Review of New Information for Proposed New NNIS Plant

Monongahela National Forest NNIS Plant Treatment RONI

Review of New Information For Proposed New NNIS Plant Treatment Sites and Modifications of Treatments at Existing Sites under the Forest-wide Nonnative Invasive Plant Management Project EA

Introduction

In addition to identifying a set of site-specific treatments, the Forest-wide Nonnative Invasive Plant Management Project Environmental Assessment (“NNIS EA”) established protocols for treating a variety of invasive plant species in typical situations. The EA anticipated that new sites would be identified on an ongoing basis, and it established a process for approving treatment of those new sites without preparing a new or updated NEPA document. The decision to implement the EA treatments, protocols, and new site incorporation was approved by Forest Supervisor Clyde Thompson on March 12, 2010 in the Decision Notice and Finding of No Significant Impact for this project.

Following is the text outlining the process for adding sites (from the "Future Treatment Activities" section of the EA, bottom of page 2-6):

“Although the proposed action identifies many specific sites across the Forest for treatment, it is likely that more high-priority treatment sites will be discovered. Therefore, the proposed action provides for the treatment of these additional sites after a review of the condition of any resources that may be affected. At a minimum, this review would involve wildlife, aquatics, botany, TES species, silviculture, recreation, and cultural resources. Treatment activities must involve situations similar to those programmatic and site-specific situations already analyzed, and any resource effects must be within the scale and scope of effects already analyzed. Line officer review and approval would be required prior to treatment. New herbicides and treatment methods would not be used without appropriate additional NEPA analysis and documentation.”

Although the EA was clear in specifying the process for adding new sites, some confusion has arisen over the procedure for modifying treatments at existing sites. At issue is whether interdisciplinary team review is needed prior to treating additional target species or using different herbicides within the boundaries of existing treatment sites. The purposes of this review are 1) to address the modification of treatments at existing sites, and 2) to review proposed new sites and determine whether treating these sites would be within the scale and scope of effects already analyzed.

New Information

Modification of Treatments at Existing Sites

Although the NNIS EA proposed treating specific NNIS species at specific sites, the effects analysis did not identify site-specific effects based on the type of herbicide to be used or the species to be controlled at specific sites. Rather, it evaluated effects more broadly in terms of what might be expected to occur wherever particular herbicides are used. Individual herbicides 1

Monongahela National Forest NNIS Plant Treatment RONI were evaluated programmatically through the use of standard risk assessments. When a risk assessment identified a concern regarding the use of a specific herbicide, the concern was addressed through design criteria, mitigation measures, and monitoring, which are to be applied at any site where the concern could exist. Thus the effects analysis was not predicated on the use of specific herbicides or the control of specific species at specific sites. Therefore, at all of the sites included in the EA, the use of any herbicide covered by the EA to control any species covered by the EA is within the scope of the existing analysis and does not require any additional review or documentation. The species that may be controlled and the herbicides that may be used are listed in Table 2.1 of the EA (beginning on p. 2-7). A copy of the table is attached to this letter for reference (Attachment A).

Although the EA analysis provides broad flexibility for applying control measures as needed at the existing sites, the following caveats must be observed:

1. All design criteria, mitigation measures, and monitoring requirements must be followed. These are listed in Chapter 2 of the EA on pages 2-15 through 2-20.

2. Only herbicides that were covered by the EA may be used. The following herbicides were covered: Glyphosate Imazapyr Fosamine ammonium Triclopyr Sethoxydim Clopyralid Imazapic Metsulfuron methyl Picloram

3. Only the treatment methods that were covered by the EA may be used. The following treatment methods were covered: Broadcast foliar application of herbicide (ground-based only; no aerial application) Spot foliar application of herbicide Cut surface application of herbicide Basal spray application of herbicide Hand pulling Mowing Grubbing using hand tools Biological control using agents that have passed standard USDA screening Prescribed fire in fire-adapted and highly altered ecosystems

4. Fosamine ammonium was analyzed only for roadside applications using vehicle-mounted equipment. Other application methods may present hazards to the herbicide applicator that were not addressed by the analysis, so any other applications of this herbicide would require additional review to determine whether the effects of the proposed application are within the scope of the existing analysis.

5. The effects analysis for threatened, endangered, and sensitive plants identified broadcast foliar application of herbicide as the primary concern for possible adverse effects, and the effect determinations for TES plants were predicated on the site-specific amounts and locations of broadcast application. Therefore, any proposed expansion of broadcast

Monongahela National Forest NNIS Plant Treatment RONI

application within existing site boundaries should be reviewed to determine whether effects are within the scope of the existing analysis.

6. Any new sites or expansion of existing sites requires review to determine whether effects are within the scope of the existing analysis.

Below are some modifications to existing sites that have been proposed. Although they do not require additional analysis and documentation, they are summarized here to give examples of the types of modifications that may occur as the need arises:

Control tree of heaven near Blue Rock Geological Area on the Cheat-Potomac District – This site was included in the NNIS EA for treatment of Japanese stiltgrass and viper’s bugloss, but tree of heaven was overlooked. Controlling tree of heaven would involve cut surface, basal spray, and possibly spot foliar spray of triclopyr, glyphosate, or metsulfuron methyl.

Control non-native thistles at the Big Bend limestone barren site – This area was covered under the NNIS EA for control of viper’s bugloss and spotted knapweed, but has since been discovered to contain non-native thistles. Control would involve spot foliar spray of triclopyr, glyphosate, clopyralid, or metsulfuron methyl.

Control tree of heaven along FR 153 (Five Lick) and associated spurs and openings – This site was included in the NNIS EA for treatment of reed canary grass, but tree of heaven was overlooked. Controlling tree of heaven would involve cut surface, basal spray, and possibly spot foliar spray of triclopyr, glyphosate, or metsulfuron methyl.

Control garlic mustard along FR 75 (Dolly Sods Scenic Area) – This site was included in the NNIS EA for control of reed canary grass and one small patch of garlic mustard. Garlic mustard has since been discovered in other areas along the road, but within the area previously analyzed for reed canary grass. Control would involve spot foliar application of glyphosate or triclopyr.

Proposed New Sites

Infestations of high priority NNIS are being discovered on the Forest periodically, as predicted in the EA. Table 1 contains a subset of sites that likely can be reviewed without additional field work because: 1) they are located in areas that have been reviewed for other projects, 2) they are located in highly disturbed areas that are not likely to present concerns related to resource impacts, or 3) they use precisely targeted treatment methods that are not likely to result in exposure of non-target organisms. These sites are scheduled for treatment beginning in spring or summer 2011, pending available funding and staffing. Maps depicting the sites are included in Attachment B.

Monongahela National Forest NNIS Plant Treatment RONI

Table 1. Additional Sites Proposed for NNIS Control under the Programmatic Component of the Monongahela Forest-wide Nonnative Invasive Plant Management Project (Sites not needing additional field botany surveys – office review during winter 2011 for treatment beginning spring/summer 2011)

Primary Target Estimated Priority Site/Project District Description of Proposed Control1 Species1 Acreage Points2 Big Springs Gap Cheat- Fig buttercup 0.15 A dense but relatively small infestation trailhead (Otter Potomac of this species occurs along the trail Creek) (adjacent down to Otter Creek. Need to limit to Fernow) further spread into the Wilderness and to abate threats to nearby running 6 buffalo clover. Use hand-pulling by volunteers to circumvent issues with using herbicide in the Wilderness and to avoid the need for a botany survey. FR 229 and Cheat- Japanese stiltgrass 42 The NNIS EA covered this area for associated spurs, Potomac reed canary grass, but it has since been openings, etc. discovered to contain large infestations of stiltgrass that extend beyond the site boundary that was analyzed initially. Control is needed to abate threats to 4 nearby running buffalo clover and prevent further encroachment toward Otter Creek Wilderness. Use foliar spray application of sethoxydim, imazapic, or glyphosate (sethoxydim and imazapic are preferred). Cave Mtn. near Cheat- Multiple 8.6 Expansion of the Big Bend limestone Big Bend Potomac barren site that was covered in the Campground NNIS EA. Foliar application of 3 triclopyr, glyphosate, metsulfuron methyl, or sethoxydim. 2004 “Four Cheat- Bush honeysuckle, Allotments The EA for these allotments only Grazing Potomac, multiflora rose, total 279 analyzed the use of Rodeo (one Allotments” EA – Greenbrier, autumn olive, acres, formulation of glyphosate). Add the Rimel, Allegheny Marlinton- nonnative thistles, infested following herbicides that were analyzed Battlefield, White nonnative privets, area likely in the NNIS EA: triclopyr, metsulfuron 1 Queens, Sulphur teasel, common St. smaller methyl, clopyralid, sethoxydim, Callison/Clark John’s wort, and imazapic, picloram, imazapyr, and other NNIS that other formulations of glyphosate. interfere with site management Western Gauley Gauley Tree of heaven, Units total During preparation for a TSI project, TSI units princess tree 102 acres, tree of heaven and princess tree were infested discovered. Use cut surface and basal 3 area likely spray application of triclopyr, smaller glyphosate, or metsulfuron methyl. Barton Bench Greenbrier Spotted knapweed 19 Control spotted knapweed so it does restoration area not take over restoration site. Use on the Mower foliar spray application of clopyralid 1 Tract (preferred), picloram, triclopyr or glyphosate.

Monongahela National Forest NNIS Plant Treatment RONI

Primary Target Estimated Priority Site/Project District Description of Proposed Control1 Species1 Acreage Points2 Barton Bench Greenbrier Tall fescue, orchard 89 The CE for this site did not cover restoration area grass, timothy, herbicide use. Herbicides may be on the Mower Kentucky and needed to prevent nonnative sod plants Tract Canada bluegrass, from out-competing the planted native 1 bird’s foot trefoil, species. Use foliar spray application of nonnative sethoxydim, imazapic, or glyphosate. lespedezas, and other sod NNIS FR 1560 turn- Greenbrier Japanese knotweed 0.01 Need to control this nascent infestation around near before it spreads. Use foliar spray 5 Chestnut Ridge application of triclopyr, glyphosate, or savanna imazapyr. FR 209 near end Greenbrier Garlic mustard <1 Control small patches along road before of road (Shaver’s they spread into the surrounding forest. Fork Fish for Fun Could be hand-pulled or spot-sprayed area) with glyphosate or triclopyr. Hand 5 pulling preferred due to TES wildlife presence. Disturbed, weedy roadside in an unfavorable area for running buffalo clover, so botany surveys not needed. Big Draft Road Marlinton- Garlic mustard 16 ac site; Control is needed to abate threats to (SR 36/1) White infested nearby TES plant occurrences and to Sulphur area much prevent spread into the Big Draft 5 smaller Wilderness. Use foliar spray application of glyphosate or triclopyr. Coordinate with WVDOH. Meadow Creek Marlinton- Autumn olive 1.1 Per WVDNR, control is needed to shale barren White abate threats to shale barren rockcress. Sulphur Hand pull or grub out isolated shrubs. May need to use cut surface or basal spray application of triclopyr, 3 glyphosate, or metsulfuron methyl if more extensive infestations occur. No herbicide use in close proximity to shale barren rockcress plants. Middle Mountain Marlinton- Autumn olive, 1.5 Per WVDNR, control is needed to South A, B, C White multiflora rose abate threats to shale barren rockcress. shale barrens Sulphur Use basal spray or cut surface application of triclopyr, glyphosate, or metsulfuron methyl. May use hand 2 pulling or grubbing in sensitive areas or for isolated small patches. No herbicide use in close proximity to shale barren rockcress plants. Peach Orchard Marlinton- Japanese stiltgrass 149 ac site; Roadsides are infested. Control is and Hopkins White infested needed to mitigate potential spread into Mountain burn Sulphur area likely the burn units. Use foliar spray 1 units smaller application of sethoxydim, imazapic, or glyphosate (sethoxydim and imazapic are preferred).

Monongahela National Forest NNIS Plant Treatment RONI

Primary Target Estimated Priority Site/Project District Description of Proposed Control1 Species1 Acreage Points2 Turkey pen shale Marlinton- Tree of heaven, 8 Per WVDNR, control is needed to barren White multiflora rose, abate threats to shale barren rockcress. Sulphur Japanese stiltgrass Use basal spray or cut surface application of triclopyr, glyphosate, metsulfuron methyl, and foliar spray 2 application of sethoxydim or imazapic. May use hand pulling or grubbing in sensitive areas or for isolated small patches. No herbicide use in close proximity to shale barren rockcress. 1If additional NNIS species are discovered, these may be controlled in accordance with the programmatic protocols established in the NNIS EA. Additional herbicides or other treatment methods may be used consistent with the protocols and limitations established by the EA. 2Priority points range from lowest priority (0 points) to highest priority (6 points). Priority points indicate which sites are most important to treat as part of the NFVW NNIS program. Sites with a low priority rank for the NFVW NNIS program may be a higher priority for other program areas. Points are assigned based on the following factors: Protection of threatened, endangered, or sensitive species – 2 points Protection of a special area – 1 point Protection of ongoing resource management – 1 point Eradication of an emerging infestation to prevent a larger, more persistent infestation from forming – 2 points

Analysis of Potential Resource Effects

Wildlife and Terrestrial TES Animals

The proposed additional new locations for NNIS treatment were reviewed using the most current wildlife information and tools used in the NNIS EA analysis. Based on that information, there were no specific wildlife resource concerns for the following areas listed as additional sites proposed for NNIS control (as depicted in the GIS data associated with the proposal): Big Springs Gap trailhead (Otter Creek); Cave Mountain near Big Bend Campground; Meadow Creek shale barren; Middle Mountain South A, B, C shale barrens; Turkey pen shale barren; Western Gauley TSI units; and FR 1560 turn-around near Chestnut Ridge savanna.

Range allotments Rimel, Allegheny Battlefield, Queens, and Callison/Clark. The southern edge of the Allegheny Battlefield allotment polygon is located in West Virginia northern flying squirrel (Glaucomys sabrinus fuscus, NFS) suitable habitat, so procedures described in the NNIS EA should be followed, particularly given the additional herbicides considered for use in the range allotments, and the potential for unforeseen problems with interactions from combined herbicides, as noted in the NNIS EA, p. 3-99. Also, as noted in the NNIS EA, it is recommended that NNIS foliar herbicide treatments in these types of areas (wildlife openings, fields and other open habitats, such as range allotments) do not use triclopyr due to a relatively high level of risk for chronic effects to large grazing mammals and birds; the suggested herbicides for woody plants in these areas were metsulfuron methyl or imazapyr. Also, the risk evaluations indicate that glyphosate poses a chronic toxicity risk for large grazing mammals and birds and an acute toxicity risk for small mammals. The risk evaluation for clopyralid indicates a chronic toxicity risk for large mammals, and the evaluation for picloram shows an acute toxicity risk for small mammals. These risks would be minimized by a special protection measure that would reduce

Monongahela National Forest NNIS Plant Treatment RONI

the application rates for these herbicides to a level that brings all hazard quotients below 1.0 (see design features section below). The SERA risk evaluation models were re-run using these lower application rates; the model runs confirmed that all hazard quotients were reduced below 1.0 (spreadsheets in project file).

Concerns noted regarding the remaining new sites are detailed below, along with recommendations regarding modifications or clarifications to proposed NNIS control methodology listed in Table 1 of the proposed action.

FR 229 and associated spurs, openings, etc. The extension of this area northward from that evaluated as part of the NNIS EA brings it to within 0.5 miles of an identified Indiana bat maternity colony; several additional roost trees also have been identified along the roadway that is now proposed for treatment; foliar spray application is proposed here. Special protection measures (see design features section) would prohibit broadcast herbicide application (i.e., vehicle-mounted), which would minimize the potential for drift. Backpack applications would be focused on low-growing Japanese stiltgrass and would not be conducted during windy conditions, which would prevent drift to trees above ~ 5’ where bats could be roosting.

Barton Bench restoration area on the Mower Tract. A CE was prepared for the Barton Bench restoration, but it did not cover herbicide use. Programmatic-level mapping depicts this area as within potential Cheat Mountain salamander (Plethodon netting, CMS) habitat, and the area lies along the fringes of mapped suitable WVNFS habitat. However, the documentation for the restoration CE determined that the entire area is a grassy reclaimed strip mine that does not provide suitable habitat for CMS or WVNFS. Vehicle-mounted broadcast spraying would not occur within 150 feet of the adjacent forest, and such spraying would not occur anywhere on the site during windy conditions (see design features section below). These measures would eliminate the potential for drift into adjacent CMS and WVNFS habitat.

Peach Orchard and Hopkins Mountain burn units. Several bat mist-netting sites are located near these units. Repeated surveys at these sites indicate consistent and relatively widespread use of the area by the eastern small-footed myotis (Myotis leibii). This species uses rock outcrop and talus slope habitats similar to those used by the Allegheny woodrat, green salamander and timber rattlesnake. The NNIS EA calls for surveys to be “…conducted at rocky outcrops, talus slopes, caves, ledges or similar habitats located within 100 meters of proposed treatment areas. If sensitive species are found (e.g., Allegheny woodrat, eastern small-footed myotis, timber rattlesnake, or green salamander), no treatments other than hand pulling or mowing with a string trimmer will occur within 50 meters of those habitat features to minimize the potential for direct or indirect effects to RFSS.” However, daytime surveys of these habitat features are unlikely to detect the presence of roosting M. leibii. Furthermore, this sensitive species is one of the species being adversely impacted by white-nose syndrome, which has now been detected in hibernacula in the vicinity of these proposed units. Thus, in addition to the restriction noted for the other RFSS species noted above, if any rock outcrop, talus slopes, ledges or similar habitats are found within 100 m of the roadway in the proposed treatment area, the area would be flagged (at a radius of 50 meters from the habitat feature), and broadcast herbicide spray (vehicle- mounted sprayers) would not be used within that area to avoid inadvertent spraying within rock crevices that may harbor roosting M. leibii. Foliar spray in this area would be limited to

Monongahela National Forest NNIS Plant Treatment RONI backpack sprayers, and care would be taken to ensure that spray drift will not affect the rocky features. Only wick, wand, or similar applications, or non-herbicide methods, would be used within 5 meters of these rocky habitats. These measures would greatly reduce the potential for adverse effects to M. leibii.

FR 209 near end of road (Shaver’s Fork Fish for Fun area). This site has a variety of potential wildlife concerns associated with it. It is within potential CMS habitat, is within suitable WVNFS habitat (and near a capture site), and small-footed bats have been captured within 80 meters of the area proposed for control. Given the number of TES species potentially inhabiting the area and the relatively limited nature of the infestation in this area, hand-pulling would be the first choice of treatments for garlic mustard. Should it be determined that the area requires spraying with glyphosate or triclopyr for effectiveness, the site would require prior CMS surveys, checking for rock outcrops (and employing small-footed bat restrictions, as noted above, for implementation in those areas) and potential follow up surveys for WVNFS, as required by the NNIS EA. These measures would minimize the potential for adverse effects.

In addition to the newly proposed areas above, the following are comments regarding modifications proposed for one of the existing sites, located along FR 153 associated spurs and openings. Previous analysis of this site was based on treatment of an herbaceous invasive (reed canary grass), which would not have affected trees in the area. However, the new proposal is to treat tree of heaven in the area as well which could be used as a roost tree by Indiana bats. Indiana bats were captured at a site on FR 153 in both 2000 and 2003 and several roost trees were subsequently identified in the area. As required by the NNIS EA, treatments applied to any trees greater than 5 inches diameter at breast height (dbh) would be limited to basal spray or “hack and squirt” herbicide application to avoid loss of potential maternity or other roost trees (i.e., no trees over 5 inches dbh will be cut). Also, as required by the NNIS EA, no foliar spray would be used on trees over 5 inches dbh or 6 feet tall to avoid the potential for direct herbicide spray on roosting bats. This should not affect the spot foliar spray noted in this proposal because spot foliar spray is only used for seedlings.

Based on the above analysis, any effects on wildlife and terrestrial TES animals would be within the scale and scope of the effects analyzed in the NNIS EA. The proposed treatments would have no adverse effects on threatened and endangered animals and would be consistent with the effect determinations that were reached in the Biological Assessment for the NNIS EA. The minimal potential for impacts to sensitive animals would be consistent with the effect determinations that were reached in the Biological Evaluation for the NNIS EA.

Hydrology, Fisheries, and Aquatic TES Animals

The proposal includes the modification of four sites that were previously analyzed in the NNIS EA, and fourteen new sites not previously identified. The herbicide application rates, volumes, and application methods are similar to those analyzed in the NNIS EA, and the results of the GLEAMS modeling apply here. Mitigation measures and design features identified in the NNIS EA to protect aquatic resources and riparian vegetation also apply to this proposal.

Monongahela National Forest NNIS Plant Treatment RONI

The concern associated with the use of herbicides is the uncertainty inherent in introducing chemicals into a natural environment supporting a diversity of organisms and complex relationships. The potential effects of herbicides on aquatic organisms have only been studied in a relatively few species, so the potential effects on other species is largely unknown. This is acknowledged by SERA (2007) when they state, “In some cases, a risk assessment may find no objective suggestion of an adverse effect based on the currently available data. In such cases, the risk characterization must clearly make the point that: Absolute safety cannot be proven and the absence of risk can never be demonstrated. No chemical is studied for all possible effects and the use of data from laboratory animals to estimate hazard or the lack of hazard to humans or other species is an uncertain process. Thus, prudence dictates that normal and reasonable care should be taken in the handling of any chemical. In other instances, risks may be apparent and this too must be clearly stated both quantitatively and qualitatively.”

Modification of Existing Sites

Four sites previously analyzed in the NNIS EA had additional NNIS plants identified within the original project area. In order to treat these species, additional herbicides would be used over those that were originally identified for the site. Based on the location and scope of the treatment, the results of the GLEAMS modeling and the design and mitigation features the risks to aquatic resources are minimized.

Big Springs Gap trailhead. An estimated 0.15 acre of fig buttercup would be treated by hand pulling. There are no aquatic resource concerns.

FR 229, Associated Spurs and Openings. An estimated 42 acres of Japanese stiltgrass would be treated with foliar spraying. Aquatic resource concerns include fish-bearing streams, Three Springs and Two Springs, as well as a number of unnamed tributaries to the Glady Fork. Based on the GLEAMS modeling for the proposed herbicides, and the design features and mitigation measures for treatments within close proximity to surface waters, the risk to aquatic resources is minimized.

Cave Mountain. An estimated 8.6 acres located would be treated near Big Bend Campground. The site is located near the ridgeline on Cave Mountain with a small unnamed tributary to the South Branch Potomac River located to the southwest. Aquatic resource concerns are negligible given the size and location of the treatment area, the results of the GLEAMS modeling for the proposed herbicides, and the design and mitigation features for aquatic resource protection.

2004 Grazing Allotments (Rimel, Allegheny Battlefield, Queens and Callison-Clark). An estimaged 279 acres would be treated for a variety of NNIS plant species. The original EA for the four grazing allotments only analyzed the use of glyphosate (Rodeo), and this proposal allows the use of triclopyr, metsulfuron methyl, clopyralid, sethoxydim, impazapic, picloram, impazapyr and other formulations of glyphosate. Aquatic resource concerns are the proximity of the allotments to surface water including within the Shavers Fork floodplain (Queens), bordered by Laurel Creek and Cochoran Run (Rimel) and near Anthony Creek (Callison-Clark). Based on the GLEAMS modeling for the proposed herbicides, the application methods, and the

Monongahela National Forest NNIS Plant Treatment RONI

design features and mitigation measures for treatments within close proximity to surface waters, the risk to aquatic resources is minimized.

Western Gauley TSI Units. An estimated 102 acres would be treated for tree of heaven and princess tree. Aquatic resource concerns are negligible given the ridge top locations of the treatment areas, the target-specific application methods (cut surface and basal spray), the results of the GLEAMS modeling for the proposed herbicides, and the design and mitigation features for aquatic resource protection.

Barton Bench Restoration Area. An estimated 19 acres would be treated for spotted knapweed. Aquatic resource concerns are negligible given the size and location of the treatment area, the results of the GLEAMS modeling for the proposed herbicides, and the design and mitigation features for aquatic resource protection.

Barton Bench Restoration Area. An estimated 89 acres, including the 19 acres to treat spotted knapweed, would be treated for a variety of other NNIS plant species. The expanded treatment area borders a small, unnamed tributary to Red Run. Aquatic resource concerns are negligible given the size and location of the treatment area, the results of the GLEAMS modeling for the proposed herbicides, and the design and mitigation features for aquatic resource protection.

FR 1560 Turnaround. An estimated 0.01 acre would be treated for Japanese knotweed. Aquatic resource concerns are negligible given the size and location of the treatment area.

FR 209. Less than one acre would be treated for roadside garlic mustard by either hand pulling or spot sprayed with triclopyr or glyphosate. The site is in close proximity to the Shavers Fork, so hand pulling is preferred. If herbicides are used, aquatic resource concerns are negligible given the size of the treatment area, the results of the GLEAMS modeling for the proposed herbicides, and the design and mitigation features for aquatic resource protection.

Big Draft Road (SR 36/1). An estimated 16 acres would be treated for garlic mustard. Aquatic resource concerns are the proximity of the road to the main stem of Big Draft and an unnamed intermittent tributary. Based on the GLEAMS modeling for the proposed herbicides and the design features and mitigation measures for treatments within close proximity to surface waters, the risk to aquatic resources is minimized.

Meadow Creek Shale Barren. An estimated 1.1 acres would be treated for autumn olive. The site is located near Meadow Creek and plants would be hand pulled or grubbed out. Herbicides may be used if more extensive infestation occurs. Aquatic resource concerns are negligible given the size of the treatment area, the target-specific application methods (hand removal, cut surface and basal spray), the results of the GLEAMS modeling for the proposed herbicides, and the design and mitigation features for aquatic resource protection.

Middle Mountain South A, B, C Shale Barrens. An estimated 1.5 acres would be treated for autumn olive and multiflora rose. Aquatic resource concerns are negligible given the size of the treatment area, the target-specific application methods (hand removal, cut surface and basal

Monongahela National Forest NNIS Plant Treatment RONI spray), the results of the GLEAMS modeling for the proposed herbicides, and the design and mitigation features for aquatic resources.

Peach Orchard and Hopkins Mountain Burn Units. An estimated 149 acres would be treated for Japanese stiltgrass. Aquatic resource concerns include treatment along roads in close proximity and crossing numerous drainages. Based on the GLEAMS modeling for the proposed herbicides, and the design features and mitigation measures for treatments within close proximity to surface waters, the risk to aquatic resources is minimized.

Turkey Pen Shale Barren. An estimated 8 acres would be treated for tree of heaven, multiflora rose, and Japanese stiltgrass. Although located just above the Anthony Creek floodplain, based on the GLEAMS modeling for the proposed herbicides, the primarily target-specific application methods, and the design features and mitigation measures for treatments within close proximity to surface waters, the risk to aquatic resources is minimal.

Based on the above analysis, any effects on aquatic resources would be within the scale and scope of the effects analyzed in the NNIS EA.

Botany and TES Plants

Threatened, Endangered, and Sensitive Plants

Big Springs Gap trailhead. This site is potential habitat for running buffalo clover (Trifolium stoloniferum, RBC), although RBC has not been observed at the site. Targeted hand-pulling of the fig buttercup would have no potential to affect RBC or any sensitive plant species that may be present.

FR 229 and associated spurs, openings, etc. A botany survey of this site was conducted in 2008 as part of the analysis for the NNIS EA. Although RBC exists in forested stands nearby, no RBC has been found on the road shoulders that would be treated. A potential occurrence of Appalachian blue violet (Viola appalachiensis, identity uncertain due to time of year of the survey) was found on an old skid trail in this area, but the skid trail does not host any stiltgrass and would not be treated. No other TES plants are known to occur in the area. Much of this site was already covered by the NNIS EA analysis, although the extent of the area to be treated is being expanded somewhat. Because no TES plants are known to occur in the area to be treated, no effects to TES plants beyond those anticipated in the EA would occur.

Cave Mountain near Big Bend Campground. This site was surveyed by TNC personnel during 2005 as part of a stiltgrass assessment of the Smoke Hole canyon. The site has also been visited more recently by Ashton Berdine of TNC. T&E plants are unlikely to occur here due to lack of habitat, but several sensitive plant species have the potential to occur at this site. Yellow nailwort (Paronychia virginica) is known to occur at this site, and potential habitat exists for Cooper’s milkvetch (Astragalus neglectus), tall larkspur (Delphinium exaltatum), Smoke Hole bergamot (Monarda fistulosa var. brevis), lance-leaved buckthorn (Rhamnus lanceolata ssp. lanceolata), Virginia mountain pimpernel (Taenidia montana), crested coralroot (Hexalectris spicata), limestone adder’s tongue (Ophioglossum engelmannii), Kate’s Mountain clover

Monongahela National Forest NNIS Plant Treatment RONI

(Trifolium virginicum), Canby’s mountain lover (Paxistima canbyi), and robust fire pink (Silene virginica var. robusta). Some potential exists for adverse impacts to undiscovered occurrences of these sensitive plants. However, treatments would be targeted spot treatments, and all TES plant protection measures and monitoring outlined in the NNIS EA would be applied (pp. 2-15 through 2-17). Therefore, any effects that might occur would be within the scale and scope of effects that were disclosed in the EA (pp. 3-22 through 3-35).

Four Grazing Allotments from 2004 EA (Rimel, Allegheny Battlefield, Queens, Callison/ Clark). These four allotments were surveyed for TES plants in conjunction with the 2004 Range EA. No TES plants were found, although the 2004 Range EA noted that potential habitat exists for Darlington’s spurge (Euphorbia purpurea) in the Allegheny Battlefield and Queens allotments. Given the lack of known occurrences despite the survey, the potential for impacts to this species or any other undiscovered sensitive species is considered very low. Therefore, the potential for effects is within the scale and scope of the effects considered in the NNIS EA (pp. 3-28 through 3-34).

Western Gauley TSI units. These units have not been surveyed for TES plants. However, the proposed treatment would consist of precisely targeted cut surface and basal spray herbicide applications, which have little or no potential for impacting non-target plants. Therefore, TES plants would not be affected.

Barton Bench restoration area on the Mower Tract. This site was surveyed and received TES plants clearance as part of the categorical exclusion for the Barton Bench restoration project. This highly disturbed strip mine bench does not provide potential habitat for TES plants, so the proposed activities would have no effect on TES plants.

FR 1560 turn-around near Chestnut Ridge savanna. This site has been inspected several times over the last few years in conjunction with running a bird survey route. The infestation is a very small patch of Japanese knotweed on a turn-around at a road intersection. RBC is present approximately ¼ mile away, but the site itself does not support RBC. This disturbed, compacted site does not provide potential habitat for TES plants, and the proposed control would not affect TES plants.

FR 209 (Shaver’s Fork). This site has not been surveyed for TES plants, but it is a disturbed roadside that would not provide habitat for TES plants. It is not in a likely area for RBC due to unsuitable geologic substrate, and no other TES plant species would be likely to occur on the disturbed roadside. Therefore, TES plants would not be affected.

Big Draft Road. This site has not been surveyed for TES plants. Treatments would be limited to the frequently mowed right-of-way of the road, which has no potential to support TES plants. Therefore, TES plants would not be affected.

Meadow Creek shale barren, Middle Mtn South A, B, C shale barrens, Turkey Pen shale barren. These sites were surveyed during the summer of 2010. They have also been visited numerous times over the years by WVDNR botanists and biologists. The endangered shale barren rockcress (Arabis serotina) is known to occur at each of these sites. The sensitive species

Monongahela National Forest NNIS Plant Treatment RONI

Virginia mountain pimpernel, Kate’s Mountain clover, lillydale onion (Allium oxyphilum), and shale barren wild buckwheat (Eriogonum allenii) occur at one or more of these sites. Due to the high incidence of TES species at these sites, special protection measures will be required (see below). These measures are required to ensure no effect to the endangered shale barren rockcress and no potential for loss of viability of sensitive plant species. Under these protection measures, most control work within the shale barren habitat would be done by careful hand- pulling or grubbing. Any necessary herbicide work in the shale barrens would be limited to highly targeted cut surface, basal spray, or wick applications, which would not affect non-target plants. Therefore, the proposed work would not affect shale barren rockcress, and would have little or no potential to affect sensitive plants.

Peach Orchard/Hopkins Mountain burn units. These sites were surveyed for TES plants in 2007 in conjunction with the White Sulphur prescribed fire project. Portions of the site were also visited during 2009 in conjunction with monitoring activities. No TES plants were found during the surveys, but TES mapping shows an old (1974) record for the sensitive species turgid gay-feather (Liatris turgida) on the shoulder of FR 139 on Hopkins Mountain. This occurrence was investigated in August 2009, when Liatris should have been in full bloom and readily apparent, but it was not found. It appears that either the location of the original report was inaccurate, or the species no longer exists at this site. In general, the heavily disturbed, maintained road shoulders that would be the target of treatment are unlikely to support TES plant species. Therefore, the treatment would have little or no potential to affect TES plants.

Effect Determinations for TES Plants. Based on the analysis presented above, the proposed activities would have no effect on threatened and endangered plants. For sensitive plants, the proposed activities may impact individuals, but would not lead to loss of viability or a trend toward federal listing for the following species: Appalachian blue violet Crested coralroot Lance-leaved buckthorn Yellow nailwort Limestone adder’s tongue Darlington’s spurge Cooper’s milkvetch Kate’s Mountain clover Lillydale onion Tall larkspur Canby’s mountain lover Shale barren wild buckwheat Smoke Hole bergamot Robust fire pink Turgid gay feather

For all other sensitive plant species, the proposed activities would have no impacts.

Other Botany Issues

The proposed activities would increase control of nonnative invasive plants, and the reduction of nonnative competition and allelopathy would generally be beneficial to the natural communities in which the activities occur. Work at Big Springs Gap, FR 229, Cave Mountain, Barton Bench, and Big Draft Road would help protect backcountry ecological reserves from NNIS invasions.

Some damage to non-target plants may occur where foliar herbicide application occurs, but given the disturbed nature of most of the treatment sites that would be subjected to foliar spray, most non-target damage would involve weedy native and nonnative species with little conservation value. Effects would be within the scale and scope of effects discussed in the NNIS EA (see pp. 3-6 through 3-10).

Monongahela National Forest NNIS Plant Treatment RONI

Soils

The proposed additional new locations for NNIS treatment were reviewed using the most current soils information and tools used in the NNIS EA analysis. The following site-specific concerns and comments would be addressed by design features in the NNIS EA, or by special protections listed in the design features section below.

For stilt grass treatment, Imazapic could become mobile in non-acidic soils, such as soils that formed from circumneutral parent material and roadside areas that are affected by limestone gravel. This risk would be minimized by using sethoxydim in these situations (see design features section below). Sethoxydim has a very short half-life (4-5 days), so it would degrade before it has a chance to move very far.

Garlic mustard treatment near the end of FR209 may have some wet soils present. If ponded water or seep areas are encountered, aquatic formulations would be used as defined by the design criteria specified in the NNIS EA.

Sites proposed along FR229 for stilt grass treatment are underlain by wet soils. If ponded water, seeps or wet areas are encountered, an aquatic-registered herbicide formulation would be applied, as required by the design features in the NNIS EA.

Western Gauley TSI units show areas that are underlain by wet soils. Treatments of cut surface and basal spray application would greatly minimize the risk for herbicide coming into contact with water; however, if ponded water, seeps or wet areas are encountered, an aquatic-registered herbicide formulation would be used, as required by the design features in the NNIS EA.

The Cave Mountain-Big Bend Campground site is located on a limestone formation that has the potential to form more alkaline soils. The use of metsulfuron methyl has an elevated risk because it is more mobile in higher pH soils. This area tends to be dry, and the lack of moisture decreases this risk. If metsulfuron methyl is used, it would be applied during dry times of the year to minimize the potential for movement in the soil (see design features below).

In the 2004 Grazing Allotments EA Decision, Rimel, Queens, and Callison/Clark allotments all exist within flood plains and have areas of wet, hydric, and/or soils that are prone to flooding. Aquatic-registered herbicide formulations would be used within stream channel buffers and within 100 feet of other water, as required by the design features in the NNIS EA.

For the Barton Bench Restoration Area (Mower Tract), if soils are severely compacted prior to herbicide application, ponded water may exist on areas of this site. This is due to soil characteristics created by post-mining reclamation activities. This surface water may be hydrologically connected to ditch lines. If this is the case, aquatic-registered herbicide formulations would be used, or deep ripping would be conducted prior to herbicide application to break the hydrologic connection (see design features below).

Based on the above analysis, any effects on soil resources would be within the scale and scope of the effects analyzed in the NNIS EA.

Monongahela National Forest NNIS Plant Treatment RONI

Silviculture

Herbicide used at the rates in the EA will have no effects on non-target overstory trees. As noted in the NNIS EA, the herbicides will have no effects on the on the public or workers at the specified rates. All design features and mitigation measures from the EA would be followed. Therefore, all effects related to silviculture and human health would be within the scale and scope of the effects discussed in the NNIS EA.

Recreation

The long-term benefits of treating NNIS would be improved by adding additional treatment sites to the NNIS EA, as was anticipated during the original EA analysis. Long-term benefits of treating NNIS include improved wildflower viewing and overall improvements to the aesthetics of the Forest by replacing monocultures of NNIS with a diverse mix of native plants.

Several additional treatment locations are adjacent to congressionally designated wildernesses. NNIS have the potential to damage the biological diversity and ecosystem integrity of wilderness areas. Specifically, NNIS threaten the untrammeled appearance, natural character, opportunities for solitude or primitive recreation by visitors, and some unique qualities of wilderness character. These species create a host of adverse environmental effects, including the displacement of native plants; reduction in habitat and forage for wildlife; loss of threatened, endangered, and sensitive species; increased soil erosion and reduced water quality; and changes in the intensity and frequency of fires. Treatment of NNIS in wilderness is allowed, but requires additional approval processes and/or more labor intensive and expensive methods. Treating areas adjacent to wilderness with the goal of preventing or limiting spread into wilderness is the best approach. The additional treatment sites are a benefit to the wilderness resource.

Executive Order 13112, issued in 1999, directs all agencies in the Executive Branch to prevent the introduction of invasive species, detect and respond rapidly to and control populations of such species. Adding treatment sites helps meets the intent of the Executive Order.

Based on the above analysis, any effects on recreation resources would be within the scale and scope of the effects analyzed in the NNIS EA.

Cultural Resources

The proposed activities would not involve any ground disturbance beyond that anticipated in the NNIS EA. Therefore, any effects on cultural resources would be within the scale and scope of effects that were analyzed in the EA.

Other Resources

It does not appear that proposed treatments would occur in any Inventoried Roadless Areas on the Forest, including RACR areas. However, even if they did, the treatments would not change the undeveloped character of these areas nor make them any less suitable for future wilderness designation.

Monongahela National Forest NNIS Plant Treatment RONI

There are no established Research Natural Areas on the Forest at this time, but the proposed treatments would not occur in any of the candidate RNAs or have any negative effects on the attributes for which they are being considered for establishment.

Some treatments would occur in other special areas—such as the Blue Rock Geological Area, the Dolly Sods Scenic Area, and specific shale barren Botanical Areas—however the NNIS treatments are designed to help protect the native flora and ecological integrity of these areas over the long term, and the limited scope and intensity of these activities should not have any significant impacts to the attributes for which these areas were established.

Required Design Features and Mitigation Measures

All design features, mitigation measures, and monitoring listed in the NNIS EA, as well as the additional precautionary measures for the Cheat Mountain salamander that were agreed to by the Forest Service and Fish and Wildlife Service, apply to the sites proposed in this RONI. In addition to those measures in place, the following special protection measures are required:

Wildlife and Terrestrial TES Animals

Range allotment sites (Rimel, Allegheny Battlefield, Queens, and Callison/Clark): To reduce the potential for toxicity to wildlife, limit application rates for the following herbicides: Clopyralid – maximum rate 0.35 lb/ac Glyphosate – maximum rate 1.1 lb/ac Picloram – maximum rate 0.4 lb/ac

FR 229 and FR 153: Do not use vehicle-mounted broadcast spray equipment to apply herbicides. Ensure that herbicide applications are directed downward toward the target plants. Do not conduct foliar spray applications when wind speed exceeds 10 mph.

FR 209: Hand-pulling is the preferred method for garlic mustard control at this site. If herbicide application is necessary, the existing protection measures in the NNIS EA would require Cheat Mountain salamander surveys, checking for rock outcrops (and employing small-footed bat restrictions, as noted below for Peach Orchard/Hopkins Mountain) and potential follow up surveys for northern flying squirrel.

Barton Bench: Do not use vehicle-mounted broadcast spray equipment to apply herbicides within 150 feet of adjacent forest. Do not conduct foliar spray applications when wind speed exceeds 10 mph.

Peach Orchard and Hopkins Mountain: Flag a 50 meter radius around rock outcrops, ledges, talus slopes, and similar habitats. Avoid vehicle-mounted broadcast spray herbicide applications within this radius. Use only wick or wand-type applicators to apply herbicide within 5 meters of rock outcrops, ledges, talus slopes, and similar habitats.

TES Plants

Monongahela National Forest NNIS Plant Treatment RONI

Attachment A. Table 2.1 from the NNIS EA

Table 2.1. NNIS Plants that May Be Treated on the Monongahela National Forest and Potential Treatment Methods

Common Name Scientific Name Possible Treatment Methods Possible Herbicides Norway maple Acer platanoides Basal spray, cut surface, foliar Triclopyr, glyphosate, spray, grubbing metsulfuron methyl Bishop’s goutweed Aegopodium podagraria Foliar spray, grubbing, mowing Glyphosate, triclopyr Giant bentgrass Agrostis gigantea Foliar spray, grubbing Glyphosate, sethoxydim Tree of heaven Ailanthus altissima Basal spray, cut surface, foliar Triclopyr, glyphosate, spray, grubbing metsulfuron methyl Chocolate vine Akebia quinata Foliar spray, grubbing Glyphosate, triclopyr Garlic mustard Alliaria petiolata Foliar spray, hand pull, fire Glyphosate, triclopyr Porcelain berry Ampelopsis Basal spray, cut surface, foliar Glyphosate, triclopyr brevipedunculata spray, grubbing, hand pull Sweet vernal grass Anthoxanthum odoratum Foliar spray, grubbing, hand pull Glyphosate, sethoxydim Lesser burdock Arctium minus Foliar spray, mowing, grubbing, Glyphosate, clopyralid, hand pull triclopyr Common Artemisia vulgaris Foliar spray, mowing Clopyralid, glyphosate wormwood Small carpgrass Arthraxon hispidus Foliar spray, mowing, hand pull Sethoxydim, imazapic, glyphosate Giant reed Arundo donax Foliar spray, cut surface Glyphosate Yellow rocket Barbarea vulgaris Hand pull, grubbing, foliar spray, Glyphosate, triclopyr mowing Non-native Berberis thunbergii, Basal spray, cut surface, foliar Triclopyr, glyphosate barberries Berberis vulgaris spray, grubbing, hand pull Field brome Bromus arvensis Foliar spray, hand pull, mowing Glyphosate, sethoxydim, imazapic Meadow brome Bromus commutatus Foliar spray, hand pull, mowing Glyphosate, sethoxydim, imazapic Smooth brome Bromus inermis var. Foliar spray, hand pull Glyphosate, sethoxydim, inermis imazapic Rye brome Bromus secalinus Foliar spray, hand pull, mowing Glyphosate, sethoxydim, imazapic Barren bromegrass Bromus sterilis Foliar spray, hand pull, mowing Glyphosate, sethoxydim, imazapic Cheatgrass Bromus tectorum Foliar spray, hand pull, mowing Glyphosate, sethoxydim, imazapic Flowering rush Butomus umbellatus Cutting, grubbing, foliar spray and Glyphosate foliar application (wick/glove) Plumeless thistle Carduus acanthoides Foliar spray, mowing, grubbing Metsulfuron methyl, clopyralid, glyphosate, triclopyr Curled thistle Carduus crispus Foliar spray, mowing, grubbing Metsulfuron methyl, clopyralid, glyphosate, triclopyr Musk thistle Carduus nutans Foliar spray, mowing, grubbing Metsulfuron methyl, clopyralid, glyphosate, triclopyr Oriental Celastrus orbiculatus Cut surface, basal spray, foliar Triclopyr, glyphosate bittersweet spray, grubbing, hand pull

Monongahela National Forest NNIS Plant Treatment RONI

Common Name Scientific Name Possible Treatment Methods Possible Herbicides Brown knapweed Centaurea jacea Foliar spray, biological control, Triclopyr, glyphosate, hand pull clopyralid, picloram Tyrol knapweed Centaurea nigrescens Hand pull, foliar spray, biological Triclopyr, glyphosate, control clopyralid, picloram Meadow knapweed Centaurea pratensis Foliar spray, biological control, Triclopyr, glyphosate, hand pull clopyralid, picloram Spotted knapweed Centaurea stoebe Hand pull, foliar spray, biological Triclopyr, glyphosate, control clopyralid, picloram Celandine Chelidonium majus var. Foliar spray, hand pull, grubbing Triclopyr, glyphosate majus Chicory Cichorium intybus Foliar spray, hand pull, grubbing Triclopyr, glyphosate Canada thistle Cirsium arvense Foliar spray Clopyralid, glyphosate, imazapic Bull thistle Cirsium vulgare Foliar spray, mowing, grubbing Clopyralid, glyphosate, triclopyr, metsulfuron methyl Poison hemlock Conium maculatum Foliar spray, mowing, grubbing, Glyphosate hand pull Field bindweed Convolvulus arvensis Foliar spray, grubbing, hand pull Glyphosate Crown vetch Coronilla varia Foliar spray, mowing, grubbing Triclopyr, glyphosate, clopyralid, metsulfuron methyl Gypsy-flower Cynoglossum officinale Foliar spray, mowing, hand Metsulfuron methyl, picloram pulling, Queen Anne’s lace Daucus carota Foliar spray, mowing, hand pulling Triclopyr, glyphosate Chinese yam Dioscorea oppositifolia Foliar spray, grubbing, mowing Glyphosate, triclopyr Fuller's Teasel Dipsacus fullonum Foliar spray, grubbing Metsulfuron methyl, glyphosate Cut-leaved teasel Dipsacus laciniatus Foliar spray, grubbing Metsulfuron methyl, glyphosate Common teasel Dipsacus sylvestris Foliar spray, grubbing Metsulfuron methyl, glyphosate Indian-strawberry Duchesnea indica Foliar spray, hand pulling Triclopyr, clopyralid Viper’s bugloss Echium vulgare Hand pull, foliar spray Glyphosate, clopyralid Russian olive Eleagnus angustifolia Basal spray, cut surface, foliar Triclopyr, glyphosate, spray, grubbing, hand pull metsulfuron methyl Autumn olive Eleagnus umbellata Basal spray, cut surface, foliar Triclopyr, glyphosate, spray, grubbing, hand pull metsulfuron methyl Quackgrass Elymus repens Foliar spray Sethoxydim, glyphosate Burningbush Euonymus alata Basal spray, cut surface, foliar Triclopyr, glyphosate, spray, grubbing, hand pull imazapyr Winter creeper Euonymus fortunei Foliar spray, cut surface, grubbing, Triclopyr, glyphosate hand pull Leafy spurge Euphorbia esula Foliar spray Glyphosate, picloram, imazapic Japanese knotweed Polygonum cuspidatum Foliar spray Triclopyr, glyphosate, imazapyr Glossy buckthorn Rhamnus frangula Basal spray, cut surface, foliar Glyphosate, triclopyr spray, grubbing, hand pull False baby’s breath Galium mollugo Foliar spray Triclopyr, glyphosate Ground ivy Glechoma hederacea Foliar spray, grubbing, hand pull Glyphosate, triclopyr English ivy Hedera helix Foliar spray, cut surface, hand pull Triclopyr, glyphosate Giant hogweed Heracleum Foliar spray Glyphosate, triclopyr mantegazzianum

Monongahela National Forest NNIS Plant Treatment RONI

Common Name Scientific Name Possible Treatment Methods Possible Herbicides Dame’s rocket Hesperis matronalis Foliar spray, hand pull, grubbing Glyphosate, triclopyr Meadow Hieracium caespitosum Foliar spray, grubbing Glyphosate, triclopyr, hawkweed clopyralid Field hawkweed Hieracium pretense Foliar spray, grubbing Glyphosate, triclopyr, clopyralid Velvet grass Holcus lanatus Foliar spray, grubbing, hand pull Sethoxydim, glyphosate Japanese hop Humulus japonicus Foliar spray, hand pull Glyphosate

Common St. Hypericum perforatum Foliar spray Metsulfuron, picloram, John’s wort glyphosate Hairy cat’s ear Hypochaeris radicata Foliar spray, grubbing Clopyralid, glyphosate Cogon grass Imperata cylindrica Foliar spray Glyphosate, imazapyr Yellow iris Iris pseudacorus Foliar spray and foliar application Glyphosate (wick/glove) Korean bushclover Kummerowia stipulacea Foliar spray, hand pull, mowing Triclopyr, glyphosate Japanese clover Kummerowia striata Foliar spray, hand pull, mowing Triclopyr, glyphosate Japanese Lespedeza bicolor Foliar spray, mowing Triclopyr, glyphosate, bushclover clopyralid, metsulfuron methyl Sericea lespedeza Lespedeza cuneata Foliar spray, mowing Triclopyr, glyphosate, clopyralid, metsulfuron methyl Ox-eye daisy Leucanthemum vulgare Foliar spray, grubbing, hand pull Imazapyr, picloram, clopyralid Exotic privets Ligustrum vulgare, L. Cut surface, basal spray, foliar Glyphosate, triclopyr, sinense, L. japonica, L. spray, grubbing, hand pull metsulfuron methyl obtusifolium Butter-and-eggs Linaria vulgaris Foliar spray, hand pull Glyphosate, picloram Perennial ryegrass Lolium perenne ssp. Foliar spray, grubbing Sethoxydim, glyphosate multflorum Japanese Lonicera japonica Foliar spray Glyphosate, metsulfuron honeysuckle methyl Exotic bush Lonicera maackii, L. Basal spray, cut surface, foliar Glyphosate, metsulfuron honeysuckles tatarica, L. morrowii, L. x. spray, grubbing, hand pull methyl bella, other shrubby Lonicera Bird’s foot trefoil Lotus corniculatus Foliar spray, grubbing Clopyralid, glyphosate, triclopyr Moneywort Lysimachia nummularia Foliar spray, hand pull Glyphosate, triclopyr Purple loosestrife Lythrum salicaria Foliar spray, grubbing, hand pull Glyphosate, triclopyr White sweet clover Melilotus alba Foliar spray, hand pull, mowing Imazapyr, picloram, metsulfuron methyl, glyphosate Yellow sweet Melilotus officinalis Foliar spray, hand pull, mowing Imazapyr, picloram, clover metsulfuron methyl, glyphosate Japanese stiltgrass Microstegium vimineum Foliar spray, hand pull, mow Imazapic, sethoxydim, glyphosate Chinese silvergrass Miscanthus sinensis Foliar spray Glyphosate, imazapyr Grape hyacinth Muscari botryoides Foliar spray, grubbing Glyphosate, triclopyr Star of Bethlehem Ornithogallum umbellatum Grubbing, hand pull Drooping star of Ornithogalum nutans Grubbing, hand pull Bethlehem

Monongahela National Forest NNIS Plant Treatment RONI

Common Name Scientific Name Possible Treatment Methods Possible Herbicides Wild parsnip Pastinaca sativa Foliar spray, grubbing, mowing Glyphosate, triclopyr Princess tree Paulownia tomentosa Basal spray, cut surface, foliar Glyphosate, triclopyr, spray, grubbing, hand pull imazapyr Beefsteak plant Perilla frutescens Foliar spray, hand pull, grubbing Glyphosate, triclopyr Reed canary grass Phalaris arundinacea Foliar spray Glyphosate, sethoxydim Japanese corktree Phellodendron japonicum Basal spray, cut surface, foliar Glyphosate, triclopyr spray, grubbing, hand pull Common reed Phragmites australis Foliar spray, mowing Glyphosate Canada bluegrass Poa compressa Foliar spray Glyphosate Kentucky Poa pratensis Foliar spray Glyphosate bluegrass Rough bluegrass Poa trivialis Foliar spray Glyphosate Oriental lady’s Polygonum caespitosum Foliar spray, grubbing, hand Glyphosate thumb var. longisetum pulling, mowing Mile-a-minute vine Polygonum perfoliatum Foliar spray Triclopyr, glyphosate, imazapyr Sachaline Polygonum sachalinense Foliar spray Triclopyr, glyphosate, imazapyr Kudzu Pueraria montana var. Foliar spray Glyphosate, triclopyr, lobata metsulfuron methyl, picloram Lesser celandine Ranunculus ficaria Foliar spray, grubbing, hand pull Glyphosate Creeping buttercup Ranunculus repens Foliar spray, grubbing, hand pull Glyphosate Common Rhamnus cathartica Basal spray, cut surface, foliar Glyphosate, triclopyr buckthorn spray, grubbing, hand pull Jetbead Rhodotypos scandens Basal spray, cut surface, foliar Glyphosate, triclopyr spray, grubbing Creeping yellow Rorippa sylvestris Foliar spray, grubbing Triclopyr cress Multiflora rose Rosa multiflora Basal spray, cut surface, foliar Glyphosate, triclopyr, spray, grubbing, hand pull imazapyr, metsulfuron methyl Wineberry Rubus phoenicolasius Foliar spray, grubbing Glyphosate, triclopyr, metsulfuron methyl Tall fescue Schedonorus phoenix Foliar spray, grubbing Glyphosate, imazapyr, imazapic Meadow fescue Schedonorus pratensis Foliar spray, grubbing Glyphosate, imazapyr, imazapic Stringy stonecrop Sedum sarmentosum Foliar spray, hand pull, grubbing Glyphosate, triclopyr Johnsongrass Sorghum halapense Foliar spray, hand pull, grubbing Glyphosate, sethoxydim Japanese spiraea Spiraea japonica Basal spray, cut surface, foliar Glyphosate, triclopyr spray, grubbing, hand pull Common Stellaria media Foliar spray, hand pull, grubbing Glyphosate, triclopyr chickweed Colt’s foot Tussilago farfara Foliar spray, hand pull, grubbing Glyphosate, triclopyr Great mullein Verbascum thapsus Foliar spray, hand pull Glyphosate, triclopyr, metsulfuron methyl Bigleaf periwinkle Vinca major Foliar spray, hand pull, grubbing Glyphosate, triclopyr, picloram Common Vinca minor Foliar spray, hand pull, grubbing Glyphosate, triclopyr, periwinkle picloram

Monongahela National Forest NNIS Plant Treatment RONI

Attachment B. Maps depicting locations of proposed new NNIS treatment sites

Monongahela National Forest NNIS Plant Treatment RONI