNIP infestations would likely be beneficial. The program would help prevent the degradation of wetland and riparian habitats favored by RFSS dragonflies on the HNF. Treatments of NNIP outside of habitat used by RFSS dragonflies would help to keep uninvaded habitat NNIP-free. Design criteria, project protocol and 2006 Forest Plan management direction combine to create guidance that would lessen risk of adverse impacts.

Mechanical or manual method of treatment – At the approximate maximum of 200 acres per year, actions to reduce NNIP should result in minimal or discountable effects to this group of species. Noise from manual and mechanical treatments, such as use of the weed torch, brush cutter and saw in the immediate vicinity of breeding and foraging sites would not disturb RFSS dragonflies.

Chemical Treatment - The data for chemical treatment methods are summarized in Table E-1, Table E-2 and Table E-3. Table E-3 presents a qualitative assessment of risk to organism from information from several sources. The most relevant toxicological data for assessing impacts to insect species is the noted effect or risk to honeybees, as this animal is commonly used to evaluate toxicity for invertebrates. In Table E-2, the topical LD50 data for honeybees represent the quantities of active ingredient contacting the exterior surface of the honeybee that result in 50 percent mortality. A crude approach for estimating exposure of an insect that happens to fly under a hand- held spray boom at the time of application would be to assume that the top surface of the insect is roughly 1 square inch. If glyphosate is sprayed at a rate of 3.75 lb active ingredient per acre, a rate commonly used for general vegetation control (WSSA 2002), the insect would be exposed to roughly 6 X 10-6 lb (270 μg) of active ingredient. The estimated exposures exceed the corresponding topical LD50 values in Table E-1. Especially when uncertainties whether honeybee data actually reflects the assessed species, it is possible that insects directly contacted by herbicide spray could be adversely affected. Insects that contact wet foliage immediately after spraying could be similarly affected. Once the spray dries, it is unlikely that insects could be exposed to such high topical concentrations, even if they briefly land on treated foliage. The ecological risk assessments summarized in Table E-3 also suggest that insects directly contacted by spray streams could be affected, but that the herbicides proposed for use, in general, pose little risk to invertebrates. However, conservatively, we concluded that herbicide treatments may impact individuals of RFSS dragonflies. The design criteria for herbicide use, specifically Nos. 1, 2, 3, 5, 10, 11, 13 and 14 (pp. 12-13) and protocol No. 8 (p. 11) provide for review and oversight by the FS district biologist, parameters for herbicide application and RFSS survey requirements, further reduce the overall risks to RFSS dragonflies from herbicide treatment to a level we consider minimal. Protections and mitigation are built into the HNF NNIP Control project:

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1) All treatments proposed for RFSS dragonfly habitat (wet meadows, fens, bogs, riparian sites, and other wet areas) would be reviewed by a wildlife biologist (design criteria No. 10, p. 12); activities would be stopped and/or modified if it is determined that harm could result to RFSS. 2) Design criteria No. 14 (p. 13) directs that movement in RFSS dragonfly habitat should be minimized if treatment is determined necessary through the wildlife biologist’s review. 3) No treatment would occur in RFSS dragonfly habitat from the second week in April until the end of August (This corresponds to approximately two weeks before and two weeks after the adult flight period) (criteria No. 13, p. 13) 4) There are also buffers required around wet areas to ensure that only those herbicides with formulations approved for aquatic use can be used (criteria No. 11, p. 13) (It is based on guidance in Michigan BMPs (MDNR 1994) - The minimum upland buffer is 100 feet in width); and, 5) Spot herbicides treatments are to be used over broadcast spraying (protocol 8, p. 11).

Biological Control - The biological control agents proposed for use on the HNF are vegetation consuming insects (Table I-7). There is no evidence to suggest they would compete with native insects, including RFSS dragonfly adults and larvae, for plant food and other resources. All of the agents have a proven record of use without adverse impacts on native insect populations (Van Driesche et al. 2002). All feed preferentially on the target NNIP species, thus obtaining food from plants that are generally not attractive to native insects. All are beetles or weevils in the Order Coleoptera, with distinctively different ecological niches than insects in the Order Odonata (includes the dragonflies). The risk of adverse effects through competition with the rare native insects described above is therefore discountable, even if the target NNIP species is eradicated. Releases of biological control agents would be performed manually from the road, away from any RFSS dragonfly habitat, eliminating the need to walk into habitat and risk physical disturbance. There are several insects specified that are effective against purple loosestrife, a potential NNIP that could adversely impact dragonfly habitat in the future. Activities that reduce the spread and infestation of NNIP are thought to be of benefit for the species by maintaining native plant diversity, which might enhance reproductive success and survival rates (USFWS 2006, 219). We conclude that use of biological controls would pose no risk to RFSS dragonflies.

All NNIP Control Methods - For all treatment methods (mechanical/manual, chemical and biological) human disturbance associated with Alternative 2 would be minimal because most applications would not require the use of motorized equipment. NNIP treatments in habitats used by RFSS dragonflies would occur in only a small portion of the annual treatments on the Forest. There may be some increases in noise and movement, in proximity to suitable habitats, but they are expected to be of minimal impact because all treatments would be temporary, localized and of short duration. Noise would not adversely impact RFSS dragonflies. Design criteria reduce or eliminate the risks of trampling individuals, eggs and larvae, as well as other threats (see design criteria Nos. 1, 2, 4, 5, 10, 11, 13 and 14). For all treatments, work in areas of suitable or occupied habitat would be limited and monitored by a wildlife biologist (see design criteria). Herbicide buffers would be used to ensure that only those herbicides labeled for wetlands would be used in and near dragonfly breeding habitat (design criteria 11, p. 13).

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items and eventually the RFSS dragonflies. The benefit over the 5-year period of this EA is expected to be small. However, over a longer period of NNIP control, the result is expected to be a more diverse vegetative community on the Forest, a condition that theoretically could result in increased numbers of these rare insects.

Considering the design criteria and small magnitude of adverse impacts, any response by RFSS dragonflies is likely to be positive. Any indirect beneficial effects resulting from NNIP control by improving vegetation diversity, cover, and sources of prey for this species could theoretically be greater under Alternative 2 because more treated acres would be possible. Under Alternative 2, NNIP control activities would have a higher level of certainty to be accomplished, since three methods of treatment could be employed to combat infestations. Potential adverse direct impacts from human disturbance and direct exposure to pesticide spray have been addresses with specific design criteria that decrease the risk to a level we consider minimal.

Cumulative Effects Because the risk of adverse impacts is minimal, implementing Alternative 2 will not add to any effects of past, present, or reasonably foreseeable future activities. The removal of NNIP from near and within suitable habitats may improve viability for RFSS dragonflies, albeit over the long-term and offset adverse impacts elsewhere in suitable habitats. Great lakes shoreline development such as home construction may have a negative effect on this group and reduce available habitat. Increased recreation use such as OHV use on the Forest may also negatively affect RFSS dragonflies. Wetland habitats are unsuitable for most management activities, but illegal OHV use can potentially impact occupied locations or locations that are suitable but as yet unoccupied.

Determination Alternative 1 – No impact Alternative 2 – May impact individuals; not likely to cause trend to listing or loss of viability

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SUMMARY OF DETERMINATIONS

This section includes determinations of effects for federal threatened and endangered (T&E) species (Table D-1) and Regional Forester Sensitive Species (RFSS) (Table D-2).

Table D-1. Federally-listed threatened and endangered (T&E) species – Summary of Determinations of Effects

ALTERNATIVE 1 ALTERNATIVE 2 SPECIES EVALUATED PLANTS Dune thistle NLAA NLAA Lakeside daisy NLAA NLAA Dwarf lake iris NLAA NLAA Hart's tongue fern NLAA NLAA Houghton's goldenrod NLAA NLAA ANIMALS Bald eagle NE NLAA Canada lynx NE NLAA Gray wolf NE NLAA Hine's emerald dragonfly NE NLAA Hine's emerald dragonfly critical NE NLAA habitat* Kirtland's warbler NE NLAA Piping plover NLAA NLAA Piping plover critical habitat NE NLAA NE - No effect; NLAA - May affect, not likely to adversely affect; LAA - May affect, likely to adversely affect * - This is proposed critical habitat - the USFWS has not published the final decision on critical habitat as of 3/2007.

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Table D-2. Regional Forester Sensitive Species (RFSS) and Likely to occur RFSS (LRFSS) - Determinations of Effects

ALTERNATIVE 1 ALTERNATIVE 2 SPECIES or GROUP EVALUATED PLANTS Aquatic plant habitat MINT MINT Open/wet habitat MINT MINT Open/dry & Beach habitat MINT MINT Shaded/wet habitat MINT MINT Shaded habitat MINT MINT ANIMALS Mammal Gray wolf* NI MINT Birds Raptors NI MINT Wetland birds NI MINT Grassland/Shrub birds NI MINT Black-backed woodpecker NI MINT Connecticut warbler NI MINT Bald eagle* NI MINT Reptile Blanding’s turtle NI MINT Fish Lake Sturgeon NI MINT Mollusks Mollusks NI MINT Insects Lake Huron locust MINT MINT Northern blue (butterfly) MINT MINT Dragonflies NI MINT NI - No Impact; BI - Beneficial Impact; MINT - May impact individuals but not likely to cause a trend to federal Listing or loss of viability; MILT - May impact individuals but likely to cause a trend toward federal listing or loss of viability. * bald eagle and gray wolf were also evaluated as RFSS due to the likelihood of removal from T&E list

Likely to Occur RFSS

There are 21 "likely to occur" plant species identified in the 2006 Forest Plan BE (USDA 2006b, p. 712). These RFSS occur on other national forests in the Forest Service’s Eastern Region and have suitable habitat on the HNF. Botanical searches include these plants as well as other species that are of concern in Michigan. We have found no occurrences of these plants to date. The plants were grouped with the known RFSS in plants analysis section, above. They are also listed in Appendix A, Table 4. In the event any are discovered in the execution of this project, they would be duly recorded and offered the protection described for RFSS species in the Forest Plan (USDA 2006a, p. 2-17).

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MONITORING

Treatments implemented under Alternatives 2 would be monitored to ensure that they effectively control the targeted NNIP infestations. Repeated treatments or alternate treatments would be implemented if initial treatments do not adequately control the target infestations. It is expected that certain treatments would require repeated applications at the same sites in succeeding years. For example, crews cutting or mowing NNIP vegetation could miss individual plants, NNIP species could regenerate from residual seed, herbicide sprays could fail to kill certain individuals in a treated stand, or buckthorn or honeysuckle shrubs that are cut and the surfaced treated with herbicide could still regenerate sprouts. Repeated applications would count against the proposed acreage thresholds for both the initial treatment year and the repeated treatment year(s).

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APPENDIX A: SPECIES CONSIDERED

APPENDIX A: TABLE 1. Federally Listed Species - Endangered (E) Threatened (T)

Common Name Scientific Name Habitat # EOs

Plants American hart’s tongue Phillitis (Asplenium) shade - alvar/rock, mesic 6 fern (T) scolopendrium v. americanum forest Pitcher’s thistle (T) Cirsium pitcheri open - dune 2 open / wet - interdunal Lakeside daisy Hymenoxys herbacea 1 wetlands, alvar Dwarf lake iris (T) Iris lacustris open - dune, beach 3 open - dune, beach, Houghton’s goldenrod (T) Solidago houghtonii 9 interdunal wetland Michigan Monkey-flower - Mimulus glabratus var. shaded / wet - springs, 0 "likely" (E) michiganensis seeps in cedar swamps Animals mosaic of forested uplands Gray wolf (E) Canis lupus and lowlands, young forest small size, densely stocked Kirtland's warbler (E) Dendroica kirtlandii jack pine Great Lakes shoreline, Piping plover (E) Charadrius melodus beach marsh, fen, sedge Hine's emerald dragonfly Somatochlora hineana meadow w/calcareous (E) substrate lakes, rivers, shorelines Bald eagle (T) Haliaeetus leucocephalus and riparian edge, mosaic of forested uplands Canada lynx (T) Lynx canadensis and lowlands, young forest

APPENDIX A: TABLE 2. Regional Forester Sensitive Species (RFSS) - Plants # Common Name Scientific Name Habitat EOs Vascular Plants-RFSS Climbing fumitory Adlumia fungosa shade - mesic forest, calcareous 1 Round-leaved orchis Amerorchis rotundifolia shade - old cedar swamp 2 Lake cress Amoracia lacustris aquatic - spring fed 1 Walking fern Asplenium rhizophyllum shade - mesic forest, rock 13 Asplenium trichomanes Green spleenwort shade - mixed forest, rock 13 ramosum Canadian milk-vetch Astragalus canadensis open - beach 4 Cooper’s milk-vetch Astragalus neglectus open - beach 1 American sloughgrass Beckmannia syzigachne open - marsh Prairie moonwort Botrychium campestre open - dune, prairie w/ limestone 2 Botrychium michiganense open & shade - mesic field, Michigan moonwort 2 (hesperium) forested dune Goblin moonwort Botrychium mormo shade - mesic forest 2 Blunt-lobed grapefern Botrychium oneidense shade - mesic to dry mesic

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APPENDIX A: TABLE 2. Regional Forester Sensitive Species (RFSS) - Plants # Common Name Scientific Name Habitat EOs forest Pale moonwort Botrychium pallidum open - meadow, field, dune 3 Ternate grape fern Botrychium rugulosum open - pine barrens Spathulate moonwort Botrychium spathulatum open - dune 5 Autumnal water-starwort Callitriche hermaphroditica aquatic 1 Calypso orchid Calypso bulbosa shade/wet conifer swamp 13 Beauty sedge Carex concinna shade - boreal forest, limestn 2 shade - wet forest, bog/fen, Hudson Bay sedge Carex heleonastes 1 muskeg shade - mesic to dry mesic New England sedge Carex novae-angliae 2 forest Richardson sedge Carex richardsonii open - beach, alvar Bulrush sedge Carex scirpoidea open wet - beach, alvar Wiegand’s sedge Carex wiegandii open wet - bog, poor fen 15 Douglas’s Hawthorn Crataegus douglasii shade - forested dunes, barrens 1 shade - mesic forest calcareous Slender cliff brake fern Cryptogramma stelleri rock Cynoglossum virginianum var. shade - mesic to dry mesic Northern wild comfrey 16 boreale mixed forest Ram’s head lady slipper Cypripedium arietinum shade/wet - conifer swamp 4 shade - forest with calcareous Laurentian bladder fern Cystopteris laurentiana 2 rock open - interdunal wetland, English sundew Drosera anglica 1 bog/fen Spreading wood fern Dryopteris expansa shade - mesic forest 4 Male fern Dryopteris filix-mas shade - mesic forest 1 open wet - beach, marsh, shore, Flattened spike-rush Eleocharis compressa 1 calcareous Blue wild-rye Elymus glaucus open - beach, forest edges 1 Black crowberry Empetrum nigrum open - Lake Superior beach <10 Hyssop-leaved fleabane Erigeron hyssopifolius open wet - beach, marly pools 4 Northern three-lobed Galium brevipes shade - interdunal conifer forest 2 bedstraw Northern wild licorice Galium kamtschaticum shade - mesic forest, seeps 2 shade - calcareous conifer Limestone oak fern Gymnocarpium robertianum 2 swamp Downy sunflower Helianthus mollis open - barrens, prairie 1 open wet - alvar, interdunal Fir clubmoss Huperzia selago 6 wetlands Butternut Juglans cinerea shade - mesic forest 19 Moor rush Juncus stygius open wet - bog, poor fen 1 Vasey’s rush Juncus vaseyi open wet - interdunal wetland 1 Dune grass Leymus mollis open - dune, beach 1 shade - shrub, streambank, Auricled twayblade Listera auriculata 1 sand American shoregrass Littorella uniflora aquatic - sandy edge of lake 2 Small flowered wood rush Luzula parviflora shade - mesic forest openings Northern prostrate club moss Lycopodiella margueritae open wet - wet meadow, marsh White adder’s mouth Malaxis brachypoda shade - conifer swamp 9 Mat muhly Muhlenbergia richardsonis open wet - bog, wet meadow

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APPENDIX A: TABLE 2. Regional Forester Sensitive Species (RFSS) - Plants # Common Name Scientific Name Habitat EOs Alternate-flowered water aquatic - soft water lakes, Myriophyllum alterniflorum milfoil streams Omalotheca (Gnaphalium) shade - mesic forest edges, Woodland cudweed 4 sylvatica sand open & shade - swamp, bog, Plains Ragwort Packera (Senecio) indecora 1 beach open wet - fen, bog, wet Sweet-coltsfoot Petasites sagittatus 4 meadow Butterwort Pinguicula vulgaris open wet - moist cliff, fen, bog 2+ Piptatherum (Oryzopsis) open - barrens, edge of dry pine Canada rice-grass 12 canadense forest Algal pondweed Potamogeton confervoides aquatic - acid bog lakes shade - dry mesic to mesic Pine drops Pterospora andromeda 4 forest Lapland buttercup Ranunculus lapponicus shade - conifer swamp 3 open wet - fen, bog, edge of Dwarf raspberry Rubus acaulis 1 swamp open wet - beach of lake or Satiny willow Salix pellita 1 stream, marsh open wet - marsh, beach, wet Torrey’s bulrush Schoenoplectus (Scirpus) torreyi 1 meadow Prairie dropseed Sporobolus heterolepis open - prairie, barrens, alvar 1 Long-stalked stitchwort Stellaria longipes open - dune, beach 1 Tanacetum bipinnatum ssp. Lake Huron tansy open - Great Lakes beaches 1 huronense open - beach, edge of thicket, Veiny meadow rue Thalictrum venulosum v. confine rocky open - barrens, sandy, edge of Dwarf bilberry Vaccinium cespitosum 5 forest Non-Vascular Plants Eastern candlewax lichen Ahtiana aurescens shade - on trees conifer swamp Small firedot lichen Caloplaca parvula shade - on ash, maple swamp liverwort Frullania selwyniana shade - on trees cedar swamp Porthole lichen Menegazzia terebrata shade - on trees or rock shade - pond edges, stream Spongy gourd moss Pohlia lescuriana banks Dotted line lichen Ramalina farinacea shade - on trees, mesic forest shade - mesic forest, tip-ups, Schistostega moss Schistostega pennata crevices open - on sandy soil, fields, Foam lichen Sterocaulon condensatum openings Little Georgia moss Tetradontium brownianum shade -

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APPENDIX A: TABLE 3. Regional Forester Sensitive Species (RFSS) - Animals

Common Name Scientific Name Habitat BIRDS Northern goshawk Accipiter gentilis woodlands Short-eared owl Asio flammeus grassland/marsh Red-shouldered hawk Buteo lineatus woodlands Black tern Chlidonias niger lakes/ponds Yellow rail Coturnicops noveboracensis marsh Trumpeter swan Cygnus buccinator lakes/ponds Prairie warbler Dendroica discolor shrub/dune American peregrine falcon Falco peregrinus cliffs/shore Common loon Gavia immer lakes/ponds Migrant loggerhead shrike Lanius ludovicianus migrans grassland/shrub Black-crowned night heron Nycticorax nycticorax marsh Connecticut warbler Oporornis agilis woodlands Picoides arcticus jack pine/conifer Black-backed woodpecker woodlands Caspian tern Sterna caspia beach/dunes/shore Common tern Sterna hirundo beach/dunes/shore Sharp-tailed grouse Tympanuchus phasianellus grassland/pine barrens Le Conte’s sparrow Ammodramus leconteii grassland/sedge meadow REPTILES Blanding’s turtle Emydoidea blandingii marsh/streams FISH Lake Sturgeon Acipenser fulvescens lakes/streams MOLLUSKS Land snail Catinella exile cobble beach w/Carex turf Land snail Euconulus alderi tamarack/white cedar Eastern flat-whorl Planogyra asteriscus tamarack/white cedar Land snail Vallonia gracilicosta albula other Delicate Vertigo Vertigo bollesiana carbonate cliffs Six Whorl Vertigo Vertigo morsei calcareous wetland Mystery vertigo Vertigo paradoxa carbonate cliffs INSECTS Green-faced clubtail Hylogomphus viridifrons rocky rivers/streams Northern blue butterfly Lycaeides idas nabokovi grassland/pine barrens Warpaint emerald dragonfly Somatochlora incurvata bog/fen Lake Huron locust Trimerotropis huroniana beach/dunes Ebony Boghaunter Williamsonia fletcheri bog/fen Ringed Boghaunter Williamsonia linteri bog/fen

APPENDIX A: TABLE 4. "Likely to Occur1" Regional Forester Sensitive Species (RFSS) - No Element Occurrences of these species on the HNF Common Name Scientific Name Habitat Vascular Plants Screwstem Bartonia paniculata open wet - meadow, bog, fen Northern reed-grass Calamograstis lacustris open - beach, cliffs

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Large tooth-wort Cardamine maxima shade - rich mesic forest Walking sedge Carex assiniboinensis shade - mesic hardwood forest Schweinitz’s sedge Carex schweinitzii shade wet - swamp, streambank Many-headed sedge Carex sychnocephala open wet - shore, wet meadow Hill’s thistle Cirsium hillii open - barrens, alvar, calcareous soil Purple clematis Clematis occidentalis shade - part open, rocky woods Rock witlow-grass Draba arabisans open - beach, bedrock, alvar open wet - fen, interdunal wetland, pond Slender spike-rush Eleocharis nitida edge Mountain fir clubmoss Huperzia appalachiana open wet - moist cliff, acidic rock Farwell’s water milfoil Myriophyllum farwellii aquatic - muck bottom lake Yellow pond lily Nuphar pumila aquatic - Hill’s pondweed Potamogeton hillii aquatic - calcareous lake pond Little shinleaf Pyrola minor shade - mesic forest Awlwort Subularia aquatica aquatic - sand/gravel bottom lakes Non-Vascular Plants Lichen Cladonia wainoi open - rock Forked liverwort Metzgeria furcata shade - on bark of trees Felt lichen Peltigera venosa shade - on moist rock Yellow speckleberry Lichen Pseudocyphellaria crocata shade - on moist rock in forest Methuselah’s beard lichen Usnea longissima shade - on trees, humid forest Likely to occur as Forest Service Region 9 Sensitive Species on the HNF and “Other Species of viability concern”, based on risk evaluation and presence in R9. Source of list page 712 in 2006 Forest Plan Biological Evaluation.

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APPENDIX B: LOCATION OF PROJECT

Actions that are part of the proposed NNIP control program would take place at multiple locations on federally-owned property within the Hiawatha National Forest (HNF). The HNF is located in central and eastern Upper Peninsula of Michigan, including portions of Alger, Chippewa, Delta, Mackinac, Marquette, and Schoolcraft Counties. The HNF proclamation boundary encompasses approximately 1.3 million acres and includes tracts of National Forest System land totaling approximately 895,000 acres (USDA FS 2006b). A diversity of vegetation types, soils, and landforms exist on the Forest. The uplands within the HNF are forested by various stands of northern hardwoods, hemlock, pine, aspen, spruce, and fir. Most other lands comprise a mixture of forested and non-forested upland openings, wetland habitats as well as numerous streams, lakes, and other open water habitats. The HNF is home to a variety of animals and plants, ranging from common to rare, and provides a variety of habitats, recreation opportunities, and forest products.

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