United States Department of Agriculture
Forest Service
Phragmites and Reed Canarygrass Management Environmental Assessment
January 2015
Shawnee National Forest
Responsible Official: Tim Pohlman, District Ranger
Contact Person: Chad Deaton, Wildlife Biologist
Shawnee National Forest
521 N. Main, Jonesboro, IL 62952
(618) 833-8576, Fax (618) 833-3693, [email protected]
This document and supporting documents can be found on the Shawnee National Forest website.
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Table of Contents
Introduction……………………………………………………………………………………………………………………………… 4
Chapter 1 – Purpose of and Need for Action…………………………………………………………………………..... 4 o Background………………………………………………………………………………………………………………………… 4 o Purpose of and Need for Action…………………………………………………………...... 8 o Proposed Action………………………………………………………………………………………………………………… 8 o Decision Framework………………………………………………………………………………………………………….. 9 o Public and Agency Involvement…………………………………………………………………………………………. 9 o Issues…………………………………………………………………………………………………………………………………. 9
Chapter 2 – Alternatives……………………………………………………………………………………………………………. 11 o Alternative 1 – No Action…………………………………………………………………...... 11 o Alternative 2 – Proposed Action…………………………………………………………...... 11 o Monitoring ………………………………………………………………...... 17 o Alternatives Eliminated from Detailed Study……………………………………………...... 18
Chapter 3 – Affected Environment and Environmental Consequences………………………………………... 21 o Human Health and Safety………………………………………………………………………………………………….. 21 o Watershed Resources ……………………………………………………………………………………………………….. 27 o Wildlife Resources …………………………………………………………………………………………………………….. 32 o Botanical Resources ………………………………………………………………………………………………………….. 40 o Heritage Resources …………………………………………………………………………………………………………… 43 o Fire Risk and Fuels Effects………………………………………………………………………………………………….. 45 o Disclosures...... 49 o Finding of No Significant Impact…………………………………………………………………………………………. 51
References……………………………………………………………………………………………………………………………….. 53
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Introduction
The Forest Service has prepared this environmental assessment in compliance with the National Environmental Policy Act and other applicable federal and state laws and regulations. It discloses the direct, indirect and cumulative environmental effects expected to result from the proposed action and the no-action alternative. This document is organized into three parts:
Chapter One. Purpose of and Need for the Proposed Action: This section includes information on the purpose of and need for the project and our proposal for achieving that purpose and need.
Chapter Two. Alternatives: This section describes the proposed action and no-action alternatives developed based on issues raised during the scoping of the environmental assessment.
Chapter Three. Affected Environment and Environmental Consequences: This section describes the effects of implementing the proposed action and no-action alternatives.
Additional documentation, including working papers with detailed analyses of project-area resources, maps of the areas proposed for treatment, modeling, data and scientific references, is filed in the project record, located at the Shawnee National Forest Jonesboro Work Center, 521 N. Main St., Jonesboro, Illinois. Chapter 1 – Purpose of and Need for Proposed Action
Background We have detected on the Shawnee National Forest (hereafter the Forest) two invasive plant species that pose a serious threat to wetlands and to the plant and wildlife communities that depend on them. Common reed (Phragmites australis) and reed canarygrass (Phalaris arundinacea) are known to be devastating threats to wetlands, including river floodplains, pond banks and other riparian areas. These species are a threat to native plants and animals and serve as source-populations to propagate future invasions. Currently there are 23 known sites of common reed (hereafter phragmites) on about 15 acres and 30 known sites of reed canarygrass (hereafter RCG) on about 67 acres. All known populations of these two species, as well as populations found in the future, are proposed for treatment.
Problem In The floodplain
Since the early 1900’s, wetlands, especially those of the middle Mississippi River floodplain, have suffered much human-caused alteration. Today, most of this region’s wetlands have been cleared, drained and further degraded by flood-control levees, reducing this ecological community to a fraction of what it once was. Therefore, restoration and conservation of wetland habitat is imperative and has been a priority for the Forest since the early 1960’s. However, the progress that has been made could be undermined by the invasion and proliferation of invasive species adapted to floodplain environments. Such invasive plants not only affect biodiversity and ecosystem functions but also human use and enjoyment of wetlands.
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Common reed (Phragmites australis) Reed canarygrass (Phalaris arundinacea)
Figure 1. Phragmites and Reed Canarygrass Infestations
The loss of native plant diversity results in the decline of wildlife habitat, including that needed to support migratory birds and native, resident animal species. By out‐competing native wetland plants, phragmites and RCG disrupt typical food webs for waterfowl and marshbirds, since the dense, monotypic stands of these plants are not used by most wildlife species. Since phragmites and RCG proliferate in shallow and moist soil wetlands, foraging substrate for dabbling ducks and long‐distance migrant birds is lost. The destruction of habitat and diversity are compounded by the fact that dense phragmites and RCG stands alter the water regime in wetland systems, causing the ‘drying’ of wetland soils through increased evaporation and trapping of sediments.
The wetland habitats on the Forest are among the most biologically diverse places in the Midwest. Oakwood Bottoms is recognized as a globally significant “Important Bird Area” by the National Audubon Society and as a “Wetland Focus Area by the Central Hardwoods Joint Venture.1 Maintaining the natural wetland functions is important not only for improving water quality and reducing flooding, but also for providing critical habitat for a wide variety of native plants and animals, in particular migratory birds.
Invasive Nature and Effects of Phragmites and RCG Invasion
Phragmites
Phragmites is a clonal grass species prevalent across North America. It is a common invader of coastal and inland wetlands, especially along the Atlantic Coast and Great Lakes. However, it has increasingly become a problem in the Midwest and in northwestern states. It can grow up to 6 meters (20 feet) high in very dense monotypic stands, and is long-lived. Phragmites is capable of reproduction by seeding, but primarily reproduces by means of rhizomes spreading eventually to monotypic stands of reeds on pond banks and shallow wetlands.
1 The Central Hardwoods Joint Venture (CHJV) is a partnership of state, federal and not-for-profit wildlife conservation agencies and organizations that work together to insure the long-term viability of native bird populations across the U.S. Fish and Wildlife Service Central Hardwoods Bird Conservation Region.
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Phragmites invasion alters the structure and function of diverse wetland ecosystems by changing nutrient cycles and hydrological regimes (Meyerson et al., 2000). Dense phragmites stands in North America decrease native biodiversity and quality of wetland habitat, particularly for migrating waders and waterfowl species (Meyerson et al., 2000). As phragmites proliferates, it shades out native plants, out-competing and then replacing them, leading to the loss of critical wetland habitat and the wildlife associated with it.
Reed Canarygrass
RCG is also a rhizomatous perennial grass. Following the repeated introduction of European strains since the mid-19th century, the species has spread aggressively throughout North American wet habitats (Merigliano and Lesica 1998). Similar to phragmites, RCG spreads by seed and rhizome reproduction. Furthermore, this species also has the ability to form roots in its branches. These branches and plant fragments can establish new plants if cut or broken off (Kercher and Zedler 2004). Few native species remain where this species dominates. As plant community organization is modified by RCG, delicate relationships between plants and animals are altered or eliminated (Spyreas et al 2010).
When phragmites and RCG monocultures are allowed to form and persist, floristic diversity decreases, along with prey-species diversity. Furthermore, the dense stands alter natural stream and wetland functions and hydrology. The dense monotypic stands eventually constrict waterways by promoting silt deposition, and alter the structure and function of marshes because of nutrient and hydrological alterations (INPC 2005).
Considerations for Control
Considerations for phragmites and RCG control range from the use of herbicides to mowing, dredging, flooding, draining, grazing and burning. Considerations for these methods are explained below.
Mechanical Control
Mowing and cutting: According to Hazelton et al. (2014), mowing does little to eliminate rhizomatous grass such as the two species proposed for treatment. Phragmites management in the USA (Hazelton et al., 2014) states that mowing actually stimulates shoot production and may result in increased density of phragmites shoots. Overall, simply cutting is ineffective in eliminating phragmites; but with proper timing and frequency, cutting could help reduce dominance (through depletion of underground reserves) and control the expansion of the population. Mowing of RCG leads to similar results: dominance can be reduced, but it will not eradicate the populations (Lavergne and Molofsky, 2006).
The most effective means of mechanical control of the species is when used in combination with herbicide application, or covering stubble with black plastic for a growing season. However, there are limitations to the plastic-covering method; it is usually applied to small areas, as it is labor intensive (Hazelton et al. 2014). Covering RCG with black plastic tarps could limit regrowth, but this may not be fully effective since rhizomes can persist after two years under plastic and some shoots can even grow through it (Lavergne and Molofsky, 2006).
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Disking: Tilling or disking of plant roots and soil is not an effective mechanical treatment method for phragmites or RCG (Lavergne and Molofsky, 2006). These activities promote the spread of the species because viable rhizome segments are dispersed by machinery, especially disks and track vehicles commonly used to transverse wetland terrain.
In summary, mechanical methods alone are not a sufficient control strategy for phragmites or RCG because of their ability to vigorously spread through rhizomes.
Burning
Like mowing or cutting, burning is not effective unless combined with herbicide application. Burning alone has been shown to stimulate shoot growth in phragmites (Thompson and Shay 1985). Both RCG and phragmites appear to benefit from disturbance. The Forest has been burning one known RCG site at Pennant Bar in Johnson County on a two-year rotation, with no reduction of dominance.
Flooding
The Forest has documented phragmites eradication after long-term river flooding; however it would be difficult to intentionally flood the known populations without affecting the surrounding vegetation and forest. Therefore, flooding is not a viable option.
Grazing
Grazing can successfully control phragmites within two growing seasons, but effectiveness can vary with the number of animals on site (Brundage 2010). However, the use of grazers would require the fencing of the animals into many discrete areas and the provision of supplemental feed and water, requirements that would be overly burdensome, both practically and economically. Furthermore, grazing practices bring on additional ecological impacts such as soil erosion and compaction.
Chemical Control
The most widespread and successful approach appears to be the application of glyphosate late in the growing season, followed by prescribed burning or mechanical removal of dead stalks (INPC 2011). One reason for the reliance on chemical control is that habitat management such as cutting, mowing and disking could potentially encourage the spread of phragmites and RCG because of their ability to spread from rhizomes, as described above. The most commonly used herbicides for control of phragmites and RCG contain the active ingredient glyphosate. Glyphosate mixtures approved for aquatic use, Rodeo and Aquamaster, are recommended by the Illinois Nature Preserve Commission (Table 3). For both phragmites and RCG, chemical treatments are most effective when used in combination with burning or mowing. The application of glyphosate to RCG in early spring typically results in complete control by the end of the growing season, but will not prevent subsequent germination the following year; therefore, chemical treatments usually require multiple applications over successive years to be effective (Hazelton et al., 2014). To prevent the killing of non-target species, RCG can be treated in late October or early spring when other plants are dormant but RCG is green (Lavergne and Molofsky, 2006).
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Purpose of and Need for Action The purpose of this project is to restore and protect native wetland ecosystems, including river floodplains, pond banks and other riparian areas on the Forest by utilizing all available, environmentally responsible tools for the control or elimination of populations of phragmites and RCG on the Forest. Action is needed at this time because:
o phragmites and RCG infestations are jeopardizing the survival of wetland ecological communities, o phragmites and RCG infestations are increasingly degrading native plant communities, o phragmites and RCG infestations are serving as a source for spreading infestations, o taking action now, while phragmites and RCG populations are small, can avert a more widespread and costly future problem, o existing phragmites and RCG populations can spread to adjacent lands, o phragmites and RCG populations are persisting and continuing to spread, pointing to the need for treatment, and o prevention of the establishment of new infestations is more effective than trying to control and eradicate entrenched infestations.
Action is needed following the guidance in the Forest Plan:
The risk of damage from existing invasive species should be reduced through integrated pest management. Invasion-prevention measures should be implemented to maintain native ecosystems. Existing populations of invasive species should be eradicated, controlled and/or reduced. Effects of management activities on the encroachment and spread of invasive species should be considered and mitigated, if needed.
Proposed Action The Forest proposes to use a dual approach for the control of phragmites and RCG:
1. Site-specific treatment utilizing mechanical, fire and/or chemical control methods of all known sites of phragmites and RCG.
2. Rapid response to any newly discovered phragmites and RCG infestations within the Forest utilizing mechanical, fire and/or chemical control methods.
The proposed action would integrate prescribed fire, mowing or cutting and/or chemical treatments to eliminate phragmites and RCG populations threatening unique ecosystems or degrading floodplain-community integrity. We would limit our chemical treatments to one herbicide: aquatic glyphosate (trade names: Rodeo and Aquamaster). We followed the published guidance of the Illinois Nature Preserves Commission (INPC 2011) and The Nature Conservancy (TNC 2004) in selecting these commonly used, generally low impact herbicides approved for aquatic and wetland use. Additionally, we propose to use the most controllable application methods that would have the least residual impact: hand-held applicator, backpack sprayer, or boom-mounted spray rig (on an all-terrain or utility vehicle, pickup truck, or tractor).
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This work would be accomplished as funding and staffing allow. After initial control, follow-up treatments may be necessary to eliminate regeneration. Monitoring of the treatment areas will coincide with periodic reviews of the assumptions, data and analysis on which the responsible official will base his decision.
On the Forest, there are currently 23 known phragmites populations (about 15 acres) ranging from 0.002-8 acres, and 30 known RCG populations (about 67 acres) ranging from 0.01-50 acres. However, we anticipate that new populations will arise over time. This especially is the case in the Mississippi River floodplain, where seed dispersion from river flooding is most likely. We propose to respond rapidly to any new infestations to treat them while they remain very small and limit the impacts on native vegetation and animals. Doing this will also limit the amount of chemical needed to control them.
Decision Framework Given the purpose and need, the responsible official will review the alternatives in order to make the following decisions:
o Should herbicides, mechanical methods and prescribed fire be used to eradicate, control and/or reduce phragmites and RCG on the Forest? o What design features and mitigation should be used to achieve resource objectives? o What monitoring should be done to evaluate the implementation and success of the project?
Public and Agency Involvement
The public and concerned agencies were notified about the proposed Phragmites and Reed Canarygrass Management project and encouraged to comment on the proposal. A scoping notice was mailed to about 193 individuals and agencies who have requested to be informed about Forest proposals. The scoping letter, attachments and maps were posted on the Forest’s website. Responses were analyzed by the interdisciplinary team in order to identify issues. All comments were supportive of the proposed project on the Forest.
In addition, we coordinated with Natural Resources Conservation Service and the River-to-River Cooperative Weed Management Area to increase our knowledge of phragmites and RCG distribution on the Forest.
Issues
Issues are points of debate, disagreement, or dispute about the environmental effects of a proposed action. Following our scoping of the public and other agencies, the interdisciplinary team identified issues related to the proposal and divided them into two groups, key and non-key. Key issues are those directly or indirectly caused by implementing the proposed action or alternatives. The content and issues analysis was reviewed and approved by the responsible official.
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Key Issues and Indicators: The application of herbicides may affect humans.
Human Health Indicator: We will discuss the response of humans in terms of the effects that the approved and properly applied herbicides could have on public health and employees/applicators.
The establishment and spread of phragmites and RCG may affect natural areas and ecosystems, including plants and wildlife.
Plant Community Indicator: We will discuss the response of the plant community in terms of acres of invasive species reduced and native species restored/protected.
Wildlife Community Indicator: We will discuss the response of federally listed species in terms of potential changes in their habitat.
The application of prescribed fire and mechanical treatments may affect designated natural areas and ecosystems, including soil, water, plants and wildlife.
Soil and Water-Quality Indicator: We will discuss the predicted amount of soil erosion in terms of tons/acre/year.
Plant Community Indicator: We will discuss the response of the plant community in terms of potential changes in the number and frequency of phragmites and RCG and native plant species.
Wildlife Community Indicator: We will discuss the response of Regional Forester’s Sensitive Species and species with viability evaluation in terms of potential changes in the habitat.
The application of herbicides may affect designated natural areas and ecosystems, including soil, water, plants and wildlife.
Soil and Water Quality Indicator: We will discuss the potential persistence of the proposed herbicides in the environment.
Plant Community Indicator: We will discuss the response of plant communities in terms of the potential effects on natural areas’ significant and exceptional features.
Wildlife Community Indicator: We will discuss the response of the wildlife community to the proposed action in terms of potential changes in the habitat of management indicator species.
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Chapter 2 – Alternatives
This chapter describes each alternative and compares the alternatives considered.
Alternative 1 – No Action
Under this alternative, we would continue to implement current strategies of phragmites and RCG management, mowing annually the populations on managed levees, burning populations within burn units and inventorying and mapping known and new infestations. No herbicide would be applied at the proposed treatment locations outside of administrative sites and campgrounds.
Alternative 2 – Proposed Action
Under this alternative, we would treat phragmites and RCG infestations using an integrated combination of prescribed fire and manual, mechanical and/or chemical methods. Past prevention measures have been inadequate to stop the spread of these aggressive invasives. We have applied prescribed fire and mechanical and manual control methods without success. Under our proposal, we would treat known infestations (see maps) and any newly discovered infestations on the Forest given available time and resources. Our proposal is a dual approach to treating phragmites and RCG:
1) Treatment of all known sites of phragmites—on about 15 acres at 23 locations—and RCG—on about 67 acres at 30 locations—with mechanical, fire and/or chemical control methods.
2) Rapid response to any newly discovered phragmites and RCG infestations within the Forest utilizing mechanical, fire and/or chemical control methods:
The interdisciplinary team identified the most threatened areas and likely areas of invasion. About 65,000 acres of the Forest are considered most vulnerable. We propose to respond rapidly to any future invasion found on the Forest, to treat them while they remain very small and limit the impacts on native vegetation and animals. Doing this will also limit the amount of chemical needed to control them.
Implementation of the proposed action would be accomplished as funding and staffing allow. The initial work at known locations would be accomplished over the next year, with follow-up treatments in subsequent years to ensure eradication. We expect to be able to treat no more than 150 acres across several watersheds in a given year. After 2-3 years of treatments, we expect the acreage to decrease as populations are controlled and eradicated.
Prior to the treatment of newly documented phragmites or RCG populations, a botanist will identify target plants, sensitive sites, rare plants and methods to protect non-target species. Selected non-target species would be protected with barriers to prevent contact from overspray or drift. Post-treatment monitoring will evaluate effectiveness and success, which we will disclose in our annual monitoring reports. Monitoring of the treatment areas will coincide with periodic reviews of the assumptions, data and analysis on which the responsible official will base his decision.
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Mechanical and Prescribed Fire Treatments
Management would combine mowing or burning followed by herbicide treatments. Burning or mowing reduces aboveground biomass and removes litter, which allows for more efficient application of herbicide and reduces the overspray of non-target plants. Furthermore, removing excess litter will increase colonization of desirable plant species. Most known infestations are small enough that prepping will require only hand-cutting dead stems with mechanical trimmers; however, some will require bushhog-mowing. No heavy equipment will be operated in aquatic environments. Mowing could occur adjacent to streams and wetlands; however, this will be done during dry periods so that soil disturbance is minimized. Infestations in existing prescribed burning units will be treated with herbicide in coordination with scheduled burns. We do not propose any additional burn units, fire lines or tree removal.
Herbicide Treatments
We propose to apply herbicide to phragmites and RCG after the application of fire or mowing. We would follow label directions and limit herbicide use to aquatic glyphosate (trade names: Rodeo and Aquamaster). We selected this herbicide in consultation with the Illinois Department of Natural Resources (IDNR) and the River-to- River Cooperative Weed Management Area, both of which have extensive experience with herbicides. We followed the published guidance of the Illinois Nature Preserves Commission (INPC 2011) and The Nature Conservancy (TNC 2004) in selecting these commonly used, generally low impact herbicides approved for aquatic and wetland use. Additionally, we propose to use the most controllable application methods that would have the least residual impact: hand-held applicator, backpack sprayer, or boom-mounted spray rig (on an all- terrain or utility vehicle, pickup truck, or tractor). We do not propose aerial applications.
For phragmites, it is recommended that herbicide treatments be applied when plants are tasseling (August - October) (INPC 2005). For small stands with sparse stems, we will apply herbicide manually with a glove, sponge, or hand applicator to eliminate treatment of non-target plants. Larger, dense stands will be mowed or burned and allowed to regrow to a height of four or five feet to ensure adequate herbicide coverage. In most stands, follow-up treatments over several years will be necessary for elimination (INPC 2005).
For RCG, burning or mowing in combination with herbicides is an effective strategy. For small populations, herbicides will be applied in late fall or early spring when the plant is green and most native plant species are still dormant. For larger infestations, herbicide applications will be done in June and again in September following a spring burn, as recommended by the Illinois Nature Preserve Commission (INPC, 2003). In most stands, follow-up treatments over several years will be necessary for elimination (INPC 2003).
We propose to treat both of these invasive species with one herbicide: aquatic glyphosate. More than 50 formulations of glyphosate were considered in the current Forest Service risk assessment, which reports that there are obvious and often substantial differences among toxicities of technical grade glyphosate, formulations with no surfactant or with polyoxyethyleneamine surfactants (SERA 2011). Table 1 shows classifications of formulations that discriminate among less toxic and more toxic formulations. In implementing our proposal, we would employ only those formulations with low toxicity. Our analysis of glyphosate effects is based on this.
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Table 1. Classification of Glyphosate Formulations (SERA 2011). Apparent Toxicity Confidence Low Medium High High Accord Glyphos Aquatic Buccaneer Roundup Orig. Accord Conc. Glyphosate VMF Cornerstone Roundup Pro AquaMaster Glypro Eliminator Roundup Pro Conc. AquaNeat Rodeo Gly Star Plus Roundup ProDry Foresters Honcho Roundup ProMax Ranger Pro Roundup UltraMax
Medium Diamondback Accord SP Glyphomax Plus Glyphogan Buccaneer Plus Gly-4 Plus Glyphos X-TRA Cornerstone Plus Honcho Plus Roundup Orig. Max
Low Aqua Star Accord XRT Accord XRT II RapidFire Durango DuraMax WeatherMax Glyphomax XRT Durango DMA RT 3 Mirage Helosate Plus
As specified in the Design Criteria in Table 2, we would apply herbicides at or below label-recommended rates, using only those registered by the Environmental Protection Agency (EPA) for the specific type of site and use we propose. We would follow all applicable state and federal laws. We would apply herbicides within the natural area treatment zones in accordance with the guidance published by the Illinois Nature Preserves Commission and The Nature Conservancy, and monitor our use in compliance with the project design criteria, best management practices and direction in the Forest Service Manual (2080, 2150 and 2200). We would prepare a Pesticide Use Proposal (FS-2100-2) and safety plan (FS-6700-7) prior to herbicide use. We would post signs to alert the public to the location and types of treatments being done and the date when a treated area could be re-entered.
We would apply herbicides during the time of year when application is most effective for a particular species and its life-cycle (Table 2). If the first application of an herbicide is not as effective as expected, we would re- treat with the appropriate herbicide of those proposed to ensure complete removal or control. We would ensure the re-establishment of native vegetation on a treated site through monitoring after removal of the invasives, and reseeding and/or planting native species if necessary to repopulate the site.
Control techniques could vary depending on the size or location of the infestation (Table 2). We developed our proposed methods after review of the guidance published by the Illinois Nature Preserves Commission for management of state nature preserves and The Nature Conservancy, scientific literature, the field experiences of Forest botanists and wildlife biologists, and discussions with invasive species experts.
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Table 2. Proposed Treatment Methods under Alternative 2, Based on Recommendations of the Illinois Nature Preserves Commission for Natural Area Protection (INPC 2011). Reed canarygrass Apply fire in late spring; apply 1.5% solution of aquatic Glyphosate in June and September to ensure control. Phragmites Spraying should be done after the period of peak bloom, usually late August. Over water, use 1.5% solution of Rodeo (aquatic Glyphosate).
Restoration of Native Vegetation
Following treatment and control/elimination of targeted plants, we would ensure the repopulation of the treated areas by native plant species. We expect that dormant native seedbanks would once again germinate and restore the areas to native species. However, if monitoring indicates that this is not occurring following a growing season, we would take action to reseed or replant the areas with native species.
Design Criteria
In order to minimize impacts on the environment and habitats from phragmites and RCG management, we would apply several design criteria (Table 3). These criteria are based on requirements of Forest Service regulations, the Forest Plan, IDNR Forestry Best Management Practices and herbicide label directions. They are part of the design of the project rather than mitigations developed as responses to concerns or ongoing effects. All treatment locations will be recorded with global positioning systems and tracked in a database to plan out- year program needs.
Table 3. Design Criteria for Phragmites and Reed Canarygrass Management. Resource Design Criteria Rationale / Effectiveness Public Affairs Continue to raise awareness and inform and Public awareness of the spread of invasive educate the public and Forest visitors and staff species and the resulting adverse effects on about 1) the issue and effects of invasive species on Forest biodiversity is critical to help prevent the Forest, 2) prevention activities and 3) the introduction and/or spread of invasives in opportunities to participate in low-impact invasive the Forest. species removal activities. Clean all equipment before entering and leaving Minimizes spread of noxious weeds from one project sites. site to the next (USDA-FS 2004). Guide to Workers should inspect, remove and properly Noxious Weed Prevention Practices (2001). Invasive dispose of plant parts found on clothing and Plant equipment before entering or leaving the project Treatments area. Minimize soil disturbance to avoid creating favorable conditions that encourage invasives establishment. All treatment locations will be recorded with global positioning systems and tracked in the database of record. Known or new occurrences that cross ownership Improves effectiveness of control and boundaries will be noted and data shared with increases opportunities for treatment on landowners and other agencies. other lands.
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Table 3. Design Criteria for Phragmites and Reed Canarygrass Management. Botanical Protect rare plant resources, including state-listed Protection of state-listed rare plant resources threatened and endangered species, from and habitat enhancement at request of IDNR. mechanical or chemical treatments. Wildlife Retain all standing dead trees unless necessary to These criteria are required “terms and cut for human safety or to accomplish project conditions” or “reasonable and prudent objectives. measures” in USFWS Biological Opinion for To reduce the chances of affecting bat maternity the Forest Plan (Forest Plan, Appendix H, roosts and foraging habitats, no prescribed burns C.1.b. and C.1.c.). shall be done in upland forests from 5/1-9/1. Burning near known timber rattlesnake den Den sites are extremely important to the locations will be done only during hibernation - maintenance of populations (Forest Plan). 11/1-3/31. For protection of nesting migratory birds, burns For the protection migratory birds (Forest should be done as early or late in the season as Plan, FW51.1.2.6. possible, preferably before 4/1 and after 8/1. In order to protect eastern small-footed bats, fires This species requires additional RFSS will not be ignited near known-occupied rock protection identified in the Forest Plan (USDA outcroppings or cave entrances. No firelines will be 2006). constructed in or immediately adjacent to cave habitat. High-intensity prescribed fire should not be applied Suggested in the conservation assessment for to known locations of the carinate pillsnail in LaRue- the carinate pillsnail (Anderson 2005). Pine Hills Research Natural Area. Heritage The Area of Potential Effects will be reviewed and Implementing protocol methods will ensure inventoried as needed to ensure that all heritage protection of heritage resources (SHPO/IHPA resources are adequately protected. 2009). Recreation Ensure visitor safety before, during and after Forest Plan, Chap. I, B; FW23.2 & FW23.3. and burning activities. Burn areas should be closed to Visual the public. Protect recreational improvements (campgrounds, Forest Plan, FW23.2 trailheads and trail-signing). Damage to trails and roads used as firebreaks or for access should be repaired to standard. Forest Plan, Chap. FW23.3 Wilderness Ensure non-motorized invasives treatments are Wilderness Act of 1964, Forest Plan WD19.3 utilized. Avoid treatments during periods with typical high Mitigate impacts on solitude. visitor volume (holidays). Use erosion-control measures, including seeding, for Illinois Forestry Best Management Practices firelines that could erode soil into water resources. are designed to ensure that prescribed fire Maintain soil-stabilization practices until the site is does not degrade the forested site and that fully revegetated and stabilized. waters associated with these forests are of the highest quality (Holzmueller et al. revised Avoid operating heavy equipment to cause excessive 2012). These BMP’ are periodically reviewed soil displacement, rutting or compaction. and revised. We have monitored the Soil and effectiveness of mitigation measures on Water several past prescribed fire projects and found that the measures were effective in minimizing soil erosion and subsequent sedimentation in streams. Specific guidelines can be found in the Illinois Forestry Best 15 | P a g e
Table 3. Design Criteria for Phragmites and Reed Canarygrass Management. Management Practices.
Apply guidelines for protection of water quality and Implementation of the protection measures riparian areas; guidelines for the reduction of bare- and management recommendations at Forest soil disturbance; retain native vegetation and limit Plan FW25 will prevent excessive soil disturbance as much as possible. sedimentation. Revegetate soils disturbed by management activities Adherence to Forest Plan direction and Illinois by allowing growth of existing on-site vegetation Department of Natural Resources Best where possible and desirable or by planting or Management Practices regarding protection seeding native vegetation. of aquatic habitats will prevent damage to Fueling or oiling mechanical equipment must be these areas. done away from aquatic habitats. When using pesticides in riparian areas and within 100 feet of sinkholes, springs, wetlands and cave openings, adhere to the following: Minimize the use of herbicides; use only herbicides labeled for use in or near aquatic systems; and use only herbicides based on analysis that shows they are environmentally sound and the most biologically effective method practicable (using filter strip widths in the Shawnee LMRP for guidelines). Consider prevailing weather conditions and use lower volatility formulations under conditions that might result in a high risk of volatilization. If burning of target populations is to be conducted To provide for public and employee safety, during the dormant season (fire season) or during ensure sufficient resources for control, and extreme drought, it should be done as part of a properly manage smoke. broadcast burn
Table 4. Design Criteria for Human Health and Safety.
Safe handling and application ensures protection of the health and safety of employees and the public. We will review and follow Job Hazard Analyses, Material Safety Data Sheets and product labeling in order to preserve and protect human health and safety. We will train applicators in the safe handling and application of all herbicides. All Safety and Spill Plan requirements will be followed. We will adhere to the following standards: Pre-application Herbicides will be used only when they will provide the most effective control relative to the potential hazards of other proposed management techniques; choose the most effective herbicide requiring the least number of applications. The use of pesticides must comply with the product label. All applications will be under the direction of a certified pesticide applicator. All individuals working with herbicides will review corresponding Material Safety Data Sheets. Herbicide label directions will be carefully followed. This could include temporary closure of treatment areas in order to prevent or limit public exposure and insure public health and safety. Weather forecasts will be obtained prior to herbicide treatment. Treatment will be halted or delayed, if necessary, to prevent runoff during heavy rain or high wind. Herbicide will be applied only when wind speeds are less than 10 mph, or according to label direction, to minimize herbicide drift. Appropriate protective gear will be worn by herbicide applicators.
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Table 4. Design Criteria for Human Health and Safety.
Application Use the lowest pressure, largest droplet size, and largest volume of water permitted by the label to obtain adequate treatment success; use the lowest spray boom and release height possible consistent with operator safety. Apply pesticides during periods of low visitor use when possible; areas treated with pesticides shall be signed, as appropriate, to ensure users are informed of possible exposure. When using herbicides where runoff may easily enter the water table, (i.e. creeks, rivers, wetlands, caves, sink-holes, or springs), minimize the use of pesticides, herbicides, fertilizers or hazardous materials; use only pesticides labeled for use in or near aquatic systems. Post-Application All herbicides will be stored in approved buildings when not in use. Herbicides will have Material Safety Data Sheets per Forest Service guidelines. Washing and rinsing of equipment used in the mixing and application of pesticides will be done in areas where runoff will not reach surface waters, wetlands, fens, sinkholes, or other special habitats. Rinse water from cleaning or rinsing actions in conjunction with herbicide treatment will be disposed of according to the Federal Insecticide, Fungicide and Rodenticide Act (http://www.purdue.edu/dp/envirosoft/pest/src/container.htm). Herbicide containers will be stored and disposed of following label specifications.
Monitoring
We will monitor our implementation of either alternative in cooperation/collaboration with interested parties and the public to determine whether or not we are accomplishing expected outcomes (Table 5). If monitoring reveals unacceptable outcomes, we will implement appropriate measures to correct problems.
Table 5. Monitoring under Any Alternative. Monitoring Activity Description Location and Timing Soil Visual inspection for sheet, rill and gully Before, during and after project activities Resources erosion. Inspection of soil disturbance. are completed in project area. Invasive Species Samples of project area would be surveyed to Selected locations would be monitored assess invasive species increase/decrease. before and after implementation. Ensure that invasive species design criteria Selected locations would be monitored are implemented. during and after implementation. Rare Plant Monitor known rare plants to ensure no Selected locations would be monitored Resources adverse impacts. during and after implementation. Heritage Resources Ensure that heritage resources are protected This project would be checked annually to during and after implementation. assess damage to historic properties. Native Species Visual inspection to determine presence / In treated areas following a growing repopulation of treated areas by native season. species.
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Alternatives Eliminated from Detailed Study
Treatment of Phragmites and RCG without synthetic herbicide
The interdisciplinary team considered alternatives that would utilize non-chemical methods to treat phragmites and RCG. Considerations for control without herbicide ranged from mowing, disking, flooding, grazing and burning. Considerations for these methods are explained below.
Mechanical Contol
Mowing and cutting: According to Hazelton et al., mowing does little to eliminate rhizomatous grasses such as the two species proposed for treatments. Phragmites management in the USA (Hazelton et al. 2014) states that mowing actually stimulates shoot production and may result in increased density of phragmites shoots. Overall, simply cutting is ineffective in eliminating phragmites, but with proper timing and frequency, cutting may help reduce dominance (through depletion of underground reserves) and control the expansion of the population. Mowing of RCG leads to similar results: its dominance can be reduced but it will not be eradicated (Lavergne and Molofsky, 2006). Mowing would not meet the purpose and need.
Disking: Tilling or disking of plant roots and soil is not an effective mechanical treatment method for phragmites or RCG (Lavergne and Molofsky, 2006), as these promote the spread of the invasives by dispersing viable rhizome segments. Disking would not meet the purpose and need.
Burning
Like mowing or cutting, burning is not effective unless coupled with herbicide application. Burning alone has been shown to stimulate shoot growth in phragmites (Thompson and Shay 1985). Both RCG and phragmites appear to benefit from disturbance. We have been burning one known RCG site at Pennant Bar in Johnson County on a two year rotation, with no reduction of dominance. We conclude that burning would not meet the purpose and need
Flooding
The Forest has documented phragmites eradication after long-term river flooding; however, it would be difficult to intentionally flood known populations without affecting surrounding vegetation and forest. Therefore, flooding would not meet the purpose and need.
Grazing
Grazing can control phragmites when grazed hard over several growing seasons; but effectiveness varies with the number of animals on the site (Brundage 2010). Moreover, goats, cattle and other grazers are hard on the land, resulting in soil erosion, and indiscriminate as to the vegetation they consume. Furthermore, the use of grazers would require the fencing of the animals into many discrete areas and the provision of supplemental feed and water, requirements that would be overly burdensome, both practically and economically. This is especially true since we would need to move/ transport the animals many times for their use to be effective. We concluded that grazing would not meet the purpose and need.
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Non-Synthetic Herbicides
The use of “natural weed killers” was considered by the interdisciplinary team and eliminated from detailed analysis because they are designed to top-kill the plant, with no ability to move internally to kill the roots and rhizomes. Because phragmites and RCG are perennial rhizomatous grasses, systemic herbicides, which move internally in plants to kill all stem tissues including stolons, rhizomes and roots, are necessary. The team concluded they would be impractical and not meet the purpose and need. Chapter 3 – Affected Environment and Environmental Consequences
We describe in this chapter, by resource area, the physical, biological and health and safety conditions that may be affected by the alternatives. As directed by the Council on Environmental Quality’s implementing regulations for the National Environmental Policy Act, the discussion focuses on resource conditions associated with the key issues. The discussion of environmental consequences forms the scientific and analytical basis for comparing the alternatives. Environmental consequences are discussed in terms of direct, indirect and cumulative effects. The discussions are drawn from working papers for each resource area; these may be found in the project record at the Jonesboro Work Center and on the Forest website: www.usda.gov/shawnee.
Direct effects are caused by the proposed activities and occur at the same time and place. Indirect effects are caused by proposed activities and occur later in time or are further removed in distance. Cumulative effects result from the incremental effects of proposed activities when added to other past, present and reasonably foreseeable future actions, regardless of what agency or person undertakes such other actions.
This analysis is tiered to the 2006 Forest Plan programmatic final environmental impact statement (FEIS) and incorporates by reference the programmatic biological assessment and opinion for the Plan. The U.S. Fish and Wildlife Service issued the biological opinion with restrictions to ensure that plan implementation would not likely affect federally listed species on the Forest. This analysis also incorporates by reference the human health and ecological risk assessments of the herbicides proposed for use.
Cumulative Effects
Our analysis was prepared in accordance with the Council on Environmental Quality’s cumulative effects guidance. Resource specialists on the project interdisciplinary team analyzed the cumulative effects on their resource areas from implementing the alternatives and disclosed these in the resource sections of this chapter. Spatial and temporal boundaries for cumulative effects analyses may differ for each resource area. We considered the effects of the past, present and reasonably foreseeable future actions.
Past Actions
Activities over the years on National Forest System and private lands in project-area watersheds include, but are not limited to: farming—including herbicide use—and grazing; mining; timber harvest; wildfires and 3,000-5,000 acres of prescribed fires; development and use of system and non-system equestrian and hiker trails; wildlife management, including wildlife openings and pond and waterhole construction; outdoor recreational use, including picnicking, hunting, fishing, hiking; use of authorized and unauthorized all-terrain vehicles and off- highway vehicles; artifact hunting and collection; special-use permits; construction, maintenance and use of 19 | P a g e
recreational facilities and roads; tree-planting and timber-stand improvements, including tree-thinning; powerline construction and maintenance, including extensive herbicide use. Activities occurring on National Forest System and private lands in the project area are listed in Table 6.
Present Actions
Many types of the past activities on Forest and private land in project-area watersheds are still occurring; however, the prevalence of many of the past activities has changed. Present actions in the project area include, but are not limited to: trail construction, maintenance and use; powerline maintenance; development and use of non-system trails; campground maintenance; all-terrain vehicle use, authorized and unauthorized; timber harvest; agricultural management, with row-cropping, pasturing and pesticide use; wildfire, prescribed fire on 6- 10,000 acres, and fire suppression; road maintenance and use; tree-planting; equestrian use; public visitation and outdoor recreational use, hiking and hunting; special-use permitting, invasive species treatments and openlands management.
Table 6. Past, Present and Reasonably Foreseeable Future Actions in Project Area HUC6 Watersheds (Includes National Forest System and Private Lands). Action Scope of Action Agriculture (cultivated/row-cropping)* About 230,000 acres (past, present and future), HUC 6 watersheds (Includes fertilizer and pesticide use) Agriculture (cultivated/row-cropping)* About 1,054,168 acres (past, present and future), HUC 4 watersheds (Includes fertilizer and pesticide use) Agriculture (pasture)* About 230,000 acres (past, present and future), HUC 6 watersheds (Includes fertilizer and pesticide use) Agriculture (pasture)* About 784,548 acres (past, present and future), HUC 4 watersheds (Includes fertilizer and pesticide use) Prescribed fire ** About 3,000-5,000 acres per year (past). About 6,000-10,000 acres per year (present and future). Wildfires About 85 acres per year (past). About 100 acres per year (future). Timber harvest/firewood cutting About 1,000 acres per year (past, present and future). Includes Harris Branch and Lee Mine timber sale Timber stand improvement (some About 800 acres per year (past, present and future). herbicide use) Recreational use *** About 300,000 people visited the Forest for recreation. About 37,000 for horseback riding About 150,000 for hiking or walking About 37,000 for hunting About 16,000 for fishing About 5,000 for gathering mushrooms, berries and others. About 600 for bicycling.
ATV use Variable use in watersheds (past, present and future).
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Table 6. Past, Present and Reasonably Foreseeable Future Actions in Project Area HUC6 Watersheds (Includes National Forest System and Private Lands). Action Scope of Action Road (including right-of-way) maintenance About 300 miles per year (past, present and future). (Includes herbicide use.) Tree planting About 500 acres per year (past, present and future). Utility ROW maintenance (Includes About 250 miles per year (past, present and future). herbicide use.) Trail construction, reconstruction and About 75 miles maintained per year (past, present and future). maintenance Non-system trails Less than 100 miles of trail (past, present and future). Special-use permits -telephone, electric, Less than 20 acres per year (past, present and future). driveways. Residential chemical use (Includes fertilizer About 1,000 acres treatment per year (past, present and future). and pesticide). Openlands management Disking and planting about 200 acres (past). Disking and planting about 100 acres (future). Residential development About 2,000 new houses per decade (past and future). Invasive species treatments**** Maximum of 1750 acres per year of herbicide treatments. *Agriculture data is based on watershed size. The Hydrologic Unit Code (HUC) is a system of defining watersheds based on size. HUC6 are smaller, 10,000-30,000–acre, watersheds; HUC4 are larger, hundreds of thousands of acres. ** The Forest is planning to burn about 8,000-12,000 acres per year in the future. The prescribed burns in the proposal (about 12,000 acres) would be included in these acres. *** Based on the 2008 National Visitor Use Monitoring Survey. ****Based on the Invasive Species Management EA and DN, the Forest is planning to treat, with chemicals, up to 1750 acres of invasive plants.
Reasonably Foreseeable Future Actions
Reasonably foreseeable future actions on National Forest System and other public and private lands include activities similar to the present as well as those awaiting implementation, planned or listed in out-year schedules such as the quarterly Schedule of Proposed Actions. Activities similar to past and present actions on National Forest System and other public and private lands are reasonably foreseeable in the future (see Table 6). In the next 15 years, the Forest plans to continue to maintain roads and construct and maintain trails; remove trees for ecological restoration; issue special-use permits for access-roads, utilities and outfitter-guides; suppress wildfires as they occur; herbicide treat invasive plants, and implement prescribed burning. Generally, special-use permits allow activities like communications, outfitting and guiding for hunting, hiking and horseback riding, roads, water, power, gas and telephone utilities, commercial and non-commercial recreation events, and cemetery and church access. Human Health and Safety
Of prime importance to the Forest Service are the safeguarding of human health and safety and protection of the environment. Human health and safety is a primary issue related to our proposal to apply herbicide since we
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propose to use potentially hazardous materials. Trained Forest Service personnel, partners or contractors would be applying these chemicals and participating in other invasive species management activities that may have an effect on health and safety.
The boundaries for this project were determined through an analysis of the proposed treatments, protections resulting from implementing treatment protocols and design criteria prescribed to prevent herbicide from drifting, the limited mobility and relatively quick decomposition of the proposed herbicide, and the inability of the Forest Service to predict or control activities beyond Forest boundaries.
Design Criteria – The Forest Service implements a Safety and Health Program that is an integral part of the mission of the agency. The Health and Safety Code Handbook is the main source of standards for safe and healthful workplace conditions and operational procedures in the Forest Service. The handbook is consistent with the standards and regulations of the Occupational Safety and Health Administration (OSHA). The design criteria in Tables 3 and 4 are consistent with all safety practices and procedures included in the Forest Service Handbook and Manual.
The handbook includes safety practices and procedures for herbicide application in the action alternative. Personal protective equipment (e.g., goggles, long sleeves, gloves) is required for use by all applicators. A Job Hazard Analysis is also required. This is a process used to identify and mitigate safety and health hazards in work projects or activities. It is used to identify potential hazards and develop actions to reduce those hazards.
The agency’s Forest Health Protection staff is responsible for managing and coordinating the proper use of pesticides on national forests. It is responsible for providing technical advice and support and conducting training to maintain technical expertise. In order to achieve this function, the Forest Service maintains a cadre of pesticide coordinators and specialists located at regional offices and some forest offices.
The Forest Service is authorized by the Federal Insecticide, Fungicide and Rodenticide Act and Cooperative Forestry Assistance Act to use pesticides for multiple-use resource management and to restore and maintain the value of the environment, within the legal framework provided by the National Environmental Policy Act and the Council on Environmental Quality regulations.
The Federal Insecticide, Fungicide and Rodenticide Act, as amended, is the authority for the registration, distribution, sale, shipment, receipt, and use of pesticides. The Forest Service may use only pesticides registered or otherwise permitted under this act;
The Cooperative Forestry Assistance Act of 1978, as amended by the Food, Agriculture and Trade Act of 1990, is the authority for assisting and advising states and private land-owners in the use of pesticides and other toxic substances applied to trees and other vegetation and to wood products;
The Clean Water Act requires a National Pollutant Discharge Elimination System permit for herbicide applications on or near the “waters of the United States”;
The provisions of the National Environmental Policy Act and the Council on Environmental Quality regulations apply to pesticide management proposals.
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Federal law requires that before selling or distributing a pesticide in the United States, a person must obtain a registration or license from the U.S. Environmental Protection Agency (EPA). Before registering a new pesticide or new use for a previously registered pesticide, the EPA first ensures that the pesticide, including all adjutants, surfactants, or other ingredients of the product, when used according to label directions, can be used with a reasonable certainty of no harm to human health and without posing unreasonable risks to the environment. To make such determinations, the EPA requires more than 100 scientific studies and tests from applicants (USEPA 2006). In 1966, Illinois became one of the first states to regulate pesticides and continues to have one of the most thorough licensing and enforcement programs.
The Illinois Department of Agriculture Environmental Program administers programs for the control and eradication of plant pests and diseases. It regulates pesticide use by registering products, certifying and licensing applicators, and investigating suspected misuse. Department of Agriculture staff also administers programs concerning proper pesticide recordkeeping and waste reduction; pesticide and fertilizer storage, containment and disposal; pesticide container recycling; noxious weed control; and underground water protection initiatives. A department laboratory tests underground water, plant, animal and soil samples for pesticide residues.
Alternative 1 – Direct and Indirect Effects
Effects on human health and safety would continue to relate to the current levels of control measures for invasive species. However, the locations of known or anticipated infestations of phragmites and RCG are generally not in proximity to current invasives-management activities.
We have been applying prescribed fire to about 6,000 acres per year. As a result, there currently are short-term effects from the use of prescribed fire. Smoke from prescribed fire can temporarily reduce visibility and produce some pollutants, especially near the fire. Some, including firefighters, might experience short-term irritation (coughing, watery eyes and runny noses). Particulate matter from smoke in the air can cause a health problem for individuals in proximity to the fire who have respiratory disease, or who are elderly (Core and Peterson 2001, Hall 2009, Sharkey 1997, USDA FS 2001).
Past experience has shown us that these effects are greatly diminished with increasing distance from the fire: the greater the distance, the more air is available to dilute any harmful effects of smoke. Smoke usually lasts only 4-6 hours, although smoldering may occur over several days. In addition, some characteristics of smoke accumulation are predictable based on wind speed and direction, and can be managed effectively to reduce effects on humans. This management is an elemental part of approved burn plans that stipulate beneficial wind direction and speed and atmospheric conditions. These plans also incorporate the state burning permit, discussed below. The burn-plan development process also requires notification of individuals living in a burn- area of upcoming burns.
The Illinois EPA has developed a statewide management plan for smoke from prescriptive fires used to achieve resource benefits. The goals of the plan are: coordination with land managers to develop a basic framework of procedures and requirements for managing smoke, avoidance of significant deterioration of air quality and potential national ambient air-quality standards violations, and mitigation of the nuisance and public safety hazards posed by smoke in populated areas. Prescribed fires in the Forest are in compliance with this plan and follow detailed burn plans and strict prescription standards. Prescribed burns are also evaluated using smoke-
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management models (V-Smoke and/or SASEM—Simple Approach Smoke Estimation Model). Because prescribed fires are planned and can have some short-term, indirect effects from smoke, people living or working in areas adjacent to a burn-area who might be at risk are notified.
Alternative 2 – Direct and Indirect Effects
Based on review of the human health risk assessment of glyphosate (for use near water), the herbicide we propose to use, we can reasonably state that there would be no direct or indirect, adverse effects on human health and safety as a result of implementing the proposed action. The proposed control-method poses extremely minimal safety risks to workers or the public, since we would implement stringent safety practices. Non-Forest personnel working to implement the proposal would be provided with safety orientation, training and personal protective equipment.
We selected the proposed herbicide for its low toxicity to humans and the environment (see Table 1). To assess the potential health effects of the proposed herbicide, we rely not only on the toxicology data used by the EPA to certify the safety of pesticides, but also on the risk assessment produced for the Forest Service independently by Syracuse Environmental Research Associates (SERA). This assessment considered data from scientific literature as well as that submitted to the EPA to support pesticide registration (SERA 2007). Measures of risk in the assessment are based on typical Forest Service uses of the herbicide. Risks to human health from the herbicide we propose were assessed by SERA (SERA 2011). In the analysis of our proposal, we have reviewed and are incorporating, as appropriate, relevant information from the risk assessment, as well as risk information from scientific research articles, both to inform our decision-making as well as to disclose the potential environmental effects. The risk-analysis process quantitatively evaluates the probability that use of a given herbicide might harm humans or other species in the environment.
Potential effects relate to direct contact with the herbicide, exposure to treated vegetation, or consumption of contaminated water, fish or vegetation. The possibility of direct exposure of workers or visitors to freshly treated vegetation is low, since workers would be aware and we would post notices warning the public. The greatest risk of exposure to herbicides would be for the workers mixing and applying them. Adherence to label directions would minimize the exposure of workers during application and apparatus cleanup.
Table 7. Human-Health Risk-Characterizations for Glyphosate (SERA 2011; Tu and Randall 2001). Non-irritating to slightly irritating with direct contact; no permanent damage reported. Inhalation is not an important exposure route because of its low volatility. Poorly absorbed through skin. Classified as Group E pesticide by US EPA: “Evidence of non-carcinogenicity for humans.” Adverse human reproductive effects have not been noted in the United States. Highest HQ for accidental exposure of one hour is 0.003.
Because adherence to all label instructions is required and expected, the design criteria reduce the risk of herbicide drift. If necessary, amendments can be added to the mixture to reduce drift. The herbicide will be hand-applied, ensuring limited environmental exposure to the chemical. When using a spraying apparatus, label directions place restrictions on applications at certain wind speeds. The proposed herbicide does not readily volatilize—vaporize into the air.
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As we discuss in the Watershed Resources section (pages 27-32), the proposed herbicide has a relatively short half-time and would not build up in the environment. It has limited mobility and is approved for use near water. Our proposed application method poses no risk to underground water. Based on the estimated levels of exposure and the criteria for chronic exposure developed by the EPA, there is no evidence that typical or accidental exposures would lead to dose-levels that exceed the level of concern. In other words, all anticipated exposures—most of which involve highly conservative assumptions—are at or below the reference dose. The use of the reference dose, which is designed to be protective from chronic or lifetime exposures, is itself a very conservative component of this risk characterization because the duration of any plausible and substantial exposures is far less than lifetime exposure (SERA 2011).
– Hazard Quotient as Indicator of Human Health and Safety –
The hazard quotient (HQ) is the measure of a level of concern. It is defined by the EPA as:
…the ratio of the potential exposure to the substance and the level at which no adverse effects are expected. If the Hazard Quotient is calculated to be less than 1, then no adverse health effects are expected as a result of exposure. If the Hazard Quotient is greater than 1, then adverse health effects are possible. The Hazard Quotient cannot be translated to a probability that adverse health effects will occur, and is unlikely to be proportional to risk. It is especially important to note that a Hazard Quotient exceeding 1 does not necessarily mean that adverse effects will occur (emphasis added) (www.epa.gov/ttnatw01/nata1999/gloss.html).
Based on the HQ method, the concern for workers is minimal. At the highest labeled rate of 8 pounds active ingredient per acre, the highest HQ is 0.6. The highest HQ for any accidental exposure scenario is 0.003, the upper bound for a spill over the lower legs that is not mitigated for one hour. This is below the level of concern by a factor of 300. To reach a level of concern, an HQ of 1, would require the application of 300 pounds of glyphosate per acre, exposure duration of 300 hours, or about 12 days, none of which is credible.
For Forest visitors, the only non-accidental exposure of concern is for acute exposure involving consumption of contaminated vegetation shortly after the application of glyphosate. For the longer-term consumption of contaminated vegetation, a maximum application rate of 8 pounds active ingredient per acre would not exceed the level of concern (HQ=1). For aquatic applications, the highest HQ is 0.01, the upper bound of the HQ for a child who drinks surface water immediately after an aquatic application of glyphosate. This upper bound is below the level of concern by a factor of 100, thus there is no basis for asserting plausible risk (Durkin 2011a).
– Consideration of Possible Human Endocrine System Disruption –
Neurotoxicity, immunotoxicity and endocrine-disruption risk are also considered in the risk assessments prepared for the Forest Service by SERA (Durkin and Diamond 2002a and 2002b):
The EPA has developed screening assays for endocrine disruption under its Endocrine Disruptor Screening Program and is requiring the testing of glyphosate. No results of the screening assays have been posted to date on the EPA website. The Forest Service risk assessment of glyphosate includes several laboratory studies that indicate no remarkable results regarding endocrine disruption (SERA 2011). As is pointed out above, effects on endocrine function can be expressed as diminished or abnormal reproductive performance. No general 25 | P a g e
conclusions could be drawn in the risk assessment from the several laboratory studies cited. The EPA-derived “chronic” reference dose for glyphosate is two milligrams per kilogram of body weight per day; the Forest Service adopts the same reference dose in its risk assessment. This reference dose represents a daily intake that would cause no adverse effects. It is based on laboratory reproductive studies of glyphosate that indicated no harmful effect.
The Endocrine Disruption Exchange, or TEDX, is a non-profit organization that compiles and disseminates scientific evidence on the health and environmental problems caused by low-dose exposure to chemicals that interfere with development and function, called endocrine disruptors. TEDX maintains a list of potential endocrine-disruptors (TEDX 2011). Each chemical on the list has at least one citation to published scientific research demonstrating effects on the endocrine system. Glyphosate and the herbicide Roundup can be found on the list, although each listing is supported by only one study indicating a potential for endocrine disruption.
The glyphosate study (Paganelli et al. 2010) was done in South America in response to concern over the ubiquitous use of glyphosate-based herbicides in agriculture there. The glyphosate formulations used in South America are unlike those used in the United States and no studies have been done of them in this country (Durkin 2011). The study refers to cases of human deformity and spontaneous abortion in Paraguay and Argentina related to the direct exposure of pregnant women to glyphosate in villages surrounded by genetically- modified crops treated with glyphosate-based herbicides. The Roundup study (Richard et al. 2005) was done on human placental cells and aromatase. It found that Roundup has more deleterious effects on the cells over time than glyphosate alone.
The EPA is currently requiring additional tests of glyphosate to assess its potential to cause endocrine effects. While we note the studies that led to the listing of the herbicides by TEDX, we refer to the limitations of our proposed use of glyphosate. Our application of glyphosate would be focused on phragmites and RCG in discrete areas of a watershed, not applied to thousands of acres of crops. Our implementation of the project design criteria specified in Tables 3 and 4 would ensure that Forest visitors would be made aware of treated areas and, so, prevent their exposure.
– Consideration of Cancer Risk –
The SERA risk assessments and other scientific information on which we rely for our analysis do not establish a cancer risk or cumulative cancer-risk baseline for the herbicide we propose for use. This is because glyphosate is not known to be a carcinogen, so it is reasonable to conclude that there would be no increase in cancer risk from its use (SERA 2011). Based on our review of the human health risk assessment of glyphosate, we can reasonably state that there would be no significant, direct or indirect, adverse effects on human health and safety as a result of implementing the proposed action.
Also under Alternative 2, we propose to apply fire on the phragmites and RCG infestations before they are treated with herbicide. However, as under Alternative 1, we would be able to burn only about 6,000 acres per year, with a planned increase to about 10,000 acres per year. The area treated with fire in this proposal would be included in the Forest’s annual goal.
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We can reasonably expect that effects on human health and safety would be similar to those under Alternative 1. The amount of smoke effects from the increased acreage would not be noticeably different, since the additional amount of fire is expected to be applied over increased time and not in addition to the amount we have been applying. Our fires are well planned and result in minimal smoke-effects and fairly rapid dissipation (Huffman 2009, USDA FS Shawnee 2009).
Both Alternatives – Cumulative Effects
The area under consideration is the project area within the Forest, the 11 counties in which the Forest lies. Although the amount of time required for glyphosate to break down is relatively short, the temporal boundary of ten years was selected because that is the length of the expected life of the effects of phragmites and RCG management activities, as well as the extent to which these effects are measurable and meaningful. Five years past was chosen to consider these specific actions because their effects would not be discernible beyond a five- year timeframe. Past, present and reasonably foreseeable future actions within the analysis area are described at the beginning of Chapter 3.
Considering the minimal effects on human health and safety of implementing the proposed action with those of past, present and reasonably foreseeable future actions, and considering the minimal amount of glyphosate we propose to use in the context of the vast amounts applied for agriculture and other private use—the effects of which would occur with or without implementation of our proposal— the incremental effects on human and health and safety of implementing of the proposed action would be immeasurable and inconsequential and result in minimal cumulative effects.
Watershed Resources
This section analyzes the potential effects of the proposed project on watershed resources (including soil, water, and air) to determine whether they would result in a degradation of watershed resources in the project area.
Soil
The soils in the project area consist mainly of silt loams, which have low rock content. Many are developed in a layer of loess, silt-sized particles carried by the wind. Many of the bottomland and floodplain soils were developed in alluvial, water-transported, material. Some bottomland soils are classified as floodplain soils and others as hydric soils. Nearly all the soil-mapping units have a high potential for compaction; most have slight limitations for prescribed burning (NRCS ratings). Soil mapping units are also delineated according to pesticide leaching-potential and pesticide runoff-potential. Most in the project area have slight-to-moderate leaching potential and moderate-to-high pesticide runoff potential. We do not expect herbicide runoff on this project since it would be applied in specific areas according to the design criteria.
Water
Overall, the water quality of Forest streams is very good. A few are listed as impaired, but that is generally related to mining, agriculture, or other off-Forest impacts. Table 8 presents the acreage of National Forest System lands in the major, HUC4, watersheds of southern Illinois. The data in this table show National Forest acres make up approximately 7.7% of the total acres. 27 | P a g e
Water quality information was taken from the EPA water quality report (Illinois Environmental Protection Agency, 2014 (draft) Illinois 2014 Water Quality Report Stream and Lake Assessments) covering the seventy- four 6th field watersheds and the 5th field watersheds in which they are nested. Water quality is evaluated according to five beneficial uses and rated as fully supporting, non-support, or not assessed (unknown). For any stream and lake reach receiving a less than full support designation, source and causes of non-attainment are listed. Lakes (public and private) evaluated by the IL EPA are also given. Runoff from forest, grassland, parkland, loss of riparian habitat, and stream-bank modification are the sources occurring on areas near project areas and this would most likely occur on private lands.
Air
The Illinois Environmental Protection Agency air quality report was consulted; found on line at: the Illinois EPA Air Quality website. The air quality data from the monitoring stations in the airsheds in which the project area is located are given in the appendices in the Working Paper and are part of the project file. Massac County generally has the highest estimated levels of five pollutants (carbon monoxide, nitrogen oxides, particulate matter, sulfur dioxide, and volatile organic matter) and Pope County has the lowest estimated of the counties in which the project areas are located: Illinois EPA Air Quality Issue webpage. Some prescribed burns on the Shawnee were monitored for PM 2.5 using equipment provided by southern tier Region 9 Air Quality Specialist.
Table 8. HUC4 Watersheds of the Project Area Name (Percentage Forest Service Ownership) National Forest Non-National Forest Total Acres System Acres System Acres Big Muddy River (3) 48,809 1,478,053 1,526,862
Cache River (6) 14,815 219,056 233,871
Lower Ohio River (2) 6,998 375,685 382,683
Lower Ohio River-Bay Creek (30) 117,771 265,186 382,957
Saline River (6) 45,659 707,549 753,208
Upper Mississippi River – 51,607 384,545 436,152 Cape Girardeau (12) TOTAL 285,658 3,430,074 3,715,732
Atmospheric deposition is monitored in southern Illinois both in the past and to the present day. There were two monitoring stations in the National Atmospheric Deposition network (Carbondale and Dixon Springs), with the Dixon Springs station still in operation. Overall, the pH of atmospheric deposition is acidic but has been rising over the past few decades (becoming less acidic). Sulfates have decreased over the long term while nitrate and ammonia levels have fluctuated. Graphs of trend plots are given in the Working Paper appendices and are part of the project record. (National Atmospheric Deposition Program (NADP). 2014. NADP / MTN Sites IL63& IL35. Information found on-line at: the National Atmospheric Deposition Program website for SIU and the National Atmospheric Deposition Program website for Dixon Springs.
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The Illinois EPA has developed a statewide Smoke Management Plan to address smoke from prescriptive fires (prairie and forest) used to achieve resource benefits. The goals of the plan are to coordinate with land managers to develop a basic framework of procedures and requirements for managing smoke from prescribed fires; to avoid significant deterioration of air quality and potential NAAQS violations; to mitigate the nuisance and public safety hazards posed by smoke intrusions into populated areas; and to avoid visibility impacts in Federal Class I Areas. (Illinois Environmental Protection Agency Bureau of Air found on-line at: www.epa.state. il.us/air/. Prescribed fires on the Forest are in line with this plan and the Forest Plan. These treatments follow a detailed burn plan and strict prescription standards. Prescribed burns also are evaluated using smoke management models (V-Smoke/PC-Hysplit).
Herbicide Use
The use of herbicides is common in southern Illinois, as in most of the United States. The State of Illinois uses herbicides to maintain roadsides; electric companies use herbicides to maintain right-of-ways; farmers apply herbicides to protect their crops. In southern Illinois, the majority of watersheds with forested lands also contain cropland. The hydrologic unit code (HUC) 6 watersheds with National Forest System lands in the project area— each of which is about 50,000-150,000 acres—contain about 629,936 acres of cropland and pastureland (Table 9). Most of this land is treated with herbicides, fungicides and fertilizers on an annual basis.
Within these same watersheds, the Forest consists of about 287,000 acres, on 1,750 acres of which we are planning to apply some amount of herbicides annually (Invasive Species Management Project), and up to 150 acres/year proposed under this project. Compared to the non-Forest acreage on which herbicides are applied in the same watersheds, this annual maximum area of application is negligible and insignificant. Additionally, our predominant methods of application would be with backpack sprayers and hand-held applicators. Some would be applied with small, boom-mounted equipment. These methods allow for a great deal of control as compared to other methods, such as large spray-rigs, herbicide cannons, or aerial application.
Alternative 1 – All Effects
None of the proposed activities would take place. Therefore, no management-related appreciable changes in productivity of the land would occur. Soils would be impacted by regular maintenance and use of roads as well as planned and ongoing natural resource management activities. In the absence of wildfire, current runoff and erosion pattern would be maintained. An upland erosion rate of less than one ton per acre per year is predicted by FSWEPP (acronym for Forest Service Water Erosion Prediction Project model) for stands on steep slopes in the absence of fire (Elliott 2000, 2002). Natural processes and functions would continue to occur as dead material decomposes. Actual soil organic matter may increase with an accompanying increase in microorganisms and fungi. Dead and dying trees would decay with carbon released to the atmosphere. Management activities in and adjacent to the project areas already planned would be carried out.
Natural functions may also include pathogens and insects contributing to oak decline leading to dead and down trees. Salvage operations would not take place under this alternative. Dead and down trees would increase fuel levels leading to increased wildfire danger. In the absence of wildfire, dead and down trees would decompose over time leading to increased macro and micro-organism populations carrying out the decomposition process. As decomposition proceeds, dead and down material would eventually be incorporated into the organic horizon
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and surface horizons leading to increased soil nutrient capital. Cumulative watershed effects are the estimated additive changes in watershed disturbance and hazard of damage to soil from fire that might occur from the existing conditions, implementing the proposed project, current activities within the analysis area, plus any foreseeable actions (Table 6).
Soil compaction effects are variable and there is no information as to the time length for compacted soil to return to pre-project conditions in Illinois or in the Shawnee Hills. Some information from the southeast U.S. indicates 10 - 15 years is the average time for restoration of compacted areas through natural processes. The source of this information is from a technical bulletin on the effect of heavy equipment on the physical properties of soils and long-term productivity done under the auspices of the National Council for Air and Stream Improvement (NCASI, Miller, Colbert, & Morris 2004).
Alternative 2 – All effects
Under this alternative, activities associated with phragmites and RCG management include prescribed burning, the application of herbicide, and mechanical and manual treatments. These activities have the potential to expose soil and cause some compaction. Exposed soil has the potential to erode at a faster rate than normal geologic rates. Soil particles can be loosened and transported in overland flow. The direct effects would be minimized through preventative and mitigating actions. Design criteria are discussed in this assessment (Tables 3 and 4). Preventative measures are based on Illinois forestry best management practices (Holzmueller 2012), Forest Plan Standards and Guidelines and soil suitability and limitation identified by the NRCS.
Prescribed Burning
No new burn units or firelines are proposed under the proposed action; however, since this method will be used when phragmites or RCG populations are within an existing burn unit, the effects were analyzed. The effects of prescribed burning on soil erosion and nutrient loss are related to the severity of the burn. These effects are complex and depend on a host of factors. Low-intensity prescribed fire used alone or in combination with the other project measures would not be expected to have an adverse, long-term effect on the quantity of water flow, nutrient budgets, or soil quality. The soil erosion potential is low to medium off fire roads and trails at 0 – 10% slopes and medium to high on slopes at 10 – 18 %. Soil erosion modeling for this activity for all the soil mapping units are given in the appendix. The potential of damage to soil from fire is low to moderate for every soil mapping unit. The potential for damage to soil from fire is a rating given to soil mapping units by the NRCS. The criteria for this rating are given in the Appendix of the Working Paper.
Repeated prescribed fire may reduce organic matter content and increase the loss of soil organisms through erosion. However, monitoring data from our prescribed fires show an average one centimeter of litter consumption, with the majority of litter unburned. Forest burns are typically low-intensity and low-consumption burns (Nowacki, Region 9 Ecologist, personal communication, 2010).
The effect of prescribed burning on the release of carbon dioxide and greenhouse gases into the atmosphere was considered. An increase of greenhouse gases has been observed during the past few decades. Gerould Wilhem of the Conservation Research Institute in Elmhurst, Illinois, in his article “The Realities of Carbon Dioxide: Seeing Through the Smog of Rhetoric and Politics states in his summary: “Planting trees or setting
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forests aside cannot offset the oxidation of fossil fuels because fossil carbon represents stored carbon from another era. Such organic carbon is converted to CO2 in surplus amounts. Trees and vegetation of this era already are cycling carbon into the atmosphere at a rate and concentration to which contemporary life forms are adapted. Relatively sudden changes in atmospheric chemistry, such as we are seeing today, impose global system constraints at a rate to which most life forms have difficulty adjusting during their life spans and physiologic development; most cannot adjust at all. These rapid macrohabitat system changes are not in synchrony with other systems such as day length, genetics, physiology, and chemistry” (Wilhems 2009).
Pesticide Application
The aquatic formulations of glyphosate are proposed for use. In most cases, these formulations would have a minimal impact on soil and water resources, including underground water. In most cases, soil micro-organism populations would increase briefly in the presence of glyphosate as microbial populations would recognize herbicides as a carbon food source. Some minimal temporary effect to the air resource may result as a result of the chemical application through drift and volatilization, although these would be controlled by our application methods.
Little information suggests that glyphosate would harm soil microorganisms under field conditions and a substantial body of information indicates glyphosate is likely to enhance or have no effect on soil microorganisms. Most field studies of microbial activity in soil after glyphosate exposure note an increase in microorganisms and/or activity. While the mechanism of this apparent enhancement is unclear, it is plausible that glyphosate causes an increase in pathogenic fungi in soil (sometimes noted in field studies) because it is used as a carbon source by the fungi and/or treatment results in increased nutrients for fungi. There is no indication that transient enhancement of populations of soil fungi or bacteria result in any substantial or lasting damage to soil ecology (SERA 2011, Extoxnet 2002). Its half-time averages two months in soil and it rapidly dissipates in water to settle in sediment, where its half-time can range from 12 days to 10 weeks (Tu et al. 2001).
Federal ownership in the seventy –two sixth field watersheds in which the project areas are located is 21 percent. The other ownership of 79 percent is likely to influence watershed conditions in the project areas to a greater degree than the project activities of proposed action including chemical application.
Mechanical and Manual Methods
Cutting and mowing would have minimal to no effects on soil or water. Overall, these methods would have a minor impact on soil erosion, compaction, sediment load and the percentage of bare ground. These impacts would occur in individual, widely spread watersheds and should not impact soil productivity. Affected areas would be scattered across the landscape and minimal soil would actually be transported off-site.
Alternative 2 – Cumulative Effects
The cumulative effects of the activities proposed in Alternative 2, considered together with the effects of past, present and reasonably foreseeable future actions, would be imperceptible, non-measurable and insignificant. In light of the vast quantities of herbicides and pesticides applied on the hundreds of thousands of acres of agricultural fields (see Table 9) within the HUC6 watersheds and the larger HUC4 watersheds that contain the Forest—629,936 and 1,838,716 acres, respectively—the amount of herbicide we propose and expect to use is 31 | P a g e
trivial even when added to the planned 1,315 acres of other invasive plant treatments: in terms of glyphosate, 0.12 percent of agricultural use in these watersheds. The incremental effects on watershed resources of implementing Alternative 2 would be short-term, non-measurable and inconsequential, resulting in no significant cumulative effects.
All currently observed effects from other herbicide and pesticide use in the watersheds will be realized under either the no action or proposed action alternatives. Total expected glyphosate application on the Forest— about 1366 pounds—is about 0.12 percent of agricultural use in the HUC6 watersheds of the project area. Table 9 below compares this glyphosate use. Acreage of known populations of Phragmites and RCG are used to show pounds of active ingredient proposed to be used during initial treatment of known populations. In subsequent years we do not expect to treat more than 150 acres (including re-entry and any new populations) of Phragmites and RCG per year. As a worst case scenario a second column is included to display a 150 acre per year figure (Table 9). Realistically, the acres treated should decrease after 2-3 consecutive years of management.
Table 9. Proposed Glyphosate Active Ingredient (AI) Application (in Pounds) Forest-Wide vs. Agricultural Application Herbicide National Forest System Land Agricultural Land Active ingredient (AI) on 1,315 AI on 83 acres of AI on 150 acres HUC6 HUC4 acres based on planned phragmites and of maximum AI on AI on 1,838,716 invasive species management. RCG infestations. potential 629,936A Acres treatments/year Glyphosate 1218 148 270 1,102,388* 3,217,753* Total proposed glyphosate use is about 0.12% of agricultural glyphosate use in all treated HUC6 watersheds and about 0.04% of total agricultural use in the HUC4 watersheds containing the Forest. *We calculated the quantity of agricultural use of glyphosate in the herbicide Roundup using figures from the Center for Food Safety (CFS 2008) and comparing these to GIS land-use layers to conclude an average of 1.75 pounds of active ingredient per acre.
Wildlife Resources
In this section we discuss the wildlife in the project area and the expected effects of the alternatives on these resources. Three federally listed or proposed species are known from Forest: the Indiana bat, the gray bat and the northern long-eared bat, and eight other federally listed, proposed or candidate species are known to occur adjacent to the Forest in the Big Muddy River and/or some perennial streams on the Forest that are direct tributaries of the Mississippi and/or Ohio Rivers. Forty Regional Forester’s Sensitive Species (RFSS), nine wildlife species with viability evaluation (SVE) and five management indicator species are known or suspected in the project area. This section is a summary of the wildlife working papers and biological evaluations prepared for this project. More detail can be found in those documents (project record).
The geographic boundary of the analysis of effects on endangered and threatened species, RFSS and SVE will be different for each species based upon its distribution and/or its habitat distribution in the project area. The temporal boundary for the effects analysis is the estimated 10-15 year life of the Forest Plan for present and future actions. Actions on non-federal land in the project area vicinity are anticipated to be similar to present actions on these areas during this timeframe. The temporal boundary for past actions is the last ten years. Any projects beyond ten years in the past are considered part of the baseline.
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Herbicide Application and Ecological Receptors
Our analysis indicates that use of the herbicide we propose under Alternative 2 would have minimal to non- measurable adverse effects on wildlife. The SERA risk assessment of the proposed herbicide speaks to its safety:
The less toxic formulations of glyphosate do not appear to present any risks to terrestrial organisms other than terrestrial plants. Unlike the case with more-toxic formulations, risks to amphibians and aquatic invertebrates appear to be insubstantial. Less toxic formulations of glyphosate pose no apparent risk to mammals. The risk to birds appears virtually non-existent and is “supported by several field studies indicating that aquatic applications of less-toxic formulations of glyphosate are beneficial to waterfowl due to the improvement of habitat conditions” (SERA 2011).
Based on the EPA’s approach to risk assessment, the risk to terrestrial-phase amphibians from less-toxic glyphosate formulations would be characterized the same as risks to birds. Most field studies suggest that effects on terrestrial invertebrates would be minimal and secondary to changes in vegetation; those that don’t utilize South American formulations of glyphosate, which are not available in the United States in any case (SERA 2011). Regarding amphibians, “there is no basis for asserting that adverse effects…would be apparent even at the upper bound estimates of exposure at the maximum application rate (and) as with fish and amphibians, the risks associated with the less toxic formulations of glyphosate are minimal” (SERA 2011). A study of eastern red- backed salamanders showed that these terrestrial amphibians “are able to detect and avoid all three herbicide formulations at their full label application rates and to avoid the Roundup formulation at 10% the label concentration” (Gertzog et al. 2011). For this project, only glyphosate approved for aquatic use will be used; these herbicides being of the lowest toxicity of any herbicides (SERA 2011).
Management Indicator Species
Table 10 summarizes the expected effects on the five management indicator species under each alternative.
Table 10. Summary of expected effects on the five management indicator species under each alternative. Common Name No Action Alternative 2 Northern Bobwhite Continued loss of habitat, downward Improvement of habitat; decrease in trending population. invasives; increased native herbaceous groundcover, seed production, plant diversity; improvement in early- successional forest and field habitats. Wood Thrush Adverse effect on native understory Beneficial effects: Improved native plant species and thus on food and understory plants and/ or native prey cover for most riparian and that depend upon them are maintained bottomland hardwood forest or improved. dependent species. Yellow-Breasted Chat Continued loss of habitat, downward Maintenance and improvement of native trending of population. plant foods, nesting cover and insect prey. Scarlet Tanager Adverse effects to native plant foods Maintenance and improvement of native and insect prey, resulting in plant foods and insect prey.
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Table 10. Summary of expected effects on the five management indicator species under each alternative. population decline across Forest. Worm-Eating Warbler No measurable effect because it is No measurable effect is expected. an upland species and will not likely lose habitat to Phragmites or RCG invasion.
Federally Listed Species
The project area contains habitat for the northern long-eared bat (Myotis septentrionalis), Indiana bat (Myotis sodalis) and gray bat (Myotis grisescens): The entire Forest is considered to be potentially occupied by Indiana bats during summer months, utilizing standing dead and live trees for summer roost sites and for foraging (Carter 2005; Herkert 1992). Northern long-eared bats are likely to be present throughout the Forest during summer months, especially in close proximity to permanent water sources, such as lakes, streams, or ponds. Gray bats use caves year-round; one cave on the Forest is known to shelter gray bats during part or all of the year. It is recognized that gray bats frequent areas of the Forest in close proximity to larger streams and rivers, such as Big Grand Pierre Creek and the Saline River as travel corridors and for foraging.
In early 2013 the presence of Pseudogymnoascus destructans was confirmed in the Forest. This fungus is the cause of white-nose syndrome, which affects many species of bats in the eastern and central United States, killing up to 99 percent of affected cave-dwelling bats. Since the fungus was only recently discovered in Illinois, our continued monitoring of the bats will tell what effect the disease is having on bats on the Forest. We continue to implement our Forest Plan in cooperation with the U.S. Fish and Wildlife Service and in compliance with the Service’s 2005 Biological Opinion of the Forest Plan.
The other federally listed, proposed or candidate species are dependent upon open water: pink mucket pearly mussel (Lampsilis abruptus), orange-footed pearly mussel (Plethobases cooperianus), fat pocketbook pearly mussel (Potamilus capax), spectaclecase (Cumberlandia monodota), sheepnose (Plethobasus cyphus), least tern (Sterna antillarum) and pallid sturgeon (Scaphirhynchus albus) (see Table 11). All are known adjacent to the Forest in the Mississippi and/or Ohio Rivers. The fat pocketbook pearly mussel is also known in the Saline River.
Indiana, Northern Long-eared, and Gray Bats
Alternative 1 and 2– All Effects
Alternative 1 will have no direct, indirect, or cumulative effect on the northern long-eared, Indiana or gray bat. Alternative 2 may affect but is not likely to adversely affect the northern long-eared, Indiana or gray bat. Effects are considered beneficial, though insignificant and discountable. This was determined primarily because of the possibility of a short-term loss of prey abundance and the possibility of ingesting contaminated prey. However, the treatment of phragmites and RCG may also be beneficial for the northern long-eared, gray and Indiana bats because it will help maintain native habitats and those native insects (prey species) that have evolved with native plants. To protect these three species, only formulations approved for aquatic-use would be applied and label directions followed.
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Fueling or oiling of mechanical equipment would occur at least 100 feet from aquatic habitats, caves and mine openings. Exposed soils will be promptly re-vegetated so as to avoid re-colonization by phragmites and/or RCG and for soil stabilization. With implementation of standards and guidelines in the Forest Plan, along with design criteria for Alternative 2, the potential for “incidental take” is nil as similarly identified in the BO for the Forest Plan (USFWS 2005).
Table 11. Federally Threatened, Endangered, Proposed and Candidate Species Analyzed for the Project Class Species Common Name Status Alt. 1 Alt. 2 Mollusk Lampsilis abruptus pink mucket pearly Endangered NE NLAA mussel Mollusk Plethobasus orange-footed Endangered NE NLAA cooperianus pearlymussel Mollusk Potamilus capax fat pocketbook Endangered NE NLAA pearlymussel Mollusk Cumberlandia spectaclecase Endangered NE NLAA monodota Mollusk Plethobasus cyphus sheepnose Endangered NE NLAA
Mollusk Quadrula cylindrical rabbitsfoot Threatened NE NLAA
Bird Sterna antillarum least tern Endangered NE NLAA Mammal Myotis sodalis Indiana bat Endangered NE NLAA Mammal Myotis grisescens gray bat Endangered NE NLAA Mammal Myotis northern long-eared bat Proposed Endangered NE NLAA Septentrionalis Fish Scaphirhynchus pallid sturgeon Endangered NE NLAA albus Plant Asclepias meadii Mead’s milkweed Threatened NE NE NLAA = Not Likely to Adversely Affect NE = No Effect NLAA was determined for pallid sturgeon and pink mucket, spectaclecase, and scaleshell mussels because effects are considered insignificant and/or discountable. NLAA was determined for Indiana bat, gray bat and northern long-eared bat because effects are considered beneficial, though insignificant and/or discountable. NE determinations were made due to lack of documented occurrences on Forest lands, the project is outside the known or expected range of the species, and/or design criteria were incorporated into the project proposal and will be implemented to protect the species.
Federally Listed, Proposed or Candidate Avian and Aquatic Species
Alternative 1 and 2– All Effects
Implementation of no action, would have no effect on least tern, fat pocketbook, pink mucket, orange-footed pearlymussel, sheepnose, rabbitsfoot, spectaclecase, and pallid sturgeon since none of the species are known from existing or potential treatment areas and treatments would have little direct or indirect effects on aquatic habitats for these species. Implementation of Alternative 2 may affect but is not likely to adversely affect least tern, fat pocketbook, pink mucket, orange-footed pearlymussel, sheepnose, spectaclecase, rabbitsfoot, and pallid sturgeon. This determination was made primarily because it may be possible for direct or indirect adverse
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effects to occur to individuals. However, for reasons given below, these effects are considered insignificant and discountable.
Several design criteria related to water quality will be implemented to protect these species from potential adverse impacts of treatments proposed in Alternative 2. In particular, only formulations approved for aquatic- use would be applied and label directions will be followed. Mixing of these chemicals will be done at least 100 feet away from these areas to prevent spills and concentrated chemicals from entering water occupied by rare species. Exposed soils will be promptly re-vegetated to avoid re-colonization by phragmites or RCG and to stabilize the soil. Fueling or oiling of mechanical equipment would occur at least 100 feet from aquatic habitats, caves, and mine openings. In addition, effects from herbicide application within the watersheds could occur, but these effects are considered insignificant and discountable given the implementation of Forest Plan standards and guidelines and design criteria, the scattered location of treatments within a watershed, and the relatively small individual sites being treated and could potentially be treated.
Beneficial effects from the elimination or reduction of phragmites and RCG (as proposed in Alternative 2) from adjacent terrestrial habitats would be long term. Protecting aquatic habitats and allowing native vegetation to thrive will also benefit various host species that the five mussels rely upon.
Regional Forester Sensitive Species (RFSS) and Species with Viability Evaluations (SVE)
RFSS and SVE are grouped by affected habitats for this analysis:
1. Aquatic 3. Grassland/Oldfield 5. Upland and Bottomland Hardwood Forest 2. Cave 4. Cliff
1. Aquatic Habitats
Alternative 1 – All Effects
Taking no action would result in no direct effects on aquatic RFSS and SVE mammals, birds, reptiles, amphibians, fish and invertebrates as no actions are planned near perennial streams that could directly affect the species. However, long-term indirect effects are expected for many aquatic RFSS and SVE. This is partly due to the expected changes in plant diversity as phragmites and RCG continue to invade and spread, creating monocultures. It has been documented in Illinois that, as plant community organization is modified by reed canarygrass, delicate relationships between plants and animals are altered or eliminated (Spyreas et al 2010). If phragmites and RCG monocultures are allowed to form and persist, floral diversity will decrease, along with prey-species diversity. Additional long-term indirect effects are expected as phragmites and RCG continue to invade and alter natural stream and wetland functions and hydrology. Dense monotypic stands will eventually constrict waterways by promoting silt deposition, altering the structure and function of marshes because of nutrient and hydrological changes (INPC 2005). Many of the aquatic RFSS and SVE animals depend on wetlands for all or part of their life-cycles. These species would be indirectly impacted under the No Action alternative.
It is unknown how quickly or how far existing or new phragmites and RCG infestations will take hold and spread in the ten-fifteen year cumulative-effects timeframe if left untreated, but it is likely floral diversity will decrease, along with prey species diversity. Additionally, untreated phragmites and RCG invasions could alter 36 | P a g e
natural stream and wetland functions and hydrology. The dense monotypic stands could eventually constrict waterways by promoting silt deposition and alter the structure and function of marshes because of nutrient and hydrological alterations (INPC 2005). These potential impacts along with past, present and future actions on public and private lands are the expected cumulative effects to aquatic RFSS and SVC species.
Alternative 2 – All Effects
Prescribed burning or mowing as proposed would have minor negative effects, if any, on water quality and sedimentation and, thus, overall within known and potentially suitable habitats of aquatic RFSS and SVE, the indirect effects on RFSS and SVE aquatic species would be minimal and immeasurable.
Herbicide treatments could cause potential direct effects to aquatic wildlife species, including exposure as herbicides are applied to terrestrial areas adjacent to aquatic settings. In addition, indirect effects could occur if the food chain (primarily aquatic invertebrates) is affected. However, due to the limited extent of proposed treatment areas, the relatively small amounts of herbicide used in any one location, and the ability of these aquatic-labeled herbicides to dilute in aquatic systems and degrade by sunlight and microorganisms; it is likely that the amount of herbicide that could affect any aquatic environments in the project areas would be far below any of the levels of concern shown for fish and aquatic invertebrates.
Only low-toxicity aquatic-approved glyphosate is being proposed for use. Herbicide treatment in riparian areas would follow label direction, specified design criteria and Forest Plan direction to protect aquatic resources. When herbicides are used according to label specifications, no substantial long-term impacts to water quality, aquatic habitat, or aquatic species are expected.
While any adverse effects from the proposed action would be minimal and temporary, beneficial effects from reducing or eliminating phragmites and RCG would be more wide-spread and long-term in plant and animal communities.
Treatment of terrestrial habitats under this alternative could cumulatively contribute to minor, minimal herbicide runoff when combined with past, present and reasonably foreseeable future activities. However, these effects would not contribute measurably to the existing effects on aquatic habitats and associated species.
2. Cave Habitats
Alternative 1 – All Effects
Cave-obligate species are dependent on subterranean environments in caves or mines to live all or a portion of their life cycle. Alternative 1 would have no direct or indirect effects on these species because no actions are planned near perennial or intermittent streams and/or caves that could directly affect these species. Additionally, allowing Phragmites and RCG to persist and continually invade streams, wetlands, riparian corridors, lakes and ponds would not directly or indirectly effect cave or karst environments. This alternative would have no direct or indirect effects and, thus, no cumulative effects on cave-obligate species.
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Alternative 2– All Effects
No direct effects are expected on any of these species from planned actions in Alternative 2 because major soil, water, and/or noise disturbances would not occur near cave entrances as a result of standards and guidelines for Indiana and gray bats and design criteria for eastern small-footed bats. Additionally, no trees (potential bat summer roosts) are being proposed for removal.
Indirect effects could occur to unknown populations in cave environments as a result of mechanical mowing and herbicide treatment and the effects of those actions on sedimentation of perennial and intermittent streams or pesticide contamination to aquatic environments without management guidelines. However, planned actions would include standards and guidelines and/or design criteria to prevent these indirect effects. Only pesticide formulas that are approved for use in or near aquatic areas will be used because they do not persist or spread to aquatic systems beyond project sites and/or do not harm animals. Filter-strip guidelines and design criteria that limit soil disturbance in riparian areas and near cave entrances would greatly reduce the threats of sedimentation and noise into cave environments near project locations.
Beneficial effects from the elimination or reduction of Phragmites and RCG (as proposed in Alternative 2) from adjacent riparian, lake or wetland habitats would be long term. Protecting aquatic habitats and allowing native vegetation to thrive will also benefit various prey and/or host species for the all or some of the ten cave- obligate RFSS and SVC animal species.
Herbicide runoffs from planned actions in Alternative 2 may contribute but would not add measurably to the existing effects on cave systems from private lands identified above especially because of the herbicide selected for us and with applications of Forest Plan standards and guidelines and project design criteria. Cumulative effects of the proposed action would be small and immeasurable on habitat for and populations of cave obligate RFSS and SVC.
3. Grassland/Oldfield Habitats
Alternative 1 – All Effects
Alternative 1 would have no direct effects on the Henslow’s sparrow, loggerhead shrike, or northern bobwhite, since none of the proposed actions would be implemented. This alternative could have indirect adverse effects on the grassland/oldfield-associated birds as Phragmites and RCG continue to invade Forest openlands and replace native grassland and openland plants throughout the project area, lacking more-aggressive invasive plant treatments.
Alternative 2 – All Effects
Implementation of the proposed action alternative would have no direct effect on the grassland/oldfield- specific species, but would have beneficial, indirect effects from herbicide treatments of the worst infestations of Phragmites and RCG, reducing their spread and improving native vegetation. Considering the effects of past, present and reasonably foreseeable actions, the cumulative effects of either alternative on these species
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would be minimally beneficial, with improvements of native food and cover that would result in minor, overall improvements in species populations.
4. Cliff Habitats
Alternative 1 – All Effects
Alternative 1 would not have any direct effects on any of the cliff-dependent RFSS as no actions would occur. Indirect negative effects are not likely because future Phragmites or RCG infestations are not expected in or around cliff habitats. With no direct or indirect effects there will be no cumulative effects to cliff dependent RFSS or SVE animals.
Alternative 2 – All Effects
Because Phragmites and RCG habitats differ greatly from cliff habitats and associated cliff species, there will be no direct or indirect effects from the proposed action on cliff dependent RFSS and SVC. With no direct or indirect effects there will be no cumulative effects to cliff dependent RFSS or SVC animial.
5. Upland and Bottomland Hardwood Forest Species
Alternative 1 – All Effects
Alternative 1 would not have any direct effects on any of the upland or bottomland forest dependent RFSS or SVC as no actions would occur. Indirect, negative effects could occur on most of the above hardwood forest dependent species, as habitats decline due to associated declines in native, prey abundance and/or preferred native, plant foods and cover when Phragmites and RCG are not controlled on the Forest. These would also be the cumulative effects on these species, when considering the effects of past, present and reasonably foreseeable actions.
Alternatives 2 and 3 – All Effects
Alternative 2 would not have any direct effects on most all of the upland and bottomland hardwood dependent species except for grey treefrog from herbicide exposure and American woodcock from burning or mowing early in the spring. Direct effects would be eliminated on these species either because they are seasonally not present (includes migratory birds not nesting or migrating to other parts of the Americas and reptiles and mammals that are underground in dens or in caves during burning or herbicide treatment seasons), not affected as nests or roosts are protected by Forest standards and guidelines and/or project design criteria, or are mobile and can move to avoid herbicide and burning impacts.
Few if any of the above species would be negatively, indirectly affected by herbicide applications and ingestion of herbicide-treated vegetation or insects contaminated with herbicides. The herbicide proposed for use is of low toxicity to mammals, reptiles, amphibian and birds (Appendices B, C, D, and E). The indirect, positive effects of herbicide applications (Alternative 2) and the control of Phragmites and RCG for the benefit of all species would be the maintenance and/or improvement of habitat, including the native vegetation and/or the native prey species that depend upon it. These would be the cumulative effects on these species from
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Alternative 2, except that positive effects on all species would be less pronounced overall as some populations of Phragmites and RCG would persist on adjacent, untreated private forest habitats adjoining the Forest.
Botanical Resources
In this section we discuss the anticipated effects of the alternatives on botanical resources; it is a summary of the Botanical working papers in the project record. We focused our analysis on the environmental effects of the alternatives on rare plant resources. The rare plant resources are grouped by specific habitats, and the natural areas associated with the specific habitats are identified.
Federally Listed Species
All Alternatives – All Effects
Asclepias meadii (Mead’s milkweed) is the only federally listed plant species known to occur on the Forest; it is federally threatened. Alternative 1 and Alternative 2 would not affect Mead’s milkweed because it does not grow in habitats where Phragmites and RCG are found. Therefore, the proposed project will have no effects to this species.
Regional Forester Sensitive Species (RFSS) and Species with Viability Evaluation (SVE) Plants
RFSS (Regional Forester Sensitive Species) and SVE (species that have undergone species viability evaluations) plants that occur on the Forest are addressed in the plant biological evaluation. Field reconnaissance of the project area has been conducted for decades by naturalists, researchers, Forest employees and other professionals. The identified species are documented in records, literature, herbaria and databases.
Of the 83 RFSS and 5 SVE plants on the Forest, 50 RFSS and 5 SVE plants will have no impacts from the proposed project because they do not grow in habitats suitable for Phragmites and RCG. Impacts to the remaining 30 RFSS plants are summarized below. These plant species are grouped into three categories according to their general habitats.
1. Wetlands, Swamps, and Floodplain Forests
2. Streambanks and Streams
3. Lichens on Trees
1. Wetlands, Swamps, and Floodplain Forests
RFSS plants in this group are found in wetland habitats including wet floodplain forests, wet woodlands, pin oak flatwoods, swamps, spring-fed ditches, and moist, open fields. These plants are: Bromus nottowayanus (brome-like sedge), Carex alata (winged sedge), Carex bromoides (brome-like sedge), Carex decomposita (cypress-knee sedge), Carex gigantea (giant sedge), Carex lupuliformis (false hop sedge), Carex socialis (low woodland sedge), Chelone obliqua var. speciosa (red turtlehead), Cynosciadium digitatum (finger dogshade), Dichanthelium joorii (variable panic grass), Eleocharis wolfii (Wolf’s spikerush), Glyceria arkansana (Arkansas manna grass), Heteranthera reniformis (kidneyleaf mudplantain), Hottonia inflata (American featherfoil), 40 | P a g e
Hydrolea uniflora (one-flowered false fiddleleaf), Juglans cinerea (butternut), Platanthera flava var. flava (palegreen orchid), Spiranthes vernalis (spring lady’s tresses), Styrax americanus (American snowbell), Torreyocholoa pallida (pale false manna grass), and Urtica chamaedryoides (nettle).
Alternative 1
This alternative would have no direct impacts on the plants listed above, but there would likely be adverse indirect impacts. These habitats are the most vulnerable to invasion by Phragmites and RCG. Most of the above species have occurrences that are in close proximity to infestations of these grasses and are at the highest risk. It is likely that populations of these RFSS plants will be invaded by Phragmites and/or RCG, resulting in some populations being reduced or destroyed.
Cumulative impacts would be largely adverse as well. 1) Prescribed fire takes place, or will take place at or near most sites where these plants occur. General habitat will improve from the reduction of competing woody vegetation and suppression of most invasive plants. However, fire does not suppress Phragmites or RCG and may even stimulate their growth. Off-site fire will also improve habitat and suppress most invasive plants, but may increase the spread of these invasive grasses. Overall impacts from fire should be beneficial, but there would be some adverse impacts. 2) Some sites where these species occur are authorized for chemical control of invasive plants. This will improve habitat for the RFSS plants at those sites, having beneficial impacts. However, the chemical control of Phragmites and RCG is not authorized. The spread of those grasses would remain unchecked, posing a threat to these RFSS plants. 3) Recreation, including hunting in wetland areas and traffic along roads, will continue to introduce invasive plants to these habitats. Invasive plants brought into wetland habitats will continue to threaten RFSS plants growing there. 4) Destruction and degradation of wetland habitats, in general, will continue to have adverse impacts on wetland vegetation, including RFSS wetland plants on the Forest.
Alternative 2
Alternative 2 is expected to have no direct impacts on the RFSS plants listed above. Field assessments before implementation and design criteria would ensure that those species would be protected during chemical, mechanical, or fire treatments. Indirect impacts should be beneficial. Infestations of Phragmites or RCG found at or near the known site of these plants on the Forest could be chemically treated and controlled before becoming a threat. This would decrease the likelihood of RFSS plant populations being reduced or destroyed.
Cumulative adverse impacts would be substantially reduced with this alternative. 1) The benefits of prescribed fire would remain the same. Since infestations of Phragmites and RCG could be chemically controlled, increased spread of those grasses from fire could be prevented. 2) The chemical control of invasive plants at some site where RFSS wetland plants occur would have beneficial impacts, especially since Phragmites and RCG could also be chemically controlled. 3) Recreational use will continue to introduce invasive plants to wetland habitats. Since Phragmites and RCG infestations could be chemically treated, adverse impacts would be reduced to the above RFSS plants. 4) Adverse impacts from wetland degradation and destruction in general will be somewhat reduced with the ability to control Phragmites and RCG on the Forest.
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2. Streambanks and Streams
RFSS plants in this group can be found growing in moist thickets, streambanks, sandy soil of mesic forests near streams, rich mesic woodlands, cool ravines, streams that flood, spring-fed streambeds, and gravel bars or sandbars along creeks. Plants in this group are: Amorpha nitens (shining false indigo), Dichanthelium yadkinense (Yadkin’s panicgrass), Lilium superbum (Turk’s-cap lily), Plantago cordata (heartleaf plantain), Rhynchospora glomerata (clustered beaksedge), Stenanthium gramineum (eastern featherbells), and Vitis rupestris (sand grape).
Alternative 1
This alternative would have no direct impacts on the plants listed above, but there could be adverse indirect impacts. Although only a few of sites of those plants are near infestations of Phragmites and RCG, they grow in habitats that are vulnerable to being invaded. It is possible that some populations of these RFSS plants will be invaded by Phragmites and/or RCG, resulting in those populations being reduced or destroyed.
Cumulative impacts would be adverse, as well. 1) Prescribed fire takes place, or will take place at some of the sites where these plants occur. General habitat will improve from the reduction of competing woody vegetation and suppression of most invasive plants. However, fire does not suppress Phragmites or RCG and may even stimulate their growth. Off-site fire will also improve habitat and suppress most invasive plants, but may increase the spread of these invasive grasses. Overall impacts from fire should be beneficial, but there would be some adverse impacts. 2) Some sites where these species occur are authorized for chemical control of invasive plants. This will improve habitat for the RFSS plants at those sites, having beneficial impacts. However, the chemical control of Phragmites and RCG is not authorized. The spread of those grasses would remain unchecked, posing a threat to these RFSS plants. 3) Disperse recreation and traffic along roads will continue to introduce invasive plants to these habitats, threatening these RFSS plants.
Alternative 2
Alternative 2 is expected to have no direct impacts on the RFSS plants listed above. Field assessments before implementation and design criteria would ensure that those species would be protected during chemical, mechanical, or fire treatments. Indirect impacts should be beneficial. Infestations of Phragmites or RCG found at or near the known site of these plants on the Forest could be chemically treated and controlled before becoming a threat. This would decrease the likelihood of those RFSS plant populations being reduced or destroyed.
Cumulative adverse impacts would be substantially reduced with this alternative. 1) The benefits of prescribed fire would remain the same. Since infestations of Phragmites and RCG could be chemically controlled, increased spread of those grasses from fire could be prevented. 2) The chemical control of invasive plants at some sites where these RFSS plants occur would have beneficial impacts, especially since Phragmites and RCG could also be chemically controlled. 3) Recreational use will continue to introduce
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invasive plants to these habitats. Since Phragmites and RCG infestations could be chemically treated, adverse impacts would be reduced to the above RFSS plants.
3. Lichens on Trees
Only one RFSS species on the Forest grows in this habitat—Phaeophyscia leana (wreath lichen). It grows in a single area along the Ohio River.
Alternative 1
This alternative would have no direct impacts Phaeophyscia leana, but there could be adverse indirect impacts. Although there are no known infestations of Phragmites or RCG near the site of this species, it grows in habitat that is vulnerable to invasion by these grasses. Phaeophyscia leana requires relatively open air conditions for spore dispersal. If this site becomes heavily infested by either Phragmites or RCG, open air conditions would not be maintained, and reproduction would be severely reduced. This population may eventually be destroyed.
Cumulative impacts would be largely adverse as well. 1) The site where this lichen is located is prone to severe flooding, which could have adverse impacts. 2) Periodic mowing has occurred at this site, maintaining open conditions for this species. 3) Off-site fire will suppress most invasive plants, but may also increase the spread of Phragmites and RCG. 4) The site where this lichen occurs is near a recreational area, where the introduction of invasive plants is increased. 5) River traffic is also likely to continue the introduction of invasive plants at this site.
Alternative 2
Alternative 2 is expected to have no direct impacts on Phaeophyscia leana. Field assessments before implementation and design criteria would ensure that this species would be protected during chemical, mechanical, or fire treatments. Indirect impacts should be beneficial. Infestations of Phragmites or RCG found at or near the site of this lichen on the Forest could be chemically treated and controlled before becoming a threat. This would decrease the likelihood the population of this species being reduced or destroyed.
Cumulative adverse impacts would be substantially reduced with this alternative. Adverse impacts from flooding would remain the same, as would beneficial impacts from mowing. The threat of invasive plants brought in from recreational use and river traffic would be slightly reduced because the chemical control of Phragmites and RCG would be allowed. These grasses would be less likely to spread to the site of this lichen because they would be controlled forest-wide, reducing adverse impacts to this species.
Heritage Resources
This section describes the heritage resource concerns within the project area, including: the affected environment, design criteria developed to protect and preserve the heritage resources and a discussion of the potential effects of both alternatives.
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The primary heritage resource issue in this analysis is the preservation and protection of heritage resources and the assurance that significant heritage resources will not be affected by project implementation. Archaeological sites are located on and in the ground and are affected by any activity that disturbs the soil. Because all project-related activities (mowing, cutting, herbicide application and prescribed fire) will be confined to the currently proposed project area as well as newly discovered Phragmites and RCG colonies within the Forest, the area under consideration is the project area itself, as well as potential colonies that may occur across the Forest in the future, especially on approximately 65,000 acres of low riparian areas within the Forest boundary. Since current project activities are confined to the project area 82.1 acres and heritage resources on federal lands beyond the current project boundary are also protected by law, it is reasonable to include in this analysis the current project area, as well as the methods used to control the spread of Phragmites and RCG that will be used on any new colonies.
The design criteria (Table 2) developed for the analysis of the project area included methods that have evolved over the last several decades since the passage of the National Historic Preservation Act (NHPA) and its implementing regulations. According to Section 106 of the NHPA, “The agency official shall take the steps necessary to identify historic properties within the area of potential effects. The area of potential effect is defined as “….the geographic area or areas within which an undertaking may directly or indirectly cause alterations in the character or use of historic properties…The area of potential effects is influenced by the scale and nature of an undertaking and may be different for different kinds of effects caused by the undertaking.” [36CFR 800.16(d)].
As noted earlier, the area of potential effects may vary depending upon the level of disturbance and what earth-disturbing activities are planned. Invasive species management activities for Phragmites sp. and reed canarygrass include only non-earth-disturbing activities.
Of the Phragmites and RCG control methods that have been proposed, mowing, cutting, herbicide treatments and prescribed fire alone have no potential to cause effects on heritage resources. However, prescribed fire under certain circumstances that have been agreed upon by the Forest, the State Historic Preservation Officer (SHPO) and the Advisory Council on Historic Preservation (ACHP) (fire line construction, above-ground combustible features, and prehistoric rock art) does have the potential to affect historic properties that are located within the area of potential effects. A previously agreed upon protocol has also be been agreed upon by the same parties (SHF, SHPO and ACHP) that will protect and preserve historic properties that might otherwise be at risk (Cultural Resource Report No. 09-08-04-119, as amended and SHPO/IHPA Log #023092407; Programmatic Agreement Among The Advisory Council on Historic Preservation, the United States Department of Agriculture Forest Service Shawnee National Forest and Midewin National Tallgrass Prairie, and the Illinois State Historic Preservation Officer regarding the Process for Compliance with Section 106 of the National Historic Preservation Act for Undertakings related to Prescribed Fire Programs on the Shawnee National Forest and Midewin National Tallgrass Prairie, 2009). In addition, no new fire lines are being proposed under this environmental assessment, nor is the mechanical removal of trees and shrubs a part of this project.
Alternative 1
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There will be no direct, indirect or cumulative effects on heritage resources as a result of the implementation of this alternative because no additional non-native invasive species eradication projects would be implemented and, therefore, activities that might potentially damage archaeological sites and other historic properties would not take place. Currently 100-150 acres of non-native invasive species are either pulled or spot torched annually. Treatment of invasive species with manual (hand pulling herbaceous invasive plants such as garlic mustard and Japanese stiltgrass), or torching would have no effect on subsurface or sub-plow zone heritage resources. Much of the project area and the Forest in general have been previously subjected to decades of traditional farming activities such as plowing and disking, and therefore the top 4-8 inches of soil are already disturbed and the whatever cultural deposits are present are mixed. This mixed layer of soil is called the plow zone. Invasive species management activities that further mix the soil within the plow zone (hand pulling and light grubbing) will not contribute additional effects to any cultural material that might be contained in the plow zone.
Alternative 2
There will be no direct, indirect or cumulative effects on heritage resources as a result of the implementation of an action alternative. As noted above project methods used to control Phragmites sp. and reed canarygrass include the use of mowing, cutting, herbicide treatments, and prescribed fire. Mowing, cutting, herbicide treatments and prescribed fire are not considered to be earth-disturbing activities, and will have no potential to cause effects to heritage resources. In general, mowing and cutting are non-earth-disturbing, and herbicide treatments do not have the resident time of pesticides and would not affect the chemical structure or character of surface or subsurface archaeological materials, and therefore it is not necessary to further address the use of these methods within the current project area, nor any new invasive colonies.
It has been determined that Eastern Woodlands prescribed fire, in the absence of earth-disturbing activities, will not have an adverse effect on heritage resources (Cultural Resource Report No. 09-08-04-119, as amended and SHPO/IHPA Log #023092407). In regard to prescribed fire, a methodology is in place to protect heritage resources from some related earth-disturbing activities (fire line construction) associated with prescribed fire (see project file: Programmatic Agreement Among The Advisory Council on Historic Preservation, the United States Department of Agriculture Forest Service Shawnee National Forest and Midewin National Tallgrass Prairie, and the Illinois State Historic Preservation Officer regarding the Process for Compliance with Section 106 of the National Historic Preservation Act for Undertakings related to Prescribed Fire Programs on the Shawnee National Forest and Midewin National Tallgrass Prairie). However, some activities associated with prescribed fire, such as fire line and mechanical removal of trees and shrubs, may affect heritage resources. The protocol and mitigation measures included the Prescribed Fire Programmatic Agreement were designed to protect heritage resources that might be adversely affected during prescribed fire projects. As noted above, no new fire lines, or other earth-disturbing activities are being proposed as a result of this environmental assessment. In addition, these two invasive species prefer open areas where with a minimum of woody vegetation where the mechanical removal of trees and shrubs will not be necessary and are not being proposed within the current project area, as well any new colonies. Fire Risk and Fuels Effects
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This section describes the current and desired future conditions regarding fire hazard and risk, fuel characteristics, and Fire Regime Condition Class (FRCC), and the expected direct, indirect, and cumulative effects of implementing the proposed action.
Direct and Indirect Effects
Alternative 1
Under this alternative, no new management action would occur. Current and ongoing management would continue, such as intentional flooding at Oakwood Bottoms, mowing annually those populations on managed levees, burning those populations within burn units, and inventorying and mapping known and new infestations. No herbicide would be applied at the proposed treatment locations outside of administrative sites and campgrounds.
Fuels Characteristics: Current populations of Phragmites and RCG would expand, and some new ones would become established. In open areas, this would mean a fuel type conversion to taller, coarser, and denser grass. This is modeled as a change from a fuel model such as GR3 or GR5 to GR7 for RCG and GR9 for Phragmites. In bottomland areas, fuel types may go from open water/marshy areas (unburnable) or bottomland hardwoods to thick stands of Phragmites. In bottomland hardwood stands, it is unlikely there would be significant invasion far from the water’s edge due to shading from the overstory, until floods, fires, timber harvest, windstorms, senescence or other canopy disturbances increase the available light, allowing it to spread laterally into canopy openings. Fire behavior from the resulting changes in vegetation is shown below.
Table 12. Expected Fire Behavior Changes
Predicted Fuel Current Fuel Models Fire Behavior Characteristic Models TL2 GR1 GR3 GR5 GR6 GR7 GR9
Rate of Spread (chains/hour) 1.2 16.1 61.7 74.1 96.6 125.3 220.9
Flame Length (feet) 0.8 0.8 7.5 11.9 14.9 19.0 35.2
Heat per Unit Area (btu/ft2) 144 144 395 909 1131 1494 3232
Reaction Intensity (btu/ft2/min) 678 395 1326 3860 5908 7134 13568
Maximum Spotting Distance (miles) 0.0 0.1 0.2 0.3 0.3 0.4 0.6
Note: Predictions made using the 90th percentile weather observations from 1997-2012 from the Shawnee National Forest Remote Automated Weather Stations.
Conversion to a Phragmites-dominated landscape would mean an astounding increase in fire potential. High rates of spread and long flame lengths frequently are characteristic of large and/or difficult to contain wildfires. These fire behavior variables would both increase dramatically post-conversion. For instance, stands
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of native warm season grass (modeled as GR5) would spread almost 200% faster after conversion to Phragmites (GR9). For short grass such as fescue found along roads and levees (GR1), fires would spread over 1270% faster after infestation with Phragmites. Flame lengths would increase 136-4300%. Reaction intensity is sometimes used as a theoretical proxy for a fire’s impact or severity. This would also increase 130-3330%, suggesting a dramatic increase in the impact to surrounding vegetation and soil as well. This is supported byoutputs from the First Order Fire Effects Modeling (Lutes et al 2013) software program showing 100% mineral soil exposed after a fire in a seasoanlly flooded RCG herbland. It also shows soil heating exceeding 60° C (the temperature of expected plant tissue death) up to 2 cm in depth, indicating lethal heat to shallow- rooted plants.
Risk Determination: It is possiible that the “drying effect” of Phragmites invasion into wetlands may render these areas more likely to burn, i.e. experience more frequent wildfires. However the correlation between drier fuels and increased fire ignition is speculative and difficult to quantify. For the purposes of this report fire occurrence is assumed to remain constant over the analysis period. Values at risk are likewise not expected to change much over the nexy 10 years. Since these items are not expected to change, the only factor affecting fire risk is the fuel hazard. As shown above, this would dramatcially increase with invasion by Phragmites and RCG. The risk would increase slowly at first, since the populations are small and isolated. Even at double their current size, firefighters could easily suppress a fire when it entered adjacent, less volatile fuels, and keep the fire small. As the population continues to expand, however, firefighters’ ability to control the fire would decrease and fire risk would increase at an accelerating (non-linear) rate. This has been evident in the large fires that have occurred north of the Forest in recent years. Explosive fire growth and difficulty of control was attributed to extensive Phragmites patches in in the 160 acre Raleigh Fire (Saline County, 2009), a fire outside of West Frankfort estimated at 200 acres (Franklin County, 2011), and a fire in Lake County estimated at 1000 acres. It is unknown how big populations would be at the end of the analysis period (10 years). It is likely that they would not be as extensive as those in the areas that experienced these larger fires at that point, but it is clear that they would support a dramtic increase in fuel hazard and fire potential in the areas that are infested at that time. Since many of the current and potential infestations are in the area of the highest ignition density on the Forest, the fire risk is likely to increase commensurate with the expansin of the exotic grasses.
Fire Regime Condition Class: Phragmites and RCG invasion into grassland areas would not change the fire regime, since it would remain Fire Regime II, or subject to frequent, high intensity fires. However, fire intensity and severity would increase as described above. Fire size would probably still remain much smaller than historic levels, since there would be large areas of row crops, roads and other constructed firebreaks, and prompt suppression response. The timing of fires would also likely not change. Invasion into former wet areas and bottomland hardwoods would cause a shift in fire regime. Areas formerly Fire Regime III or V would become Fire Regime II, indicating an increase in fire frequency and likely severity. Patch size would likely be smaller than historic levels for the same reasons indicated above.
The resultant changes to vegetation would push the landscape toward having a higher percentage of Condition Class 3, but this is considered a minor increase. Invaded areas can be described as outside the range of historic variation since species never historically known to the landscape are occupying it, and causing a wholesale change in ecosystem functioning. These species would comprise an ever greater proportion of the landscape. Even so, at the end of the analysis period the proportion of the landscape in CC3 would only it would still be a 47 | P a g e
slightly higher (assuming no uninvaded portions degraded to a CC3). Gucker (2008) reports various intrinsic expansion rates of 0.19-0.34, 0.0767 – 0.2312, 18% over 22 years, and 20%. If the invaded area (currently ~80 acres) expanded at 10% per year, it would occupy 207 acres at the end of the analysis period. Even at a 34% expansion rate, the area infested would only be about 1500 acres in 10 years. While this is an increase of over 1400 acres, it is still just over 2% of the 65,000 acre analysis area.
Alternative 2
Under this alternative, the Forest would treat Phragmites and RCG infestations using an integrated combination of prescribed fire and manual, mechanical and/or chemical methods. This includes known infestations and any newly discovered infestations.
Fuel Characteristics: Burning and mowing of these species would temporarily reduce fuel loading, height, and density. Spraying soon after would further reduce the loading, height, and density. However, these patches occupy a small portion of the landscape, and the overall fuel complex would not appreciably change from the baseline. There would be some isolated areas of more volatile fuels as new populations arise. Since they would be treated quickly, they would not have time to form extensive stands.
Risk Determination: Without the fuel complex changes anticipated under Alternative 1, there would be no elevated fuel hazard, and accordingly, no change in risk rating.
Fire Regime Condition Class: Fire Regime Condition Class would improve at the stand level as non-native species are reduced. FRCC across the landscape would not change from the baseline. It would remain largely departed from reference conditions due to lack of disturbance and other factors, but would not slowly degrade as in Alternative 1.
Cumulative Effects
Alternative 1
There would be changes to fuels properties, fire risk, and fire regime condition class under this alternative as noted above. However, the interaction of doing nothing and other activities on the landscape (flooding, farming, etc.) was already accounted for in that discussion. There are by definition no cumulative effects of this alternative.
Alternative 2
Fuel Characteristics: This alternative would have positive impacts to fuels properties as noted above. When combined with prescribed burning, chemical methods are more effective, and should lead to a reduced fuel hazard. Row crop farming, grazing, utility right-of-way maintenance, and openlands management keep much of the landscape at low fuel loadings. These activities also create non-combustible features on the landscape that aid in controlling wildfires. Timber harvest and timber stand improvement elevate fuel loading temporarily, but as slash is treated, and later, as downed wood decomposes, fuel load and continuity are both reduced. Invasive species treatment, prescribed fire, and wildfires all may decrease or increase fuel loads at times. Spraying halts plant growth but converts it to a dead (more flammable) state. Some species may also be
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replaced with vegetation that has greater or lesser burning characteristics. Prescribed and wildfires initially reduce fuel loads in all size classes and create areas of discontinuity, which aid in suppressing fires, but also can increase fuel load in some size classes by top-killing vegetation (e.g. creating new snags), that eventually fall to the forest floor to become fuel for the next fire. This may also provide conditions for establishment of some species that may inhibit fire growth (e.g. aster, goldenrod, etc.) or exacerbate it (e.g. oriental bittersweet).
Risk Determination: Under this alternative, the fuel hazard would not be elevated. Residential development and recreation may increase an area’s use, and thereby increase the ignition potential, but this is speculative and it is not expected to be a large change if there is one. Given the expected decrease in size of Phragmites and RCG populations, and that new populations would be kept small and/or controlled quickly, there would be no change in risk rating from the present.
Fire Regime Condition Class: Many activities such as agriculture and residential development maintain or increase the amount of the landscape outside the range of natural or historic variability. However, the rate of this change is generally low in the analysis area, and is thought to be negligible in the 10 year analysis period. Timber harvest can improve FRCC, or it can accelerate the degradation into Condition Class 2 or 3 depending on the species and size classes involved in the harvest. Invasive species control, timber stand improvement, and prescribed burning both tend to maintain or improve FRCC. Combined with this project’s actions, FRCC is expected to improve over the analysis area in the next 10 years. This improvement is expected to be very slight given the limited extent of the project’s actions.
Disclosures
Agencies Consulted
Illinois Department of Natural Resources Illinois Invasive Plant Species Council
Illinois Nature Preserves Commission River-to-River Cooperative Weed Management Area
Clean Water Act – Activities identified in the alternatives comply with Section 319 of the Federal Clean Water Act. The Illinois Non-point Source Management Program, which recommends using Illinois Department of Natural Resources Best Management Practices, was developed to comply with Section 319 of the Federal Clean Water Act (IDNR et al. 2007 [revision]). These practices, as well as Forest Plan Standards and Guidelines and soil suitability and limitations, as determined by the Natural Resources Conservation Service, will be used to guide the action alternatives.
Migratory Bird Treaty Act – This proposal complies with the Migratory Bird Treaty Act and Executive Order 13186. See the Wildlife working paper for details.
National Historic Preservation Act – Following consultation, the State Historic Preservation Office has concurred with our determination of no-effect on heritage resources from implementation of our invasive species management proposal.
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Floodplains – Site productivity and riparian function would be maintained in the project area with the proposed action; therefore, also on the floodplains in the project area. Site productivity and riparian function would be negatively affected by Alternative 1.
Wetlands – Alternative 1 would have an adverse effect on the site productivity or function of the sites near the project area identified as having one or more wetland characteristics. The proposed action would have a positive effect.
Irreversible or Irretrievable Commitment of Resources – None of the project alternatives would have an irreversible or irretrievable commitment in the project area or adjacent analysis area if design criteria and Forest Plan protections are adhered to. We anticipate no irreversible effects on soil and water resources from any alternative. Soil erosion above natural rates is an irretrievable effect.
Forest Plan – All actions proposed under any alternative are consistent with the Forest Plan.
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Finding of No Significant Impact I, the responsible official, have evaluated the environmental effects of the project disclosed in the EA relative to the definition of significance established by Council on Environmental Quality (CEQ) regulations. I have reviewed and considered the EA and documentation in the project record and have determined that implementation of the proposed action as described under Alternative 2 will not have a significant effect on the human environment. Accordingly, an environmental impact statement will not be prepared. My rationale for this finding follows. It is organized by sub-sections of the CEQ definition of significance at 40 CFR 1508.27.
Context As defined at 40 CFR 1508.27(a), the context of the proposed action is the Forest, specifically, the management of known sites of Phragmites (15 acres at 23 locations), known sites of RCG (about 67 acres at 30 locations) and any newly discovered Phragmites and RCG infestations.
Implementation of the proposed action would achieve multiple-resource benefits and make progress towards Desired Future Conditions described in the 2006 Forest Plan. It includes activities that work towards meeting Forest Plan goals and objectives for minimizing adverse effects from invasive plant species on Forest resources. The proposed project involves limited, focused actions in discrete areas of the Forest that would have no significant short- or long-term, direct or indirect effects, and cumulative effects indiscernible from the Forest- related and private activities occurring in the HUC6 watersheds of the Forest.
Intensity Intensity is a measure of the severity, extent, or quantity of effects as disclosed in the EA and the project record. I have determined that the project interdisciplinary team considered the effects of this proposed project appropriately and thoroughly with an analysis responsive to concerns and issues raised by the public. They took a hard look at the environmental effects using relevant scientific information and their knowledge of site-specific conditions gained from field visits and monitoring. My finding of no significant impact is based on the intensity of effects using the ten factors identified in 40 CFR 1508.27(b):
1. Impacts that may be both beneficial and adverse. A significant effect may exist even if on balance the effect will be beneficial – § 1508.27(b)(1).
My finding of no significant environmental effects reflects consideration of both the adverse and beneficial effects of implementing the action: The design criteria incorporated into this project were explicitly created to avoid significant direct, indirect and cumulative adverse effects on non-target wildlife and plant species, as well as people, while at the same time ensuring the benefits of implementation. Indeed, the interdisciplinary team found that implementation of the proposal would result in no significant direct, indirect, or cumulative effects on the environment. These effects are documented in the EA at pages 21-49.
2. The degree to which the proposed action affects public health or safety – § 1508.27(b)(2).
My finding of no significant environmental effects is based on the analysis of the proposal in the EA. The potential effects of the proposed action on human health were among the key issues identified by the interdisciplinary team, and the team took a hard look at possible effects on people. In their analysis, they examined multiple factors in the determination of risk from the use of the proposed herbicide: the hazard quotient, or HQ, as an indicator of public health and safety, possible human endocrine system disruption, cancer risk and exposure scenarios.. They determined there would be an extremely minimal possibility of adverse impacts on human health or safety from implementation of the project in compliance with the project design criteria (pages 14-17 and Tables 3 and 4). Understanding the design criteria, we simply cannot foresee a scenario in which a visitor would 51 | P a g e
accidentally be exposed to freshly applied herbicide. With human exposure prevented, I find no threat to health or safety.
3. Unique characteristics of the geographic area such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas – § 1508.27(b)(3).
My finding takes into account all the unique characteristics of the Forest, with particular attention to wetland and riparian habitats. One of the main purposes of the proposed action is to protect the unique ecological characteristics of wetland and riparian environments from the damaging effects of invasive Phragmites and RCG by utilizing manual, mechanical and herbicide tools, an approach endorsed by the IDNR and the Illinois Nature Preserves Commission. Based on the analysis documented in the EA, I find that the selected alternative—the proposed action—will accomplish the intended purpose of managing or controlling Phragmites and RCG to the benefit of wetland and riparian areas and the health and biodiversity of our ecological communities. Additionally, as was determined in the EA, the activities we plan to implement in accordance with the project design criteria will have no significant adverse effect on our candidate wild and scenic rivers, wetlands, wildernesses, or heritage resources.
4. The degree to which the effects on the quality of the human environment are likely to be highly controversial – § 1508.27(b)(4).
Based on public participation, the involvement of resource specialists, and the counsel of the IDNR and the Illinois Nature Preserves Commission, I believe effects on the quality of the human environment are not likely to be highly controversial. This does not mean that the decision to proceed with the project will be acceptable to all, as some will probably find that their needs and interests are not served by the selected alternative. However, the comments they expressed during scoping and comment periods, which were considered in the EA, did not disclose any significant adverse effects that would result from the project on the quality of the human environment. Thus, it is my professional judgment that physical, biological, social and economic issues have been addressed well enough for me to make an informed decision. The proposed actions are similar to management activities currently being implemented on state lands; therefore, the results are reasonably predictable.
I interpret the controversy criterion in a FONSI to be the degree to which there is scientific controversy relative to the results of the effects analysis, not whether one favors or opposes a specific alternative. Based upon the previous implementation of similar projects by the state, non-governmental organizations and others in our area, the effects of the selected alternative on the quality of the human environment would not be considered as highly controversial. While there are different views about the proposed management action, the activities included in the proposal would be consistent with Forest Plan direction and best available science. Therefore, I have determined that the effects as displayed in the EA and supporting documentation in the project file are not likely to be highly controversial.
5. The degree to which the possible effects on the human environment are highly uncertain or involve unique or unknown risks – § 1508.27(b)(5).
Based on the discussions and conclusions of the analysis in the EA, including the contributions of commenters, I conclude that there is no uncertainty or unique or unknown risks associated with this proposal. The proposed treatment methods, including the use of herbicides, are commonly and successfully employed in southern Illinois and across the country, including by the IDNR, the Illinois Nature Preserves Commission and The Nature Conservancy. The proposed herbicide is of low toxicity 52 | P a g e
and persistence and would be applied in discrete locations at a very limited scale; any risk associated with its use would be minimal. Implementation of the selected alternative in accordance with the project design criteria minimizes the already low risk involved with the proposed activities and will have no significant adverse effect on the environment (pages 19-49).
6. The degree to which the action may establish a precedent for future actions with significant effects or represents a decision in principle about a future consideration – § 1508.27(b)(6).
The proposed action focuses on the use of common mechanical and herbicide treatments on discrete areas of the Forest. The proposed project would advance Desired Future Conditions described in the Forest Plan. The size and scope of the proposed project are typical of projects on the Forest to implement the Plan. Simply because the project involves the use of herbicides to control invasive species in no way means it sets a precedent for future projects with significant effects. Any additional future actions regarding the treatment of other invasive plant species would be appropriately analyzed under the NEPA. My decision to implement this proposal is limited to this action and unrelated to future considerations (pages 11-14, 19-44).
7. Whether the action is related to other actions with individually insignificant but cumulatively significant impacts. Significance exists if it is reasonable to anticipate a cumulatively significant impact on the environment. Significance cannot be avoided by terming an action temporary or by breaking it down into small component parts – § 1508.27(b)(7).
My finding of no significant impact from implementation of the selected alternative includes consideration of its cumulative impacts in relationship to other activities, whether conducted by the Forest Service or others. All known actions associated with the selected alternative that are likely to occur in the reasonably foreseeable future have been identified and the direct, indirect and cumulative effects disclosed in the EA (pages 19-44). Compliance with the project design criteria will ensure that any direct and indirect effects from implementing this proposal will be minimal. The minor, incremental effects this project would add to the effects of past, present and future actions are, therefore, minimal and limited in duration.
Our description of the minimal cumulative effects expected from this action is supported by an analysis grounded in the best scientific and field data available. It is not likely that an unexpected cumulative effect could present a risk of a significant adverse impact. However, with monitoring incorporated as an integral part of the project, I am confident that we would detect any unexpected effect and prevent its development into a significantly adverse cumulative effect.
The herbicide treatments authorized by this decision are similar to, or involve less herbicide than, projects already being successfully implemented by other governmental and private entities in southern Illinois and surrounding areas. I am unaware of any scientific information, field data, or other evidence that indicates the effects of this project would differ from, or be more adverse than, those encountered during implementation of these similar projects. When compared to the use of glyphosate in the high-intensity agriculture surrounding and within the Forest, in the HUC4 and HUC6 watersheds, the amount of herbicide we propose to use is insignificant and the cumulative effects indiscernible even when combined with herbicide amounts planned to be used on the Forest under the NNIS EA (pages 31,32 and table 9).
8. The degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places or may cause loss or destruction of significant scientific, cultural, or historical resources – § 1508.27(b)(8).
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Implementation of the action as proposed will have no adverse effect on districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places because:
1) Areas to which we will apply prescribed fire are inventoried according to a programmatic agreement among the Forest, the Illinois State Historic Preservation Officer and the Advisory Council on Historic Preservation;
2)All activities proposed under the Action Alterniative are considered non-earth–disturbing activities and will have no effect on heritage resources (pages 43-45).
9. The degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973 – § 1508.27(b)(9).
The protection of threatened, endangered and sensitive species was a major consideration during our environmental analysis of the proposed action. My finding of no significant impact relies on the conclusion of the EA and the concurrence of the US Fish and Wildlife Service that implementation of the proposal will be protective (pages 32-40). On December 5, 2014 the U.S. Fish and Wildlife Service concurred with our biological evaluation of the proposal that concluded: Implementation “may affect but (is) not likely to adversely affect” Indiana bat, northern long-eared bat, gray bat, least tern, fat pocketbook, pink mucket, orange-footed pearlymussel, sheepnose, spectaclecase, rabbitsfoot, and pallid sturgeon and would have no effect on mead’s milkweed (pages 34-36, table 11 and BE in the Project Record).
10. Whether the action threatens a violation of federal, state, or local law or requirements imposed for the protection of the environment – § 1508.27(b)(10).
Implementation of the selected alternative will result in no action that would violate federal, state, or local laws or requirements for the protection of the environment. We considered applicable laws and regulations in the EA (EA pages 49,50) and confirmed that the proposed action is consistent with the Forest Plan (page 8, 50).
The effects analysis in the EA (pages 19-44) considered both the context and intensity of the action in determining its significance as outlined in 40 CFR 1508.27. Based upon the analysis, I have determined that the selected alternative—the proposed action—will not significantly affect the human environment. Consequently, an environmental impact statement will not be prepared.
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