Finger Lakes Invasive Pest Strategy (FLIPS) Project

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1 United States Department of Agriculture Forest Service February 2016 Finger Lakes Invasive Pest Strategy (FLIPS) Project Scoping Information Finger Lakes National Forest Hector Ranger District Town of Hector, Schuyler County and Town of Lodi, Seneca County, New York. Compartment 80- Softwoods and Ash in forest health decline. For Information Contact: Tim Noon Natural Resource Specialist Hector Ranger District Finger Lakes National Forest 5218 State Rte. 414, Hector, NY (607) ext. 316 Responsible Official: Jodie Vanselow District Ranger Hector Ranger District Finger Lakes National Forest 5218 State Rte. 414, Hector, NY (607) ext. 314

2 In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident. Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA s TARGET Center at (202) (voice and TTY) or contact USDA through the Federal Relay Service at (800) Additionally, program information may be made available in languages other than English. To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C ; (2) fax: (202) ; or (3) program.intake@usda.gov. USDA is an equal opportunity provider, employer and lender. This document can be made available in large print. Contact Tim Noon: (607) ext. 316

3 Introduction Finger Lakes Invasive Pest Strategy Scoping Information The USDA Forest Service is proposing to implement management activities (proposed action) on the Finger Lakes National Forest (FLNF) as part of the forest health themed Finger Lakes Invasive Pest Strategy (FLIPS) Project. The Hector District Ranger for the FLNF is seeking your input on this proposal. The FLIPS Project was initiated from an internal Forest Service effort to develop an invasive pest strategy for the FLNF. The strategy is based on the observed forest health decline visible in many forested stands on the FLNF, as well as the imminent threat posed by non-native invasive pathogens and insects such as the emerald ash borer (EAB.) The FLIPS Project proposes vegetation management to improve forest health on the FLNF with secondary goals to restore native forests and to improve wildlife habitat. This scoping information document includes the purpose and need for the project, a description of the proposed action, the decision to be made, and information on how you can submit comments on this project to the Forest Service. Forest Service activities such as those proposed in the FLIPS Project must follow regulations established by the National Environmental Policy Act of 1969 (NEPA) prior to implementation. Compliance with NEPA at the project level includes the disclosure of environmental effects of proposed activities, public participation, and preparation of a decision document that provides specific direction for project implementation. The environmental analysis for management activities proposed in the FLIPS Project is planned for documentation in a site-specific Environmental Assessment (EA). The FLIPS Project will be analyzed utilizing an expedited NEPA process following robust public collaboration under authority provided by the Healthy Forest Restoration Act (HFRA) as amended by the 2014 Farm Bill. Background The FLNF and the Northeastern U.S. in general has seen a rise in non-native invasive insect and disease proliferation over the past century that coincides with an increase in globalization and transportation. Insects and diseases not native to North America forests have the potential to devastate native North American forests and ecosystems that may lack the natural resistance or biological control required to regulate them. Prime examples of this potential and subsequent devastation are readily visible in the loss of American chestnut (Castanea dentata) to the landscape due to chestnut blight, and the near extirpation of American elm (Ulmus americana) trees due to Dutch elm disease, and Butternut trees (Juglans cinerea) to the butternut canker. The loss or severe decline of these three tree species alone have wide ranging and well documented ecological and economic impacts. With the increased quantity and pace of trade and transportation, the introduction of non-native invasive insects and diseases is increasing. More recent arrivals to forests of the Northeastern US from Asia or Europe include the hemlock wooly adelgid (HWA), Asian longhorned beetle, and the Emerald Ash Borer (EAB) to name a few. Each of these has the potential to or is already greatly impacting native forests. In the case of HWA and EAB, near total tree mortality can be expected inside infestation centers. Emerald ash borer has proven to be particularly prolific since its discovery in Michigan in the early 2000 s. The EAB, native to Asia, likely arrived in Michigan in the mid-1990 s in wood packing material carried by cargo ship or airplane, and has since spread to at least 24 states as well as Canada. In New York State as of 2015, there were 14 expanding EAB infestation centers spread across the state, with near total mortality occurring within each one. Finger Lakes Invasive Pest Strategy, Scoping Information Page 1

4 Finger Lakes Invasive Pest Strategy (FLIPS) The FLNF in cooperation with the Forest Service Northern Research Station (NRS) and Forest Service State and Private Forest Health Protection (FHP), has monitored the expansion of non-native invasive insects and diseases on and near the FLNF for many years. In 2011, the FLNF formed the Finger Lakes Invasive Pest Strategy (FLIPS) to address known forest health issues related to invasive insects and diseases, and to position itself ahead of future potential non-native insects and diseases outbreaks. This early strategy spawned many projects on the FLNF such as: The Butternut Scion Collection and Seed Orchard Project: This project involved the collection of scion (terminal branch endings) from Butternut trees exhibiting some resistance to the butternut canker. Scion material was then grafted to Walnut root stock, and planted on the FLNF s butternut seed orchard, creating a future potential source of canker resistant butternut seed. Figure 1 Riparian Elm Planting Riparian Elm Restoration Project: This project is a collaborative effort with the Forest Service NRS, to plant Dutch elm resistant American elm trees in fenced pasture riparian areas (Figure 1). The project promotes the study of Dutch elm resistance, as well as the efficacy of riparian planting techniques. Reintroduction of elm and other species through this project is also aimed at reducing the forecasted impact due to Ash tree lost in these riparian areas. Hemlock Wooly Adelgid Suppression Project: This project was developed collaboratively with input from the Forest Service FHP and Cornell University extension and involves designating approximately 3,000 acres of moderate to high density Eastern hemlock stands on the FLNF for potential biological and chemical treatment against the present infestation of HWA. Ash Seed Collection: Ash seed was collected in 2011 to preserve local genotype. The Finger Lakes Invasive Pest Strategy had not yet addressed many forest health concerns on the FLNF, creating the purpose and need for the FLIPS Project as detailed in this document further below. Healthy Forest Restoration Act The 2014 Farm Bill amended a portion of the Healthy Forest Restoration Act (HFRA) to allow special designation of areas with substantially increased tree mortality or increased risk of tree mortality due to insects and disease. The entirety of the FLNF became a designated area under this authority following request by New York State Governor, Andrew Cuomo and confirmation by Forest Service Chief, Tom Tidwell in the spring of 2014, for present or near present insect and disease threats such as HWA and EAB. Section 602 of the HFRA as amended by the 2014 Farm Bill allows for an expedited environmental analyses within designated areas. The decision to exercise the HFRA authority for this project is due to the imminent threat of invasive pests to the FLNF Forest resources. The HFRA limits an environmental assessment to include no more than two action alternatives: the Proposed Action and another alternative if necessary and meets the following criteria: 1) proposed during scoping or the collaborative Finger Lakes Invasive Pest Strategy, Scoping Information Page 2

5 process; and 2) meets the purpose and need of the project. FLIPS Project Collaborative Development Collaboration in the development of this project has taken place since the inception of the FLNF s invasive pest strategy in Early collaboration focused on input from cooperators in other branches of the Forest Service including the Northern Research Station (NRS) and State and Private Forest Health Protection (FHP). Early cooperators outside of the Forest Service include Cornell University Cooperative Extension, the National Wild Turkey Federation (NWTF), New York State Department of Environmental Conservation (DEC), and multiple local stakeholders. Additionally, information was sought by the Forest Service on regional response to insects and diseases such as EAB at meetings of local EAB task forces, and in consultation with New York State cooperators. From December 2015 through mid-february of 2016 the Forest Service concluded a more formal collaborative stage of project development in conjunction with a draft purpose and need and proposed action that was developed by Green Mountain and Finger Lakes National Forests staff. These collaborative efforts included: Cooperators: Sharing of proposed actions with frequent cooperators at Cornell University Cooperative Extension. Sharing of proposed actions with New York State DEC, and tour of DEC vegetation management activities in areas with current infestation of EAB. Sharing of proposed actions with Forest Service Northern Research Station (NRS) branch. Briefing and tour of proposed treatment areas with staff from NWTF. Organizations: Sharing and solicitation of feedback with FLNF Trail User groups. These groups include representatives from horseback, snowmobile, hiking, mountain biking, and trail running organizations. These groups represent a very engaged and highly diverse subset of FLNF users. Public: Briefed and solicited feedback from Town boards for Hector and Lodi, as well as residents in attendance. Held a project open house at the Hector Ranger District where a project briefing and solicitation of feedback was held with members of the public. Advertisement of the project and subsequent opportunities to be involved in the collaborative open houses through flyers placed around the community and through press releases distributed and carried by local media outlets. All informal and formal public collaboration resulted in no major issues being identified with the draft proposed action. As a whole, support for the project and interest in continued engagement were experienced at all levels of collaboration. As seen in prior collaborative efforts undertaken by the FLNF, general public interest in forest health issues and how those issues cross onto other municipality or private property was experienced. Purpose and Need for Action The FLIPS project is being proposed with a primary purpose to address current forest health conditions and near present forest health threats on the FLNF, with secondary purposes to a.) Restore native forests and b.) Improve wildlife habitat. The FLIPS project seeks to implement the 2006 Finger Lakes National Forest Land and Resource Management Plan (Forest Plan). The need for the project is Finger Lakes Invasive Pest Strategy, Scoping Information Page 3

6 identified through comparison of existing conditions on the ground with the desired future conditions established in the Forest Plan. Specifically, the purpose and need for this action according to the project objectives is to: Forest Health Slow the spread of non-native invasive insects and pathogens on the FLNF. Increase resilience to forest health threats on the FLNF through improved stand and tree vigor. Reduce the amount of forest stands currently overstocked. Reduce frequency of off-site plantations and promote native, site appropriate forest ecosystems. Minimize the impact to FLNF and town infrastructure such as roads and trails, through reduction of insect and disease related hazard trees. Improve crop tree performance, vigor, and ecosystem value through timber stand improvement activities. Restoration Restore off site softwood plantations to site appropriate Oak Hickory or Northern Hardwood type forests. Provide space for restoration research of near extirpated species through planting (American elm, American chestnut, etc.) Planting of select pasture hedgerows that experience decline due to insect and disease. Wildlife Improve stand structural and compositional diversity through reduction of plantation acreage. Create additional early successional habitat. Improve hardwood mast production. Existing Conditions Existing forest conditions include multiple forest health concerns and opportunities for restoration and wildlife habitat improvement work. Prominent among these is the presence of EAB within 20 air miles of the FLNF to the southwest near the town of Bradford, NY, and 30 miles to the northeast in the town of Montezuma, NY (see Figure 2 below). The EAB rate of spread can be upwards of 15 miles/year under its own power, and may be more easily transported against quarantine rules through movement of firewood. Stands of the FLNF comprise upwards of 30-50% ash species, resulting in the potential for widespread mortality within the next decade. The decline of ash species is already visible in some areas of the FLNF due to wet soils or ash yellows. Most noticeable, ash is in decline in several pasture hedgerows where the understory is comprised mostly of non-native invasive plants. Numerous other forest health concerns have been documented by Forest Service Forest Health Protection (FHP) staff which include various root rots, beech bark disease, and sirex wood wasp. Figure NY EAB Infestation Additional forest health threats are forecasted to potentially impact the FLNF in the next decade according to the Forest Service National Insect and Disease Risk Map (NIDRM) Finger Lakes Invasive Pest Strategy, Scoping Information Page 4

7 ( These potential impacts include general species declines already visible in the Northeast including Oak Decline or Maple Decline. The Forest Service Forest Health Advisory System also provides a summary of existing forest health threats (See attached FLNF Forest Health Advisory). Numerous FLNF stands in the Oak Hickory and Northern Hardwoods Forest Plan Management Areas that allow commercial timber harvest are currently overstocked as result of limited vegetation management activities over the past 20 years. This overstocking and subsequent tight competition for resources amongst individual trees may result in low individual tree vigor and overall stand resilience to incoming forest health threats. There also exists numerous softwood plantations on the FLNF that are non-native, or not site adapted. Examples include: Jack pine (planted south of its native range), Norway spruce (not native), red pine (planted in poorly drained soils), table mountain pine (planted north of its native range) and pitch pine (planted at northern limit of range). These overstocked or stagnating plantations also exhibit various root rots or the presence of the invasive sirex wood wasp, and many have native hardwood understories that are available to be released. Softwood plantations in addition to being in decline, also exhibit poor structural and compositional diversity desired by wildlife and contribute to the fragmentation of habitat due to their small size. Figure 3 Typical FLIPS Project Red Pine Stand Forest Plan Goals and Objectives-- Desired Future Conditions The following Forest-Wide Goals and Objectives are excerpted from the 2006 Forest Plan and provide guidance relative to the FLIPS Project: (Forest Plan pp 10-17) Goal 2: Maintain and restore quality, amount, and distribution of habitats to produce viable and sustainable populations of native and desirable non-native plants and animals. Forest-wide Habitat Composition and Structure Objectives 2.2-2: Maintain northern hardwood forests, native softwood forests, and forests of oak, hickory, and pine, on sites that ecologically support these habitats. Maintain, and where desirable increase, the acres of aspen and regenerating forest in order to support species that prefer these habitats. Promote Hardwood Mast species (Oak, hickory, beech, Goal 5: Maintain or restore ecological processes and systems on the FLNF within desired ranges of variability, including a variety of native vegetation and stream channel types, and their patterns and structural components. Finger Lakes Invasive Pest Strategy, Scoping Information Page 5

8 Objectives: Manage oak-pine natural communities on the FLNF to maintain their presence and continuity on the Forest, Convert planted softwood stands to native vegetation that is suited to the site. Goal 8: Provide for a sustainable supply of forest products. Objectives: Provide high-quality sawtimber and other wood products for local economies. Goal 14: Support regional and local economies through resource production and resource protection. Objectives: Increase coordination with communities and local businesses to enhance the economic contribution. Vary the range of project sizes for contracts. Maintain communications with Forest communities with regard to Payment in Lieu of Taxes, 25 Percent Fund, and/or Secure Schools and Community Self- Determination Act Goal 15: Maintain and enhance partnerships. Objectives: Increase the effective use of partnerships to achieve Forest goals. Increase coordination with State, county, and local agencies and landowners in the prevention, control, containment, and monitoring of non-native invasive species. Establish, maintain, or enhance partnerships with community organizations for resource planning. Increase work with communities in community development to enhance social capital and economic baseline. Management Area (MA) Desired Future Condition (DFC) Forest Plan MA direction provides Desired Future Conditions (DFC) for that area in which the desired future character of that landscape is described. (Forest Plan pp ) The DFC provides a snapshot of the desired ecological and visual character of a MA, as well as the types of uses (grazing, commercial harvest, etc.) and types of recreation that are anticipated. FLIPS Project activities are proposed for the Oak Hickory, Northern Hardwood, and Grassland for Grazing Management Areas (MA) as referenced in Table 2 below. The Desired Future Conditions for Oak Hickory, Northern Hardwood, and Grassland for Grazing MA s are incorporated for by the FLIPS Project. Overall forest health is necessary to provide the species diversity, stand conditions, and wildlife habitat described in each MA DFC. Forest health and restoration opportunities exist specifically to move deteriorating softwood plantations towards Oak Hickory or Northern Hardwoods MA DFCs. Plantations and old farm fields that have regenerated naturally following abandonment, and sale back to the federal government in the early 1900 s are now becoming overstocked or are stagnating in health, creating potential for native and non-native insect, disease, and plants to further a foothold on the FLNF. Several plantation areas show potential to be converted to natural forest communities due to understory or surrounding stand conditions. Both Northern Hardwood and Oak Hickory Management areas call for forested communities that would naturally be present, whereas current plantation stands are off site and growing poorly or are not native to the region (Jack pine, Table Mountain pine, etc.) Finger Lakes Invasive Pest Strategy, Scoping Information Page 6

9 Wildlife habitat diversification and improvement is expected with the restoration of Oak-Hickory and Northern Hardwood Management Areas stands from softwood monocultures and through the creation of early successional areas. Current plantations within the proposed project area provide very little in terms of habitat diversity. Habitat improvement is also sought in Grasslands for Grazing with hedgerows that have high density of Ash, most of which are already experiencing high levels of mortality and subsequent infestation of Non-Native Invasive Plants (NNIP). Proposed Action The FLIPS Project proposes 800 acres of vegetation management activities across the FLNF. The project area (see attached map) spans an approximate 10 miles from north to south and 6 miles from east to west. Designation of the project area took place based on extensive field visits by staff from the Green Mountain and Finger Lakes National Forests, Forest Service FHP, and cooperators. The stands proposed in this project are those identified as having the greatest needs according to the project goals for forest health, restoration, and wildlife habitat improvement as well as having the best alignment with Forest Plan goals and objectives and desired future condition. Acreage by treatment type is referenced in Table 1 below, and treatment by National Forest compartment and stand is referenced in Table 2 below. Vegetation Management Activities Various commercial and pre-commercial treatment activities would be used to achieve desired future condition and/or set the proposed FLNF forest stands on a trajectory towards meeting those conditions with particular respect towards improving forest health and resiliency, restoring stands, and improving wildlife habitat. Commercial timber harvest would be the primary tool utilized in meeting the project objectives and may include thinning, group selection, shelterwood, clearcuts, improvement cuts, and roadside firewood harvest. Specific harvest type proposed is based on whatever treatment is projected to best meet desired future conditions and project objectives on an individual stand basis. Recommendation for type of commercial harvest utilizes stand inventory data collected during the summer of 2015 and analyzed during the winter of Interdisciplinary team follow up visits were also conducted in proposed stands over the period 2014 to Pre-commercial treatment activities are to include timber stand improvement (TSI), also known as crop tree release. Timber stand improvement treatments involve the pre-commercial thinning of trees in stands that have had commercial management activities within the past 20 years to improve health and vigor of individual trees across a forested stand to meet forest health and wildlife objectives. A minor component of the project also includes the proposed planting of pasture hedgerows where Ash species are a dominant component. A diversity of native hardwoods and softwoods are proposed for planting in existing hedgerows where total ash loss is expected. To meet forest health objectives, prescriptions and harvest methods would be utilized that reduces overall stand density, promotes individual tree vigor, promotes stand diversity, as well as reduction of density in ash species. Reduction in density of Ash species is recommended practice ahead of emerald ash borer infestation as a way to limit the available food source (ash phloem), subsequently reducing potential insect numbers and slowing mortality. All proposed treatments across the project area will maintain the base theme to improve forest health by increasing stand vigor and resiliency, regardless of particular stand objectives for restoration or wildlife. To meet restoration objectives, the full range of commercial harvest options may be utilized to release existing advanced hardwood regeneration, or to recruit native hardwood regeneration. Softwood plantations are proposed for clearcut in situations where the stand is overstocked, stagnating, or starting to decline. Planting of clearcuts is proposed for areas with insufficient native regeneration in the understory. Thinning is proposed in stands where stocking is lower and softwoods may still be able to Finger Lakes Invasive Pest Strategy, Scoping Information Page 7

10 respond favorably to reduced competition, while also providing space for the establishment of a native hardwood understory. Commercial harvest also would meet wildlife objectives by increasing early successional habitat as well as creating structural, compositional stand diversity, and mast production. Table 1. Summary of the Proposal Proposed Vegetation Management Acres Thinning 52 Shelterwood with Reserves 103 Roadside Firewood 83 Improvement Cut 132 Group Selection 155 Clearcut 78 Timber Stand Improvement 123 Hedgerow Planting 74 Total 800 Non-Native Invasive Plant Treatment A substantial consideration for proposed management activities related to the FLIPS Project is the infestation of Non-Native Invasive Plants (NNIP). Many of the project areas have current known infestation of NNIP and early planning is necessary to minimize and eliminate the chance for further spread of NNIP as well as introduction of new NNIP. Authorization for treatment of NNIP is already defined by the 2008 Finger Lakes Invasive Plant Control (FL IPC)Project Decision Notice and Finding of No Significant Impact and updated Supplemental Information Report (June of 2014.) The FL IPC Project Decision Notice and Finding of No Significant Impact is the result of an Environmental Analysis that provided a preferred Alternative for treatment of NNIP and includes Design Criteria that further specify what types of herbicides may be applied and when, as well as specific measures to take relative to resource area. Because of this existing authority, treatment of NNIP does not need to be considered as part of the FLIPS Project, with the exception of consideration during the analysis phase for cumulative effects of all past, current, and future management activities on the resource. The Interdisciplinary Team for the FLIPS Project has been conducting active and early discussions to best plan for inventory and treatment of NNIP. This consideration will remain at the forefront of discussion during the analysis, and will be addressed on an individual stand basis. It is anticipated that a combination of NNIP treatment alternatives will be paired with any stands that dictate such treatment following the conclusion of NNIP survey data. Finger Lakes Invasive Pest Strategy, Scoping Information Page 8

11 Table 2. Stand Summary Compartment Stand Acres Proposed Treatment Forest Plan Management Area Thinning Oak Hickory (3.1) Thinning Oak Hickory (3.1) Thinning Oak Hickory (3.1) Thinning Oak Hickory (3.1) Thinning Oak Hickory (3.1) Thinning Oak Hickory (3.1) Shelterwood with reserves Northern Hardwoods (2.1) Roadside firewood Oak Hickory (3.1) Roadside firewood Oak Hickory (3.1) Improvement Oak Hickory (3.1) Improvement Oak Hickory (3.1) Improvement Northern Hardwoods (2.1) Improvement Oak Hickory (3.1) Group Selection Oak Hickory (3.1) Group Selection Oak Hickory (3.1) Group Selection Northern Hardwoods (2.1) Group Selection Northern Hardwoods (2.1) Clearcut Oak Hickory (3.1) Clearcut Oak Hickory (3.1) Clearcut Oak Hickory (3.1) Clearcut Oak Hickory (3.1) Clearcut Northern Hardwoods (2.1) Clearcut Oak Hickory (3.1) Clearcut Oak Hickory (3.1) Timber Stand Improvement Northern Hardwoods (2.1) Timber Stand Improvement Northern Hardwoods (2.1) Timber Stand Improvement Northern Hardwoods (2.1) Timber Stand Improvement Oak Hickory (3.1) Timber Stand Improvement Oak Hickory (3.1) Timber Stand Improvement Oak Hickory (3.1) Timber Stand Improvement Oak Hickory (3.1) Timber Stand Improvement Oak Hickory (3.1) Timber Stand Improvement Oak Hickory (3.1) Hedgerow Planting Grasslands for Grazing (1.1) Hedgerow Planting Grasslands for Grazing (1.1) Hedgerow Planting Grasslands for Grazing (1.1) Hedgerow Planting Grasslands for Grazing (1.1) Hedgerow Planting Grasslands for Grazing (1.1) Hedgerow Planting Grasslands for Grazing (1.1) Total 800 Finger Lakes Invasive Pest Strategy, Scoping Information Page 9

12 CFR 218 Pre-Decisional Objection Process The pre-decisional objection regulations (36 CFR 218) provide an opportunity to object to a project prior to the final decision. The regulations state that in order to be eligible to object under this process, you will need to submit timely specific written comments (36 CFR 218.2) during any period designated for public comment (36 CFR 218.5(a)). The scoping period for this project is the only designated opportunity to provide comments for this project. How are you involved in this Decision? We are soliciting your comments on all aspects of this project. The analysis for the FLIPS Project will be documented in an Environmental Assessment (EA). Your thoughtful input will help us refine our proposal, identify issues of concern, determine whether an alternative needs to be considered in detail, evaluate impacts, identify the analysis level needed, and decide whether to implement the project. Comments will be accepted on this project for a 30 day period, beginning on February 26, 2016 and ending on March, 28th Directions for how to comment are included in the Cover Letter of this Scoping package. If you comment or otherwise express interest in this project during the 30-day comment period, you will be notified of future actions associated with the proposal. Thank you for your interest and participation in the management of the Finger Lakes National Forest. Finger Lakes Invasive Pest Strategy, Scoping Information Page 10