Monongahela National Forest NNIS Plant Treatment RONI Review of New Information For Proposed New NNIS Plant Treatment Sites and Modifications of Treatments at Existing Sites under the Forest-wide Nonnative Invasive Plant Management Project EA Introduction In addition to identifying a set of site-specific treatments, the Forest-wide Nonnative Invasive Plant Management Project Environmental Assessment (“NNIS EA”) established protocols for treating a variety of invasive plant species in typical situations. The EA anticipated that new sites would be identified on an ongoing basis, and it established a process for approving treatment of those new sites without preparing a new or updated NEPA document. The decision to implement the EA treatments, protocols, and new site incorporation was approved by Forest Supervisor Clyde Thompson on March 12, 2010 in the Decision Notice and Finding of No Significant Impact for this project. Following is the text outlining the process for adding sites (from the "Future Treatment Activities" section of the EA, bottom of page 2-6): “Although the proposed action identifies many specific sites across the Forest for treatment, it is likely that more high-priority treatment sites will be discovered. Therefore, the proposed action provides for the treatment of these additional sites after a review of the condition of any resources that may be affected. At a minimum, this review would involve wildlife, aquatics, botany, TES species, silviculture, recreation, and cultural resources. Treatment activities must involve situations similar to those programmatic and site-specific situations already analyzed, and any resource effects must be within the scale and scope of effects already analyzed. Line officer review and approval would be required prior to treatment. New herbicides and treatment methods would not be used without appropriate additional NEPA analysis and documentation.” Although the EA was clear in specifying the process for adding new sites, some confusion has arisen over the procedure for modifying treatments at existing sites. At issue is whether interdisciplinary team review is needed prior to treating additional target species or using different herbicides within the boundaries of existing treatment sites. The purposes of this review are 1) to address the modification of treatments at existing sites, and 2) to review proposed new sites and determine whether treating these sites would be within the scale and scope of effects already analyzed. New Information Modification of Treatments at Existing Sites Although the NNIS EA proposed treating specific NNIS species at specific sites, the effects analysis did not identify site-specific effects based on the type of herbicide to be used or the species to be controlled at specific sites. Rather, it evaluated effects more broadly in terms of what might be expected to occur wherever particular herbicides are used. Individual herbicides 1 Monongahela National Forest NNIS Plant Treatment RONI were evaluated programmatically through the use of standard risk assessments. When a risk assessment identified a concern regarding the use of a specific herbicide, the concern was addressed through design criteria, mitigation measures, and monitoring, which are to be applied at any site where the concern could exist. Thus the effects analysis was not predicated on the use of specific herbicides or the control of specific species at specific sites. Therefore, at all of the sites included in the EA, the use of any herbicide covered by the EA to control any species covered by the EA is within the scope of the existing analysis and does not require any additional review or documentation. The species that may be controlled and the herbicides that may be used are listed in Table 2.1 of the EA (beginning on p. 2-7). A copy of the table is attached to this letter for reference (Attachment A). Although the EA analysis provides broad flexibility for applying control measures as needed at the existing sites, the following caveats must be observed: 1. All design criteria, mitigation measures, and monitoring requirements must be followed. These are listed in Chapter 2 of the EA on pages 2-15 through 2-20. 2. Only herbicides that were covered by the EA may be used. The following herbicides were covered: Glyphosate Imazapyr Fosamine ammonium Triclopyr Sethoxydim Clopyralid Imazapic Metsulfuron methyl Picloram 3. Only the treatment methods that were covered by the EA may be used. The following treatment methods were covered: Broadcast foliar application of herbicide (ground-based only; no aerial application) Spot foliar application of herbicide Cut surface application of herbicide Basal spray application of herbicide Hand pulling Mowing Grubbing using hand tools Biological control using agents that have passed standard USDA screening Prescribed fire in fire-adapted and highly altered ecosystems 4. Fosamine ammonium was analyzed only for roadside applications using vehicle-mounted equipment. Other application methods may present hazards to the herbicide applicator that were not addressed by the analysis, so any other applications of this herbicide would require additional review to determine whether the effects of the proposed application are within the scope of the existing analysis. 5. The effects analysis for threatened, endangered, and sensitive plants identified broadcast foliar application of herbicide as the primary concern for possible adverse effects, and the effect determinations for TES plants were predicated on the site-specific amounts and locations of broadcast application. Therefore, any proposed expansion of broadcast 2 Monongahela National Forest NNIS Plant Treatment RONI application within existing site boundaries should be reviewed to determine whether effects are within the scope of the existing analysis. 6. Any new sites or expansion of existing sites requires review to determine whether effects are within the scope of the existing analysis. Below are some modifications to existing sites that have been proposed. Although they do not require additional analysis and documentation, they are summarized here to give examples of the types of modifications that may occur as the need arises: Control tree of heaven near Blue Rock Geological Area on the Cheat-Potomac District – This site was included in the NNIS EA for treatment of Japanese stiltgrass and viper’s bugloss, but tree of heaven was overlooked. Controlling tree of heaven would involve cut surface, basal spray, and possibly spot foliar spray of triclopyr, glyphosate, or metsulfuron methyl. Control non-native thistles at the Big Bend limestone barren site – This area was covered under the NNIS EA for control of viper’s bugloss and spotted knapweed, but has since been discovered to contain non-native thistles. Control would involve spot foliar spray of triclopyr, glyphosate, clopyralid, or metsulfuron methyl. Control tree of heaven along FR 153 (Five Lick) and associated spurs and openings – This site was included in the NNIS EA for treatment of reed canary grass, but tree of heaven was overlooked. Controlling tree of heaven would involve cut surface, basal spray, and possibly spot foliar spray of triclopyr, glyphosate, or metsulfuron methyl. Control garlic mustard along FR 75 (Dolly Sods Scenic Area) – This site was included in the NNIS EA for control of reed canary grass and one small patch of garlic mustard. Garlic mustard has since been discovered in other areas along the road, but within the area previously analyzed for reed canary grass. Control would involve spot foliar application of glyphosate or triclopyr. Proposed New Sites Infestations of high priority NNIS are being discovered on the Forest periodically, as predicted in the EA. Table 1 contains a subset of sites that likely can be reviewed without additional field work because: 1) they are located in areas that have been reviewed for other projects, 2) they are located in highly disturbed areas that are not likely to present concerns related to resource impacts, or 3) they use precisely targeted treatment methods that are not likely to result in exposure of non-target organisms. These sites are scheduled for treatment beginning in spring or summer 2011, pending available funding and staffing. Maps depicting the sites are included in Attachment B. 3 Monongahela National Forest NNIS Plant Treatment RONI Table 1. Additional Sites Proposed for NNIS Control under the Programmatic Component of the Monongahela Forest-wide Nonnative Invasive Plant Management Project (Sites not needing additional field botany surveys – office review during winter 2011 for treatment beginning spring/summer 2011) Primary Target Estimated Priority Site/Project District Description of Proposed Control1 Species1 Acreage Points2 Big Springs Gap Cheat- Fig buttercup 0.15 A dense but relatively small infestation trailhead (Otter Potomac of this species occurs along the trail Creek) (adjacent down to Otter Creek. Need to limit to Fernow) further spread into the Wilderness and to abate threats to nearby running 6 buffalo clover. Use hand-pulling by volunteers to circumvent issues with using herbicide in the Wilderness and to avoid the need for a botany survey. FR 229 and Cheat- Japanese stiltgrass 42 The NNIS EA covered this area for associated spurs, Potomac reed canary grass, but it has since been openings, etc. discovered to contain large infestations of stiltgrass that extend beyond the site boundary that was analyzed initially. Control is needed to abate threats to 4 nearby