environmental assessment oconee range...

United States Environmental Assessment Department of Oconee Range Allotments Agriculture Forest Chattahoochee-Oconee National Forest Service Oconee Ranger District Southern Greene and Jasper County, Georgia Region August 2014 Responsible Agency: USDA Forest Service Responsible Official: Thomas Dozier, District Ranger For Further Information, Contact: Elizabeth Caldwell Wildlife Biologist (706) 485-7110 x 105 [email protected] or write to: Oconee Ranger District Chattahoochee-Oconee National Forest 1199 Madison Road Eatonton, GA 31024 USDA Nondiscrimination Statement The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, gender, religion, age, disability, political beliefs, sexual orientation, and marital or family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA's TARGET Center at 202-720-2600 (voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326-W, Whitten Building, 14th and Independence Avenue, SW, Washington, DC 20250-9410 or call (202) 720-5964 (voice or TDD). USDA is an equal opportunity provider and employer.

ENVIRONMENTAL ASSESSMENT

Oconee Range Allotment Project Oconee Ranger District

Chattahoochee-Oconee National Forest, Georgia

TABLE OF CONTENTS Table of Contents ............................................................................................................... ii List of Tables and Figures ................................................................................................... iii Chapter 1 – Purpose and Need for Action.......................................................................... 1 1.0 Introduction .................................................................................................... 1 1.1 Background ..................................................................................................... 1 1.2 Project Area Description ................................................................................. 2 1.3 Purpose and Need for Action .......................................................................... 2 1.4 Proposed Action Description .......................................................................... 2 1.5 Forest Plan Direction ....................................................................................... 3 1.6 Scope of the Environmental Analysis .............................................................. 5 1.7 Decision Framework ........................................................................................ 6 1.8 Public Involvement ......................................................................................... 6 Chapter 2 – Alternatives ..................................................................................................... 8 2.1 Introduction .................................................................................................... 8 2.2 Alternative Given Detail Study (including Proposed Action) .......................... 8 2.3 Features Common to All Action Alternatives ................................................ 11 2.4 Monitoring And Evaluation ........................................................................... 12 2.4 Alternatives Considered But Eliminated From Detailed Study ..................... 13 2.5 Comparison of Alternatives .......................................................................... 13 Chapter 3 – Affected Environment ................................................................................... 14 3.0 Introduction .................................................................................................. 14 3.1 Presence or Absence of Resources ............................................................... 14 3.2 Vegetation ..................................................................................................... 15 3.3 Soil and Water ............................................................................................... 19 3.4 Climate Change and Carbon Storage ............................................................ 36 3.5 Threatened, Endangered, Sensitive (TES) and Locally Rare Species ............. 37 3.6 Management Indicator Species and Demand Species .................................. 38 3.7 Non-native Invasive Plant Species (NNIS) ..................................................... 40 3.8 Heritage Resources ....................................................................................... 42 3.9 Recreation ..................................................................................................... 44 3.10 Public Health and Safety ............................................................................. 44 3.11 Irreversible or Irretrievable Commitment of Resources ............................. 50 3.12 Consistency with Laws ................................................................................ 50

Oconee Range Allotments Environmental Assessment ii

Chapter 4 – Consultation and Coordination ..................................................................... 52 Chapter 5 -- References .................................................................................................... 53 Appendices Appendix A Overview Map Carey Station Range Allotment Map Cold Springs 1 & 2 Range Allotments Map Dyar Pasture Range Allotment Map Gladesville Range Allotment Map Greenbriar Creek Range Allotment Map Penfield Range Allotment Map Redlands Range Allotment Map Sellars Range Allotment Map Town Creek Range Allotment Map Appendix B: Standard Mitigation Measures for Herbicide Use Appendix C: Results of the Risk Assessment – Detailed Summary Appendix D: Mode of Action in Plants for Herbicides Proposed for Use in this Project Appendix E: Emergency Spill Plan Appendix F: Response to Scoping Comments List of Tables and Figures Table 1.1: Range allotments with management descriptions ............................................ 5 Table 1.2: Management descriptions and location in Forest Plan ..................................... 5 Table 2.1: Livestock class, permitted animal unit month, and season of use for each allotment. ............................................................................................................ 10 Table 2.2: Comparison of alternatives ............................................................................. 13 Table 3.1: The number of acres by allotments ................................................................. 15 Table 3.2: Soil series in range allotments on the Oconee Ranger District, Georgia ........................................................................................................... 22 Table 3.3: 5th & 6th level hydrologic units with range allotments .................................... 23 Table 3.4: Streams listed of 2012 GA 303(d) list due to water quality ............................ 25 Table 3.5: Summary of acres for past, present, and reasonably foreseeable ground disturbing activities ......................................................................................... 34 Table 3.6: Percent of 6th level watershed by land use category ...................................... 35 Table 3.7: Known NNIS in the Oconee Range Allotment project area ............................. 40 Table 3.8: Herbicide application rate assumptions for foliar spray applications ............. 46 Table 4.1: Forest Service Interdisciplinary Team .............................................................. 52 Figure 1: Improve livestock stream crossing on perennial stream on Greenbrier Creek Allotment ................................................................................... 30 Figure 2: Fencing of riparian area at Dyar Pasture Allotment with Lake Oconee with Lake Oconee in the background ........................................................................... 30

Oconee Range Allotments Environmental Assessment iii

Chapter 1: Purpose and Need for the Proposed Action 1.0 INTRODUCTION This environmental assessment (EA) documents the results of a study of the potential environmental impacts of actions proposed by the United States Department of Agriculture (USDA) Forest Service, to authorizing livestock grazing and associated activities on the Oconee Ranger District of the Chattahoochee-Oconee National Forests in Georgia. For the purpose of this EA, the Oconee Range Allotment project will be referred to as the “ORA” and the tracts will be referred to as the “project area” This Environmental Assessment will disclose the direct, indirect, and cumulative environmental impacts that would result from the proposed action and alternatives. This EA was prepared in accordance with the National Environmental Policy Act (NEPA) of 1969 (42 United States Code (USC) 4321 et seq.), which requires an environmental analysis for federal actions having the potential to impact the quality of the human environment; the Council on Environmental Quality (CEQ) regulations (40 Code of Federal Regulations (CFR) 1500 through 1508) for implementing NEPA; Forest Service Procedures for Implementing CEQ regulations (Forest Service Manual (FSM) Chapter 1950); and the Forest Service Policy and Procedures Handbook (Forest Service Handbook (FSH) 1909.15). This chapter 1) describes the project area, 2) discusses Forest Plan direction related to this project, 3) explains why the proposed action is needed, 4) describes the proposal, referred to as the “proposed action”, 5) defines the scope of the analysis, and 6) lists the decisions to be made with this project. Additional documentation, including more detailed analyses of project-area resources, may be found in the project planning record located at the Oconee Ranger District (ORD) Office in Eatonton, GA. 1.1 BACKGROUND The project area is located on 11 separate tracts of National Forest System lands totaling approximately 723 acres of grazing allotments (Please refer to maps in Appendix A). Beginning in the 1930s, some of the areas now managed as the Oconee National Forest were identified for restoration by the federal governments due to extensive row-crop agriculture (1820 -1900) and land abandonment. In the early 1940’s the U.S. Soil Conservation Service purchased the lands. In 1959, the land was transferred to the USDA Forest Service for administration and management with additional lands acquired by willing sellers over time. These 9 grazing allotments are on National Forest System Lands and have been managed as a grazing resource since acquisition.

Oconee Range Allotments Environmental Assessment 1

1.2 PROJECT AREA DESCRIPTION The improved pastures are located within Greene and Jasper County. Carey Station, Cold Springs, Dyar Pasture, Greenbriar, Penfield, Redlands, Sellars, and Town Creek Allotments are in Greene County with the Gladesville Allotment in Jasper County. Please see “Overview Maps” in Appendix A for visual information. The project areas total 723 acres. The total percentage of National Forest Systems land in grazing allotments is less than 0.1%. These grazing allotments help provide edge and grassland habitat for a variety of wildlife species including grassland birds, game birds, raptors, small mammals, and white-tailed deer. Designated goals, objectives, and standards for management are identified in the Land Resource Management Plan (LRMP) for the Chattahoochee-Oconee National Forest (Forest Plan, 2004) The ORD has been actively implementing principals of restoring fire-adaptive ecosystems in these allotments and adjacent project areas for the past ten to twenty years. The ORD has previously prescribed burned some of these grazing areas. The objectives of the past prescribed fires have been to restore and maintain open land pastures, promote native grasses, and specialized habitats. These objectives were successfully met with little or no negative impacts to the physical or biological resources. 1.3 PURPOSE AND NEED FOR ACTION The purpose of authorizing grazing is contained in several levels of Forest Service regulations and policy. In compliance with NEPA and 1995 Rescissions Act, the purpose of this project is to allow livestock to graze on 9 existing grazing allotments on the ORD over 723 acres. It is Forest Service policy to make forage available to qualified livestock operators from lands suitable for grazing consistent with land management plans (FSM 2203.1; 36 CFR 222.2 (C)). The ORD is proposing to authorize livestock grazing in a manner that continue to meet Forest Plan Goal and Objectives and desired conditions. The primary purpose is to provide range forage in response to demand, maintain open pasture, and improve pasture conditions. Open and semi-open lands are important habitats that provide different habitat structure then what is found in dominant forested and agricultural lands. For wildlife species that utilize open land habitat, there is a need for some open land communities to be maintained. In addition to the previous stated activities these areas will eventually be converted back to native grasses. The ORD is proposing this action to maintain these open lands and also to bring the allotments into compliance with direction in the LRMP. 1.4 PROPOSED ACTION DESCRIPTION The ORD grazing management is to meet Goals and Objectives and desired conditions of the LRMP. In order to continue to move towards and meet desired conditions through existing management techniques, the following maintenance would be completed.

• Maintain range infrastructure (i.e. gates, fences); • Improve grazing systems;


• Maintain existing water developments to enhance livestock distribution; • Maintain range allotments through mowing, haying cultivation, hand cutting, seeding,

fertilizing, liming, the use of herbicides on undesirable and non-native plants, and mechanical treatments of weedy vegetation;

• Maintain and improve warm and cool season pastures to provide quality forage that includes a variety of warm and cool season grasses and fobs.

This project would issue Grazing Permits and Allotment Management Plans (AMP). The AMP’s would implement an adaptive management approach (FSH 2209.13, Chapter 90) which will specify the maximum limits or parameters for the appropriate timing, intensity, frequency (rest/rotation), and duration for grazing. Annual Operating Plans with permittees will be in place.

1.5 FOREST PLAN DIRECTION The LRMP (Forest Plan) was completed in January 2004. The LRMP, and accompanying Final Environmental Impact Statement (FEIS), and Record of Decision specify the overall direction for managing the natural resources on the Forest, and consists of both Forest-wide and area-specific goals, objectives and standards that provide for land uses with anticipated resource outputs. This EA documents the site-specific analysis of implementing the Forest Plan in the Oconee Range Allotment Project Area. The LRMP identifies Forest-wide goals and objectives. The Oconee Range Allotment Project is designed to support the following goals:

• GOAL 2 A diversity of habitat will be provided for the full range of native and other desired species. Sufficient amounts of interior or late-successional habitat as well as early-successional habitat will be provided to meet needs of all successional communities. Early successional habitat will be well distributes in all forest types, elevations, aspects, and slopes including riparian corridors.

• GOAL 3 Enhance, restore, manage and create habitats as required for wildlife and plant communities, including disturbance-dependent forest types.

• GOAL 12 Minimize adverse effects of invasive native and nonnative species. Control such species where feasible and necessary to protect national forest resources.

• GOAL 22 Watersheds are managed (and where needed, restored) to provide resilient and stable conditions to support the quality of water necessary to protect ecological functions and support intended beneficial water uses.

• GOAL 24 Maintain or restore soil productivity and quality.


• GOAL 78 Apply ecosystem management techniques when maintaining existing range allotments. Emphasize conversion of these areas to native warm-season grasses and control of noxious weeds; that is, nonnative invasives.

• GOAL 79 Phase out individual range allotments when there is no immediate demand for a particular allotment.

STANDARDS

FW-218 Trampling by livestock may not expose mineral soil or displace soil on more than 10 percent of the area on any given allotment. FW-219 Where livestock can reach a stream, their access will be controlled to maintain the integrity of stream channels and banks. Reauthorizing grazing in riparian corridors within these existing allotments may occur if continued grazing would be compatible with riparian management desired conditions and objectives.

FW-220 Where grazing is currently under a permit, control and mitigate to restore, enhance, or maintain the integrity of ephemeral streams. New grazing permits will be designed to minimize negative impacts to ephemeral zones to the maximum extent practicable. Livestock will be excluded from ephemeral zones whenever these zones cannot be maintained or restored without such exclusion. FW-221 Where livestock entry points, crossings, and watering points are permitted (i.e., authorized under special-use permit) and have been designated, they will be armored to maintain stream bank stability. They will also be located, sized and maintained to minimize the impact to riparian vegetation and function. FW-222 Feeding troughs, watering troughs, and salt and mineral blocks are not allowed inside the riparian corridor unless the entire pasture is within the riparian corridor, in which case they will be located as far away from the streams as possible. Watering troughs will be appropriately located to protect the streams. FW-224 On the Oconee, when managing for range forage species, wildlife, and livestock use should not exceed 50 percent of current annual growth or key grass species, 20 percent of total annual production of key forb species, and 20 percent of current annual growth of key shrub species

The Forest Plan addressed permanent grazing allotments that are maintained as permanent grass openings. The Forest Plan identifies Management Prescriptions (MP) for each piece of National Forest System lands across the Chattahoochee-Oconee National Forests. The Oconee Range Allotment project area is located in several different MPs. Management Prescription 11 for Riparian Corridors would apply across all the allotments. Table 1.1 lists the management prescriptions identified in the project areas. Table 1.2 defines the management prescriptions and the location in the Forest Plan.


Table1.1: Project Areas with management descriptions.

Allotment Name Management Prescriptions

Carey Station 9H Cold Springs 9H Dyar Pasture 7.E.2/4H Gladesville 8D.1/9.H Greenbriar 9H Penfield 7.E.2/9H Redlands 7.E.2 Sellars 7.E.2/9H

Town Creek 9H

Table 1.2: Management descriptions and location in Forest Plan.

Management Prescription

Description of Management Prescription LRMP Reference

4.H Outstandingly Remarkable Streams Chapter 3, Pages 3-91 to 3-94

7.E.2 Dispersed Recreation Areas with Vegetation Management

Chapter 3, Pages 3-126 to 3-129

8.D.1 Red-cockaded Woodpecker Sub-habitat Management Areas


9.H Management, Maintenance, and Restoration of Plant Associations


11 Riparian Corridors Chapter 3, Pages 3-171 to 3-182

1.6 SCOPE OF THE ENVIRONMENTAL ANALYSIS National forest planning takes place at several levels: national, regional, forest, and project levels. The ORA EA is a project-level analysis; its scope is confined to addressing the purpose and need of the project, possible environmental consequences of the proposal, and alternatives. It does not attempt to address decisions made at higher levels. It does, however, implement direction provided at higher levels.


The LRMP embodies the provisions of the National Forest Management Act, its implementing regulations, and other guiding documents. The LRMP sets forth in detail the direction for managing the land and resources of the Chattahoochee-Oconee National Forests. Where appropriate, the Oconee Range Allotment EA tiers to the Forest Plan Final Environmental Impact Statement (FEIS) (40 CFR 1502.20). This EA evaluates and documents the effects caused by the proposed activities and various alternatives. The site-specific proposed action and alternatives to it are identified in Chapter 2. The administrative scope of this document can be defined as the laws and regulations that provide the framework for analysis. 1.7 DECISION FRAMEWORK The decision to be made will be whether to implement the proposed actions, modify the proposed actions, or select an alternative action (including the no action alternative).The District Ranger is the responsible official to make this decision. The District Ranger for the ORD is the line officer who has responsibility and authority for conducting analyses, preparing necessary documentation, and making decisions on proposed actions under their jurisdiction (FSM 1950.41d). 1.8 PUBLIC INVOLVEMENT The scoping process is the first step to identify issues to the proposed actions. Scoping is defined by the National Environmental Policy Act (NEPA) of 1969 (40 CFR 1501.7) as “an early and open process for determining the scope of issues to be addressed and for identifying the significant issues related to the proposed action.” The issues are used to develop alternative management actions (including mitigation measures) and evaluate environmental consequences of such actions. This proposal was listed in the “Schedule of Proposed Actions,” for the Chattahoochee-Oconee National Forests in March 1, 2013. A scoping letter describing the proposal was provided to the public and other agencies on March 2, 2013. The mailing list is on file in the project record. During the scoping period, seven responses were received. Using the comments from the public and other agencies the interdisciplinary team developed a list of issues to address. A detailed listing of the public comments, along with forest response, is provided in the Appendix F of this EA. Another Opportunity to Comment was sent out to those that commented in the previous comment period. This was done in the Eatonton messenger on July 17, 2014. The comment period was for 30 days. Letters were also sent to individuals who commented with information on the objection period. The comment period ended on August 18, 2014. No comments were received.


The United States Fish and Wildlife Service were contacted on June 27, 2014. They concurred with determinations listed in the Biological Assessment. Current permittees were contacted on March 29, 2013. All permittees would like to continue to graze and did not have any additional issues or concerns. Issues The Interdisciplinary Team (IDT) identified driving issues to be addressed in the environmental analysis (EA) based on comments received from the public. The issues guide the formulation of alternative and provide a framework for the effects analysis to be documented in the environmental analysis.

Other Disclosures

Evaluation of the proposed action indicated effects on the following would not vary between alternatives and/or there would be very little to no effect on these resources. Therefore, the following are not covered in detail in the EA, but are discussed briefly below to add to the overall understanding of the proposed action and alternative. Technical reports with additional information are available in the project record (Project Record is available for review at the Oconee Ranger District in Eatonton, GA).

Aquatics

The project areas contain streams and creeks that may result in minimal disturbances. Our Forest Plan with the use of Best Management Practices (BMP’s), provide information on developing design criteria to help minimize the impacts. The Allotment Management Plan (AMP) has specific instructions on maintenance and protection of our streams, creeks, and water holes. Inspections are done routinely to make sure the permittees are following the AMP. Majority of the improved pastures have riparian protection and livestock is centralized in one location. When these areas become filled with siltation they are cleaned and either seeded or graveled to help minimize the sedimentation to the waterway.


Chapter 2 - Alternatives 2.1 INTRODUCTION Chapter 2 describes and compares the alternatives considered for the Oconee Range Allotment Project. It includes a description of the alternative development process, including how public comments help formulate alternatives, alternatives considered but eliminated from detailed study and alternatives considered in detail. Alternatives were designed with an interdisciplinary team approach considering the size and scope of the project, the purpose and need, unresolved public issues, and the expected environmental impacts. This chapter also presents the alternatives in comparative form, sharply defining the differences between each alternative and providing a clear basis for choice among options by the decision maker and the public. While every effort has been made to assure accuracy, acres and mileages may vary slightly throughout this document due to rounding and measuring differences. 2.2 ALTERNATIVES GIVEN DETAILED STUDY (INCLUDING THE PROPOSED ACTION) The following section gives a description of each alternative given detailed study, including a description of features common to alternatives. The numbers of acres or miles identified for activities have been identified from mapping and should be considered estimates based on available data. After an alternative has been selected and as the project is implemented, actual amounts of activities on the ground (measured in acres or miles) may vary. All changes would be evaluated to ensure that any effects are within the parameters of effects analyzed in this document and would be documented in the project record. Below are the two alternatives being carried forward in the Oconee Range Allotments project environmental analysis. A “no action” alternative must be included as on the alternatives analyzed. Alternative 1 – No Action The Forest Service is required to analyze the No Action Alternative under the provisions of NEPA (40 CFR 1502.14). For livestock grazing projects, this is considered to be equivalent to No Grazing. The No Action Alternative would not authorize livestock grazing on any allotments within the Oconee Ranger District. This alternative does not preclude livestock grazing or livestock management on these allotments in the future if a decision is made through another comprehensive analysis to resume these actions.


Under this alternative, all livestock would be removed from the allotment and grazing permits would not be issued. Since no grazing would occur there would be no livestock capacity determinations, no utilization or grazing intensity guidelines, no grazing management system, and no implementation or effectiveness monitoring. Under this alternative, no new structural improvements would be built. Existing structural range improvements would require a separate analysis to determine whether or not to maintain or remove these improvements. Changes, such as road maintenance, might occur through current management direction, natural processes, or other management decisions in the future. Prescribed fire, vegetation management, and non-native invasive plant control would continue to occur as authorized under previous decisions. Alternative 2 – Proposed Action This alternative is the proposed action based on the purpose and need outlined earlier in this document. This represents the interdisciplinary team’s proposal to move the existing resource condition toward the desired condition as specified in the 2004 Forest Plan. Below is a summary of actions (identified in Chapter 1) that would occur in Alternative 2.

• This project would issue Grazing Permits and Allotment Management Plans (AMP). The AMP’s would implement an adaptive management approach (FSH 2209.13, Chapter 90) which will specify the maximum limits or parameters for the appropriate timing, intensity, frequency (rest/rotation), and duration for grazing. Annual Operating Plans with permittees will be in place.

• Maintenance practices to include: mowing, hand-cutting, seeding, fertilizing, liming, herbicide and mechanical treatments of non-native invasive plants and undesirable plants, water source and fence maintenance. The above actions have been variously implemented within the previously existing, grazed, and maintained allotments, and constitute a continuation of ongoing activities; therefore, they are not anticipated to result in additional ground disturbance. (Note: Herbicide treatment of non-native invasive plant species would also be utilized as a result of the Oconee Forest Health and Wildlife Habitat Improvement Project (OFHWHIP)(USDA, 2011). All activities will adhere to best management practices.

• AMPs will comply with the 2004 Forest Plan and are designed to use livestock grazing to help meet wildlife objectives while minimizing impacts to other resources such as soil, water, riparian areas, and aquatics. There are no Threatened, Endangered or Sensitive species known to occur within the allotments which are currently being grazed on ORD.

• Monitoring of the allotments will take place annually or as needed. Monitoring will be used to determine the need for changes in numbers or duration of use due to reduced forage availability from drought or excess forage from above normal precipitation. See Table PA for livestock numbers and season of use within the Oconee Range Allotment project area.

• Through time the range allotments will be converted back to native grasses as funding allows.


• Individual range allotments will be phased out when there is no immediate demand for a particular allotment (Goal 79).

The maximum permitted livestock use level for the improved pastures are identified in Table 2.1 and grazing activities cannot go beyond the maximum number of AUMs listed. These improved pastures are available for grazing as forage requirements are met based on the AMP’s (refer to project file). Table 2.1: Livestock class, permitted animal unit month, and season of use for each allotment.

Allotment

/Pasture Name

Status Acres Fence

(Miles)

Livestock Number and Class (Animal

Units-AU)

Seasons of Use/(Days)

Permitted Animal Unit

Months (AUM's)

Number Class

Carey Station

Vacant 21 1.4 11 Cow/Calf 3/1-2/28 (365)

135

Coldspring 1 Active 120 4.8 30 Horses 3/1-9/30 (240)

240

Coldspring 2 Vacant 29 1.0 30 Horses 3/1-9/30 (240)

120

Dyar Pasture Active 86 2.3 30 Cow/Calf 3/1-2/28 (365)

383

Gladesville Active 23 1.0 11 Cow/Calf 3/1-2/28 (365)

123

Greenbriar Creek

Active 188 3.8 55 Cow/Calf 3/1-2/28 (365)

664

Penfield 1 Active 49 1.6 15 Cow/Calf 3/1-2/28 (365)

150

Penfield 2 Vacant 97 1.6 15 Cow/Calf 3/1-12/31 (305)

150

Redlands Active 29 1.0 15 Horses 3/1-9/30 (240)

204

Sellars Vacant 42 1.3 60 Cow/calf 3/1-9/30

(365)

163

Town Creek Active 40 1.3 60 Cow/Calf 3/1-2/28 (365)

163

*All treatment activity values listed in Table 2.1 are given with approximate values.


Annual authorized livestock numbers will be based on existing conditions, available water and forage. Adjustments to the annual authorized livestock numbers (increase or decrease) may occur during the grazing year, based on conditions and/or monthly range allotment inspections.

The typical season of use will be within 12 months; from March 1 to February 28.

Structural Improvements:

1. Enclosure fencing will be constructed and maintained at riparian areas when needed to protect riparian areas while still providing for livestock watering.

2. Lower authorized number of livestock combined with rest-rotation schedules are expected to reduce livestock grazing to allow riparian conditions to improve.

3. Repair, replacement, and maintenance of cattle guards, gates, and fences. Forage improvement The proposed action would allow treatment of weedy or undesirable species for all allotments on the Oconee Ranger District. Treatments would include a combination of manual, cultural, and chemical control methods through an adaptive management approach. Undesirable plants are species that pose threats to management and restoration of native vegetation and may cause digestive issues in some livestock. These species may be native to the Piedmont area or introduced. For chemical control methods, foliar spray applications for glyphosate or triclopyr would be used. Standard mitigation measures for herbicide use are listed in Appendix B. Grazing and haying restrictions stated on the herbicide label will be followed. Mowing and haying may continue even when allotments are vacant. Both of these techniques are used to maintain open lands and mechanically treat NNIS and other undesirable species. Native Grasses These areas may be converted back to native grasses. This will occur over time as funding and opportunities allow. The conversion process will include the use of herbicide (NNIS plants and other undesirable species); prescribe burning; and seeding the area with native species from appropriate genetic sources and other non-persistent crops. Seeding may include disking and/or tilling; mowing; drilling to plant seed, and soil amendments (fertilizer and/or lime). 2.3 FEATURES COMMON TO ALL ACTION ALTERNATIVES Design Features In response to public comments on the proposal, design features were developed to ease some of the potential environmental impacts the various alternatives may cause. The design features may be applied to any of the action alternatives.

• Retain native vegetation and limit soil disturbance as much as possible.


• Follow Best Management Practices when placing riparian excluder devices to minimize

disturbance to springs, creeks, rivers, streams, or marshes.

• Fueling or oiling of mechanical equipment and mechanically constructed fire lines for prescribed burning would occur at least 100 feet from aquatic habitats.

• Use low intensity burns with less than 2-foot flame lengths to minimize soil exposure.

• When prescribed burning operations are scheduled to take place in these areas, range allotments will need to be excluded or livestock removed from allotment area during and after burning operations for a period of time to allow the pasture to restore vegetation.

• The cattle exclusion fence within Penfield 1 allotment cultural site must be functional.

2.4 MONITORING AND EVALUATION Monitoring and evaluation would occur under Alternatives 2. Monitoring and evaluation are separate, sequential activities. Monitoring involves collecting data by observation or measurement. Evaluation involves analyzing and interpreting monitoring data. Data will be collected according to Forest Service policy and direction. Two types of monitoring will be conducted on the Oconee Range Allotment area: Implementation: Did we do what we said we would do in the Project Area? Were

activities implemented as planned and meet the desired conditions? Effectiveness: Were the planned activities and design features effective in meeting goals

and objectives? The main goal of monitoring and evaluation is to assess project implementation and compliance with Forest Plan direction. It provides a reporting system so the Forest Supervisor, District Ranger, Forest Staff, and the public can openly follow the success or failure of a project and implementation of the Forest Plan. Conduct short-term and long-term monitoring to determine if adjustments to grazing are necessary (FSH 2209.13 sec. 95). Project specific short-term monitoring would involve the following activities:

• The Forest Service would conduct compliance monitoring. Annual operating instructions (AOIs) and terms and conditions would be monitored for compliance.

• The Forest Service would invite participation from permittees, other rangeland users, and interested parties in the short-term monitoring efforts.


Long-term monitoring would be used to determine if grazing management guidelines included in the proposed action and the AMPs are effective in moving resources towards functioning ecological conditions and ensuring an upward or stable trend in resource conditions. Project specific long-term monitoring would involve the following activities:

• Evaluation of the effects of range management activities on soil quality will compare results to the R8 Soil Quality Standards (FSH R8 2508.18). Monitoring will be conducted primarily by visual examination on an annual basis within allotments in active management.

• Evaluation of the effects of range management activities on water quality will assess impacts within riparian areas included in allotment boundaries, primarily on streambanks, e.g. active erosion or bank stability. Monitoring will be conducted primarily by visual examination on an annual basis within allotments in active management.

Monitoring of soil and water resources in range allotments will be conducted by District range program manager, with assistance as needed from the Forest specialists. 2.5 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED STUDY Federal agencies are required by NEPA to rigorously explore and objectively evaluate all reasonable alternatives and to briefly discuss the reasons for eliminating any alternatives that were not developed in detail (40 CFR 1502.14). Public comments provided suggestions and information pertaining to management of the allotments. The suggestions brought up issues, but did not propose any additional alternatives that were not already being considered in detail. Some of the concerns were also outside of the scope of this decision. 2.6 COMPARISON OF ALTERNATIVES This section provides a summary of the effects of implementing each alternative. Information in the table is focused on activities and effects where different levels of effects or outputs can be distinguished quantitatively or qualitatively among alternatives.

Table 2.2: Comparison of alternatives.

Item Measurement Alternative 1: No Action

Alternative 2: Proposed

Action PURPOSE AND NEED (OBJECTIVES)

Grazing Acres maintained as range allotment 0 723

Mowing Allotments Annually Acres mowed annually 0 482


Chapter 3 – Affected Environment

3.0 INTRODUCTION This section summarizes the physical, biological, social and economic environments of the affected project area and the potential changes to those environments due to implementation of the alternatives. It also presents the scientific and analytical basis for comparison of alternatives presented in the chart above. Direct effects are those occurring at the same time and place as the triggering action (e.g. prescribed fire causes smoke). Indirect effects are those caused by the action, but occur later, or at a distance from the triggering action (e.g. prescribed fire reduces fuel loading causing wildfire to become less frequent and less intense). Cumulative effects are environmental effects that result from incremental effect of the action in addition to the effects of other past, present, and reasonably foreseeable future actions, regardless of whether or not the agency or person undertakes them and regardless of land ownership on which other actions occur. An individual action when considered alone may not have a significant effect, but when its effects are considered in addition to effects of other past, present, and reasonably foreseeable future actions, the effects may be significant. The USDA-Forest Service uses the most reliable and timely data available. Accuracy from the Forest Service Vegetation database (FSVEG), Geographical Information Systems (GIS), Natural Resource Information System (NRIS), Forest Inventory, and Analysis Database (FIADB), Infrastructures Database (INFRA) and other databases vary in accuracy. All attempts to verify and update this information have been made where possible. The Forest Service developed mitigation measures to be used as part of the action alternatives. For simplicity, all mitigation measures are listed at the end of Chapter 2 of this document. 3.1 PRESENCE OR ABSENCE OF RESOURCES The following resources are not present in the Oconee Range Allotment project area; wild and scenic rivers, ecologically critical areas; coastal zone; research natural areas; State or National parks; conservation areas; other areas of ecological, scenic or aesthetic importance; prime farmlands, wetlands, floodplains, or wilderness. There are also no Native American concerns associated with proposed activities or minority and low-income populations that would be adversely affected.

Historic or cultural resources exist in the project area. These resources would not be adversely impacted by any of the alternatives because the areas would be avoided (see Heritage Resources section). The effects to migratory birds and threatened, endangered, and sensitive species are documented later in this chapter. None of the alternatives are expected to result in short or long term adverse effects to these species population viability.


3.2 VEGETATION Measure – Effects of proposed activities on vegetation conditions . Bounds of Analysis – Spatial: The Oconee Range Allotment Project analysis area consists of the National Forest System lands contained within outside boundary of the improved allotments. Temporal: Approximately ten years following implementation. Existing Conditions

The Oconee National Forest lies within the Piedmont section of Georgia (Midland Plateau-Central Uplands Subsection in the Southern Appalachian Piedmont Section). In the Piedmont area of Georgia, vegetation communities consist of oak hardwood and southern pine woodlands converge with some areas of openings of native grasses creating a distinctive array of open grassy woodlands and savannas. Within some of these forested areas, there were farms that had pastures and when the government received the lands the areas may have remained in improved pastures. Detailed descriptions of these Suction, Subsections and the Landtype Associations can be found in the report of Ecological Classification System on the Oconee National Forest (USDA, 2009). The proposed project covers 9 different allotments that are currently permitted or vacant. There are approximately 723 acres which include 482 acres of open, improved pasture (Table 3.1).

Table 3.1: The number of acres by allotments.

Allotment Name Total Allotment Acres

Open Improved Pasture

Carey Station 21 20 Cold Springs 149 65 Dyar Pasture 86 67 Gladesville 23 4 Greenbriar 188 118 Penfield 146 132 Redlands 29 21 Sellars 42 27 Town Creek 40 30

Currently, the improved pastures are grazed, mowed, and occasionally limed and fertilized to maintain forage for livestock. Most pastures are dominated by tall fescue, Bermuda grass and other introduced grasses. Desirable legumes have been seeded into some of the pastures to improve forage. Native warm season grasses may be found around the edge of forested areas. The allotments have been inter-seeded with legumes to improve forage quality. Forested vegetation around these pastures has a dense canopy with various species of shrubs and forbs in


the understory. Dominant species surrounding the areas are yellow pine and hardwoods. These open areas where historically farmlands and pastures. These areas over the past 20 years have been maintained for grazing. The existing native vegetation on many of the improved pastures is in some areas heavily infested with non-native plant species and other undesirable. Permittees are working with local Natural Resources Conservation Service (NRCS) to eliminate NNIS and some undesirable species as funding is available. These undesirable species are a threat to some livestock and if ingested can cause issues with digestive system in some livestock. These undesirable plant species take up forage availability and need to be control and eliminated so that forage and native desirables can be re-established and prevent any digestive problems in livestock. Permittees have used mowing and herbicide to control undesirable species. Common species considered undesirables are cocklebur (Xanthium ssp), bitter sneezeweed (Helenium ssp.), dog fennel (Eupatorium capilliforum), pigweed (Amaranthus spp.) and horse nettle (Solanum carolinense). These species are usually a small percentage of the grazing allotment. Effects of Alternative 1 (No Action) Direct and Indirect Effects Under Alternative 1 (no action), livestock grazing would not be allowed. Permits would be revoked. The project areas would be transition into shrubs and saplings over a period of time. . If no action is done to these open areas they soon will be invaded by loblolly pine, sweetgum, blackberry, persimmon, and other early successional shrubs. NNIS plants would likely increase within the open areas. Under this alternative, no new structural improvements would be built. Existing structural range improvements would require a separate analysis to determine whether or not to maintain or remove these improvements. Effects of Alternative 2 (Proposed Action) Direct and Indirect Effects Effects to vegetation from livestock depend on the species present, timing of grazing, and the type of livestock. Cattle and horses prefer grasses (Osmond et al. 2007). Grazing can directly impact plants by removal of the above ground portion of the plant. Horses can bite plants at the ground surface which can be more damaging to the plant. Rest from grazing will allow the plants to recover. Cattle will also graze on riparian shrubs and forbs and increase time spent in riparian area in summer. Maintenance of range infrastructure such as gates, fences, and water developments would continue for the enhancement of livestock distribution and where possible, rotational grazing systems. Open lands would be maintained through mowing, hand-cutting, seeding, fertilizing, liming, and mechanical treatments of native and non-native invasive plants. Pastures would be maintained to provide quality forage that includes a variety of cool-season and warm-season grasses and forbs.


This alternative allows use of a variety of tools and management practices for the direct establishment and encouragement of desirable vegetation for all management as described in the Forest Plan. Total restoration of all pastures would be difficult and potentially cost prohibitive, but use of this alternative would result in progress towards desired conditions. Grazing management will also depend on dominant grass species and the objectives of the Allotment Management Plan (AMP). Pastures dominated by cool season grasses would be managed different that pastures dominated by warm season grasses. Fescue management requires careful attention to achieve desired results. Heavy grazing of fescue in the spring reduces fescue competition and stimulates forbs, legumes and native warm-season grasses. Light grazing during spring or fall growing seasons helps develop a clumpy structure for nesting cover and to improve animal mobility by creating travel lanes. Intensive grazing for a short duration in early spring would stimulate forb production and reduce the dominance of fescue. Grazing should keep the grass height below 3 inches until after the peak growing period, May to June. This type of grazing would provide bare ground and reduce fescue competition to allow desirable summer legumes and forbs such as ragweed to develop. With light grazing in late fall or early spring the intent is to have about 50 to 75 percent virtually ungrazed and 25 to 50 percent closely grazed. Fescue is a bunchgrass which can provide fair quality nesting structure if lightly grazed. Light grazing in late summer and fall would create paths through dense grasses for small wildlife to have access to food and for escape cover. Periodic disking is an option that decreases grass thickness and increases annual forbs. Disking is most effective in late spring when fescue is actively growing and root reserves are low. The resulting bare soil allows annual plants to become established and produce seed. Disking when fescue is dormant produces a more vigorous stand of fescue than was originally present. Both burning and disking are short-term options; their effects persist less than 2 years in soil with medium to high productivity. Soils with low productivity can be managed by burning or disking with 3 to 4 years effects. Grazing in pastures dominated by warm season grasses or to promote warm season grasses would differ. Through adaptive management, the timing of grazing could be used to promote warm season grasses. Native warm season grasses can provide forage for livestock (Surrency and Owsley 2006). Warm season native grasses pastures cannot be maintained with continuous, close grazing and rest in the fall will allow for recovery. In addition, native grasses usually take two seasons to establish before tolerating grazing. Grazing of tall fescue pasture can also be managed to encourage warm season grasses by increasing and timing grazing when native grasses are dormant. By employing these management practices on fescue fields, some remnant native species quite often respond without direct conversion practices. Management for diverse herbaceous plant composition within grazed areas also is beneficial to livestock production. Inter-seeding legumes within cool-season pastures aids in the dilution of the amount of tall fescue consumed. This reduces the effects of fescue toxicity (summer slump) in cattle. Fescue toxicity is caused by a fungal endophyte found within tissues of the fescue


plant. Symptoms include poor weight gains, reduced conception rates, intolerance to heat, elevated body temperature and nervousness. Depending on the circumstances, conversion to native grasses and forbs would take several years. During conversion, there is risk of reinvasion of fescue and invasion of NNIS such as Johnson grass, musk thistle, and Bermuda grass. To reduce risk, conversion practices include techniques to help native plants compete with undesirables. The following practices included in this alternative would encourage re-establishment of native warm season grasses and reduce risk of reinvasion and/or invasion of NNIS. Undesirable species are a threat to some livestock and if ingested can cause issues with digestive system in some livestock. These undesirable plant species take up forage availability and need to be control and eliminated to prevent any digestive problems in livestock. Herbicide and mowing would continue to control undesirable species under this proposed action. Appendix B lists standards and best management practices for use of herbicides. Livestock would be removed after treatment following herbicide label directions. This alternative would effectively control persimmon, pine species and other woody species. Use of mowing along with prescribed fire provides land managers increased capability to control woody plant invasion. Sweetgum would be effectively controlled by prescribed fire and blackberry, persimmon, and other woody shrubs that would be effectively controlled by mowing. Selective mowing would also allow for recruitment of desirable woody species such as oak, hickory, and pine into open lands. Haying may be used occasionally to remove new growth, reduce litter and control woody invasion. Haying and mowing even when allotments are vacant will help maintain the open lands. However, haying tends to eliminate forbs and create uniform plant height rather than the irregular, patchy structure preferred by wildlife. Grazing, mowing, proper fertilizing, and prescribed fire would keep the areas in an open condition managed for wildlife. Grazing would take place any time of the year depending on the situation and what type of management needs application. Grazing is the most cost-effective management tool to keep fescue productive for wildlife. Cumulative Effects Ongoing prescribed fire, vegetation management, and NNIS treatments could continue in the allotments based on a forest level Decision (USDA, 2011). NNIS treatments have occurred in the past and may occur in the future. The application of prescribed fire within the compartment areas, , would change dominant species of woody invasion and could be beneficial in just maintaining the open areas in some degree of early successional habitat encouraging native grass seed to germinate. Prescribed fire would favor more fire resistant woody species. Sweetgum would be part of the vegetative community if burns occurred every 3 to 5 years, but not in a position of over story dominance. The area can be treated for invasive species or utilized for hay cultivation.


Prescribed burning would remove litter, stimulate annual forbs, reduce fescue dominance, and set back woody invasion. Burning in early spring before fescue growth exceeds 1 inch, or during summer dormancy, would stimulate fescue dominance and remove litter. Conversely, burning after fescue has grown 1 to 6 inches (April 15 to June 1) would stimulate annual forbs and native legumes (both native and non-native). Burning 6-8 inch fescue (early boot stage, late April to June 1), would reduce fescue's dominance. A late spring burn would not be difficult if a year's growth were allowed to accumulate, then burn when relative humidity drops below 40 percent. Woody invasion can be retarded with April through June burns when woody plants are full leafed out and root reserves are lowest. Climate change is predicted continue increasing temperatures across the Piedmont section of the south (Wear and Greis, 2013, pg. 21-44). As this occurs, shifts in vegetation and spread of NNIS will occur with increases in species that tolerate the changing conditions. This would result in the need to adapt management of the range allotments and increasing potential drought. Alternative 1 Alternative 1 would not implement addition resource management activities through livestock management. These areas could be treated for NNIS, vegetation management, and prescribed fire but no other actions would occur leaving the area to eventually have less forage availability and open habitat under this alternative. Alternative 2 In the Proposed Action Alternative 2, effects from previous impacts, expected new impacts from livestock grazing operations and foreseeable future events combine to influence vegetation condition. Design and implementation of Forest Plan standards, including the application of appropriate Best Management Practices and design criteria would be expected to address any disturbance. By combining prescribed fire and NNIS treatment with the proposed action, the open areas would be maintained. In summary, the proposed action alternative combined with all past, present, and reasonably foreseeable management activities would affect vegetation in the project area. Foreseeable activities include NNIS treatment, National Forest system road management and maintenance, Forest recreation maintenance and management, and fire management. The combined effects of most future activities would cumulatively improve vegetation, primarily by moving vegetation through adaptive management of livestock grazing towards desired conditions. 3.3 SOIL AND WATER Soil Productivity and Water Quality The range allotments and permanent pastures of the Oconee Ranger District occur in a landscape impacted by a historic period of intensive agriculture that contributed to depletion of soil nutrients. This loss of soil productivity resulted in abandonment of thousands of acres of cultivated land, resulting in accelerated soil erosion due to the absence of vegetation cover and conservation practices to protect against the forces that cause erosion.


Trimble (1974) published what is considered the “gold standard” study of intensive land use in the Southern Piedmont and the resulting effects of accelerated erosion. In the study, “Man-Induced Soil Erosion on the Southern Piedmont, 1700-1970,” Dr. Trimble describes the Southern Piedmont as a sub-maturely to maturely dissected plateau lying between the Blue Ridge Mountains to the west and the Atlantic Coastal Plain to the east. The lower Piedmont, which encompasses the Oconee Ranger District, is characterized by broad interfluves with a large proportion of the land in gentle slopes. The range allotments evaluated in this analysis are generally situated on these broad ridge areas; however there is evidence of the past erosion impacts from soil descriptions and the presence of gullies or other erosion formations. Trimble’s 1974 study classifies the Southern Piedmont region into Erosive Land Use (ELU) regions, describing the various periods and types of land uses that occurred through the region and the time frame of the effects on erosion. ELU Region III includes the Oconee Ranger District, identified primarily as cotton cultivation with the greatest period of erosive land use from 1840 through 1920. The impact of the boll weevil caused rapid abandonment of lands and resulting erosion. Erosion depth loss through ELU Region III is estimated at 9 to 12 inches or greater, the highest amount of soil loss in the Trimble study area. All of these lands were privately owned prior to the 1930s when the Federal government began the purchase of lands to be managed by the Resettlement Administration followed by the USDA Soil Conservation Service (SCS). The primary task for the SCS at that point was to implement conservation practices to arrest the severe erosion, restore vegetation cover and slow the sediment contribution to the streams of the region. Transfer of these lands, about thirty years later, to the USDA Forest Service resulted in the creation of the Oconee National Forest and Ranger District. Although records of the origin and use history of the range allotments have not been reviewed, it is assumed most of the allotments and permanent pastures were in existence prior to Forest Service administration and have continued in this use to the present. Existing Condition – Soils There are seven different soil series identified and mapped on the allotments, further classified into eighteen (18) soil mapping units. Mapping units characterize site specific properties of the soil series, such as slope gradient, surface erosion classes and soil textures. Associated site characteristics, e.g. flooding risk, can also be reflected in soil mapping units. The paragraphs below describe soil attributes or properties that can contribute to effects and/or the need for management actions related to range management. Riparian soils – The soils that occur in riparian areas are associated with streams and floodplains. These soils, and the landscape position of their occurrence, have a risk of flooding and typically receive sediment deposition from upland positions. Soil series on riparian landform positions, within the allotments, include Cartecay, Chewacla, Toccoa, Wehadkee and Wickham. The Cold Springs, Dyar Pasture, and Greenbrier allotments have larger acreages of riparian soils delineated.


Wetland soils – Soils in wetland landforms are classified in the National and Georgia lists of hydric soils. Hydric soils are one of the components used in delineation of jurisdictional wetlands, typically with drainage classification of somewhat poorly drained or poorly drained. Two soil series with mapping units on the allotments in this category are the Wehadkee and Chewacla soils. The Greenbrier allotment has areas of these soils. Wetland soils are also mapped in the Dyar Pasture waterfowl area. Flooding frequency and duration – Flooding frequency is expressed in soil mapping units as none, rare, occasional, or frequent. This classification defines the risk of flooding on the soil mapping unit under normal weather conditions. Duration describes the possible length of time the site would be covered by floodwaters. The Toccoa-Cartecay complex is the soil mapping unit with flooding concerns on the allotments. Erosion potential – Erosion can result in loss of nutrients for vegetation productivity (Pritchett and Fisher, 1987). Erosion potential is rated according to risk of erosion on forestland where normal practices are used in managing the land. A rating of slight indicates soil loss is not an important concern; a moderate rating indicates that some attention to soil loss is required; and a severe rating indicates that intensive treatments (such as seeding and mulching disturbed areas, water controls, etc.) or special equipment or operations are required to minimize erosion. Potential erosion hazard is primarily based on slope gradient and erodibility as well as soil texture and soil depth. Soil mapping on the Oconee Ranger District includes a classification of the erosion condition due to historic land use, reflecting the amount of the original surface soil lost to erosion, often as much as seven to ten inches. This condition is reflected in the soil mapping unit name, e.g. Pacolet sandy loam, severely eroded, which has lost 75% or more of the original surface horizon. This eroded condition occurs on each of the allotments on the uplands with slope exceeding 10%. This condition also reflects the potential for erosion under current management scenarios. Compaction potential – compaction increases soil bulk density and decreases porosity because of the application of forces such as weight and vibration caused by the operation of heavy equipment, or animal use. Continued trampling by animals such as cattle or horses in a confined area can result in compaction that can detrimentally influence both soil productivity and watershed conditions by causing increased overland flow during storm events and reduced plant growth due to rooting zone restrictions. Soil compaction risk is a combination of soil texture, organic matter, and soil moisture (McKee et. al 1985). This effect can hamper root growth, reduces soil aeration, and inhibits soil water movement below the surface. Lighter textured soils (sandy) have a higher range of bulk density compared to heavier textured soils (clay). Presence of organic matter and vegetation cover can buffer soil compaction by providing support to equipment or animals. Soil moisture content has a pronounced effect on soil compaction as it influences soil porosity. Riparian area soils, that typically have higher levels of soil moisture present throughout the year, have a moderate to high potential for soil compaction, particularly those with fine-textured or clay soils. Activities on these areas during wet periods will increase the hazard of soil compaction. Mitigation measures to overcome the effects of compaction typically require soil tillage to break up the compacted layers of soil and promote water infiltration and root growth.


Occurrences of soil compaction have been observed in several allotments, primarily along frequently used animal trails, and in areas of concentrated animal use such as stock pen areas and around water sources. Table 3.2 below displays the soil series mapped on the Oconee Ranger District range allotments. This data is based on soil survey data in the Forest GIS soils coverage as of 2013, originally surveyed by the USDA Forest Service and Natural Resources Conservation Service, published in county soil surveys. Table 3.2: Soil Series in Range Allotments on the Oconee Ranger District, Georgia Soil Series Landform General Description Acres in

Allotments Altavista stream

terraces alluvium, sandy loam, stream terraces on larger streams

20.48

Cartecay a floodplains alluvium, sandy loam, well to poorly drained 51.61 Chewacla a floodplains alluvium, sandy clay loam, poorly drained, hydric

portions 6.39

Gwinnett uplands clayey, dissected ridges and sideslopes, dark red, eroded

32.82

Hiwassee uplands broad ridges, gently sloping, clayey, dark red color on surface, eroded

48.57

Pacolet uplands upland ridges and sideslopes, clayey, red, eroded 135.25 Toccoa a floodplains alluvium, sandy loam, well to poorly drained n/a Wedowee uplands narrow ridges and sideslopes 193.27 Wehadkee a floodplains alluvium, sandy clay loam, poorly drained, hydric

portions n/a

Wickham terraces alluvium, sandy clay loam, level terraces on Oconee River

207.38

a – Soils mapped in the Toccoa-Cartecay and Wehadkee-Chewacla map units are classified as a soil complex and individual soil series acres not separated. Existing Condition - Water Streams within the Oconee Ranger District have a range of conditions related to the historic agriculture land use, the period of erosive land use, and the more recent decades of conservation and restoration. Trimble’s 1974 study shares a quote from a survey of streams in the Piedmont in the 1880s in ELU Region III: …in many places filling up with detritus…sand and mud…which is washed from the hill-sides so that many shoals are being rapidly obliterated, and at many places where the memory of middle aged men there were shoals or falls of 5 to 10 feet, at present scarcely any shoals can be noticed (Trimble, 1974, pg. 28). Generally the areas where high rates of erosion were occurring on the hillsides, the streams in the floodplains and valleys were filling with sediment deposition and aggrading to cause streams to


flow above their valley floors. During the period of erosive land use the streams flowed turbid, carrying high levels of sediments that were deposited downstream in floodplains and choking stream channels. The transition to the period of conservation measures and restoration reduced sediment delivery downstream. Streams have become more stabilized, sediment delivery has declined and stream turbidity has decreased to more normal levels. Streams continue to degrade through legacy sediments depositing further downstream. The Oconee Ranger District is located in the South Atlantic-Gulf Hydrologic Region as delineated by the U.S. Geologic Survey hydrologic unit system. Range allotments being evaluated are further located in two 5th level hydrologic units (HUC) and four 6th level HUCs. Table 3.3 displays these HUCs for the allotments: Table 3.3: 5th & 6th level hydrologic units with range allotments. 5th Level Hydrologic Unit

NF Acres in 5th Level HUC

6th Level Hydrologic Unit Name - Total Acres in HUC

NF Acres in 6th HUC - % NF Land

Range Allotment Name

Range Allotment Acres

6th Level HUC Watershed Condition Classification

Oconee River-Greenbrier Creek

20,784

Town Creek/18,952

7,060 / 37%

Cold Springs 180 Class 2 - Functioning at Risk

Town Creek 33 Class 2 - Functioning at Risk

Penfield 121 Class 2 - Functioning at Risk

Greenbrier

Creek/19,348 2,599 / 13%

Greenbrier Creek

108 Class 2 - Functioning at Risk

Oconee River-

Lake Oconee/15,662

3,883 / 25%

Dyar Pasture 61 Class 2 - Functioning at Risk

Sellars 20 Class 2 -Functioning at Risk

Redlands 30 Class 2- Functioning at Risk

Carey Station 23 Class 2 - Functioning at


5th Level Hydrologic Unit

NF Acres in 5th Level HUC

6th Level Hydrologic Unit Name - Total Acres in HUC

NF Acres in 6th HUC - % NF Land

Range Allotment Name

Range Allotment Acres

6th Level HUC Watershed Condition Classification

Risk Ocmulgee River- Big Sandy Creek

14,618

Gladesville-Little Falling Creek/14,016

4,055 / 29%

Gladesville 28 Class 2- Functioning at Risk

Watershed Condition Classification The Forest Service completed the Watershed Condition Framework on all National Forest System (NFS) lands in 2011. The Framework is a comprehensive approach for: 1) evaluating the condition of watersheds 2) strategically implementing integrated restoration, and 3) tracking and monitoring outcome based program accomplishments. It improves the way the agency approaches watershed restoration by targeting the implementation of integrated suites of activities in focus watersheds (USDA, 2011). The Watershed Condition Framework further describes watershed condition assessment as the process of describing watershed condition in terms of three discrete classes that reflect the level of watershed health. Primary emphasis is placed on indicators that directly or indirectly impact soil and hydrologic functions and riparian and aquatic ecosystems. Watershed condition is the state of the physical and biological characteristics and processes within a watershed that affect soil and hydrologic functions. All 6th level hydrologic units on the Chattahoochee-Oconee with 25% or more National Forest lands were evaluated using a twelve (12) indicator model of watershed condition. Forest Service staff evaluated available data for each of the indicators, primarily using GIS data from a number of sources. Each 6th level HUC was classified into one of three classes; Class 1 – Functioning Properly, Class 2 – Functioning at Risk, or Class 3 – Functionally Impaired. Watershed Condition indicators evaluate aquatic and terrestrial conditions (reference Watershed Condition Framework, FS-977, May 2011) with weighted emphasis on aquatic physical, aquatic biological and terrestrial physical. Each of the 6th level HUCs on the Oconee containing range allotments is classified as functioning at risk, or Class 2. Class 2 watersheds exhibit moderate geomorphic, hydrologic, and biotic integrity relative to their natural potential condition (FSM 2521.1, USDA Forest Service, 2004). The indicators of water quality, aquatic habitat, aquatic biota, and riparian/wetland vegetation are indicators that can reflect land management, including the range allotments, and reflect existing conditions of the watershed and streams within them. These four indicators were rated as fair or poor at the 6th level HUC for the four HUCs containing range allotments, primarily due


to listing of stream segments as impaired by the Georgia Environmental Protection Division (EPD) on the 303(d) listing or known water quality or aquatic habitat problems. Water Quality Total Maximum Daily Load (TMDL) A total maximum daily load (TMDL) specifies the maximum amount of a pollutant that a water body can receive and still meet water quality standards. It also allocates pollutant loadings among point and nonpoint (NPS) pollutant sources. Under the Federal Clean Water Act (CWA) each state is required to publish a 305(b) report that summarizes water quality conditions for state waters. If a stream segment or water body does not meet established standards for a variety of parameters, it may be listed as impaired for not meeting beneficial uses. Impaired stream segments are listed biannually in a 303(d) report released by the State. Town Creek is listed by the Georgia Environmental Protection Division (GA EPD) as not meeting current water quality standards for fecal coliform by the Georgia EPD on the 2012 Integrated 305(b)/303(d) List (GA EPD 2013) (Table 3.4). The listed segment, identified as “not supporting designated uses” is from Penfield to Lake Oconee in Greene County, approximately 7 miles. Potential causes are non-point pollution sources, e.g. animal grazing, animal access to streams and application of manure to pastureland.

Table 3.4: Streams listed on 2012 GA 303(d) list due to water quality. Reach Name

Criterion Violated

Water Use

Potential Causes

TMDL Status

Stream Miles on NF lands

6th Level HUC

Town Creek

FC (fecal coliform)

Fishing NP (nonpoint)

TMDL completed 2007

5 miles ** 030701010703, Town Creek

** About a third of the stream miles, the stream is the property boundary with one side in private ownership. Georgia EPD is the lead agency responsible to develop a plan to address impairment sources and levels, a Total Maximum Daily Load or TMDL plan. EPD completed the Plan that includes the Town Creek segment in 2007. (GA EPD, 2007) The TMDL plan identifies livestock animal grazing and animal access to streams as a typical nonpoint source of fecal coliform. Estimated agricultural livestock population in Greene County is 7,400 head of beef cattle and 7,400 head of dairy cattle. The TMDL plan identifies the design and implementation of Best Management Practices (BMPs) to reduce fecal coliform sources and achieve instream fecal coliform standards, primarily controlling direct access of livestock to streams, and animal grazing in pastures. BMPs for this project can be identified as mitigation measures to be included in the allotment management plans. Three allotments, Penfield, Town Creek and Cold Springs, are in the Town Creek 6th level HUC and border the main channel of Town Creek. Along most of the stream channel below Penfield, the stream is the property boundary with one side in private ownership.


Desired Condition The Forest Plan has a Goal related to the desired condition of soils; Goal 24 states maintain or restore soil productivity and quality (USDA, 2004; page 2-20). The Plan also tiers to the Regional Soil Management Handbook which identifies soil quality standards to be applied to areas where management prescriptions are being implemented (FSH 2509.18, Chapter 2, 2003). Soil Quality Standard 2.2, #4 states “Minimum soil quality standards are met when the physical, chemical, and biological properties are not significantly impaired”. Soil impairment does not occur when:

a. At least 85 percent of an activity area is left in a condition of acceptable potential soil productivity following land management activities.

b. Compaction in an area should not significantly impair soil productivity. Goal 22 of the Forest Plan addresses water quality desired condition (page 2-20). Watersheds are managed (and where needed, restored) to provide resilient and stable conditions to support the quality of water necessary to protect ecological functions and support intended beneficial water uses. Environmental Effects The following excerpt from the National Core Best Management Practices Technical Guide (USDA 2012, pg. 83) provides a narrative explanation of potential effects of grazing on watershed condition, soil productivity and water quality: “Improper grazing can adversely affect the watershed condition in several ways. Loss of effective ground cover in the uplands leads to increases in overland flow and peak runoff. Soil compaction, loss of ground cover, and reduced plant vigor in riparian areas decreases the ability of the riparian area to filter pollutants and function as a floodplain. Streambank trampling increases stream channel width/depth ratio, resulting in a change of stream type and a lowering of the water table. Wider and shallower streams have higher stream temperatures and lower dissolved oxygen content and are often unable to move the sediment load effectively, resulting in increased flooding and bank stress. Introducing sediment, nutrients, and pathogens into waterbodies from grazing can lower water quality. Managing livestock numbers, distribution, timing, and season of use can reduce the potential for these impacts.” Scope of the Analysis The spatial boundary for the effects on soil quality would be the boundaries of the allotment areas where treatments such as grazing, tillage for renovation, burning and other mechanical treatments are proposed. For water quality the spatial boundary is the four 6th level HUCs listed in Table-Water A, with all land ownerships totaling 52,316 acres within the 4 HUCs, 17,597 acres of NF lands (33%), and a total of 604 acres of allotments, or less than 0.01% of the watershed acres. The temporal boundary, or time frame, considered is ten years for the following reasons for soils:


a) Ten-year time frames provide a basis for measuring change in soil disturbance due to soil erosion and/or soil compaction.

b) Increases in soil erosion from project and associated activities generally return to pre-project levels in three to five years

c) Soil compaction effects are variable depending on the soil type, the source of compaction impacts, and the pre-project conditions. Studies of compaction caused by heavy equipment and the resulting effects on soil properties indicate ten years as an average time for restoration through natural processes (NCASI, 2004).

The following activities or disturbances are of primary concern and could potentially affect soil productivity and/or water quality:

• Animal grazing on pastures • Animal trailing areas, stock pens, watering sources • Tilling or scarification of pastures for vegetation renovation • Construction, maintenance and closure of firelines for control burns

These activities have the potential to disturb the soil and/or stream banks or channels, and affect soil productivity or water quality through erosion, compaction, rutting, displacement, sediment movement, or channel stability, and loss of organic matter and ground cover. These impacts can create detrimental disturbances that cause impairment or loss of natural function. Methodology Field surveys, Geographic Information System data, records of past activities, and information from the soil surveys or stream inventories for the Oconee Ranger District were used to evaluate the impacts of proposed activities. Forest Service Handbook FSH 2509.18 Soil Management Handbook R8 Supplement 2 soil quality standard 4.a states “At least 85 percent of an activity area is left in a condition of acceptable potential soil productivity following land management activities (USDA-FS-R8-2509.18, 2003). The Chattahoochee-Oconee Land and Resource Management Plan has a Forest-wide standard under Range (Oconee Only) - FW-218; “Trampling by livestock may not expose mineral soil or displace soil on more than 10 percent of the area of any given allotment.” Effects Common to All Alternatives Soil Disturbance, Compaction, Erosion and Sedimentation Range management activities generally result in soil disturbance. Soil disturbance refers to a change in the natural state of a soil caused by an artificially imposed force (Arnup, 1998). Four basic steps can be analyzed to determine whether a proposed activity will cause adverse impacts to soil productivity: Determine what is detrimental disturbance caused by the activity

Match use or livestock capacity levels and best management practices to the site

capability


Minimize detrimental disturbance

Ameliorate or rehabilitate detrimental disturbance where needed Soil disturbances from livestock grazing are found mainly in small concentration areas. The real extent of these impacts is relatively minor in comparison to the transportation system and logging operations. The amount of detrimental disturbance that occurs depends on soil moisture, slope steepness, complexity of topography, and rock content of the soil, depth of slash, season of harvest, skidding design, type of equipment used, sale administration and the skill of equipment operators. Combinations of these factors affect the magnitude and extent of disturbance. Disturbance of soils from management practices involving grazing and pasture renovation will result in some form of physical, chemical and biological changes within the sites disturbed. Direct effects to the soils are changes/loss of soil organic matter content, soil erosion, soil compaction, and nutrient leaching and/or displacement. Indirect effects are loss of soil as sediment, alteration of organic matter formation, and alteration of soil permeability/water infiltration. This disturbance usually includes compaction, mixing of soil layers, and rutting. Surface erosion within an allotment is usually limited because of the quantity of vegetation left on the surface that disperses overland flow, and the minimal displacement of the surface. Soil Compaction Compaction increases soil bulk density and decreases porosity as a result of the application of forces such as weight and vibration caused by the operation of heavy equipment used in forest operations. Soil compaction is dependent on soil texture, organic matter, and soil moisture (McKee et al. 1985). Soil compaction causes increased soil density (weight per unit volume) or bulk density. This effect can hamper root growth, reduces soil aeration, and inhibit soil water movement. The lower the bulk density range, the greater the impacts to plant growth from soil compaction. Lighter textured soils (sandy) have a higher range bulk density compared to heavier textured soils (clay). Presence of organic matter and tree limbs and leaves can buffer soil compaction by providing support to equipment. Soil moisture content has a pronounced effect on soil compaction as it influences soil porosity. Identifying soils by surface texture, maintaining surface organic matter, and allowing grazing under optimal soil moisture conditions will reduce the effects of soil compaction. Heavy trampling can compact subsurface layers while loosening the soil surface, and many studies have examined the influence of stocking rates, seasonality, soil moisture and soil texture on soil compaction. Soil Erosion The process of erosion is natural and occurs on all landscapes. In the southeastern U.S., erosion occurs predominantly as a result of the interaction of water with soil. Soil may be permanently lost and soil particles leaving this site may result in sediment in nearby streams which would impact water quality and possibly compromise aquatic habitats. Ground disturbing management


practices influence erosion principally because they remove vegetative ground cover and often concentrate and channel runoff water. A soil’s susceptibility to erosion varies by soil type and position on the landscape. Erosion is the process of soil particle detachment and movement. When the soil particles are detached from the soil aggregate particles can be carried away by the action of falling raindrops, flowing water, or freezing and thawing. On bare soil, such as a native surfaced road, the force of a raindrop hitting the ground (raindrop splash) can transport soil particles several feet under a heavy rainfall. The action of flowing water can transport soil particles for even greater distances where the flow is concentrated in gullies, depending on the gradient and length of the slope. Steep slopes allow water to flow at higher velocity, thus it can transport more soil, and detach more particles along the way. The erosion process of freezing and thawing is largely a detachment mechanism caused by the influence of moisture in the soil and soil temperatures that fluctuate between freezing and thawing. As water freezes in the soils, often within the upper few inches, it expands, carrying soil particles with it. When thawing occurs, soil particles are deposited in a new location. These detached particles, now separated from the soil aggregate, are susceptible to further erosion. All allotments are expected to meet the Forest Plan standard (FW-218) and regional soil quality guidance (FSH 2509.18) maintaining soil quality standards. Streams in the allotment areas are expected to meet the Georgia EPD Water Quality standards for water use (Chapter 391-3-6-.03). Five Forest-wide standards for range management on the Oconee are in place to direct the management of range allotments to address animal impacts to riparian corridors and stream channels; FW-219, FW220, FS-221, FS-222, and FW-223. Beneficial water uses are assigned by the State of Georgia (EPD) to all surface waters. The streams associated with the allotments north of Interstate 20 are Greenbrier Creek, Town Creek and Beaverdam Creek, all within the Lake Oconee drainage watershed. Each of these streams is assigned the water use classification of fishing. The Gladesville allotment located in Jasper County is associated with Gladesville Creek, within the drainage watershed of Ocmulgee River. Gladesville Creek is also assigned the classification of fishing. All of the streams in the allotments have been impacted over the years by the erosion and sediment deposition impacts previously described. There are site level impacts such as unstable stream banks, log and debris jams at various segments on the streams. Some of these impacts are associated with animal access to the streams that need to be evaluated for improvement or rehabilitation to restore normal stream functions.


Figure 1: Improved livestock stream crossing on perennial stream on Greenbrier Creek Allotment. A project completed on the Dyar Pasture allotment by the permit holder at the District’s direction has fenced out the riparian area directly associated with Lake Oconee. The understory vegetation and riparian corridor buffer function have improved as a result of the project.

Figure 2: Fencing of riparian area at Dyar Pasture allotment with Lake Oconee in the background. Effects of Alternative 1 (No Action) Direct and Indirect Effects No new management activities would take place, nor any associated activities with the proposed action. Therefore, no management-related appreciable changes in productivity would occur. Alternative 1 for this Project would not authorize livestock grazing on any Oconee range allotments within the District. This alternative does not preclude livestock grazing or livestock management on the allotments in the future if a decision is made through another analysis to resume these actions.


Under this alternative, all livestock would be removed from the allotments and grazing permits would not be issued, resulting in a slight decrease in compaction, from non-occupancy by livestock, and erosion due to cattle paths re-vegetating. Since no grazing would occur there would be no livestock capacity determinations, no utilization or grazing intensity guidelines, no grazing management system, and no implementation or effectiveness monitoring. No new structural improvements would be built, and existing structural range improvements would require a separate analysis to determine whether or not to maintain or remove these improvements. Existing areas of bare soil within the boundaries of the project area, such as roads and trails, would continue to have soil movement. The erosion and surface flow over bare soils adds to the already existing sediment load in streams. Soils would continue to erode in these areas until some physical point of stabilization is met. Natural weathering and erosion occurs at background levels throughout the project area. However, mitigation measures and adherence to BMPs in the proposed action alternative would be expected to yield minimally greater if not identical effects. Effects of Alternative 2 (Proposed Action) Direct and Indirect Effects Soil disturbances on range allotments will be primarily related to animal grazing and use of equipment for pasture renovation operations. Proposed activities in the project area will have long- and short-term direct negative effects on forest soils. Effects include:

• Compaction or rutting • Soil surface disturbance

The effect of proposed activities should be relatively short compared to techniques used in the past. If all natural elements and processes remain intact, one can expect soil impacts to be nearly undetectable within 10 years. Soil rutting and compaction can result from the use of equipment for open land mowing treatments, or other pasture renovation treatments to improve vegetation cover and productivity. Grazing may also contribute to compaction due to hoof pressure. This effect would be most evident where cattle traffic is concentrated along travel routes and around watering areas. Travel routes and watering areas are a small portion of the total allotment areas; therefore soil compaction would not be significant across the project area. Indirect effects are possible when soil conditions are compromised. Compaction can decrease water infiltration rates, leading to increased overland flow and associated erosion and sediment delivery to streams. Compaction decreases gas exchange (oxygen), which in turn degrades sub-surface biological activity and above ground forest vitality. Rutting and soil displacement cause the same indirect effects as compaction and also channel water in an inappropriate fashion, increasing erosion potential.


Indirect effects of soil nutrient loss include reduced growth and yield and increased susceptibility to pathogens, such as root disease and insect infestation. Precipitation and weathering of rocks will continue to make additional nutrients available on site. Annual needle, leaf, and twig fall, forbs and shrub mortality will continue to recycle nutrients as well. To summarize, by maintaining organic matter and ground cover on at least 85 percent of the site, nutrient cycling and availability should not be altered. The mitigations and Best Management Practices are prescribed to achieve this desired outcome. Localized losses may occur at log landings or along some temporary roads. Cumulative Effects The lands within the nine allotments have been in range management or permanent pasture since the establishment of the Oconee National Forest in 1959, and possibly during the period of management by the USDA Soil Conservation Service prior to 1959. Past activities within the allotments have been primarily livestock grazing, pasture management; including mowing, fertilization and liming, herbicide control of weeds, and periodic prescribed burning. Some of the allotments have received treatments for the cultivation of appropriate grasses or legumes. There is minimal evidence of accelerated erosion within the grass pastures, however there is evidence of gullies and some stream bank stability problems in some of the riparian areas that are generally delineated by trees and woody vegetation that have been retained through the period of conservation and restoration. Private land actions The land ownership pattern of the Oconee Ranger District is typical of the National Forests of the southern United States. The Oconee National Forest contains approximately 115,353 acres or 41% of the total of 280,849 acres within the proclamation boundary. Within proximity of the allotments are private lands that can be generally characterized as rural farm lands, in mixtures of land use including timber land, row crops, pasture and small areas of residential or urban uses that contribute impacts to the streams and watersheds. On private lands in proximity to the range allotments, past activities have included timber management, agriculture uses (pasture, hay production, some row crops), and isolated residential areas. Some private lands have gone through conversion from timber land to pasture land, often resulting in an increase in sediment movement to streams. Implementation of BMPs on private lands, e.g. leaving stream buffers intact when clearing land, have left stream banks that appear stable and functional. Alternative 1 Grazing activities and maintenance would cease on National Forest lands within the project area resulting in woody encroachment and soon thereafter gradual disappearance of the open land areas. As the vegetation species composition of the areas changes, a subsequent alteration of the soils would occur. Erosion levels may decrease slightly as compaction potential and the resulting surface run-off is reduced.


Alternative 2 In the Proposed Action Alternative 2, effects from previous impacts, expected new impacts from livestock grazing operations and foreseeable future events combine to influence long-term soil productivity and water quality. The effects to long-term soil productivity and water quality as a consequence of the actions being proposed in Alternative 2 relates to the cumulative effects from erosion, compaction, sedimentation, and displacement as previously described. The management activities proposed in this EA could result in some soil disturbance or decline of water quality. This disturbance or decline would result from proposed actions. Design and implementation of Forest Plan standards, including the application of appropriate Best Management Practices and mitigation measures would be expected to address any disturbance. In summary, the proposed action alternative combined with all past, present, and reasonably foreseeable management activities would affect soil productivity in the project area. Foreseeable activities include timber harvest, National Forest system road management and maintenance, Forest recreation maintenance and management, and fire management. The combined effects of most future activities would cumulatively improve soil productivity, primarily by reducing impacts from roads, and improving forest health of the residual stands. At the scale of the project area, the contribution of cumulative impacts by the Proposed Action would not be significant on soil productivity or the soil resource. Forest Service activities would meet standards for maintaining soil productivity through proper implementation of management requirements and the prescribed mitigation measures. Irreversible or irretrievable commitment on resources. Neither of the Alternatives would have an irreversible or irretrievable commitment on the soil and water resources in the project areas. Unavoidable Adverse Impacts Livestock grazing in permanent pastures under the proposed action alternative would occur on up to acres over the planning horizon of 10 years. Implementation of any alternative would result in some adverse environmental effects that cannot be avoided. The application of the management prescriptions, standards, best management practices (BMPs), and monitoring and evaluation are intended to limit the extent, severity, and duration of these effects. Although the formulation of the alternatives included avoidance of potential adverse environmental effects, some adverse impacts to the environment that cannot be completely mitigated are expected to occur. Although standards, BMPs, and monitoring plans are designed to prevent significant impacts to soil and water, the potential for impacts does exist. Sediment production could exceed natural rates in certain locations where roads are being built or maintained, or where management activities including harvesting and removal of timber. Sediment would result from surface erosion, channel erosion and mass movement. Cumulative Effects – Water


The area considered for cumulative effects includes the sixth-level watersheds with range allotments on Chattahoochee-Oconee National Forest System (NFS) lands, and the analysis includes the potential effects of Forest, state and private activities on the waters within and leaving the Forest. Cumulative effects address the environmental consequences from activities implemented or projected within the watersheds in the past, present and reasonably foreseeable future. The combination of activities on NF lands, state and private lands can create an effect at a watershed scale that otherwise would not be perceived as a problem at the project or sub-watershed scale. In addition to their natural variability, watersheds differ by their management history, ownership patterns, and the types and levels of contemporary management activity. The combination of natural variables, ownership patterns and management activities contribute to the cumulative effects that shape the current conditions of the aquatic ecosystems within the analysis area. The existing conditions of the aquatic resources on the Oconee RD reflect the cumulative effects of past and present actions. Sediment levels are elevated in many streams due to past land disturbances and current sediment sources. Stream morphology is altered due to channelization, impervious surfaces (roads, urban development) and past land management activities that did not include Best Management Practices (BMPs). Future activities can contribute to these effects or alleviate some of the problems. For the Oconee RD, the reasonably foreseeable future actions are considered to be the continuation of existing activities such as vegetation management, prescribed burning, road maintenance/use, and recreation. Table A displays a summary of acres of past (2006-09), present (2010-11), and reasonable foreseeable (2014-2018) future ground disturbing activities by 6th level watershed. Disturbances older than 2-3 years have a reduced potential for erosion due to revegetation or restoration treatments. When analyzing FS lands within the watershed, the percent of the watershed disturbed over 8 years ranges from less than 1 percent to 28.95 percent. When analyzing all lands within the watershed, the percent of watershed disturbed ranges from less than 1 percent to 8 percent. For example, the entire stand is not disturbed for each treatment. Table 3.5 does not reflect any acres from the proposed action, but it provides a basis to analyze the proposed action for cumulative effects. Table 3.5: Summary of acres for past, present and reasonably foreseeable ground disturbing activities.

HUC

2006 – 2009 Ground Disturbing Activity (acres)


2010 – 2011 Fire Line Constructed (acres)


2012-2013 Estimated Fire Line Constructed (acres)

Percent of watershed disturbed – FS lands

Percent of watershed disturbed – ALL lands

Gladesville Creek - Little Falling Creek

325 65 6 766 4 28.77 8.32

Greenbrier Creek 0 0 0 0 6 0.22 0.03 Oconee River - Lake Oconee 0 0 0 0 4 0.09 0.02

Town Creek 0 0 5 0 17 0.31 0.12


Most of the treatments are pine thinning and prescribed burning, which result in less disturbance than vegetation restoration activities. For some watersheds like Gladesville Creek-Little Falling Creek, the percent of FS lands treated is high but the percent of the total watershed disturbed (all lands) is still relatively small (3%). National Forest ownership for the 6th level HUCs on the Oconee ranges less than 1 percent to 49.5 percent. Private lands in these watersheds influence the water quality of waters coming onto the NF. In watersheds where NF lands are limited, the influence of private activities on overall water quality is greater. Land use data for the 6th level watersheds with range is listed below in Table 3.6. These data indicate that the 6th level watersheds on the Oconee are mostly forested, including both FS and private lands. This also supports the conclusion that major historical disturbances are still affecting water resources. Site specific watershed improvements such as gully restoration, stream restoration or the establishment of agricultural stream buffers are still needed, as well as work to improve road-stream interactions. These improvements or management practices will further contribute to past efforts to restore these watersheds to a properly functioning condition. Forested watersheds serve many purposes. Acting as a living filter, forests capture rainfall, regulate storm water and stream flow, filter nutrients and sediment, and stabilize soils. The high percentage of forested land cover across the Oconee will help mitigate erosion from short-term disturbances resulting from proposed treatments. Mitigation measures will be utilized to minimize direct, indirect and cumulative effects for this alternative. Mitigation measures include the use of Forest Plan standards, state and local erosion/sedimentation control programs, and Best Management Practices for forestry and forestry-related activities. Additional mitigation measures may be applied as needed when site-specific projects are implemented. All water quality regulations or criteria are expected to be met if alternative 2 is selected.

Table 3.6: Percent of 6th level watershed by land use category.

HUC

Bar

e So

il,

Roc

k O

utcr

op,

etc

Cul

tivat

ed

land

Fo

rest

ed

(Con

ifer

or

Mix

ed)

Fore

sted

(P

rim

arily

H

ardw

ood)

Fres

h w

ater

Fres

hwat

er

Mar

sh

Gra

ssla

nd

past

ure

Scru

b, S

hrub

or

Cle

ar-c

ut

Urb

an -

Dev

elop

ed

Gladesville Creek - Little Falling Creek

0.01

0.16

61.39

26.69

0.65

0.07

2.86

3.95

4.22

Greenbrier Creek 0.0

3.67

39.64

26.69

1.38

0.25

18.17

5.24

4.96

Oconee River - Lake Oconee

0.0

2.57

35.70

19.22

18.83

1.01

13.55

4.49

4.61

Town Creek 0.0

0.40

54.79

23.92

1.37

0.14

8.71

7.18

3.49


3.4 CLIMATE CHANGE AND CARBON STORAGE Affected Environment On January 16, 2009 the Chief of the US Forest Service directed the national forests to consider climate change during project planning. National forests were directed to consider the impacts that climate change would have on meeting goals and objectives stated in Forest Plans and the effects that the project contributes to climate change. The US Global Changes Research Program published a 2009 report (USGCRP 2009) on climate changes on different regions. Predictions for the Southeast include: air temperature increases; sea level rise; changes in the timing, location and quantity of precipitation; and increased frequency of extreme weather events such as hurricanes, heat waves, droughts and floods. These predicted changes would affect renewable resources, aquatic and terrestrial ecosystems and agriculture, with implications for human health. Human greenhouse gas (GHG) emissions, primarily carbon dioxide emissions (CO2), are the main source of accelerated climate change on a global scale. The Template for Assessing Climate Change Impacts and Management Options (TACCIMO) was used to assess differences among three general circulation models for the Chattahoochee-Oconee National Forest. TACCIMO (USFS 2014) was used to create a report that summarizes the resulting climate change impacts. Climate change, especially climate change variability (droughts and floods), may alter hydrologic characteristics of watersheds with implications for wildlife, forest productivity and human use. This climate change variability may result in long-term and seasonal changes in temperature that the ORA could influence ecosystem health and function. These impacts result from both long-term warming and from shorter term fluctuations in seasonal temperature that may interrupt or alter temperature dependent ecosystem processes. The ORA is a mixture of open grassland and water habitat and thus provide a source for uptake and storage of carbon. At the watershed scale and larger global scale it is not measureable. The affected environment for climate change is two-fold. First, climate change may affect the natural resources on the Oconee Ranger District and the objectives for the project area. Secondly, vegetation management activities may affect carbon storage ability. In this case the affected environment is global. Climate change scenarios to predict that increases in temperatures and drought occurrence in the Southeast could result in increased losses of carbon, possibly exacerbated by increased wildfire disturbance. The consequences of drought depend on annual and seasonal climate changes and whether the current drought adaptations of trees offer resistance and resilience to changing conditions. The seasonal severity of fire hazard is projected to increase about 10 percent over the next century over much of the US with a 30 percent increase in fire hazard for the southeast predicted. Direct, Indirect and Cumulative Effects of Alternative 1 (No Action) Alternative 1 would result in no short term change to the current trend for carbon storage or release in the project area. Grazing activities and maintenance would cease on National Forest lands within the project area resulting in woody encroachment and soon thereafter gradual disappearance of the open land areas. Native and non-native invasive species (NNIS) are likely to continue to spread and increase in density due to increasing temperatures resulting from climate change (Wear and Greis, 2013, pp. 397-456). Declines in agriculture as a result of loss of


soil productivity would lead to the establishment of yellow pine across the piedmont. Peaks in wildfire activity will also occur with increased hazardous fuels. The ORA are currently in areas of the National Forest that are composed mosaic of diverse tract and habitat conditions. Potential gains and losses of carbon would be subject to changes in land-use, such as the conversion of agricultural to forest lands. Increase urbanization is occurring on private lands around the forest. However, national forest system lands provide for the long-term management of forested areas to offset these other changes in the piedmont. Direct, Indirect and Cumulative Effects of Alternative 2 (Proposed Action) 723 acres within the project area would vary throughout the year from being cut in early spring through summer to being dry in the fall through winter. Forbs and other grasses being removed from the 723 acres would temporarily decrease (by a miniscule amount) the amount of carbon being sequestered. Native grasses and crops would be planted which would build up the amount of carbon sequestered and also increase the amount of soil as the grasses break down during the fall when it would be dormant. At a global or national scale, the short-term reduction in carbon stocks and sequestration rates of the proposed project are imperceptibly small, as are the potential long-term benefits. Other past, present and future projects on federal and private land, cumulatively would add very small amounts of carbon dioxide to the air and the effects would not be measurable at a global scale.

3.5 THREATENED, ENDANGERED, SENSITIVE (TES) AND LOCALLY RARE SPECIES Measure - Effects on habitat conditions and populations of TES and Locally Rare species from project activities. Bounds of Analysis – Spatial: The Oconee Range Allotment Project analysis area consists of the National Forest System lands contained within outside boundary of the improved allotments. Temporal: Approximately ten years following implementation. Effects of Alternative 1 (No Action) and Alternative 2 (Proposed Action) Direct and Indirect Effects Threatened, endangers, sensitive species are evaluated in the biological evaluation within the project file. There are not any TES or locally rare plant species located within the project areas. Surveys for TES plant have occurred in the allotments. Limited rare plant habitat is found in the Cold Spring Allotment, but no rare plants were located during surveys. There are no known occurrences for TES plant species in the grazing allotments. Therefore, there will be no effects to TES plant species from alternative 1 or alternative 2. There are some sensitive animal species such as the loggerhead shrike. This bird species benefits from the pastures being on the forest. This bird species impels their food on the barbed wire.


These grazing areas provide insects for this species. There is no red-cockaded woodpecker habitat in the Greene County area. However, the Gladesville allotment is near a RCW recruitment stand but any of the management activity done in the pasture is not likely to adversely affect this species or any other of the animal species on our list. (Biological Assessment/Evaluation is available in the project record). Current surveys are done throughout these areas prior to any ground disturbance or management activity. 3.6 MANAGEMENT INDICATOR SPECIES (MIS) AND DEMAND SPECIES

Measure - Effects on habitat conditions and populations from project activities. Bounds of Analysis – Spatial: The Oconee Range Allotment Project analysis area consists of the National Forest System lands contained within outside boundary of the improved allotments. Temporal: Approximately ten years following implementation. Existing Conditions The Oconee National Forest host 350 wildlife and fish species along with 1,500 plant species. Of these many species management is difficult and so the Forest Service has identified several species that represent the several ecological communities associated with successional stages that are within the Forest. The primary objective of every project is to ensure the viability of any species present is not adversely affected. MIS is used as a tool for identifying special habitats and creating habitat objectives and standards as guidelines. Both population and habitat data are used to monitor MIS on National Forests (USDA, 2004). Of the 15 terrestrial MIS on the Chattahoochee- Oconee National Forest 4 do not occur on the Oconee those are black bear (Ursus americanus), smooth coneflower (Echinacea laevigata), chestnut-warbler (Dendrocia pennsylvanica), and ovenbird (Seiurus aurocapillus) (USFS, 2004). There will be no effects on these species. The eleven species that occur on the Oconee Ranger District red-cockaded woodpecker (Picodes borealis), wood thrush (Hylociachla mustelina), pine warbler (Dendrocia pinus), hooded warbler (Wilsonia citrine), prairie warbler (Dendrocia discolor), Acadian Flycatcher (Empidomax virescens), Swainson warbler (Limnothlpis swainsonii), Scarlet tanager (Piranga olivacea), field sparrow (Spizella pusilla, and pileated woodpecker (Dryocopus pileatus) and white-tailed deer. Additional information including the habitat requirements, personal observation, deer harvest records, and Neotropical bird point count surveys can be found in the project file. White-tailed Deer, Northern Bobwhite Quail, and Eastern Wild Turkey represent the demand species for the Oconee National Forest. These species are game species that are hunted during specific seasons throughout the year. Hunters use the pasture areas for hunting these species (per conversation with Georgia DNR and permittees). These open pastures provide foraging areas for these species.


Effects of Alternative 1 (No Action) Under Alternative 1, no action which would not allow areas to be permitted for grazing and no management activities these areas would grow back into forest. This would eliminate the foraging availability of these areas over a period of time if no management was implemented to maintain in early successional habitat. There would still be NNIS within these areas under another decision (USDA, 2011) These areas would have limited forage availability over a period of time till burning or another vegetative management activity was scheduled. Burning rotations of 3-5 years for compartments are what is scheduled. Due to the specific parameters the areas within Greene County are not always on the three year rotation and would not always be burned. Over a period of time these areas would eventually become forested areas and provide limited habitat for wildlife diversity. Effects of Alternative 2 (Proposed Action) Red-cockaded woodpecker, pileated woodpecker, scarlet tanager, Swainson’s Warbler, wood thrush, and hooded warbler depend on mid to late successional habitats. No nesting areas would be affected by grazing since there is sufficient habitat in the surrounding areas that would provide suitable habitat. Food availability for the birds would be available as well as the white-tailed deer within the open pasture area. The other birds such as the pine warbler, prairie warbler, and Acadian flycatcher will be in adjacent wooded habitat. These species need wooded areas and would have habitat both in and outside the project areas. Field sparrow would need this habitat management for food, nesting, and cover. Other insect and seed eating species would also benefit from the open pasture area. Majority of the pastures have streams but have riparian excluder devices to minimize any impacts to the stream and the vegetation along the stream. These species were also evaluated within the Oconee Forest Health and Wildlife Habitat Improvement Project which address the vegetation management for control of non-native invasive species (USDA, 2011). There will be no adverse effects from livestock grazing on any of the MIS species. Alternative 2 offers sustainability of the areas providing foraging availability. These areas would remain managed for grazing but also would provide the open areas for the demand species. Over the past twenty years these pastures have been foraging areas for the deer, turkey, and quail. At certain times of the year many visitors to the forest enjoy viewing these species in these open pastures. Grazing would not have a negative effect on these species if permittees follow the management guidelines. These areas have always been maintained as early successional habitat providing food and cover for wildlife species as well as grazing opportunities for livestock. The management activities that are required to maintain the forage and meet the follow the AMP would have minimal effects to wildlife species would not affect TES species. The OFHWHIP does address the herbicide effects for NNIS control (USDA, 2011). Herbicide treatment to native weeds would be minimal and is also address in the Vegetation Management EIS. The treatment areas for native weeds and grasses would be minimal. Following the Vegetation Management guidelines and treatment for non-desirable should not affect wildlife species. This alternative would continue to provide habitat for wildlife diversity.


3.7 NON-NATIVE INVASIVE PLANT SPECIES (NNIS) Measure – Effects of proposed activities on habitat conditions and resulting establishment and/or spread of NNIS Bounds of Analysis – Spatial: The ORA Project analysis area consists of the National Forest System lands contained within outside boundary of the improved allotments. Temporal: Approximately ten years following implementation. Existing Conditions Non-native invasive (NNIS) plants occur throughout the Oconee National Forest landscape. A variety of NNIS are present in each of the allotments (Table 3.7). The predominant plants in the improved pastures are cool-season grasses native to temperate Europe and western Asia, including tall fescue and Bermuda grass. These species were planted historically and provide the primary forage for cattle. Other NNIS species such as Chinese privet, trifoliate orange and Japanese honeysuckle occur in the allotment predominately in the wooded areas. Sericea lespedeza and Johnson grass occurs predominately in the open areas.

Table 3.7: Known NNIS in the Oconee Range Allotment project area.

Species Occurrence in Sumac Creek analysis area

I-rank*

Albizia julibrissin Mimosa, silktree Unknown Carduus nutans Musk thistle, nodding plumeless

thistle Unknown

Elaeagnus umbellata

Autumn olive High

Lespedeza cuneata

Chinese lespedeza, sericea lespedeza Medium

Ligustrum sinense

Chinese privet High

Lonicera japonica Japanese honeysuckle High Melia azedarach Chinaberrytree Medium Microstegium vimineum

Japanese stiltgrass, Nepal grass High

Poncirus trifoliata Hardy orange, trifoliate orange Unknown Rosa multiflora Multiflora rose Medium Schedonorus arundinaceus Tall fescue High Sorghum halepense Johnsongrass High *NatureServe Invasive Species Impact Rank to categorize its negative impact on natural biodiversity.

Effects of Alternative 1 (No Action)


Direct and Indirect Effects Present populations of NNIS would continue to survive, grow, and would likely expand. However, the spread would depend on existing and future conditions. As shrubby and other woody tree species increase without mowing associated with grazing, some species such as tall fescue may decrease. As the tree canopy increases, other species such as Chinese privet, autumn olive, trifoliate orange may continue to spread and dominate the understory. Effects of Alternatives 2 (Proposed Action) Direct and Indirect Effects Direct and indirect effects from grazing and associated activities would increase the risk of introduction and spread of NNIS. Activities such as tilling and seeding would increase ground disturbance which increases habitat for the spread of NNIS. Fertilizing will also encourage invasive species over native species. Mowing may decrease the density of NNIS by mechanical removal. Many of the species present in grazing allotment readily sucker after damage or removal of the top growth. The equipment as well as cattle and horses serves as vectors moving seed and plant parts from infested areas. Hay used as supplement feed and fertilized sources also serve as potential NNIS weed sources. This increase the risk of introduction of additional invasive species and spread into areas currently not infested. NNIS are treated in the allotments and those treatments would likely continue with grazing. However, removing hay from the allotments also increases spreading the existing NNIS species to new areas. Treatment for NNIS prior to hay removal reduces that risk of spread. Cumulative Effects On-going activities would continue that would impact the introduction and spread of NNIS. The areas surrounding the grazing allotment s and adjacent access roads are also infested with NNIS serving as source populations. Potential use from public travel and trail system would substantially increase the likelihood that new populations of NNIS. Equipment associated with prescribed fire may also serve as a vector to spread invasive species. The use of prescribed fire is likely to continue in the allotments and adjacent areas. Evans et al. (2006) reports that many of the NNIS plants that are found commonly in the analysis area recolonize or resprout after fire. Some NNIS can also be controlled by prescribed burning under particular environmental condition. Timing of prescribed burns without active treatment of NNIS may also encourage the spread of NNIS. For example, early spring burns may reduce tall fescue but encourage warm season grasses, both native and non-native. NNIS could be reduced by the treatment of NNIS in the grazing allotments and surrounding areas. NNIS species are likely to continue to spread and increase in density due to increasing temperatures resulting from climate change (Wear and Greis, 2013, pp. 397-456). Many NNIS species may continue to expand their ranges north in the Piedmont due to increasing


temperatures. With increased disturbance and temperatures, even with active treatment, NNIS will continue to an issue in the project area. Alternative 1 Present populations of NNIS would continue to survive, grow, and would likely expand. Permittees would no longer assist in treatment of NNIS. The livestock, feed, and equipment would be eliminated reducing the number of introductions of NNIS species and sites. However, the spread would depend on existing and future conditions. As shrubby and other woody tree species increase without mowing associated with grazing, some species such as tall fescue may decrease. As the tree canopy increases, other species such as Chinese privet, autumn olive, trifoliate orange may continue to spread and dominate the understory. Alternative 2 Cumulative effect from alternative 2 would be similar to alternative 1. However, the risk of introduction and spread would be increased. Many of the activities associated with grazing can increase ground disturbance and increase bare ground. As soil disturbance increases and other activities affect existing vegetation, this would affect the response of NNIS. NNIS could be reduced by the treatment of NNIS in the grazing allotments and surrounding areas. As these areas vegetation and soil condition improve due to shifts in grazing management, the vegetation should be more resistant to invasive of NNIS. In the Proposed Action Alternative 2, effects from previous impacts, expected new impacts from livestock grazing operations and foreseeable future events combine to influence the abundance and distribution of NNIS. Design and implementation of Forest Plan standards, including the application of appropriate Best Management Practices and mitigation measures would be expected to reduce the risk and spread of NNIS. In summary, the proposed action alternative combined with all past, present, and reasonably foreseeable management activities would affect NNIS distribution and abundance in the project area. The combined effects of most future activities would cumulatively reduce the distribution and abundance of NNIS through improved livestock management, improve soil conditions, and improved vegetation. 3.8 HERITAGE RESOURCES Regulatory Framework Cultural resources provide the tangible evidence of past human behavior. As such, they are both finite and non-renewable. The primary legislation governing cultural resource management is the National Historic Preservation Act (NHPA) of 1966, as amended, and its implementing regulations, 36 CFR 800. Section 106 of the NHPA requires federal agencies take into consideration the effects of their undertakings on historic properties, which are defined in 36 CFR 800.16(l) as any district, site, building, structure, or object that is included in or eligible for inclusion in the National Register of Historic Places (NRHP), while Section 110 requires federal agencies to establish a process to identify, evaluate, and nominate historic properties; preserve


and protect those properties that are eligible or potentially eligible to the National Register; and to consult with interested parties, among them federally recognized tribes and the State Historic Preservation Officer. The 2012 Programmatic Agreement (PA) Among the US Department of Agriculture, Forest Service, Chattahoochee-Oconee National Forests; the Georgia State Historic Preservation Officer; The Alabama-Quassarte Tribal Town; the Eastern Band of Cherokee Indians; the Muscogee Creek Nation; and the United Keetoowah Band of Cherokee Indians Regarding the Process for Compliance with Section 106 of the National Historic Preservation Act for Undertakings on the Chattahoochee-Oconee National Forests of the Southern Region of the USDA Forest Service lists certain categories of projects as Exempt Undertakings due to their low potential to affect historic properties. Among these are: #33, reauthorizing grazing permits unless new constructions (e.g., cattle guards, fences, stock tanks) are planned—these require survey; #2, permits…that do not authorize ground disturbance; #6, maintenance or alteration of existing facilities (e.g., cattle guards, fences, stock tanks); #8, pesticide/herbicide applications; #12, non-ground disturbing broadcast seeding, no-till seeding, and spreading mulch; #17, prescribed burns; and #29, existing…openings, bush-hogging of existing openings and installation/maintenance of existing structures. The exemption for grazing permits provided in the Chattahoochee-Oconee’s PA is in recognition of the historic nature of the grazing pastures. When the federal government initiated the process to acquire abandoned farmlands in the mid-1930s, appraisers for the Resettlement Administration’s Piedmont Plantation Project produced maps depicting the land status of each tract (USDA Forest Service, 1935-1979). The 1940 appraisal maps for the Cold Springs 1 & 2, Dyar, Greenbriar, Penfield 1 & 2, Redlands, Sellers, and Town Creek allotments all document either pasture or cropland for what is today pasture land. The appraisal report for the Gladesville allotment mentioned 14 acres of cropland, but contained no maps; while the Carey Station tract file mentions 28 acres in pasture, a barn (among other improvements), but again, no map. The Oconee’s acquisition files for these tracts of land also indicate that each was owned and operated as farmland at least as early as the post-Civil War period. Farm operations invariably necessitated the use of draft animals, which in turn required pasturage. Indeed, appraisal reports document each tract’s improvements, including barns, strengthening the argument for not only the existence of draft animals, but their pasturage as well. Because of the exempt nature of most activities associated with grazing on the Oconee National Forest, only some of the allotments—those with woodlands--have been subjected to previous cultural resource surveys. Of the sites recorded, only one, an unevaluated site within the Penfield 1 allotment, needs protection from the planned activities (cattle grazing). The site is located in an area of soil erosion; in 1986, a cattle-exclusion fence was constructed around the site. The fence must be repaired prior to any action taking place. Direct, Indirect, and Cumulative Effects The SHPO and the Forests recognize that historic properties on forests within the Southeastern Region have been subjected to grazing in pastures for at least a hundred years, and that some degree of impacts may have already occurred. The effects from the use of the grazing pastures on


cultural resources vary by any number of factors. Surfaces can be disturbed by the removal of vegetation from grazing and trailing, sometimes resulting in increased soil erosion—as at the site in the Penfield 1 allotment, and surface artifacts can be broken and displaced by trampling both along the trails (e.g., alongside fences) and in areas of concentrated use (e.g., at water sources). Most of the potentially affected cultural resources in the Oconee’s grazing allotments are plowzone prehistoric or historic artifact scatters. Generally, these site types are “not sensitive” to the impacts from grazing and livestock traveling across the landscape. Alternative 1 has no effect for cultural resources. No grazing, no new improvements, no effects. Alternative 2 is a continuation of existing practices: authorize grazing permits, fence maintenance, mowing, hand-cutting, seeding, fertilizing, liming, and herbicide application. As noted earlier, each of these activities is considered an exempt undertaking for Section 106 review according to the Programmatic Agreement and has no effect. Cumulative Effects The cumulative effects on cultural resources should take into account all surface-altering actions that have occurred or are likely to occur within the Forest. Historic farming practices, historic Soil Conservation Service practices (land managers of what is now the Oconee National Forest from federal acquisition until 1959), current and previous Forest Service management activities, public recreational use and natural processes have all impacted cultural resources to greater or lesser degrees. Within the Forest, other planned or reasonably foreseeable activities that may affect cultural resources are listed in the current Schedule of Proposed Actions (SOPA). Prior to any actions or ground-disturbing activities that have the potential to affect the character or use of cultural resources, the Oconee National Forest ensures compliance with the NHPA by following the stipulations of its programmatic agreement. If cultural resources are located within the project areas, avoidance or appropriate mitigation measures will be implemented to achieve a determination of no effect to cultural resources. Therefore, this proposed action is a no historic properties affected project according to 36 CFR 800.4(b)(2)(d), implementing regulations for the National Historic Preservation Act. 3.9 RECREATION Maintaining and improving the range allotments on the ORD will not pose any negative impacts on the recreation resource. There is one developed recreation areas within the Project area. Dyar Pasture boat ramp and wildlife viewing areas are directly attached to the Dyar Pasture Range Allotment. Permittee is responsible to prevent livestock from entering the recreation area. There are no trails within the project area. There are few dispersed recreation opportunities within the project areas i.e. bird watching however, there will be no significant impacts on these activities in the project area. 3.10 PUBLIC HEALTH AND SAFETY


The following issues of public health and safety will be addressed: the use and application of herbicides to control vegetation. Measure - Measure will consist of the types of herbicide to be used, the application rates and the number of acres to be treated. Bounds of Analysis - Spatial: Public health and safety issues will be analyzed for the project area and adjacent private lands. Temporal: Public health and safety issues related to project activities that will occur for the next ten years. Existing Conditions The primary recreational use in range allowtments is hunting. Many recreational users are present during the spring turkey season and fall and winter deer, bear, and small games seasons. The health and safety of employees and contractors is also extremely important when implementing any project on National Forest lands. Effects of Alternative 1 Direct and Indirect Effects There would be no changes in current direct and indirect effects on safety regarding herbicide use. None of these additional activities would occur under Alternative 1. There would be no additional direct or indirect effects on herbicide use since none of the additional activities would occur for this project. Effects of Alternative 2 Direct and Indirect Effects There is a perception by the public that any use of herbicides in the forest is unsafe. The more recent Human Health and Ecological Risk Assessments (HERA) for herbicides (USDA, 2004 and 2006) evaluate all pesticides used in the Forest Service. In these documents, the process of risk assessment is used to quantitatively evaluate the probability (i.e. risk) that pesticide use might pose harm to humans or other species in the environment. For all herbicides, and for both cut surface applications and foliar applications, risk assessments have been developed for the Forest Service by Syracuse Environmental Research Associates (SERA). The details of the risk assessment results are included in the process record. Additional information on this process and for assessments for all pesticides commonly used by the Forest Service can be found at http://www.fs.fed.us/foresthealth/pesticide/risk.shtml and http://www.sera-inc.com/. The worksheets that accompany the risk assessments are based on typical application rates for each pesticide (lb/acre) rather than the full range of possible application rates. The use of application rates that exceed the typical rates would need to be further analyzed in the risk assessment. Two terms commonly referred to in this process are the Reference Dose (RfD) and Hazard Quotient (HQ).


http://www.fs.fed.us/foresthealth/pesticide/risk.shtml

http://www.sera-inc.com/

RfD - Derived by US EPA, this is the maximum dose in mg of herbicide active ingredient per kg of body weight per day that is not expected to cause injury over a lifetime of exposure. In other words, it is, in EPA’s opinion, a “safe” lifetime daily dose. This is a conservative estimate, and is designed to be protective. HQ - This is the ratio of the estimated exposure dose to the RfD. A HQ of 1 equals exposure to the RfD; HQs less than 1 represent exposures to less than the RfD, while HQs greater than 1 represent exposures greater than the RfD. HQs of 1.0 or less represent exposure levels that are not of concern. HQs greater than 1.0 represent possible effects to be examined more closely. The assumptions for any exposures producing a HQ greater than 1.0 are examined to see if the exposures need to be mitigated or avoided. For the effects on wildlife, one must remember that these effects are constructed for individuals and not wildlife populations. For Alternative 2, the spill plan in Appendix E would be in place. Alternative 2 also assumes that all of the mitigation measures in this document would be followed, as would mitigation measures in the VMEIS. Published analyses of environmental effects in the VMEIS are not duplicated in this document. However, information published subsequent to the VMEIS encountered in the open literature that is both relevant to this analysis and demonstrates a potential for significant effect on the conclusions drawn in the VMEIS has been included in the current analysis. The risk assessments are based on the standard application rates in the SERA Version 4.04 Worksheets. In some cases, the actual application rates for this project may be lower than the assessed application rates. Since results of the risk assessments with lower application rates would be the same or less as using the standard application rates, new scenarios for lower application rates were not run for this analysis. The following tables show the basis for the estimated application rates that will be used in this project.

Table 3.8: Herbicide application rate assumptions for foliar spray applications.

Herbicide Lbs ai/gal % solution Gallons of spray/acre

Lbs ai/acre

Glyphosate 5.4 2.0% 10 2.0 Triclopyr (amine) 3.0 4% 25 1.0 Triclopyr (ester) 4.0 2.0% 25 1.0

For each herbicide, hazard quotients are developed that summarize risk characteristics for workers, the general public, terrestrial animals and aquatic species. For this analysis, hazard quotients derived from spill scenarios into ponds have been set to zero. The reason is that the project has mitigation measures in place (Appendix B) that make such spills so unlikely that such an analysis would be irrelevant. In addition, in the unlikely event this should occur, expedited clean up and exclusion from use are required until clean up has been accomplished. The specific spill scenario referenced is: acute/accidental exposure, contaminated water consumed by a child


(EO4 sheet). Hazard quotients for the general public involving direct spray exposures to the entire body or lower legs are also considered so unlikely as to be irrelevant. These have also been set to zero. Following is a summary of the findings from this assessment for values over 1.0. A complete summary of results of the risk assessment is in Appendix C of this document. Detailed risk assessment information can be found in the project process record. The most important hazard quotient is the general exposure HQ for workers. These are the people most likely to have direct exposure to herbicides. According to the Forest Service Southern Region Pesticide Specialist, the central HQ best reflects a realistic upper exposure and risk for workers using required personal protective equipment and employing proper washing and hygiene habits. Rapid personal cleanup in the event of any exposure should keep the dosage internalized (the hazard) in the typical, rather than the upper bound range. Results of the risk assessment for typical exposures of glyphosate at 2.0 lbs/acre are well under 1.0 (see project file) indicating low risk. For both the amine and ester formulation of triclopyr, results of the risk assessment found that typical exposures of workers to directed ground spray (backpack) were 1.0 or less. Although upper exposures were calculated above 1.0 for general exposure of workers using a backpack and for a spill on the lower legs to a worker (triclopyr amine), the central HQ best reflects a realistic upper exposure and risk for workers using appropriate personal protective equipment and employing proper washing and hygiene habits according to the Forest Service Southern Region Pesticide Specialist. Accidental exposure of a worker to contaminated gloves shows a typical HQ of less than 1 for triclopyr (ester formulation) at 1.0 lbs/acre, but for upper exposures, were above 1.0. This is unlikely to occur because the scenario assumes that the contaminated glove will be left on the hands in direct contact with the skin for 1 hour. Labeling instructions and worker protection standards require proper hygiene. Contaminated gloves should be removed immediately and both the contaminated skin and gloves should be washed with an appropriate soap or detergent, and water. The use of protective clothing can substantially reduce worker doses. Protective clothing can reduce worker exposures by 27 to 99 percent, as shown in a number of field studies of worker exposure (VMEIS, Volume II, Appendix A, page 5-35). Workers would be required to wear all personal protective and safety equipment required by labeling. A change of clothes as well as soap, wash water, eyewash bottles and first aid equipment would also be provided on-site. While workers are more likely to be exposed to the herbicide than the general public, the risk to workers (systemic and reproductive) from ground based spraying application of these herbicides at typical rates is low (VMEIS, Volume 1, Chapter IV, page IV-18). For both the amine and ester formulation of triclopyr, typical hazard quotients for consumption of vegetation by an adult female are above 1.0 for both acute and chronic exposures. However, consumption of contaminated vegetation is unlikely for the following reasons:


• Herbicide application areas are signed to preclude accidental exposure.

• With cut surface or injection application, the amount of non-target vegetation subject to

spray deposition is very small.

In addition, the long term scenario assumes that for a long term exposure to occur contaminated or vegetation eaten 90 days in a row. For both the amine and ester formulation of triclopyr, typical hazard quotients for vegetation contact of an adult female in shorts and a t-shirt are above 1.0. However, this scenario is unlikely since herbicide application areas are signed to preclude accidental exposure. As a result of these analyses, and given that Forest Plan Standards, project mitigation, and assumptions are met, there should be no significant negative effect to human health or safety as a result of herbicide use in this alternative. The following information summarizes the mode-of-action in humans for the most commonly used on the Oconee National Forest. It is summarized and evaluated from a human safety viewpoint, evaluating risks, short term effects and cumulative effects. All information contained in the risk assessments is incorporated by reference into this analysis. For both workers and members of the general public there is very little indication of high potential risk at the assessed application rate of 2 lbs a.e./acre of glyphosate. Although the risk is low, applicators have the greatest risk of exposure and the chance of adverse health risk from herbicides. The herbicidal activity of glyphosate is due primarily to the inhibition of the shikimate (photosynthesis, nutrient uptake, etc.) pathway which is involved in the synthesis of aromatic amino acids in plants. This causes inhibition or cessation of growth and plant death. This metabolic pathway does not occur in humans or other animals, thus this mechanism of action is not directly relevant to the human risk assessment. Two dermal adsorption studies have been published on glyphosate and both of these studies indicate that glyphosate is very poorly absorbed across the skin. Glyphosate is known to damage mucosal tissue when ingested. Like all chemicals, glyphosate may be toxic at high exposure levels. Glyphosate does not accumulate in animal tissue, and is readily excreted by the kidneys. Acute LD50 values of this chemical range from approximately 2,000 to 6,000 mg/kg. The chronic dietary no-observed-adverse-effect-level for glyphosate in mammals is a daily dose of 175/mg/kg. Glyphosate is classified as slightly toxic. Glyphosate has a half-life of 61 days in soil, depending on temperature, and as short as 10 hours in water at 77 degrees F (SERA). Triclopyr is a herbicide that mimics indole auxin, a plant growth hormone, inducing uncontrolled growth and lack of viability in plants. Like any chemical, triclopyr at sufficiently high exposure levels can cause toxic effects, even death. Nonetheless, triclopyr has a low order of acute lethal potency. There is no information suggesting that triclopyr causes direct adverse effects on the nervous system, endocrine system, or immune function. Triclopyr does not accumulate in animal tissue, and is readily excreted by the kidneys. The acute oral LD50 values of triclopyr range from 849 mg/kg to 2055 mg/kg for birds and laboratory animals. The chronic dietary no-


observed-adverse-effect-level for triclopyr in mammals is a daily dose of 5/mg/kg. Triclopyr formulations have been classified by the U.S. EPA as non-toxic to slightly toxic to birds and practically non-toxic to honeybees. There is a number of field studies that have assessed the effects of triclopyr on terrestrial organisms, both animal and plant. There is very little suggestion in any of the field studies that triclopyr had any direct adverse effect on terrestrial species and most reported effects may simply reflect changes in habitat secondary to vegetation management practices. Triclopyr has a half-life of 46 days in soil, depending on temperature (SERA). Site parameters were adequately considered in these analyses. Analyses included risk assessments of human health and safety of workers, and of the general (visiting or off-site) public, analyses of risk to wildlife (terrestrial and aquatic) and plants both on and off site, and clear evaluations of the risk posed by potential off-site movement either in water (runoff, leaching, or other lateral transport in water through the soil) or via volatility and subsequent off-site vapor transport. Based on these analyses we affirm that there are no unintended direct or indirect negative effects projected as resulting from the proposed use of herbicide in this project. Cumulative effects from using herbicides as proposed also pose no significant risk of causing unintended negative cumulative effects due to their short half-lives and the selectivity of the proposed treatment methods. Forest wide standards, the product label, and SERA (HERA) Risk Assessments will be followed for all herbicides used. Cumulative Effects Alternative 1 There will be no cumulative effects on public safety from the no action alternative for this project. Alternative 2 The potential cumulative effects to health and safety would be similar in type and extent from those associated with previous projects, such as prescribed burning and timber harvesting, across the district and would not be significant. The use of herbicides carries some risks to human health and safety, particularly to the applicator. This risk is reduced by requiring the applicator to be trained in safety precautions, proper use, and handling of herbicides. Other factors reducing the risk of herbicide use to human health and safety is the low level of active ingredient per acre and placement of notice signs posted in areas where herbicide has been applied. The signs include information on the herbicide used, when it was applied, and who to contact for additional information (see also Appendix B, Standard Mitigation Measures for Herbicide Use). All standards in the current Forest Plan which relate to herbicide use will be met. An Emergency Spill Plan that outlines procedures to be followed in the event of an accidental spill is included in the Appendix. The Emergency Spill Plan also contains information on providing care to persons who are exposed to a spill. In cut surface treatment, herbicide is applied directly to a freshly cut stump in an amount that will not run off. The herbicide is rapidly absorbed into the stump and is dry within an hour of


treatment. When applied at the required typical rate, these herbicides pose an insignificant risk (systemic and reproductive) to the public either from dietary exposure (water, fish, meat, vegetable, foraged berry) or dermal exposure (on-site or drift) (VMEIS, Volume 1, IV-16). To mitigate any possible contact with the public, dye is added to the herbicide and warning signs are placed in all treatment areas. Cumulative effects that might result from the use of herbicides on private land are difficult to assess. The use of herbicides on private land is generally for the control of woody plants near homes. Other small projects on the district that are currently proposing herbicide use are minimal and well distributed across the project area, thus posing no additional cumulative effects. The treatments are also proposed for implementation over a 10 year period of time. For these reasons and because the effects to human health and safety are likely to be small, Alternative 2 will result in few or no cumulative impacts to human health and safety. Cumulative effects include effects resulting from the use of herbicides on private land which is difficult to assess. Herbicides are typically applied on private land only for agricultural production, including crops and/or pine forests, but all herbicide label requirements should be followed in all cases. Nonnative invasive plant control treatments are likely to be repeated on the same sites as much as 6 times during the next 10 years. Silvicultural treatments within forest communities would be limited to two treatments over the next five years, and follow up treatments only used if surveys show a need for an additional treatment. Since half-lives of all of the herbicides considered are low to moderate, especially in warm weather, and they do not accumulate in soils or organisms, the effects to human health and safety are likely to be small. Safety standards on herbicide labels will be followed in all cases. Therefore, the Proposed Action, including activities relating to the use of prescribed fire, timber harvesting, and herbicides should result in few or no cumulative effects to human health and safety. 3.11 IRREVERSIBLE OR IRRETRIEVABLE COMMITMENT OF RESOURCES There would be no irretrievable commitment of resources as a result of the Sumac Creek action alternatives, as there are no areas proposed for construction of new roads. 3.12 CONSISTENCY WITH LAWS None of the alternatives threatens a violation of Federal, State, or local law or requirements imposed for the protection of the environment. As documented in this EA or in the project file, alternatives would be consistent with the following applicable laws and Executive Orders: American Indian Religious Freedom Act of 1978 Antiquities Act of 1906 (16 USC 431433) Archaeological and Historical Conservation Act of 1974 (16 USC 469) Archaeological Resources Protection Act of 1979 (16 USC 470) Cave Resource Protection Act of 1988 Clean Air Act of 1977 (as amended)


Clean Water Act of 1977 (as amended) Endangered Species Act (ESA) of 1973 (as amended) Forest and Rangeland Renewable Resources Planning Act (RPA) of 1974 (as amended) Historic Sites Act of 1935 (16 USC 461467) Multiple Use Sustained Yield Act of 1960 National Environmental Policy Act of 1969, (as amended) (42 USC 43214347) National Forest Management Act (NFMA) of 1976 (as amended) National Historic Preservation Act of 1966 (16 USC 470) Organic Act 1897 Prime Farmland Protection Act Wild and Scenic Rivers Act of 1968, amended 1986 Forest Service Manuals such as 2361, 2520, 2670, 2620, 2760 Executive Order 11593 (cultural resources) Executive Order 11988 (floodplains) Executive Order 11990 (wetlands) Executive Order 12898 (environmental justice) Executive Order 12962 (aquatic systems and recreational fisheries) Executive Order 13112 (NNIS)


Chapter 4 – Consultation and Coordination 4.0 PREPARERS The Forest Service consulted with the following individuals persons during the development of this environmental assessment:

Table 4.1: Forest Service Interdisciplinary Team. Specialist Responsibilities

Daryl Hodges—Wildlife Biologist Inter Disciplinary Team Leader

Kurt Steele—Silviculturist Silviculture

Elizabeth Caldwell—District Wildlife Biologist Wildlife, Botany, and NNIS

Stacy Lundgren—District Archeologist Heritage Resources

Tim Kolnik—District Fire Management Officer Fire and Fuels

Melissa Anderson—Engineering Technician Roads

Jeff McDonald—Recreation Program Manager Recreation

Mara Jones-Branch—Timber Management Assistant

Timber

Dick Rightmyer—Forest Soil & Water Scientist Soils & Water

Joanne Baggs—Forest Botanist/Ecologist Range, Botany, and NNIS


CHAPTER 5 -- REFERENCES Arnup, R.W. 1998. The extent, effects and management of forestry-related soil disturbance, with reference to implications for the clay belt: a literature review. OMNR, Northeast Science Technology. Technical Report TR-037. 30p. Fisher, R.F., and D. Binkley. 2000. Ecology and Management of Forest Soils (3rd Edition) Wiley, New York. 489 p Hancock, D.W., R.C. Lacy, and R.L. Stewart, Jr. 2011. Forage Systems for Stocker Cattle. UGA Cooperative Extension Bulletin 1392. The University of Georgia Cooperative Extension. Georgia Department of Natural Resources. 2007. Total Maximum Daily Load Evaluation for Seventy-Two Stream Segments in the Oconee River Basin for Fecal Coliform. Georgia Department of Natural Resources, Environmental Protection Division, Atlanta, GA. Georgia Department of Natural Resources. 2013. The 305(B) and 303(d) Listing of Waters for the waterbodies of Georgia. Georgia Department of Natural Resources, Environmental Protection Division, Atlanta, GA. Georgia Department of Natural Resources. 2012. Water Quality in Georgia, 2010-2011. Georgia Department of Natural Resources, Environmental Protection Division, Atlanta, GA. McKee, Jr. W.H., G.E. Hatchell and A.E. Tiarks. 1985. Managing site damage from logging. USDA For. Serv. Southeastern Experiment Station Gen. Tech. Rep. SE-31. 21pp. Miller, Richard E., S.R. Colbert, and L.A. Morris. 2004. Effects of heavy equipment on physical properties of soils and on long-term productivity: a review of literature and current research. National Council for Air and Stream Improvement, Research Triangle Park, NC. Technical Bulletin No. 887. Potyondy, John P. and Geier, T.W. 2011. Watershed Condition Classification Technical Guide. USDA Forest Service, Washington, D.C. Publication FS-978, 41pp. Surrency, D. and C.M. Owsley. 2006. Native Warm-Season Grasses in Georgia, Alabama, South Carolina. USDA-NRCS Jimmy Carter Plant Materials Center, Americus, Georgia.

TACCIMO Climate Change Report: South Carolina, unpublished, July 2, 2014. Trimble, S. W. 1974. Man-induced soil erosion in the southern Piedmont, 1700-1970. Soil and Water Conservation Society, Akeny, IA. 188 p.


USDA Forest Service. 2003. FSH 2509.18 - Chapter 2 – Soil Quality Monitoring. Soil Management Handbook. Atlanta, GA. U.S. Department of Agriculture, Forest Service, Southern Region. USDA Forest Service. 2004. Chattahoochee-Oconee National Forests Land and Resource Management Plan. R8-MB 113E. Atlanta, GA. U.S. Department of Agriculture, Forest Service, Southern Region. USDA Forest Service. 2012. National Best Management Practices for Water Quality Management on National Forest System Lands. Volume 1: National Core BMP Technical Guide. USDA Forest Service, Washington, D.C. Publication FS-990a. ISDA Forest Service. 2011. Oconee Forest health and Wildlife Habitat Improvement Project. Eatonton, GA. U.S. Department of Agriculture, Forest Service, Southern Region, Chattahoochee-Oconee National Forest, Oconee Ranger District. USDA Forest Service. 2009. Process used in mapping Ecological Classification System (ECS) Units on the Oconee National Forest of the Georgia Piedmont. Gainesville, GA. U.S. Department of Agriculture, Forest Service, Southern Region, Chattahoochee-Oconee National Forest. Wear, D. J, and J.G. Greis. 2013. The Southern Forest Futures Project: technical report. Gen. Tech. Rep. STS-GTR-178. Asheville, NC; USDA-Forest Service Southern Research Station. 542 p.


APPENDIX A

Overview Map


Carey Station Range Allotment Map


Cold Springs 1 & 2 Range Allotments Map


Dyar Pasture Range Allotment Map


Gladesville Range Allotment Map


Greenbriar Creek Range Allotment Map


Penfield Range Allotment Map


Redlands Range Allotment Map


Sellars Range Allotment Map


Town Creek Range Allotment Map


APPENDIX B

STANDARD MITIGATION MEASURES FOR HERBICIDE USE

1. Herbicides are applied according to labeling information and the site-specific analysis done for projects. This labeling and analysis are used to choose the herbicide, rate, and application method for the site. They are also used to select measures to protect human and wildlife health, non-target vegetation, water, soil, and threatened, endangered, proposed, and sensitive species. Site conditions may require stricter constraints than those on the label, but labeling standards are never relaxed.

2. Only herbicide formulations (active and inert ingredients) and additives registered by EPA and approved by the Forest Service for use on national forests are applied.

3. Public safety during such uses as viewing, hiking, berry picking, and fuelwood gathering is a priority concern. Method and timing of application are chosen to achieve project objectives while minimizing effects on non-target vegetation and other environmental elements. Selective treatment is preferred over broadcast treatment.

4. Areas are not prescribed burned for at least 30 days after herbicide treatment. 5. A certified pesticide applicator supervises each Forest Service application crew

and trains crew members in personal safety, proper handling and application of herbicides, and proper disposal of empty containers.

6. Each Contracting Officer's Representative (COR), who must ensure compliance on contracted herbicide projects, is a certified pesticide applicator. Contract inspectors are trained in herbicide use, handling, and application.

7. Contractors ensure that their workers use proper protective clothing and safety equipment required by labeling for the herbicide and application method.

8. Notice signs (FSH 7109.11) are clearly posted, with special care taken in areas of anticipated visitor use.

9. Triclopyr is not ground-applied within 60 feet, of known occupied gray bat habitat. Buffers are clearly marked before treatment so applicators can easily see and avoid them.

10. No herbicide is ground-applied within 60 feet of any known threatened, endangered, proposed, or sensitive plant. Buffers are clearly marked before treatment so applicators can easily see and avoid them Selective applications to control competing vegetation within this buffer designated to protect TES plants may occur when needed to protect the TES plants from encroachment by invasive plants and when a non-soil active herbicide is used.

11. Application equipment, empty herbicide containers, clothes worn during treatment, and skin are not cleaned in open water or wells. Mixing and cleaning water must come from a public water supply and be transported in separate labeled containers.

12. No herbicide is ground-applied within 100 horizontal feet, of lakes, wetlands, or perennial or intermittent springs and streams. No herbicide is applied within 100 horizontal feet of any public or domestic water source. Selective treatments


(which require added site-specific analysis and use of aquatic-labeled herbicides) may occur within these buffers only to prevent significant environmental damage such as noxious weed infestations. Buffers are clearly marked before treatment so that applicators can easily see and avoid them.

13. Herbicide mixing, loading, or cleaning areas in the field are not located within 200 feet of private land, open water or wells, or other sensitive areas

14. During use, equipment to store, transport, mix, or apply herbicides is inspected daily for leaks.

15. Herbicides and application methods are chosen to minimize risk to human and wildlife health and the environment. No class B, C, or D chemical may be used on any project, except with Regional Forester approval. Approval will be granted only if a site-specific analysis shows that no other treatment would be effective and that all adverse health and environmental effects will be fully mitigated. Diesel oil will not be used as a carrier for herbicides, except as it may be a component of a formulated product when purchased from the manufacturer. Vegetable oils will be used as the carrier for herbicides when available and compatible with the application proposed.

16. Herbicides are applied at the lowest rate effective in meeting project objectives and according to guidelines for protecting human (NRC 1983) and wildlife health (EPA 1986a). Application rate and work time must not exceed levels that pose an unacceptable level of risk to human or wildlife health. If the rate or exposure time being evaluated causes the Margin of Safety (MOS) or the Hazard Quotient (HQ) computed for a proposed treatment to fail to achieve the current Forest Service R-8 standard for acceptability (acceptability requires a MOS > 100 or a HQ of < 1.0 using the most current of the SERA or Risk Assessments found on the Forest Service website). Additional risk management must be undertaken to reduce unacceptable risks to acceptable levels, or an alternative method of treatment must be used.

17. Weather is monitored and the project suspended if temperature, humidity, or wind becomes unfavorable for correct application as shown in Table 1.

Table 1. Weather Restrictions for Herbicide Application

Application Method Temperatures Higher Than

Humidity Less Than

Wind (at target) Greater Than

Ground: Hand (cut surface) N.A. N.A. N.A. Hand (other) 98oF 20% 15 mph Mechanical: Liquid 95oF 30% 10 mph Granular N.A. N.A. 10 mph Aerial: Liquid 9OoF 50% 5 mph Granular N.A. N.A. 8 mph


18. Nozzles that produce large droplets (mean droplet size of 50 microns or larger) or streams of herbicide are used. Nozzles that produce fine droplets are used only for hand treatment where distance from nozzle to target does not exceed 8 feet.

19. Pesticide mixing, loading, or cleaning areas in the field are located at least 50 feet from ephemeral streams.

20. No-soil active herbicide with half-life longer than three months is broadcast within 25 feet of ephemeral streams. Selective treatments with aquatic-labeled herbicides are allowed. Such areas are clearly marked before treatment so that applicators can easily see and avoid them.

21. No herbicide is broadcast within 100 feet of private land or 300 feet of a private residence, unless the landowner agrees to closer treatment. Buffers are clearly marked before treatment so applicators can easily see and avoid them.


APPENDIX C

RESULTS OF THE RISK ASSESSMENT – DETAILED SUMMARY

Effects of all herbicides have been assessed in the Final Environmental Impact Statement for Vegetation Management in the Appalachian Mountains (VMEIS). For all herbicides considered, an additional risk analysis was completed using methodology developed for the Forest Service by Syracuse Environmental Research Associates (SERA – Version 5.00.64a). The details of the risk assessment results are available in the project record. In the risk assessments, there are two terms not used in the VMEIS. These are Reference Dose (RfD) and Hazard Quotient (HQ).

• RfD - Derived by USEPA, this is the maximum dose in mg of herbicide active ingredient per kg of body weight per day that is not expected to cause injury over a lifetime of exposure. In other words, it is, in EPA’s opinion, a “safe” lifetime daily dose. This is a conservative estimate, and is designed to be protective.

• HQ - This is the ratio of the estimated exposure dose to the RfD. A HQ of 1 reflects an exposure to amounts of a.i. equal to the RfD; HQs less than 1 reflect exposures to amounts of a.i. less than the RfD, while HQs greater than 1 reflect exposures to amounts of a.i. greater than the RfD. HQs of 1.0 or less reflect exposure levels that are not of concern. HQs greater than 1.0 reflect exposures to possible effects to be examined more closely to see if the projected exposures need to be further mitigated or need to be avoided. For the effects on wildlife, one must remember that these effects are constructed for individuals and not populations.

For Alternative 2, the spill plan in Appendix E would be in place. Alternative 2 assumes that all of the mitigation measures in Chapter 2 and Appendix B of this document would be followed, as would mitigation measures in the VMEIS. Published analyses of environmental effects in the VMEIS are not duplicated in this document. However, information published subsequent to the VMEIS encountered in the open literature that is both relevant to this analysis and demonstrates a potential for significant effect on the conclusions drawn in the VMEIS has been included in the current analysis. The risk analysis is based on the standard application rates in the SERA Version 5.00.64a Worksheets. In some cases, the actual application rates for this project may be lower than the standard application rates. Since results of the risk analysis with lower application rates would be the same or less as using the standard application rates, new scenarios for lower application rates were not run for this analysis. The following tables show the basis for the estimated application rates that will be used in this project.


Herbicide Application Rate Assumptions for Foliar Spray Applications

Herbicide Lbs ai/gal % solution Gallons of

spray/acre Lbs ai/acre

Glyphosate 5.4 2.0% 10 2.0 Triclopyr (amine) 3.0 4% 25 1.0 Triclopyr (ester) 4.0 2.0% 25 1.0 For each herbicide, hazard quotients are developed that summarize risk characteristics for workers, the general public, terrestrial animals and aquatic species. For this analysis, hazard quotients derived from spill scenarios into ponds have been set to zero. The reason is that the project has mitigation measures in place (Appendix A) that make such spills so unlikely that such an analysis would be irrelevant. In addition, in the unlikely event this should occur, expedited clean up and exclusion from use are required until clean up has been accomplished. The specific spill scenario referenced is: acute/accidental exposure, contaminated water consumed by a child (EO4 sheet). Hazard quotients for the general public involving direct spray exposures to the entire body or lower legs are also considered so unlikely as to be irrelevant. These have also been set to zero. The most important hazard quotient is the general exposure HQ for workers. These are the people most likely to have direct exposure to herbicides. According to the Forest Service Southern Region Pesticide Specialist, the central HQ best reflects a realistic upper exposure and risk for workers using required personal protective equipment and employing proper washing and hygiene habits. The herbicides considered for use in this EA are glyphosate and triclopyr. Hazard quotients were calculated for the estimated application rates for this project. HQ’s over 1.0 are discussed below.

Glyphosate, injection or cut stump treatment @ 2.0 lbs/acre Glyphosate was analyzed under two situations, with and without the use of a surfactant. Because the use of a surfactant (most commonly a detergent) would slightly increase any toxicity, those results are reported here. Results for typical exposures of glyphosate are all less than 1.0 for human health (Sheet E04). The upper bound HQ is 1.4 for consumption of contaminated vegetation by an adult female. However, the upper bound exposure is most unlikely for the following reasons:



• With cut surface or injection application, the amount of non-target vegetation subject to spray deposition is very small.

Wildlife G03 sheet, acute exposure hazard quotients to fish, aquatic invertebrates and aquatic macrophytes for accidental spills have calculated values over 1.0. Such exposures and risk are most unlikely for glyphosate. This is because glyphosate is strongly adsorbed to (bound to the surface of) both organic matter and clay particles. Therefore it is very immobile in the environment, and unlikely to reach aquatic habitat. Even in the unlikely event that it might reach such habitat, it would probably be quickly bound to sediment or organic matter in the stream. In addition, with the provision of riparian buffer strips on stream zones, the risk is further reduced. This includes a standard that prohibits non-aquatic labeled herbicide application within 100 horizontal feet of lakes, wetlands, or perennial or intermittent springs and seeps (FW standard FW-022). In riparian areas, only herbicides that are specifically labeled for aquatic use may be used.

Triclopyr (amine) cut surface or foliar application @ 3.75 lbs/acre Human health E02 sheet, general exposure for workers, upper bound HQ = 6.0, upper bound for spill on hands is 0.3 and upper bound for spill on lower legs is 0.9. Typical exposures are 1.0 or less. The upper bound exposure is most unlikely for the following reason:

• According to the Forest Service Southern Region Pesticide Specialist, the central HQ best reflects a realistic upper exposure and risk for workers using appropriate personal protective equipment and employing proper washing and hygiene habits. Forest Service personnel are required to follow these safety protocols whenever applying pesticides. Rapid personal cleanup in the event of any exposure should keep the dosage internalized (the hazard) in the typical, rather than the upper bound range.

Human health E04 sheet, the typical HQ for vegetation contact of an adult female in shorts and a t-shirt is 3.0 and the lower level is 1.0. However, this scenario is unlikely since herbicide application areas are signed to preclude accidental exposure and with cut surface or injection application, the probability of exposure is low.

For acute exposure, the upper bound HQ for consumption of fruit by an adult female is 6.0. Typical exposures are above 1.0. The typical HQ for consumption of vegetation by an adult female is 12.0 and the lower level is 0.8. However, consumption of contaminated fruit and vegetation is unlikely for the following reasons:

• Herbicide application areas are signed to preclude accidental exposure. • With cut surface or injection application, the amount of non-target vegetation

subject to spray deposition is very small.


Long term exposure for a female, contaminated fruit, upper bound HQ = 9.0. Typical exposures are less than 1.0 at a value of 0.4. The typical HQ for long term consumption of vegetation by an adult female is 6.0 and the lower level is 0.3. The upper bound exposures are most unlikely for the following reasons:

• Herbicide application areas are signed to preclude accidental exposure. • The scenario assumes that for a long term exposure to occur contaminated fruit or

vegetation eaten 90 days in a row. • Blackberries, the only types of fruit likely to be available in any substantial

quantity, would not continue to ripen for more than approximately one week after treatment. After that time, they would be unavailable to berry foragers.


Wildlife G02 sheet, long term consumption of contaminated vegetation by a large mammal and large bird, shows typical HQs of 1.9 and 1.5, respectively. These hazard quotients are not of significant concern because:


• The scenario assumes a diet composed of 100% contaminated vegetation from the site. The diets of large mammal and birds such as deer and turkey are highly variable and include hard and soft mast (deer and turkeys), insects and seed (turkey) as well as green vegetation. Large mammals and large birds also typically have fairly large home ranges. The scenario also assumes that such vegetation will be consumed from the same sites for 90 consecutive days. The rate at which treated vegetation becomes unappetizing and then unavailable to foraging mammals and birds following treatment make the assumptions proposed for this scenario quite unrealistically conservative for the project area.

Although there are upper level values above 1.0 for small mammals eating a contaminated insect and large mammals eating grass, the typical values are all less than 1.0. Typical values represent the most likely situation. In addition to the effects described above, direct effects to birds or mammals are unlikely since these species are likely to move from the area when project activities are implemented. Although direct effects to amphibians are more likely since contact with herbicide could be absorbed through the skin and effect metabolic activity, amphibians are likely to be under logs, rocks or leaves, making direct contact with chemicals less likely. Direct effects to other non-target plants occurring in these habitats could occur. Application methods, including direct application to target foliage or freshly cut stumps, would minimize the possibility for spills and/or direct contamination to non-target species. Wildlife G03 sheet, the upper exposure HQ’s for fish and aquatic invertebrates for accidental spills exceed 1.0 but typical exposure HQ’s are less than or equal to 1.0.


The typical exposure HQ for aquatic plants and algae are greater than 1.0 for accidental spills. These are not of concern because:

• With the provision of riparian buffer strips around streams, the risk of herbicide spills or movement into streams is further reduced.

• Mixing and dilution in active streams will minimize any potential hazard from any small spills which might occur during implementation of this project.

• Most herbicide application in the project will be confined to the mid-upper slopes and ridgetop sites, well away from any streams. No herbicide application will occur within the riparian corridor, unless specifically labeled for aquatic use.

Hazard quotients for exposure of terrestrial vegetation from runoff of triclopyr amine (Sheet G04) have hazard quotients greater than 1.0 in areas with more than 25 inches of rainfall per year. These values vary depending on the average annual rainfall in a given area and the scenarios assume that rain falls every 10 days. The typical value for an area with 50 inches of annual rainfall is 1.4. However, all proposed herbicide applications are to be applied directly to the targeted vegetation; therefore by correctly following application procedures, impacts to non-targeted species would be minimal. Although some loss of terrestrial plants could possibly occur, there are mitigation measures already in place to protect sensitive species so overall effects should be minimal.

Triclopyr (ester) cut surface or foliar application @ 1.0 lbs/acre Human health E02 sheet general exposure for workers, upper bound HQ = 1.6. Typical exposures are less than 1.0 at a value of 0.3. The upper bound exposure is most unlikely for the following reason:

• According to the Forest Service Southern Region Pesticide Specialist, the central HQ best reflects a realistic upper exposure and risk for workers using appropriate personal protective equipment and employing proper washing and hygiene habits. Forest Service personnel are required to follow these safety protocols whenever applying pesticides.

Human health E02 sheet, accidental exposure of a worker to contaminated gloves shows a typical HQ of 0.5 and an upper bound HQ of 4.0. This is unlikely to occur because the scenario assumes that the contaminated glove will be left on the hands in direct contact with the skin for 1 hour. Labeling instructions and worker protection standards require proper hygiene. Contaminated gloves should be removed immediately and both the contaminated skin and gloves should be washed with an appropriate soap or detergent, and water. The typical HQ for vegetation contact of an adult female in shorts and a t-shirt is 1.3 and the upper level is less than 1.7 (Sheet E04). However, this scenario is unlikely since


herbicide application areas are signed to preclude accidental exposure and the scenario assumes contact occurs while the vegetation is still wet. The typical HQ for consumption of vegetation by an adult female is 3.0 and the lower level is 0.2 However, consumption of vegetation is unlikely for the following reasons:



The typical HQ for long term consumption of vegetation by an adult female is 1.6 and the upper level is 18. These hazard quotients are not of significant concern because:

• Herbicide application areas are signed to preclude accidental exposure. • The scenario assumes that for a long term exposure to occur contaminated

vegetation eaten 90 days in a row. • With cut surface or injection application, the amount of non-target vegetation

subject to spray deposition is very small. Wildlife G02 sheet, longer term exposure (90 days) of a large bird or large mammal to contaminated vegetation on site, had upper level HQ’s above 1.0. Typical values were less than 1.0. The upper level hazard quotient is not a concern for the following reason:

• The scenarios assume a diet composed of 100% contaminated vegetation from the site. The diets of large mammal and birds such as deer and turkey are highly variable and include hard and soft mast (deer and turkeys), insects and seed (turkey) as well as green vegetation. Large mammals and large birds also typically have fairly large home ranges. The scenario also assumes that such vegetation will be consumed from the same sites for 90 consecutive days. These assumptions make the scenario quite unlikely.

. Wildlife G03 sheet, the exposure HQ for aquatic plants, algae and fish had typical values greater than 1.0 from an accidental spill and for aquatic plants and algae typical HQ values exceed 1.0 for peak EEC (Expected Environmental Concentrations). This is not of significant concern because:

• With the provision of riparian buffer strips on streams, the risk of herbicide spills or movement into streams is further reduced.

• Mixing and dilution in active streams will minimize any potential hazard from any small spills or runoff which might occur during implementation of this project.


• All herbicide application in the project will be confined to the mid-upper slopes and ridgetop sites, well away from any streams. No herbicide application will occur within the riparian corridor, unless specifically labeled for aquatic use.

Hazard quotients for exposure of sensitive and tolerant terrestrial plants from runoff of triclopyr ester have hazard quotients greater than 1.0 for areas which receive more than 20 inches of annual rainfall. These values vary depending on the average annual rainfall in a given area and the scenarios assume that rain falls every 10 days. However, all proposed herbicide applications are to be applied directly to the targeted vegetation; therefore by correctly following application procedures, impacts to non-targeted species would be minimal. This will further protect non-targeted vegetation, including rare plants, from any direct or indirect impacts. Although some loss of terrestrial plants could possibly occur, there are mitigation measures already in place to protect sensitive species so overall effects should be minimal.


APPENDIX D

MODE OF ACTION IN PLANTS FOR HERBICIDES

PROPOSED FOR USE IN THIS PROJECT

Glyphosate – is a wide spectrum herbicide and is effective in treating a variety of annual and perennial herbaceous species including grasses. It is not as effective in penetrating woody bark. Because it is non-selective, application or drift spray could affect non-target vegetation if care is not taken. Where it is used for aquatic treatments, only specified formulations would be used that are registered for aquatic use. In water, it is rapidly dissipated through adsorption to suspended and bottom sediments. It is strongly adsorbed to soil particles, which prevents it from excessive leaching or from being taken up from the soil by non-target plants. It is degraded primarily by microbial metabolism, but strong adsorption to soil can inhibit microbial metabolism and slow degradation. Soil microorganisms break down Glyphosate and the surfactant used to carbon dioxide. (SERA 2004)

Triclopyr – is a selective systemic herbicide used to control woody and herbaceous broadleaf plants. Triclopyr controls target weeds by mimicking the plant hormone auxin, causing uncontrolled plant growth that leads to withering and death. It is absorbed through the roots, foliage and green bark of plants. Grasses are not as susceptible to this chemical. It is especially effective against root-or stem-sprouting species. Offsite movement through surface or subsurface runoff is a possibility with Triclopyr acid, as it is relatively persistent and has only moderate rates of adsorption to soil particles. In water, the salt formulation is soluble and, with adequate sunlight, may degrade in several hours. (SERA 2004)


APPENDIX E

EMERGENCY SPILL PLAN

1. PREVENTION AND READINESS In their vehicles, Contracting Officer Representative and crew leaders will carry copies of this spill plan, the herbicide labels and MSDSs for the herbicides, surfactants and dyes being used. They will also carry a vehicle spill kit having the contents specified at the end of this appendix. 2. PROVIDE FOR CARE OF INJURED OR CONTAMINATED PERSONNEL Immediately determine if any personnel are injured or contaminated. Assist with first aid of injured or contaminated personnel. Remove injured or contaminated personnel from the spill site to an area safe and free of pesticides. If eyes are contaminated with pesticide, give first priority to washing them out, using portable eyewash bottles, or if these are unavailable, wash with any clean water. Remove contaminated clothing from affected individuals, and wash pesticides off skin with detergent and clean water. If any pesticides have been ingested, see the Material Safety Data Sheet for specific first aid measures. Immediately seek medical assistance for injured and contaminated personnel. Do not leave contaminated individuals alone unless essential to secure aid. If necessary, direct a third person to stay with the injured until a physician takes charge and has been advised of the actual or possible pesticide exposure. Watch for the following symptoms of pesticide poisoning: Eye irritation, skin irritation, discomfort or pain in stomach or intestinal area, dizziness, headache, nausea, vomiting, diarrhea, slurred speech, muscle twitching or convulsions, or difficulty in breathing. 3. SPILL IDENTIFICATION Determine product name for chemical or chemicals spilled and check the label and Material Safety Data Sheet for immediate hazards. Extinguish all flames and possible ignition sources and stop any smoking by personnel in case chemicals are flammable. Isolate the contaminated area and keep unnecessary persons away from the spill site. 4. NOTIFY AND INFORM District Pesticide Coordinator: Kelvin Jackson at (706) 485-7110 ext. 118 District Safety Officer: Brad Elliot, telephone: (706) 485-7110 ext. 127 Forest Pesticide Coordinator:

Brian Jackson, telephone: (770) 297-3020 Forest Safety Office: Chip Manson, telephone: (770) 297-3077


Speak directly with at least one of the above personnel, in order or priority, and inform as to: a. Chemical Name and Brand Name b. Location of Spill c. Compartment and Stand Number d. Nearest Road Name and Number e. Size or Volume of Chemical Spilled 5. CONTAIN THE SPILL Contain the spilled pesticide. Keep spill from entering streams, drains, wells, ditches, or other water systems. Wear appropriate and approved protective clothing, including rubber or nitrile gloves, safety glasses, or goggles, overalls or rain suit, rubber boots or overshoes, or a respirator if extra protection is needed. Prevent further leakage from containers by repositioning them so that the damaged part of the container is above the level of the containers, or by applying rags, tape, or other materials at hand to temporarily seal the leak. Separate leaking containers from undamaged containers. Flag off the area and post warning signs to keep unprotected personnel from entering. Confine the spill to prevent it from spreading. Encircle the spill area with a dike of sand or other absorbent material. Rags or similar material may be used if necessary. If spilled material may flow toward sensitive areas, divert it by ditching. If the soil involves a small watercourse, dam it to confine the spill if possible. If available, activated charcoal may be used to filter contaminated water. For larger waterways, a log boom or baled straw may used to contain the spill. Dam or divert the flow of clean water around the spill if possible. Some pesticides (such as glyphosate) may be inactivated by muddying the water. If a liquid pesticide is spilled on land, cover the spill with absorbent material (kitty litter). If the spilled pesticide is in a dry formulation, cover it with a secured plastic tarpaulin to prevent it from becoming wet or being blown away. Contained materials must be reused if possible, or disposed of as toxic waste. Do not flush contained or spilled pesticides into ditches, sewers, drains, or off of a road, since this will further spread the chemical. Small spills require use of vehicle spill kits. Large spills may require the use of a dozer and or additional items from the storage facility spill kit.

SUMMARY OF CLEAN UP STEPS


DRY SPILLS

1. Cover powder or dust chemicals with a tarpaulin to prevent it from becoming airborne. A fine mist may also dampen the chemical to reduce spreading. Too much water may dissolve the chemical. Use caution.

2. Sweep the material together as the tarp is rolled slowly back. 3. Shovel the material into plastic bags or drums. 4. Seal the bags and label them, identifying the pesticide and other contents. 5. Store the containers of material in the pesticide storage building until the content can

be evaluated for disposal or re-used in a manner consistent with labeling. LIQUID SPILLS 1. Pump or bail as much of the spilled liquid as possible into containers. 2. Use absorbent material, such as commercially bagged clay, kitty litter, or sawdust to

soak up the spill. Use only enough material to absorb the spill. Begin spreading the absorbent material around the edge of the spill, and work toward the center.

3. Shovel the absorbent material and pesticide, along with any contaminated soil, into leak proof containers.

4. Label all containers. 5. Store the containers in the pesticide storage building until the contents can be evaluated for disposal or re-use in a manner consistent with labeling. LIST OF OTHER KEY PERSONNEL AND AGENCIES

Georgia Emergency Services: (800) 338-6745

Poison Control Center (404) 616-9000

Putnam General Hospital (706) 485-2711

Local Fire Departments 911

Local County Sheriff 911


RECOMMENDED PESTICIDE SPILL KIT CONTENTS

Storage Facility Kit Vehicle Kit 4 pairs of nitrile gloves 2 pairs of nitrile gloves 2 pairs non-vented goggles 1 pair of non-vented goggles 1 respirator and cartridge (chemical resistant) 1 pair of rubber or neoprene boots 2 pairs of rubber or neoprene boots or overshoes 1 shop brush or whisk broom 2 pairs of overalls or rain suits 6 polyethylene bags with ties 1 roll of flagging or engineers tape 1 pint liquid detergent 1 dust pan 1 polyethylene or plastic tarp 1 shop brush or whisk broom 10 blank labels 1 dozen polyethylene bags with ties 1 ABC type fire extinguisher 1 quart liquid detergent 30 lbs. absorbent material (kitty litter) 1 polyethylene or plastic tarp 2 eyewash bottles (filled) 10 blank labels 1 round point shovel 1 ABC type fire extinguisher 1 30-gallon plastic garbage can 80 lbs. absorbent material (kitty litter) with lid (use for cleanup 1 square point D handle shovel and transport) 1 30-gallon plastic garbage can with lid 1 roll of flagging (use for cleanup, storage and transport) 1 roll of duct tape 1 roll of duct tape


APPENDIX F

RESPONSE TO SCOPING COMMENTS

Listed in the following tables are groups and individuals that commented during the external scoping process with their comments and concerns.

John Clark Geiger, Vice President, Friends of Georgia, Dahloneag, GA Larry Winslett, Sierra Club, Georgia Chapter, Decatur, GA Darren Wolfgang, Georgia Forest Watch, Ellijay, GA Herbert C Daniels, Range Permittee, GA Tim Duvall, Range Permittee, GA John Dyar, Range Permittee, GA Sam Booher, Augusta, GA

Economics John Dyar 1) I cannot do rotational grazing because I have no other place to move cows. Rotational grazing may be implemented in a variety of ways. Grazing will be managed through the Allotment Management Plans as described in the proposed action.

Roads Management John Dyar 1) There is a need for the front and rear cattle crossing guards to be replaced. They need to be taken up and dug out under them and replaced. Thank you for identifying a maintenance need. General maintenance of range improvements including cattle guards is addressed in the proposed action. The adjacent recreation area in Dyar Pasture is also analyzed on pages 44-45 of the Environmental Assessment.

Range Management Georgia Forest Watch 1) What are the Annual Operating Plan (AOP) specifics already in place for existing/currently occupied allotments? This information is found in each Range Allotment Management Plan (AMP) in the allotment files. 2) FSH 2209.13, Ch. 90 seems to provide plenty of general guidance. How will you work to develop site specific BMPs for the units identified in this proposal? The process for developing site specific BMPs is listed on pages 9-11 and in the design criteria on page 11-13 of the Environmental Assessment. 3) It is our understanding that range allotments have existed on the district for many years. The Scoping promises that “adaptive management” will be used to develop new AOP’s for this proposal. Based on this information, it would seem like the district should already have plenty of baseline observations and that it should be able to make basic recommendations about animal unit months, problem areas, recommended rotation cycles, etc. We would be interested in learning more about this. The proposed action describes the current grazing systems and the proposed action list recommended changes. The Chapter 3 identifies site specific issues related to livestock grazing. 4) What kind of fertilizer will be used and how often?


Specific regimes for improving forage would depend on the current condition, soil tests, and desired condition as described in the proposed action of the Environmental Assessment (page 11). 5) What, if any measures will be taken to close the fertility loop of these grazing systems and move range allotments away from constant maintenance inputs (plowing, liming, fertilizing?) Long term objectives to convert the allotments to native grasses, as funding and opportunities allow, is described in the proposed action (page 11). 6) How will AOPs aide in maintaining and improving composition and distribution of native warm and cool season grasses? For example, what species are to be planted? What species are problematic and targeted for reduction/removal treatments? Invasive species and non-desirable species will be targeted for treatment as described in the proposed action and in Chapter 3 on pages 15-19 and pages 40-41. The AMPs will discuss desired conditions and steps to move towards that desired conditions based on the Forest Plan and this decision. Sam Booher 1) It is also my understanding that along with cattle grazing the Forest Service has no objection to grazing operations that include: use of seeding, herbicides use on Native Plants, fertilizing Public Forest lands and introducing non-native species to improve Forest Lands for domestic livestock. It appears to the public that your existing private cattle grazing program policy does not find these actions totally inappropriate for a National Forest and its watersheds. The Forest Plan determined these improved pastures were appropriate for livestock grazing. The proposed action described the range vegetation management that would be implemented. Friends of Georgia 1) I am writing to inform you that Friends Of Georgia (FOG) is opposed to all grazing on Georgia National Forests Lands. In fact we are opposed to grazing on all National Forest. As such we feel that the grazing allotments on the Oconee National Forest should be phased out and these lands be allowed to return to a forested or natural state. The Forest Plan determined these improved pastures were appropriate for livestock grazing. When there is no more interest in using the allotments, the allotment will be phase out according to the Forest Plan (GOAL 79). Any activities after the allotment is close would be address in future NEPA decisions. 2) While grazing has many negative impacts associated with it we are particularly opposed to the unnatural use of seeding, fertilizing, liming, and herbicides to maintain these lands for domestic livestock. Alternative 1, no action, described the effects of removal of grazing and associated management activities. Chapter 3 described the effects for the associated management activities. Sierra Club 1) I am writing to inform you that the Georgia Chapter of the Sierra Club is opposed to all grazing on Georgia National Forests Lands. In fact we are opposed to grazing on all National Forest. As such we feel that the grazing allotments on the Oconee National Forest should be phased out and these lands be allowed to return to a forested or natural state. The Forest Plan determined these improved pastures were appropriate for livestock grazing. When there is no more interest in using the allotments, the allotment will be phase out according to the Forest Plan (GOAL 79). Any activities after the allotment is close would be address in future NEPA decisions. 2) In our opinion grazing is the most pervasively destructive activity allowed on public lands and completely inconsistent with managing these lands for their higher values of watershed, natural habitat, and wildlife protection. The effects of livestock grazing and the associated management activities are described in Chapter 3.

Wildlife Georgia Forest Watch 1) What types of wildlife monitoring have been conducted to evaluate how existing range activities have impacted local wildlife (positively or negatively)?


The effects to wildlife are described in the Biological Evaluation and Chapter 3 on pages 37-39 in the Environmental Assessment. 2) The kinds of habitat created by these types of range activities are typically desirable to game species. Will these areas allow hunter access with prior coordination from the range permit holders and the USFS? Hunter access is beyond the scope of this project.

Herbert C. Daniel 1) It is a lot of wildlife at both of these locations. I see no need for anything to change. Everything looks like it’s in order. Thank you for your comment.

Tim Duvall 1) I am satisfied with the current arrangement that we have now, being that the water situation has been a problem since 2007. Planting wheat & grain sorghum is a big factor for wildlife & turkey. Thank you for your comment.

John Dyar 1) I believe the grasses in the pasture are fine for the wildlife in the area. I’m always seeing dear and turkey in the field. Thank you for your comment.

Water Quality Sam Booher 1) As a Soil & Water District Supervisor for the past four years, I have been allocating USDA funds to farmers to fence off their private land for cattle from streams and ponds. While at the same time the Forest Service is allowing private cattle an open range to our Forest Watersheds as part of your allowing grazing on Public Forest Lands. I offer the US Forest Service needs to decide is America going to have clean drinking water coming off Public Lands or are we going to continue to subsidize the Cattle Industry destruction of Public land and watershed pollution. Thank you for your comment. The effects to water resources are addressed in Chapter 3 on pages 19-36. Georgia Forest Watch 1) What (if any) data has been collected to evaluate whether or not current grazing operations are contributing to water quality impairment? The existing information and effects to water resources are addressed in Chapter 3 on pages 19-36. 2) How will manure and runoff be dealt with? The existing information and effects to water resources are addressed in Chapter 3 on pages 19-36.


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