Nettle Patch Response to Comment
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APPENDIX D- NETTLE PATCH RESPONSE TO COMMENT The following is a list of those who provided Comment during the various project scoping and comment periods. LTR COMMENTER AGENCY / ORGANIZATION # 1 Shayne Fields Trail Coordinator / City of Norton 2 Yolanda Saunooke / Holly Austin Eastern Band of Cherokee Indians (provided scoping and DEA Comments) VA Department of Conservation and Recreation (provided scoping Comments and additional 3 S. Rene’ Hypes follow up prior to DEA) 4 Wayne Thacker Rocky Mountain Elk Foundation VSLT and Grouse Hunter (provided scoping and DEA Comments) 5 Kathy Funk Rocky Mountain Elk Foundation 6 Linda Ordiway Ruffed Grouse Society 7 Appalachian Voices (completed public Comment sheet) 8 Bettina Sullivan / Valerie Fulcher VA Department of Environmental Quality (provided scoping and DEA Comments) 9 Wayne Browning* Clinch Coalition (provided scoping and DEA Comments) 10 Sherman Bramford Sierra Club, Wild Virginia (provided scoping and DEA Comments) 11 Scott Word (Provided scoping Comments) 101 responses forward by Annie 12 101 respondents sent form emails from the Clinch Coalition Jane Cotten 13 Diana Withen Clinch Coalition President 14 Andrew James Chapman Clinch Coalition 15 Shannon Dwyer Clinch Coalition 16 Frank M. Frey Clinch Coalition, The University of VA’s College at Wise 17 Gerry Scardo Clinch Coalition 18 Ryan Huish The University of VA’s College in Wise, Clinch Coalition 19 Philip C. Shelton The University of VA’s College in Wise 20 Annie Jane Cotton Clinch Coalition Individuals present at this meeting have asterisks (*) next to their names above. Additional Nettle Patch Informational Meeting individuals present at this meeting include: Dave Sligh / Wild VA, Beth / VA Master Naturalist, 21 3/5/2016 Bobby Wheeler / Big Stone Gap, Stephanie Otis / Friends of SWVA, Brad Kreps / TNC, J Clay, Seth Thompson VADGIF, Sharon and Jue Still / Town of Coeburn, Carol Schoolaft, Gena Kiler 22 Abigail O’Hare (provided DEA Comments) 23 Bill Worrell (provided DEA Comments) 24 Gena Kiser (provided DEA Comments) 25 David Sligh Wild Virginia (provided DEA Comments) 26 Laura Miller (provided DEA Comments) 27 William Mays City of Norton (provided DEA Comments) 28 Mary Meade (provided DEA Comments) 29 Gerald Rose (provided DEA Comments) 30 Brenda Whitaker (provided DEA Comments) 31 Angela Watland The Nature Conservancy (provided scoping and DEA Comments) 32 Kristen Davis / Diane Withen Southern Environmental Law Center / The Clinch Coalition (provided DEA Comments) 33 Dick Artley (provided DEA Comments) 34 Charles Brown (provided DEA Comments) 1 LTR # Comment Response I did not think to ask about what sort of treatment is planned for the National Forest Management Act of 1976 (16 U.S.C. 1608). Directs that roads be surface of FS 2420. Presently, it is a beautiful, peaceful, grassy, scenic designed to standards appropriate for their intended uses and requires revegetation road, excellent for hiking and biking. A few Forest Service vehicles, in of temporary roads authorized under a contract, permit, lease, or other written and out, from time to time, do no real, lasting damage. However, the 1 authorization within 10 years of termination of the written authorization. normal preparation for logging usually involves the addition of heavy gravel. Furthermore, the practice of putting loaded logging trucks on a BMP's are followed. Timber sale administrator monitors contract throughout the life of road that is as wet as 2420 always is, is a recipe for something that contracts will most likely end up a sloppy mess. National Forest Management Act of 1976 (16 U.S.C. 1608). Directs that roads be In our meeting, I raised concerns about possible damage to the Pickem designed to standards appropriate for their intended uses and requires revegetation Mountain Trail, and another trail (which trail users have been calling of temporary roads authorized under a contract, permit, lease, or other written “Fern Gully”), which joins FS2420 from the west, 1.7 miles up the road 1 authorization within 10 years of termination of the written authorization. (south) from where Pickem Mountain Trail joins the road. In addition to these two trails, I spoke about Stidham Fork, and the trail that follows BMP's are followed. Timber sale administrator monitors contract throughout the life of the eastern side of the creek. contracts National Forest Management Act of 1976 (16 U.S.C. 1608). Directs that roads be I just wanted to keep these concerns fresh in the minds of the Forest designed to standards appropriate for their intended uses and requires revegetation Service, in hopes that Stidham Fork can be brought back to its former of temporary roads authorized under a contract, permit, lease, or other written 1 state, by cutting out deadfalls and Rhododendron, and that FS 2420 authorization within 10 years of termination of the written authorization. and the two trails mentioned above, be protected, so that future trail users can enjoy the serene nature of their current condition. BMP's are followed. Timber sale administrator monitors contract throughout the life of contracts The project’s location is within the aboriginal territory of the Cherokee People. Potential cultural resources important to the Cherokee people may be threatened due to adverse effects expected from the level of 2 ground disturbance required for this project. Please send all related Comment noted. archaeological, cultural resource and historical investigatory materials, including the Phase I report, completed by the applicant to this office for review and Comment. Upon review of the Draft Environmental Assessment for the Nettle Patch Vegetation Management Project, it is the opinion of the EBCI THPO that the work associated with this proposed undertaking and its 2 proposed alternatives will not adversely affect any historic properties Comment noted. eligible for or listed on the NRHP. In the event that project design plans change, or cultural resources or human remains are inadvertently discovered, the EBCI THPO requests that all work cease and be 2 notified so we may continue the nation-to-nation consultation process as stipulated under §36CFR800. DCR supports the use of prescribed fire in the treatment areas as a 3 Comment noted. management tool. If karst features such as sinkholes, caves, disappearing streams, and large springs are encountered during the project, please coordinate 3 Agree. with Wil Orndorff (540-230-5960, [email protected]) to document and minimize adverse impacts. If the project involves filling or “improvement” of sinkholes or cave openings, DCR would like detailed location information and copies of 3 Project does not involve filling or “improvement” of sinkholes or cave openings. the design specifications. In cases where sinkhole improvement is for stormwater discharge, copies of VDOT Form EQ-120 will suffice. Tiering to FW-99: No herbicide is aerially applied within 300 feet, nor ground-applied within 60 feet, of any known threatened, endangered, proposed, or sensitive plant, DCR recommends no herbicide use near documented occurrences of 3 except where its use is necessary to control non-native invasive species affecting rare plants. federally listed or sensitive species. Buffers are clearly marked before treatment so applicators can easily see and avoid them. 3 The Pickem Mountain Conservation Site is located within the project site. Pickem Mountain Conservation Site has been given a biodiversity significance ranking of B5, which represents a site of general biodiversity. Central Appalachian Montane Oak – Hickory Forest (Rich Type) G3G4/S3S4/NL/NL Carex roanensis Roan Mountain Sedge G2G3/S2/NL/NL High Knob Conservation Site is located within the project site. High Knob Conservation Site has been given a biodiversity significance ranking of B2, which represents a site of very high significance. The natural heritage resources of concern at this site are: Central Appalachian Montane Oak – Hickory Forest (Rich Type) G3G4/S3S4/NL/NL Carex roanensis Roan Mountain Sedge G2G3/S2/NL/NL The forest considered including these areas in the JNF plan revision. We identified This plant is rare in the mountains of Virginia and is found at middle to some areas of Old Growth and included those areas within the 6C management high elevations in dry to mesic, often rocky, hardwood forests (Weakley prescription. In treatment units of concern, as part of this project, new Old Growth 3 et al., 2012). As of 2014, the Virginia Natural Heritage Program had surveys were completed, and aside from small areas that we are avoiding, nothing documented 10 extant and 1 historic site. Threats include logging of meeting our criteria for Old Growth was found. Therefore, no impact on Old Growth its habitat and competition from non-native invasive plant species. communities that Heritage is concerned about would be impacted. Burns Creek Conservation Site is located within the project site. Burns Creek Conservation Site has been given a biodiversity significance ranking of B5, which represents a site of general biodiversity. The natural heritage resource of concern at this site is: Cleistesopsis bifaria Small spreading pogonia G4?/S2/NL/NL Upon further review, DCR supports the use of prescribed fire in the targeted areas as a management tool. However, we do not support the other treatments proposed in the scoping notice including two TSI-Crop Tree Release units which encroach into the Montane Mixed Oak-Oak- Hickory forest EO associated with High Knob Conservation Site and the two thinning treatment units which the Oak/Heath Forest element occurrence associated with the Pickem Mountain conservation site. DCR also recommends no herbicide use near documented occurrences of rare plants. This project is situated on karst-forming carbonate rock and can be Areas of karst geology will be considered in the layout of the sales, if approved. 3 characterized by sinkholes, caves, disappearing streams, and large Jefferson National Forest Plan's standards for swallets and caves will be followed if springs. these areas are encountered during sale layout.