lee mine hardwood restoration and habitat enhancement...

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June 2016

Lee Mine Hardwood Restoration

and Habitat Enhancement

Environmental Assessment

Shawnee National Forest

Responsible Official: Tim Pohlman, District Ranger

Contact Person: Leonard Pitcher Shawnee National Forest

602 N. First Street, Vienna, IL 62995 (618) 658-2111, Fax (618) 658-1300, [email protected]

This document and supporting documents can be found on the Forest website (www.fs.usda.gov/project/?project=45123).

United States Department

of Agriculture

Forest Service

http://website/

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USDA NONDISCRIMINATION STATEMENT

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and

policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA

programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity

(including gender expression), sexual orientation, disability, age, marital status, family/parental status, income

derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in

any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and

complaint filing deadlines vary by program or incident.

Persons with disabilities who require alternative means of communication for program information (e.g., Braille,

large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET

Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339.

Additionally, program information may be made available in languages other than English.

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-

3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or write a

letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy

of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) Mail: U.S.

Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue SW,

Washington, D.C. 20250-9410; (2) Fax: (202) 690-7442; or (3) Email: [email protected].

USDA is an equal opportunity provider, employer, and lender.

mailto:[email protected]

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Table of Contents

Introduction…………………………………………………………………………………………………………………………………… 5

Chapter 1 –Need for the Proposed Action…….…………………………………………………………………………........ 6

o Background………………………………………………………………………………………………………………………………. 6

o Need for Action…………………………………………………………................................................................. 8

o Proposed Action……………………………………………………………………………………………………………………..… 8

o Decision Framework…………………………………………………………………………………………………………………. 8

o Public and Agency Involvement………………………………………………………………………………………………… 9

o Issues……………………………………………………………………………………………………………………………………….. 10

Chapter 2 – Alternatives…………………………………………………………………………………………………………………. 11

o Alternative 1 – No Action………………………………………………………………….......................................... 11

o Alternative 2 – Proposed Action…………………………………………………………........................................ 11

o Alternative 3 – Cut and Leave on the Ground…………………………………………………………………………… 12

o Comparison of Alternatives.......................................................................................................... 198

o Alternatives Eliminated from Detailed Study……………………………………………................................. 198

Chapter 3 – Affected Environment and Environmental Consequences………………………………………........ 2019

o Human Health and Safety………………………………………………………………………………………………………… 221

o Watershed Resources ……………………………………………………………………………………………………………… 27

o Wildlife Resources …………………………………………………………………………………………………………………… 332

o Botanical Resources ………………………………………………………………………………………………………………… 39

o Forest Vegetation…………………………………………………………………………………………………………………….. 410

o Heritage Resources ………………………………………………………………………………………………………………….. 45

o Recreation Resources……………………………………………………………………………………………………………….. 46

o Agencies and Persons Consulted………………………………………………………………………………………………. 48

Finding of No Significant Impact……………………………………………………………………………………………………….. 49

References……………………………………………………………………………………………………………………………………….. 52

APPENDIX: Response to Comments………………………………………………………………………………………………….. 54

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Tables

Table 1. Design Criteria for Lee Mine Hardwood Restoration and Habitat Enhancement……………………….. 13

Table 2. Design Criteria for Human Health and Safety……………………………………………………………………………. 176

Table 3. Monitoring of Action Alternatives……………………………………………………………………………………………… 187

Table 4. Comparison of the Effects of the Alternatives on the Key Issues……………………………………………….. 198

Table 5. Spatial and Temporal Boundaries for the Analysis of Each Resource Area…………………………………. 210

Table 6. Human-Health Risk-Characterizations for Proposed Herbicides………………………………………………… 24

Table 7. Regional Forester Sensitive Species and Species with Viability Evaluation………………………………… 357

Table 8. Outstandingly Remarkable Values of Big Creek…………………………………………………………………………. 479

Figures

Figure 1. Lee Mine project area…………………………………………………………………………………………………………….. 7

Figure 2. Oak seedlings typical in the understory..………………………………………………………………………………… 9

Figure 3. Oak saplings typical in the understory..………………………………………………………………………………….. 9

Figure 4. Relatively dense pines and the understory hardwoods that would benefit from increased sunlight from removal of the pines…………………………………………………………………………………………

9

Figure 5. Pine stand at One-Horse Gap after removal of overstory pines, showing developing hardwood understory……………………………………………………………………………………………………………..

9

Figure 6. Lee Mine streams and wetlands……………………………………………………………………………………………… 298

Figure 6. View of new shelterwood harvest area………………………………………………………………………………….. 4336

Figure 7. View of shelterwood harvest area following three seasons….………………………………………………… 4334

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Introduction The USDA Forest Service is proposing to implement management activities in the Lee Mine area of the Shawnee

National Forest (Forest) to restore and maintain the health and habitat diversity of the site by restoring the native-

hardwood oak-hickory forest-type through removal of non-native pines, application of prescribed fire, timber-stand

improvement, development of up to 18 vernal ponds, installation of erosion-control structures, and protection of rare

species. The 1400-acre proposed project area is located on National Forest System (NFS) land in Hardin County, Illinois,

Township 11 South, Range 8 East.

This project is designed to advance the site towards the desired future condition of the Even-Aged Hardwood and

Natural Area management areas described in the 2006 Shawnee National Forest Land and Resource Management Plan

(Plan) (pages 59-61 and 76-78) (USDA FS 2006). The proposed activities work towards meeting Forest Plan goals and

objectives for converting pine stands to hardwood.

We have prepared this environmental assessment in compliance with the National Environmental Policy Act and other

applicable federal and state laws and regulations. The analysis described herein is a summary of the data, methodology,

analysis and findings set forth in the record. We intend for this assessment to be an analytical, science-based document

that focuses on the issues identified during scoping as being most relevant to disclosure of environmental effects [40

CFR 1500.1(b); 1500.4(b), (c)]. We disclose the direct, indirect and cumulative environmental effects that might result

from implementation of the proposed action and alternatives.

Additional documentation, including the resource specialists’ working papers, is filed in the project record located at the

Hidden Springs-Mississippi Bluffs District Office, 602 N. First Street, Vienna, Illinois, and is available on the Forest website

(http://www.fs.usda.gov/project/?project=45123).

This document is organized into three chapters:

Chapter One. Need for the Proposed Action: Includes information on why the project is needed and our proposal for

meeting that need. It details public involvement and identifies key issues addressed in the environmental assessment.

Chapter Two. Description of Alternatives, including the Proposed Action: Provides a description of the proposed action

as well as alternatives developed to address public issues and includes a table summarizing the environmental

consequences associated with each alternative.

Chapter Three. Affected Environment and Environmental Consequences: Describes the environmental effects of

implementing the proposed action and alternatives by resource area, disclosing the direct, indirect and cumulative

effects. The affected environment sections describe the existing condition of the resource as it relates to the effects

analysis.

http://www.fs.usda.gov/project/?project=45123

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Chapter 1 – Need for the Proposed Action

Background

One of the principal goals of the Forest Plan is the restoration and/or maintenance of the native-hardwood oak-hickory

forest-type:

Forest resources will be managed…in a manner that addresses the complex issue of biological diversity (page

19)…Maintaining the oak-hickory forest-type…is important for biological diversity and wildlife habitat. The

Forest will utilize various vegetation-management activities, such as landscape-level prescribed burning, timber

harvesting and timber-stand improvement to help create and/or maintain the ecological conditions necessary to

regenerate and maintain the oak-hickory forest-type. Forest-wide diversity of vegetation-types is ensured by

application of the (Plan) management prescriptions.

This goal emphasizes the maintenance of a healthy and sustainable hardwood-forest ecosystem that includes

the production of some timber products as a by-product of vegetation-management activities. This would utilize

a renewable forest resource and support the growing need for wood products in an environmentally sound

manner that is compatible with other uses (pages 21-22).

The proposed 1400-acre Lee Mine project area (Figure 1) is situated in the Big Creek watershed in the eastern portion of

the Forest, a relatively small site (less than half of one percent of the Forest) with non-native pine stands interspersed

with hardwood stands. Big Creek, protected as a zoological natural area under the Forest Plan, flows through the project

area. The 572 acres of pine stands were planted during the 1940’s and 1950’s to stabilize the soil. The pines have

accomplished this task and the mature trees now often form a dense canopy above the forest floor, where oak, hickory

and other hardwood seedlings struggle for sunlight.

If the majority of these trees were removed through a commercial harvest, more sunlight would be able to reach the

forest floor. Sufficient hardwoods are present in the understory to ensure restoration of the native-hardwood oak-

hickory forest-type in the area. It is clear that a past commercial harvest stimulated hardwood regeneration. Further

removal of some of the pine canopy at this time would stimulate the growth of the existing hardwoods and other sun-

loving species. Without removal, the stand will eventually be dominated by shade-tolerant species, limiting native plant

and animal community diversity and resilience and having a generally poor ecological condition (Plan, page 12; Plan FEIS,

pages 124-131, Silvicultural Working Paper).

Other issues require attention to maintain quality habitat in the area: Big Creek is being adversely affected by erosion

and runoff: intervention is needed to prevent sediment-loading to the creek. The Elizabethtown spur of the River-to-

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River Trail passes through the area: it would benefit from maintenance and erosion control. There is also the

opportunity to provide early-life–cycle habitat for amphibians with the development of vernal ponds.

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Figure 1. Lee Mine project area.

Need for Action

The proposed action is needed to improve conditions for the restoration of the native-hardwood oak-hickory forest

community in the project area. Reducing the pine overstory would move the area toward the desired future condition

described in the Forest Plan (page 59). Implementation of the proposal would improve native ecological composition,

function and structure. The best available science indicates that the adverse effect of these pine stands on the

development of the native-hardwood oak-hickory community is likely to persist for many more decades (See Silvicultural

Working Paper, Project Record). The project, with the erosion-control measures to protect Big Creek, the work on the

River-to-River Trail and the protection of rare plants, would support wildlife community diversity by increasing hard

mast, improving conditions for aquatic species and providing escape-cover, forage and micro-site conditions (moisture,

light, cover) that favor native plant and wildlife-population development.

Proposed Action

The Forest Service proposes to enhance wildlife habitat in the project area by restoring the native hardwood oak-hickory

forest-type in current pine stands, applying prescribed fire to about 1400 acres in and around the area, installing erosion-

control features for the protection of Big Creek, establishing up to 18 vernal ponds, applying herbicides as required to

protect rare plants from invasives, reconstructing up to five miles of existing roads and realigning about one and a half

miles of interior roads to protect rare plants, and improving conditions on the River-to-River Trail spur that crosses the

area. We would utilize site-preparation treatments and a commercial sale to reduce the pines on the site to 30-40 square

feet basal area (BA) per acre. While establishing high-quality early-successional habitat, this would provide the light and

growing space required to restore the native-hardwood oak-hickory forest community to the area (Figures 4 and 5). To

facilitate natural regeneration, small shade-tolerant trees (less than 10-inch diameter at breast height [dbh]) in the

understory would be cut to further increase the amount of sunlight reaching seedlings and saplings on the forest floor. See

Alternative 2—the Proposed Action, below—for a detailed description.

Decision Framework

Given the need for the proposal, the responsible official will review the analysis of the proposed action and the

alternatives in order to decide whether or not to:

Employ a commercial sale to remove the pine overstory to release shade-intolerant oak, hickory and other

hardwoods;

Utilize site-preparation tools to restore the native-hardwood oak-hickory forest community;

Apply prescribed fire to about 1033 acres not already approved for burning under NEPA;

Establish up to 18 vernal ponds in the area;

Construct erosion-control structures for the protection of Big Creek Zoological Natural Area;

Apply herbicides to prevent invasives intrusion on rare plants;

Adjust alignment of interior roads to prevent damage to rare plants and habitat;

Improve the River-to-River Trail spur in the area.

Figure 1. Lee Mine Project Area

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Public and Agency Involvement

The proposal and request for public comment was published in the Southern Illinoisan August 14, 2014; a scoping notice

was sent to all known interested parties, state agencies and non-governmental organizations requesting comments, the

scoping letter was posted on the Forest website. After review the scoping comments, the interdisciplinary team developed

a list of issues to address in this environmental assessment.

Figure 2. Oak seedlings typical in the understory. Figure 3. Oak saplings typical in the understory.

Figure 4. Relatively dense pines and understory

hardwoods that would benefit from increased

sunlight from removal of the pines.

Figure 5. Pine stand at One-Horse Gap after

removal of overstory pines, showing the

developing hardwood understory.

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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 identified

the key issues. 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.

Key Issues and Indicators:

Harvest of the pine will have undesirable effects on wildlife populations, including threatened and endangered species and migratory birds. Indicators for monitoring these effects are:

Changes in species diversity and abundance over time and

Numbers and size of snags.

Harvest of the pine overstory will increase the density of non-desirable understory plants (native and non-native) that will compete with the hardwood seedlings and saplings. The indicator for monitoring these effects is:

Changes in the numbers and frequency of native and non-native plant species, including shortleaf pine.

Soil erosion and compaction resulting from harvest activities and road re-alignments will have an adverse effect on soil productivity and water quality. Indicators for monitoring these effects are:

The amount of soil displaced (tons/acre/year)

Sediment load in the watershed (Project area %)

Bare ground (%)

The application of herbicides may affect humans. Indicators for monitoring these effects are:

Human health indicator: We will discuss the response of humans in terms of the effects that the herbicides could have on public health and employees/applicators.

The application of herbicides may affect a designated natural area, soil, water, plants and wildlife.

Soil and water quality indicator: We will discuss the potential persistence of the proposed herbicides in the

environment.

Plant indicator: We will discuss the response of rare plants to the protection against invasives provided by

herbicide application.

Wildlife indicator: We will discuss the effects of the proposed herbicides on wildlife.

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Chapter 2 – Alternatives

This chapter includes a description of each alternative and compares the alternatives that were considered. It provides

alternatives based on the issues brought forward in the public comments.

Alternative 1 – No Action

Under this alternative, current management would continue in the project area. None of the proposed management

activities would be implemented.

Alternative 2 – Proposed Action

The Forest Service proposes to enhance wildlife habitat in the project area by restoring the native hardwood oak-hickory

forest-type in current pine stands, applying prescribed fire to the area, installing erosion-control features for the

protection of Big Creek, establishing up to 18 vernal ponds, and improving conditions on the River-to-River Trail spur that

crosses the area. We would utilize site-preparation treatments and a commercial sale to reduce the pines on the site to

30-40 square feet BA per acre. While establishing high-quality early-successional habitat, this will provide the light and

growing space required to restore the native-hardwood oak-hickory forest community to the area (Figures 5, 8 and 9).

Commercial Timber Harvest: We propose to utilize a commercial sale to reduce the pine density on about 572 acres of

the project area, using the shelterwood method (Figure 5). We would designate the pine trees to be removed, leaving

about 30 to 40 square feet BA of pine per acre. Tree-spacing after harvest would be up to 50 feet between mature pine

trees. The design of the harvest will incorporate the USDA Forest Service National Best Management Practices (BMP) for

Water Quality Management on NFS Lands and the Illinois Department of Natural Resources Forestry BMP, as well as

Forest Plan filter-strip guidelines, snag-retention strategies and other measures for the conservation of biological

diversity (Plan, pages 40-41, 201-202 and 288-289). The appearance of harvested areas will change with treatment,

allowing much more sunlight to the forest floor.

Skid-trails and log-landings would be located to limit ground-disturbance. Logs would be loaded onto trucks at log-

landings and hauled off-site. System roads would be constructed, realigned, or maintained and used to remove trees

from the project area. All landings would be located along the system road within the stand. Within three years

following harvest, we would perform site-preparation activities to enhance the development and growth of hardwoods,

including cutting small (less than 10-inch dbh), undesirable, shade-tolerant, woody species to further increase sunlight to

desirable trees and leaving larger native trees to maintain diversity. Mechanical shears or chainsaws may be used to

remove trees.

Prescribed Fire: Prescribed fire would be applied to the area as often as every two years, including 1033 acres not already

approved for burning under another decision. This will release existing shade-intolerant tree species and provide site

conditions favorable for future regeneration. Fire-lines would be constructed manually or mechanically, generally

following past fire-control lines or using existing man-made or natural boundaries where practical.

Vernal Ponds: We would construct up to 18 vernal ponds to provide a seasonal water source for amphibians, bats and

other wildlife species and repair the failed impoundments of six existing vernal ponds.

Roads: We would upgrade or realign roads where necessary to facilitate removal of cut pines and/or to protect rare

plant species.

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Erosion Control: Erosion-control work would be done on system roads and the River-to-River Trail, including the

installation of water bars and water turnouts, ditch cleaning, stabilizing the road or trail surface with rock or other

methods. We would construct a rock check-dam to capture sediment running off private land in the headwaters of Big

Creek.

Herbicides: The herbicides sethoxydim and/or clethodim would be applied as needed to protect sensitive plant species

from the adverse effects of invasive plant infestations.

Alternative 3 – Cut and Leave on the Ground

Under this alternative, we would treat the same trees as under Alternative 2; but, rather than removing felled trees from

the site, we would leave them on the ground. We would designate the pine trees to be felled, leaving about 30 to 40 BA

of pine per acre. Tree-spacing after felling would be up to 50 feet between mature pine trees. Implementation of this

alternative would be in accordance with State of Illinois Forestry Best Management Practices and USDA Forest Service

(FS) National Best Management Practices for Water Quality Management on NFS Lands, as well as Forest Plan filter-strip

guidelines, snag-retention strategies and other measures for the conservation of biological diversity (Forest Plan, pages

40-41 and 287-292). Conventional felling equipment would likely be used for this treatment. The appearance of

harvested areas will change with treatment, allowing much more sunlight to the forest floor.

During tree felling, we would perform site-preparation activities to enhance the development and growth of hardwoods,

including cutting small (less than 10-inch dbh), undesirable, shade-tolerant, woody species to further increase sunlight to

desirable trees and leaving larger native trees to maintain diversity. Mechanical shears or chainsaws could also be used to

remove trees.

Prescribed Fire: Prescribed fire would not be implemented (likely for 10-15 years) until the fuel load is decreased to

appropriate levels such that burning will not adversely affect hardwood regeneration. Fire could then be applied to the

area as often as every two years to release existing shade-intolerant tree species and provide site conditions favorable for

future regeneration. Firelines would be constructed manually or mechanically, generally following past fire-control lines or

using existing man-made or natural boundaries where practical.

Vernal Ponds: We would construct up to 18 vernal ponds to provide a seasonal water source for amphibians, bats and

other wildlife species and repair the failed impoundments of six existing vernal ponds

Erosion Control: Erosion-control work would be done on system roads and the River-to-River Trail, including the

installation of water bars and water turnouts, ditch cleaning, stabilizing the road or trail surface with rock or other

methods. We would construct a rock check-dam to capture sediment running off private land in the headwaters of Big

Creek.

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Design Criteria for Action Alternatives

In order to minimize effects on resources, several design criteria are mandatory during project implementation (Table 1).

Table 1. Design Criteria for Lee Mine Hardwood Restoration and Habitat Enhancement.

Resource Design Criteria Rationale / Effectiveness

Invasive Species

1. Inspect clothing and equipment before entering or leaving the project area and remove and properly dispose of mud, dirt, and plant parts.

FS policy; use equipment-cleaning contract provisions WO-C/CT 6.36 (Appendix 1 Guide to Noxious Weed Prevention Practices (2001) and BT6.35 (Project Record).

Rare Plants

2. Protect known locations of regionally listed sensitive species and plants with species viability evaluation from mechanical treatments.

Required by law, regulation and Forest Plan.

Protect the majority of Cherokee sedge (Carex cherokeensis) plants from road reconstruction and competition from an invasive grass by:

Re-aligning timber hauling roads to avoid most Cherokee sedge plants.

Herbicide treatments of Nepalese browntop (Microstegium vimineum) infestations near Cherokee sedge locations using grass specific herbicide (sethoxydim and/or clethodim)

Recommendation of District Botanists to the District Ranger in order to protect Cherokee sedge. The single known population of this species on the Forest is within the project area. This sedge was recently discovered to occur in the State of Illinois at only a few other sites; it is not yet listed as threatened or endangered in the State. Although this sedge has not been classified as a Regional Forester Sensitive Species for the Shawnee National Forest, it would likely qualify for that designation.

Aquatic and Watershed Resources

1. Conduct soil and watershed improvements (water bars, water diversion structures, rock armoring at stream crossings) to existing FS roads, to reduce sediment loads into streams, Big Creek.

Roads eroding: sediment is transported downslope to enter drainageways and Big Creek or Harris Creek. Prior to harvest activities under Alternative 2, IDNR and USDA Forest Service BMPs will be implemented and road-conditions improved as necessary to reduce sediment loads into aquatic areas, thereby enhancing aquatic habitat, promoting and maintaining aquatic diversity in Big Creek Natural Area.

2. Refrain from using heavy equipment along ephemeral, intermittent, or perennial streambanks and from skidding or winching downed trees across ephemeral, intermittent, or perennial stream-courses, except at designated crossings.

To prevent soil compaction and displacement and maintain soil productivity; protect intermittent and perennial streambanks from gouging and scraping; protect riparian and downstream aquatic resources and maintain the integrity of riparian filter-strips.

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3. Delineate a 100-foot riparian filter-strip extending outward from each side of Big Creek. No cutting of standing trees from 0-25 feet. Retain a minimum basal area of 50-60 within 26-100 feet. Allowable bare-soil exposure limit is 10% of each 150-foot linear segment of filter-strip.

Complies with Forest Service and IDNR BMPs and Forest Plan standards and guidelines. Retention of vegetation in filter strip slows velocity of overland water-flow, dispersing surface runoff and preventing formation of rills and gullies; promotes infiltration of water and settling of suspended solids, reducing sediment and nutrient loads into aquatic areas; stabilizes streambanks and reduces bank erosion; maintains cooler stream temperatures and higher dissolved oxygen levels; provides a source of downed woody debris, a source of organic matter.

4. Delineate a 50-foot riparian filter-strip extending outward from each side of intermittent streams. No cutting of trees on streambanks. Retain a minimum average of 50-60 basal area 0-50 feet in the riparian filter strip. Allowable bare-soil exposure limit is 10% of each 150-foot linear segment of filter strip.


5. Maintain a 25-foot riparian filter-strip extending outward from each side of ephemeral streams. Retain a minimum average of 40-50 basal area 0-25 feet in the filter strip. Allowable bare-soil exposure limit is 10% of each 150-foot linear segment of filter strip.


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6. Maintain a 100-foot filter-strip within extending from ponds or wetlands and refrain from dropping trees into or across ponds. Refrain from operating heavy equipment in wetlands. Bare soil exposure is limited to 10% of each 150-foot linear segment of filter-strip. Provide leave-trees to shade ponds.

Complies with Forest Service and IDNR BMPs and Forest Plan standards and guidelines. Retention of vegetation in filter strip slows velocity of overland water-flow, dispersing surface runoff and preventing formation of rills and gullies; promotes infiltration of water and settling of suspended solids, reducing sediment and nutrient loads into aquatic areas; stabilizes streambanks and reduces bank erosion; maintains cooler surface-water temperatures and higher dissolved oxygen levels; provides a source of downed woody debris, a source of organic matter.

7. Designate skid-trails reusing previous skid-trails and log-landings when possible. Skid-trails will normally be less than 8-percent grade and avoid crossing streams when practical. Skid-trails and log-landings will be seeded and mulched as soon as practical after disturbance as needed.

Complies with Forest Service and IDNR BMPs and Forest Plan standards and guidelines. Prevents the displacement and movement of soil and the associated/resulting degradation of aquatic habitats and soil productivity.

8. Construct and maintain water-control structures to divert water from the skid-trails.

Complies with Forest Service and IDNR BMPs and Forest Plan standards and guidelines.

9. Do not operate heavy equipment in a manner that causes excessive soil-displacement, rutting, or compaction.

Complies with Forest Service and IDNR BMPs and Forest Plan standards and guidelines. Prevents compaction, which can prevent natural water infiltration and percolation, resulting in heavy surface water-flows and the movement of displaced soil from the site, with adverse effects on aquatic habitats.

Wildlife

1. Conduct no prescribed burns from 5/1 through 9/1 in upland forest-types.

Complies with Forest Plan. Prevents potential for direct impacts to nesting Neotropical migratory birds.

2. Retain a minimum number of snag or cavity trees in clumps within the harvest area. Identify existing or potential large (>9” dbh) cavity trees or snags and reserve a portion of the stand around them.

Complies with Forest Plan. Protects bat species.

3. Follow “Snag and Cavity Management for Thinning and Timber-Stand Improvement, Tables H-1 and H-2, and standards listed on pages 288-290, 2006 Forest Plan Appendix H—Strategies and Guidelines for Conservation of Biological Diversity.

4. Protect known Indiana bat roost trees during prescribed burning and silvicultural activities.

5. Protect known occupied northern long-eared bat maternity roost trees during prescribed fire or silvicultural activities.

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Heritage Resources

1. Conduct an inventory of the Area of Potential Effects to ensure that all heritage resources are adequately protected from project-related impacts.

Inventory completed; identified two sites, neither eligible for National Register of Historic Places; concurred with by State Historic Preservation Officer.

2. Monitor project area following implementation to assess the thoroughness of the present inventory.

Monitoring 1991-2005 indicated few sites have been missed initially using SHPO-required inventory methods.

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Table 2. 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.

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.

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Monitoring of Action Alternatives

We would monitor implementation of either action alternative to determine if management has been implemented as

specified and if the design criteria are effective. If monitoring exposes unacceptable resource damage, appropriate

measures would be implemented to correct problems (Table 1).

Table 3. Monitoring of Action Alternatives.

Activity Description Location and Timing

Soil

IDNR forestry best management practices (BMP) and USDA Forest Service BMP compliance and efficacy checks: Includes inspection for sheet, rill and gully erosion and inspection of log-landings, skid-trails and other disturbed areas.

Before, during and after harvest/tree-felling and as burning activities are completed.

Conduct compaction comparison: bulk-density core or penetrometer (Amacher and O’Neil 2004)

Aquatic Habitat

Assess changes in habitat utilizing Wolman pebble-count method.

Before and after harvest/tree-felling and as burning activities are completed.

Assess turbidity/total suspended solids. Before, during and after harvest/tree-felling and as burning activities are completed.

Sensitive Plants

Survey areas to be treated with herbicide to locate rare/sensitive species.

Prior to implementation in all areas to be treated with herbicide.

Monitor known rare plants to ensure no adverse impacts.

Selected locations would be monitored during and after implementation.

Air Quality

Monitor air quality utilizing E-sampler. Immediately prior to, during, and following prescribed burn.

Vegetation

Utilize established monitoring plots to determine vegetative changes.

Post-harvest/tree-felling monitoring throughout the project area will determine effectiveness in meeting project need.

Heritage Resources

Ensure that heritage resources are protected and preserved during and after project implementation.

Annual Forest Plan monitoring will assess the thoroughness of inventory methods and mitigation/protection measures.

Wildlife

Number of cavity trees retained post-treatment will be monitored to determine if standards and guidelines are effective.

During and after project implementation.

Snags will be monitored to determine if snag retention strategies and guidelines are effective.

Once, post-project implementation.

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Comparison of Alternatives

A summary of the effects of implementing each alternative is provided in Table 3:

Table 4. Comparison of the Effects of the Alternatives on the Key Issues.

Indicator Alternative 1 Alternative 2 Alternative 3

Oak, hickory, native hardwood regeneration

No change

Short-term (20 years): increase in sunlight to forest floor; advanced growth of oak, hickory and native hardwood seedlings and saplings. Long-term (50 years): successful ecological restoration with oak-hickory dominance of site.

Short-term (20 years): increase in sunlight to forest floor; delay in growth of oak, hickory and native hardwood seedlings and saplings; composition heavy with shade-tolerant species. Long-term (50 years): less-than-successful ecological restoration with oak-hickory interspersed with shade-tolerant species.

Species diversity and abundance

No change: Low species

diversity

Short-term: increase in early-successional species; slight increase in nest-predation and parasitism. Long-term: increase in late-successional and interior species; decrease in habitat fragmentation.

Short-term: increase in early-successional species; slight increase in nest-predation and parasitism. Long-term: increase in late-successional and interior species; decrease in habitat fragmentation.

Snags No change Decrease in small snags; slight decrease in large snags.

Felling, slight decrease in snags.

Number of non-desirable plant species

Increase expected.

Increase expected. Increase expected.

Frequency of non-desirable plant species

Increase expected.

Increase expected. Increase expected.

Amount of soil erosion (tons/acre/year)

No change Slight increase in erosion for 2-3 years past treatment.

No change

Sediment load delivered to stream system (tons/acre/year)

No change Slight short term increase in sediment load

No change

Alternatives Eliminated from Detailed Study

Clearcutting: The interdisciplinary team considered clearcutting, a harvest method used in the past to remove non-

native pine. The Forest Plan (pages 38 and 60) defines conditions where clearcutting may be optimal. The team

determined, based on the Forest Plan criteria, that the shelterwood method would adequately move this pine stand

toward the desired condition and recommended that this alternative be removed from further study.

Girdling: The interdisciplinary team considered an alternative under which the selected trees would be girdled and left

in place to die and eventually fall to the forest floor. It was decided, based on previous analysis, that this method would

not only pose an unnecessary safety risk to forest visitors but would also fail to achieve the ecological restoration goals

of the proposal.

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Winter-Season Commercial Harvesting for Nesting Birds and Roosting Bats: The interdisciplinary team considered an

alternative under which we would harvest only between November 1 and March 31 in order to minimize potential

effects on nesting birds, roosting Indiana bats and other species. However, this time of the year is usually wet in the area

and the opportunity to harvest would be limited by the design criteria for soil protection. In addition, winter weight-

limitations on public roads would restrict transportation of cut pines from the site. The team determined that restricting

harvesting to this period would cause more resource impact and would not greatly benefit these species compared to

the action alternative and its design criteria.

Chapter 3 – Affected Environment and Environmental Consequences We describe in this chapter, by resource area, the environmental 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, filed in the Project Record. The project record may be examined at the District Ranger’s Office in Vienna.

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 programmatic FEIS for the 2006 Forest Plan (USDA FS 2006a) and incorporates by reference

the programmatic biological assessment and U.S. Fish and Wildlife Service (FWS) Biological Opinion of the Plan (Project

Record).

Cumulative Effects Analysis: 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 differ for each resource area (see Table 4).

Past Actions: Past activities on NFS and private lands in the project-area watershed include, but are not limited to,

farming and grazing; mining; timber harvest; wild and prescribed fires; development and use of system and non-system

equestrian and hiker trails; wildlife management, including wildlife openings and pond construction; outdoor

recreational use, including picnicking, hunting, fishing, horseback riding, hiking; use of all-terrain vehicles and off-

highway vehicles; artifact hunting and collection; issuance of special-use permits; recreational facilities construction and

maintenance; road construction, maintenance and use; tree-planting and timber-stand improvements; power-line

construction and maintenance and electrification of rural areas.

Table 5. Spatial and Temporal Boundaries for Analysis of Each Resource Area.

Resource Boundary Rationale

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Table 5. Spatial and Temporal Boundaries for Analysis of Each Resource Area.

Resource Boundary Rationale

Vegetation

Spatial: the stand itself. The effects of the proposal will not extend beyond the stand.

Temporal: From the existing condition to stand condition at 20, 50 and 100 years

These periods reflect changes in habitat quality resulting from the proposed action.

Wildlife

Spatial: Indiana bat: Up to 3 miles from project area; MIS birds: 5-mile radius from project area; aquatic animals: 5 miles downstream from project area

Indiana bat: Up to 3 miles includes bats roosting outside project area that might forage or roost in the project area. MIS birds: The entire Forest is considered since many Neotropical migrants are affected by actions at their wintering grounds.

Temporal: From 5 years in the past to 50 years in the future.

Effects of projects beyond five years are not readily apparent. Fifty years into the future because the full effects of the proposed action should be realized in about 50 years

Botanical Resources

Spatial: The project area The effects of the proposal would be confined to this area.

Temporal: From the 1940’s to a point 10 years into the future

Presence and extent of rare plant species and communities or invasive plants before pine planted unknown; 10 years into future is life-span of Forest Plan: long enough to gauge management effects and short enough that any unforeseeable deleterious effects can be addressed, reversed or mitigated.

Soil and Water

Spatial: HUC-6 watershed containing project area

Watershed-based cumulative effects are best addressed within the watershed since erosion and sedimentation is not supplied across watershed boundaries.

Temporal: 15 years

15-year timeframe provides solid basis for measuring soil disturbance; soil erosion from project and associated activities returns to pre-project levels within 3-5 years.

Heritage Resources

Spatial: The project area

Earth-disturbing activities are confined to the project area; heritage resources beyond the project boundary are protected by law.

Temporal: From 30 years in the past to 10 years in the future

This period addresses activities from 1980 to the present, including two inventories for past effects, as well as project actions to 10 years in the future.

Recreation Resources

Spatial: The project area Effects on recreation are confined to the project area.

Temporal: 10 years 10-year timeframe provides solid basis for measuring effects on recreational activities.

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Present Actions: Many past activities in the project-area watershed are still occurring. Present actions include, but are

not limited to, trail reconstruction, maintenance and use; power-line maintenance; ATV use; timber harvest; agricultural

management; prescribed and wild fire and fire suppression; use trails; road maintenance and use; equestrian use; public

visitation and outdoor recreational use (hiking and hunting).

Reasonably Foreseeable Future Actions: Activities similar to past activities are reasonably foreseeable in the future. In

the next 15 years, the Forest plans to continue to maintain roads and trails, issue special-use permits ranging from

access-road and utility permits to outfitter-guide permits, suppress wildfires and apply prescribed fire. Reasonably

foreseeable future actions include those activities that are awaiting implementation, planned or listed in out-year

schedules such as the Schedule of Proposed Actions or might be expected to occur in the area.

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. 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 integral to 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. The design criteria in Tables 1 and 2 are consistent

with all safety practices and procedures 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 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”;

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The provisions of the National Environmental Policy Act and the Council on Environmental Quality regulations apply to

pesticide management proposals. 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).

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

Under Alternative 1, we would continue to apply prescribed fire to about 300 acres in the project area under a previous

decision. We have been applying prescribed fire to about 6,000 acres per year Forest-wide, resulting in short-term

effects: Smoke can temporarily reduce visibility and produce some pollutants, especially near the fire. Some, including

fire-crew members, might experience short-term irritation (coughing, watery eyes and runny noses). Particulate matter

from smoke in the air can cause health problems for individuals in proximity to the fire who have respiratory disease, or

who are elderly (Hardy et al. 2001, Hall 2009, Sharkey 1997). 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 people. 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-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.


Based on our review of the human health risk assessments of the herbicides we propose, we can reasonably state that

there would be no measurable, direct or indirect effects on human health and safety as a result of implementing the

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proposed action. The proposed chemical control-methods pose extremely minimal safety risks to workers or the public,

since we would implement stringent safety practices.

To assess the potential health effects of the proposed herbicides, we rely not only on the toxicology data used by the

EPA to certify the safety of pesticides, but also on risk assessments produced for the Forest Service independently by

Syracuse Environmental Research Associates (SERA). These assessments consider data from scientific literature as well

as that submitted to the EPA to support pesticide registration (Durkin 2007). Risks to human health from the herbicides

we propose were assessed by SERA (Durkin 2001, 2014). In our analysis we have reviewed and are incorporating, as

appropriate, relevant information from the risk assessments, both to inform our decision-making as well as to disclose to

the public 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. Measures of risk were based on typical Forest

Service uses of each herbicide.

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, but adherence to label directions would

minimize the exposure of workers during application and apparatus cleanup. Because adherence to all label instructions

is required, compliance with the design criteria reduces the risk of herbicide drift or the possibility of off-site movement

into water or wetlands.

The proposed herbicides have relatively short half-lives—one to ten days—and would not build up in the environment.

They have limited mobility, and only herbicides approved for aquatic use would be applied near water. None of our

proposed application methods poses a risk to surface or 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 of the 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

(Durkin 2001 and 2014).

Table 6. Human-Health Risk-Characterizations for Proposed Herbicides (Durkin 2001 and 2014).

Clethodim:

Relatively non-toxic.

Moderate skin irritation, if mishandled.

Mild eye irritation, if mishandled. Highest HQ, for consumption of contaminated vegetation, is 0.3 – 0.4

Sethoxydim:

Irritating upon direct contact.

Some irritation at high exposure levels. Does not readily volatize.

Based on studies, no evidence of cancer risk or reproductive risks. Highest HQ, for exposure to drinking water contamination, ranges from 0.008 – 0.04.

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– 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).

Clethodim – For exposures anticipated in the normal use and application of clethodim, the risk characterization is

reasonably simple. The upper bound HQ based on confidence intervals are below the level of concern by factors of

about 3: 0.3 for backpack workers. None of the HQs for accidental or non-accidental exposures to the herbicide exceed

the level of concern: The extreme scenarios of a child drinking water contaminated by an accidental spill or being

directly sprayed with the herbicide involve upper-limit HQs of 0.9 and 0.7, respectively. None of the acute non-

accidental exposure scenarios for members of the general public exceed the level of concern. All exposure scenarios

involving contaminated water are substantially below the level of concern—by factors of about 33—the upper-bound

HQ of 0.03 involves water consumption by a small child following two applications—to over 150 million—the lower-

bound HQ of 6x10-9 for the consumption of contaminated fish following one application (Durkin 2014).

Sethoxydim – None of the longer-term human-exposure scenarios exceed a level of concern. The upper limits for hazard

indices are below a level of concern by factors of 25 (longer-term consumption of contaminated fruit) to 2000 (longer-

term consumption of fish by the general population). Thus, the risk characterization is clear: based on the available

information and under the foreseeable conditions of application, there is no route of exposure or exposure scenario

suggesting that the general public will be at risk from exposure to sethoxydim.

The unlikely exposure scenario involving a person drinking water immediately following an accidental spill results in

a modest elevation above the reference dose at the upper limit of exposure—i.e., a hazard quotient of 1.3. This

exposure scenario is extreme to the point of limited plausibility. This sort of scenario is routinely used in Forest

Service risk assessments as an index of the measures that should be taken to limit exposure in the event of a

relatively large spill into a relatively small body of water. For sethoxydim, this standard exposure scenario may have

only very limited applicability because the amount spilled, about 15 lbs., is about four times more sethoxydim than

the Forest Service used in all of 1999. The acute drinking-water scenario for water contamination of a small stream

after a rainfall is much more plausible (although still highly conservative) and leads to very low hazard quotients—

i.e., 0.008 to 0.04 (Durkin 2001).

– 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):

Clethodim – The most recent EPA risk assessment indicates that evaluation of an immunotoxicity study in mice showed

that clethodim did not produce immunotoxicity… at doses of 40 up to 1312 mg/kg bw/day (Durkin 2014).

Sethoxydim – As stated earlier, the effects on endocrine function can be expressed as diminished or abnormal

reproductive performance. The Forest Service risk assessment reports:

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Sethoxydim has been tested for its ability to cause birth defects…as well as its ability to cause reproductive

impairment. Two studies…were conducted on sethoxydim: one in rats and one in rabbits. In the rat study…no

effects on fetuses were noted at the highest dose tested, 250 mg/kg/day. In the rabbit study, the highest dose

tested (480 mg/kg/day) resulted in toxic effects to the dams (decreased weight gain) and fetuses (decreased

number of viable fetuses and decreased fetal weight)…U.S. EPA/OPP (1998a) summarizes the results of a two-

generation reproduction study in which rats were fed diets…(that) resulted in daily doses of approximately 0, 7.5,

30, and 150 mg/kg. No effects were observed in dams or offspring (Durkin 2001).

– 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 herbicides that we propose. This is because neither is known to be a

carcinogen, so it is reasonable to conclude that there would be no increase in cancer risk from our use of them (Durkin

2001 and 2014). Based on our review of the human health risk assessments of the herbicides we propose, we can

reasonably state that there would be no measurable, direct or indirect effects on human health and safety as a result of

implementing the proposed action.

Also under Alternative 2, we propose to apply fire to about 1400 acres in the project area. It is possible that fire could be

applied to vegetation that had been treated with herbicides. The Center for Invasive Species and Ecosystem Health of

the University of Georgia addressed the question of the effects of prescribed fire applied to vegetation treated with

herbicides. They found, in a study by McMahon and Bush (1992), that:

…Fourteen prescribed burning operations were monitored to determine possible worker exposure. Field-worker

breathing-zone concentrations of smoke-suspended particulate matter, herbicide residues, and carbon

monoxide were monitored on sites treated with labeled rates of forestry herbicides containing the active

ingredients imazapyr, triclopyr, hexazinone, and picloram. The sites were burned 30-169 days after herbicide

application. No herbicide residues were detected in 140 smoke samples from the 14 fires. These detection levels

are several hundred to several thousand times less than any occupational exposure limit for these herbicides

(emphasis added).

Further, they found:

Worker exposure to herbicide residues released from burning treated vegetation was estimated in the U.S.

Department of Agriculture Forest Service Southern Region Environmental Impact Statement (Weeks et al. 1988).

This analysis assumed that: 1) 3.0x107m3/ha smoke is produced, 2) herbicides are applied at maximum labeled

application rates, 3) herbicides degrade with time at published dissipation rates, and 4) no thermal

decomposition of the parent compound occurs in the burning process. Margins of safety (MOS’s) were

estimated for all registered herbicides, comparing predicted smoke residue levels to threshold limit values. All

MOS’s were found to be >150 except for triclopyr ester, which had a MOS of 84…Herbicide concentrations in the

air dissipate with distance from the burn site; thus the public would be expected to have lower exposures than

on-site workers.

NOTE: “Margin of safety” is the ratio of the animal NOEL (no-observed-effect level) and the estimated human

dose received. A larger MOS indicates a smaller dose compared with the NOEL and thus a smaller human risk. In

order to satisfy the criterion suggested by the EPA and adopted by the Forest Service, the quotient of this

formula must be greater than or equal to 100.0 to pose an acceptable level of risk.

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Understanding the above, we can reasonably expect that effects on human health and safety would be similar to those

under Alternative 1. The amount of smoke effects would not be noticeably different, since our fires are well planned and

result in minimal smoke-effects and fairly rapid dissipation (Huffman 2009, USDA FS Shawnee 2009).


Alternative 3 includes no use of herbicides, so would have no herbicide-related effects on human health and safety. This

alternative also includes the use of prescribed fire and would have effects similar to those described under Alternatives

1 and 2.

Cumulative Effects –Alternatives 2 and 3

Although the amount of time required for a proposed herbicide 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 invasive species 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.

Since the acres of prescribed fire we propose would not be in addition to the acreage already burned annually on the

forest, there would be no additional prescribed fire effects under these alternatives. Smoke production as a result of

prescribed fire has the potential to affect human health and safety in the area; however, adherence to the design

criteria and burn plan prescriptions will lessen the effects to a minimal level. Since we only apply prescribed fire under

appropriate atmospheric and wind conditions, the smoke produced by a prescribed fire on the Forest would not

contribute cumulatively to adverse smoke conditions produced by any ill-timed fire ignited elsewhere in the project

area. Thus, our smoke production would have no measurable cumulative effect in the project area or adjacent

properties because there would be minimally adverse, direct and indirect effects under all three alternatives.

Considering the effects of implementing either Alternative 2 or 3 with those of past, present and reasonably foreseeable

future actions, there would be no measurable, direct or indirect effects on human health or safety.

Watershed Resources

Watersheds: The project area is comprised of parts of three HUC6 watersheds: Big Creek-Ohio River, dominant at 2800

acres; Big Grand Pierre Creek-Ohio River, 6 acres in the northwest corner of the area; and Eagle Creek-Saline River, 440

acres in the southwest corner of the project area.

Streams: Several perennial, intermittent and ephemeral streams flow through the project area. Harris Creek is a

perennial stream in the Eagle Creek-Saline River watershed, about 400 feet away from the nearest area to be harvested.

It is listed by the Illinois EPA as impaired for aquatic life due to low dissolved oxygen levels attributed to agriculture, crop

production, surface and subsurface mining and upstream channelization. Big Creek is a perennial stream in the Big

Creek-Ohio River watershed. It is managed under the Forest Plan as a zoological natural area and a candidate

recreational Wild and Scenic River. Under the Natural Area management prescription, the stream itself is managed to

protect its aquatic life; under the Candidate Wild and Scenic River management prescription, a quarter-mile on either

side of the stream is managed to protect its values, including the prevention of “any modifications that would adversely

affect the free-flowing nature” of the stream (CR25[S], Plan, page 53). Although this area is unsuitable for timber

production, timber may be removed to meet other objectives, such as the enhancement of wildlife habitat. The Illinois

EPA classifies Big Creek as fully supporting aquatic life and aesthetics.

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Soil: Eleven soil series are mapped within the project area, the majority of which are silt loams. Topography is variable,

ranging from little to no change in elevation to steep terrain (35%-75% slopes). Generally, the erodibility of the soils is

moderate. Hydric soils were assessed using the Natural Resources Conservation Service’s Web Soil Survey. One soil,

Belknap silt loam, was shown to have hydric properties; it is located predominately along stream-courses. Specific

information regarding erosion hazards, limitations of prescribed burning, potential damage by fire and the suitability of

natural-surface roads, haul roads, major skid trails and log landings can be found in the Watershed working paper.

Wetlands: The FWS has mapped about 46 acres of wetlands in the project area. These are comprised of 21 ponds

covering about 6 acres and five forested wetlands of about 40 acres. Mapped as required by the Forest Plan and

specified in the project design criteria (Table 1). See Figure 6 for wetland details.

Air: We consulted the Illinois EPA air quality report. Overall, the pH of atmospheric deposition is acidic, but it has been

becoming less acidic over the past few decades. Sulfates have decreased, while nitrate and ammonia levels have

fluctuated. Air quality in the area meets EPA standards. Air quality across the Forest is good.

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Displaying information from the National Wetlands Inventory

and USDA Forest Service databases.

Figure 6. Lee Mine aquatic and wetland areas.

Lee Mine Hardwood Restoration Project Area

Aquatic and Wetland Areas

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The Illinois EPA has developed a statewide Smoke Management Plan to address smoke from prescriptive fires 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. Prescribed fires on the Forest comply 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.

Alternative 1 – All Effects

No new management activities associated with the proposed action would take place: therefore, no management-

related changes in productivity of the land would occur. Current runoff and erosion patterns would be maintained: an

erosion rate of less than one ton per acre per year is predicted by FSWEPP for steep slopes in the absence of fire.

Natural functions would continue as dead material decomposes. Soil organic matter may increase, with an

accompanying increase in microorganisms and fungi. Sediment lost from existing roads would likely be transported

downslope, affecting aquatic habitat and the quality of streams and wetlands. In the absence of wildfire, dead and down

trees would decompose over time, leading to increased macro- and micro-organism populations carrying out

decomposition. As decomposition proceeds, dead and down material would eventually be incorporated into the organic

horizon and surface horizons, leading to increased soil nutrient capital and water retention.

Cumulative Effects

Soil quality and productivity would be increased in the long term as organic matter decomposes and converts to the A

horizon. Geologic erosion would continue and some of this sediment could be expected to enter the streams. In

addition, without installation of the proposed erosion-control structures for the protection of Big Creek, this alternative

would be likely to result in continuing soil erosion and sediment-loading to Big Creek. Water quality would be affected at

current levels, considering anticipated future actions and assuming the inputs from private land remain stable.

Implementation of this alternative could result in measurable changes to water quality if sediment-inputs from private

land were to increase.


Activities associated with the proposed shelterwood harvest and other management activities include the use and/or

realignment of existing roads, construction and use of skid trails, log landings and stream-crossings. These activities can

expose and compact soil, which then has the potential to erode at a faster rate than normal geologic rates. Soil can be

loosened and transported in overland flow. Most of the eroded soil is trapped in vegetation and deposited downslope,

but some enters streams and can decrease water quality and the amount of quality aquatic habitat. Loss of substantial

amounts of nutrient-rich topsoil can also decrease site-productivity, or the long-term ability of the land to grow healthy

trees. Herbicide use to protect discrete areas of rare plants could affect soil health.

Soils: Removal of a portion of the forest canopy by harvesting increases the sunlight reaching the forest floor, thereby

increasing soil temperature. Warmer soil temperatures, combined with an increase in organic matter and soil moisture,

would likely result in rapid decomposition and mineralization due to increased microbial activity. This surge of nutrients

would promote the rapid growth of young saplings, seedlings and new germinations, as well as sprouts from the existing

root systems in harvested areas.

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The proposed harvest could result in some soil erosion and compaction, soil displacement and bare-soil exposure.

Erosion and sedimentation would generally be greatest through the period of active management a year after

completion of harvest. Erosion is expected to return to pre-harvest levels two to three years after harvest and

associated activities. The area is expected to recover quickly from compaction. Research shows that the upper few

inches of soil recovers quickly from light to moderate compaction (Burger 1985; Hatchell 1971; Kozlowski 1999),

although skid trails and log landings may recover more slowly.

Disturbance depends on the timing of the prescribed burning. Fire applied when the soil, litter and organic matter are

moist will typically consume less of these components that are necessary for substrate microbial organisms and

maintenance of long-term soil productivity. Fire may be applied in a pre-harvest burn and up to three burns post-harvest

over a ten-year period. 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 but certain generalizations seem relatively

consistent:

o Burning has its most pronounced effect on the forest floor where carbon (C), nitrogen (N), and sulfur (S) are

volatilized and calcium (Ca), magnesium (Mg), potassium (K), and phosphorus (P), and other elements are left as

ash;

o The ash is leached by rain into the mineral soil, which increases its base saturation and pH (Alban 1977);

o Increased nutrient availability at higher pH’s may result in positive plant responses following fire (Van Lear and

Kapeluck 1989);

o The positive response of plants leads to less soil erosion because plants hold the soil and slow the impact of

rainfall (Neary, Ryan, & DeBano 2005).

Fire-lines would be constructed with erosion-control measures to reduce potentially adverse effects to minimal levels.

Increased initial erosion on areas with high erosion potential and riparian soils could result in increased soil loss,

although the limitations of the area soils are slight.

The herbicide sethoxydim would be applied to protect discrete areas of rare plants from invasives intrusion. Sethoxydim

targets grasses. It is moderately to slightly toxic to aquatic species, but has a low persistence in soil and underground

water. Its average half-life in soils is one to three days, although it could range shorter or longer, to 10 days (Durkin

2001). It has a very low volatility and a weak tendency to adsorb to soil particles. In field tests, it did not leach below the

top four inches of soil, and it did not persist. In soil, its photodegradation takes less than four hours. The disappearance

of sethoxydim is primarily due to action by soil microbes. In water, photodegradation of sethoxydim takes less than one

hour (Extoxnet 1996c, Shoaf and Carlson 1992). Because it is water-soluble and does not bind strongly with soils, it can

be highly mobile. However, there are no reports of water contamination or off-site movement by sethoxydim. It is of

relatively low toxicity to birds, mammals and aquatic animals and has little noticeable impact on soil microbe

populations (Tu et al. 2001d). Considering the amount of this chemical that could be applied over the life of this project,

direct effects would be limited to target grasses, with no measurable direct or indirect effect on soil, surface water, or

underground water.

Water Quality: The removal of trees would result in a decrease in the uptake of water and evapotranspiration, leading

to higher soil-moisture levels and an increase in surface runoff during rainfall. Implementation of this alternative could

result in short-term (1-2–year) disturbance of riparian areas. As vegetation grows, the soil will stabilize and turbidity and

sediment levels are expected to return to pre-management levels within a growing season following completion of the

project. Indirectly, a slight decrease in water quality of adjacent streams may occur due to increased turbidity and

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siltation, but this is expected to be short-term (3 years), and water quality would be maintained in the long term.

Increased erosion from prescribed fire would likely result in increased sediment and nutrients in adjacent streams.

However, due to the scale of the anticipated burns, these effects are not expected to be measurable in terms of water

quality.

Air Quality: Prescribed fires on the Forest comply with the statewide Smoke Management Plan as well as the Forest

Plan, following detailed burn plans and strict prescription standards. We evaluate prescribed fires using smoke-

management models (FOFEM, V-Smoke and/or SASEM). Our monitoring of recent burns on the Forest—the Blowdown,

One Horse Gap, Cedar Grove, Eagle Mountain and others—confirmed they complied with the Forest Plan, followed burn

plans and prescriptions, and resulted in no measurable adverse effects on air quality (Huffman 2009, USDA FS Shawnee

2009).

Cumulative Effects

An increase in soil erosion and siltation is anticipated for 5-10 years, in addition to a slight, temporary decrease in water

quality. Once the project area returns to pre-disturbance levels, of erosion and sedimentation, the cumulative effect of

all actions in the watersheds would result in a minimal sediment load in the streams, such that impacts to water quality

are considered negligible.


The direct and indirect effects to water and soil resources from this alternative would be less than under Alternative 2,

because most of its direct effects to soil and water are a result of the methods used to remove cut trees. Under this

alternative no trees would be removed from the site. Consequences of this alternative would be similar to Alternative 2,

but the rapid revegetation anticipated under that alternative is expected to be diminished under Alternative 3 due to

the total mass and area of downed trees that will cover the forest floor and possibly inhibiting the growth of seedlings.

Soils: Trees remaining on the site will become incorporated into the organic and surface horizons of the soil. As

decomposition occurs, soil nutrients will increase. An increase in soil productivity is anticipated for 10-15 years under

this alternative. This alternative would probably result in some short-term (1-3 years) bare-soil exposure, soil

displacement, erosion, rutting and compaction on roads used to reach the sites. This alternative would result in slightly

less soil erosion, compaction and disturbance than under Alternative 2 and more than Alternative 1. The consequences

of prescribed burning would be very similar to those under Alternative 2; but, because of the greater fuel loads, a more

intensive fire is possible, leading to diminished soil productivity.

Water Quality: As under Alternative 2, by removing trees, a decrease in the uptake of water and evapotranspiration

would result, leading to higher soil-moisture levels and an increase in surface runoff during rainfall. However, the

downed trees would intercept surface runoff, thereby slowing its velocity and erosive power. Slower-moving runoff has

greater time to infiltrate, resulting in a greater volume of water entering the soil and a reduction in the volume of

surface runoff entering streams.

Cumulative Effects

Cumulatively, the effects of this project considered together with other actions in the watershed would result in

negligible to minimal short-term (5-10 years) increase in erosion and sedimentation to the streams. Upon returning to

baseline, pre-disturbance levels of erosion and sedimentation, the cumulative effects of all actions in the watershed

would result in minimal, long-term sediment load that would affect water quality to a negligible degree.

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Wildlife

No unique wildlife habitat features are known in the project area and any species associated with unique habitats should

be absent. Consequently, these features and associated species should remain unaffected by implementation of either

action alternative. A variety of aquatic habitat types is present in the project area. Numerous ponds are scattered

throughout. Once water sources for livestock, they now provide water for reptiles and amphibians, wild turkey, white-

tailed deer and a variety of bats, some of which are rare. Several ponds are not holding water due to breaches in their

earthen dams. Both action alternatives propose to repair earthen dams so that they can hold water throughout the year.

Both alternatives propose to construct up to 18 new vernal ponds/wetlands, helping to restore habitat for amphibians

and reptiles. Big Creek flows through the area. It is designated in the Forest Plan as a zoological natural area due to the

diversity of aquatic species known to be present within it (Forest Plan, Appendix D-Special Features). The Forest Plan

states:

Zoological areas possess authentic, significant and interesting evidence of the national heritage as it pertains to

fauna. These areas are meaningful because they embrace animals, animal groups, or animal communities that

are natural and important due to occurrence, habitat, location, life-history, ecology, environment, rarity, or

another feature.

Federally Listed Animal Species

Based on the presence of suitable habitat, the capture of individual bats, the documentation of multiple summer roost

trees and the documented presence of maternity colonies, we find that Indiana bat (Myotis sodalis), gray bat (Myotis

grisescens) and northern long-eared bat (Myotis septentrionalis) are the only federally listed species with the potential

to occur within or near the project area.


Indiana bat (MYSO)

Alternative 1 is not expected to have any direct, indirect, or cumulative effects on MYSO habitat or populations. The

existing pine stand would remain as poor quality foraging and/or summer roosting habitat into the future. Over time, as

dominant canopy trees die, there should be a gradual increase in potential roost trees, as well as a gradual opening-up

of the canopy, for a slight increase in foraging habitat. Any improvement in the quality of Indiana bat summer roosting

or foraging habitat is expected to occur at a slow rate.

Gray bat (MYGR)

Alternative 1 would maintain the current condition of roads, trails and stream crossings in the project area. Sediment

would continue to be introduced into Big Creek, compromising aquatic habitat, with adverse indirect effects to MYGR

continuing unabated. Implementing Alternative 1 would likely result in both indirect and cumulative adverse effects to

MYGR. Because of this, the affects determination for Alternative 1 is may affect-likely to result in adverse indirect and

cumulative effects.

Northern long-eared bat (MYSE)

Implementation of Alternative 1 would have no direct, indirect, or cumulative adverse effects to MYSE. Therefore, the

effects determination for MYSE from implementation of Alternative 1 is No Effect.

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Alternatives 2 and 3 – All Effects

With regard to any of the federally listed bat species discussed below, the use of sethoxydim or clethodim as proposed

should have no effect. The simple interpretation of the quantitative risk characterization of sethoxydim or clethodim for

terrestrial animals is this:

…the weight of evidence suggests that no adverse effects in terrestrial animals are plausible using typical or even

very conservative worst-case exposure assumptions. As with the human health risk assessment, this

characterization of risk must be qualified. Sethoxydim has been tested in only a limited number of species and

under conditions that may not well represent populations of free-ranging non-target animals. Notwithstanding this

limitation, the available data are sufficient to assert that no adverse effects can be anticipated in terrestrial animals

from the use of this compound in Forest Service programs (Durkin 2001).

Indiana bat (MYSO)

Any actions that modify the structure, density and size of trees can affect the quality and quantity of MYSO summer

roosting and/or foraging habitat. Timber harvesting operations during the summer roosting period have the potential

for causing direct mortality to roosting bats. Several actions should work together to reduce the likelihood of adverse

effects:

a) completion of summer mist-netting surveys and identification of a primary maternity colony tree,

b) compliance with the Terms and Conditions in the Forest Plan BO,

c) compliance with Snag and Cavity Management Standards and Guidelines in the Forest Plan,

d) the absence of known MYSO hibernacula within or near the project area and

e) implementation of the design criteria included within the proposed action.

Any incidental take of individual bachelor or non-reproductive female MYSO should fall within the range evaluated and

documented in the BO and addressed in Tier Two consultation with the Service. Implementation of the above protection

and conservation measures should also reduce the likelihood that maternity colony take would result from

implementation of the proposed action.

Because individual MYSO, likely bachelors or non-reproductive females, may be affected by implementation of either

Alternative 2 or 3, the project effects determination is may affect-not likely to adversely affect MYSO. Anticipated effects

from implementation of either Alternative 2 or 3 should fall within the range of effects projected and evaluated for the

Forest Plan and formal consultation previously completed with the Service. As such, any incidental take resulting from

implementation of the Lee Mine project should be covered under the level of incidental take issued with the BO.

Implementation of hardwood restoration activities should have a long-term, beneficial, indirect effect on MYSO summer

roosting and foraging habitat conditions due to a reduction in the density of the pine overstory, which would provide

increased solar radiation to residual pine trees, and the restoration of mixed mature hardwoods in the future.

Implementation of hardwood restoration activities should have no long-term, adverse, indirect or cumulative effects to

MYSO populations in the project area or across the Forest because of implementation of project design criteria and

compliance with Forest Plan standards and guidelines.

Gray bat (MYGR)

Implementation of either Alternative 2 or 3 could result in adverse as well as beneficial effects to MYGR. Implementation

of the road improvement necessary to facilitate harvesting would reduce the current level of sediment introduced into

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Big Creek and its tributaries and reduce the potential for indirect adverse effects to MYGR. Additionally, implementation

of improvements to sections and crossings associated with the River–to-River Trail and construction of a rock catch-dam

upstream where a feeder stream/ditch empties into Big Creek, would help to reduce the potential for adverse indirect

and cumulative effects on MYGR. Retaining a component of live trees within riparian filter-strips should assist in

maintaining their function and reduce potential adverse downstream effects to aquatic insects. Residual trees would

provide shading of riparian filter-strips and be effective in reducing sediment transported from timber-treatment areas

into aquatic areas and in maintaining stream temperatures. Implementation of the design criteria would help to

enhance and maintain healthy aquatic systems and aquatic insect populations.

These actions are consistent with objectives and acceptable practices in the USDA FS National BMP (USDA 2012).

Implementation of Alternative 2 would result in improvements to the water quality of Big Creek and, so, have beneficial

indirect and cumulative effects to MYGR. Implementation of Forest Plan filter-strip standards and guidelines, together

with design criteria that buffer Big Creek with a no-cut strip and a wider zone of higher residual BA, would virtually

eliminate the likelihood of any direct adverse effects to individual MYGR. The effects determination for implementation

of either Alternative 2 or 3 for MYGR is may affect-not likely to adversely affect.

Northern long-eared bat (MYSE)

The effects determination for MYSE from implementation of either Alternative 2 or 3 is May Affect-Likely to Adversely

Affect. Implementation of either Alternative 2 or 3 may result in adverse cumulative effects to MYSE, but these are not

expected to rise to the level of jeopardizing the continued existence of the species.

Regional Forester Sensitive Species (RFSS) and Species with Viability Evaluation (SVE)

Based on their known or likely occurrence within or in close proximity to the affected project area, the following 14

species were selected for effects analysis:

Table 7. Regional Forester Sensitive Species and Species with Viability Evaluation.

Common Name Scientific Name Taxa Status

1. Timber rattlesnake Crotalus horridus Reptile RFSS

2. Little brown bat Myotis lucifigus Mammal RFSS

3. Tri-colored bat Perimyotis subflavus Mammal RFSS

4. Big-claw crayfish Orconectes placidus Invertebrate RFSS

5. Kentucky crayfish Orconectes kentuckienses Invertebrate RFSS

6. Bald Eagle Haliaeetus leucocephalus Bird RFSS

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Table 7. Regional Forester Sensitive Species and Species with Viability Evaluation.

Common Name Scientific Name Taxa Status

7. American Woodcock Scolopax minor Bird SVE

8. Worm-eating warbler Helmitheros vermivorum Bird SVE

9. Wood thrush Hylocichla mustelina Bird SVE

10. Yellow-breasted chat Icteria virens Bird SVE

11. Northern bobwhite Colinus virginanus Bird SVE

12. Gray treefrog Hyla versicolor Amphibian SVE

13. Red-Headed Woodpecker Melanerpes erythrocephalus Bird SVE

14. River otter Lantra canadensis Mammal SVE


1. Timber rattlesnake: Implementation of Alternative 1 should have no direct, indirect, or cumulative adverse impacts to

the species. The poor quality of habitat is expected to persist well into the future.

2. Little brown bat: Implementation of Alternative 1 should have no direct, indirect, or cumulative adverse impacts to

the species. The poor quality of bat habitat is expected to persist well into the future.

3. Tri-colored Bat: Implementation of Alternative 1 should have no direct, indirect, or cumulative adverse impacts to the

species. The poor quality of bat habitat is expected to persist well into the future.

4 and 5. Big-claw crayfish and Kentucky crayfish: Implementation of this alternative is expected to result in similar

aquatic habitat conditions into the near future. Sediment will continue to be deposited into Big Creek causing indirect

and cumulative impacts to the species.

6. Bald Eagle: There should be no direct, indirect, or cumulative adverse effects to this species from this alternative. The

unsuitable habitat would be maintained.

7. American Woodcock: Implementation of Alternative 1 will maintain the existing forested conditions, at least into the

near future. It is unlikely that American Woodcock would utilize the area, due to the reasons previously discussed in this

document. Habitat quality is anticipated to remain somewhat poor into the near future.

8. Worm-eating Warbler: There should be no direct, indirect, or cumulative adverse impacts to worm-eating warbler

populations or habitat from the implementation of this alternative. In the short term, pine stands will remain as

unsuitable or low productive habitats.

9. Wood Thrush: There should be no direct, indirect, or cumulative adverse effects to this species from this alternative.

The marginally suitable habitat would be maintained.

10. Yellow-breasted Chat: No direct, indirect, or cumulative adverse impacts are expected to result from the Alternative

1. In the absence of management activity, the marginally suitable habitat located within the hardwood areas will most

likely not be maintained. In the long term, as individual pines begin to die and fall out of the canopy, habitat quality will

remain low, since yellow-breasted chats do not readily utilize small habitat patches (Woodward et al. 2001).

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11. Northern Bobwhite: No direct, indirect, or cumulative adverse impacts are anticipated to occur from this alternative.

In the absence of management activity, the unsuitable to marginally suitable habitat will most likely remain into the

future.

12. Gray Treefrog: Implementation of Alternative 1 is expected to maintain existing habitat conditions for gray treefrog,

at least into the near future. Permanent and seasonal water sources will continue to be somewhat limited in distribution

and abundance.

13. Red-headed Woodpecker: Implementation of Alternative 1 is expected to perpetuate the existing poor habitat

conditions. The dense pine stands provide very poor quality habitat for red-headed woodpecker.

14. River Otter: Implementation of this alternative is expected to result in similar aquatic habitat conditions into the

near future. Sediment will continue to be deposited into Big Creek causing indirect and cumulative impacts to the

species.


With regard to any of the sensitive species discussed below, the use of sethoxydim as proposed should have no effect.

The simple interpretation of the quantitative risk characterization of sethoxydim for terrestrial animals is this:

…the weight of evidence suggests that no adverse effects in terrestrial animals are plausible using typical or

even very conservative worst-case exposure assumptions. As with the human health risk assessment, this

characterization of risk must be qualified. Sethoxydim has been tested in only a limited number of species and

under conditions that may not well represent populations of free-ranging non-target animals. Notwithstanding

this limitation, the available data are sufficient to assert that no adverse effects can be anticipated in terrestrial

animals from the use of this compound in Forest Service programs (Durkin 2001).

4 and 5. Big-claw crayfish and Kentucky crayfish: Implementation of Alternative 2 could result in adverse as well as

beneficial impacts to the two crawfish species. Implementation of the road improvements necessary to facilitate

harvesting would reduce the current level of sediment introduced into Big Creek and its tributaries and reduce the

potential for indirect adverse impacts to aquatic species. Additionally, implementation of improvements to sections and

crossings associated with the River–to-River Trail and construction of a rock catch-dam upstream where a feeder

stream/ditch empties into Big Creek, would help to reduce the potential for adverse indirect and cumulative impacts.

Retaining a component of live trees within riparian filter-strips should assist in maintaining their function and reduce

potential adverse downstream effects. Residual trees would provide shading of riparian filter-strips and be effective in

reducing sediment transported from timber-treatment areas into aquatic areas and in maintaining stream

temperatures. Implementation of the design criteria would help to enhance and maintain healthy aquatic systems.

Implementation of Alternative 2 would result in improvements to the water quality of Big Creek and, so, have beneficial

indirect and cumulative effects to both crayfish. Implementation of Forest Plan filter-strip standards and guidelines,

together with design criteria that buffer Big Creek with a no-cut strip and a wider zone of higher-residual BA, would

virtually eliminate the likelihood of any direct adverse impacts.

11. Northern Bobwhite: It is anticipated that as pine areas are thinned and burned, that habitat suitability for bobwhite

will improve substantially into the near future. The reduced density of mature pines will allow sunlight to reach the

forest floor, which should create both desirable food and cover vegetation that bobwhite prefer. These habitat

conditions should persist about 15 years, during which time thinned areas will transition from open-canopied pine with

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dense herbaceous and woody groundcover, to open-canopied pine with somewhat dense mid-story woody trees and

saplings. Treated pine areas are anticipated to remain unsuitable bobwhite habitat in the long term, as the area

transitions into mature mixed upland hardwood and pine forest.

Alternatives 2 and 3

1. Timber rattlesnake: All of the project area is considered to represent marginally suitable to unsuitable rattlesnake

denning habitat with an extremely low likelihood of timber rattlesnakes being present within them. There is no known

suitable denning habitat present within pine stands proposed for timber treatments. However, individual timber

rattlesnakes, especially male snakes, could be present in adjacent forested areas since many of the hardwood areas

have some karst rocky habitats, and suitable foraging areas. Thus, timber rattlesnakes could be present within the

project activity area during summer months and be affected by timber treatments, operation of motor vehicles, or

prescribed burns. Consequently, implementation of Alternatives 2 or 3 could result in adverse direct impacts to

individual rattlesnakes. Indirect and cumulative effects should result in the improvement of foraging habitat.

2. Little brown bat: Implementation of Alternative 2 or 3 may adversely impact an individual little brown bat, most likely

being a bachelor male or non-reproductive female. However, should any individual bats be adversely impacted, the level

of impacts are not expected to rise to the level that will contribute to a loss of species viability, nor jeopardizes the

existence of the species. Indirect and cumulative impacts should be an overall positive impact with the improvement of

foraging and roosting habitat.

3. Tri-colored Bat: Implementation of Alternative 2 may result in direct adverse impacts to individuals, but should not

contribute to the loss of species viability, nor cause a trend toward federal listing. Implementation of Alternative 3 will

have some similar potential impacts to tri-colored bats when trees are cut and left on the ground. Indirect and

cumulative impacts from both action alternatives should be an overall positive impact with the improvement of foraging

and roosting habitat.

6. Bald Eagle: This analysis concludes that bald eagles are not likely to be present within or near the proposed project.

Consequently, implementation of the proposed project is not likely to result in any direct, indirect, or cumulative

adverse impacts to bald eagles.

7. American Woodcock: Implementation of Alternatives 2 and 3 is expected to improve habitat suitability for American

Woodcock within the area, at least for the short-term. Improvement in habitat quality is not expected to be as high for

Alternative 3, due to the high amount of large woody debris on the forest floor.

8. Worm-eating Warbler: Bird surveys in late May of 2014 detected the presence of warblers at six bird points. Suitable

habitat is present throughout the project area in hardwood stands. As such, implementation of the project has the

potential to have both direct and indirect affects to warblers within the project area. Potential direct effects to this

species may include: 1) direct mortality resulting from the felling of standing live trees falling on nests/nestlings; 2)

disturbance to nesting birds from timber operations; and, 3) short-term displacement from the project activity area

resulting from timber harvesting/felling operations. Implementation of Alternative 2 or 3 may have some direct adverse

impacts to individual birds within the project area but should be relatively short-lived, confined to the area, and should

not adversely affect population viability across the Forest. Implementation of Alternative 2 is likely to result in beneficial

cumulative effects to warbler habitat and populations in the long term due to establishment of mature mixed pine and

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hardwood forest. It is reasonable to expect warbler populations to be higher once treated areas convert to mature

hardwood and pine forest.

9. Wood Thrush: Pine areas proposed for implementation of restoration activities currently represent very marginal to

low-quality habitat, with a low probability of the species being present. Wood Thrush could be expected to be present in

the adjacent hardwood areas (not proposed for treatment). Bird surveys in late May of 2014 documented Wood Thrush

at seven bird points. Any potential direct adverse impacts would be unlikely since the pine stands proposed for

treatment represent low quality habitat, and Wood Thrush are not expected to be present during timber treatment

activities. In the short term, implementation of either Alternative 2 or 3 is not expected to impact individuals in the

project area. In the long term, restoring hardwood species as part of the dominant canopy should benefit populations in

the project area, being higher then pre-treatment.

10. Yellow-breasted Chat: Implementation of these alternatives is not expected to have any direct or indirect adverse

impacts to this species, since the existing vegetative condition of the project area represent unsuitable habitat. Reducing

stand density and opening up the pine canopy in mature yellow pine stands should result in positive indirect short-term

effects through an anticipated increase in the amount of suitable habitat in the area. It is anticipated that

harvesting/felling will create early-successional habitat. The number of chats is expected to increase in the short term. In

the long term, the project area would be expected to return to unsuitable habitat.

12. Gray Treefrog: Implementation of Alternatives 2 and 3 is expected to result in no or only minor localized direct

effects to grey treefrog in the form of direct mortality from felling operations. Indirect and cumulative effects for

Alternative 2 will likely be overall positive due to the construction of vernal ponds and the improvement of habitat.

13. Red-headed Woodpecker: Implementation of Alternatives 2 and 3, however, is expected to improve habitat quality

for the Red-headed Woodpecker, at least into the near future. Implementing harvesting/felling activities will reduce the

number of trees per acre, which will create good-quality habitat. The use of sustained dormant season burning should

extend the time period where suitable habitat will be maintained.

14. River Otter: Suitable habitat is present within the project area along Big Creek. However, implementation of the

project is not likely to result in any direct, indirect, or cumulative adverse impacts to river otters or to the habitat upon

which they depend.


4 and 5. Big-claw crayfish and Kentucky crayfish: Water quality is likely to remain somewhat unchanged since no skid

trails or temporary roads would be constructed, and no mechanized equipment would be used. As such, implementation

of Alternatives 3 is not expected to have any direct, indirect, or cumulative adverse impacts to big claw and Kentucky

crayfish.

11. Northern Bobwhite: Where live pines are cut and left on the ground, there should be no increase in the quantity or

quality of bobwhite habitat, since the areas would be too dense with downed woody debris. Bobwhite would be unlikely

to use most of these areas due to an increase in habitat for predators.

Aquatic Species Related to Big Creek Zoological Natural Area

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A partial listing of aquatic species known or likely to be present within Big Creek includes 60 species. Big Creek has been

classified in the Forest Plan as a Zoological Area due to the high diversity of aquatic species. Many of these species are

associated with clear, cool, running water conditions, such as darters, sculpin, smallmouth bass, darters, suckers,

madtoms, crayfish, and several species of aquatic mussels. As such, any actions that result in reduced water quality in

Big Creek have adverse direct and indirect effects on aquatic species. Any actions that improve water quality in Big Creek

have beneficial direct and indirect effects on aquatic species.

Botanical Resources

There are no recorded occurrences of federally listed plants in Hardin County where the project area is located. There is

no suitable habitat in the project area for the single federally threatened plant on the Forest, Mead’s milkweed.

Although no Forest-specific Regional Forester Sensitive plant species have been found in the project area, we discovered

populations of a plant rare to Illinois, Carex cherokeensis, or Cherokee sedge. It has been reported from only a few sites

in some southern Illinois counties; it is found here for the first time on the Forest. Thousands of plants were found in the

western part of the project area, primarily within or near roads. A plant with Forest Plan species viability evaluation

(SVE) is also found in the project area, the climbing milkvine (Matelea obliqua).

All Alternatives – All Effects

Federally or Regionally Listed Plants

Since no federally listed plants are known in the project area, we expect no direct or indirect effects to any under any of

the alternatives. No Regional Forester Sensitive plants are known to be present in the project area, so there should there

be no direct, indirect, or cumulative impacts to any from implementing any of the alternatives.

SVE Plants

There would be no direct or indirect impacts to climbing milkvine (Matelea obliqua), a Forest SVE plant, under

Alternative 1 because there would be no project actions. However, over time this plant could be threatened by the

spread of Nepalese browntop, an invasive grass, with infestations nearby.

There would be no direct impacts under Alternative 2 because this plant would be protected from mechanical activities

generated by the project. There would be largely beneficial indirect impacts with this alternative. Although Nepalese

browntop infestations would likely expand because of timber harvest activities, herbicide treatment of this grass to

protect Cherokee sedge (see below) would also protect climbing milkvine since it occurs next to some of the sedge

plants. Opening the forest canopy and expanding prescribed fire would also improve the habitat for this species.

Under Alternative 3, there would fewer direct impacts because there would be less disturbance than with Alternative 2

because timber would not be harvested. There would be both beneficial and adverse impacts with this alternative.

Opening the forest canopy and expanding prescribed fire would improve the habitat for this species. Nepalese

browntop would likely not spread as rapidly as with Alternative 2. However, it is expected to spread and out-compete

native herbaceous vegetation, possibly overwhelming the milkvine within the project area.

Implementing Alternative 1 would have no cumulative impacts to climbing milkvine, since there would be no direct or

indirect impacts. Nepalese browntop would continue to spread slowly and might eventually out-compete and cause the

extirpation of the milkvine in the project area. Under Alternative 2, there would be beneficial impacts to this species

because its habitat would be improved, and Nepalese browntop infestations near it would be controlled. Under

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Alternative 3, habitat for climbing milkvine would improve, but it would likely be out-competed and eventually

extirpated with the uncontrolled spread of Nepalese browntop.

Other Rare Plants

There would be no direct or indirect impacts to Cherokee sedge (Carex cherokeensis) under Alternative 1 because there

would be no project actions. However, over time this plant could be threatened by the spread of Nepalese browntop,

which has infestations near most of the Cherokee sedge plants within the project area.

Under Alternative 2, adverse direct and indirect effects to Cherokee sedge would largely be prevented. There would be

some adverse direct effects. Roads would be realigned to avoid most locations of the plants, protecting the majority of

the population. However, some plants would be damaged or destroyed. There would be few adverse indirect effects.

Nepalese browntop infestations near sedge plants would be controlled by the application of grass-specific herbicide

(sethoxydim and/or clethodim). This would prevent that invasive grass from out-competing the Cherokee sedge

population.

Under Alternative 3, there would be less disturbance than under Alternative 2 because timber would not be harvested.

So there would be less direct impacts to Cherokee sedge. There could be adverse indirect impacts. Nepalese browntop

would spread more rapidly with disturbance caused by project actions. This grass would expand more rapidly and out-

compete native vegetation, including this sedge.

Implementing Alternative 1 would have no cumulative impacts to Cherokee sedge, since there would be no direct or

indirect impacts. Nepalese browntop would continue to spread slowly and might out-compete of the sedge in the

project area, reducing the population within the project area. Under Alternative 2, there would be beneficial cumulative

impacts because the Cherokee sedge population would be protected long-term from the spread of Nepalese browntop.

Under Alternative 3, there would be adverse cumulative impacts. Infestations of Nepalese browntop would expand

more rapidly than with Alternative 1 and would be uncontrolled by herbicide. Cherokee sedge plants within the project

area would be out-competed by this grass. The population would be reduced and may eventually be extirpated.

Forest Vegetation

The pine stands in the project area are a mosaic of relatively dense trees that dominate the canopy. The midstory—

growth greater than 4.5 feet high and up to the crowns of the overstory—includes mostly native hardwoods like oaks,

hickories, sassafras, tulip poplar, maple, ash, elm and others. The understory is a mix of native and non-native hardwood

trees, shrubs and woody species. Past management in the area includes a thinning of the pine in 1990 that opened the

canopy and allowed hardwood species to become established in the understory; 371 acres have been burned several times

over a 10-year period. Based on the presence of oak and hickory seedlings and saplings, this past disturbance was effective

in encouraging the establishment of native hardwoods.

Existing overstory-tree densities average about 110 mature pines per acre (about 90 square feet BA). Most overstory pines

appear to be in good health and continue to expand their crowns into unoccupied space or mesh with adjacent pine

crowns, increasing the amount of shade to the forest floor. Past thinning was not uniform across the stand: some areas

were thinned more heavily than others. In areas thinned heavily, ample sunlight is available and the native hardwood

seedlings and saplings are larger and have fuller crowns. Regeneration surveys show numerous oak, hickory and other

native seedlings and saplings in the stands at an average density of about 228 oak and hickory seedlings/saplings per

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acre. This advanced hardwood regeneration is important to ensure the successful establishment of the hardwoods.

Conversely, in areas thinned lightly, the resulting crown-closure is higher and less sunlight reaches the floor. In these

areas, partial or complete overstory crown-densities provide sufficient shade to inhibit desirable native tree species. The

limited sunlight reaching the forest floor retards the growth and persistence of existing oak and hickory seedlings and

saplings.

On Invasive Plants in the Project Area:

Note that invasive plants are non-native to the ecosystem under consideration.

Several invasive plant species have been recorded in and around the project area, the most aggressive being Oriental

bittersweet and Nepalese browntop. (A comprehensive discussion of these invasives as they relate to the proposal can be

found in the Invasive Plants Working Paper in the project record.) Our primary concern with invasive plants is the

possibility that reducing the pine overstory could lead to increased densities of invasive and undesirable understory

plants. These could out-compete native vegetation including oak, hickory and other hardwood seedlings and saplings,

resulting in reduced hardwood sapling survival and slower hardwood regeneration rates.

As we analyze this proposal we are familiar with the best science available on the Nepalese browntop and its effects on

forests. We note in this section the effect the alternatives could have on the invasive species, as well as the effect the

invasive species could have on the success of the alternatives.


The effect of taking no action would be continued growth of overstory and midstory tree crowns, increasing shade to

the ground. Shade-tolerant tree species in the understory would continue to develop, further increasing the shade.

Many developing oaks and hickories would be suppressed or die due to lack of sunlight. The lifespan of shortleaf pine

can vary depending on site conditions; but it is possible for the pine in the project area to continue dominating the

overstory for another 100-200 years (Guyette et al. 2007). Data from Union County, Illinois indicate native shortleaf pine

ranging from 177-275 years old (Silviculture Working Paper). As individual pines die, shade-tolerant species rapidly

respond to the increased sunlight to the forest floor, filling in gaps in the canopy created by the dead trees. The slower-

growing oaks and hickories would also respond to the increase in sunlight, but they do not compete well with the shade-

adapted species, which would eventually dominate the site, shading out most of the oaks, hickories and other more

desirable species (Johnson, Shifley and Rogers 2002). Some shortleaf pine regeneration could occur on the margins or

within the stand if sunlight and soil conditions are favorable.

Based on typical stand dynamics and development, within 20 years the overstory crowns of pine would have developed

laterally, filling the open space between crowns and decreasing the sunlight to the forest floor. Midstory trees would

grow laterally and vertically. Where there is insufficient sunlight, oaks would be suppressed and many would die. The

midstory would eventually be dominated by maple, elm and other shade-tolerant species. The developing overstory and

midstory would increasingly provide more shade to the forest floor, favoring shade-tolerant species and limiting the

growth of trees requiring sunlight, such as oak and hickory.

In 50 years, the lateral growth of the overstory pine should have decreased substantially. Competition with adjacent

trees, insect damage, pathogens, windthrow, or a combination of these factors, would have caused some of the pine

overstory to die. The midstory trees should be about 40-60 feet tall and respond to any opening in the canopy,

increasing lateral growth and the amount of shade on the forest floor. Shade-tolerant trees would dominate the

midstory. The developing overstory and midstory would increasingly provide more shade to the floor, limiting the

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growth of trees requiring sunlight. In 100 years midstory trees would have grown to the height of the existing pine,

filling holes in the canopy. Individual oaks and hickories would maintain dominance where adequate sunlight exists. The

overstory species would be pine, shade-tolerant hardwoods and some oak and hickory. The midstory and understory

would be dominated by plants adapted to dense shading (Pierce et al. 2006; Zaczek et al. 2002).

This alternative would have no direct effects on forest-floor native vegetation because there would be no actions.

Indirectly, native vegetation in most of the project area would likely continue to be threatened by invasives in the long

term. The application of prescribed fire on about 300 acres of the project area provides a limited degree of native plant

restoration and control of some invasives. Invasives will continue to spread to some degree throughout the project area

whether or not pines are harvested.


The removal of overstory pine trees using a shelterwood harvest method would result in an increase of sunlight to plants

in the understory. This would encourage the health and vigor of existing, native hardwood species such as oaks and

hickories. Additionally, conditions for germination should also improve, adding to existing stocking levels. An example of

effective overstory removal can be observed in the One-Horse Gap area, where a similar cutting regime has been

successful in promoting the growth and regeneration of desirable native hardwood species (Figures 6 and 7).

We would continue to apply prescribed fire to temporarily remove the ground-surface litter, providing conditions

conducive to the regeneration of oaks and hickory. Acorn germination occurs most successfully on mineral soil with a

thin layer of leaf-litter (Van Lear and Watt 1992). This would allow for continued recruitment of oak and hickory

seedlings. Repeated fire would also reduce or kill some species that compete with the oak and hickory community-type

(Brose et al. 1999) and limit the development of pine in the stand. Shortleaf pine seedlings could re-sprout; but, as

seedlings, would compete poorly with hardwood stems with larger, established root systems. Disturbance from logging

could damage or kill some understory trees. Oak would re-sprout from damaged stems, maintaining their presence in

the stand. Others, primarily shade-tolerant species less inclined to sprout, may die, increasing direct and indirect

sunlight to the ground. The post-harvest activity of cutting small-diameter, shade-tolerant trees and invasive species

would further reduce competition.

The appearance of the stands will change with harvest. The dense pine overstory that is prohibiting the growth of shade-

intolerant oak and hickory tree species (Figure 8) will be greatly reduced. The harvest will allow ample sunlight to reach

existing shade-intolerant tree species on the forest floor (Figure 7). The effects of harvesting will be apparent with

logging-slash, skid-trails and log-landings clearly visible throughout the harvesting area. The visual appearance of

harvesting is short-term, lasting through the first growing season. Figure 8 shows a stand in the One Horse Gap area

which was harvested to approximately 40 basal area, what is being proposed for this project. In approximately 20 years

the seedlings and saplings on the forest floor will have responded to the increased sunlight and have grown to 20-30

feet in height.

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Figure 7. View of new shelterwood harvest area. Figure 8. View of shelterwood harvest area following three

seasons.

Under this alternative, based on typical stand dynamics and development, within 20 years, without the overstory-

removal cut, the overstory of pine crowns would be about 10 to 30 feet apart, allowing a substantial amount of sunlight

to reach the midstory and forest floor. The midstory would be comprised of a diverse mix of oaks, hickories and others

such as maple, elm, ash and tulip poplar. These trees would have developed from lower, midstory trees and

seedlings/saplings responding to the increased sunlight. The understory would contain a mix of shade-intolerant and -

tolerant seedlings and saplings. With overstory-removal the stand would be 20-30 feet tall and comprised of a diverse

mix of oaks, hickories and others such as maple, elm, ash and tulip poplar.

Within 50 years, without the overstory removal cut, the diverse midstory would be about 40-60 feet tall and growing

into gaps in the canopy created by the shelterwood harvest and any additional die-off of the remaining pines. The

developing midstory would increasingly provide more shade to the forest floor, limiting the growth of trees requiring

sunlight. We would apply periodic prescribed fire to reduce the number of shade-tolerant species and favor sun-loving

species. In 100 years the midstory would have grown to the height of the existing pine, filling in holes in the canopy created

by past management and individual pine mortality. The overstory would be a diverse mix of oak, hickory, maple, elm, ash

and others including pine. The composition of the midstory and understory would depend on what future management

actions occur on the site, with prescribed fire and timber stand improvement favoring the oaks and hickories. With

overstory removal the stand would be comprised of a diverse mix of oaks, hickories and others such as maple, elm, ash

and tulip poplar.

Implementation of this alternative would most likely encourage the aggressive spread of Nepalese browntop throughout

the project area. The expansion of prescribed burning along with increased disturbance from logging, timber hauling,

the creation of vernal ponds and road reconstruction and maintenance will greatly increase disturbed sites for this plant

to invade. As noted above, at the nearby Harris Branch hardwood restoration project area Nepalese browntop has

rapidly spread after timber harvest. The spread of this grass could reduce the survival and recruitment of oak seedlings.

Planned erosion-control measures could reduce disturbance to a degree, however, and slow the spread of this invasive.

Under this alternative, oriental bittersweet also has the potential to spread aggressively. Although located in an area

that will not be harvested or disturbed, its seeds could nonetheless spread throughout the disturbed area, allowing

expansion of the infestation. Autumn olive and black locust could spread more rapidly into disturbed areas, although not

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as aggressively as Nepalese browntop or oriental bittersweet. Japanese honeysuckle and multiflora rose are invasive

species that could spread into areas disturbed by pine removal, but the application of prescribed fire has been shown to

be an effective tool in controlling or reducing the spread of these species.

The Japanese chaff flower, an aggressive invasive new to the United States, could increase its spread into the project

area following the disturbance of pine removal. However, we expect that the application of prescribed fire could inhibit

the spread, as could the rapid expansion of Nepalese browntop. There are several other invasive species in the project

area that are likely to spread only moderately following pine removal.


Implementation of this alternative is likely to have similar effects as Alternative 2 by increasing sunlight to seedlings and

saplings on the forest floor in the short or long term. This alternative is expected to be slightly less beneficial than the

proposed action for promotion of the oak and hickory component, due to a slight decrease of sunlight reaching the

forest floor because of the pine logs and undisturbed pine tops shading the forest floor. Since less logging-disturbance

would occur that could kill or damage young shade-tolerant seedlings and saplings, a larger component of shade-

tolerant species is expected to remain, increasing their potential to compete with oak and hickory seedling and saplings.

Consequently, the stand would develop with an increase in shade-tolerant seedlings decreasing the degree to which the

project would meet the ecological restoration goals of the purpose and need. Prescribed fire would continue as

proposed in Alternative 2, although burning in treated pine stands would be delayed due to the increase in fuel loading.

All Alternatives – Cumulative Effects

Because the effects of the proposed action on vegetation resources would be restricted to the stands, there would be no

cumulative effects beyond the stands. With the exception of prescribed burning that was approved in an earlier

decision, no other management actions by the Forest, other agencies or private individuals are anticipated to have any

effect on vegetation resources within the project area (Silvicultural Working Paper).

The application of prescribed fire would generally benefit the oak and hickory component of the stand, as these species

are adapted to re-sprout in response to fire. Without disturbance in the canopy, however, oak and hickory seedlings are

not likely to grow out of the understory. The cumulative effect of prescribed fire with the crown-disturbing activities of

either action alternative is expected to favor oak and hickory recruitment into the overstory (Silvicultural Working Paper

and Fire and Fuels Report). The degree of benefit over the long term improves greatly if the two treatments are applied

in close succession.

Commercial timber harvest, or cut-and-leave-on-the-ground, will increase the amount of fuel on the site that

contributes to fire intensity when burned. The largest material produces the most intense fire. In places where this

material exists in quantity, the heat produced from its burning could kill adjacent reproduction of all species, decreasing

the effectiveness of stand treatments. Fire managers can plan the initial burning after cutting so that the fuel moisture in

large logs is high enough to limit fire-intensity. The leaf litter, needles, seedlings, small saplings and small branches (1-,

10-, and 100-hour fuels) would be consumed in a fire, but larger limbs and logs (100-1000-hour fuels) would not burn to

a significant degree. Such conditions are present for only a brief time each year and implementing at just the right time

is operationally difficult. Thus, by attempting to limit fire-intensity, we decrease the likelihood that the area will be

burned at a time when shade-tolerant reproduction is small enough to be negatively affected by fire. Cutting and leaving

the trees would create these heavy fuel loads immediately.

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The increased fuel-loading from felled trees could serve to delay the reintroduction of fire into the stand for as long as 10-

15 years. Prescribed burning in those early years would most certainly kill oak and hickory seedlings and saplings below the

root collar due to the intense heat. It is also expected that the intense fire would kill some of the native hardwood and non-

native pine in the residual overstory, potentially reducing the basal area per acre of live trees to an unacceptable

degree. Avoiding the impacts of intense fire by not burning in the first years after treatment would likely result in the

continued dominance of shade-tolerant trees.

Heritage Resources

The primary issue 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. The project area has been inventoried in the past and re-inventoried using

the most current field methods to ensure that all sites were recorded. There are 24 archaeological sites within or near

the project area. Thirteen sites are the remains of farmsteads, two are the remains of historic mining complexes, one an

historic cemetery, a multi-component historic and prehistoric artifact scatter and three historic isolated finds consisting

of isolated wells/cisterns and isolated artifacts.

Seven farmsteads have been determined to be potentially eligible for inclusion on the National Register of Historic

Places (NRHP), as is the multi-component artifact scatter which consists of both historic artifacts as well as prehistoric

lithic artifacts. However, six historic farmsteads are not considered to be eligible for inclusion on the NRHP; they appear

to have been damaged by past management activities prior to their protection under the 1966 National Historic

Preservation Act. Both the historic and prehistoric isolated finds are not considered to be eligible since recording their

location exhausts their research potential. The mining complexes are also not considered to be eligible for listing:

recording their location and surface features exhausts their ability to contribute meaningful information regarding the

economic history of the region. The historic Watters Cemetery is not considered eligible because it does not contain the

grave of a historical figure of outstanding importance.


There will be no direct, indirect or cumulative effects on heritage resources as a result of the implementation of this

alternative because no hardwood restoration activities would occur and, therefore, earth-disturbing activities would not

take place.

Alternatives 2 and 3 – All Effects

There will be no direct effects on heritage resources as a result of the implementation of an action alternative. Eight

sites potentially eligible for inclusion on the NRHP are near to, but not included in, the cutting units and will be avoided

during all earth-disturbing activities: the project will be redesigned to exclude each potentially eligible site, and a 50-foot

buffer will be placed around each site boundary with directional felling of trees away from the site to protect all intact

surface and subsurface cultural deposits. No potentially eligible sites will be affected by earth-disturbing activities (tree

felling, skidding, road maintenance or log-landing activities). No indirect effects are anticipated on sites in the project

area.

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Because there are not expected to be adverse effects (direct or indirect) to the archaeological resources as a result of

the actions proposed in any of the alternatives, there would be no resulting cumulative effects.

Recreation

In the project area, recreational uses of the Forest include horseback-riding, hunting, hiking, fishing, mushroom

gathering, wildlife viewing, driving for pleasure and dispersed camping. Some use of all-terrain vehicles, both authorized

and not, also occurs.

Roads and Trails

Approximately 2.5 miles of the River-To-River Trail crosses the project area, from Karbers Ridge in the north to County

Road 12 in the west. The trail is designated for hiker and equestrian use. The section of the trail in the project area is

part of a longer stretch recently designated to connect Elizabethtown with Karbers Ridge. The majority of the trail

follows road beds and Forest Service Roads. All of the roads are native surface (soil), with remnants of sections once

graveled. The majority of the road culverts remaining are non-functional, collapsed or plugged with debris. Vegetation

has encroached into most of the road corridors, blending sections back into the surrounding forest. The trail segment

south of the project area, connecting Roads 1793 and 1462, is difficult to find; there is no old road bed to follow, an ATV

path connects the two roads. Other than the natural beauty of the surrounding forest along the trail in the project area,

there are no destinations to attract large groups of trail users. During a recent field survey, there was little evidence of

hiker or equestrian traffic on the section within the project area.

Big Creek

Big Creek is a Candidate Recreational River under the National Wild and Scenic River Act. Recreational Rivers are “Those

rivers or sections that are readily accessible by road or railroad, that may have some development along their

shorelines, and that may have undergone some impoundment or diversion in the past” (Appendix D – FEIS Forest Plan

page 70). Big Creek flows through the project area for approximately two miles; it is managed under the Candidate Wild

and Scenic River (CR) Management Area Prescription of the Forest Plan. Management activities that may be seen include

prescribed burning, trails maintenance, recreational facility maintenance and non-native invasive species control (Forest

Plan, page 52).

For a river to be eligible for designation to the National System, one or more of the following values within the river area

must be outstandingly remarkable:

Scenic

Recreational

Geological

Fish and Wildlife

Historical

Cultural

Other, including ecological values

The outstandingly remarkable values related to Big Creek are described in Table 8. In accordance with the Forest

Plan standards and guidelines for CR Management Prescription, the outstandingly remarkable values of Big

Creek must be maintained.

Table 8. Outstandingly Remarkable Values Related to Big Creek.

Value Description

Recreational Fishing, hiking, wildlife watching; floatable near the Ohio River.

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Table 8. Outstandingly Remarkable Values Related to Big Creek.

Value Description

Geological Karst topography

Aquatic Two endangered crayfish, spring cavefish (rare), smallmouth bass

Wildlife River otter, Red-shouldered hawk

Historic Illinois Iron Furnace National Historic Site

Cultural Fluorspar mining

Other One of the few remaining spring-fed streams in Illinois.


No management activities associated with the proposed action would take place. Little if any Forest resources

would be used to improve or maintain the section of the River-to-River Trail within the project area, as it is not a

heavily used route for Forest visitors. Trail maintenance of this section would mostly be on a three- to five-year

rotation as assigned in the Trail Maintenance Plan. Hunting would continue to decline in this area as native oak

and hickory mast would be reduced due to the presence of pine. There would be no direct or indirect effects on

recreation, so no cumulative effects on recreation.


Project activities could directly affect recreation by causing congestion on area access routes, displacing visitors,

or creating unwanted noise. For the typical dispersed recreation pursuits in the area, such as hiking, hunting and

fishing, it is expected that visitors will be able to avoid project activities. Project activities could affect hunters,

although the lack of deer hunting camps indicates that this portion of the forest is less intensively hunted than

others; therefore, the rate of displacement of hunters is likely to be minimal. Installation of a River-to-River Trail

crossing of Big Creek could cause temporary sedimentation, but a proper crossing would result in not only a

safer means of equestrians and hikers crossing the creek, but reduce the sedimentation load to the stream.

There should be no deterioration of the stream potential classification. The improvements to the routes needed

for the project’s proposed activities will likely increase the ease of access for forest users. Implementation would

improve Big Creek habitat quality in the long term; but, since the Forest has no control of activities upstream of

the area, sediment would continue to be carried into the area.


Project activities could directly affect recreation by causing congestion on area access routes, displacing visitors,

or creating unwanted noise. For the typical dispersed recreation pursuits in the area, such as hiking, hunting and

fishing, it is expected that visitors will be able to avoid project activities. Project activities could affect hunters,

although the lack of deer hunting camps indicates that this portion of the forest is less intensively hunted than

others; therefore, the rate of displacement of hunters is likely to be minimal. Installation of a River-to-River Trail

crossing of Big Creek could cause temporary sedimentation, but a proper crossing would result in not only a

safer means of equestrians and hikers crossing the creek, but reduce the sedimentation load to the stream.

There should be no deterioration of the stream potential classification. The improvements to the routes needed

for the project’s proposed activities will likely increase the ease of access for forest users. Implementation would

improve Big Creek habitat quality in the long term; but, since the Forest has no control of activities upstream of

the area, sediment would continue to be carried into the area.

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Agencies and Persons Consulted

U.S. Fish and Wildlife Service: Matt Mangan, Kraig McPeek, Kristen Lundh

Illinois Department of Natural Resources

Illinois Environmental Protection Agency

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FINDING OF NO SIGNIFICANT IMPACT I, the responsible official, have evaluated the environmental effects of the project disclosed in the

environmental assessment (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. As a result, 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 project area, the Ramsey Branch pine

stand. Implementation of the proposed action would achieve multiple-resource benefits and make progress

towards the Desired Future Condition for the Even-Aged Hardwood Management Area described in the Forest

Plan. It includes activities that work towards meeting Forest Plan goals and objectives for restoring and

maintaining the oak-hickory hardwood forest-type. The proposed project involves a limited, focused action in a

discrete area 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 project area.

Intensity

Intensity is a measure of the severity, extent, or quantity of effects as disclosed in the environmental assessment

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 effects, 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.

The environmental effects are discussed in the Affected Environment and Environmental Consequences

section of the EA, pages 19-48.

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

environmental assessment. Public health and safety will not be adversely affected by implementation of

the proposed action. The removal of pine should pose no risk to the public. The environmental effects

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are discussed in the Affected Environment and Environmental Consequences section of the EA, pages

19-48.

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).

There are no unique characteristics in the geographical area, such as heritage resources, park land,

prime farmland, wetlands, wild and scenic rivers, or ecologically critical areas that would be significantly

affected by the action. The environmental effects are discussed in the Affected Environment and

Environmental Consequences section of the EA, pages 19-48.

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 the involvement of Forest resource specialists, other agencies and the public, I do not find the

anticipated effects of this action on the quality of the human environment to be highly controversial.

This does not mean that the decision to proceed with the project will be acceptable to all people, as

some may not agree with the decision to harvest pine trees. However, it is my professional judgment

that physical, biological, social and economic issues have been addressed. The environmental effects are

discussed in the Affected Environment and Environmental Consequences section of the EA, pages 19-48.

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 environmental effects are discussed in the Affected Environment and Environmental

Consequences section of the EA, pages 19-48.

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).

This action does not establish a precedent for future actions with significant effects or represent a

decision in principle about a future consideration. The action is consistent with the 2006 Forest Plan.

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. Compliance with the project design criteria will ensure that any direct and

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indirect effects from 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.The

environmental effects are discussed in the Affected Environment and Environmental Consequences

section of the EA, pages 19-48.

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).

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

none are present in the project area. Heritage resources are discussed on pages 45-46 of the EA.

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 biological evaluation of the proposal determined that current or proposed federally listed

threatened or endangered species would not likely to be adversely affected by this action. The

environmental effects are discussed in the EA, pages 19-48.

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 development of the proposal and analysis and confirmed that the proposed action is

consistent with the Forest Plan.

The effects analysis in the environmental assessment considered both the context and intensity of the proposed

action. Based upon the analysis, I have determined that the selected alternative will not significantly affect the

human environment. Consequently, an environmental impact statement will not be prepared.

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REFERENCES

Alban, D.H. 1977. “Influence on soil properties of prescribed burning under mature red pine.” USDA Forest Service, Research Paper NC-139. North Central Forest Experiment Station, St. Paul, Minn.

Amacher, Michael C. and Katherine P. O’Neill. 2004. Assessing Soil Compaction on Forest Inventory & Analysis Phase 3 Field Plots Using a Pocket Penetrometer. USDA Forest Service, Research Paper RMRS-RP-46WWW. Rocky Mountain Research Station.

Brose, Patrick H., David H. van Lear, Patrick D. Keyser. 1999. “A Shelterwood-Burn Technique for Regenerating Productive Upland Oak Sites in the Piedmont Region.” South. J. Appl. 16(3):158-163

Burger, J. A., V. Perumpral, R. E. Kreh, J. L. Torbert and S. Minaei. 1985. “Impact of Tracked and Rubber-Tired Tractors on a Forest Soil.” American Society of Agricultural Engineers, 28(2):369-373.

Durkin, Patrick. 2001. Sethoxydim (Poast)—Human Health and Ecological Risk Assessment: Final Report. Syracuse Environmental Research Associates, Inc., Fayetteville, N.Y.

Durkin, Patrick. 2007. Preparation of Environmental Documentation and Risk Assessments for the USDA Forest Service. Syracuse Environmental Research Associates, Inc., Fayetteville, N.Y.

Durkin, Patrick. 2014. Scoping/Screening Level Risk Assessment on Clethodim: Final Report. Syracuse Environmental Research Associates, Inc., Manlius, N.Y.

Durkin, Patrick R. and G. Diamond. 2002. Neurotoxicity, Immunotoxicity and Endocrine Disruption with Specific Commentary on Glyphosate, Triclopyr and Hexazinone: Final Report. Syracuse Environmental Research Associates, Inc., Fayetteville, N.Y.

EXTOXNET (Extension Toxicology Network). 1996. Pesticide Information Network—Sethoxydim. Oregon State University.

Guyette, Richard P., Rose-Marie Muzika, Stephen L. Voelker. 2007. “The historical ecology of fire, climate, and the decline of shortleaf pine in the Missouri Ozarks.” In: Kabrick, John M., Daniel C. Dey, David Gwaze, eds. Shortleaf pine restoration and ecology in the Ozarks: proceedings of a symposium; 2006 November 7-9; Springfield, MO. Gen. Tech. Rep. NRS-P-15. Newtown Square, PA: U.S. Department of Agriculture, Forest Service, Northern Research Station: 8-18.

Hall, Gill. 2009. “Toxicology of Smoke Inhalation,” Fire Engineering Magazine.

Hardy, Colin C., Roger D. Ottmar, Janice L. Peterson, John E. Core, Paula Seamon, eds. 2001. “Smoke Management Guide for Prescribed and Wildland Fire, 2001 Edition.” National Wildfire Coordination Group, December 2001.

Hatchell, G. E. and C.W. Ralston. 1971. “Natural Recovery of Surface Soils Disturbed in Logging.” Southeastern Forest Experiment Station, USDA Forest Service, 2292: 5-9.

Huffman, Tedd. 2009. Prescribed Burn Smoke Monitoring—2009. Shawnee National Forest Cedar Grove Prescribed Burn.

Johnson, P. S., S. R. Shifley and R. Rogers. 2002. The Ecology and Silviculture of Oaks. CABI Publishing International, Oxford. 528 p.

Kozlowski, T.T. 1999. “Soil Compaction and Growth of Woody Plants,” Scandinavian Journal of Forest Research, 14:6, 596-619.

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McMahon, Charles K. and Parshall P. Bush. 1992. “Forest Worker Exposure to Airborne Herbicide Residues in Smoke in Prescribed Fires in the Southern United States,” American Industrial Hygiene Association Journal, 53/April 1992.

Neary, D.G., K.C. Ryan, L.F. DeBano, eds. 2005. Wildland fire in ecosystems: effects of fire on soils and water. USDA Forest Service Rocky Mountain Research Station. RMRS-GTR42.

Page-Dumroese, D.; A.M. Abbott, T.M. Rice. 2009. USDA Forest Service Soil Disturbance Monitoring Protocol, Volume 1 – Rapid Assessment. FS-WO-82a. Moscow, ID: USDA Forest Service Rocky Mountain Research Station. Found on-line at: http://forest.moscowfsl.wsu.edu/smp/solo/documents/GTRs/WO_82/SoilMonProtocol_GTR-WO-82a.pdf.

Page-Dumroese, D.; A.M. Abbott, T.M. Rice. 2009. Forest Soil Disturbance Monitoring Protocol, Volume 2 – Supplementary Methods, Statistics, and Data Collection. FS-WO-82b. Moscow, ID: USDA Forest Service. Found online at: http://forest.moscowfsl.wsu.edu/smp/solo/documents/GTRs/WO_82/SoilMonProtocol_GTR-WO-82b.pdf

Pierce, A, G. Parker, Kerry Rabenold. 2006. “Forest Succession in an Oak-Hickory-Dominated Stand during a 40-Year Period at the Ross Biological Reserve, Indiana. Natural Areas Journal, 26 , 351-359.

Sharkey, Brian. 1997. Health Hazards of Smoke—Recommendations of the Consensus Conference April 1997.

Shoaf, Antony R. and William C. Carlson. 1992. “Stability of Sethoxydim and Its Degradation Products in Solution, in Soil, and on Surfaces,” Weed Science, Volume 40:384-389.

Tu, M., C. Hurd, R. Robison, J.J. Randall. 2001. Sethoxydim: Weed Control Methods Handbook, The Nature Conservancy.

USDA FS. 2006. Shawnee National Forest Land and Resource Management Plan. Harrisburg, Ill.

USDA FS. 2006a. Final Environmental Impact Statement on the Shawnee National Forest Land and Resource Management Plan. Harrisburg, Ill.

USDA FS. 2012. National Best Management Practices for Water Quality Management on National Forest System Lands, Volume 1: National Core BMP Technical Guide. FS990a.

USEPA. 2006. Ecological Risk Assessments (www.epa.gov/oppefed1/ecorisk).

Van Lear, D.H. and P.R. Kapeluck. 1989. Fell and burn to regenerate mixed pine-hardwood stands: an overview of effects on soil. In: Waldrop, T. A., Proceedings of Pine-Hardwood Mixtures: A Symposium on Management and Ecology of the Type. Atlanta, GA. USDA Forest Service, Southeastern Forest Experiment Station, Asheville, N.C. p. 83-90, General Technical Report SE-58.

VanLear, D.H. and J.M. Watt. 1993. The role of fire in oak regeneration. In: Loftis, D.L., C.E. McGee, eds. 8-10 September 1992. Knoxville, Tenn: Proceedings, oak regeneration: serious problems, practical recommendations. Gen. Tech. Rep. SE-84. Asheville, NC: USDA Forest Service Southeastern Forest Experiment Station. pp. 66-78.

Woodward, A.A., A.D. Fink, and F.R. Thompson III. 2001. “Edge effects and ecological traps: effects on shrubland birds in Missouri,” Journal of Wildlife Management 65, 668-675.

Zaczek, James J., John W. Groninger, J.W. Van Sambeek. 2002. “Stand Dynamics in an Old-Growth Hardwood Forest in Southern Illinois, USA.” Natural Areas Journal 22(3):211-219.

http://forest.moscowfsl.wsu.edu/smp/solo/documents/GTRs/WO_82/SoilMonProtocol_GTR-WO-82a.pdf

http://forest.moscowfsl.wsu.edu/smp/solo/documents/GTRs/WO_82/SoilMonProtocol_GTR-WO-82a.pdf

http://forest.moscowfsl.wsu.edu/smp/solo/documents/GTRs/WO_82/SoilMonProtocol_GTR-WO-82b.pdf

http://forest.moscowfsl.wsu.edu/smp/solo/documents/GTRs/WO_82/SoilMonProtocol_GTR-WO-82b.pdf

http://www.epa.gov/oppefed1/ecorisk

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APPENDIX

Response to Comments

Best Available Science

1. The same stale, out-of-date, incomplete, inaccurate and biased statements are contained in this EA with virtually no consideration of how the environment and science have progressed in the last 30 plus years.

Response: We rely on the best-available science, along with years of management experience in southern

Illinois, to present a proposal that would accomplish the stated goals and meet the need for the action. The

scientific information used in project development is documented in the record and summarized in the

environmental assessment. The interdisciplinary team relied on published science, as well as field observation

and information gathered from other resource experts concerning oak-hickory, native-hardwood community

restoration by other landowners and nearby national forests. The team documented its methodology, rationale

and findings in the record. No scientific information has been presented to us that contradicts the findings of the

team on this issue.

Silviculture

2. There is little if any true scientific connection between heavy logging in the pine plantations and accelerated

and improved regeneration.

Response: The comment suggests that there is no scientific foundation for the proposed action when, in fact,

the project record documents that the proposal for the Lee Mine project is based on sound science. The

interdisciplinary team devoted considerable effort to gathering field data and reviewing published scientific

information. In addition, the team was aware of the published scientific research studies that were relied on

during development of the 2006 Forest Plan and the 2006 final environmental statement on the Forest Plan,

which clearly describe the desired condition and the science behind the shelterwood harvest method. As noted

in the record, research and site-specific analysis of the field information clearly demonstrate that oaks, hickories

and other plants in an oak-hickory community require sunlight to maintain their presence in a stand (Abrams

1992 as cited in Barret 1995). Additionally, research has determined that prescribed fire is beneficial in the

establishment of oaks and hickories (Van Lear and Johnson 1983).

As referenced in the environmental assessment (page 42), Brose et al. (1999) concluded that, with a

shelterwood-burn prescription, oak regeneration can be successful on productive sites by removing less fire-

resistant competitors. The Lee Mine project area is a productive site that fits this description. Similarly, Van Lear

and Watt (1992) recognized the role of fire and its influence on oak when they found that fire plays an

important role in shaping the composition and structure of many forest ecosystems. Many other studies have

shown similar evidence for the role of fire in developing and perpetuating oaks (Franklin et al. 2003, Abrams

2005, Brose et al. 2005 and Groninger et al. 2005).

The proposal for hardwood restoration follows guidance provided by the studies mentioned above. The need for

management is identified in the environmental assessment (page 8) and described in the proposed action (page

8). The proposed action is consistent with the Even-Aged Hardwood management prescription in the Forest Plan

(page 59) which states “oak and hickory and associated understory dominate” and addressed in the Forest Plan

FEIS (pages 101 and 102). Additionally, the FEIS (page 110) described the use of the shelterwood system and its

effectiveness in managing for a shade-intolerant, hardwood forest.

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3. Letting the pines regenerate naturally is the superior way, and the most environmentally protective way, to

have the forest convert from plantation to a natural forest.

Response: The Forest Plan FEIS (page 113) and project analysis acknowledged that most pine stands will

eventually convert to a mixed pine-hardwood forest without management (see “No-Action” Alternative, page

18). The shortleaf pine in the project area is about 70 years old; the species has been documented to live over

200 years. While the non-native shortleaf pine is outside of its native range, the interdisciplinary team

nonetheless reasonably concluded that the pine in the project area could attain approximately the same age

(200 years) since it is growing in the same climatic range. During this time, shade-tolerant species in the mid-

story would continue to develop and eventually dominate the stand. Shade-intolerant trees—oak, hickories and

other sun-loving species—would be suppressed; many would die (page 18). The comment refers to a “natural

forest”; which in this scenario would a mixed pine-hardwood forest of shade-tolerant species. The desired

condition and need for this proposal are to move the project area toward a native, oak-hickory (shade-

intolerant) hardwood forest community.

Prescribed Fire

4. The rhetoric about the benefits of prescribed fire has a similar lack of science and truth. Not only that, but

there is scant attempt to give a true analysis of the adverse effects of burning.

Response: Besides the beneficial effects of prescribed fire in advancing the restoration or maintenance of the

oak-hickory hardwood forest-type, the general effects of prescribed fire are the same under any application on

the Forest. Its effects on soil erosion and nutrient loss are related to the severity of the burn. These effects are

complex and depend on a variety of factors, but certain generalizations are relatively consistent.

As is stated on page 30, burning has the most pronounced effect on the forest floor, where carbon, nitrogen and

sulfur are volatilized, and calcium, magnesium, potassium, phosphorus and other elements are left as ash. The

ash is leached by rainfall into the mineral soil, which increases its base saturation and pH (Alban 1977).

Increased nutrient availability at higher pH’s may result in beneficial plant responses following fire (Van Lear and

Kapeluck 1989). The beneficial response of plants leads to less soil erosion because plants hold the soil and slow

the impact of rainfall. These findings coincide with results from a variety of other reviews and studies (DeBano

et al. 1998, Liechty et al. 2004, and Neary et al. 2005).

We do not expect low-intensity prescribed fire to have an adverse effect on the quantity of water-flow, nutrient

budgets, or soil quality over the long term. Prescribed fire can reduce organic-matter content and increase the

loss of soil organisms through erosion. However, monitoring data from prescribed fires on the Forest show that

an average of one to two centimeters of litter is consumed, with the majority unburned (Fire Monitoring 2009).

Repeated fires may be necessary to achieve multiple-use objectives: the control of invasive and mesophytic

species to allow oak establishment. Forest burns are typically low-intensity–low-consumption burns. Burning

that achieves variable consumption in mosaic patterns can provide substrate and habitat for microbial re-

colonization following a fire. Monitoring shows this pattern in Forest burns (RxFire Monitoring 2010).

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Carbon

5. There is no real analysis of the carbon cycle and how removing carbon from the forest through removing trees

and releasing stored carbon through burning and soil disturbance.

Response: This analysis is tiered to the 2006 Final Environmental Impact Statement on the Forest Plan, which

addressed this issue at the appropriate programmatic level (pages 196-197) (USDAFS 2006). There was no

project-level discussion of this issue since no project-level effects could affect the carbon cycle in a meaningful

way.

Ecosystem Services

6. There is no analysis of the current ecosystem services being provided by the forest as it currently stands, and

no attempt to give a true balancing of alternatives.

Response: We agree that “ecosystem services” are natural assets provided by forests that are important to the

health and productivity of our environment. We do not agree that these services were ignored in the analysis of

the effects of the proposed action. The environmental assessment specifically looked at the potential effects of

the proposed alternatives on vegetation, wildlife, soil (including carbon sequestration), water, air quality,

heritage resources and socioeconomics. The no-action alternative examined the merits of not implementing the

proposed action in the project area. The ecosystem services of the project area were addressed in the

assessment. The purpose of our environmental analysis is to display the potential environmental effects of the

proposed action on these resources, or services. The environmental assessment’s analysis of these services was

appropriately tiered to the final environmental impact statement prepared for the Forest Plan.

In large part, this proposal was designed and developed specifically to enhance “ecosystem services,” including,

but not limited to, forest health, resilience to environmental stress and plant and animal community diversity.

As described in the environmental assessment (Chapter 3) and working papers, the adverse effects are short-

term and localized in scope. The beneficial effects of this action—increased diversity of trees, plants and

wildlife—are longer-term. The comment implies that monetary gain is the primary purpose for this action;

however, there is no evidence to support that supposition. The purpose here is not financial in nature. Instead,

the proposal is designed to move the project area towards the desired future condition and ensure the

sustainability of the oak-hickory native hardwood community.

Neither NEPA nor the Council on Environmental Quality regulations require that a monetary value be assigned

to environmental effects, specify a particular accounting methodology, or even require that all costs and

benefits be reduced to monetary values. Likewise, the National Forest Management Act and the Forest

Rangeland Renewable Resources Planning Act mandate no particular economic analysis technique. Additionally,

neither the National Forest Management Act nor NEPA requires site-specific analyses to provide a monetary

value for non-timber resources. “Nothing in the National Forest Management Act or the regulations the USFS

promulgated in 1982 requires site-specific analyses to monetize non-timber resources…Nor does NEPA require

monetized calculations of non-timber resources in timber sale economic analyses (Forest Conservation Council

v. United States Forest Service, Civ. No 05-35166, Ninth Circuit, October 5, 2006).

The National Forest Management Act established a two-step process for forest planning: First, the Forest

develops and maintains a land and resource management plan that guides the Forest to a desired future

condition and determines what outputs might be produced (see Forest Plan FEIS pages 303-308). Second, the

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Forest implements the Plan by developing site-specific actions such as the Harris Branch project that are

consistent with the Plan. As part of the first step, the Final EIS for the 2006 Forest Land and Resource

Management Plan (Plan) contained an economic analysis (FEIS pages 301-308). After weighing both

environmental and economic considerations at the programmatic level, the Forest Plan allocated different

management prescriptions to all portions of the Forest. As part of the second step, the project environmental

analysis incorporated a discussion of socioeconomic values (EA pages 42-44).

Forest Service internal policy and guidance manuals provide direction on economic analysis. The Manual states,

“The responsible line officer determines the scope, appropriate level, and complexity of economic and social

analysis needed” (Forest Service Manual 1970.6). The Responsible Official clearly has considerable discretion in

determining the appropriate level and type of economic analysis required for the project decision. The

interdisciplinary team took a hard look at ecosystem services and documented the potential impacts of this

project on these socioeconomic values, contrary to the comment’s claims. In addition, many of the associated

effects were considered in the Forest Plan FEIS.

Alternatives

7. There are only two alternatives - logging or not logging

Response: NEPA requires federal agencies to study, develop and describe appropriate alternatives to the

proposed action. Based on scoping and the purpose and need for the project, the Forest developed a reasonable

range of alternatives. NEPA regulations require federal agencies to “include the alternative of no action” in

environmental impact statements (40 CFR 1502.14[d]). Generally speaking, “no action” means that the activity

would not take place and the resulting environmental effects from taking no action are compared with the

effects of allowing the proposal to proceed (Forest Service Handbook 1909.15, 14.1 and CEQ “40 Questions”

guidance, 46 Fed. Reg. 18027). The intent of the no-action alternative is to provide a baseline for comparison.

The no-action alternative in this analysis depicts and describes the environmental effects of continuing the

status quo. The interdisciplinary team took a hard look at the environmental effects, focusing on the issues

found to be most important to the analysis: soil, water, wildlife effects and non-native invasive species

management (see EA page 9).

Informed and meaningful consideration of the no-action alternative was an integral part of this project analysis

(EA pages 18, 22-23, 29, 32-33, 35-36, 39-40, 41-42, 46, 47). NEPA does not require agencies to analyze

alternatives anticipating proposed matters pending before congress. The environmental assessment properly

considered the effects of no action (i.e., no tree-cutting or prescribed burning, Alternative 1), as well as no

commercial timber harvest (Alternative 3), and disclosed the environmental trade-offs. Thus, the environmental

assessment included an alternative—the no-action alternative—that considered the no-timber-harvest

alternative suggested in this comment (EA pages 9 and 13).

The Forest is keenly aware that the analysis of a reasonable range of alternatives is at the heart of this NEPA

analysis. Great care was taken to ensure that the proper range of alternatives was developed and examined,

based on issues raised during scoping and on the purpose and need for the action. A reasonable range of

alternatives was analyzed in the environmental assessment: the no-action alternative, the proposed action and

a no-harvest alternative.

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Economics

8. This project is for making money for the agency. It is even doubtful that it does that.

Response: The Forest Service discussed below-cost sales in a November 6, 2000 letter from Ann M. Bartuska,

Director, Forest and Rangeland Staff, subject: Forest Service Comments on the Report Entitled, “The Economic

Case against National Forest Logging.” Excerpts follow:

When a sale is offered, it is offered competitively—and the contract is normally awarded to the firm offering

the highest bid. These requirements have been imposed to help insure that the government is justly

compensated for any timber it sells. Arguments of a subsidy arise from the fact that the price the

government charges for timber is not always sufficient to cover its full costs of sale preparation and

administration…the Forest Service cannot always price its timber high enough to cover its full costs of

production, because if it did so–in some instances it would only succeed in driving itself out of the market–

which would compromise its ability to use timber sales as a management tool…

9. The only party that stands to make decent money is the timber buyer. This is a sad continuation of the under

and mis valuations that the agency puts on our forests.

Response: The interdisciplinary team was aware of the potential for below-cost action on the Forest in

conjunction with restoration activities since below-cost timber sales were discussed at the programmatic level in

the 2006 Forest Plan FEIS (Appendices page 197). At that time the interdisciplinary team for the programmatic

FEIS noted that, “We hope to make a profit on the timber that is sold from national forest lands; however, we

emphasize that the objective of any timber removal on the Forest is not the production of timber products, but

the creation of vegetative conditions that enhance wildlife habitat and maintain a healthy forest ecosystem.

Timber sales are a vegetative-management tool to help achieve these objectives.”

The need for this proposal is clearly set forth in the environmental assessment (page 8). This proposal is a

resource-restoration action. Efficiency and cost were considerations in project development, but not overriding

objectives or constraints (see Multiple-Use Sustained-Yield Act, 16 U.S.C. 531[a]). The issue of below-cost timber

sales to accomplish ecological restoration work is not a new issue. It has been thoroughly considered by the

Forest Service and the interdisciplinary team for this site-specific proposal. The team took a hard look at the

potential economic consequences of the project. This comment points to no information that the Forest

overlooked or ignored.

Watershed Resources

10. To somehow insinuate that you will allow intensive mechanical logging near Big Creek and improve it in the

process is nothing but agency fantasy. Any honest appraisal would and should find that the soil disturbance,

removal of shade, and air pollution and ash from burning and machinery is going to seriously degrade the

watershed.

Response: The protection and restoration of watershed health are primary objectives of the Forest Service and

we aim to improve watershed conditions during implementation of our projects. While short-term impacts of

three to five years are expected in the Big Creek watershed, sustained improvements are expected in the long

term (five to ten years). We expect the condition of the watershed to be improved by applying erosion-

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abatement measures to existing degraded roads, repairing and/or constructing up to 18 vernal ponds, and

establishing a vigorous understory to stabilize the soil.

We are aware that soil disturbance can result in sediment transport with the potential to degrade water quality,

which is why we will be employing the best management practices (BMPs) adopted by the IDNR and the USDA

Forest Service. A bare-soil exposure limit of 10 percent will be applied to each 150-foot linear segment within

designated filter-strips along perennial, intermittent and ephemeral streams, wetlands and ponds. To ensure

effectiveness, the BMPs will be in place during management activities and remain on site until conditions have

stabilized. See Table 1 of the EA for a description of BMPs included in the design criteria.

Old roads in the project area are presently unmaintained; some are the locations of a newly found rare plant on

the Forest. Those roads utilized or constructed during restoration activities will be improved with waterbars and

water-diversion structures to disperse flows and alter flow paths that could result in sediment transport. Water

quality will be further improved in the long term by repair of several degraded ponds and construction of new

vernal ponds that would detain stormwater, thereby reducing the volume and velocity of surface runoff, as well

as the amount of sediment entering surface waters.

The dense canopy of non-native pines in the project area has shaded out much of the understory. Low light-

levels have inhibited the natural hardwood ecosystem understory. The fine shallow roots of understory

vegetation play a major role in mitigating erosion from concentrated flows (Li et al., 1991; Gyssels et al., 2005).

Because the growth and reproduction of understory species is often light-limited in deeply shaded environments

(Chazdon, 1991; Shirley, 1945), one of the goals of the proposal is to alter the shady conditions in the project

area by removing the pine and allowing light to penetrate to the forest floor. Research has found a positive

correlation between the percentage of canopy opening and the percentage of understory vegetation cover

(Anderson et al., 1969).

Light is necessary for the establishment of a robust understory and the reproduction of native hardwoods. As

opposed to the evergreen non-native pine, the desired oak-hickory forest-type that we are managing for will

perpetuate the presence of an understory on account of its deciduous leaves, which permit a greater availability

of light throughout the year. Even during the summer months enough light filters through the canopy as sun

flecks to maintain a vigorous understory.

Air quality may be locally and temporarily affected by prescribed burning and the operation of heavy machinery

during restoration, but these effects are minimal to non-existent (Forest Plan FEIS, 2006). The Forest complies

with all federal (Clean Air Act) and state (Illinois Smoke Management Plan) laws and regulations. Prior to each

burn season an annual burn permit is obtained from the IEPA identifying the areas scheduled to be burned.

Individual burn plans are developed prior to each burn to ensure that appropriate actions are taken to disperse

smoke in a safe manner, with low emissions. Plans detail how smoke impacts are analyzed and mitigated for by:

a) estimating fuel loading, fuel consumption, and emissions; b) identifying smoke sensitive areas and potential

impacts; c) specifying techniques that may be employed to reduce impacts to those areas, and; d) determining

appropriate monitoring for smoke impacts.

All recent Air Quality Reports are reviewed prior to the burn to confirm attainment of state and federal ambient

air quality standards. A Standard Fire Behavior Fuel Models (Scott and Burgan, 2005) is used to predict fire

behavior and this information is translated to the Prescribed Fire Prescription. The prescription defines

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acceptable ranges for the following parameters: relative humidity, wind speed, wind direction, temperature,

fuel load, and time of year. These parameters are set to minimize negative impacts to potentially sensitive

receptors.

Air quality is monitored during all burns with monitoring kits and/or observations of smoke behavior. During a

large-scale burn, air-quality monitoring kits are strategically positioned downwind of the burn unit to capture

the highest concentration of pollutants and fine particulate matter. While impacts to air quality have been

observed during the burn, air quality generally returns to pre-burn conditions within hours or the following day.

To date there have been no violations of national ambient air standards.

lee mine hardwood restoration and habitat enhancement...

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