United States Department of Agriculture Invasive Dandelion Removal in the Alpine Zone White Mountain National Forest, NH and ME Decision Memo For Information Contact: Dan Sperduto Supervisor s Office 71 White Mountain Dr. Campton, NH 03223 Phone: 603 536-6225 Fax: 603-447-8405 FedRelay 711 Forest Service White Mountain National Forest
White Mountain National Forest 1. Summary 2. Background After careful consideration of public input, the recommendations of appropriate resource specialists, and the requirements of applicable laws and regulations, I have decided to allow removal of invasive dandelions from the alpine zone of the White Mountain National Forest to eliminate the threat to native alpine vegetation and prevent expansion to other parts of the alpine zone. This authority extends to all Management Areas which contain alpine habitat for a period of up to five years (until dandelion control is integrated into the Forest Wide Non-Native Invasive Species EA). Common dandelions have long been known to occupy limited areas of disturbed human settings in the alpine zone; specifically around the summit buildings (Summit House collection by E.F. Williams, 1895) and at the AMC Lakes of the Clouds Hut. They have never been noted, however, by botanists as being present in any abundance in natural alpine habitats in New Hampshire. While dandelions are not considered a problematic invasive species in lowland environments, it was an alarming discovery that the species was proliferating abundantly in native alpine snowbank communities close to the summit of Mt. Washington (reported by Allison Bell in 2014). Non-native dandelions are considered invasive and problematic in other alpine and Arctic environments in North America and in other parts of the world, including in the Rocky Mountains, and in Denali National Park in Alaska. Denali NP has initiated a concerted effort to manually control dandelions that have invaded deep into the National Park, utilizing both park staff and SCA crews. Recent control efforts (Androscoggin Ranger District Decision Memo, June 2015) yielded 222 pounds of dandelions removed from the summit cone area of Mt. Washington, reflecting the combined efforts of WMNF and NH State Park staff, researchers, and volunteers. The concern with dandelion infestations in alpine areas on the White Mountain National Forest is the potential expansion to new natural alpine habitats (in particular into snowbank communities), and the displacement of rare and other native alpine vegetation. The occurrence and apparent success in snowbank settings is particularly concerning since these alpine communities represent less 2
Invasive Dandelion Removal in the Alpine Zone Decision Memo than one percent of the alpine zone, yet contain at least half the diversity of rare species and other alpine-restricted species that occur in New England alpine zones overall. The best and most efficient opportunity for success for controlling the dandelions is in the immediate future, while the populations are small and limited in extent. This decision memo describes actions that are consistent with a key global strategy in controlling invasive species impacts to ecosystems: Early Detection/Rapid Response (EDRR). Effort and cost to control invasive species is never smaller than when infestations are limited, and can grow exponentially when infestations expand, along with diminishing prospects for control. We don t know what factors control or limit expansion of dandelions within the alpine zone at this time, but the managerial intent is to react quickly to prevent a potentially much larger problem, in part through a diverse partnership with state, federal, private, and citizen parties. Monitoring of infestation areas should provide an indication of whether control efforts are having the intended effect, and whether the magnitude of the problem remains manageable in coming years. Presently, in addition to the known locations on the summit cone, dandelions are documented from the Lake of the Clouds and Madison Springs Hut vicinity (see maps), and at treeline adjacent to The Horn parking lot (not depicted on map). Surveys of new areas will be expanded as feasible, particularly into snowbank settings or lee-positions that characterize most of the known sites. Coordination with AMC will be needed for Madison Springs Hut location if removals are attempted in 2016 (some plants here occur on the WMNF and some on the AMC-owned in-holding within the WMNF). Ongoing cooperation and coordination with the State of NH will be necessary for removals from the Mt. Washington State Park, as well as potential infestations on the Cog Railway or Auto Rd. Current infestations are known from MA 8.1 lands (Alpine), but are proximal to and potentially threaten Wilderness Areas (MA 5.1) and the Alpine Garden RNA (MA 8.4) with alpine or subalpine vegetation. A Minimum Requirement Decision Guide (MRDG) was prepared for the proposed project to analyze removal of dandelions in Wilderness Areas; in addition, a Research Natural Area (RNA) permit is under review to authorize removal in the event of discovery in the Alpine Garden RNA. 3
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White Mountain National Forest 3. Decision to Be Implemented My decision is to allow for removal and monitoring of invasive dandelions from all affected alpine areas on the White Mountain National Forest for a period of up to five years. Details of the action are as follows: Work crews and removal methods: Removals will be done by hand with basic weed diggers by small teams, consisting of the Forest Botanist assisted by other WMNF staff and volunteers, state partners, and volunteer botanists involved in alpine research. Target time frame is July, before the plants go to seed. Removal of entire plants including roots and fruiting or flowering heads will be the preferred harvest method. Plant parts will be bagged, weighed for each removal area, and disposed of properly in the lowland environment. In some cases, where removal impacts are a concern or time is limited, removal of seed heads or above ground parts is an alternate short-term strategy. Independent research teams and removals on WMNF land will be coordinated with the USFS and permitted via an appropriate research permit. Heritage/Archeology: Any potential human artifacts encountered while removing dandelions will be left undisturbed in the ground, and WMNF Heritage Program staff will be notified of the potential artifact. Monitoring: Monitoring will consist of repeat surveys of transects at the two snowbank patches surveyed in 2015 to confirm that impacts to native vegetation are undetectable, or minimal and acceptable in comparison to the alternative of known or probable expansion of dandelions and displacement of native alpine vegetation. Additional plot documentation prior to removals will be considered for new infestations. Dandelions will also be bagged and weighed according to location to help gauge efficacy of removals over time (i.e., by comparison to previous removals). Priority removal areas: Primary focus for 2016 will be on currently known Mt. Washington localities; Lakes of the Clouds and Madison Springs hut removals will be coordinated with AMC; the Lakes of the Clouds dandelions removals may need to be coordinated with the proposed septic system upgrade project, as appropriate and depending on timing of the two projects. Partner coordination and public outreach: The Forest Service will continue to coordinate with and obtain permission from other landowners on Mount 6
Invasive Dandelion Removal in the Alpine Zone Decision Memo Washington (State Parks, Auto Road, Cog Railway), as appropriate, for any potential removals on those lands. No dandelions were observed along the Auto Road in the summit vicinity in 2015, although some occur at or below treeline (near and below ~Mile 4). Public outreach through the Forest Service and partners may help identification of new locations of dandelions. We will not permit removals from National Forest System lands by individuals that are not specifically authorized by the Forest Service. Alignment with Forest Plan and internal review: This decision is based on my review of the project record, including input from the public, appropriate resource specialists, and the three District Rangers on the Forest. The proposed project is consistent with Forest Plan guidance on Early Detection/Rapid Response of invasive species, and high priority given to control of invasive species in the Alpine Zone (Forest Plan MA 8.1, Standards and Guidelines). MAs 8.4 (RNAs) and 5.1 (Wilderness) also call for using manual control methods as the initial approach for invasive species infestations. Common dandelion has been added to the invasive species list for the White Mountain National Forest. The intention will be to transition future dandelion removal to occur under the authority of a revised Forest Wide Non-native Invasive Species Removal Project, as appropriate. 4. Rationale for Categorically Excluding the Decision 4.1 Category of Exclusion I have determined that this decision can be categorically excluded from documentation in an environmental impact statement or environmental assessment. The selected action is a routine activity within the following category of exclusion found at 36 CFR 220.6(e)(6) or FSH 1909.15, Chapter 30, Timber stand and/or wildlife habitat improvement activities. This category is applicable because the alpine zone is a primary type of wildlife habitat on the Forest and dandelion infestations are affecting native plant communities. 4.2 Finding that No Extraordinary Circumstances Exist Based on information presented in this document and the entirety of the project record, I have evaluated the resource conditions listed in 36 CFR 220.6(b)(1) and determined there are no extraordinary circumstances related to this project. A 7
White Mountain National Forest summary of the project s potential effects on each resource condition follows. Federally listed threatened or endangered species or designated critical habitat, species proposed for Federal listing or proposed critical habitat, or Forest Service sensitive species. Potential effects of this decision on listed species have been analyzed and documented in a Biological Evaluation (project record). Based on known occurrence records and habitat conditions, no federally listed species have the potential to occur in the area that would be affected by this project. Therefore, there will be no effect on T&E species. Based on known occurrence records and habitat conditions, 27 sensitive species have the potential to occur in the project area because they are alpine-restricted species. For the reasons indicated in the Biological Evaluation, it was determined that this decision may impact individuals of sensitive species, but would not likely cause a trend toward federal listing or loss of viability. Impacts to rare species, other native species, and soils will be avoided or minimized. Prior to removal of the dandelions, an on-site survey for rare species will be conducted by the Forest Botanist and accompanying botanists, or by qualified botanists with a research permit. In addition, the identity of plants as common dandelion (Taraxacum officinale) will be confirmed prior to removals (other dandelion species are possible, including a very remote possibility for a rare native arctic dandelion, not presently documented from New England). Other non-native dandelions, if documented, may be removed. If rare plants are present, removals will be planned and executed in a manner that avoids or minimizes impacts. Dandelion removal will not be attempted if the removal itself presents a substantial or greater threat to a listed species population than not removing the dandelions (dandelions are outcompeting native plants in portions of the snowbank communities). If impacts of removals are deemed too intrusive in a local area, removals may be limited to harvesting of above ground dandelion plant material only. Floodplains, Wetlands, or Municipal Watersheds Executive Orders 11988 and 11990 direct federal agencies to avoid adverse impacts to floodplains or wetlands, which are defined in the executive orders. Dandelions are not documented from wetlands in lowland or alpine environments, and therefore wetlands may occur within the project area near 8
Invasive Dandelion Removal in the Alpine Zone Decision Memo dandelions, but no effects to the wetlands are expected. The WMNF Forest Plan indicates that high quality water will be maintained for public water supplies (Plan p. 1-18). Alpine areas form the headwaters for municipal watersheds, but there are no dandelions infestations near alpine streams. Further, potential for sedimentation associated with removals that might occur near streams in the future is negligible. Therefore, there will be no effects on municipal watersheds (project record). Congressionally designated areas, such as wilderness, wilderness study areas, or national recreation areas The closest Wildernesses, the Presidential Dry River and Great Gulf Wilderness Areas, contain substantial alpine areas near the known dandelions infestations. The Pemigewasset, Sandwich, and Caribou-Speckled Wilderness Areas contain some small alpine or subalpine areas with alpine plants in them, and are considered in this Decision Memo as well. A Minimum Requirement Decision Guide workbook (MRDG) was prepared and signed by the Forest Supervisor (project record). As detailed in the MRDG, methods, mitigations, and impact avoidance strategies designed for other alpine areas adequately address resource concerns in Wilderness and RNA Management Areas as well. Inventoried roadless area or potential wilderness area The project area contains some areas that were included in both the Raodless Area Conservation Rule and Forest Plan revision inventories. No effects are expected because the proposed action does not include tree cutting, road building, or other activities that could affect roadless characteristics. Research Natural Areas A permit request to conduct removals of dandelions within the Alpine Garden Research Natural Area (RNA) is under review by the RNA program, in the event that infestations are discovered in the Alpine Garden RNA. No removals will be performed in the RNA without an authorizing permit. Methods, mitigations, and impact avoidance strategies for the Alpine Garden RNA are identical to those designed for other alpine areas. American Indian religious or cultural sites No American Indian religious or cultural sites have been identified by federally recognized tribes or surveys on the WMNF. Therefore this decision will not affect 9
White Mountain National Forest any of these resources. Archaeological sites and historic properties or areas This decision complies with the National Historic Preservation Act and the Archaeological Resources Protection Act. Surveys were conducted for archaeological sites and historic properties or areas that might be affected by this decision (project record). Consultation occurred with the State Historic Preservation Office and they concurred with our findings (project record). 5. Public Involvement This project was listed on the quarterly White Mountain National Forest Schedule of Proposed Actions (SOPA) beginning in April 2016, and will remain on the SOPA until after a decision is made. Public involvement included ongoing consultation with partners and interested parties over the past year since 2015 removal activities; educational outreach at research and plant conservation meetings; and notification by email to land abutters and other conservation partners (State Parks, NH Natural Heritage Bureau, Auto Road, Cog Railway, Appalachian Mountain Club, New England Wildflower Society, USFS Northern Research Station, University of Connecticut, The Sages College, and independent scientists). All responses from these groups were supportive of the effort. In addition to the efforts listed above, individuals and groups who expressed interest in the project were offered an opportunity to comment in early May, 2016. One response was received from a member of the public. It suggested that the project was not important enough to justify the expense; would result in inevitable failure; and that we should preserve the dandelions because bees don t have enough other vegetation to use. I considered the points made by the commenter and decided to implement the project anyway because: 1) The updated purpose and need in this Decision Memo and supporting documents in the project record address the ecological importance of the project, the imperative and cost efficiency of Early Detection/Rapid Response in controlling invasive species, and the role of monitoring in gauging success. 2) While the project does involve Forest Service staff and expense, we have broad-based and otherwise unanimous support from all land owners, public and private conservation groups, researchers, and other members of the public, 10
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