United States Department of Environmental Assessment Agriculture Feral Pig Damage Control Project Forest Service on Cleveland National Forest March 2013 and Bureau of Land Management Lands

Lead Agency: USDA Forest Service Cleveland National Forest 10845 Rancho Bernardo Road, Suite 200 San Diego, CA 92127-2107

Cooperating Agency: Bureau of Land Management Palm Springs – South Coast Field Office 1201 Bird Center Drive Palm Springs, CA 92262

San Diego, Orange and Riverside Counties, California

CHAPTER 1 Introduction

1.1 Document Structure

The Cleveland National Forest (CNF) has prepared the Feral Pig Damage Control Project Environmental Assessment in compliance with the National Environmental Policy Act (NEPA) and other relevant federal laws and regulations. This environmental assessment discloses the direct, indirect, and cumulative environmental effects that would result from the proposed action and alternatives. The document is organized into the following parts:

 Chapter 1: Introduction. This chapter includes the background information on project area, the purpose and need for the project, and a description of the proposed action. This chapter also details how the public was informed of the proposal and how the public responded.  Chapter 2: Alternatives. This chapter provides a more detailed description of the proposed action as well as any alternative methods for achieving the stated purpose that may have been developed based on significant issues raised by the public and other government agencies during the scoping period. This chapter includes possible mitigation measures.  Chapter 3: Environmental Consequences. This chapter describes the affected environment for each resource, as well as the environmental effects of implementing the proposed action and any other alternatives.  Chapter 4: Agencies and Persons Consulted. This section provides a list of preparers and agencies consulted during the development of the environmental assessment.  Appendices. The appendices provide more detailed information to support the analyses presented in the environmental assessment.

Additional documentation, including more detailed analyses of project-area resources, may be found in the project planning record located at the Cleveland National Forest Supervisor’s Office, 10845 Rancho Bernardo Road, Suite 200, San Diego, CA 92127.

1.2 Lead and Cooperating Agency Roles

The proposed action involves activities on National Forest System lands administered by USDA Forest Service, Cleveland National Forest, activities on lands administered by the Bureau of Land Management (BLM), Palm Springs - South Coast and El Centro Field Offices, and on the Capitan Grande Indian reservation for actions funded or undertaken by the Bureau of Indian Affairs (BIA). The Forest Service has been designated the lead Federal agency for preparation of this environmental assessment. As the lead agency, the

Forest Service assumes responsibility for coordinating the environmental analysis with the BLM and soliciting cooperation and input from other Federal, Tribal, State or local agencies with jurisdiction by law or special expertise on environmental issues that should be addressed in the environmental analysis. As a cooperating agency, the BLM provided technical support and agency specific expertise in preparation of this environmental assessment. The BIA was consulted and provided pertinent data for tribal lands and technical review.

1.3 Cooperation with State and Local Agencies

Concurrent with the NEPA environmental analysis for feral pig damage control on Federal lands, State and local agencies in San Diego County are undertaking an environmental analysis on a similar proposed action for feral pig damage control on lands under their jurisdiction according to the requirements of the California Environmental Quality Act (CEQA). The State of California Department of Parks and Recreation has been designated the lead agency for the CEQA analysis. The proposed actions and alternatives under the CEQA and NEPA analysis have been developed with interagency cooperation and cross participation in inter-disciplinary teams between the Federal and the State and local agencies.

1.4 Background

Feral pigs (Sus scrofa) are a non-native and invasive species to California and North America. Populations of feral pigs are the result of either escaped or released domestic livestock, European wild boars or a hybridization of the two. Environmental and agricultural damage from feral pigs across the United States has become a substantial problem nation-wide and has been widely documented in scientific literature and media reports. Recently the financial cost of feral pig damage to the environment and agriculture was estimated conservatively at $1.5 billion annually nationwide (West et al. 2009). As a result, several feral pig eradication and control efforts have been accomplished or are underway across the country. The magnitude of the feral pig problem is well illustrated by the volume of information on feral pig damage and feral pig control efforts available online with a simple search of the internet.

Until recently, feral pig populations on the CNF and surrounding areas have been very low (a few individuals) or non-existent. Over the past several years, however, feral pigs have been introduced by people, either intentionally or inadvertently, and populations have recently become established in several areas of the CNF. A map showing the proposed project area and locations with evidence of feral pig occupancy on the CNF and surrounding lands is depicted in Appendix A. Currently, there is not documentation of feral pig populations on Bureau of Land Management (BLM) lands in San Diego or southern Riverside counties, but feral pigs are expected to continue to expand their range and are likely to spread onto BLM lands. The Capitan Grande Indian Reservation is completely encircled by CNF lands where feral pig activity has been reported. It was

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added to the analysis due to its critical location for conducting a successful feral pig damage control program.

The Forest Service and the BLM are participants in the Inter-Governmental Group on Feral Pig Impacts. This group has developed Principles of Understanding to work together to address feral pig impacts in San Diego County and to develop an “all-lands” approach to dealing with the feral pig population. This group has established a “Working Group” where key participants from multiple agencies in the area have come together to share knowledge and develop strategies for dealing with the feral pig population in the County across jurisdictional boundaries (see section 2.6).

Feral pig populations have been growing in San Diego County in recent years as expected for the early phase of an introduction (SDNHM 2010 ). Survey results suggest that the feral pig population in San Diego County remains isolated from populations to the north in Riverside and Los Angeles Counties and to the south in Baja Mexico (SDNHM 2010). Due to this isolation, it is still possible to eradicate the feral pig population in the County. However, the goals of this project are to minimize damage to natural and cultural resources. So, while eradication is preferable and may be possible, controlling and reducing feral pig populations in San Diego County will meet project goals.

Trapping efforts have occurred in San Diego County on private lands. These efforts have resulted in notable decreases to feral pig damage in certain areas. For example, trapping occurred on Vista Irrigation District lands near Lake Henshaw in 2011. There was a notable decrease in feral pig sign on Palomar Mountain following the trapping effort. Feral pig damage has also been reduced in the Upper San Diego River, most likely due to trapping efforts on adjacent private ranchlands and organized hunts organized by the Barona tribe on Capitan Grande Indian Reservation. These efforts demonstrate that a desirable decrease in feral pig damage can occur as the result of actions to reduce pig populations.

Currently, recreational hunting of feral pigs is legal in California with a valid California hunting license and feral pig game tag. The hunting season for feral pigs is year round and there is no limit to the number of tags a hunter can purchase. Hunting is allowed on all Forest Service and BLM lands in the project area with minor exceptions. Despite significant hunter interest and activity on public lands, recreational hunting alone has not resulted in control or stabilization of feral pig population growth in San Diego County. Furthermore, a literature review revealed no known locations in the United States where feral pig recreational hunting alone has controlled feral pig populations.

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1.5 Affected Environment and Project Area

The proposed Feral Pig Management Program project area encompasses over 600,000 acres, including a significant portion of central San Diego County within the foothill and mountain zone, portions of southern Riverside County, and Forest Service lands within the Santa Ana Mountains of northwestern San Diego, Orange and southwestern Riverside Counties. Because of the size of the project area and its extensive geographical range, general habitat types or vegetation communities within the project area are diverse and include; sage scrub, chaparral, grassland, wetlands, riparian, oak woodland, mixed forest, desert scrub and desert wash. Proposed project activities will occur primarily within open or mixed open areas of grassland, oak woodland, riparian, and forested habitat types.

For both action alternatives, Alternative 2 and Alternative 3, the project area includes the entire CNF (Trabuco, Palomar and Descanso Ranger Districts), the BLM lands roughly surrounding the Palomar and Descanso Ranger Districts, and the Capitan Grande Indian Reservation. The project areas are depicted in the map in Appendix A. At this time, there have been feral pig reports but no widespread feral pig damage reported on the Trabuco Ranger District, but it has been included in the project area in case those conditions change. Capitan Grande Indian Reservation (CGIR) was added to this analysis due to its critical location. Without feral pig damage control activities on the CGIR, it is possible that the Reservation would serve as a sanctuary to feral pigs and could reduce the chances for success of the project. It is possible that federal funds may be used to conduct feral pig damage control on the CGIR. Although the project area as shown in Appendix B encompasses lands under a variety of governmental, tribal and private ownership, feral pig damage control activities proposed in Alternative 2 and Alternative 3 only apply to Federal lands within the project area which are under the administration of CNF or BLM, or lands within the CGIR. The total land area of the Federal lands within the project boundary is 618,706 acres with 423,472 acres of CNF lands, 179,694 acres of BLM lands and 15,540 acres on the Capitan Grande Indian Reservation.

The areas of greatest pig concentration currently are the Upper San Diego River area and its tributaries like Cedar and Boulder Creeks and lands on Palomar Mountain adjacent to Lake Henshaw. There has also been significant feral pig activity around the community of Descanso.

1.6 Purpose and Need

Since feral pigs became established on the CNF several years ago, they have been causing damage to biological, cultural and watershed resources (SDNHM 2010, CBI 2009). Pigs cause resource damage by turning up the soil with their snouts while rooting for food and creating wallows in riparian and oak grassland habitats. They compete with native wildlife and plants for habitat and resources and prey upon small native animals (Wilcox and Van Vuren, 2009). Feral pig populations can grow rapidly and dispersal can

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result in pigs quickly colonizing and populating new areas (Waithman et al. 1999, Bieber 2005)). Unless feral pig damage control efforts are undertaken, resource damage on public lands will become more widespread and increase in intensity.

The CNF Land Management Plan (LMP) directs the Forest Service to take action against damage caused by invasive species:

Forest Goal 2.1: Reverse the trend of increasing loss of natural resource values due to invasive species. The LMP desired condition is that the structure, function and composition of plant and animal communities are not impaired by the presence of invasive non-native plants and animals (LMP, Part 1 p. 32).

Implementation Strategy: IS 1 - Invasive Species Prevention and Control. Prevent the introduction of new invaders, conduct early treatment of new infestations, and contain and control established infestations (LMP, Part 2, p. 91).

The BLM Resource Management Plans (RMP’s) direct the agency to protect resources from degradation that may be caused by a variety of factors, including invasive species. Foraging by pigs may reduce oak regeneration because the animals have been known to feed on acorn masts (Sweitzer and Van Vuren, 2002). Given current declines in populations of coast live and black oaks due to drought related stress and the spread of the invasive Gold-spotted Oak Borer on CNF, further stress caused by pigs could present a significant problem for oak habitats.

The pigs are competing with native wildlife and plant species, including threatened, endangered and sensitive species, for habitat and resources. The distribution of feral pigs on the CNF overlaps with occupied habitat for the Least Bell’s Vireo, the Southwestern Willow Flycatcher, the California Gnatcatcher, the Arroyo Toad, Quino Checkerspot, and the Laguna Mountain Skipper, which are either federally threatened or endangered species. Irreparable and irreversible harm may occur to these animal species as a result of feral pig damage if no action is taken.

Forest Service sensitive animal species which may be impacted by pigs include the San Diego Horned Lizard, the Southern Pacific Pond Turtle, the Two-striped Garter Snake, the San Diego Ringneck Snake, the San Diego Mountain King Snake, the Rosy Boa, and the California Legless Lizard. Forest Service sensitive plant species that may be impacted by pigs include the Deane’s and the Descanso milkvetches, Orcutt’s clusterlily, Dunn’s Mariposa lily, Payson’s wild cabbage, Lakeside ceanothus, long-spined spineflower, delicate clarkia, foothill larkspur, Ramona horkelia, Parish’s slender meadowfoam, thickleaf mountainbalm, chaparral beargrass, Gander’s ragwort, Moreno currant, Laguna Mountain jewelflower, and velvety false lupine. Pigs also compete for habitat and forage with native game species and can destroy the nests, eggs, and young of ground-nesting bird species.

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Feral pigs can have negative effects on watershed and cultural resources as well. Pig populations are established in municipal watersheds serving San Diego County residents. Feral pigs wallowing and rooting in riparian areas and streamside environments can be detrimental to water quality. Damage to cultural resources sites is a concern. At least one pre-historic archeological site on CNF is already known to have been damaged by pig rooting and wallowing activities.

The purpose and need for the project is to eliminate or reduce impacts of feral pigs on the natural resources of CNF and surrounding BLM lands. There is also a need to prevent the CNF and BLM lands from becoming refuges for feral pig populations in order to aid County-wide feral pig management efforts on other government, private and tribal lands.

Figure 1. Feral Pig Damage in a Riparian Area near the San Diego River.

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Figure 2. Feral Pig Damage to a Meadow, Palomar Mountain.

Figure 3. Feral pigs rooting in a stream on Palomar Mountain

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1.7 Land Management Plan Direction, CNF

The proposed action is consistent with the Cleveland National Forest Land Management Plan (LMP, 2005). The proposed action is directly related to goals to reverse the trend of loss of resource values to non-native species, improve wilderness character, improve watershed and riparian conditions, and to provide ecological conditions to sustain viable populations of native species. All applicable LMP goals, direction and standards are found in Appendix B. 1.8 Resource Management Plan Direction, BLM

The proposed action is consistent with the South Coast Resource Management Plan (RMP,1994) . The South Coast RMP provides management guidance for public lands in Los Angeles, Orange, and western San Diego, San Bernardino, and Riverside Counties. The proposed action is also consistent with the Eastern San Diego Resource Management Plan (RMP, 2008). All applicable RMP goals, direction and standards are found in Appendix B.

1.9 Proposed Action

In order to address the purpose and need for this project, the CNF and BLM propose to inventory, trap, aerial hunt by helicopter and ground hunt with dogs feral pig populations on public lands. The BIA proposes to implement the same feral pig control measures on the Capitan Grande Indian Reservation. During these efforts, short spans of livestock fencing may be installed in certain areas to enhance the effectiveness of pig removal activities or to protect resources. An adaptive management process will be used to ensure project objectives are practical and attainable. Both short and long-term monitoring will be implemented to evaluate project success. Formulation of this proposed action draws upon a large body of experience from many successful feral pig elimination and control efforts across the United States in recent years that used a variety of methods.

1.10 Decision Framework

Based on the analysis contained in this environmental assessment and in the project record, the deciding official will select the Proposed Action, the No Action alternative, or an alternative to the proposed action for implementation. The CNF and BLM will each make separate decisions based on this analysis concerning implementation of an alternative for those lands under their respective jurisdictions and may select different alternatives for each jurisdiction. The BIA will make a separate decision based on this analysis for federal action in implementing or funding feral pig control activities on Capitan Grande Indian Reservation. Tribal governments are sovereign and have the authority to fund and conduct their own feral pig control efforts on tribal lands, including the Capitan Grande Indian Reservation.

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1.11 Public Involvement

The proposal is listed in the Schedule of Proposed Actions (SOPA). The 30-day scoping period for this project began with a legal notice published in The San Diego Union- Tribune on May 28, 2011. The legal notice summarized the proposed action and requested public input on the proposed action. A scoping letter explaining the proposed action was sent to the CNF mailing list of approximately 1,000 individuals, agencies, tribes, and organizations. Approximately 600 comments were received from the public during the 30-day scoping period. The draft Environmental Assessment included modifications made in response to comments. The public was notified of a 30-day public comment period to comment on the draft Environmental Assessment. Over 100 comments were received by email, approximately 20 comments were received by mail, and approximately 10 comments were received by telephone during this time period. Comments were used to help modify and clarify the Proposed Action and alternatives as described in the Final Environmental Assessment. In addition, a cost/benefit analysis was added to the Environmental Assessment (section 2.7).

1.12 Issues

The interdisciplinary team (ID team), considering public scoping, developed a list of key issues to be analyzed in this environmental analysis.  Impacts to wildlife and botanical resources, especially to federally listed threatened, or endangered species and species considered sensitive by Forest Service and BLM land management plans. This issue is analyzed in section 3.2.  Impacts to resources resulting from the establishment and spread of noxious weed species. This issue is analyzed in section 3.3.  Impacts to water quality, watershed condition and soil conditions. This issue is analyzed in section 3.4.  Impacts to heritage and cultural resources. This issue is analyzed in section 3.5.  Impacts to recreational opportunities. This issue is analyzed in section 3.6.  Impacts to wilderness characteristics. This issue is analyzed in section 3.7.  Impacts to crop agriculture and domesticated livestock production in the region. This issue is analyzed in section 3.8.

The issues below were raised during public scoping. They were identified during review of public scoping and considered for relevance in development of the proposed action and alternatives. Public scoping did lead to the consideration of several different alternatives.

1.12.1 An alternative method to control feral pigs that does not involve aerial hunting should be used. Commenters were concerned that aerial hunting of feral pigs with helicopters is a cruel and inhumane practice. Commenters were concerned that aerial hunting activities would reduce opportunities for recreational hunters. In response to this issue, Alternative

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2 was developed which excludes use of aerial hunting and is described in detail in Chapter 2.2 of this Environmental Assessment.

1.12.2 Professional hunting of feral pigs is cruel and inhumane. Commenters were concerned that removing and euthanizing pigs from public lands was cruel and inhumane treatment of animals. Feral pigs will be treated as humanely as possible during trapping and professional hunting operations to minimize their suffering under the proposed action. Humane treatment of the pigs is discussed in more detail in the description of the proposed action (Ch. 2.2).

1.12.3 The meat from feral pigs should not be wasted. Commenters did not want to see the meat from feral pigs wasted. In response to this issue an alternative was considered to distribute feral pig meat for human consumption (see Ch. 2.5.1).

1.12.4 Recreational hunters should be given a bigger role in the feral pig control effort. Commenters wanted to see a greater role given to the recreational hunting community in the control of feral pigs. Recreational hunting of feral pigs would be allowed to continue during implementation of the proposed action. However, recreational hunting of feral pigs has proven an ineffective method of addressing the problem. For the 2010-2011 hunting season, only eight feral pigs, or less than one-quarter of 1% of pigs taken in California, were reported as taken by hunters in San Diego County according to California Department of Fish and Game records (CDFG, 2011). Recreational hunting in California has not proven an effective method to reduce resource damage caused by pigs (Sweitzer, 2003). Alternative 1, the no-action alternative, relies on recreational hunting to control damage from feral pigs.

1.12.5 The financial cost of the project is not justified given the nature of the problem and other priorities. Commenters were concerned about the high cost of the project which may be several hundred thousand to several million dollars. Damage from feral pigs across the United States has proven a serious and costly problem impacting both natural resources and commercial agriculture. Feral pigs damage habitat for federally endangered species as well as archeological and watershed resources. The cost of inaction and damage to resources is likely to be higher over time than the cost of carrying out the proposed action. For these reasons and those further detailed in other sections of this document (Ch. 1.3, Ch. 2.3 and Ch. 3), the financial cost of the project is believed to be justified.

1.12.6 The military or volunteers should be used to reduce feral pig populations. Commenters and a National Guard unit offered their services for pig removal efforts as an alternative.

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In response to this issue, an alternative using military personnel or volunteers to undertake pig removal was considered (see Ch. 2.5.2).

1.12.7 It will not be possible to eliminate all feral pigs in the project area. Commenters were concerned that eliminating all feral pigs in the project area was not a realistic goal because of potential pig migrations or re-releases. Since feral pig populations in the project area are newly established and believed to number in the hundreds to low thousands, elimination of pig impacts along with most or all of the animals is believed feasible. Under the proposed action, after 5-years of intensive pig removal efforts project goals will be re-evaluated. If at that time elimination of the feral pig impacts is determined to have become impractical, efforts will shift to that of reducing impacts to minimize resource damage caused by feral pigs as much as possible. The proposed action addresses this issue (Ch 2.2)

1.12.8 Non-lethal methods of feral pig control should be considered. Commenters recommended non-lethal methods of feral pig population control such as sterilization and relocating the animals. In response to this issue, an alternative was considered for non- lethal pig control methods (see Ch. 2.5.3). Both action alternatives considered in detail in Chapter 2 also include a fencing component as a non-lethal control measure.

1.12.9 The Forest Service should consider opening up closed roads for better recreational hunting access into remote areas. Commenters suggested opening closed roads to hunters to help control feral pig populations. Many of the gated Forest Roads are closed to the public where the roads cross private lands because the Forest Service has no easement for public access on private property. However, the status of motorized access routes is outside the scope of this Environmental Assessment. The Cleveland National Forest analyzed motorized routes for public access in the Travel Management Environmental Assessment (2008). A decision about which roads would be available for public use was made based on that analysis.

1.12.10 Feral pigs serve beneficial environmental purposes. Commenters stated that feral pigs serve beneficial environmental purposes. Alternative 1, the no-action alternative, was analyzed in detail for the environmental consequences of feral pigs in this Environmental Assessment (Ch. 2.1, Ch. 3).

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CHAPTER 2 Alternatives

2.1 Introduction

This chapter describes and compares the alternatives considered under this environmental analysis. This chapter presents the alternatives in comparative form, defining the differences between each alternative and providing a basis for choice by the decision maker and the public. Some information used to compare the alternatives is based on the design of the alternative and some information is based upon the environmental and social effects of implementing each alternative.

2.2 Alternatives considered in detail

Three alternatives were considered in detail for this project. The alternatives are described below.

2.2.1 Alternative 1 (No Action) Under Alternative 1, current management plans would continue to guide management of the project area. Current management includes recreational feral pig hunting as currently managed by California Dept. of Fish an Game. Feral pig populations are expected to continue to occupy the CNF and the CGIR. Feral pig populations would increase in numbers and expand their range. BLM lands would soon be occupied by feral pigs. Damage to sensitive biological, cultural and watershed resources is expected to continue and increase over time.

2.2.2 Alternative 2 (Proposed Action) The proposed action is an integrated feral pig damage management approach wherein the most effective, selective and environmentally desirable method or combination of methods allowed under this alternative would be tailored to site specific field conditions. Based on variables encountered in the field such as location, topography, land uses, vegetation type and numbers of pigs, the Forest Service, BLM and BIA would decide which of the allowable control methods would be most suitable for their own jurisdictions. The proposed action can be implemented at different levels of intensity depending on the amount of funding that is received to carry out the effort. Project activities and control methods are described below.

1. Inventory feral pig populations and areas of resource damage. Prior to taking action to remove feral pigs, detailed data will be gathered to more accurately identify areas of feral pig habitation and environmental impact. This will help concentrate trapping and hunting efforts in key areas and make

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those efforts as effective as possible. Feral pig location data will be acquired by ground surveys, habitat mapping and modeling and a review of existing documentation concerning location of feral pig populations. Trail cameras may be deployed to track size and habits of sounders of pigs (a sounder is a herd of pigs/swine). Use of radio-collared “Sentinel Pigs” may also occur; this involves capturing feral pigs, outfitting them with radio collars and GPS units and releasing them so that they may be tracked and potentially reveal locations of additional animals.

2. Removal of Feral Pigs. Three methods will be employed to remove feral pigs from public lands within the project area. The methods will be used strategically and in coordination to maximize the reduction in feral pig numbers. It is believed that most animals will be removed by trapping, with professional ground-based hunting being used to pursue “trap-averse” animals after trapping efforts have taken place. Trapping has already proved to be an effective way to reduce feral pig impacts in San Diego County, as described above. Aerial hunting will be utilized only in remote locations that are difficult to access on foot, and is expected to be used only to pursue animals or sounders that are difficult to trap. Aerial hunting is expected to be the least used feral pig removal method, but may be necessary to completely clear some areas of feral pigs.

a. Trapping. Trapping is expected to be the largest part of feral pig damage control effort on Federal lands. Corral style traps large enough to hold multiple animals will be utilized in areas frequented by pigs. Open corral style traps allow large non-target wildlife such as deer to escape. Areas where trapping will take place will be determined from the results of ongoing efforts to monitor pig populations and impacts. They will likely be set near water sources, riparian areas or groves of oak trees where pigs are likely to congregate and forage. Traps will be set so as to avoid resource damage within areas of sensitive biological, cultural or watershed resources. Trapping in areas easily accessible by or visible to the public will be avoided as much as possible. If an important trapping location is used that is accessible or visible by the public, there may be a need for small scale temporary closures of some areas. Installation of traps may involve minor ground disturbance with the installation of fence t-posts and anchors, as well as the activity of the pigs themselves while they are inside the traps. Traps will be baited with grain or other food attractive to feral pigs. Trapping locations in remote areas may be logistically supported by helicopter as needed; trapping may also be supported by limited use of packstock when feasible. Stock would be restricted to designated trails.

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Humane treatment of captured feral pigs will be emphasized during the control program. Thus, during all capture operations traps would be set in the afternoon/evening and checked early the following morning to avoid the possibility of feral pigs overheating in traps prior to the arrival of a technician for dispatch. Captured animals would be dispatched quickly by gunshot to the head. For scientific purposes and for evaluating the progress of the control effort for changes in population age structure, basic biological data will be collected. After dispatch, all carcasses will be removed as soon as possible and transported to another location for disposal in compliance with California Department of Fish and Game codes and regulations and any other applicable laws and regulations. Blood and tissue remaining in or around the traps will be covered with soil or diluted with water to avoid attracting other wildlife.

It was recommended by Sweitzer and Loggins (2001) that during the first intensive trapping session, all traps should be set for captures for a minimum of 5 consecutive nights. Traps should then be locked open and prebaited for 5-7 days prior to being set for another 5 day capture period. Traps would typically be in one place no longer than two or three weeks to avoid acclimatizing pigs to the traps in those locations. Successive pre-baiting and capture periods would continue for the duration of the trapping session. Technicians/contractors would move traps to new locations when no additional captures are being made in an area. If large numbers of non-target wildlife are accessing the bait that would be unable to escape the set trap, the trap would be moved. At the end of the first session of intensive trapping, all traps would be removed from trapping locations, cleaned, repaired, and stored until the second trapping session. After the initial intensive trapping phase, both professional contract dispatchers and agency personnel would actively track and dispatch pigs during regular surveys in the project areas. This phase may also include tracking with dogs and aerial dispatch utilizing helicopters. Periodic surveys for fresh rooting disturbance would be used to assist trackers in locating areas with active groups of feral pigs. b. Ground hunting, potentially with trained dogs. Ground hunting will utilize professional hunters. Ground hunters will systematically cover terrain and work through each drainage basin to ensure no pigs are missed. The hunters will work closely with their trained dogs. The dogs will be trained to bark and corner pigs, but trained not to attack them nor harass wildlife. Dogs will be outfitted with radio collars and/or GPS units so hunters will be aware of their locations at all

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times. Ground hunting operations may be logistically supported by helicopter as needed and would include landing in remote locations, including Wilderness areas. Limited use of packstock to support ground operations may occur when feasible. Packstock would be restricted to designated trails. Night hunting with the use of night- vision technology may occur.

c. Aerial hunting with helicopters. Aerial hunting will involve a helicopter with a professional marksman systematically covering the terrain with precise, low altitude flights and working through each drainage basin searching for pigs. Helicopter landings in remote locations during these activities, including Wilderness areas, may be needed. Feral pigs are active in the mornings and evenings, and so most flights are likely to occur during those times. Aerial hunting will typically occur in remote locations that are inaccessible by road. To ensure public safety and minimize noise impacts, buffer zones of approximately ½ mile would be established around communities and residential subdivisions and, where desired, along tribal lands; buffer zones of approximately 1000 feet will be established around private lands and other facilities. Areas actively undergoing aerial hunting activities may be temporarily closed to the public by Forest Order to protect public safety. When pigs are found they would be quickly dispatched by lethal rifle shots. Individual carcasses may be left in place to decompose; multiple carcasses in the same area may be removed by helicopter and disposed of off-site if feasible.

d. Euthanization of pigs. Feral pigs trapped or hunted during this project will be put to death as quickly and humanely as possible. Experienced professional hunters will be used to minimize the chances that pigs are wounded and escape an encounter with hunters. Trapped pigs will be put to death as soon as possible after trapping to minimize distress to the animals. Use of aerial hunting methods is expected to reduce the number of pigs put to death during the project by shortening project duration and thereby reducing the reproduction of pigs in that time.

3. Disposal of carcasses: Disposal of feral pig carcasses will be dependent on location of dispatch and land jurisdictions. Food safety regulations and concern for disease transmission limit options for dealing with feral pig carcasses. In order for feral pig carcasses dispatched on Federal lands to be donated or sold for human consumption, there is a legal requirement that the pigs be slaughtered at a USDA inspected slaughter facility. Capturing and transporting live pigs to slaughter facilities would add greatly to the cost of the program to the public and is therefore not being considered. Based on discussions, donation of carcasses to zoos or wildlife facilities is unlikely due

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to similar concerns about disease transmission and prohibitive costs associated with testing each animal prior to donation. If a wildlife facility is identified that could accept carcasses in a cost effective manner, this option may be pursued.

When feasible, pig carcasses from trapping in accessible locations will be taken off site and disposed of according to applicable regulations. This may include transport to an animal rendering facility or landfill. In remote locations pig carcasses will be left in the project area to decompose and provide food for native wildlife (See Alternative 2.5.1).

4. Temporary fencing. Short spans of temporary fencing may be constructed within the project area to restrict or funnel movement of feral pig populations during trapping and hunting activities to enhance the effectiveness of those efforts. Fencing may also be used to protect environmentally sensitive areas from feral pig damage. Feral pig fences will be constructed with openings at ground level so as not to restrict the movement of small wildlife.

5. Monitoring. Basic biological information about pigs trapped or taken by professional hunters will be taken. Areas cleared of feral pigs will be regularly monitored for up to three years to ensure the pigs have truly been eliminated and do not return. Subsequently, intermittent long-term monitoring will continue indefinitely in case the animals are re-introduced to the area. Monitoring methods could involve the use of trail cameras, and the monitoring of likely use areas for signs of fresh rooting. In the event that feral pigs are found in an area in which they were believed to have been eliminated, trapping and hunting activities will resume there.

The Forest Service and BLM will maintain involvement with San Diego County-wide monitoring and inventory efforts that are part of the Inter- Governmental Group on Feral Pig Impacts. Monitoring by this group will be able to track estimates of total pig populations in the County and whether the current infestation in the County continues to remain isolated from adjacent populations.

6. Adaptive management. If after five years of intensive efforts, resource impacts from feral pigs have not been eliminated from the project area, then project goals shall be re-evaluated. Information from County wide monitoring being undertaken by multiple agencies will be used to determine if feral pig populations are being significantly reduced and if the geographic distribution of feral pigs is being reduced. If it is determined after five years that elimination of feral pig impacts from the project area is not a practical objective, then efforts will be scaled back to focus on reducing, rather than eliminating, environmental impacts of feral pigs by decreasing their numbers

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to the extent that is effective and feasible. Feral pig activity would be regularly monitored with trapping and hunting activities prescribed as needed to reduce impacts in sensitive areas.

7. Public Safety: Public and worker safety will be a top priority during all feral pig management activities. Professional hunters are highly trained individuals who will only take shots when target is visible and identifiable. If operations need to occur in an area with public access, there may be temporary trailhead or road closures. Any signage posted will be in English and Spanish and will use standard universal symbols to express the closure.

Aerial hunting operations are generally going to occur in very remote areas with little to no public access in the way of roads or trails. All special use permittees in an area where professional hunting (including aerial hunting) may occur will be notified prior to activities commencing. The military will be notified in advance if aerial hunting will be occurring in areas under special use permit for military training. It is unlikely that aerial hunting will ever be used in these areas as they are generally highly accessible by roads and trails.

Aerial hunting will not by conducted during extreme fire weather conditions. Helicopter operations will only occur during weather conditions and at altitudes were safe operations are possible.

8. Helicopter Flight Paths and Landing Areas. Helicopter flight paths and landing areas will be screened for effects on threatened, endangered and sensitive species to avoid negative impacts to those resources. Monitoring of nest locations for golden and bald eagles occurs annually. This information will be used to establish operating buffers and season of use restrictions for helicopters around active nest sites. Helicopter landing areas will be located in existing openings in vegetation and in previously disturbed locations. No improved landing areas will be constructed.

9. Helicopter use in Wilderness. The use of mechanized equipment is generally prohibited in federally designated wilderness areas, “... except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act...( The Wilderness Act, 1964)” For the Cleveland National Forest, the Pacific Southwest Regional Forester has the authority to authorize the use of mechanized equipment in Forest Service wilderness areas in certain situations. For the BLM, this authority falls to the Associate Field Manager. The approval considers the relative impact of the activity (in this case helicopter use) on wilderness characteristics and weighs that impact against consideration of necessity, safety, potential alternatives, and cost effectiveness.

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In order to receive approval the proposal must go through the Minimum Requirements Analysis process, which documents the necessity for the prohibited action in relation to the requirements for the administration of the wilderness area. This process also explores alternatives to the prohibited action. In the case of feral pig removal activities, the Forest Service and BLM will have to also consider whether project goals could be accomplished using pack teams and ground based hunting in wilderness areas. Trade-offs in terms of project success, cost effectiveness, and duration of the project will be considered before an approval for helicopter use can be made.

The approval process requires a level of specificity about the number and duration of helicopter flights that is impossible to determine at this time.

As feral pig control activities are undertaken, a clearer picture will emerge about what control methods will be most effective in various landscapes. This will lead to more detailed plans for helicopter use in areas that include wilderness. When this occurs, the Cleveland National Forest or BLM will go through the Minimum Requirements Analysis process to seek appropriate approval for the activity. It is expected that this approval will be sought on a per contract or per hunting season basis.

Helicopter use in wilderness areas will be considered when it is evident that their use would improve the likelihood of success of feral pig removal activities and would reduce the cost and duration of feral pig removal activities in wilderness areas compared to non-mechanized options. Impacts from helicopter use in wilderness areas are analyzed in this document in section 3.7.

9. Recreational Hunting: Public hunting of feral pigs is currently legal and expected to remain so throughout the duration of the project. It is possible that the Forest Service or BLM, in coordination with CA Fish and Game, may ask for organized hunts to put pressure on specific locations. California Fish and Game has organized special pig hunts in the state and there is the potential for these to take place in San Diego County.

10. Public Information. The Forest Service currently maintains a webpage with information for the hunting of wild pigs, including maps. This page can be found via the Cleveland National Forest homepage (http://www.fs.usda.gov/cleveland). This website will be updated with current information throughout the life of the project and provide links to other websites as they are developed.

California Fish and Game also maintains online information about feral pig hunting at http://www.dfg.ca.gov/wildlife/hunting/pig/. California Fish and

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Game also hosts a website about feral pig damage and options for private landowners at http://www.dfg.ca.gov/keepmewild/pig.html.

2.2.3 Alternative 3 (No aerial hunting) Alternative 3 is identical to Alternative 2, the proposed action, except that it excludes aerial hunting activities. This alternative was developed in response to public comments that expressed concerns about the aerial hunting of feral pigs.

2.3 Resource Protection and Design Features Common to All Action Alternatives

The following design features are incorporated into all action alternatives to avoid negative effects to resources and public safety as a result of implementation:

2.3.1 Pre-Activity Surveys for Feral Pig Damage and Focused Removal Efforts Prior to initiation of feral pig removal activities, surveys will be carried out to identify those specific locations being impacted by feral pigs. Pig removal efforts will be highly focused and limited to such areas.

2.3.2 Trap Placement and Vegetation Trimming Proposed trap locations and vegetation trimming activities will be screened for threatened, endangered and sensitive species and archeological sites to avoid impacting those resources. Traps may be placed in riparian areas but will not be placed directly in or directly adjacent to stream channels to avoid water quality impacts. Trap placement will avoid areas visible from recreation facilities, trails and roads to protect recreation resources and avoid potential vandalism.

2.3.3 Lead Free Ammunition Only lead free ammunition will be used during aerial hunting, ground hunting and euthanization of trapped pigs to avoid lead contamination and therefore potential adverse effects to wildlife.

2.3.5 Short Term Closures of Public Lands During periods of active aerial and ground based hunting operations, limited areas of public lands might be closed to public access for safety reasons. Closures will be restricted to the minimum size and duration needed for public safety. Closures of high use recreation areas will be avoided during weekends and holidays whenever possible.

2.3.6 Use of Weed-Free Feed for Packstock Any use of packstock will require certification of weed-free feed to minimize chances of introducing non-native and noxious weeds into the project area.

2.4 Comparison of Alternatives

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This section provides a summary of the effects of implementing each alternative. Information in the table is focused on activities and effects where different levels of effects or outputs can be distinguished quantitatively or qualitatively among alternatives. More detailed information on effects for each alternative is located in Chapter 3.

Table 1. Comparison of Effectiveness of Pig Removal by Alternative.

Alternative 1 Alternative 2 Alternative 3

No Action Proposed Action No Aerial Hunting

Lower. Ground Higher. Aerial hunters limited to hunting methods covering difficult will enable hunters terrain and to cover more land vegetation by foot area and remove and motorized use more pigs over a on roads only will Time given period of make slow effectiveness N/A time. progress. Lower Benefit. High Cost. While Higher Benefit. ground based High Cost. Aerial methods are hunting methods cheaper over a are expensive given period of relative to ground time, they will likely based methods take several times over a given period the duration of of time, but will efforts involving reduce project aerial methods, completion time thus negating most and reduce the cost saving benefit. amount of resource Resource damage damage from pigs will continue to carried out during occur for a longer project period because of Benefit / Cost N/A implementation.* slower progress.* Higher. Pig control Lower. Pig control efforts using aerial efforts without hunting methods aerial hunting have proven more methods have successful than pig proven less control efforts successful than pig Probability of without aerial control efforts with Success N/A methods.* aerial methods.*

*Based on a comparison of feral pig removal efforts using aerial hunting methods on Santa Cruz Island with feral pig removal efforts not using aerial hunting methods on Santa Catalina Island (Morrison, 2007).

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Table 2. Summary of Effects on Biological Resources by Alternative

Alternative 1 Alternative 2 Alternative 3

No Action Proposed Action No Aerial Hunting Negative. Pigs Positive, but to a will continue to lesser extent impact T&E habitat because results and adverse would take longer effects are and are expected expected to Positive. Damage to be less increase over time. control efforts will effective. Damage Effects on Irreversible and eliminate or reduce control efforts will Threatened and irretrievable feral pig impacts reduce impacts Endangered damage may occur and protect T&E and protect T&E Species (T&E) to listed species. habitat. habitat. Positive, but to a lesser extent because results would take longer Negative. Pigs and are expected will continue to Positive. Damage to be less impact sensitive control efforts will effective. Damage species habitat eliminate or reduce control efforts will and adverse feral pig impacts reduce impacts Effects on effects are and protect and protect Sensitive expected to sensitive species sensitive species Species increase over time. habitat. habitat. Positive, but to a lesser extent because results would take longer and are expected to be less Positive. Nesting effective. Nesting birds, chicks and birds, chicks and eggs are protected eggs are protected Negative. Pigs from predation by from predation by prey on nesting feral pigs as their feral pigs as their Effects on birds, chicks and numbers are numbers are Migratory Birds eggs. reduced. reduced. Positive, but to a lesser extent because results Negative. Pigs will would take longer continue to root and are expected and wallow under to be less oak canopies and effective. Damage feed on acorn Positive. Damage control efforts will mast adversely control efforts will eliminate or affecting seedling eliminate or reduce reduce feral pig Effects on Oak survival with feral pig impacts impacts and Woodlands effects increasing and promote promote seedling Regeneration over time. seedling survival survival

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Table 2. Alternative 1 Alternative 2 Alternative 3 (Continued) No Action Proposed Action No Aerial Hunting

Positive, but to a lesser extent because results would take longer and are expected to be less Positive. Removal effective. Removal Negative. Rooting of pigs will protect of pigs will protect and wallowing by against weed against weed pigs destroys infestation by infestation by ground cover and reducing or reducing or turns over the soil eliminating pig eliminating pig Effects on making areas caused disturbance caused Noxious Weed susceptible to of soil and disturbance of soil Management weed infestation. vegetation. and vegetation.

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Table 3. Summary of Effects on Watershed Resources by Alternative

Alternative 1 Alternative 2 Alternative 3 No Action Proposed Action No Aerial Hunting

Positive, but to a lesser extent because results would take longer Negative. Pigs and are expected will continue to to be less root and wallow in Positive. Damage effective. Damage sensitive stream- control efforts will control efforts will Effects on side environments eliminate or reduce reduce feral pig Riparian with effects feral pig impacts impacts and Conservation increasing over and protect stream- protect stream- Areas time. side environments. side environments. Positive, but to a lesser extent Negative. Pigs because results rooting and would take longer wallowing in and and are expected along water Positive. to be less courses will Elimination or effective. increase reduction of pig Reduction of pig sedimentation and populations will populations will fecal bacteria in protect water protect water Effects on Water municipal quality in municipal quality in municipal Quality watersheds. watersheds watersheds.

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Table 4. Summary of Effects on Recreation Resources by Alternative

Alternative 1 Alternative 2 Alternative 3

No Action Proposed Action No Aerial Hunting Negative, but to a lesser extent because results would take longer and be less Negative. Feral effective. Feral pig pig hunting would hunting would continue, but continue, but Positive. removal of feral removal of feral Recently pigs will reduce pigs will reduce established population numbers population opportunities to and eliminate or numbers and hunt feral pigs will reduce recently reduce recently Effects on continue and are established established Recreational expected to opportunities to opportunities to Hunting increase over time. hunt feral pigs. hunt feral pigs. Negative. Positive, but to a Encounters with lesser extent as the recreating results would take public will increase longer and be less along with safety Positive. As feral effective. As feral concerns. Some pig removal efforts pig removal efforts animals may grow reduce numbers of reduce numbers of quite large and pigs, public safety pigs, public safety become will be maintained will be maintained Effects on aggressive. or improved and or improved and Developed and Recreation sites recreation sites will recreation sites will Dispersed may experience be protected from be protected from Recreation resource damage. damage. damage.

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Table 5. Summary of Effects on Cultural, Wilderness, Agriculture and Range Resources by Alternative

Alternative 1 Alternative 2 Alternative 3

No Action Proposed Action No Aerial Hunting Positive, but to a lesser extent because results would take longer and are expected Negative. Feral to be less pigs rooting and Positive. Cultural effective. Cultural Effects on wallowing behavior resources are resources are Cultural and disturbs soil, along protected by protected by Heritage with cultural reducing numbers reducing numbers Resources resources. of pigs. of pigs. Positive. Positive, but to a Reduction or lesser extent elimination of pig because results impacts to would take longer Negative. Feral Wilderness areas and are expected pigs are a non- will protect their to be less native species and natural character. effective. their behavior Wilderness Reduction or damages character will be elimination of pig resources. Pigs in temporarily impacts to Effects on Wilderness detract impacted by Wilderness areas Wilderness from natural presence of aircraft will protect their Character character. and traps. natural character. Positive, but to a lesser extent because results would take longer Negative. Feral and are expected pigs are known to to be less damage Positive. Removal effective. Removal agricultural crops. of pigs will protect of pigs will protect Effects on Agriculture is a agriculture within agriculture within Agriculture large part of the and in proximity to and in proximity to Resources local economy. the project area. the project area. Positive, but to a lesser extent because results Negative. Feral would take longer pigs are known to and are expected transmit diseases to be less to cattle and other effective. livestock and Positive. Removal Removal of pigs damage range of pigs will protect will protect Effects on improvments such livestock from livestock from Range as fencing and potential disease potential disease Resources water sources. transmission. transmission.

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Table 6. Animal Welfare Comparison by Alternative

Alternative 1 Alternative 2 Alternative 3

No Action Proposed Action No Aerial Hunting Invasive feral pigs compete with Pig removal efforts native species for which include the Pig removal efforts habitat and prey use of aerial which exclude the on small animal hunting methods use of aerial species leading to would be a more hunting methods displacement and time effective would be death. Irretrievable removal strategy. substantially less and irrerversible Because of faster time effective. harm may occur to pig removal efforts Because of this Threatened and using aerial more pigs will Endangered hunting, less reproduce during species as a result animals would have the project, of feral pig to be put to death resulting in more Animal Welfare occupancy of the during the project animals that would Effects project area. duration.* be put to death. * *Based on a comparison of feral pig removal efforts using aerial hunting methods on Santa Cruz Island with feral pig removal efforts not using aerial hunting methods on Santa Catalina Island (Morrison, 2007).

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2.5 Alternatives considered but not analyzed in detail

The following alternatives were considered but not brought forward for detailed analysis. The alternatives and rationale for their elimination from further study are described below.

2.5.1 Distributing Feral Pig Meat for Human Consumption This alternative was considered in response to public comments (see Ch. 1.7.3) and a desire on the part of the Forest Service and BLM that feral pig meat should not be wasted. Under this alternative, feral pigs would need to be captured alive and transported to an approved USDA inspected slaughter facility. The closest such facilities for pigs are located in northern California, several hundred miles from the project area. Capturing pigs alive in remote locations with rugged topography, dense vegetation and limited access and transporting them to approved slaughter facilities would not be practical or financially feasible given the scale of the project. Therefore, this alternative was not given further consideration.

2.5.2 Military or volunteers should be used to reduce feral pig populations This alternative was considered in response to public comments (see Ch. 1.7.6) that offered volunteer or military services for feral pig hunting. This is not within the direct mission of the military, who’s priorities can shift at any time based on military priorities. Treatment requires greater certainty of presence of specific and consistent trained personnel. Volunteers are prone to turnover and vary considerably in their skills and physical ability to do this work under arduous conditions. In addition, the government assumes liability and responsible for physical injuries or accidents when incurred as part of official volunteer duties. A single accident could significantly increase the cost of operations. These consideration, along with concerns for public safety and humane treatment of animals led to elimination of this alternative. Only highly trained and experienced professional pig hunters would carry out pig removal efforts for the agencies because of these reasons. Recreational hunting of pigs would not be restricted under any of the alternatives considered in detail.

2.5.3 Non-lethal feral pig control methods should be considered This alternative was considered in response to public comments (see Ch. 1.7.8) that recommended non-lethal methods of feral pig population control such as sterilization and relocating the animals. Feral pig control efforts have been carried out for many years across the United States and a variety of methods have been tried. Lethal methods are recognized as the most widely used and effective means of feral pig control (West et al. 2009). Non-lethal means on a large scale are not used for pig control efforts because they have not yet been proven effective and are still widely considered experimental. Methods such as relocation of animals are complex, labor intensive and not practical given the magnitude of the problem (Sweitzer, 2003). There are no known facilities in the region that are capable of lawfully handling captured feral pigs for relocation purposes.

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Relocation of live animals would require the ability to transport pigs from all trapping locations. This is not feasible in the remote areas where pigs are currently found.

There are currently no permanent methods for feral pig sterilization that do not require field surgery of captured animals to perform castration or spaying. There is a sterilization injection (GonaCon™) that has recently become available and has shown to be effective for up to five years in feral pigs (USDA 2011a). This is the approximate lifespan for feral pigs. However, field surgery and injections require trapping feral pigs. Once trapped, dispatching of pigs is a cheaper and more assured method to prevent further reproduction. Releasing pigs back into the wild would fail to address the purpose and need of the project by allowing pigs to continue to damage native habitat and property, threaten agriculture production and pose threats to water quality and human health. Neither the Forest Service nor BLM would be able to release non-native animals back into the wild after capture based on guidance in our management plans to limit damage from non-native species. One exception may be the use of “sentinel pigs” to help identify and remove larger pig populations. For these reasons, extensive use of non- lethal control methods was not considered in detail. Exclosure fencing to protect sensitive resource areas is one non-lethal control method that is incorporated into both of the action alternatives (Ch. 2).

2.6 Element Common to all Action Alternatives: All Lands Approach - Inter- agency coordination:

The feral pig population in San Diego County is not isolated on Federal lands or any particular jurisdiction. Feral pigs have rapidly spread onto lands governed or owned by many different jurisdictions and tribes. To help coordinate feral pig control efforts across the County, an Inter-Governmental Group on Feral Pigs was formed. A Principles of Understanding (POU) was signed by tribal governments and jurisdictions ranging from city governments, State agencies, water districts and the Forest Service and BLM. All these entities agreed to work together, potentially pooling financial and human resources towards a county-wide effort to eradicate or control feral pigs recognizing that any course of action necessitates cooperation and willingness of adjacent landowners to work together since pigs move freely band forth across jurisdictional boundaries. The purpose of this group is to coordinate feral pig management actions, foster collaboration and share information to address the negative impacts of feral pigs to our natural and cultural resources as well as the economic and physical health of our region.

Concurrent with this EA, a California Environmental Quality Act (CEQA) document is being prepared to support work on lands under State, County and City of San Diego lands.

Members of the group have already conducted feral pig inventory and monitoring activities in the County.

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2.7 Estimated Costs and Cost/Benefit Comparisons of Alternatives:

Alternative 1: No Action:

Analyzing the potential economic costs for allowing feral pigs presence to continue under current management on federal lands (legalized game hunting only) provides information to compare costs of feral pig control activities with benefits of preventing feral pig damage.

Feral pigs cause damage to property, crops, and other natural resources through disturbance and by being vectors for disease. Pimentel (2007) estimated that crop damage nationwide averaged $300.00 annually per pig. One estimate of damage to crops from pig rooting alone was $1.73 million dollars annually across 40 counties in California in the 90’s (Frederick 1998 via CBI 2009). . In San Diego County, Animal and Plant Health Inspection Service (APHIS) personnel estimated economic damage from feral pigs at $38,640.00 dollars over 2 ½ year period at properties they were requested to visit. Most of this damage was loss of pasture due to pig rooting as well as damage to turf grasses and landscaping (John Turman, email communication). This figure only represents assessments on a small selection of properties in the county of this time period. In addition, economic damages could increase significantly in San Diego County if there was an instance of food contamination due to feral pigs as has occurred elsewhere in the California (Jay 2007).

Economic costs associated with impacts to natural resources are difficult to estimate because it is difficult to attribute monetary values to amenities like wildlife habitat damage or reduced oak recruitment (CBI 2009). This is the case with most of the damage that is occurring on CNF and BLM lands in the project area. The Conservation Biology Institute assessment for San Diego County notes that, “Damage to these lands can result in costs associated with damage to sensitive habitats or species, as well as declines in visitor experience, and these costs should be considered in the assessments of the monetary costs of feral pigs (CBI 2009).

All the economic costs associated with feral pig presence would be ongoing, adding to total economic damages annually. Total potential monetary costs are difficult to estimate for feral pigs in San Diego. Costs are likely to increase annually, especially if the feral pig population expands into orchard and other agricultural areas. Recent estimates for economic damage over a five year period Statewide were $1.7 million dollars (Krieth 2007). This estimate was before recent E. Coli outbreaks in spinach that were attributed to feral pig activity.

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Feral pigs in San Diego can result in some economic income in the form of hunting tourism. Landowners could charge a hunting fee on private lands. Between 1999 and 2009, California Department of Fish and Game made between $340,000 and $877,000 annually from the sale of pig hunting tags statewide (CBI 2009). “However, the state also invests a great deal of resources in pig management, and it is unknown if profits from tag sales can offset the cumulative costs of management, damage to agricultural resources, and the extensive but difficult to quantify impacts to natural resources (CBI 2009.”.

Alternative 2: Proposed Action:

The proposed action can be implemented at different levels of intensity depending on the amount of funding that is received to carry out the effort. It is difficult to estimate a total cost for the project due to the uncertainty in funding and the uncertainties regarding the feral pig populations and their movements.

One cost estimate was developed for the possibility that multiple agencies would be able to fund a coordinated and intensive three year San Diego County wide eradication effort, including aerial hunting. The estimate was that this effort would cost 1.6 to 2.0 million dollars (Pers Communication. The Nature Conservancy, Dave Van Cleves). The share of this cost for work on the CNF and BLM lands would depend on funding availability.

It is also possible that funding will be available for smaller level efforts for several years. Estimates of these costs can be derived from efforts already underway. In San Diego County trapping has occurred in several locations on private lands and on Vista Irrigation District lands. APHIS conducted trapping on several private properties with depredation permits in the county for costs around $20,000 including staff time and materials (John Turman, email communication). Vista Irrigation District was able to trap 30 feral pigs for costs under approximately $10,000. Costs for trapping on Federal lands will likely be higher than these due to more remote trapping locations. Very remote trapping locations may require the use of helicopters to move and stage materials and personnel, adding greatly to the cost.

Current costs for contracts to monitor and map the current extent of feral pig distribution in the County are $15,000 a year. These costs are being currently being paid by other organizations. These costs are expected to continue for the life of the project.

In total, very rough estimates for costs of undertaking the project range from approximately $50,000/year from Federal agencies for trapping and monitoring activities on Federal lands to near one million dollars for the federal share of a coordinated, rapid county wide eradication effort that would last several years.

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Alternative 3: No Aerial Hunting:

Costs for this alternative are expected to be similar to the proposed action. This alternative may still rely on helicopters to move trapping materials and personnel into remote locations. Any saving from not hiring helicopters for aerial hunting is likely to be offset by increased costs in hiring more days for professional hunters or increased trapping in the backcountry and increased duration of the control efforts.

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CHAPTER 3 Environmental Consequences

3.1 Introduction

This section summarizes the physical, biological, social and economic environments of the affected project area and the potential changes to those environments due to implementation of the alternatives. It also presents the scientific and analytical basis for the comparison of alternatives presented in the charts in Chapter 2.

Cumulative effects: A general discussion of cumulative effects is provided for each issue area. Cumulative effects analysis is used to determine if potential impacts from the alternatives would add to impacts that are occurring to resources from other proposed projects or ongoing activities. The analysis is used to determine if all impacts to a resource would add up to a significant impact on a resource.

Because the project area is so large, potential projects and ongoing activities that are considered are different for each resource area.

3.2 Wildlife and Botanical Resources

The proposed project area encompasses over 600,000 acres, including a significant portion of central San Diego County within the foothill and mountain zone, portions of southern Riverside County, and Forest Service lands within the Santa Ana Mountains of San Diego, Orange and Riverside Counties. This area includes 11 primary watersheds. Because of the size of the project area and its extensive geographical range, general habitat types or vegetation communities within the project area are diverse and include; sage scrub, chaparral, grassland, wetlands, riparian, oak woodland, mixed forest, desert scrub and desert wash. Proposed project activities, particularly ground disturbing actions from trapping will occur primarily within open areas of grassland, oak woodland, riparian, and forest habitat types.

Special status species considered in this analysis are those which are state or federally threatened, endangered or candidate, Regional Forester’s Sensitive Species, and BLM Sensitive Species. Only those species that are known or have the potential to occur within the project area are listed, and only those species with the potential to be negatively affected by project activities are addressed in detail. There are 122 endangered, threatened, candidate, and sensitive plant and animal species listed as occurring or potentially occurring on the Cleveland National Forest and BLM lands within the project area, including 46 animal (Table 7) and 76 plant species (Table 8). Information on listed species which have the potential to occur within the proposed project area were identified from field surveys, USDA Forest Service databases, files and reports, project reports, California Natural Diversity Data Base (CNDDB), and BLM documents. Twenty-six of

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the 122 species are Federal and/or State listed as endangered or threatened. Only six of these species were determined to have the potential to be negatively affected by the proposed project activities. They are: Bald Eagle and Golden Eagle, Penisular Bighorn Sheep, Arroyo Toad, Southwestern Willow Flycatcher and Least Bell’s Vireo.

The impacts to the special status wildlife and plant species of the proposed action were analyzed in a Biological Assessment and Biological Evaluation (BA/BE) prepared for this project and contained in the project record. This section presents a summary of the findings from this analysis.

Table 7: Special status wildlife species within the Feral Pig Management Program Area.

1

2

4

4

3

BLM List BLM

Federal Listing State Listing USFS List LISTED ANIMAL SPECIES Documented on Cleveland NF Documented in Project Area Potential Occurrence in Project Area Suitable Habitat in Project Area Designated Habitat in Project Area Potential For Negative Effects. BIRDS Bald Eagle* Haliaeetus leucocephalus E S Yes Yes - Yes Golden Eagle Aquila chrysaetos S Yes Yes - Yes Swainson's Hawk Buteo swainsoni T Yes Yes - No California Spotted Owl Strix occidentalis occidentalis C S Yes Yes - No Southwestern Willow Flycatcher Empidonax trailii extimus E E Yes Yes Yes Yes Least Bell's Vireo Vireo bellii pusillus E E Yes Yes Yes Yes California Gnatcatcher Polioptila californica T C Yes Yes Yes No Gray Vireo Vireo vicinior S Yes Yes - No San Diego Cactus Wren Campylorhynchus brunneicapillus C S Yes Yes - No Burrowing Owl Athene cunicularia S No Yes - No Tricolored Blackbird Agelaius tricolor S Yes Yes - No White-tailed Kite Elanus leucurus S Yes Yes - No Western Yellow-billed Cuckoo Coccyzus americanus occidentalis C E S No No No No - No

1 T-Threatened, E-Endangered, C-Candidate 2 T-Threatened, E-Endangered, R-Rare 3 S- Regional Forester’s Sensitive Species, BLM Sensitive Species

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Table 7 continued.

1

2

4

4

3

BLM List BLM

Federal Listing State Listing USFS List LISTED ANIMAL SPECIES Documented on Cleveland NF Documented in Project Area Potential Occurrence in Project Area Suitable Habitat in Project Area Designated Habitat in Project Area Potential For Negative Effects? MAMMALS California Leaf-nosed Bat Macrotus californicus C S S No ? Yes - No Pallid Bat Antrozous pallidus C S S Yes Yes - No Western Red Bat Lasiurus blossevillii C S Yes Yes - No Townsend's Big-eared Bat Corynorhinus townsendii townsendii C S S Yes Yes - No Spotted Bat Euderma maculatum S No ? Yes - No Western Mastiff Bat Eumops perotis californicus S No ? Yes - No Yuma Myotis Myotis yumanensis S No ? Yes - No Small footed Myotis Myotis ciliolabrum S Yes Yes - No Long-eared Myotis Myotis evotis S ? ? Yes - No Fringed Myotis Myotis thysanodes S ? ? Yes - No Stephen's Kangaroo Rat Dipodomys stephensi E E Yes Yes - No Peninsular Bighorn Sheep Ovis canadensis nelsoni E T No Yes - Yes Los Angeles Pocket Mouse Perognathus longimembris brevinasus C S No No No No - No REPTILES and AMPHIBIANS Two-striped Garter Snake Thamnophis hammondii C S S Yes Yes - No San Diego Mountain Kingsnake Lampropeltis zonata pulchra C S S Yes Yes - No San Diego Ringneck Snake Diadiphis punctatus similis S Yes Yes - No Coastal Rosy Boa Charina trivirgata roseofusca S Yes Yes - No Silvery Legless Lizard Anniella pulchra pulchra C S Yes Yes - No San Diego Horned Lizard Phrynosoma coronatum blainvillei C S S Yes Yes - No Barefoot Gecko Coleonyx switaki T S No ? Yes - No Coranado Skink Plestiodon skiltonianus S Yes Yes - No Southwestern Pond Turtle Clemmys marmorata pallida C S S Yes Yes - No Arroyo Southwestern Toad Bufo microscaphus californicus E C Yes Yes Yes Yes California Red-legged Frog ** Rana aurora draytoni T C No No No No No No Sierra Madre Yellow-legged Frog ** Rana muscosa E C S No No No No No No Western Spadefoot Toad Scaphiopus hammondi S Yes Yes - No Large-blotched Salamander Ensatina eschscholtzii klauberi C S Yes Yes - No FISH Southern Steelhead Trout Oncorhynchus mykiss E C S Yes Yes - No Arroyo Chub Gila orcutti C S Yes Yes - No Santa Ana Speckled Dace C S Yes No No - No INVERTEBRATES Hermes Copper Butterfly Lycaena hermes S Yes Yes - No Thorne's Hairstreak Butterfly Callophrys thornei S ? ? - No Quino Checkerspot Butterfly Euphydryas editha quino E Yes Yes Yes No Laguna Mountain Skipper Pyrgus ruralis lagunae E Yes Yes Yes No Warner Springs Shoulderband Snail Rothelix warnerfontis S Yes Yes - No 1 T-Threatened, E-Endangered, C-Candidate 2 T-Threatened, E-Endangered, R-Rare 3 S- Regional Forester’s Sensitive Species, BLM Sensitive Species

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Table 8. Special Status Listed Plant Species for the Feral Pig Management Program Area.

1

3

2

4

Federal Listing State Listing Forest Service BLM

Documented on Cleveland NF Potential Presence in Project Area SPECIES No Action- Advers Effects Action Alternatives - Adverse Effects Acanthomintha ilicifolia San Diego Thorn-mint T E Yes Yes Yes No Ambrosia pumila San Diego Ambrosia E No Yes Yes No Allium munzii Munz's Onion E T Yes Yes Yes No Astragalus brauntonii Brauton's Milk Vetch E No Yes Yes No Baccharis vanessae Encinitas Baccharis T E Yes Yes Yes No Berberis nevinii Nevin's Barberry E E Yes Yes Yes No Brodiaea filifolia Thread-leaved Brodiaea T E Yes Yes Yes No Ceanothus ophiochilus Vail Lake Ceanothus T E Yes Yes Yes No Dodecahema leptoceras Slender-horned Spineflower E E Yes Yes Yes No Dudleya cymosa var. ovatifolia Oval-leaved Dudleya T Yes Yes Yes No Fremontodendron mexicanum Mexican Flannelbush E R No Yes Yes No Nolina interrata Dehesa Nolina E Yes Yes No Poa atropurpurea San Bernardino Bluegrass E S Yes Yes Yes No Rosa minutifolia Small-leaved Rosa E No No No No Abronia villosa v. aurita Sand Verbena S Yes No Arctostaphylos otayensis Otay Manzanita S No Yes Yes No Arctostaphylos rainbowensis Rainbow Manzanita S Yes Yes No Astragalus deanei Dean's Milk-vetch S S Yes Yes No Astragalus douglasii var. perstrictus Jacumba Milk-vetch S S Yes Yes No Astragalus oocarpus San Diego Milk-vetch S S Yes Yes No Astragalus pachypus var. jaegeri Jaeger's Milk-vetch S Yes Yes No Brodiaea orcuttii Orcutt's Brodiaea S S Yes Yes No Calochortus plummerae Plummer's Mariposa Lily S Yes No Calochortus dunnii Dunn's Mariposa Lily R S Yes Yes No Calochortus weedii var. intermedius Intermediate Mariposa Lily S Yes Yes No Castilleja lasiorhyncha San Bernardino Mountains Owl's Clover S No Yes No Caulanthus simulans Payson's Jewel-Flower S Yes Yes No Ceanothus cyaneus Lakeside Ceanothus S S Yes Yes No Chorizanthe parryi v. parryi Parry's Spineflower Yes No Chorizanthe polygonoides var. longispin Long-spined Spineflower S Yes Yes No Clarkia delicata Delicate Clarkia S S Yes Yes No Cupressus stephensonii Cuyamaca Cypress S Yes Yes No Cupressus forbesii Tecate Cypress S S Yes Yes No Deinandra floribunda Tecate Tarplant S No Yes Yes No Delphinium hesperium ssp. cuyamacae Cuyamaca Larkspur R S Yes Yes No Dudleya multicaulis Many-stemmed Dudleya S S Yes Yes No Dudleya viscida Sticky Dudleya S Yes Yes No Dudleya variegata Variegated Dudleya S Yes No Eriogonum evanidum Vanishing Wild Buckwheat S Yes No Galium californicum ssp. Primum California Bedstraw S Yes No Githopsis diffusa ssp. filicaulis Mission Canyon Bluecup S No Yes No Hazardia orcuttii Orcutt's Hazardia S Yes No Hemizonia floribunda Tecate Tarplant S S No Yes No Hemizonia mohavensis Mojave Tarplant E S S Yes Yes No Heuchera brevistaminea Laguna Mountains Alumroot S No Yes Yes No Horkelia cuneata puberula Star Potentilla S Yes No Horkelia truncata Ramona Horkelia S Yes Yes No Hulsea californica San Diego Sunflower S Yes No Lepechinia cardiophylla Heart-leaved Pitcher Sage S Yes Yes No Lepechinia gander Gander's Pitcher Sage S Yes No Lessingia glandulifera var. tomentosa Warner Springs Lessingia S No Yes No Lilium parryi Lemon Lily S Yes Yes No Linanthes gracilis ssp. parishii Parish's Meadowfoam E S Yes Yes No 1 T-Threatened, E-Endangered, C-Candidate 2 T-Threatened, E-Endangered, R-Rare 3 S- Regional Forester’s Sensitive Species, BLM Sensitive Species

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Table 8 (cont.). Special Status Listed Plant Species for the Feral Pig Management Program Area.

1

3

2

4

SPECIES FederalListing Listing State ForestService BLM on Documented NF Cleveland Presence Potential Area Project in No Action- Effects Adverse Action Alts- Adverse Effects Linanthus orcuttii Orcutt's Linanthus S S Yes Yes Yes No Lupinus excubitus var. medius Mountain Springs bush Lupine S Yes Yes No Machaeranthera asteroides var. lagunensis Laguna Mtn. Aster R S Yes Yes Yes No Monardella hypoleuca ssp. lanata Felt-leaved Monardella S Yes Yes Yes No Monardella macrantha ssp. hallii Hall's Monardella S Yes Yes Yes No Monardella nana ssp. leptosiphon San Felipe Monardella S Yes Yes Yes No Muilla clevelandii San Diego Goldenstar S Yes Yes No Navarretia peninsularis Baja Navarretia S No Yes Yes No Navarretia fossalis Spreading Navarretia Yes Yes No Nolina cismontana Chaparral Beargrass S Yes Yes Yes No Packera ganderi Gander's ragwort R Yes Yes No Penstemon californicus California Beardtongue S No Yes Yes No Phacelia suaveolens ssp. keckii Santiago Peak Phacelia S Yes Yes Yes No Ribes canthariforme Moreno Currant S S Yes Yes Yes No Satureja chandleri San Miguel Savory S Yes Yes Yes No Scutellaria bolarderi ssp. austromontana Southern Skullcap S Yes Yes Yes No Senecio ganderi Gander's Butterwort R S Yes Yes Yes No Sibaropsis hammattii Hammitt's Clay-crest S Yes Yes Yes No Streptanthus berardinus Laguna Mtn. Jewelflower S Yes Yes Yes No Streptanthus campestris Southern Jewelflower S S Yes Yes No Symphyotrichum defoliatum San Bernardino Aster S Yes Yes No Tetracoccus dioicus Parry's Tetracoccus S S Yes Yes Yes No Thermopsis californica var. semota Velvety False Lupine S Yes Yes Yes No 1 T-Threatened, E-Endangered, C-Candidate 2 T-Threatened, E-Endangered, R-Rare 3 S- Regional Forester’s Sensitive Species, BLM Sensitive Species

3.2.1 Direct and Indirect Effects

Alternative 1 – No Action: Under this alternative, feral pigs would continue to have a negative impact on native wildlife and flora through habitat disturbance, trampling and direct competition for resources such as food and water as described in the purpose and need section. Some native plant and animal species may benefit from the habitat disturbances, or from utilizing feral pigs as a prey species or as a source for carrion. All sensitive plant species have the potential to be negatively impacted by feral pig activity through trampling and rooting.

Irrerversible harm may occur to threatened and endangered species as a result of feral pig occupancy of the project area. Arroyo Toads, which burrow in sandy riparian soils, would continue to be directly impacted by pig trampling and rooting behavior. Willow Flycatchers and Least Bell’s Vireos, both riparian nesting birds, would continue to be impacted by disturbances to their habitats. The Peninsular Bighorn Sheep could become impacted by possible disease transmission and for competition for watering sites if the feral pigs expand into their range.

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Alternative 2 – Proposed Action: Under this alternative, impacts to native wildlife and plant species from feral pigs will be eliminated or drastically reduced. Individuals of certain wildlife may be disturbed by hunting activities, firearm discharge, hunting dogs and helicopter noise. Individuals of certain plant species may be impacted by trampling from hunting teams and dogs and in areas of trapping and feral pig herding. These impacts are expected to be minor and transitory.

The BE/BA determined that six special status species have the potential for negative effects from implementation of the proposed action (see table 7). Bald and Golden Eagles could be disturbed by aerial hunting activities around nest sites. Peninsular Bighorn Sheep could also be disturbed by helicopter activities, especially during lambing activities. Arroyo Toad could be negatively impacted by trap placement in burrowing areas. Least Bell’s Vireo and Southwestern Willow Flycatcher could also be impacted by trap placement and by pruning or trimming of riparian vegetation for trap placement or temporary fencing. These potential impacts have led to the development of several mitigation measures and restrictions as part of the project design. With the mitigations in place, it was determined that the proposed action would not adversely affect these six species.

The traps being utilized are open topped corral style traps. The most likely non-target wildlife species that will be attracted to these traps are deer. They will be able to escape the trap by leaping out. Smaller wildlife will be able to escape through the paneling. The trap will be open and monitored for several days before setting. If large numbers of non- target wildlife are accessing the bait, the trap may be moved. Due to these design features, it is possible, but unlikely, that non-target wildlife will be directly impacted by trapping efforts.

Some native animal species may benefit carrion feeding on carcasses that are left in remote areas from the proposed action. These include Turkey Vultures, Coyotes, Bobcats, Mountain Lions, Ravens and Crows. The limited timeframe that carcasses may be available in any particular area is expected to limit any effect of increasing populations of these animals.

Alternative 3 – No Aerial Hunting: This alternative would have impacts similar to the proposed action except that impacts from helicopters would be eliminated while impacts from ground hunting teams would be increased. These impacts would continue to be minor and transitory. Because it would likely take longer to reduce feral pig populations without aerial hunting, the beneficial impacts from reducing or eliminating feral pig activity would be less immediate than from the proposed action, but a net benefit is still expected to occur.

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3.2.2 Cumulative Effects

Feral pig activity is expected to add to impacts caused by other non-native plants and animal species, and trampling and disturbance from recreational use, unauthorized OHV use and domestic livestock use. The effect of the proposed action would be to reduce or eliminate feral pigs as a stressor to these plant and animal populations.

Other projects that may add to impacts to wildlife and botanical resources from the proposed action include the use of helicopters for the maintenance of the Sunrise powerlink and by Border Patrol and law enforcement in the area. The mitigation of altering flight paths and activity times to minimize impacts to nesting raptors will ameliorate these cumulative effects.

3.3 Noxious Weeds

3.3.1 Direct and indirect effects

Alternative 1 – No Action: The presence of feral pigs presents a large source of disturbance via foraging and travelling that is expected to damage native vegetation and lead to increased likelihood of establishment of invasive weed species. Feral pigs also can be expected to move seed of some species on their fur and hooves as they travel (Dovrat 2012). Feral pig rooting activities create sites of soil disturbance that are favorable to the establishment of non-native weed species (West et al. 2009).

Alternative 2 – Proposed Action: The proposed project is not likely to measurably increase noxious weeds. There is some potential impact from increased foot traffic as part of hunting efforts, but these impacts are not expected to be significant. Packstock may be used on a limited basis in support of project activities; pack animals would be fed weed-free feed to minimize introduction of noxious weeds. There is a chance that workers could introduce invasive plant seeds via their clothing, vehicles or use of packstock.

By minimizing or eliminating impacts for feral pigs the proposed action is expected to have a net beneficial effect on noxious weed spread and establishment.

Alternative 3 – No Aerial Hunting: Eliminating aerial hunting is expected to prolong the influence on feral pigs on weed abundance and establishment over the proposed action, and would also prolong and increase the potential weed introductions from hunting teams and their activities. However, this alternative is still expected to have a net beneficial impact by reducing feral pig activity and damage.

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3.3.2 Cumulative Effects

Feral pig activity is expected to add to impacts from recreational use and unauthorized OHV use to the spread of noxious weeds and the introduction of noxious weed seed into new areas.

The action alternatives are not expected to have a discernable impact to noxious weed spread, other than a benefit by reducing or eliminating feral pig disturbance. Therefore there are no expected cumulative effects from the action alternatives.

3.4 Watershed

The project area covers the Forest Service and Bureau of Land Management Lands within San Diego County, Riverside, and Orange Counties. The area includes perennial streams to ephemeral streams to dry desert washes and debris flow channels. The precipitation ranges from as little as 9 to 11 inches in the dry areas to 40 or more inches in the high mountaintop elevations. This zone can produce very high peak flows during long-duration rain storms falling on shallow snowpack. Averages of precipitation are not very useful due to highly variable yearly precipitation. A majority of the hydrology work that is responsible for stream channel morphology occurs during 10 year storm events.

As described above the project area covers a large diverse area. The soil series range from poorly developed soils of newer alluvial fans to well developed soils of meadows, forested and chaparral areas. Soil moisture regimes vary from aridic to xeric while some soils in wetland areas would be classified as aquic. Soil temperature regimes range from thermic to mesic. Project specifications and implementation of the action alternatives would not vary significantly due to soil type or classification. Wetland and hydric soils would be avoided for the installation of temporary traps.

Elevation ranges from about 500 feet to over 6,000 feet. The predominant vegetation types are mixed conifer forests, oak woodland forest, and various types of chaparral. San Diego County is a major population center and a significant portion of National Forest and Bureau of Land Management lands are situated in a wildland/urban interface. Watersheds face increasing pressure of development, intense recreation, invasive species, climate change and urban pollution.

3.4.1.1 Direct and Indirect Effects on Soil Quality

Alternative 1 – No Action: Feral pigs in their feeding typically root through the upper soil layer. This disturbance can be extensive around an area and frequently occurs in riparian areas (West et al. 2009). This disturbance displaces soils and vegetation, thus creating large areas of bare soil. Bare soil is vulnerable to erosion and deposition into streams (Cooray and Mueller-Dombois, 1981). This erosion can lower soil quality and productivity for the long term (Singer, 1981) and the correlation between soil erosion and

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the presence of feral pigs in a watershed is supported in the scientific literature (Browning, 2008). Rooting by feral pigs has also been documented to accelerate leaching of calcium, phosphorous and several micronutrients from the soil profile, further lowering soil quality as well as water quality (Singer et al. 1984). Increases in nitrate concentrations suggest alterations in the nitrogen transformation process as well.

The No Action Alternative would fail to halt the damage to soils by feral pig populations and could prevent the Cleveland National Forest from maintaining Pacific Southwest Regional Soil Quality Standards.

Alternative 2 – Proposed Action: The proposed action may have minor and short term impacts to soil quality in small areas due to the placement of traps. This effect will be minimized by avoidance of wet areas and streambanks for trap placement. Otherwise, the proposed action is expected to have a beneficial impact on soil resources due to reduction or elimination of feral pig impacts. The benefits of removal or reduction of feral pig populations would far outweigh any degradation of soil quality by the implementation of the action alternatives.

Alternative 3 – No Aerial Hunting: This alternative will have impacts similar to the proposed action except that the number of traps may be slightly higher and over a longer term. This alternative is still expected to have a beneficial impact to soil resources.

3.4.2 Direct and Indirect Effects on Stream and Meadow Condition

Alternative 1 – No Action: A majority of the stream and meadow conditions on the Federal lands surveyed showed streambanks and stream conditions to be stable and to be within Forest Plan and Riparian Conservation Area standards and guidelines. It is well documented in the scientific literature that feral pigs can detrimentally affect the condition of stream and meadow habitats (West et al. 2009, Kaller et al. 2007). The bare soil created by rooting can increase sedimentation and sediment input into waters of the US, causing nutrient pollution as well as negatively affecting stream processes (Braysher, 2004, Mitchell and Mayer, 1997). Meadows and wetlands can be compacted by pigs while feeding during the wet season, reducing meadow productivity and damaging habitat (Vtorov, 1993). The no-action alternative would be detrimental to riparian, stream and meadow resources

Alternative 2 – Proposed Action: The proposed action is not expected to have negatively impact stream or meadow condition. Traps will not be placed on streambanks or in wet meadows. Hunting teams are expected to mostly utilize pre-existing or pig created trails for movement. The proposed action is therefore expected to have a beneficial impact on stream and meadow condition by reducing pig damage to these resources.

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Alternative 3 – No Aerial Hunting: This alternative will have impacts similar to the proposed action except that the number of traps may be slightly higher and over a longer term and the damage caused by pigs will persist for a longer period. This alternative is still expected to have a beneficial impact to stream and meadow resources.

3.4.3 Direct and Indirect Effects on Water Quality

Alternative 1 – No Action: The effects of feral pig populations on water quality are well documented in scientific literature (Kaller et al. 2007, Braysher, 2004, Atwill et al. 1997). The Cleveland National Forest and Bureau of Land Management lands are very important sources of surface waters for municipal use. The Cleveland National Forest provides water for several municipal water agencies as well as forest users collecting water during recreation activities. Scientific studies across several states and in Australia document the degradation of water quality due to the presence of feral pigs (Braysher, 2004, Mitchell and Mayer, 1997). A study in Tennessee indicate increases in nitrate concentrations in soil and stream water related to feral pig rooting and populations (Singer et al. 1984). In Louisiana and California, feral pigs are a documented source and possibly a major source of coliform bacteria in watersheds (Dunkell et al. 2011a, Kaller et al. 2007, Atwill et al. 1997).

The foraging and wallowing behavior of pigs can markedly increase the turbidity of water supplies, but more importantly, they can transmit and excrete a number of infectious waterborne organisms that are pathogenic to humans. Their persistence in drinking water catchments also makes them potentially significant reservoirs for zoonotic pathogens. Important protozoan parasite pathogens, such as Giardia, Cryptosporidium, Balantidium, and Entamoeba are often present in the feces of feral pigs. These pathogens have been correlated with the presence of feral pigs in municipal watersheds (Braysher, 2004). In a study conducted in California it is suggested “that given the propensity for feral pigs to focus their activity in riparian areas, feral pigs may serve as a source of protozoal contamination for surface water” (Atwill et al. 1997). Significant feral pig populations pose a threat to water quality by reducing the health of waters and potentially serving as a vector for contamination of surface water supply and associated risks to human health.

By allowing pig populations to persist and expand, the No Action Alternative would not allow the Forest Service nor the Bureau of Land Management to maintain water quality standards and protect beneficial uses outlined in the Regional Water Quality Control Board Basin Plans.

Alternative 2 – Proposed Action: Carrying out the proposed action is not expected to have any negative impacts on water quality. The proposed action will have a beneficial impact to water quality by reducing or eliminating feral pig activity.

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Alternative 3 – No Aerial Hunting: The alternative is expected to have impacts similar to the proposed action on water quality, with positive impacts delayed due to longer pig persistence.

3.4.4 Cumulative Effects on Watershed Resources

This project is not expected to change current estimated cumulative watershed effects. Existing erosion and sediment transport from areas with established traps may increase slightly because of the proposed action. Because these increases would be minor and short-term they are not expected to increase cumulative watershed effects. The effects from the implementation of professional hunting, monitoring, or other actions to control the damage by feral pigs would be minor and short term.

Cumulative watershed effects would be increased if the present feral pig population expands its range and increases in population, or inhabits sensitive areas for a longer time frame. Feral pigs tend to prefer riparian areas and areas where water is available. The occupation of these habitats by the non-native species that would occur under the No Action Alternative would have long term negative effects on waters of the US, riparian habitat, and water quality that are not consistent with the Cleveland National Forest Land Management Plan or Bureau of Land Management Resource Management Direction.

3.5 Heritage and Cultural Resources

Section 106 of the National Historic Preservation Act (NHPA) requires federal agencies to take into account the effects of their undertakings on historic properties and to afford the Advisory Council on Historic Preservation (ACHP) a reasonable opportunity to comment. The Section 106 process is detailed in the NHPA and its implementing regulations in 36 CFR 800. The Section 106 process includes delineating the Area of Potential Effects (APE), and inventorying, identifying, and recording cultural resources. Historic properties are prehistoric or historic districts, sites, buildings, structures, or objects included in, or eligible for inclusion in, the National Register of Historic Places (NRHP) (36 CFR 800.16[1]). For federal projects, cultural resource significance and identification of historic properties is evaluated in terms of eligibility for listing on the NRHP.

The Pacific Southwest Region (Region 5) of the Forest Service has implemented the FIRST AMENDED REGIONAL PROGRAMMATIC AGREEMENT AMONG THE U.S.D.A. FOREST SERVICE, PACIFIC SOUTHWEST REGION, CALIFORNIA STATE HISTORIC PRESERVATION OFFICER, AND ADVISORY COUNCIL ON HISTORIC PRESERVATION REGARDING THE PROCESS FOR COMPLIANCE WITH SECTION 106 OF THE NATIONAL HISTORIC PRESERVATION ACT FOR UNDERTAKINGS ON THE NATIONAL FORESTS OF THE PACIFIC SOUTHWEST REGION (USDA Forest Service 2001). The Bureau of Land Management has implemented the PROGRAMMATIC AGREEMENT AMONG THE BUREAU OF LAND MANAGEMENT,

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THE ADVISORY COUNCIL ON HISTORIC PRESERVATION, AND THE NATIONAL CONFERENCE OF STATE HISTORIC PRESERVATION OFFICERS REGARDING THE MANNER IN WHICH BLM WILL MEET ITS RESPONSIBILITIES UNDER THE NATIONAL HISTORIC PRESERVATION ACT (BLM 2012). Region 5 of the Forest Service, the BLM, the SHPO, and the ACHP agree that all undertakings on Forest Service lands in Region 5 and BLM lands shall be implemented in accordance with the stipulations contained in these Programmatic Agreements in order to take into account the effect of their undertakings on historic properties; and when so administered, the processes specified in these PAs for identification, documentation, evaluation, review, consultation, and public notification and participation may be followed, in lieu of the requirements of 36 CFR 800, and that the implementation of these processes satisfies the requirements of Section 106 of the NHPA.

The Area of Potential Effects (APE) for the proposed action has been determined to be limited to the federal lands (Forest Service and Bureau of Land Management) and Tribal lands (Capitan Grande Indian Reservation) within the boundary of the proposed action, as defined in Section 1.5. Due to the size and scope of the proposed action, intensive inventory and identification of all historic properties within the entire APE is not feasible. Portions of the APE have been previously surveyed, and cultural resources, including historic properties, have been identified and recorded within the APE. There were no significant issues or concerns regarding cultural resources identified during the public scoping period. The CNF would implement the stipulations of the Regional Programmatic Agreement (PA) on CNF lands within the APE, and the BLM would implement the stipulations of its PA on BLM lands within the APE for compliance with Section 106 of the NHPA and its implementing regulations in 36 CFR 800 in in order to take into account the effect of the undertaking on historic properties associated with the implementation of the only component of the proposed project (trapping) that has been determined to have the potential to have an effect on historic properties. This process would include the review of specific proposed trapping locations and activities by cultural resource management specialists at each agency and the issuance of compliance documentation including a Section 106 Finding and Determination and a Fieldwork Authorization (BLM), or a Programmatic Agreement Compliance document (CNF) confirming the avoidance of potential effects to historic properties prior to the implementation of trapping activities at specific locations within the proposed project APE.

Native American consultation for the proposed project was initiated by the Forest Service during the early planning stages of the proposed project. This included a letter sent to all Tribes in September 2011 outlining the proposed action and timeline for the preparation of the Draft EA and a request comments or requests for consultation. The Viejas Band of Kumeyaay Indians requested consultation, which was conducted in a Government-to- Government consultation meeting between the CNF and Viejas in November 2011. All Tribes were notified in writing of the availability of the Draft EA for comment. Comments were received from three Tribes and Viejas requested consultation. A second

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Government-to-Government consultation meeting took place in September 2012. The CNF requested that this consultation meeting be open to all interested Tribes and Viejas agreed. In attendance at the meeting were Tribal council members and representatives from Viejas, the chairman and a council member from Barona, the environmental coordinator for La Jolla, and representatives from the Kumeyaay-Diegueno Land Conservancy (KDLC), and Forest Service representatives. Tribal concerns were discussed and addressed, and the consulting Tribes and the Forest Service agreed to continue coordinating and sharing information as the project moves into implementation. A complete Tribal Consultation Summary is contained in the project record.

If any cultural resources were to be inadvertently discovered during implementation of the proposed action or selected alternatives, all project related activities in the vicinity of the discovery would cease, appropriate steps to secure and protect the discovery would be taken, the Forest Service or BLM Archaeologist would be notified, and the process for dealing with the inadvertent discovery of cultural resources defined in the appropriate Programmatic Agreement would be implemented. Any identification of human remains during the implementation of the proposed project would result in the implementation of the same procedures, as well as the implementation of the procedures for the proper protection and disposition of human remains stipulated in the Native American Graves Protection and Repatriation Act (NAGPRA, 1990). Suspended project activities in the vicinity of the inadvertent discovery of any cultural material or human remains would be resumed only with the written permission of the Forest Service or BLM archaeologist, as appropriate.

3.5.1 Direct Effects

Alternative 1 – No Action: Feral pigs can impact subsurface and surface cultural resources through rooting and trailing activities. There has been documented damage to a cultural resources site resulting from feral pig rooting in the vicinity of Palomar Mountain. Therefore Alternative 1, the no action alternative, is expected to lead to further damage to cultural sites as feral pig populations persist and expand.

Alternative 2 – Proposed Action: The APE for the proposed action is considered to be limited to the boundary of the proposed action, as defined. Due to the size and scope of the proposed action, intensive inventory, identification, and recordation of cultural resources within the APE is not feasible. Portions of the APE have been surveyed, and cultural resources, including historic properties, are known to exist within the APE. Of the various activities proposed under the action alternatives, only the placement and utilization of traps appears to have a potential to cause direct effects to historic properties. In order to avoid any potential for effects to historic properties associated with this component of the proposed action, trapping locations would be analyzed on an individual basis by a qualified archaeologist and traps would not be situated within or in the vicinity of historic properties. Avoidance of historic properties would result in no potential for effects to historic properties associated with the implementation of the proposed action.

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By reducing or eliminating feral pig populations, the proposed action would instead have a beneficial effect on cultural resources by protecting them from damage.

Alternative 3 – No Aerial Hunting: This alternative is expected to have impacts similar to the proposed action. The use of aerial hunting in the proposed action is expected to yield faster results than Alternative 3 and thereby afford cultural resources sites greater protection.

3.5.2 Cumulative Effects

No cumulative effects to historic properties are expected from implementation of the action alternatives. Feral pig activity has resulted in effects to cultural resources in the proposed project APE. As a result, implementation of the No Action Alternative could result in an increased potential for cumulative effects to cultural resources.

3.6 Recreation

CNF and BLM lands provide both developed and dispersed recreation facilities and opportunities to the public within the project area. Most of the lands that could be occupied by feral pigs are primarily places of dispersed recreation activity such as hiking, horseback riding, mountain biking, scenic touring and hunting for several species of game. Developed recreation facilities, such as campgrounds and trailheads are also located throughout the project area and may be impacted by pigs. There have been reports of pig sightings from at least one campground in the project area (CDPR, 2011). Although feral pigs are not typically considered dangerous animals, there have been reports of pigs chasing people in San Diego County. Feral pigs have been known to become aggressive occasionally and may attack humans and pets; as recently reported in the media in other parts of the country (Moore 2008, Sanchez 2011). Therefore, feral pig populations pose at least a low-level safety risk to the recreating public.

Feral pigs are designated a game animal for hunting in California. Hunting opportunities for feral pigs within the project area have become available since populations became established over the past few years. However, very few feral pigs are reported to be taken by hunters in the project area. According to California Department of Fish and Game records, only eight feral pigs were taken by hunters in San Diego County during the 2010-2011 hunting season, which is less than one quarter of 1% of all pigs taken by hunters in the state (CDF&G, 2011). Recreational hunters face a variety of challenges in pursuit of feral pigs. Low densities of the animals in readily accessible areas can make them hard for hunters to locate. Public access for recreational hunting of feral pigs is difficult because of rugged topography in areas occupied by pigs as well as the complex landownership pattern. Lack of access across private lands, which are inter-mixed with public lands, limits access to feral pigs for hunters using motorized and non-motorized means of travel.

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3.6.1 Direct Effects

Alternative 1 – No Action: Under Alternative 1, no pig control activities would be undertaken. Resource damage caused by feral pigs is expected to continue and spread to new areas used by the recreating public. The outdoor recreation setting would be further degraded over time by pig rooting and wallowing behavior. Given the likelihood of increasing encounters between feral pigs and recreationists, public safety would continue to be a concern. Recreational hunting of feral pigs would continue.

Alternative 2 – Proposed Action: Feral pig control activities as described in Alternative 2 are expected to have limited, intermittent and short-term effects on the vast majority of outdoor recreational use of public lands. Outdoor recreation activities, including hunting, would be allowed to continue during implementation of the project. However short-term closures of limited extent during aerial and ground hunting operations would exclude recreational activity while in effect to protect public safety. Closures would be minimized in high use recreation areas, particularly during weekends and holidays. Noise from helicopters, gunshots and dogs may be heard by the recreating public during project implementation. Corral traps set for feral pigs will not be placed in locations visible from recreation facilities, roads or trails and are not expected to negatively affect outdoor recreation. Short spans of temporary fencing used to enhance removal efforts will be placed away from recreation facilities and out of public view wherever possible. A 1000-ft. buffer around open developed recreation facilities will be established for aerial hunting operations to further reduce noise impacts on the recreating public. Removal of feral pigs from public lands would improve the safety of the recreating public by decreasing or eliminating pig-human encounters.

Recreational hunting of feral pigs would be allowed to continue during control efforts. If control efforts are successful in eliminating feral pigs from the project area, opportunities for hunting feral pigs would be lost. The negative impact on recreational hunting is expected to be minor, given the small number of pigs reported taken in the project area. The removal of pigs would alleviate problems with resource damage and thereby improve the setting of outdoor recreation activities.

Alternative 3 – No Aerial Hunting:

Feral pig control activities, as described in Alternative 3, exclude the use of aerial hunting with helicopters. Helicopters would still be used to provide logistical support for ground- based pig removal operations, however. Without the use of aerial hunting pig control efforts are expected to be less effective and be of a longer duration and a greater inconvenience to the recreating public. Resource damage and safety issues would also persist for a longer time.

3.6.2 Cumulative Effects

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Because the effects of the action alternatives on recreation would be minor and short- term, no cumulative effects on recreation are expected from their implementation. The No Action Alternative could lead to cumulative effects on recreation by allowing feral pigs to alter the recreational experience of public lands.

3.7 Wilderness

The project area includes lands within the San Mateo (CNF), Agua Tibia (CNF), Pine Creek (CNF), Hauser (CNF), Otay Mountain (BLM), Carrizo Gorge (BLM), Sawtooth Mountains (BLM), and Beauty Mountain (BLM) Wilderness Areas. These areas are managed in accordance with the Wilderness Act of 1964 in such a manner that ecosystems are unaffected by human manipulation and influences to the greatest extent possible so that plants and animals develop and respond to natural forces. Rugged topography and/or dense chaparral vegetation characterize these areas, thus making administrative or public access difficult. Wilderness character in several of the subject areas is currently impacted by law enforcement activities involving the use of helicopters, as well as impacts from illegal immigration relating to unauthorized trails, litter and human waste.

The project area also includes the Hauser Mountain and Beauty Mountain Wilderness Study Areas (BLM) and Recommended Wilderness (CNF) additions to Pine Creek, Hauser and Agua Tibia Wilderness Areas. Wilderness Study Areas are generally unaffected by human development, provide opportunities for primitive or unconfined recreation and have special ecological, geological, educational, historical, scientific and/or scenic value. Until Congress makes a final determination on the status of a Wilderness Study Area, the BLM must manage the area“so as not to impair the suitability of such areas for preservation as wilderness”. In the CNF LMP, Recommended Wilderness is defined as, “land that the Forest Service is recommending to Congress for wilderness designation and will be managed in the same manner as existing wilderness so that the wilderness attributes of the area are retained until Congress passes legislation, or the area is released from consideration.”

The CNF is in the process of developing a Supplemental Environmental Impact Statement (SEIS) to analyze a proposed Land Management Plan (LMP) amendment which would designate additional areas of CNF as Recommended Wilderness.

Currently, the most likely wilderness areas to be affected by the proposed action are the Pine Creek and Hauser Canyon Wilderness Areas. Both of these wilderness areas face numerous management challenges due their proximity to the international border with Mexico, including immigrant traffic, trash, and impacts from law enforcement activities. Management of the wilderness has focused on trash removal and patrolling for illegal campfires.

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The presence of feral pigs, a non-native invasive species, detracts from the natural character of the wilderness. The impacts to ecosystem dynamics caused by feral pig rooting and wallowing activity can have serious consequences for native plant and animal species, particularly the several endangered and/or threatened species endemic to the project area. In addition, visitors to wilderness might have to adjust their recreation patterns based on pig infestations as feral pigs have the potential to cause severe physical harm to humans. Because of the impacts to the untrammeled, natural, and outstanding opportunities for solitude and/or primitive and unconfined recreation qualities of wilderness character, allowing the feral pigs to remain on the landscape does not support the purpose and goals of the Wilderness Act of 1964.

3.7.1 Direct Effects

Alternative 1 – No Action: Under Alternative 1, the no-action alternative, current management practices would continue. Without feral pig damage control efforts, feral pig populations and associated resource damage are expected to spread into Wilderness, Recommended Wilderness and Wilderness Study Areas. The natural and untrammeled qualities of wilderness character would decrease over time as a result of damage to the natural quality of seeps, springs, and other waterbased ecosystems by feral pig rooting, wallowing, and feces should populations become established. Feral pig damage is highly visual, including disturbed vegetation, large areas of turned up disturbed ground, numerous trails and streambank impacts. Feral pig activity also has the ability to alter natural processes by reducing oak recruitment. These effects are expected to have a long- term impact to wilderness character, in addition to harming habitat conditions for native wildlife in wilderness areas.

In addition to the untrammeled and natural qualities of wilderness character, feral pigs also negatively affect the outstanding opportunities for solitude and/or a primitive and unconfined type of recreation. As feral pig populations increase, the chances of contact between visitors to wilderness and the pigs will also increase. Feral pigs are a safety issue, and management could potentially impose user restrictions to mitigate any safety concerns.

Alternative 2 – Proposed Action: Under Alternative 2, the proposed action, active pig removal efforts would be undertaken to prevent further damage to the natural quality of wilderness character; however, pig removal efforts would only be undertaken inside Wilderness, Recommended Wilderness, or Wilderness Study Areas if documented resource damage in those areas attributed to feral pigs indicates the need for such action. Aerial efforts would be targeted and focused to those areas of documented pig damage.

Feral pig control activities as described in Alternative 2, are expected to have limited, intermittent and short-term negative effects on Wilderness, Recommended Wilderness and Wilderness Study Area character within the project area. Although relatively short- term and temporary, pig control activities such as intensive aerial and ground hunting in

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combination with temporary fence installation would have a negative impact on the untrammeled character of wilderness. The primary impacts would be noise from helicopters, gunshots and barking dogs during active pig removal activities. Helicopter landings would also occur on existing cleared areas. Placement of corral style traps and short spans of temporary fencing, if needed, would be away from trails, trailheads and campsites and out of public view and is not expected to detract from the wilderness experience for most users. These activities have the potential to alter the movement of native wildlife, thus manipulating the ecological systems on the local level.

In addition to impairing the untrammeled quality, pig removal activities would have a negative effect on the undeveloped quality of wilderness character. The installation of traps and temporary fencing constitutes a structure or installation, prohibited uses under Section 4(c) of the Wilderness Act. The use of a low-flying/hovering helicopter in wilderness, another prohibited use, also adversely affects the undeveloped quality of wilderness character as it constitutes the use of motorized equipment and mechanical transport.

Furthermore, there will be short term negative impacts to solitude during active pig control operations due to noise caused by low-flying helicopters and the barking of hunting dogs. Use of helicopters for aerial hunting and logistical support would be intermittent and temporary in nature. Helicopters are already being used intermittently in CNF Wildernesses by U.S. Border Patrol and local law enforcement agencies for emergencies.

Finally, pig removal activities would have a negative effect on the quality of solitude and unconfined and primitive recreation. The noise from low-flying helicopters and hunting dogs can impact the sense of one’s solitude. Temporary closures would limit the opportunity for unconfined and primitive recreation.

While there are negative impacts to wilderness character, these activities are short-term and temporary. The use of helicopters for both aerial hunting and logistical support of ground operations is essential for successful pig removal efforts because of the steep and rugged topography and/or dense chaparral vegetation in the subject areas. Using the full range of available tools in all areas impacted by feral pigs, including Wilderness, Recommended Wilderness, and Wilderness Study Areas, is necessary to avoid giving feral pigs a safe refuge from control efforts undertaken on adjacent lands. The existence of safe refuges in the project area would make feral pig damage control efforts unlikely to succeed.

Overall, the removal/reduction of feral pig populations will have a net positive effect on qualities of wilderness character. Incidents of damage to natural landscapes will decrease as a result of the pigs’ removal, and ecosystems will be allowed to return to a natural state. In the long term, visitors will enjoy freedom of movement through the wilderness as their activities will not be managed to avoid feral pig populations out of safety

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concerns. The protection and restoration of wilderness resources as a result of feral pig removal will enhance the wilderness experience visitors yearn for.

Alternative 3 – No Aerial Hunting: Under Alternative 3, the impacts to Wilderness, Recommended Wilderness and Wilderness Study Areas would be similar to those under the proposed action. Negative impacts to wilderness character would be limited, intermittent and short-term, and the overall effect to wilderness character would be a net positive one. Without the use of aerial hunting by helicopter, noise impacts to the natural character of the subject areas would be substantially lower. Helicopters may still be used in these areas for logistical support under Alternative 3. However, without the use of aerial hunting, feral pig damage control efforts will not be as effective, and resource damage from feral pigs impacting wilderness character would be expected to reach a greater magnitude and persist for a longer duration. Pig removal efforts would also be of longer duration and impact the subject areas for a longer period of time.

3.7.2 Cumulative effects

Limited, intermittent and short-term negative cumulative effects from the use of helicopters in Wilderness, Recommended Wilderness and Wilderness Study Areas are expected under Alternatives 2 and 3. Intermittent helicopter use is currently occurring in most of these areas as needed by Federal, State and local law enforcement agencies to enforce the law and protect public health and safety. Wilderness areas, especially Hauser Canyon, Pine Creek Wilderness, and Otay Mountain Wilderness are impacted by ground-based illegal immigrant traffic and associated law enforcement activities. Feral pig management activities will add to these impacts via helicopter flights, if approved, and ground-based hunting teams. The small number of flights and temporary nature of the project is expected to add a small fraction to the number of aircraft a visitor to these wilderness areas would experience. The negative cumulative effects would be related to noise levels and impacts to the natural character of the subject areas. The cumulative effects of the No Action Alternative on Wilderness would consist of allowing pig damage to continue to deteriorate wilderness character while it is already impacted by other activities.

3.8 Agriculture

Crop agriculture is not permitted on federal lands within the project area; however, crop agriculture and livestock farming is an important part of the economy in San Diego County and occurs on private lands within and in close proximity to the project area in the region. Over 302,000 acres of lands in San Diego County are involved in the production of agricultural products with an annual value of over $1.6 billion in 2010 (County of San Diego, 2010). Although agriculture remains an important part of the economy in the region, urbanization of agricultural lands is a continuing trend.

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Cattle grazing on public lands is a long established and continuing practice dating back over 100 years in the project area. Approximately 575 head of cattle are permitted to graze on nearly 50,000 acres of Cleveland National Forest lands. On BLM lands in the project area, up to 962 head of cattle are allotted to graze on over 37,000 acres. In the San Diego area, over the last several decades, allotment use in many cases has changed from perennial to seasonal due to climatic shift, changing fire regimes (increased fire frequency), and invasion of exotic noxious weeds. Many larger and more concentrated cattle operations occur on private lands in and adjacent to areas known to be occupied by feral pigs.

3.8.1 Direct and Indirect Effects

Alternative 1 – No Action: Under Alternative 1, no pig control efforts would be taken. Feral pig populations would become an increasing threat to agriculture within and adjacent to the project area. Crop damage resulting from feral pigs is costly and has been widely documented in other areas of the United States with annual damages to agricultural and environmental resources estimated at $1.5 billion nationwide (West et al. 2009). Feral pigs often carry diseases, such as pseudorabies and brucellosis, which can be passed on to livestock (USDA, 2005). Pigs also cause damage to pasture turf grasses through foraging and also cause damage to livestock control fencing and water infrastructure. Feral pigs may compete for scarce surface water resources with livestock, negatively impacting grazing operations. Recent media reports indicate that feral pigs have been implicated for introducing E.coli bacteria into crop fields that led to human disease outbreaks. Damage to agricultural crops and livestock from feral pig populations would negatively affect individual farmers and ranchers and may have a negative effect on the local agricultural economy.

Alternative 2 – Proposed Action: Under Alternative 2, pig control efforts would be carried out as proposed. Feral pig damage to crop agriculture and livestock within and in proximity to the project area would be reduced or avoided entirely, and so the impact of the proposed action on agriculture would be entirely positive.

Alternative 3 – No Aerial Hunting: The effect on agriculture of Alternative 3 from feral pig control activities would be similar to Proposed Action. However, without the use of helicopters, the chance of eliminating feral pig impacts entirely is also reduced and so the beneficial impact would not be as great as for the proposed action.

3.8.2 Cumulative Effects Agricultural operations in San Diego County already face pressures from increasing urbanization leading to loss of land base. Grazing operations are under pressure from a variety of environmental factors including climate, noxious weeds and fire regimes. Loss of revenues for agricultural and grazing operators from wild pig impacts would be an

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additional stressor to continuation of their operations under the No Action Alternative, while the action alternatives would not contribute to cumulative effects to agriculture.

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CHAPTER 4 Consultation and Coordination

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

4.1. Interdisciplinary Team Members

Tim Cardoza, ID Team Leader, NEPA Writer CNF Pete Gomben, Environmental Coordinator, ID Team Leader, CNF Jeff Wells, Wildlife Biologist, CNF Megan Jennings, Wildlife Biologist, CNF Kirsten Winter, Forest Biologist, CNF Steve Harvey, Heritage and Cultural Resources Program Manager, CNF Jason Jimenez, Watershed Specialist, CNF Lance Criley, Rangeland Management Specialist, ID Team Leader, NEPA Writer CNF Eric Hollenbeck, Environmental Scientist, California Dept. of Parks and Recreation Joyce Schlachter, Wildlife Biologist, BLM Jennifer Taylor, Wilderness Coordinator, BLM

4.1.3 Federal, State and Local Agencies

Bureau of Land Management USDA Natural Resources Conservation Service California Department of State Parks California Department of Fish and Game County of San Diego City of San Diego

4.1.4 Tribes

Outreach to Tribes in San Diego County has occurred throughout the project. This included a letter sent to all Tribes on Sept 15th, 2011 outlining the proposed action and timeline for the EA and requesting comments or requests for consultation. Only the Viejas Tribe requested consultation, which was conducted in a Government to Government consultation meeting between the CNF and Viejas in November 2011. All Tribes were made aware of the availability of the Draft EA for comment. Comments were received from three Tribes and the Viejas Tribe once again requested consultation. A second consultation meeting took place in Sept. 2012. The CNF requested that this consultation meeting be open to all Tribes and the Viejas Tribe agreed. In attendance at the meeting were Tribal council members and representatives from Viejas, the chairman

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and a council member from Barona, the environmental coordinator for La Jolla, and representatives from the Kumeyaay-Diegueno Land Conservancy (KDLC) and Forest Service representatives. Tribes and the Forest Service have agreed to continue coordinating and sharing information as the project moves into implementation. A complete Tribal Consulation Summary has been added to the project record and is available upon request.

4.1.5 Others

The Nature Conservancy

References Cited

Atwill, E.R.; Sweitzer, R.A., et al. 1997. Prevalence of and associated risk factors for shedding Cryptosporidium parvum oocysts and Giardia Cysts within feral pig populations in California. Applied and Environmental Microbiology. 63:3946- 3949.

Beiber, Cluadia and Thomas Ruf. 2005. Population dynamics in wild boar Sus scrofa: ecology, elasticity of growth rate and implications for the management of pulsed resource consumers. Journal of Applied Ecology 42, 1203-1213

Research Institute of Wildlife Ecology, University of Veterinary Medicine, Vienna, Austria

Braysher M. 2004. Threat abatement plan for predation, habitat degradation, competition and disease transmission by feral pigs. Australian Department of Environment and Heritage, Canberra, Australia. (Water Quality)

Browning, C.A. 2008. A preliminary examination of the effects of feral pigs on water quality and soil loss within a Hawaiian watershed. Hilo, HI: University of Hawai’i. 116 p. M.S. thesis.

California Department of Fish and Game, Wildlife Branch. 2011. 2010-2011 Wild Pig Take Report. http://www.dfg.ca.gov/wildlife/hunting/pig/docs/pigtake/2010- 11WildPigTakeReport.pdf

California Department of Parks and Recreation, Colorado Desert District. E. Hollenbeck. 2011. Personal communication.

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Conservation Biology Institute (CBI). 2009. An Assessment of the Known and Potential Impacts of Feral Pigs (Sus scrofa) in and near San Diego County with Management Recommendations. Available online at: http://consbio- static.s3.amazonaws.com/media/reports/files/Feral_pig_report_Oct_2009_with_fi gures-11.pdf

County of San Diego, Dept. of Agriculture, Weights and Measures. 2010. Crop Statistics and Annual Report.

Cooray, R. G.; Mueller-Dombois, D. 1981. Feral pig activity. Island Ecosystems: Biological Organization in Selected Hawaiian Communities. D. Mueller- Dombois, K. W. Bridges and H. L. Carson. Stroudsburg, PA, Hutchinson Ross Publishing Co.: 309-317.

Cushman, J.H.; Tierney, T.A.; Hinds, J.M. 2004. Variable effects of feral hog disturbances on native and exotic plants in a California grasslands. Ecological Applications. 14:1746-1756.

Dovrat, G., Perevolotsky, A., Ne’eman G. 2012. Wild boars as seed dispersal agents of exotic plants from agricultural lands to conservation areas. Journal of Arid Environments. Volume 78, March 2012 Pg 49-54.

Dunkell, D.O.; Bruland, G.L.; Evensen, C.I.; Walker, M.J. 2011. Effects of feral pig exclusion on Enterococci in runoff from the forested headwaters of a Hawaiian watershed. Water, Air, and Soil Pollution. Vol 221, No. ¼, pp. 313-326

Dunkell, D.O.; Bruland, G.L.; Evensen, C.I.; Creighton, M.L. 2011. Runoff, sediment transport, and effects of feral pig exclusion in a forested Hawaiian watershed. Pacific Science. 65:175 – 194

Hampton, J.; Spencer, P.B.S.; Elliot, A.D; Thompson, R.C.A.; 2006. Prevalence of zoonotic pathogens from feral pigs in major public drinking water catchments in western Australia. Ecohealth. 3:103-108.

Harveson, Louis A, Michael E. Tewes, Nova J. Silvy and Jimmy Rutledge. 2000. Prey Use by Mountain Lions in Southern Texas. The Southwestern Naturalist , Vol. 45, No. 4 (Dec., 2000), pp. 472-476

Jay MT, Cooley M, Carychao D, Wiscomb GW, Sweitzer RA, Crawford-Miksza L, et al. Escherichia coli O157:H7 in feral swine near spinach fields and cattle, central California coast. 2007. Emerg Infect Diseases. Available from http://wwwnc.cdc.gov/eid/article/13/12/07-0763.htm

Kaller, M.D.; Huseon, J.D., E.C. Achberger; W.E. Kelso. 2007. Feral hog research in

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western Louisiana: expanding populations and unforeseen consequences. Human- Wildlife Conflicts. 1:168-177.

Kaller, M.D., Kelso, W.E. 2006. Swine activity alters invertebrate and microbial communities in a coastal plain watershed. American Midland Naturalist. 156:163- 177.

Kreith, Marcia. 2007. Wild Pigs in California: The Issues. Agricultural Issues Center, AIC Issues Brief. UC Davis, Number 33 December 2007

Mitchell J.; Mayer R. 1997. Digging by feral pigs in the wet tropics world heritage area of north Queensland. Wildlife Research. 24: 591-601.

Morrison, Scott A. 2007. Reducing Risk and Enhancing Efficiency in Non-Native Vertebrate Removal Efforts on Islands: a 25 Year Multi-Taxa Retrospective from Santa Cruz Island, California. USDA National Wildlife Research Center Symposia. http://digitalcommons.unl.edu/nwrcinvasive/31.

Pimental, David. 2007. Environmental and Economic Costs of Vertebrate Species Invasions into the United States. Managing Vertebrate Invasive Species. Paper 38 http://digitalcommons.unl.edu/nwrcinvasive/38

San Diego Natural History Museum (SDNHM) 2010. Feral Pig Distribution Survey Report, San Diego County; prepared for the Nature Conservancy. Available online at: http://sdferalpigs.org/

Seward, Nathan W.; VerCauteren, Kurt C.; Witmer, Gary W.; and Engeman, Richard M. 2004. Feral Swine Impacts on Agriculture and the Environment. Sheep & Goat Research Journal. Paper 12. http://digitalcommons.unl.edu/icwdmsheepgoat/12

Singer, F.J.; Swank, W.T.; Clebsch, E.E.C. 1984. Effects of wild pig rooting in a deciduous forest. Journal of Wildlife Management. 48(2):464-473.

Singer, F. J. 1981. Wild pig populations in the national parks. Environmental Management 5(3): 263-270.

Suselbeek, Lennart, Sipke E. van Wieren, Patrick A. Jansen, Frans J.J.M. Bongers, Herbert H.T. Prins. 2012. Is Oak regeneration doomed after wild boar populations boomed? Abstract from 9th International Symposium on Wild Boar and other Suids. Sept. 2-6, 2012 Hannover, Germany.

Sweitzer, R.A. and D.H. Van Vuren. 2002. Rooting and Foraging Effects of Wild Pigs on

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Tree Regeneration and Acorn Survival in California’s Oak Woodland Ecosystems. USDA Forest Service General Technical Report. PSW-GTR-184. pp. 219-231.

Sweitzer, R.A. and D.H. Van Vuren. 2008. Effects of Wild Pigs on Seedling Survival in California Oak Woodlands. USDA Forest Service General Technical Report. PSW-GTR-217. pp. 267-277.

Sweitzer, R.A. 2003. Wild Pig Management Plan for Pacheco State Park. University of North Dakota.

USDA. 2005. Feral/Wild Pigs: Potential problems for Farmers and Hunters. Agricultural Information Bulletin No. 799

USDA. 2011a. Animal and Plant Health Inspection Service (APHIS), National Wildlife Research Center. Website: “Development of Injectable and Oral Contraceptives Technologies and Their Assessment for Wildlife Population and Disease Management – GonaCon – New Single GnRH Shot.” URL:http://www.aphis.usda.gov/wildlife_damage/nwrc/research/reproductive_c ontrol/gonacon.shtml

USDA. 2011b. Animal and Plant Health Inspection Service (APHIS), National Wildlife Research Center. “Feral Swine: Damage and Disease Threats”, Brochure issued August 2011

Vtorov, I. P. 1993. "Feral pig removal: effects on soil microarthropods in a Hawaiian rain forest." Journal of Wildlife Management 57(4): 875-880. (Soil Compaction)

Waithman, J.D., R.A. Sweitzer, A.J. Brinkhaus, I.A. Gardner, D. Van Vuren, and W.M. Boyce. 1999. Range Expansion, Population Sizes, and Management of Wild Pigs in California. Journal of Wildlife Management 63:298-308.

West, B.C., A.L. Cooper, and J.B. Armstrong. 2009. Managing wild pigs: A technical guide. Human-Wildlife Interactions Monograph 1:1-55.

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Appendix A Map of Feral Pig Project Area and Documented Feral Pig Locations

Appendix B Cleveland National Forest Land Management Plan and Bureau of Land Management Resource Management Plan Direction

This appendix summarizes goals, management direction and project design standards found the Cleveland National Forest Land Management Plan and the BLM Resource Management direction for the South Coast and East San Diego County Planning areas.

Land Management Plan Strategic Goals (LMP, Part 1, pp. 31-45)

Forest Goal 2.1: Reverse the trend of increasing loss of natural resource values due to invasive species. The LMP desired condition is that the structure, function and composition of plant and animal communities are not impaired by the presence of invasive non-native plants and animals (LMP, Part 1 p. 32).

Forest Goal 3.2: Retain a Natural Evolving Character within Wilderness. (Feral pig populations spreading to and becoming established in Wilderness areas threaten the natural component of wilderness character and their ecological integrity.)

Forest Goal 5.1: Improve watershed conditions through cooperative management. The desired condition is that national forest watersheds are healthy, dynamic and resilient and are capable of responding to natural and human caused disturbances while maintaining the integrity of their biological and physical processes. (Feral pig populations established in municipal watersheds are a threat to water quality across multiple jurisdictions of federal, state and local government agencies.)

Forest Goal 5.2: Improve riparian conditions. The desired condition is that watercourses are functioning properly and support healthy populations of native and desired non-native riparian dependent species. (Feral pigs cause damage to riparian areas by rooting and wallowing in the soil and causing sedimentation in watercourses.)

Forest Goal 6.2: Provide ecological conditions to sustain viable populations of native and desired nonnative species. The desired condition is that habitats for federally listed species are conserved, and listed species are recovered or are moving toward recovery. Habitats for sensitive species and other species of concern are managed to prevent downward trends in populations or habitat capability, and to prevent federal listing. (Feral pigs compete with native plant and animal species, including endangered, threatened and sensitive species, for habitat and resources.)

Land Management Plan Standards (LMP, Part 3, pp. 3-16) Fish and Wildlife S11: When occupied or suitable habitat for a threatened, endangered, proposed, candidate or sensitive (TEPCS) species is present on an ongoing or proposed project site, consider species guidance documents (see Appendix H) to develop project-specific or activity-specific design criteria. This guidance is intended to provide a range of possible conservation measures that may be selectively applied during

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site-specific planning to avoid, minimize or mitigate negative long-term effects on threatened, endangered, proposed, candidate or sensitive species and habitat. Involve appropriate resource specialists in the identification of relevant design criteria. Include review of species guidance documents in fire suppression or other emergency actions when and to the extent practicable. S12: When implementing new projects in areas that provide for threatened, endangered, proposed, and candidate species, use design criteria and conservation practices (see Appendix H) so that discretionary uses and facilities promote the conservation and recovery of these species and their habitats. Accept short-term impacts where long-term effects would provide a net benefit for the species and its habitat where needed to achieve multiple-use objectives. S13: Manage Critical Biological land use zones so that activities and discretionary uses are either neutral or beneficial for the species and habitats for which the area was established. Accept short-term adverse impacts to threatened, endangered, and proposed species if such impacts will be compensated by the accrual of long-term benefits to habitat for threatened, endangered, and candidate species.

S24: Mitigate impacts of on-going uses and management activities on threatened, endangered, proposed, and candidate species.

S33: Manage Special Interest Areas so that activities and discretionary uses are either neutral or beneficial for the resource values for which the area was established. Accept short-term adverse impacts to these resource values if such impacts will be compensated by the accrual of long-term benefit.

Soil, Water, Riparian and Heritage

S47: When designing new projects in riparian areas, apply the Five-Step Project Screening Process for Riparian Conservation Areas as described in Appendix E - Five-Step Project Screening Process for Riparian Conservation Areas.

S59: Manage eligible wild and scenic river segments to perpetuate their free-flowing condition and proposed classifications, and protect and enhance their outstandingly remarkable values and water quality through the suitability study period and until designated or released from consideration. When management activities are proposed that may compromise the outstandingly remarkable value(s), potential classification, or free-flowing character of an eligible wild and scenic river segment, a suitability study will be completed for that eligible river segment prior to initiating activities. S60: Until proper evaluation occurs, known heritage resource sites shall be afforded the same consideration and protection as those properties evaluated as eligible to the National Register of Historic Places.

Forest-Specific Design Criteria (LMP, Part2, pp. 68-69) CNF S9 - Avoid or mitigate, following consultation, activities resulting in direct trampling or erosion problems to Laguna Mountains skipper suitable and occupied habitat and adjacent areas (Laguna and Palomar Places).

CNF S13 - Avoid or mitigate activities that may negatively affect San Diego thornmint (Acanthomintha ilicifolia) occupied habitat (Sweetwater Place).

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CNF S14 - Restrict activities that may disturb slender-horned spineflower, Dodecahema leptoceras (Aguanga Place).

1.4.4 Forest Management Strategies (LMP Part 2, CNF Strategy, pg. 86-115) AM-2 – Forest Wide Inventory. Complete invasive nonnative plant and animal inventories based on regional protocol methods.

Work with appropriate agencies and academic sources to develop protocol and survey guidelines, gather current information and identify additional research needs for resource management. Implement research as opportunities occur. Priority wildlife studies: - The effects of nonnative species and the effects of management activities on threatened, endangered, proposed, candidate and sensitive habitat. - Best methods for removal of exotic species (bullfrog, etc.). - The results of the removal of nonnative species from threatened, endangered, proposed, candidate and sensitive species habitat. - The effects of management activities on oak regeneration. - Additional information on species specific habitat use and distribution on National Forest System lands.

WL 1 – Threatened, Endangered, Proposed, Candidate, and Sensitive Species Management. Manage habitat to move listed species toward recovery and de-listing. Prevent listing of proposed and sensitive species. Implement priority conservation strategies (table 529) CNF Conservation Strategy.

WL 2 – Management of Species of Concern. Maintain and improve habitat for fish, wildlife, and plants, including those with the following designations: game species, harvest species, management indicator species, and watch list species.

IS 1 – Invasive Species Prevention and Control. Prevent the introduction of new invaders, conduct early treatment of new infestations, and contain and control established infestations.

WAT 1 – Watershed Function. Protect, maintain and restore the natural watershed functions including slope processes, surface water and groundwater flow and retention, and riparian area sustainability.

SD 1 – Wilderness. Protect and manage wilderness to improve the capability to sustain a desired range of benefits and values and so that changes in ecosystems are primarily a consequence of natural processes. Protect and manage the areas recommend for wilderness designation to maintain their wilderness values.

SD 3 – Research Natural Areas. Protect and manage research natural areas (RNA)to maintain unmodified conditions and natural processes. Identify a sufficient range of opportunities to meet research needs.

SD 4 – Special Interest Areas. Protect and manage special interest areas (SIA) for the values and features for which they are established.

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HER 1 – Heritage Resource Protection. Protect heritage resources for cultural and scientific value and public benefit.

LG 2 – Rangeland Health. Rangelands are healthy and sustainable over the long-term. Rangelands are meeting or moving toward forest plan, ecosystem, and site-specific desired conditions.

Resource Management Plan Direction, BLM

Land management activities within the South Coast and East San Diego County Planning areas are guided by BLM policy, standards, goals and objectives outlined within the individual planning area’s Resource Management Plan (RMP). The following policy, standards, goals and objectives are applicable to activities within the proposed project area:

South Coast Planning Area 1994 RMP Policy and Management Guidance #13: BLM will continue to avoid jeopardizing the existence of any federally listed or state-listed or proposed species, and will actively promote species recovery and work to continue to improve the status of candidate and sensitive species (p. 14).

Policy and Management Guidance #19: Measures for minimizing accelerated soil erosion will continue to be made on a site-specific basis through evaluation of management actions (p. 15)

Resource Condition Objectives #1: San Diego County and Riverside County Management Areas. Emphasize protection and enhancement of sensitive species habitat and open space values (pp. 19 & 27).

Resource Condition Objectives #3: San Diego County and Beauty Mountain Management Areas. Enhance habitats for all wildlife species, including deer and quail (pp. 19 & 39).

Resource Condition Objectives #1: Beauty Mountain Management Area. Emphasize protection of sensitive species, open space, watershed and natural values (pp. 39).

Eastern San Diego County Planning Area 2008 RMP Rangeland Health Standards RHS-01, 02, 03, 04. Rangeland Health Standards for the maintenance and preservation of healthy and functioning: Soils, Riparian/wetland and stream functions, Native plant and wildlife species and water quality (pp. 21-23).

Soil Resources Goals and Objectives SRM-02. Maintain or improve ecological condition to proper functioning condition in riparian areas to minimize soil erosion (p. 24).

Soil Resources Management Action SRM-08. Manage biological resources to minimize erosion including the restoration of damaged riparian areas and promotion of healthy native plant groundcover (p. 24).

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Surface Water Goals and Objectives WRM-05, 06. Identify and protect surface waters from the standpoint of human health concerns, aquatic ecosystem health, and other public uses. Preserve and enhance stream bank and channel condition (p. 25).

Surface Water Management Action WRM-10. Prevent or reduce water quality degredation through implementation of applicable BMPs or other specific mitigation measures, when applicable (p. 26).

Desired Plant Community Goals and Objectives VEG-01, 04. Promote biological diversity through conservation of native plant communities and special status species with consideration for multiple use of the land and sustained ecological function. Promote wildlife forage and habitat values and maintain and/or restore intrinsic biological integrity and value for all native plant communities (p. 26).

Desired Plant Community Goals and Objectives VEG-06, 08. Protect or restore native species in upland and riparian communities through an integrated weed management approach emphasizing prevention, early dection, and eradication of invasive non-native plants. Ensure that desired plant communities are protected from ground disturbing activities, including recreation uses (p. 27).

Desired Plant Community Goals and Objectives VEG-13, 14. Promote riparian-associated habitat to enhance wildlife habitat. Promote oak woodland communities with oak recruitment that contain trees of various size and age classes, with an understory of native perennial grass and forb species (p. 27).

Desired Plant Community Management Actions VEG-28. Restore degraded native plant communities through restoration activities that could include but are not limited to exclusion of disturbance activity, invasive plant removal, site preparation, and revegetation (p. 29).

Priority Plant Species Goals and Objectives PPS-02. Promote landscape-scale conservation of the priority plant species to protect or restore botanical resources of concern and to ensure consistent management across jurisdictional boundaries (p. 31).

Priority Plant Species Management Actions PPS-06. Treat non-native invasive species where appropriate to protect priority plant species (p. 32).

Wildlife Management Goals and Objectives WLD-01, 04. Promote and maintain healthy key habitats and their associated wildlife assemblages. Provide suitable habitat capable of maintaining stable or increasing population trends in abundance to help keep species from becoming federally listed (p. 36).

Wildlife Management Actions WLD-11. Manage invasive and pest species or species identified as pests in accordance with applicable BLM or CDFG management policies depending on administrative area (p. 37).

Game Animal Goals and Objectives GME-01. Maintain, enhance, and protect habitat for native game animal populations (p. 41).

Special Status Species Management Goals and Objectives SSS-01. Maintain, enhance, and restore terrestrial and riparian habitats for the survival and recovery of species listed under the ESA and to prevent proposed or candidate species from becoming listed as endangered or threatened under the ESA.

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Perform management actions that contribute to recovery and delisting of species listed under the ESA (p. 42).

Special Status Species Management Actions SSS-06. Implement species- or habitat specific goals, objectives, prescriptions, and actions, as applicable, addressed in the approved recovery plans for federally listed species (p. 42).

Peninsular Bighorn Sheep Recovery Goals and Objectives PBS-01, PBS-03. Promote population increase and protect habitat. Ensure no adverse modification of critical habitat (p. 46).

Least Bell’s Vireo Management Goals and Objectives LBV-02. Ensure that riparian areas are maintained as suitable for least Bell’s vireo (p. 49).

Quino Checkerspot Butterfly Management Goals and Objectives QCB-01. Protect and maintain habitat suitable to support quino checkerspot butterfly within the critical habitat and quino checkerspot butterfly recovery area (p. 52).

Laguna Mountain Skipper Management Goals and Objectives LMS-01. Manage areas of suitable habitat for a suite of habitat features that may support future use by this species (p. 54).

Laguna Mountains Aster Management Goals and Objectives LMA-01. Protect known populations of this species (p. 56).

BLM Sensitive Species Management Goals and Objectives BSS-01. Protect habitats of sensitive plant and wildlife species on BLM-administered lands in order to keep the species from becoming listed under the ESA (p. 57)

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Appendix C Public Review of Environmental Analysis – Comment Summary and Responses to Comments

The legal notice for the 30-day period to comment on the Feral Pig Damage Control Environmental Assessment began on June 19th, 2012 and closed on July 18th 2012. Over 100 comments were received by email, approximately 20 comments were received by mail, and approximately 10 comments were received by telephone during this time period. Comments received are summarized in this document. Most comments generally fit into broad categories that are described in section headings with specific comment listed below.

1. Public hunting as only solution: A large number of commenters felt that the feral pig population in San Diego County should be managed using legal public hunting. Some felt that the feral pig population should be managed as a game species only, while others agreed with an eradication goal but felt that public hunters could accomplish the goal. Several commenters seemed unaware that pig hunting is currently legal and that tags are available. An email was sent to inform them of legal hunting opportunities.

Comment Group 1.1: Manage feral pigs as game species only.

Comment 1.1.1: Cite authority for eradication of games species, should be illegal: Response to 1.1.1: The goal of this project is to reduce or eliminate damage to natural and cultural resources from feral pigs on the Federal lands within the project area. Actions would be performed after receiving a Depredation Permit issued under Fish and Game Code (FGC) sections 4181 and 4181.1 and California Code of Regulations (CCR), Title 14 section 401. This authorization applies when the “applicant’s property is being damaged or destroyed or is immediately threatened with damage or destruction by wild pigs.” (Source: http://www.dfg.ca.gov/wildlife/hunting/pig/depredation.html) The 1997 McPherson Bill states that now under state law, “Notwithstanding Section 4652, any wild pig that is encountered while in the act of inflicting injury to, molesting, pursuing, worrying, or killing livestock or damaging or destroying, or threatening to immediately damage or destroy, land or other property, including, but not limited to, rare, threatened, or endangered native plants, wildlife, or aquatic species, may be taken immediately by the owner of the livestock, land, or property or the owner’s agent or employee, or by an agent or employee of any federal, state, county, or city entity when acting in his or her official capacity.” (Kreith 2007)

Comment 1.1.2: Damage from pigs is overstated and does not justify action beyond legal hunting. Response to 1.1.2: The Environmental Assessment addresses actual and potential impacts from feral pigs in Chapter 3. Additional analysis of the costs and benefits of the proposed action has been added to Section 2.7.

Comment Group 1.2: Change hunting rules to increase effectiveness of hunters to conduct eradication:

Comment 1.2.1: Lower or eliminate cost of pig tags. Comment 1.2.2: Consider a bounty for feral pigs. Comment 1.2.3: No limit on pig tags.

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Comment 1.2.4: Allow night hunting. Comment 1.2.5: Allow baiting. Response to 1.2.1 – 1.2.5: The Forest Service and BLM do not have the jurisdiction or authority to change California Fish and Wildlife regulations as proposed above. These changes would need to be undertaken by the State and may require legislative action.

Comment 1.2.6: Allow use of tracking dogs. Response to 1.2.6: The use of tracking dogs is currently legal for the pursuit of feral pigs (Source: http://www.fgc.ca.gov/regulations/current/mammalregs.aspx).

Comment 1.2.7 Declare feral pigs a pest species. Response to 1.2.7: The Forest Service and BLM do not have the jurisdictional authority to change the designation of feral pigs from a game species to a “pest” status. This is a decision that would be need to be made by the State of California. This is not the only instance where the Forest Service was faced with the dilemma of managing a State designated “game” species that holds value for hunters or anglers but otherwise may be considered detrimental to aspects of the environment. For example, despite their value as game species, there are examples where non-native stocked trout out compete native trout or other aquatic species on National Forests and decisions have been made to eliminate the game species in particular areas.

With respect to the noted contradiction of managing for a game species that is also an invasive pest; Forest Service policies and laws generally guide our decisions toward sustaining the health of ecosystems and their components over time. The Forest Service has determined that feral pigs fits the definition of a “pest”, “invasive” and “non-native” species as defined by the USDA Forest Service despite its “big game” status. Finally, the proposed action is consistent with the new 2011 policy on invasive species (FMS 2900).

Comment Group 1.3: Allow better access for hunters to where pigs are located

Comment 1.3.1: Open roads to allow access for hunters. Response to 1.3.1: The status of roads on the Cleveland National Forest has already been decided through the current Cleveland National Forest Land Management Plan (LMP) and also in a Motorized Travel Management Decision Notice, signed in November 2008. Some roads are permanently closed to the public for a variety of reasons, including resource protection, an inability to maintain roads due to budget constraints, or law enforcement activities. Many locked gates on the Forest also occur at private land boundaries where the Forest Service does not have a public access easement to cross private lands. The Motorized Travel Management Decision and the Cleveland LMP made an effort to maintain the maximum amount of motorized access that was compatible with other goals of the LMP, including demands to protect non-motorized backcounty areas. For these reasons, it is beyond the scope of this analysis to reconsider opening roads that are currently closed to public access.

Comment 1.3.2: Allow ATV access at least to bottom of San Diego River Gorge.

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Response to 1.3.2: The only motorized travel route to the bottom of the San Diego River Gorge involves crossing private land and Tribal lands where no public access easement exists.

Comment 1.3.3: Work with private landowners to allow access for hunting, possibly provide financial incentive. Response to 1.3.3: Private landowners are free to provide access to hunters on their properties for a freely or for a fees. Arrangements made directly between hunters and private landowners are likely to be more beneficial for both parties than an agreement arranged by Federal agencies.

Comment 1.3.4: Tribal lands should be open to hunting for a fee. Response to 1.3.4: Individual Tribal governments have the authority to allow or deny public access for hunting. Neither the Forest Service, nor the BLM has the authority to make this decision.

Comment Group 1.4: Better/updated information for hunters.

Comment 1.4.1: Advertise hunting opportunities Comment 1.4.2: Updated and more detailed maps on pig locations Comment 1.4.3: Website information. Response to 1.4.1 – 1.4.3: More information about how the Forest Service plans to communicate with hunters has been added to Section 2.2.2 of the EA. Maps on the Cleveland National Forest will be updated with the most recent survey information.

Comment 1.4.4: Information on where to process meat. Response to 1.4.4: In general, hunters need to properly field dress meat they plan on consuming and then process the meat at home or via a willing butcher. The Forest Service is unable to provide a list of recommended private vendors for this service due to restrictions on Government favoritism or endorsement.

Comment Group 1.5: Organize hunts

Comment 1.5.1: Work with sportsman groups to organize public hunts. Response to 1.5.1: There is the potential that the Forest Service or BLM will seek help from hunting groups to put extra hunting pressure in specific locations to aid in the feral pig control effort. Additionally, Calfornia Fish and Game has the authority to host special pigs hunts and these could occur on Forest Service or BLM land. This information has been added to the EA in section 2.2.2.

Comment 1.5.2: Enlist help of volunteers or local law enforcement or military. Response to 1.5.2: Volunteers may be utilized for monitoring of pig sign and populations. Volunteer hunters may be used as described in section 2.2.2.

Comment 1.5.3: Bait pigs and hold for sport removal.

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Response to 1.5.3: Baiting and holding pigs for sport removal would be in violation of California Fish and Game code (CA Fish and Game Code Section 3005). It would also be less responsive to concerns about humane treatment and dispatch of animals.

2. Cost/Benefit Analysis needed: Commenters questioned the cost of conducting the proposed action, whether the costs were justified and who should be responsible for the costs.

Comment Group 2.1: Proposed action will not work. Comment 2.1.1: Proposed action will not work and is a waste of taxpayers money. Response to 2.1.1: More information has been added to the EA about the cost/benefits of the proposed action in Section 2.7. More information has also been added about the nature of the feral pig infestation in San Diego County and the potential for eradication or achieving a beneficial reduction in feral pig damage in Sections 1.4, 2.2.2, 2.6 and 2.7. The Forest Service and BLM believe that the proposed action will have a beneficial impact by reducing feral pig damage in the County. If monitoring during the life of the project indicates that the proposed action is not working, efforts will be reevaluated as described in the proposed action.

Comment Group 2.2: More information on needed on costs.

Comment 2.2.1: Need more information on costs, numerous figures have appeared in local media sources. Comment 2.2.2: Need more specifics on how money will be spent. Response to 2.2.1 and 2.2.2: A cost/ benefit analysis has been added to the EA in Section 2.7 detailing expected costs to carry out the proposed action and expected benefits by preventing further damage from feral pigs.

Comment 2.2.3 Barona tribe should pay costs of all eradication activities. Response to 2.2.3: Requiring another entity to incur the costs of management activities falls outside the jurisdiction and authority of the Forest Service and BLM. Moreover, the introduction of feral pigs was not an official activity sanctioned or authorized by the Barona Tribal government.

Comment Group 2.3: More information on benefits.

Comment 2.3.1: Estimate of costs of damages needed. Response to 2.3.1: Section 2.7 details the estimated costs of feral pig damage in the San Diego County and predictions for how these costs may grow.

Comment 2.3.2: If population is currently unknown, then how can costs be justified. Response to 2.3.2: Section 2.7 of the EA provides information on damages that have already occurred in the San Diego County. Additional information was also added to section 1.4 about the current feral pig population in the County and how it is expected to grow. Taking action while pig populations are low greatly reduces future anticipated costs since this is known to be an expanding population.

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3. No pig hunting should be undertaken: Some commenters were opposed to any killing of feral pigs, often including recreation hunting.

Comment Group 3.1: Pigs provide environmental benefits

Comment 3.1.1: Pigs provide food for native wildlife Response to 3.1.1: Section 3.2.1 of the EA considers that some native wildlife species may benefit from the presence of feral pigs as a prey species. This benefit is not expected to outweigh negative consequences to native wildlife from feral pig presence.

Comment 3.1.2: Pigs help establish Coastal oaks by uprooting packed soil and depositing acorns. Response to 3.1.2: Commenters making this argument point to an online article published by Lee Dittman on the webpage http://www.coestatepark.com/wild_pig.htm. This article argues that feral pigs are acting in an ecological role similar to the former role of grizzly bears (now extinct in California) by digging and burying acorns. This article is self published and not peer-reviewed, nor does it present hard data. The EA relies instead on two peer-reviewed publications describing results from experimental studies that show that feral pigs reduce acorn germination and oak seedling survival (Sweitzer 2002, Sweitzer 2008).

Comment 3.1.3: Pig damage is natural Response to 3.1.3: The commenter has provided no scientific literature to support this statement. Feral pigs are a non-native species that were introduced into the local environment by humans. Native plant and wildlife species did not evolve in the presences of feral pigs. The Cleveland National Forest Land Management Plan and the BLM Resource Management Direction for the South Coast and East San Diego County planning areas direct both agencies to minimize the impacts of non-native species to native plants and animal species (See Appendix B of the EA for more detail).

Comment 3.1.4: Pigs will reach a natural balance of population. Response to 3.1.4: The EA cites several peer reviewed publications concerning the dynamics of feral pig populations in the wild (Beiber 2005, Waithman et al. 1999). While it is likely that feral pig populations in the project area would have an upper limit due to resource availability, the populations numbers at that level would have unacceptable impacts on native flora and fauna, water quality and agriculture.

Comment Group 3.2: Alternative to killing pigs should be sought.

Comment 3.2.1: Provide a reservation area, or an enclosure, as means to controlling pig damage without killing pigs. Response to 3.2.1: A reservation area, or enclosure, for pigs would involve many miles of fencing at very high costs. Feral pigs would have to be captured alive and transported to this area to be rereleased. Impacts to native flora and fauna within this reservation area would be severe and would not be allowed under the current Cleveland National Forest LMP or BLM Resource Management Direction.

Comment 3.2.2: Animals should be captured and relocated.

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Response to 3.2.2: Capturing and relocating feral pigs would require a facility willing to receive and care for potentially hundreds or more feral pigs at considerate public expense. No such facility exists. In addition, relocation of wild pigs in California is illegal without a permit issued by California Dept. of Fish and Game. No such permit has even been issued (Kreith 2007).

Comment 3.2.3: Killing pigs is immoral and should not be undertaken. Response to 3.2.3: The Forest Service and BLM do not take the killing of feral pigs lightly, but considers it necessary to protect native flora and wildlife and human health from feral pigs.

Comment Group 3.3: Proposed methods are cruel.

Comment 3.3.1: Methods do not guarantee quick and painless death. Response to 3.3.1: Trapping of feral pigs, the most likely way most pigs will be taken, allows for quick dispatch of feral pigs by professionals. Professional hunters are trained to know when to take a shot on an animal. Every effort will be made to minimize pain and suffering for feral pigs.

Comment 3.3.2: Aerial hunting will kill parents and will cause orphan pigs to suffer. Response to 3.3.2: Aerial hunting is not going to be used as the primary method for reducing feral pigs populations. Instead, it may be used to remove remnant animals from areas that are resistant to trapping. All methods being considered, including aerial hunting, may result in separation of sows from offspring. However, this fact does not offset the need for action to reduce feral pig populations.

Comment 3.3.3: Use of dogs causes pain and terror for pigs. Response to 3.3.3: The use of dogs, like aerial hunting, will be used to locate and remove remnant animals that are resistant to trapping. Dogs are likely to cause stress to feral pigs during hunting. However, this fact does not offset the need for action to reduce feral pig populations.

Comment 3.3.4: Use of dogs results in dog mortality, injuries, rattlesnake bites. Response to 3.3.4: Trained hunting dogs could potentially be injured from a variety of causes during hunting activities. However, these are working animals trained to hunt in these types of landscapes.

Comment Group 3.4: Problem is overstated, do as little as possible. Response to 3.4: The Forest Service and BLM would like to minimize cost and effort incurred to reduce feral pig populations and damage. The threat to natural resources, water quality, property and agriculture from feral pigs is well documented in the literature and cited in the EA. The problem in the project area will only increase with a lack of action.

Comment Group 3.5: Alternatives such as sterilization

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Comment 3.5.1: Use food or bait with birth control. Response to 3.5.1: There are currently no approved sterilization methods that can be delivered orally, through food or baiting. It would also be difficult or impossible to limit impacts to native wildlife ingesting such compounds if they were made available.

Comment 3.5.2: Spaying, neutering or sterilization should be used. Response to 3.5.2: Spaying and neutering would require capturing feral pigs in traps and then performing field surgery. Sterilization is also possible by injection of GonaCon™. GonaCon has proven effective at sterilizing feral pigs for periods of 1-5 years (USDA 2011). Using spaying, neutering and sterilization injections to control feral pig damage would require trapping feral pigs and then releasing them into the wild. After release, feral pigs would continue to damage native habitats, property, agricultural production, water quality and human health. Once pigs are captured, dispatching them prevents them from reproducing and from continuing to damage the environment.

Comment 3.5.3: Use of sterilization would leave pigs alive and allow them to continue to damage the environment. Response to comment 3.5.3: The Forest Service and BLM agree with this comment. See response to 3.5.2

Comment 3.5.4: Use of sterilization improperly dismissed in EA. Response to 3.5.4: The EA released for public comment incorrectly stated that sterilization by injection was not feasible due to lack of approved compounds for field use. The EA cited a paper from 2009. One commenter pointed out that this was no longer the case. The final EA has been updated to include discussion of the availability of a legal and viable injectable contraceptive called GonaCon (USDA 2011). See response to 3.5.2.

4. Comments concerning carcass disposal and use of meat: Many comments were received about the potential for wasting meat and the disposal of carcasses.

Comment Group 4.1: Meat should be put to good use.

Comment 4.1.1: Meat should be donated to homeless shelters or other human use.: Response to 4.1.1: This possibility has been explored, and while this is desirable, options are very limited due to food safety regulations that apply to feral pigs dispatched under official agency action. More information on carcass disposal was added to the proposed action (EA Section 2.2.1). The possibility of donating meat for human consumption was considered by the EA as an alternative that was not carried into full analysis (EA Section 2.5.1).

Comment 4.1.2: Hunters could make better use of meat. Response to 4.1.2: The Forest Service and BLM agree with this comment. However, recreational hunting alone is not likely to result in decrease or control of feral pig populations in San Diego County.

Comment 4.1.3: Carcasses should be donated to private zoo, or wildlife rehab facility.

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Response to 4.1.3: This possibility was explored, but zoos and wildlife rehabilitation facilities would be unlikely to accept feral pig meat due to concern of disease transmission. If a wildlife rehab facility is identified that would accept carcasses, this option may be pursued.

Comment 4.1.4: Costs of any effort to use meat could be significant, not justified. Response to 4.1.4: The Forest Service and BLM agree with this comment and are not pursuing the live transport of feral pigs to approved slaughter facilities for this reason.

Comment 4.1.5: Create volunteer list to come retrieve and use carcasses of dispatched trapped animals. Response to 4.1.5: Pigs dispatched under agency action on Federal lands would be subject to applicable food safety laws requiring USDA approved slaughter facilities, even if volunteers came to traps to take the meat.

5. Comments concerning aerial and professional hunting:

Comment Group 5.1: Comments regarding professional/contract hunters and trapping.

Comment 5.1.1: Experienced hunters, contract hunters, trained dogs all need to be defined. Response to 5.1.1: There is no specific licensing requirement in California for a professional hunter. Hunters hired under contract will be chosen by experience level conducting this type of work. They will likely be licensed professional hunting guides in California. Dogs being used by hunters will have also undergone extensive training. Professional hunters are the best judges on whether a particular dog is capable of tracking feral pigs.

Comment 5.1.2: Humane treatment protocols should be part of any professional hunting contract. Response to 5.1.2: All hunting contracts will include specifications for rapid dispatch of pigs and humane treatment.

Comment 5.1.3: Use of professional hunters would require less supervision, management, or training than volunteers or military hunting teams. Response 5.1.3: The Forest Service and BLM generally agree with this comment. However, volunteers may be utilized in certain circumstances as part of the “all-lands” approach. See response to Comment Group 1.5.

Comment 5.1.4: The use of hunting dogs will spread feral pigs onto adjacents lands. Response to 5.1.4: It is possible that feral pig control activities, including the use of dogs, will cause pigs to move to other locations within or outside of Forest Service jurisdiction. This is why the Forest Service and BLM are working with multiple jurisdictions on an “all-lands” approach to managing feral pig populations in the County. Taking action to reduce pigs is more beneficial to adjacent landowners than not taking any action. Pigs move back and forth across jurisdictions in response to water and food availability. Similarly, the Forest Service is supportive of adjacent landowners taking actions on their lands regardless of the incidental movement of pigs in response to removal actions. More information has been added to the EA in Section 2.6.

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Comment 5.1.5: More detail needed on trap designs and baiting options. Response to 5.1.5: More detail has been added in Section 2.2.2.

Comment Group 5.2: Comments regarding aerial hunting specifically.

Comment 5.2.1: Aerial shooting, done properly is more humane than ground level hunting. Response to 5.2.1: This comment was received in support of the project. The Forest Service and BLM will make efforts to ensure that trapping, ground level hunting and aerial hunting will all be done as humanely as possible.

Comment 5.2.2: Removing use of helicopters would make eradication efforts take longer. Response to 5.2.2: This comment was received in support of the project. The EA states that aerial hunting could be an important tool to help control feral pig populations.

Comment 5.2.3: Helicopters should be used to locate pigs for private hunters. Response to 5.2.3: Helicopters are likely to be used only in remote locations with little access for recreational hunters. Populations discovered by helicopters during operations would be mapped and added to public information materials. Helicopters would be used to identify and located animals to be removed in the most expedient and cost effective manner.

Comment 5.2.4: Brush is too dense for helicopters to be effective Response to 5.2.4: Additional language has been added to the EA describing under what circumstances helicopters may be used in this effort. The Forest Service and BLM acknowledge that aerial hunting may not be effective in all areas where efforts need to take place due to topography, vegetation or safety concerns. Aerial hunting is not the sole method method for reducing feral pig impacts, but this tool would be an effective adjunct to other methods.

Comment 5.2.5: Helicopter hunting would not be effective and would make pig populations more nocturnal. Response to 5.2.5: Helicopter hunting is a proven and highly effective tool for feral pig removal under the right circumstance, but it is just one tool being considered to manage feral pigs and would only be used in scenarios where success is deemed likely. More information about when various methods would be used has been added to the EA in Section 2.2.2.

Comment Group 5.3: Safety of aerial operations:

Comment 5.3.1: Stray or misguided bullets could harm wildlife or people. Response to 5.3.1: Aerial hunting would involve precision targeting of animals by highly skilled professional marksmen. Solid visual contact would always be made before a shot is fired. Aerial hunting of feral pigs has been undertaken in Texas, Florida and other Southeastern states without incidence of harm to humans.

Comment 5.3.2: Need safety plan described to not harm public.

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Response to 5.3.2: Additional information regarding the safety plan has been added to the final EA in section 2.2.2 (Item 7)

Comment 5.3.2.1: Non-English speakers would be unable to read signs about closures. Response to 5.3.2.1: Any signage posted will be in English and Spanish and will use standard universal symbols to express the closure. Aerial hunting operations are generally going to occur in very remote areas with little to no public access in the way of roads or trails.

Comment 5.3.2.2: EA needs to disclose safety plan in regards to safety of training military personnel in the area. Response to 5.3.2.2: The military chain of command will be notified in advance if aerial hunting will be occurring in areas under special use permit for military training. It is unlikely that aerial hunting will ever be used in these areas as they are generally highly accessible by roads and trails.

Comment 5.3.2.3: Lead free ammo more easily starts fires. Response to 5.3.2.3: The Forest Service could find no information confirming this contention. Aerial hunting will not by conducted during critical fire weather conditions. Lead free ammunition is designated to prevent lead poisoning of wildlife that is likely to consume pig carcasses left in the field.

Comment 5.3.2.4: Helicopters need to fly low and can be subject to wind sheers or collisions with trees. Response to 5.3.2.4: Helicopter operations will only occur during weather conditions and at altitudes were safe operations are possible.

Comment Group 5.4: Aerial hunting is cruel.

Comment 5.4.1: Aerial hunting will result in injured animals dying slowly. Response to 5.4.1: Aerial hunting would be conducted by highly trained professionals, but there is a greater likelihood of a non-lethal injury being inflicted than through trapping. However, aerial hunting may prove to be the only effective means of pursuing certain feral pig individuals in remote locations that are “trap avoiders”. It is expected that complete removal of all individuals in a sounder group using all available means will ultimately result in fewer feral pigs needing to be killed over the life of the project.

Comment 5.4.2: Sharpshooting from the ground and trapping are less cruel alternatives. Response to 5.4.2: Trapping and ground based hunting are both part of the proposed action and are likely to be used more than aerial hunting. However, maintaining aerial hunting as on option will allow greater flexibility in pursuing animals that are difficult to capture.

6. General support for proposed action. Comments were received voicing general support for the proposed action to prevent natural resource and property damage.

Comment 6.1: General approach and safety precautions seem adequate.

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Response to 6.1: The Forest Service and BLM will work throughout the project to ensure public safety and pursue the most efficient and effective approaches to reducing feral pig impacts.

Comment 6.2: Impacts from feral pigs justifies the action. Response to 6.2: The Forest Service and BLM agree that the negative impacts of feral pigs, including those already occurring and future increases if nothing is done, justify the proposed action.

Comment 6.3: Would like to volunteer to carry out proposed action. Response to 6.3: Numerous emails and calls have been received asking about the ability to volunteer to help (generally as hunters). See response to Comment Group 1.5 about the possibility of volunteer hunters being enlisted in some circumstances. There may also be volunteer opportunities to help track feral pig impacts and populations.

7. Wilderness. Comments were received expressing concerns about impacts to Federally designated wilderness areas within the project area.

Comment 7.1: Proposed project in wilderness is inappropriate since pigs are not known to be present in wilderness areas. Response to 7.1: Pigs already occur within a few miles of wilderness and it is simply a matter of time before pigs end up in wilderness if not already present. Actions will not occur in wilderness areas unless monitoring reveals feral pig presence. It is essential to the success of the project that wilderness areas do not become refuges for feral pigs. Excluding wilderness areas from the project would likely reduce the overall efficacy of the project by created refuge areas and would also significantly increase the amount of resource damage by feral pigs within wilderness as feral pigs moved into these areas to avoid hunting pressure.

Comment 7.2: Baiting, trapping and killing pigs, hunting pigs with dogs, and use of helicopters to kill and track pigs are all contrary to the direction in the Wilderness Act. Response to 7.2: The Wilderness Act allows for administrative actions that require the use of mechanized equipment and temporary structures (like fencing) in designated Wilderness unit if the action serves to preserve or enhance the wilderness character of the unit or for emergencies. The action must be analyzed to ensure that the minimum necessary tools are used. Both the use of helicopters and traps in wilderness will be very temporary impacts to wilderness character that will help preserve the condition of the wilderness area from permanent and widespread degradation due to a non-native, highly destructive species.

Comment 7.3: Construction of traps in the wilderness areas will literally trammel the wilderness. Response to 7.3: Traps will only be used in wilderness areas if monitoring demonstrates that a sounder of pigs is residing mainly in a wilderness area. The trapping effort will be temporary and will involve a very small area (likely several hundred square feet). Traps will be completely removed at the end of the effort, and disturbed ground will recover quickly. The trapping effort will prevent much longer lasting and widespread impacts from the feral pigs themselves.

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8. Comments about Environmental Assessment analysis. These comments were specific to Chapter 3 of the EA and concerned the Forest Service and BLM analysis of environmental impacts from feral pigs and the action alternatives.

Comment 8.1: Sensitive areas should be fenced proactively. Response to 8.1: There is the possibility that fencing may be placed around certain resource areas that are susceptible to feral pig damage (certain archeological sites or plant habitats for example). This was already included in the proposed action.

Comment 8.2: Statement that feral pigs can benefit some wildlife as food source not supported by literature. Response to 8.2: In analyzing the “No Action” alternative it was stated that some native wildlife may benefit from using feral pigs as prey or carrion source. This is the professional judgment of a Cleveland National Forest Wildlife Biologist. The EA does not state that this effect results in an overall benefit to native wildlife from the presence of feral pigs. One citation was added to the EA showing that mountains lions do hunt feral pigs (Harveson 2000). Morrison (2007) also details how feral pigs led to an increase in golden eagles on Santa Cruz Island.

Comment 8.3: Impact from feral pigs opening new areas to recreational and livestock use should be disclosed. Response to 8.3: Neither the Cleveland National Forest nor the BLM have experienced increased use of areas due to feral pigs opening access routes through disturbance. This is not expected to by an impact from the presence of feral pigs. Grazing use on agency lands is controlled through permit and monitored. There have not been any cases of cattle entering non-permitted lands due to access being opened by feral pig disturbance.

Comment 8.4: Comparisons to Santa Cruz Island not valid due to size, public access and connectivity. Response to 8.4: The Morrison 2007 paper was the only direct comparison of two similar feral pig eradication efforts, one using helicopter support and one not using helicopter support. This paper was used only to help predict the relative effectiveness of the proposed action to a non-helicopter alternative. The effort in San Diego County will differ greatly from these island examples and they are not the basis for the proposed action.

Comment 8.5: Killing or removing animals does not reduce population and can increase it due to spiking food supply which brings in animals from outlying areas. Response to 8.5: The feral pig population in San Diego County did not move in from outlying areas but is instead the result of local releases (CBI 2009). This comment is not supported by the literature which shows that feral pig control efforts have been effective at reducing populations and decreasing damage from feral pigs (West 2009).

Comment 8.6: Need to discuss difference between Waithman study and local conditions when using it to justify the likelihood of expanding feral pig populations. Response to 8.6: The Waithman study occurred in in northern and central California which is contains similar vegetation and climatic conditions as the project area. The Final EA added two more citations, including a populations modeling exercise done for San Diego County

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(Conservation Biology Institute 2009). The likelihood of expanding feral pig populations in San Diego County is no longer a hypothetical. Data demonstrate that pig populations have expanded in numbers and distribution since their introduction (SDNHM 2010)(see EA Appendix A - Map).

Comment 8.7: EA fails to address literature citing benefits of feral pigs and overstates/ is biased towards literature showing feral pig damage. Response to 8.7: The commenter presented several citations for studies showing a limited impact of feral pigs on oak regeneration or as a vector for native seed. These citations included Suselbeek 2012, Dovrat 2012, Work 1993, and the website discussed in response to Comment 3.1.2. These citations were added to the EA. Both the Suselbeek and Dovrat studies took place in Eurasia, where wild boar are a native species. The Dovrat study showed that wild boar are a vector for both native and non-native/exotic plant species into protected natural areas in Israel. The dispersal of exotic plant seed by feral pigs is discussed in the EA in Section 3.3.1.

The Suselbeek study showed that wild boar did not completely consume acorn crops in an experimental setting. This work was conducted in the Netherlands where wild boar are native. In California, feral pigs/boar are non-native. Any increased consumption of acorns by feral pigs is considered a negative effect and is likely to reduce oak regeneration as shown in studies conducted in California (Sweitzer 2002, 2008).

The Work 1993 citation was not added to the EA. It is a non-peer-reviewed speech given at a symposium that suggests wild pigs act in the same ecological role as grizzly bears. This idea was discussed in the response to Comment 3.1.2.

Comment 8.8: Paper referencing wild pigs as vectors of diseases is unsubstantiated. Response to 8.8: Pigs are proven carriers of a large number of diseases, some transmittalbe to humans. APHIS Wildlife Services has been testing pigs that have been taken in California and their results are one of many that supports this contention (USDA 2011b). The EA provides multiple citations about the role of feral pigs as vectors of microbial contamination in waterways (Kaller et al. 2007, Braysher, 2004, Atwill et al. 1997). While individual cases of contamination of agricultural fields or waterways from feral pigs may be controversial or conjectural, it is well documented in the scientific literature that feral pigs are a potential source of microbial contamination to waterways and agricultural fields.

Comment 8.9: No evidence given showing that proposed action could succeed. Non-federal lands will act as a refuge. Response to 8.9: Language was added to the EA in section 2.6 clarifying the “all-lands” approach. This project is part of an interagency effort to work to ensure that there are no refuge lands in the county. Language was also added about measures of success, monitoring and adaptive management in Sections 2.2.2.

Comment 8.10: Cumulative impacts from feral pigs to water quality is miniscule compared to impacts from livestock and other impacts.

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Response to 8.10: The EA and Feral Pig Damage Control Watershed Evaluation (in project file) consider cumulative impacts to water quality from the project and from no action. The Watershed Evaluation, as reported in the EA, concludes that negative impacts to watersheds will increase if feral pig populations are allowed to increase. The presence of livestock was not considered as part of the cumulative effects because livestock on federal lands are actively managed to minimize or eliminate impacts to water quality through Best Management Practices (BMPs). Feral pigs are different than cattle as to the number and transmission of diseases to humans.

Comment 8.11: Analysis fails to consider all references in regards to cruelty of pig trapping. Response to 8.11: This comment contained a list of references about pig intelligence, ability to feel emotions and cognition. The EA does not contend that pigs will not feel stressed or agitated while being trapped. The Final EA has included additional language about operating procedures for trapping designed to reduce stress on animals along with references in section 2.2.2. Concerns about the well-being of the feral pigs, however, do not offset the need to remedy the damage that they cause to natural and cultural resources on the Cleveland National Forest and BLM lands.

Comment 8.12: Analysis is too vague in relation to helicopter use, carcass disposal etc. Response to 8.12: The proposed action has been clarified in the Final EA. More information is provided about when different methods may be utilized.

Comment 8.13: Analysis lacks reference to natural condition where grizzly bears turned up soil and planted acorns. Response to 8.13: See response to Comment 3.1.2.

Comment 8.14: EA needs to address impacts from possible increased predator populations from eating carcasses on endangered species. Response to 8.14: Section 3.2.1 of the EA addresses impacts to wildlife populations from the project and concludes that, while individuals of certain wildlife species may benefit from carcasses on the landscape, the timing and distribution of carcass availability will not result in an increase in predator populations. In addition, endangered wildlife species in the project area are generally threatened by habitat loss and degradation rather than limited by predator pressure.

Comment 8.15: More specifics needed on timeline and monitoring for success. Response to 8:15: More information on monitoring and adaptive management was added to the proposed action in Section 2.2.2.

Comment 8.16: Need to demonstrate for effective scoping for tribal concerns. Response to 8.16: Outreach to Tribes in San Diego County has occurred throughout the project. This included a letter sent to all Tribes on September 15th, 2011 outlining the proposed action and timeline for the EA and requesting comments or requests for consultation. Only the Viejas Tribe requested consultation, which was conducted in a Government to Government consultation meeting between the CNF and Viejas in November 2011. All Tribes were made aware of the availability of the Draft EA for comment.

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Comments were received from three Tribes and the Viejas Tribe once again requested consultation. A second consultation meeting took place in September 2012. The CNF requested that this consultation meeting be open to all Tribes and the Viejas Tribe agreed. In attendance at the meeting were Veijas Tribal Council members and representatives, the Chairman and a Council member from Barona, the Environmental Coordinator for La Jolla, representatives from the Kumeyaay-Diegueno Land Conservancy (KDLC), and Forest Service representatives. Tribes and the Forest Service have agreed to continue coordinating and sharing information as the project moves into implementation. A complete Tribal Consultation Summary has been added to the project record and is available upon request.

Comment 8.17: Need alternative with recreational hunting banned because recreational hunting could drive pigs to epidemiological or agricultural sensitive area. Response to 8.17: This suggested alternative was not considered in the final EA because the BLM and Forest Service do not have the authority to ban recreational hunting on all lands in the County. In addition, a California Fish and Game decision to ban recreational hunting of feral pigs would limit options for private landowners to deal with pig infestations on private lands.

Comment 8.18: Need to ban commercial pig hunting ranches. Response to 8.18: The Forest Service and the BLM do not have the authority to ban commercial pig hunting ranches. There are prohibitions against releasing pigs off of private lands. Most commercial pig hunting ranches in California are hunting feral pigs that are crossing onto or resident on the property and not introducing new pigs to the landscape (for example, Tejon Ranch in Los Angeles County).

Comment 8.19: EA does not address need to work collaboratively with other land owners and Mexico. Response to 8.19: Section 2.6 has been added to the EA detailing the “all- lands” approach being pursued by multiple agencies and jurisdictions in San Diego County. While the population is not believed to be roaming into or mixing with feral pig populations in Mexico, nothing in this decision would preclude coordination with Mexico in the future.

Comment 8.20: EA has no plan for testing/sampling boars to reveal whether there are new introductions or migrations into the area. Response to 8.20: Genetic testing of populations is very expensive and unlikely to be necessary unless monitoring shows that the San Diego County population is approaching known populations to the north. Feral pigs rapidly develop “feral” characteristics that distinguish them from domestic pigs. Experts are generally able to gage from visual appearance whether a sounder is a relatively new introduction (John Turman, APHIS, personal communication). The proposed action does not preclude conducting genetic sampling if a need for this information arises in the future.

Comment 8.21: Need to stipulate lead free fuel in aircraft. Response to 8.21: The project will be using contract helicopters and will defer to the fuel requirements of the aircraft. While aviation fuel is a source of lead in the environment nationwide, it is outside the scope of this project to address this issue.

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Comment 8.22: Public education needed on impacts from wild pigs and safety, property damage concerns due to wild pigs. Response to 8.22: Public education about feral pigs is being conducted through media outreach from the Inter-Governmental Group on Feral Pigs. Additional details about public education has been added to the proposed action in Section 2.2.2.

Comment 8.23: EA does not adequately address impacts to tribal lands, even though proposed action will spread pigs to tribal lands. Response to 8.23: The Forest Service and BLM action is part of an “all lands” approach to feral pigs in San Diego County. Work will be conducted in coordination with Tribes and adjacent landowners. While it is possible that the proposed action may cause particular sounders or feral pig individuals to move within or across jurisdictions, the overall effect of the action alternatives would be a reduction of feral pig impacts within all jurisdictions in the County. See response to comment 5.14.

Comment 8.24: Impact to other species that may be captured by traps needs to be analyzed. Response to 8.24: More information about impacts to non-target wildlife from trapping was added to the proposed action and Section 3.2.1 of the Final EA. The open style of corral traps proposed for use allow the most likely non-target wildlife, deer, to escape. Trap mortality to non-target species is highly unlikely

8.1. Comment 8.25: Need to address cumulative impacts of helicopter flights authorized in wilderness, impossible without accurate description of number of flights. The EA does not discuss the indirect and cumulative impacts of the many helicopter flights, large, numerous traps in wilderness areas, or ground hunting with dogs that might be authorized as part of this Project. Response to 8.25: Cumulative impacts from helicopter flights and other actions in wilderness were analyzed in the EA in Section 3.7.2. Helicopter flight impacts, hunting impacts and trapping impacts to wilderness character are temporary in nature. It is unlikely that project efforts in wilderness areas will need to be numerous or extensive. Impacts will be considered when going through the Minimum Requirements Decision Guide process on an annual or “per contract” basis when the number of flights and traps is better known.

Comment 8.26: In regards to helicopters in wilderness, need to analyze what kinds of wildlife use these areas? Response to 8.26: Impacts to wildlife from helicopters in the entire project area, including wilderness areas is addressed in Section 3.2.1 of the EA.

Comment 8.27: How might measurable components of wilderness character be changed? Response to 8.27: The EA addresses impacts to wilderness in Section 3.7. In general, the EA concludes that impacts to wilderness character from the proposed action are temporary, minor, and small-scale in nature while potential impacts from increased feral pig damage in wilderness areas permanent, major, and widespread in nature.

Comment 8.28: What are existing conditions for wilderness character in the wilderness areas affected? What type of wilderness character monitoring does/will take place?

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Response to 8.28: The Cleveland National Forest annually reports accomplishments for wilderness stewardship on whether characteristics of wilderness are “Managed to a Minimum Stewardship Level.” One performance measure reported on is the stewardship of the wilderness area to minimize impacts by non-native species. Currently, the most likely wilderness areas to be affected by the proposed action are the Pine Creek and Hauser Canyon Wilderness Areas. Both of these wilderness areas face numerous management challenges due their proximity to the international border with Mexico, including immigrant traffic and trash, and impacts from law enforcement activities. Management of the wilderness has focused on trash removal and patrolling for illegal campfires.

Temporary increases in aircraft traffic and foot traffic from feral pig removal activities is considered to have a less negative impact on overall wilderness stewardship and condition than long term establishment of feral pigs.

Comment 8.29: Since the EA does not articulate an ordered interagency strategy for controlling or eradicating feral pigs, the full environmental effects of the actions taken cannot be anticipated. Response to 8.29: The EA addresses impacts to Federal lands from the proposed action within the project area. A separate CEQA document is being prepared for State and local governments. The “all-lands” coordinated approach is describe in Section 2.6 of the EA. Cumulative impacts to resources from all actions were considered in each pertinent section of the EA. The project itself, as proposed, is expected to have overall beneficial impacts on the environment across all jurisdictions. Comment 8.30: Multiple agency NEPA requires an EIS. Response to 8.30: At this time we are uncertain whether to prepare an environmental impact statement or a finding of no significant impact and have chosen to conduct an environmental assessment (See 40 CFR 1508.9(1)). The Forest Service is currently the lead agency for preparation of the EA. If we, in cooperation with the BLM, determine that the environmental impacts of the project will be significant, we will prepare an EIS and likely continue to serve as lead agency for NEPA compliance. There are no CEQ regulations that automatically require the preparation of an EIS when multiple agencies are involved, just that if a multi-agency project does trigger an EIS than a lead agency must be designated.

Comment 8.31: Claims of environmental damage from pigs not supported by science. Response to 8.31: Numerous peer reviewed scientific studies demonstrating negative environmental impacts from feral pigs are cited in the EA. The negative impacts of feral pigs in California and nationwide are well documented in the scientific literature.

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