##### National Park Service

U.S. Department of the Interior

Northern Great Plains

**Northern Great Plains Exotic Plant Management Plan**

**Finding of No Significant Impact**

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**Finding of No Significant Impact**

**Northern Great Plains Exotic Plant Management Plan and**

**Environmental Assessment**

The National Park Service (NPS) will implement an Exotic Plant
Management Plan (EPMP) to control exotic (non-native) plants at 13 parks
located in the Northern Great Plains (NGP) area. The intent of this
project is to manage exotic plants to reduce their negative effects on
native plant communities and other natural and cultural resources within
these parks. Parks included in this plan are Agate Fossil Beds National
Monument, Devils Tower National Monument, Fort Laramie National Historic
Site, Fort Union Trading Post National Historic Site, Jewel Cave
National Monument, Knife River Indian Villages National Historic Site,
Minuteman Missile National Historic Site, Missouri National Recreational
River, Mount Rushmore National Memorial, Niobrara National Scenic River,
Scotts Bluff National Monument, Theodore Roosevelt National Park, and
Wind Cave National Park.

Exotic plants are species that occur outside of their native ranges as a
result of direct or indirect human actions. Exotic plants replace native
plant communities, degrade wildlife habitats, and reduce the biological
diversity of ecosystems. For example, more than 20,000 acres (about 30
percent) of native habitats for plants within Theodore Roosevelt
National Park have been altered by the spread of exotic plant species.
Exotic plants are also affecting habitats of federally listed threatened
and endangered plants. Both the Missouri National Recreational River and
the Niobrara National Scenic River have sections of federally designated
critical habitat for the piping plover (*Charadrius melodus*). Purple
loosestrife (*Lythrum salicaria*), an aggressive exotic plant, is
threatening this critical habitat. More than 2,000 acres of monotypic
stands of purple loosestrife have been mapped at these parks.

# PREFERRED ALTERNATIVE

Under Alternative 2, or the preferred alternative, the NPS will use an
integrated pest management (IPM) approach to control exotic plants at 13
parks. The NPS has a mandate to preserve natural and cultural resources
now and for future generations. The preferred alternative will assist
parks in meeting this mandate by implementing effective IPM practices.

IPM is a decision-making process that supports the NPS mission by
coordinating knowledge of pest biology, the environment, and available
technology to prevent unacceptable levels of pest damage, using
environmentally sound, cost-effective management strategies that pose
the least possible risk to people, park resources, and the environment.
This process helps resource specialists determine whether treatment of
an exotic plant is necessary and appropriate, where treatment should be
administered, when treatment should be applied, and what strategies
should be used for immediate and long-term results. IPM is done on a
case-by-case basis, so that treatment strategies are tailored to local
conditions. Each exotic plant's natural history is also evaluated before
developing treatment strategies.

IPM employs multiple integrated management practices rather than a
single solution, wherever technically and economically feasible. An
integrated approach is often more effective than a single type of
treatment. This plan considers all treatment methods that are currently
being implemented by the 13 park units, or that may be used in the
foreseeable future. IPM treatments that will be used under the preferred
alternative include:

-   Cultural Treatments --- practices that promote the growth of
    desirable plants and reduce the opportunities for exotic plants to
    grow. Examples include irrigation and seeding of native plant
    species.

-   Manual/Mechanical Treatments --- physical damage to or removal of
    part or all of the plant. Examples include hand pulling, cutting,
    grubbing, haying, and mowing.

-   Biological Treatments --- biological control, or biocontrol - the
    use of "natural enemies", such as insects and microorganisms to
    reduce the abundance of an exotic plant. Natural enemies are
    imported from areas where the target exotic plant occurs as a native
    plant and are deliberately released into areas where the plant is
    exotic. Examples include plant-feeding insects such as flea beetles
    (*Aphthona lacertosa*) for leafy spurge (*Euphorbia esula*) and leaf
    beetles (*Galerucella* spp.) for purple loosestrife. Approved
    biological agents will be host-specific and have a negligible risk
    for becoming a pest.

-   Chemical Treatments --- applying pesticides as prescribed by their
    labels, using a variety of application methods. Examples of
    application methods include portable sprayers, all-terrain vehicles
    (ATVs) equipped with sprayers, and aerial application (helicopter
    and fixed-wing).

-   Prescribed Fire Treatments --- applying fire to a predetermined area
    to reduce the growth of exotic plants and to increase the growth of
    desirable plants.

Individual treatments, or combinations of those treatments, will be
implemented as appropriate to control exotic plants in the 13 parks.
Parks will cooperate with state, county, private, tribal, and federal
officials. Such coordination will be especially necessary in parks with
management partnerships such as Missouri National Recreational River and
the Niobrara National Scenic River.

Under the preferred alternative, resource specialists at each park will
use a Decision-making Tool, developed specifically for this plan, for
exotic plant management planning. In using this tool, resource
specialists at each park will follow a standard decision-making process
to identify exotic plants, determine exotic plant management priorities,
identify and evaluate the efficacy and environmental effects of the
proposed treatment, consider alternative treatments having less impacts,
justify why a treatment was selected, and confirm compliance with
applicable policies and regulations. Resource specialists will also be
able to use the results of this analysis to explain to the public how
each of these factors was considered in selecting treatment methods.

The general management objective of this plan is to prevent unacceptable
levels of exotic plant damage, using environmentally sound,
cost-effective management strategies that pose the least possible risk
to people, park resources, and the environment. Under the preferred
alternative, resource specialists will also establish specific exotic
plant management objectives for their park. These management objectives
will be developed based on NPS policy, resource management objectives
for the park, the size of the park, and the extent and type of exotic
plant infestations within the park. If the extent and distribution of
exotic plants are not known, additional data collection such as mapping
may be required before management objectives can be established.

Once management objectives are established for a park, plant species
lists will be reviewed to identify exotic plants. Those plants that
occupy or could occupy parklands directly or indirectly as the result of
deliberate or accidental human activities are considered "exotic." Any
plants that do not meet this definition are not exotic plants and will
not be managed under the EPMP.

Exotic plants that are listed as county, state, or federal noxious weeds
are considered a general management priority. Relative management
priorities for each exotic plant (including noxious weeds) will also be
determined using a system developed for this plan that allow resource
specialists to qualitatively determine exotic plant management
priorities. The results of the rankings will be used to determine
relative management priorities. In accordance with NPS management
policies, highest priority will be to manage disruptive exotic plants
that have, or potentially have, a substantial impact on park resources,
and can reasonably be expected to be controlled. Lower priority will be
given to innocuous exotic plants that are not likely to significantly
harm park resources.

Using the Decision-making Tool, resource specialists will identify a
proposed treatment option or options that are feasible given potential
costs, available resources, potential impacts and effectiveness, and
applicable regulations and policies. The resource specialist will then
consider whether there are any other treatment options, treatment
agents, or application methods available that will result in lower
impacts when compared to the proposed treatment option given potential
costs, available resources, impacts, and effectiveness. If there are no
other feasible options available, the resource specialist selects the
proposed treatment. However, if the resource specialist identifies an
alternative treatment that has lower impacts and that is feasible, the
alternative treatment option will be selected.

Once a treatment method is selected pursuant to this plan, its
compliance with NPS policies and the National Environmental Policy Act
(NEPA) will be confirmed. Two separate decision trees will be used to
confirm compliance. If chemical or biological control treatments covered
in this plan are selected, their compliance with applicable regulations
and policies will be confirmed. Compliance with NEPA will also be
confirmed for all treatments. If compliant, the resource specialist will
also determine whether there are any sensitive resources located within
the treatment area that could be affected by the proposed treatment.
Examples of sensitive resources include threatened, endangered, or
traditional use plants; historic structures with limestone grout; raptor
nests; and cave resources. If sensitive resources are identified, the
locations of these resources and appropriate buffer areas will be
delineated so they can be avoided. Once sensitive resources have been
delineated and buffer areas established, the selected treatment along
with best management practices (BMPs) to mitigate potential impacts can
be implemented.

Treated areas will be monitored to determine whether management
objectives established during the initial planning stages were met. If
management objectives are met, the resource specialist will document the
results of monitoring. The resource specialist will also continue to
consider other treatment options as they become available to identify
other alternatives that might have even lower impacts. If the proposed
treatment complies with applicable policies and regulations, the
resource specialist will document this compliance with a memo to file.

If management objectives are not met, the selected treatment may be
modified, or alternative treatments may be considered, through adaptive
management. The NPS must use adaptive management to fully comply with 40
CFR 1505.2(c), which requires a monitoring and enforcement program to be
adopted, where applicable, for any mitigation activity. Adaptive
management is a system of management practices based on clearly
identified outcomes; monitoring to determine if management actions are
meeting outcomes; and if not, facilitating management changes that will
best ensure that outcomes are met or by reevaluating outcomes. Adaptive
management recognizes that knowledge about natural resource systems is
sometimes uncertain and is the preferred method of management in these
cases.

# MITIGATION MEASURES INCLUDED UNDER ALTERNATIVE 2

The park's resource manager responsible for supervising exotic plant
management activities is responsible for ensuring that mitigation
measures and BMPs occur. To minimize the potential impacts from
personnel and equipment, the following general BMPs will be implemented
under the preferred alternative:

-   Equipment will use existing roads and trails to the maximum extent
    practical.

-   Physical disturbance to ground nesting birds and burrowing animals
    will be avoided, to the extent possible. Any activities that would
    cause direct physical disturbance to nests or burrows encountered
    will be avoided.

-   Equipment used for exotic plant management will be washed prior to
    entering a park to reduce the potential for accidentally introducing
    exotic plants from another area.

-   To limit the potential for equipment to spread exotic plant seeds,
    treatments should be completed before seed becomes viable.

-   ATVs will be transported by trailer from one general area of the
    park to another. Trailers will be used to avoid unnecessary
    cross-country travel, tracks, and to promote safe operation.

-   ATVs and other equipment will be routed along breaks in topography
    or behind existing tree groupings where possible.

-   Personnel and equipment will avoid areas having sensitive soils or
    areas that are prone to erosion.

-   Use of equipment in high visibility areas will be avoided to the
    extent feasible.

-   If ATVs will be used in highly visible areas, ATVs will follow slope
    contours to minimize the potential for visual disturbance.

-   Any crossings to access treatment areas should be done at a right
    angle to the access road.

-   Surface disturbing activities, such as tilling or use of heavy
    equipment, will be avoided within the boundary of known or potential
    cultural resource or historic resource sites.

-   ATVs will be routed to avoid palustrine (wet or marshy) wetlands.
    ATVs will avoid wetland areas with standing water or saturated
    soils, to the extent practical.

-   ATVs will be operated to minimize disturbance to vegetation and
    soils. ATVs will not be operated under conditions where soil is
    susceptible to compaction, erosion, or creation of wheel ruts.

-   The number of vehicle and ATV passes off-road will be minimized to
    the extent possible.

-   Information will be developed for the public and park staff on
    exotic plants. This information may include signs, interpretive
    displays, brochures, and programs.

Under the preferred alternative, specific BMPs were developed for
cultural, manual/mechanical, biological control, chemical, and
prescribed fire treatment methods.

# Mitigation Specific to Cultural Treatments

-   Any feed, forage, mulch, fill, gravel, or other like materials
    brought into a park should be certified free of exotic plant seed
    ("certified weed-free").

-   Sources of "clean fill" (weed-free) will be used, where available.
    If not feasible, fill not designated as "clean fill" may be used but
    should be closely monitored for exotic plant growth. Construction
    equipment will otherwise avoid exotic plant infestations, to the
    extent feasible.

-   Horses and pack animals will be brushed thoroughly and have their
    hooves cleaned before entering a park.

-   Horses and pack animals should be fed only food that is "certified
    weed free" starting 96 hours before entering a park.

-   Any seed or plant materials used for restoration efforts within a
    park should be "certified weed free."

-   Inspections and cleaning of contractors' and fire fighters'
    equipment, vehicles, and materials may be required to prevent
    importation of nonnative plant seed or materials into a park.

-   Commercial users that disturb established vegetation may be required
    to provide bonds that are retained until sites are returned to a
    specified condition.

-   BMPs will be developed to limit the amount and impact of
    ground-disturbing activities.

-   Park staff and volunteers will be trained on how to identify
    priority exotic plants.

-   Any materials used in revegetation (including mulch and organic
    fertilizers) will be free of non-native plant seeds or materials. In
    addition, locally grown, native plant materials will be used where
    possible. All plant materials used will be "certified weed-free."

-   If drought conditions are forecasted, resource managers should delay
    the purchase and planting of shrubs to avoid the need for
    irrigation. Resource managers should also confirm that there is
    water available for irrigation should the need arise.

# Mitigation Specific to Manual/Mechanical Treatments

-   Heavy equipment will only be used in areas of dense exotic plant
    infestations and where there are no natural or cultural resources
    that could be impacted by this equipment.

-   In the event that cultural resources are encountered during manual
    or mechanical treatments, all work will stop immediately and will
    not continue until the site is evaluated and cleared by a qualified
    cultural resource specialist.

-   Operation of heavy equipment for activities such as tilling will not
    be conducted when soil is either too wet or too dry, in order to
    minimize the potential for affecting soil structure.

-   Treatments that involve surface disturbance activities in riparian
    or wetland areas, such as tilling or dredging, will be avoided. Any
    activities that could disturb wetlands or waters of the U.S. will
    require separate consultation with the U.S. Army Corps of Engineers
    to determine if a permit is needed.

# Mitigation Specific to Biological Control Treatments

-   Only those biological control agents approved by U.S. Department of
    Agriculture Animal and Plant Health Inspection Service (APHIS) will
    be used.

-   When considering the use of a new biological control agent, the
    resource manager will confirm that its use is necessary and that all
    other treatment options are either not acceptable or not feasible.

-   Before a biological control agent is released, the resource
    specialist will receive approval from the National IPM Coordinator
    to release the agent.

-   If biological control agents will be obtained from another state, a
    permit, which has been reviewed by the State Entomologist, must also
    be obtained from APHIS.

-   The transport, handling, and release of biological control agents
    will be in accordance with all permit conditions. Parks will use a
    standardized form to report annual releases of biological control
    agents to the Regional IPM Coordinator.

-   Biological control agents will be released in each climatic zone
    that is occupied by the host plant so that the agent has a chance to
    develop in all areas where the host occurs.

-   The number of biological control agents released will account for
    the size and density of the treatment area and the number of agents
    required to maintain a viable biological control agent population.

-   Releases will be synchronized with the time period when the host is
    present. Biological control agents will be released at times of the
    day when they will not disperse from the treatment area.

-   Surveys for biological control agents will be completed several
    times during the season to monitor biological control agents.

# Mitigation Specific to Chemical Treatments

-   Aerial application of pesticides will only be conducted for sites
    that meet one of the following criteria:

    -   The infestation covers a large area and will be most effectively
        treated from the air. There is no acre limit for using aerial
        application; however, aerial application sites are typically
        over 20 acres and have fairly dense exotic plant coverage.

    -   The infestation covers a small area but can be successfully
        treated using a microfoil boom or similar apparatus that allows
        for a limited band of spray. Microfoil booms are designed
        specifically to minimize pesticide drift. A microfoil boom can
        be used to spray widths as small as 12 feet, effectively
        treating small infestations.

    -   The infestation is very remote and treatment using other
        application methods will require an inordinate amount of time
        for crews to arrive and apply ground treatment.

    -   The infestation is located on rough, steep terrain that prevents
        ground application and is too dangerous for employees on foot.

Pesticides will be selected and BMPs will be implemented to maximize the
effectiveness of the treatment on the target exotic plant and to
minimize the potential effects on non-target plants as follows:

-   All federal, state, and local regulations regarding pesticide use
    will be followed at all times.

-   All product labels will be read and followed by pesticide
    applicators. It is a violation of federal law to use a pesticide in
    a manner that is inconsistent with its label.

-   Pesticide applicators will obtain any certifications or licenses
    required by the state and/or county.

-   Reduced application rates of pesticides will be used wherever
    possible.

-   Pesticides will be applied as near to the target plant as possible.

-   Pesticide application will account for meteorological factors such
    as wind speed, wind direction, inversions, humidity, and
    precipitation in relation to the presence of sensitive resources
    near the treatment area and direction provided on labels.

-   Pesticides will only be applied when meteorological conditions at
    the treatment site allow for complete and even coverage and will
    prevent drifting of spray onto non-target sensitive resources or
    areas used by humans.

-   Pesticides will be applied only during periods of suitable
    meteorological conditions. Pesticides should also not be applied
    during periods of dead calm (this could indicate an inversion) or
    when wind velocity and direction pose a risk of spray drift.

-   Pesticides will be applied using coarse sprays to minimize the
    potential for drift. Combinations of pressure and nozzle type that
    will result in fine particles (mist) will be avoided. Thickeners
    will be added if the product label permits.

-   Pesticides will be applied at the appropriate time based on the
    pesticide's mode of action.

-   Pesticides will be applied according to application rates specified
    on the product label.

-   In areas where there is the potential to affect surface water or
    ground water resources, pesticide pH and soil pH will be considered
    to select the pesticide with the lowest leaching potential.

-   Highly water-soluble pesticides will not be used in areas where
    there is potential to affect surface water or ground water
    resources.

-   Pesticides with high volatility will not be used to treat areas
    located adjacent to sensitive areas because of the potential for
    unwanted movement of pesticides to these areas.

-   Pesticides with high soil retention will be used in areas where
    there is potential to affect surface water or ground water
    resources.

-   Pesticides with longer persistence will be applied at lower
    concentrations and with less frequency to limit the potential for
    accumulation of pesticides in soils.

-   As needed to protect the efficacy of the pesticide, water will be
    buffered, depending on hardness, pH, and other factors.

-   Safety protocols for storing, mixing, transporting, handling spills,
    and disposing of unused pesticides and containers are included in
    the plan will be followed at all times.

-   NPS policy requires that only pesticides that are expected to be
    used in a 1-year period can be purchased at one time. Therefore,
    pesticides will not be stored for periods greater than one year.

-   Equipment would be maintained and calibrated: prior to each
    application of pesticides.

    -   On a regular basis, and at a minimum of the start of each season

    -   Prior to an applicator operating new equipment or equipment on
        which they have not been calibrated

    -   After equipment is repaired or replaced in a manner that could
        affect the application rate.

-   During all applications, droplet size will be controlled to decrease
    the risk of pesticide drift to non-target species outside the
    immediate treatment area.

-   All concessionaires will comply with this plan and NPS policies when
    applying pesticides.

-   Any motorized water crossings to access treatment areas will be done
    at right angles to drainages to minimize potential disturbance.

-   Areas that may contain cultural or historic resources and that have
    not been previously studied will be surveyed. If cultural or
    historic resources are identified or are known to occur, all surface
    disturbing activities will be avoided in these areas.

-   Use of pesticides within the boundaries of the cultural resource or
    historic resource sites will be restricted. Because of unknown
    effects, pesticides will not be directly applied to historic
    structures with limestone grout, hearth features, or cultural
    resources comprised of organic material, bone, pollen, seeds, and
    materials made from plant fiber. However, pesticides may be used in
    lands surrounding cultural or historic sites in accordance with
    BMPs.

To minimize the potential impact of pesticides on surface water and
ground water resources, the following BMPs will be implemented:

-   Only pesticides that are registered for use in or near water will be
    used in those areas.

-   Only those pesticides that have a low potential toxicity, such as
    glyphosate (Roundup Pro and Rodeo) will be used within areas near
    surface waters or in areas with a high leaching potential.

-   Applications of pesticides will be avoided during periods and in
    areas where seasonal precipitation or excess irrigation water is
    likely to wash residual pesticides into waterways.

-   Applications of pesticides within 50 feet of surface water bodies
    (including streams, rivers, lakes, and waterways) will be done by
    hand or with vehicle mounted ground equipment to minimize the
    potential impacts to surface waters.

-   If aerial applications are used, flights will be designed and
    scheduled for wind conditions that minimize potential impacts to
    surface waters.

-   Each park currently monitors potable drinking water quality. This
    monitoring will continue to confirm that potable water meets
    drinking water standards as outlined by the Safe Drinking Water Act.

-   Parks will implement surface water and ground water monitoring
    programs as appropriate to protect natural resources.

-   The Relative Aquifer Vulnerability Evaluation (RAVE) system will be
    used by parks, as necessary and appropriate, to evaluate potential
    risks to ground water from chemical treatments. The RAVE system can
    be used to assess risk of ground water contamination for chemicals
    applied to either agriculture systems or ecosystems.

-   When available from the Regional IPM Coordinator, vertical buffer
    zones to ground water will be used.

To minimize the potential impact of pesticides on cave resources, the
following BMPs will be implemented or continued at Jewel Cave National
Monument and Wind Cave National Park:

-   Implementation plans identifying pesticide treatment zones will be
    developed for both Jewel Cave and Wind Cave. These plans will
    undergo further NEPA compliance with public involvement. Management
    practices to protect cave and karst resources could vary from park
    to park because of differing geology and hydrology.

-   "No-Pesticide Treatment Zones" will designate areas in which no
    pesticides will be applied. These zones will include areas above
    known cave drip sites, areas within the watersheds which have
    potential to drain into cave and karst resources, and areas where
    permeable rock layers are uncapped.

-   "Minor Risk Treatment Zones" will designate areas where pesticides
    can be considered as part of the IPM practices for the area. These
    zones will be areas that pose very minor risk to cave and karst
    resources. Chemicals with high specificity, low leaching potential,
    and low persistence will be preferred for use in these areas, and
    pesticides will be hand sprayed on individual plants. Broadcast
    spraying of pesticides will not be permitted in these zones.

-   "Negligible-Risk Treatment Zones" will be designated, where
    appropriate. Within these zones, all methods of chemical application
    will be considered as part of the overall IPM management.

-   Jewel Cave and Wind Cave will develop or continue programs to
    monitor water quality in the cave(s), and will re-evaluate the
    pesticide treatment zones if chemicals used by the park are detected
    in cave drip water.

# Mitigation Specific to Prescribed Fire Treatments

-   Parks with fire management plans that included the use of prescribed
    fire will be able to use prescribed fire treatments to manage exotic
    plants under the preferred alternative. BMPs, as indicated by the
    respective parks' fire management plan and specific prescribed fire
    plan, will be followed during prescribed fire treatments.

-   BMPs will include topics relevant to the park and to a specific
    prescribed fire, such as protection of pubic health and safety and
    the appropriate natural and cultural resources (air, water,
    vegetation, wildlife, soils, historic structures, archeological
    sites, other sensitive resources).

-   Standard protocol for site assessment before treatment and
    monitoring after treatment will be used to set goals and objectives,
    and to determine whether or not they were achieved. Effects of the
    treatment on specific plant species and vegetation communities will
    also be monitored.

-   Prescribed fire treatment may be excluded from sensitive resources
    or from areas with exotic plant populations that respond positively
    to fire. Monitoring will be conducted at regular intervals, such as
    immediately after the fire, 1 year post-fire, 2 years post-fire, and
    5 years post-fire.

# ALTERNATIVES CONSIDERED

The alternatives presented in this document are the result of agency and
public scoping input, and their impacts are analyzed in accordance with
NEPA. All alternatives must be consistent with the purpose and
significance of all 13 parks included in this plan, and they must meet
the purpose of and need for action, as well as the objectives of the
plan. Five alternatives, including the no action alternative, were
originally considered, three of which were dismissed for various
reasons.

The environmental assessment includes two alternatives: the preferred
alternative (Alternative 2) described above, and the no action
alternative (Alternative 1). Under Alternative 1, no additional action
will be taken to control exotic plants within the 13 parks and existing
exotic plant management programs at each of the 13 parks will be
continued. The no action alternative is the baseline for analyzing
impacts of the alternatives.

Alternative 2, the preferred alternative, proposes to use an IPM
approach to control exotic plants at 13 parks.

# Three additional alternatives were considered, but were eliminated from detailed study. These alternatives included:

# 

# Alternative 3 - Stop all exotic plant management and control activities within each park. 

# Alternative 4 - Develop an IPM Plan that considers all treatments except chemical treatments.

# Alternative 5 - Develop an IPM Plan that considers all treatments except biological control treatments.

#  

# These alternatives and issues were eliminated from detailed study because they did not meet the criteria below. 

# The alternative must be consistent with NPS management policies and guidelines.

# The alternative must respond to the purpose of and need for action.

# The alternative must be feasible from a technical and economic standpoint, while remaining environmentally responsible.

#  The alternative must be compatible with the policies and regulations of other agencies and jurisdictions.

# The alternative must be capable of being implemented in a timely manner because the purpose of and need for action is immediate.

# 

# ENVIRONMENTALLY PREFERRED ALTERNATIVE

The environmentally preferred alternative is determined by applying the
criteria suggested in the National Environmental Policy Act of 1969
(NEPA), which is guided by the Council on Environmental Quality (CEQ).
The CEQ provides direction that, "The environmentally preferable
alternative is the alternative that will promote the national
environmental policy as expressed in NEPA's Section 101:

1.  Fulfill the responsibilities of each generation as trustee of the
    environment for succeeding generations;

2.  Assure for all Americans safe, healthful, productive, and
    esthetically and culturally pleasing surroundings;

3.  Attain the widest range of beneficial uses of the environment
    without degradation, risk of health or safety, or other undesirable
    and unintended consequences;

4.  Preserve important historic, cultural, and natural aspects to our
    national heritage and maintain, wherever possible, an environment
    that supports diversity and a variety of individual choice;

5.  Achieve a balance between population and resource use that will
    permit high standards of living and a wide sharing of life's
    amenities; and

6.  Enhance the quality of renewable resources and approach the maximum
    attainable recycling of renewable resources."

Based on the analysis prepared in this environmental assessment,
Alternative 2 is considered the environmentally preferred alternative.

The no action alternative, which will continue the use of existing
methods to treat exotic plants at 13 parks, will not satisfy the first
four requirements detailed above. Alternative 1 has more potential
adverse impacts on resources due to the lack of resource-specific BMPs.
If current exotic plant management programs continue, the biological and
physical environment will continue to be degraded by impacts of exotic
plants on native plant species, wildlife, and threatened or endangered
species, thus diminishing the quality of the environment for future
generations. Alternative 1 will also have fewer beneficial effects
because the overall effectiveness of current exotic plant management
programs is limited. Parks that do not have a standardized approach to
assist in decision-making have difficulty selecting the most appropriate
treatment option. Other parks currently do not have the necessary
compliance in place to implement some treatment options. Regarding
long-term impacts, Alternative 1 realizes a lower number of positive
impacts because it provides less effective treatment of exotic plants
and requires an indefinite treatment period.

In contrast to the no action alternative, Alternative 2 will satisfy the
majority of the six requirements listed above. Alternative 2 realizes
greater beneficial effects over the long-term because it provides for
more rapid control of exotic plants. Alternative 2 is the
environmentally preferred alternative because it provides the most
long-term benefits to the environment. Exotic plants within 13 parks
will be reduced, helping to ensure a safe, healthful, and productive
environment for park visitors and employees. Control of exotic plants
will also help promote aesthetically and culturally pleasing aspects of
the surroundings, while reducing the amount of degradation, risk of
health or safety, or other undesirable and unintended consequences. The
13 parks included in this plan will be better preserved through the use
of IPM. IPM will also help maintain the integrity of important historic
and cultural aspects of our national heritage. Treatment of exotic
plants using IPM and the resultant decrease in exotic plants could
improve the public's perception of the 13 parks, perhaps resulting in
increased visitation. This will help achieve a balance between
population and resource use, permitting a "wide sharing of life's
amenities." As under the no action alternative, Alternative 2 will not
impact the quality of renewable resources or inhibit the attainable
recycling of depletable resources.

**WHY THE PREFERRED ALTERNATIVE WILL NOT HAVE A SIGNIFICANT EFFECT ON
THE HUMAN ENVIRONMENT**

As defined in 40 CFR §1508.27, significance is determined by examining
the following criteria:

## Impacts that may be both beneficial and adverse. A significant effect may exist even if the Federal Agency believes the balance of the effect will be beneficial. The preferred alternative will have no significant beneficial or adverse effects.

## 

**Geology**

IPM will not inhibit the desired condition to have natural and geologic
processes maintained in as natural condition as possible. Physical
disturbance associated with manual and mechanical treatments will not
have any measurable or perceptible effect on geologic features. However,
surface disturbance associated with IPM activities may cause minor
impacts to unknown paleontological resources. Chemical treatments will
not have any measurable or perceptible effect on geological resources.
Biological control treatments also will not have any measurable or
perceptible effect on geological resources. Prescribed fire may cause
minor changes to some geological resources. Effects may include some
deposition of carbonaceous residue and carbonaceous blackening of the
upper surfaces. However, these changes will be small, site-specific, and
will be consistent with changes observed from natural fires. The impacts
of IPM on geologic resources will be directly adverse, site-specific,
short-and long-term, and negligible to minor.

**Caves and Karst**

Exotic plant management will not inhibit the achievement of the desired
condition to have the natural systems associated with caves perpetuated.
Cultural treatments will not have any measurable or perceptible effects
on cave and karst resources at Jewel Cave National Monument and Wind
Cave National Park. Manual and mechanical treatments will also not have
measurable or perceptible effects on cave and karst resources. The
effect of tilling or other ground-disturbing activities will be
negligible. With the implementation of BMPs, the effect of chemical
treatment on cave resources, as currently understood, will be reduced.
Although impacts are difficult to determine, water sampling will reveal
any pesticide reaching the cave at selected drip sites and will allow
management to re-evaluate pesticide use practices. Cave biota, some
potentially unique and cave adapted, may be threatened if herbicides
occur in cave waters. The ecology and vulnerability of such organisms
are not well understood, and impacts could occur despite our best
efforts to prevent them. There will be no impact of biological
treatments on cave and karst resources. Impacts to the natural drainage
patterns and water quality in cave resources will not likely occur from
prescribed fires because ground cover will not be altered or eliminated
above the resource. Based on current knowledge, the impacts of exotic
plant management on cave and karst resources will likely be directly and
indirectly adverse, site-specific, short-and long-term, and negligible
to minor.

#### Air Quality and Visual Resources

IPM will not inhibit the maintenance of the desired condition to have
National Ambient Air Quality Standards met, current air quality
maintained, and integral vistas protected. There may be some impacts to
air quality, including a temporary increase in fugitive dust from
vehicles and soil disturbing activities, and an increase in emissions
from vehicle exhaust and equipment.

Wind may cause limited dispersion of chemicals, although resulting
changes in air quality will not likely be detectable. Some minor,
adverse, short-term visual impacts may occur from the use of pesticides.
On a small scale, non-target vegetation may show signs of chemical
burns. Moderate visual effects will likely occur in areas where large
infestations of exotic plants respond to chemical treatment. These areas
may be devoid of vegetation until native vegetation becomes
reestablished through reseeding and other treatments.

No known changes in air quality will occur from biological control
treatments. Prescribed burns may result in some temporary increases in
particulates and other combustion by-products, and reduced visibility
from smoke. Ability to see scenic vistas during prescribed fires may
also be reduced from smoke generation. However, prescribed fires will be
timed during periods when the potential for dispersion of smoke will be
limited. Potential effects from burning vegetation that has been treated
with pesticides are expected to be short-term, minor, and local.
By-products generated through combustion of treated vegetation will
vary. Some pesticides are almost entirely destroyed by fire. Since
pesticides will be applied in small quantities in accordance with
pesticide labels, levels of any by-products generated from burning of
treated vegetation will not likely be detectable. The impacts of exotic
plant management on air and visual resources will therefore be directly
adverse, site-specific to local, short-term, and negligible to moderate.

#### Water Resources

There may be some impacts to water quality, including temporary
increases in suspended solids. Irrigation will likely have negligible
effects on surface water flows since no surface water depletions or
accretions will occur under this alternative. Restoration activities,
such as reseeding and irrigation, will have a beneficial effect of
promoting the reestablishment of native vegetation, which could help
reduce erosion and sedimentation in surface waters. Minor mechanical
disturbance to native plants from tilling or other ground disturbing
activities may result in indirect effects, such as increased
sedimentation, to surface waters. ATVs may cross intermittent drainages
to access exotic plant populations. Stream crossings may potentially
increase localized sedimentation in standing or shallow flowing water at
the crossing. However, most drainages are dry during the summer when
most exotic plant control efforts occur. Physical changes to water
quality resulting from stream crossings will likely be below water
quality standards and criteria, and will be within the range of natural
variability.

The potential for directly spilling pesticides into surface waters is
unlikely. Pesticides will be transferred in controlled settings away
from surface water resources. All pesticides will be contained in
spill-proof containers and will be handled in accordance with label
specifications. Pesticides may pose a minor risk to ground water from
leaching. However, to minimize potential environmental effects,
pesticides will be selected based on soil texture and depth, distance to
water, and environmental conditions. Resource managers considering
application of pesticides in areas with low water tables will assess the
risk of leaching using the RAVE system or another model. Alternative
types of treatments, pesticides, or pesticide application rates will be
considered for areas with high leaching potential. Using these BMPs, the
potential for ground water contamination is unlikely.

Loss of vegetation from fire may cause negligible temporary increases in
erosion and sedimentation. Changes in water quality (such as an increase
in total suspended solids in surface waters) may be measurable and
short-term, but could be detected downstream. Runoff from burned areas
could contain ash, which will also have a negligible short-term effect
on water quality. No known direct impacts to surface waters will occur
from biological treatments.

Removal of exotic plants that affect riparian areas (such as purple
loosestrife, Russian olive \[*Elaeagnus angustifolia*\], and tamarisk
\[*Tamarix* spp.\]) will help return some surface waters to natural
flows, reduce visual obstructions along riverbanks, and create
additional habitat if these plants are removed from shallow channels.
Changes in flows may be detectable in some areas. IPM will help parks
achieve the desired condition of perpetuating surface waters and ground
waters, restoring natural floodplain values, and preserving natural
values of wetlands. The impacts of exotic plant management on water
resources will therefore be directly beneficial, directly and indirectly
adverse, site-specific to local, short-and long-term, and negligible to
moderate.

#### Wild and Scenic Rivers

Segments of the Missouri and Niobrara Rivers are classified as National
Wild and Scenic Rivers. These rivers received this designation because
of the degree to which they are free flowing, the degree to which the
rivers and their corridors are undeveloped, and the outstanding natural
and cultural characteristics of the rivers and their immediate
environments. IPM will help these parks achieve the desired condition to
have these rivers and their surrounding environments protected for the
benefit and enjoyment of present and future generations. Control of
purple loosestrife, for example, will have a measurable beneficial
effect on the character and value of both the Missouri and Niobrara
Rivers. Impacts will be beneficial, short- and long-term, and localized.
The impacts of exotic plant management on wild and scenic rivers will
therefore be direct beneficial effects, local, short-term and long-term,
and moderate.

#### Soils

There may be some temporary increases in erosion resulting from surface
disturbing activities. Cultural treatments may be used at any of the 13
parks. Reseeding and manual and mechanical treatments could cause
negligible, temporary disturbance to soil. Effects could include
compaction of soil and disturbance to upper soil profiles. ATVs may used
for the application of pesticides. Effects could include compaction of
soil and disturbance to upper soil profiles.

There is a low potential for accidental spills of pesticides that could
temporarily contaminate soils. Application of pesticides will increase
pesticide levels in soils. The potential for the build-up of pesticides
in soils is low because BMPs will account for both soil properties and
pesticide properties as part of planning. Parks may also monitor
pesticide levels in soils, as needed. No known direct impacts to soils
will occur from biological treatments.

Prescribed fires could increase nutrient availability in soil at any of
the 13 parks. The beneficial effects on soil productivity will be
readily apparent for one to several growing seasons. Loss of vegetation
from fire could cause negligible temporary increases in erosion and
sedimentation at any of the 13 parks. Mechanical disturbance to soils
during fire fighting or cleanup will be negligible. Impacts will be
site-specific and short-term. The impacts of exotic plant management on
soil resources will be directly adverse and beneficial, site-specific,
short-term to long-term, and negligible to moderate.

#### Vegetation

IPM will help parks achieve the desired condition to have, as parts of
the natural ecosystems of parks, all native plants maintained. Intrusion
into parks by personnel conducting IPM will cause short-term, direct
impacts to vegetation from foot and ATV traffic en route to exotic plant
populations. Individual plants will be trampled, resulting in no effect,
reduced vigor, or death depending on the stature and structure of the
plant and the amount and duration of pressure applied. Tilling or other
ground disturbing activities may cause minor mechanical disturbance to
individual native plants. These impacts will be adverse, short-term, and
slight to individual plants. Non-target plants subjected to pesticide
drift could experience no effect, reduced vigor, or death depending on
the sensitivity of the plant species to the specific pesticide and the
dose to which the plant is subjected. Overall, use of chemical controls
will have infrequent adverse, short-term, minor impacts on individual
plants because of drift or non-target treatment during the course of
spraying targeted species. Infrequent impacts to individual plants
generally have negligible to minor effects on plant populations, plant
communities, or ecological processes.

Because biological control agents are specific to individual species of
exotic plant, there will be negligible impacts to non-target plant
species. Impacts to target plants will be direct and beneficial. Any
biological control agent used will be host-specific so each biological
control agent will only attack one plant species (the host, or target
exotic plant).

The effect of fire on plants is species-specific. Fire may either
increase or reduce germination and vigor of plants. Prescribed fire may
have adverse impacts on some individual plants, but will affect a
relatively small portion of the overall population. Prescribed fire will
have the overall direct effect of removing stagnant, dead plant
accumulations while converting that biomass to ash and charcoal. Fires
tend to increase species diversity and reduce woody species relative to
grass and forbs species. The beneficial effects on soil productivity
will be readily apparent for one to several growing seasons. Prescribed
fire could also encourage the establishment of exotic plants following
fires. However, exotic plant infestations will be evaluated prior to the
burn to determine whether exotic plant species are present that may
increase following fire. These areas may be excluded, or follow-up
treatments will be used to control exotic plants after fires, as needed.

Reseeding and irrigation could have a beneficial effect of promoting the
reestablishment of native vegetation at any of the 13 parks. By
controlling exotic plants using IPM, native plant communities at all 13
parks will be rehabilitated, thus benefiting native plant species and
the habitat they provide. The minor short-term adverse impacts will be
outweighed by the long-term benefits to vegetation. The impacts of
exotic plant management on vegetation resources will therefore be
directly beneficial and adverse, site-specific and local, short-term to
long-term, and negligible to moderate.

#### Wetlands and Floodplains Values

Ground disturbing activities may cause negligible mechanical disturbance
to individual native wetland plants. These impacts will be adverse,
short-term, and negligible to individual plants. Activities that will
have greater impacts, such as tilling, will not be used in wetland or
riparian areas. U.S. Army Corps of Engineers permits will not be
required for any proposed IPM treatments. ATVs will be routed to avoid
palustrine wetlands. ATVs may cross intermittent drainages to access
exotic plant populations. Stream crossings could potentially increase
site-specific sedimentation in standing or shallow flowing water at the
crossing. However, most drainages are dry during the summer when most
exotic plant control efforts occur.

Non-target wetland plants subjected to pesticide drift could experience
no effect, reduced vigor, or death depending on the sensitivity of the
plant species to the specific pesticide and the dose to which the plant
was subjected. However, infrequent impacts to individual plants
generally do not impact plant populations, plant communities, or
ecological processes.

Because biological controls target a specific exotic plant, there will
be no expected impacts to non-target wetland plant species. Impacts to
target plants will be direct and beneficial to wetland communities. The
minor short-term adverse impacts will be outweighed by the long-term
benefits of habitat rehabilitation. The impacts of exotic plant
management on wetlands and floodplains will be directly beneficial and
adverse, site-specific to local, short-term to long-term, and negligible
to moderate.

Fire will primarily be used to remove undesirable wetland vegetation.
Fires have the direct effect of removing stagnant, dead plant
accumulations while converting that mass to ash and charcoal. Fires tend
to increase species diversity and reduce woody species relative to grass
and forb species. Wetland or floodplain functions will be increased. The
effect of fire on individual plants is species-specific. Fire may either
increase or reduce germination and vigor of plants. Prescribed fire may
have adverse impacts on some individual wetland and floodplain plants,
but will affect a relatively small portion of the overall population.

By controlling exotic plants, wetland communities and floodplains will
be rehabilitated, thus benefiting native plant species and the habitat
they provide. In some areas, IPM may enhance the existing wetland areas
or floodplain functions. Removal of exotic plants that affect riparian
areas (such as purple loosestrife, Russian olive, and tamarisk) will
help enhance riparian habitat. Impacts will be site-specific and effects
to individual plants could be long-term. IPM will help parks achieve the
desired condition to have, as parts of the natural ecosystems of parks,
all native animals maintained. By controlling exotic plants and
promoting healthy native plant communities, wildlife habitat will be
rehabilitated at all 13 parks. These beneficial effects will be
detectable in some areas, and may benefit wildlife populations that use
these areas over the long-term. The minor, short-term adverse impacts
will be outweighed by the long-term benefits of habitat rehabilitation.
The impacts of exotic plant management on terrestrial wildlife will be
directly beneficial and adverse, site-specific and local, short-term and
long-term, and negligible to moderate.

#### Terrestrial Wildlife

Intrusion into parklands by personnel conducting IPM will cause
short-term negligible harassment to wildlife species. There may be some
escape flight response exhibited by wildlife during these activities,
but this will produce negligible short-term, site-specific, adverse
impacts in the form of unnecessary energy expenditure. Reseeding and
irrigation could have a beneficial effect of promoting the
reestablishment of wildlife habitat at any of the 13 parks. Manual or
mechanical treatments could have site-specific adverse impacts on ground
nesting birds or burrowing animals. BMPs will keep these effects
site-specific and of little consequence to the species' population.

It is unlikely that terrestrial wildlife species will receive direct
exposure to pesticides during application because they will likely leave
the area or will return to burrows during periods of increased human
activity. However, insects and small mammals may be directly exposed to
pesticides on rare occasions. Pesticides will be applied in accordance
with label specifications, and because any nests or burrows encountered
will be avoided, there is low potential for exposure to acute levels of
pesticides. It is also unlikely that wildlife will be overexposed over
time if the pesticides are used according to label specifications and
BMPs. Impacts from chemical treatments will be small, infrequent,
site-specific, and short-term.

Fire can cause direct mortality to small mammals; some invertebrates,
reptiles, and amphibians; and non-mobile species of wildlife. Effects to
some wildlife will be detectable, but will be small and will not lead to
population-level effects. Direct mortality from fire does not usually
occur to most ungulate or bird species because they are able to move to
other areas. However, less mobile species such as small mammals,
reptiles, amphibians, and invertebrates may experience individual
mortalities during fires. Because the intensity, duration, and timing of
prescribed fires will be controlled, population-level effects are not
likely. Wildlife may also be indirectly impacted by fire through
reduction of potential nesting, resting, and foraging habitat, and
increased predation. Fire may also cause mobile animals, such as
ungulates, to concentrate in specific areas immediately after the burn
to search for food or cover. Impacts will be site-specific and
short-term. Fires that create a mosaic of burned and unburned areas may
directly benefit ground nesting bird, small mammal, and ungulate
populations. Fire may also indirectly benefit carnivore species that
feed on small mammals and ungulates.

#### IPM will help parks achieve the desired condition to have, as parts of the natural ecosystems of parks, all native animals maintained. By controlling exotic plants and promoting healthy native plant communities, wildlife habitat will be rehabilitated at all 13 parks. The additional biomass created by the introduction of biological control agents may also benefit mammal and bird species that prey on terrestrial insects. These beneficial effects will be detectable in some areas, and may benefit wildlife populations that use these areas over the long-term. The minor, short-term, adverse impacts will be outweighed by the long-term benefits of habitat rehabilitation. The impacts of exotic plant management on terrestrial wildlife will therefore be directly beneficial and adverse, site-specific and local, long-term, and moderate.

#### Aquatic Wildlife

Manual and mechanical treatments will cause negligible impacts to
aquatic wildlife and fisheries because surface disturbance in riparian
areas will be avoided. Mechanical and manual treatments will not likely
have measurable impacts to native fish or aquatic wildlife species,
their habitats, or the natural processes sustaining them.

It is unlikely that aquatic wildlife species will receive direct
exposure to pesticides during application, and it is also unlikely that
they will be overexposed if the pesticides are used according to label
specifications and BMPs. Pesticides registered for use in or near water
(such as glyphosate) have low toxicity and will not pose a risk to
aquatic communities or other standing water environments (NPS 2003h) and
will not likely be detectable. The use of pesticides will not be
expected to have any long-term adverse impacts on native species, their
habitats, or natural processes sustaining them.

Direct mortality from fire is unlikely for aquatic organisms. Aquatic
organisms may be indirectly affected by temporary loss of vegetation,
which could cause minor increases in erosion and sedimentation.
Increases in sedimentation will be site-specific and short term and may
be detectable, but will not be outside the range of natural variability.

By controlling exotic plants and promoting healthy native riparian
communities, aquatic communities at any of the 13 parks could indirectly
benefit from IPM. Indirect benefits include restoration of ecosystem
structure and surface water hydrology. Direct beneficial effects will be
detectable in some areas that have reduced sedimentation once native
plant communities are rehabilitated. The additional biomass created by
the introduction of biological control agents may indirectly benefit
some aquatic species that prey on terrestrial insects. The minor
short-term adverse impacts will be outweighed by the long-term benefits
to aquatic habitat. The impacts of exotic plant management on aquatic
wildlife and fisheries will therefore be indirectly beneficial, directly
adverse, site-specific and local, short-term and long-term, and
negligible to moderate.

#### Wilderness

The reduction or elimination of exotic plants will ultimately restore
the naturalness sought by visitors to the Theodore Roosevelt National
Park Wilderness. There will be a beneficial change in wilderness
character and quality that will be measurable and site-specific. The
minor, short-term, adverse impacts will be outweighed by the long-term
benefits to wilderness preservation. IPM will not inhibit the
maintenance of the desired condition to have no commercial enterprise
and no permanent roads within any wilderness areas, except as necessary
to meet minimum requirements for the administration of the area.

A temporary change in wilderness character and associated values will
occur during exotic plant management activities. Some aspects of IPM may
intrude on the wilderness experience. The presence of mechanized
equipment, such as aircraft, will be most notable. The presence of park
personnel and equipment could impact visitor solitude and self-discovery
in the Theodore Roosevelt National Park Wilderness. The site-specific,
short-term impacts on wilderness will be noticeable to wilderness
visitors. However, the short-term impacts of exotic plant management
will be outweighed by the beneficial effects. The impacts of exotic
plant management on wilderness will therefore be directly and indirectly
adverse and beneficial, site-specific, short-term and long-term, and
moderate.

#### Prime and Unique Farmlands

IPM will not inhibit the maintenance of the desired condition to have no
unnecessary and irreversible conversion of farmland to nonagricultural.
About 640 acres along the Niobrara River are irrigated cropland and meet
the National Resource Conservation Service (NRCS) definition of prime
farmland. According to NRCS, no other soils in the 13 parks are
classified as prime or unique farmland. No prime or unique farmland will
be converted to a nonagricultural use. The impacts of exotic plant
management on prime and unique farmlands are therefore negligible.

#### Visitor Use and Experience

In general, IPM will have a long-term, beneficial effect on visitor use
and experience by returning 13 parks to a more natural state. Many parks
receive complaints from visitors when they observe exotic plants within
the park. Rehabilitation of native plant communities will be readily
apparent to some visitors and likely long-term in some areas. Visitors
will likely be aware of the exotic plant management activities and
short-term disturbances associated with treatments. However, visitors
will also likely observe the beneficial effects of IPM and will also
likely express positive opinions about the changes. The impacts of
exotic plant management on visitor use and experience will therefore be
directly beneficial and adverse, site-specific, short-term to long-term,
and moderate.

#### Soundscapes

Parks will disseminate information about IPM programs to educate the
public on the need for ATVs and aircraft. Some degradation caused by
noise (undesirable human-caused sound) will result from operation of
equipment such as ATVs and aircraft. Human-caused noise will be
short-term and site-specific. Human-caused noise will be audible during
periods of equipment operation between sunrise and sunset. No
human-caused noise resulting from IPM will be audible between sunset and
sunrise. IPM will not inhibit the maintenance of the desired condition
to have, to the greatest extent possible, the natural soundscapes of
parks protected. The impacts of exotic plant management on soundscapes
will therefore be temporarily adverse, site-specific, short-term, and
minor.

#### Park Operations and Land Use

Each park will disseminate consistent information to the public about
current and proposed exotic plant management activities. Collaboration
with exotic plant management experts both within and outside the NPS
will also be ongoing. Improved exotic plant management will improve
relations with park neighbors as well as state and local officials who
have expressed concern about exotic plants spreading from each park onto
neighboring lands. Collaboration with exotic plant management
specialists and other parks will improve information exchange and will
help parks stay current on new exotic plant treatment technologies.

Implementation of an IPM plan could slightly affect park operations.
Funding for its implementation will come from new sources or
continuation of existing funding used for exotic plant management. There
will likely be a negligible increase in administrative support for
personnel and procurement as well as increased storage space needs,
office space and equipment needs, vehicle support, and fuel use.
However, parks already provide these services and can absorb the small
increases associated with an increase in the IPM program. The impacts of
exotic plant management on park operations and land use will therefore
be site-specific, short-term, and negligible.

#### Ethnographic Resources

IPM will not inhibit the maintenance of the desired condition to have
access to and ceremonial use of Indian sacred sites by Indian religious
practitioners accommodated. IPM will not adversely impact areas where
American Indians gather plants. Traditional use plants identified by
tribes will be avoided to the extent feasible to minimize impacts. These
impacts will be adverse, short-term, and minor to individual plants.
Infrequent impacts to individual plants generally do not impact plant
populations, plant communities, or ecological processes. The impacts of
exotic plant management on Native American concerns will therefore be
direct, site-specific, short-term, and minor.

#### Social and Economic Conditions

The reduction of exotic plants in each park will decrease the spread of
exotic plants onto private or federal lands adjacent to each park and
reduce the individual landowner\'s exotic plant control costs. While
these landowners will benefit, there will be no appreciable effect on
local communities' overall population, income, or employment base.
However, limiting the potential for exotic plants to spread from parks
to areas outside park unit boundaries will help maintain property
values. Some parks may use concessionaires to assist with IPM
treatments, which will have beneficial effects for local businesses. IPM
will not inhibit the maintenance of the desired condition to have an
understanding of parks by park visitors, the non-visiting public,
gateway communities and regions, and human interactions with park
resources provided. The impacts of exotic plant management on social and
economic conditions will be indirectly beneficial, local, long-term, and
moderate.

Degree of effect on public health or safety: NPS Management Policies
(2001) advocate a safe work environment for employees and a safe
experience for park visitors. The equipment proposed for use such as
hand tools, chainsaws, portable sprayers, ATVs, and aircraft are all
standard devices with established safety protocols. Training on the
proper use of equipment is included as part of the preferred
alternative. Safety protocols for storing, mixing, transporting,
handling spills, and disposing of unused pesticides and containers will
be followed at all times. The pesticides proposed for use have very low
acute toxicity to humans and personal protective equipment (PPE) will be
used during application to reduce the potential for chronic exposure of
employees. Safety protocols for storing, mixing, transporting, handling
spills, and disposing of pesticides and containers are an integral part
of the preferred alternative. Treated areas subject to visitation will
be marked during the no-entry period (as described on the pesticide
label or until dry) to advise visitors against entering treated areas
and thus exposing themselves to the chemicals. Training will be required
prior to use of pesticides. Meteorological conditions will be accounted
for in planning to decrease the risk of pesticide drift. Because of
these and other safety precautions, the preferred alternative will not
affect human health or safety for park employees or visitors.

Unique characteristics of the geographic area such as proximity to
historic or cultural resources, park lands, prime farmlands, wetlands,
wild and scenic rivers, or ecologically critical areas: Cultural
resources (including archaeological resources, historic structures and
buildings, cultural landscapes, and ethnographic resources); prime and
unique farmlands; wild and scenic rivers; adjacent lands; wetlands; and
wilderness will not be affected.

Degree to which effects on the quality of the human environment are
likely to be highly controversial: There were no highly controversial
effects identified during either preparation of the environmental
assessment or the public review period.

Degree to which the possible effects on the quality of the human
environment are highly uncertain or involve unique or unknown risks:
There were no highly uncertain, unique, or unknown risks identified
during either preparation of the environmental assessment or the pubic
review period.

Degree to which the action may establish a precedent for future actions
with significant effects or represents a decision in principle about a
future consideration: The preferred alternative neither establishes a
National Park Service precedent for future actions with significant
effects nor represents a decision in principle about a future
consideration.

Whether the action is related to other actions with individually
insignificant but cumulatively significant impacts: Cumulative effects
were determined by combining the effects of the alternative with other
past, present, and reasonably foreseeable future actions at each park
unit. A number of past, ongoing, or reasonably foreseeable future
actions within each park unit and in the surrounding region of each park
unit were identified and analyzed in the environmental assessment.
Cumulative impacts vary by resource; however, cumulative impacts are not
expected to be greater than moderate in intensity. The relative adverse
contributions of the preferred alternative to the overall cumulative
impacts are predicted to be negligible. However, in some cases the
preferred alternative will have a beneficial contribution to the overall
cumulative impacts.

Degree to which the action may adversely affect districts, sites,
highways, structures, or objects listed on National Register of Historic
Places or may cause loss or destruction of significant scientific,
cultural, or historical places: Impacts to cultural resources and
archaeological sites will be negligible to minor. IPM will also not
inhibit the maintenance of the desired condition to have archaeological
sites protected in an undisturbed condition unless it is determined
through formal processes that disturbance or natural deterioration is
unavoidable. All surface disturbing activities will be avoided in areas
where cultural or historic resources are identified or are known to
occur.

Surface disturbing activities and prescribed fires may physically impact
unknown cultural resources. The use of pesticides also may impact
unknown cultural resources. However, BMPs will be implemented to
minimize the potential for accidental impacts to unknown resources.
Under the preferred alternative, areas that may contain cultural or
historic resources and that have not been previously studied will be
surveyed. If cultural or historic resources are identified or are known
to occur, all surface disturbing activities will be avoided in these
areas. Use of pesticides within the boundaries of the cultural resource
or historic resource sites will be restricted. Because of unknown
effects, pesticides will not be directly applied to historic structures
with limestone grout, hearth features, or cultural resources comprised
of organic material, bone, pollen, seeds, and materials made from plant
fiber. However, pesticides may be used in lands surrounding cultural or
historic sites in accordance with BMPs. In the event that cultural
resources are encountered during treatments, all work will stop
immediately and will not continue until the site can be evaluated and
cleared by a qualified specialist.

Each of the 13 parks initiated and completed consultation as required
under Section 106 of the National Historic Preservation Act (NHPA).
Letters and copies of the environmental assessment were submitted to the
State Historic Preservation Offices (SHPO) of Montana, Nebraska, North
Dakota, South Dakota, and Wyoming for review and comment. The NPS
determined that this programmatic approach to the treatment of exotic
plants will have No Adverse Effect on the cultural qualities and
features within the 13 parks included in this plan, with the realization
that at some point additional consultation may be needed should unknown
sites be discovered. Concurrence with this determination was received
from the various SHPO as follows:

-   Montana SHPO -- concurrence received for Fort Union Trading Post
    National Historic Site on May 23, 2005.

-   Nebraska SHPO -- concurrence received for Agate Fossil Beds National
    Monument, Missouri National Recreational River, Niobrara National
    Scenic River, and Scotts Bluff National Monument on May 25, 2005.

-   North Dakota SHPO -- concurrence was received for Knife River Indian
    Villages National Historic Site, Theodore Roosevelt National Park,
    and Fort Union Trading Post National Historic Site on August 25^th^,
    2005.

-   South Dakota SHPO -- concurrence was received for Wind Cave National
    Park on July 29^th^, 2005, Missouri National Recreational River on
    August 9^th^, 2005, Mount Rushmore National Memorial on August 31,
    2005, and for both Jewel Cave National Monument and Minuteman
    Missile National Historic Site on August 5^th^, 2005.

-   Wyoming SHPO -- concurrence was received for Devils Tower National
    Monument on March 21, 2004 and for Fort Laramie National Historic
    Site on June 22, 2005.

Degree to which the action may adversely affect an endangered or
threatened species or its critical habitat: The biological assessment of
federally threatened, endangered, and candidate species describes
accounts of 14 species that occur or potentially occur within at least
one of the 13 parks included in this plan.

In accordance with the Endangered Species Act, Section 7 consultation
with the U.S. Fish and Wildlife Service (USFWS) concerning impacts to
threatened and endangered species was initiated during the initial
drafting of this EPMP/EA. In December of 2003, public scoping letters
describing the proposed action were sent to the Nebraska, North Dakota,
South Dakota, and Wyoming Ecological Services Offices of the USFWS.
Responses to the public scoping letter, including threatened,
endangered, and candidate species lists, were received from the North
Dakota and Wyoming Service Offices on January 6 and January 9, 2004,
respectively. Letters initiating informal consultation and requesting a
list of federal threatened and endangered species were sent to the
Nebraska and South Dakota Service Offices on March 3, 2003. Responses to
the informal consultation letters, including threatened, endangered, and
candidate species lists, were received from these offices on March 15
and March 19, 2004, respectively.

A biological assessment was then prepared that included determination of
effect for each of the 14 species.

Specific conservation measures will be implemented to minimize potential
impacts to threatened, endangered, and sensitive (TES) species. General
BMPs developed to minimize potential impacts to TES species include:

-   Personnel will be trained to identify and avoid TES species. If any
    species are identified in the field, treatments will be halted until
    buffer areas are established. ATVs and off-road vehicle traffic will
    be used on a limited basis in areas where TES plants are known to
    occur or have the potential to occur.

-   Restoration activities, such as reseeding and irrigation, will be
    used where necessary to promote the reestablishment of native plant
    communities. To avoid take, activities near TES species habitat will
    be avoided during sensitive periods. Any manual or mechanical
    methods will be highly selective for individual plants to minimize
    the potential for impacting TES plants. Personnel will be trained to
    identify and avoid TES species if encountered. Tilling will not be
    used in areas where TES plants are known to occur or have the
    potential to occur.

-   Cultural treatments will not likely have any measurable impacts on
    native fish or aquatic wildlife species, their habitats, or natural
    processes sustaining them. Livestock will be actively managed to
    have negligible potential impacts to stream banks and river bottom
    habitats. Impacts will be site-specific and short-term. The impacts
    of irrigation on aquatic wildlife and fisheries will therefore be
    directly adverse, site-specific, short-term, and negligible.

-   Chemicals will only be used when determined necessary, or if there
    are no other acceptable or feasible treatment options.
    Species-specific BMPs have been developed, in addition to general
    BMPs, to minimize the potential exposure of TES species to
    pesticides. Application of pesticides near TES species' habitat will
    be avoided during sensitive periods. If hand applications are used
    to apply pesticides, a 20-foot radius no-spray zone will be
    established around TES plants. Hand spraying allows for treatment of
    individual plants and the spray can be directed within an inch of
    the target plant. If boom treatments are used (ATVs or aircraft) to
    apply pesticides, a 50-foot no-spray zone will be established around
    these plants.

-   Any biological control agents released in a park will be approved by
    APHIS with no demonstrated affinity for TES plant species.

-   Project-specific prescribed fire plans will be developed for each
    prescribed fire to limit the potential for high-intensity fires.
    Prescribed fires will not be conducted in TES species' habitat
    during active periods. Project specific prescribed fire plans will
    be designed to prioritize the protection of habitat for TES species.

-   In addition, species-specific BMPs will be implemented for each TES
    species. BMPs have been developed for the bald eagle, whooping
    crane, interior least tern, piping plover, black-footed ferret, gray
    wolf, Preble's meadow jumping mouse, pallid sturgeon, Topeka shiner,
    scaleshell mussel, American burying beetle, western prairie fringed
    orchid, Ute ladies\'-tresses orchid, and Colorado butterfly plant.

Additional conservation measures will be implemented for each species.
Species-specific measures are described below. Some exotic plant
management activities may be necessary within buffer zones established
for each species. Any activities that are likely to cause a take of a
species, as defined by the ESA, will be coordinated with the appropriate
Service Field Office before any actions are taken. If these activities
may affect - are likely to adversely affect a species, formal
consultation will be conducted.

Bald Eagle (*Haliaeetus leucocephalus*)

-   Treatment areas will be evaluated for suitable bald eagle nesting
    and roosting habitat prior to conducting exotic plant management
    activities.

-   A disturbance-free buffer area will be maintained around any active
    bald eagle nests and winter roost sites. The Wyoming and North
    Dakota Service Field Offices recommend that a 1 mile buffer area be
    established around active bald eagle nests or winter roost sites.
    The Nebraska Field Office recommends a disturbance-free buffer area
    of 1/2 mile be established around active bald eagle nests or winter
    roost sites. The South Dakota Field Office recommends a buffer zone
    of one-quarter mile around active nests or winter roost sites. If a
    disturbance free-buffer zone is not feasible, then activity should
    be conducted outside of the active breeding period (February 15 to
    August 15) to protect nesting birds, and the winter roosting period
    (November 1 through April 15) to protect roosting birds.

-   Clearing of live or dead conifer or cottonwood trees greater than 12
    inches in diameter at breast height along streams, rivers, and
    wetlands will be avoided to the extent possible to help preserve
    potential bald eagle roosting or nesting habitat.

Whooping Crane (*Grus americana*)

-   Treatment areas will be evaluated for suitable whooping crane
    feeding and roosting areas prior to conducting exotic plant
    management activities.

-   If whooping cranes are present, a 1/2 mile buffer area will be
    established around any feeding or roosting areas. No exotic plant
    management activities will occur within this area while whooping
    cranes are present.

-   A no-flight aerial pesticide application buffer area of 1/2 mile
    will be established around any nesting or foraging areas when
    whooping cranes are present.

Interior Least Tern and Piping Plover (*Sterna antillarum athallasos*
and *Charadrius melodus*)

-   Treatment areas will be evaluated for potential piping plover and
    interior least tern habitat before exotic plant treatment.

-   If interior least tern or piping plover are found, a buffer zone of
    1/4 mile will be established around any active nesting colonies. No
    exotic plant management activities will occur within this buffer
    zone during the active breeding period (from April 15 to August 15).

-   A no-flight buffer area of 1/2 mile will be established around any
    active colonies.

Black-footed Ferret (*Mustela nigripes*)

-   In the event that black-footed ferrets are located, the USFWS will
    be consulted to verify the occurrence. In addition no disturbance
    will be allowed within prairie dog colonies inhabited by
    black-footed ferrets to comply with the ESA.

-   Because some black-tailed prairie dog colonies may provide habitat
    for future black-footed ferret reintroduction, a number of
    management practices will be implemented to minimize potential
    impacts to prairie dog colonies. These practices include:

    -   Physical disturbance to prairie dog towns or complexes will be
        avoided wherever possible.

    -   The use of mechanical treatments such as tilling will not be
        used in prairie dog colonies.

    -   The use of pesticides in prairie dog colonies will only be
        considered if no other alternatives are feasible.

    -   Only those pesticides that have a low potential toxicity, such
        as those that contain glyphosate as the active ingredient will
        be used within prairie dog colonies.

    -   Herbicides that do not readily break down in soil will not be
        used in prairie dog colonies.

Preble's Meadow Jumping Mouse (*Zapus hudsonius preblei*)

-   Fort Laramie National Historic Site will be evaluated to determine
    if the park contains potential Preble's mouse habitat. Fort Laramie
    was unable to complete a survey for the Preble's mouse in 2004, but
    will likely complete a survey in the near future.

-   If the Preble's mouse is not found during future surveys, and if the
    USFWS concurs with the survey results, no conservation measures will
    be required to protect the Preble's mouse.

-   Until surveys are conducted and if the Preble's mouse is found
    during future surveys, the following conservation measures will be
    implemented to protect Preble's mouse habitat:

    -   All exotic plant management activities within Preble's mouse
        habitat will be conducted in accordance with the final section
        4(d) rule. Under this rule, noxious weed control activities must
        be conducted in accordance with: federal law, including U.S.
        Environmental Protection Agency (EPA) label restrictions;
        applicable state laws for noxious weed control; applicable
        county bulletins; herbicide application guidelines as prescribed
        by herbicide manufacturers; and any future revisions that apply
        to the pesticides proposed for use within the species' range. In
        the event of future revisions to EPA label restrictions and
        pesticide application guidelines, Fort Laramie will follow these
        revisions to assure protection of the Preble's meadow jumping
        mouse.

    -   Treatment activities within Preble's mouse habitat at Fort
        Laramie will be limited to minimize the potential for loss of
        vegetation. The unnecessary eradication of entire plant
        communities will be avoided and methods to reduce impacts to
        non-target species will be employed whenever possible. Broadcast
        spraying using ATVs will only be used on a small scale to treat
        high-density stands of exotic plants in uplands, and will not be
        used within riparian areas. Backpack hand sprayers will be used
        to treat exotic plants within riparian areas.

    -   Selective pesticides will be used to limit potential impacts to
        non-target native plants at Fort Laramie. For example,
        herbicides that target broad-leaved exotic plants and do not
        damage native grasses will be used wherever possible to treat
        broad-leaved exotic plants. Treated areas will be monitored to
        evaluate the reestablishment of native plants. Where needed,
        treated areas may be reseeded using native species to facilitate
        recovery of native plant communities.

    -   Mowing will not be conducted within riparian areas at Fort
        Laramie. Mowing treatments in upland areas located within
        Preble's mouse habitat will be timed so that they do not
        coincide with active periods of the Preble's mouse.

    -   Fort Laramie will not use prescribed fires to manage exotic
        plants under this plan.

Gray Wolf (*Canis lupus*)

-   Although unlikely, gray wolves may occasionally be observed within
    Fort Union Trading Post National Historic Site and Theodore
    Roosevelt National Park. If wolves are still present in the area, no
    exotic plant management activities will be conducted within the area
    of any dens, foraging areas, or rendezvous sites.

-   In the event that a resident population of gray wolves establishes
    within one of these park units, no exotic plant management
    activities will be conducted without first consulting with the
    appropriate USFWS Field Office.

Topeka Shiner (*Notropis topeka*)

-   Missouri National Recreational River and the Niobrara National
    Scenic River will be evaluated to determine if suitable Topeka
    shiner habitat is present before application treatment commences.
    This will be done by contacting South Dakota State University to
    access their geographic information system (GIS) program that
    predicts Topeka shiner habitat presence in eastern South Dakota
    rivers and streams (Wall et al. 2001) or Nebraska Game and Parks
    Commission to identify current and historic records of Topeka shiner
    presence.

-   If Topeka shiners have been identified, or if suitable habitat is
    predicted with an 80 percent confidence level from the GIS program,
    then consultation will take place with biologists from the
    appropriate USFWS Field Office before exotic plant management
    activities will begin.

-   Physical disturbances to riparian areas located adjacent to
    tributaries to the Missouri and Niobrara Rivers will be avoided to
    the maximum practical extent to limit potential impacts to the
    Topeka shiner.

Pallid Sturgeon (*Scaphirhynchus albus*)

-   Channel island tips will not be altered in any manner.

-   Channel alternations that limit or eliminate shallow, sloping bank
    habitat will be avoided.

-   No treatments that might alter flows in pallid sturgeon habitat
    (such as the diversion of water for irrigation) are allowed under
    the proposed action.

-   A NPS biologist will consult with the USFWS before directly applying
    any pesticides directly to waters that include pallid sturgeon
    habitat.

Scaleshell Mussel (*Leptodea leptodon*)

-   NPS staff responsible for exotic plant management at Missouri
    National Recreational River will receive training on how to identify
    the scaleshell mussel and its potential habitat.

-   Physical disturbance to scaleshell mussel habitat will be avoided.

-   In the event that a scaleshell mussel is found within a park unit,
    no exotic plant management activities will be conducted without
    first consulting with the appropriate USFWS Field Office.

American Burying Beetle (*Nicrophorus americanus*)

-   NPS staff responsible for exotic plant management at Missouri
    National Recreational River and the Niobrara National Scenic River
    will receive training on how to identify the American burying beetle
    and its potential habitat.

-   If populations of the American burying beetle are identified, no
    exotic plant management activities will be conducted without first
    consulting with the appropriate USFWS Field Office.

Ute ladies'-tresses Orchid (*Spiranthes diluvialis*)

-   NPS staff responsible for exotic plant management at Agate Fossil
    Beds National Monument, Devils Tower National Monument, and Fort
    Laramie National Historic Site will receive training on how to
    identify the Ute ladies'-tresses orchid and its potential habitat.
    Potential habitat includes wetlands and associated wet meadow areas.

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-   If populations of the Ute ladies'-tresses orchid are identified,
    conservation measures developed for threatened and endangered plants
    will be implemented (see below).

Western Prairie Fringed Orchid (*Platanthera praeclara*)

-   NPS staff responsible for exotic plant management at Missouri
    National Recreational River and the Niobrara National Scenic River
    will receive training on how to identify the western prairie fringed
    orchid and its potential habitat.

-   If populations of the western prairie fringed orchid are identified,
    conservation measures developed for threatened and endangered plants
    will be implemented (see below).

Colorado Butterfly Plant (*Gaura neomexicana coloradensis*)

-   NPS staff responsible for exotic plant management at Fort Laramie
    National Historic Site will receive training on how to identify the
    Colorado butterfly plant and its potential habitat.

-   If populations of the Colorado butterfly plant are identified,
    conservation measures developed for threatened and endangered plants
    will be implemented (see below).

Threatened, Endangered, and Sensitive Plants

-   If portable spraying is used to apply pesticides, establish a 5-foot
    no-spray zone around threatened or endangered plants for treatments
    involving application of pesticides. Portable spraying allows for
    treatment of individual plants and the spray can be directed within
    an inch of the target plant.

-   If boom treatments are used (ATVs or aircraft) to apply pesticides,
    establish a 50-foot no-spray zone around threatened and endangered
    plants.

-   Tilling will not be used in areas where threatened, endangered, and
    sensitive plants are known to occur or have the potential to occur.

-   ATVs and off-road vehicle traffic will not be used in areas where
    threatened, endangered, and sensitive plants are known to occur.

-   ATVs and off-road vehicle traffic will be used on a limited basis in
    areas where threatened, endangered, and sensitive plants have the
    potential to occur.

-   Pesticides will be applied in accordance with pesticide labels.

-   Pesticide applicators will receive training on identification of
    threatened, endangered, and sensitive plants. If these plants are
    identified in the field, treatments will be halted until the
    aforementioned buffer areas are established.

Accounting for these BMPs, potential impacts to TES species are
described below:

-   At those parks where TES species are present, these species may
    benefit from the restoration of native plant communities and
    wildlife habitat. These direct beneficial effects may be detectable
    in some areas, and will benefit TES populations using those areas.
    The minor and short-term impacts will be outweighed by the long-term
    benefits of habitat rehabilitation. The impacts of exotic plant
    management on TES species will therefore be directly beneficial,
    site-specific or local, long-term, and moderate.

-   Restoration activities, such as reseeding and irrigation, will have
    a direct beneficial effect of promoting the reestablishment of
    native vegetation. The impacts of cultural treatments on TES will
    therefore be directly beneficial, site-specific, short-term, and
    minor.

-   No direct impacts to TES wildlife or plants are expected because of
    proposed mitigation measures. No escape flight response is expected
    from TES species because BMPs will be followed to avoid disturbing
    these species. The impacts of manual and mechanical treatments on
    TES species will therefore be indirect, site-specific, short-term,
    and minor. It is unlikely that TES will receive direct exposure to
    pesticides during application, and it is also unlikely that they
    will be overexposed to pesticides over time when used under label
    specifications and BMPs. Because no pesticides will be applied
    within buffer areas during sensitive periods, potential risks to TES
    from pesticide application activities are unlikely. The impacts of
    chemical treatments on TES will therefore be directly and indirect,
    site-specific, short-term, and minor.

-   Because biological control agents are specific to a target exotic
    plant, there will be no known direct impacts to non-target TES
    species. The additional biomass created by the introduction of
    biological control agents may indirectly benefit TES mammal and bird
    species that prey on terrestrial insects. The impacts of biological
    treatments on TES species will therefore be indirectly beneficial
    and minor.

-   The additional biomass created by the introduction of biological
    control agents may benefit TES species that prey on terrestrial
    insects. Impacts will be beneficial, short- or long-term, and
    site-specific. Impacts will be similar to Alternative 1. The impacts
    of biological treatments on TES species will therefore be indirectly
    beneficial, site-specific, short-term, and minor.

-   Fire will not directly affect TES species because it will not be
    used in areas that could affect these species during sensitive
    periods. The impacts of prescribed fire on TES species will
    therefore be directly and indirect, site-specific, short-term, and
    minor.

The following determinations were made in the biological assessment:

[Bald eagle (Haliaeetus leucocephalus)]{.underline}

May affect, but is not likely to adversely affect

[Whooping crane (Grus americana)]{.underline}

May affect, but is not likely to adversely affect

[Interior least tern (Sterna antillarum athallasos)]{.underline}

May affect, but is not likely to adversely affect

[Piping plover (Charadrius melodus)]{.underline}

May affect, but is not likely to adversely affect

[Black-footed ferret (Mustela nigripes)]{.underline}

May affect, but is not likely to adversely affect

[Preble's meadow jumping mouse (Zapus hudsonius preblei)]{.underline}

May affect, but is not likely to adversely affect

[Gray wolf (Canis lupus)]{.underline}

May affect, but is not likely to adversely affect

[Topeka shiner (Notropis Topeka)]{.underline}

May affect, but is not likely to adversely affect

[Pallid sturgeon (Scaphirhynchus albus)]{.underline}

May affect, but is not likely to adversely affect

[Scaleshell mussel (Leptodea leptodon)]{.underline}

May affect, but is not likely to adversely affect

[American burying beetle (Nicrophorus americanus)]{.underline}

May affect, but is not likely to adversely affect

[Ute ladies'-tresses orchid (Spiranthes diluvialis)]{.underline}

May affect, but is not likely to adversely affect

[Western prairie fringed orchid (Platanthera praeclara)]{.underline}

May affect, but is not likely to adversely affect

[Colorado butterfly plant (Gaura neomexicana coloradensis)]{.underline}

May affect, but is not likely to adversely affect

Concurrence with the above determinations was received from all four
state USFWS offices as follows:

-   Nebraska USFWS Field Office - concurrence received on July 22, 2004

-   South Dakota USFWS Field Office - concurrence received on August 13,
    2004

-   North Dakota USFWS Field Office - concurrence received on August 23,
    2004

-   Wyoming USFWS Field Office - concurrence received on September 8,
    2004

Whether the action threatens a violation of federal, state, or local
environmental protection law: The preferred alternative violates no
federal, state, or local environmental protection laws.

In addition to reviewing the list of significance criteria, the National
Park Service has determined that implementation of the proposal will not
constitute an impairment to any of the 13 parks' resources and values.
This conclusion is based on a thorough analysis of the environmental
impacts described in the environmental assessment, public comments
received, relevant scientific studies, and the professional judgment of
the decision-maker guided by direction in the NPS Management Policies
(December 27, 2000). Although this plan/project has some negative
impacts, in all cases these adverse impacts are the result of actions
taken to preserve and restore other park resources and values. Overall,
the plan results in benefits to park resources and values, opportunities
for their enjoyment, and it does not result in their impairment.

# PUBLIC INVOLVEMENT

In December of 2003, a press release announced the initiation of a plan
to control exotic plants at 13 parks located in the NGP region. Public
scoping letters were sent to 960 individuals and organizations.
Interested parties were encouraged to submit comments on this project
via mail, email, fax, the project web page, or attendance at one of four
open houses. Additional opportunities for comment were afforded to the
general public and many exotic plant-oriented and regulatory
organizations during the public review period in January and February of
2003. Open house meetings were held in Dickinson, North Dakota,
Niobrara, Nebraska, Gering, Nebraska, and Custer, South Dakota.

On May 2, 2005, this plan was sent to 93 individuals, including tribal
government representatives and members of the public who attended a
public open house, provided comments, or specifically asked to receive a
hard copy of the plan. Additionally, 12 individuals who asked to receive
information about this project electronically were sent an email with
information on how to retrieve the plan electronically. The release of
the public review document was announced widely through press releases
distributed by each park. The plan was posted on the project's web page:
http://www.northerngreatplains-nps.com. The document then underwent a
45-day public review period from May 2, 2005 to June 15, 2005. A total
of 7 responses were received. Three of the letters included support for
the preferred alternative. Responses to substantive comments are
included in the errata sheets.

# CONCLUSION

The preferred alternative does not constitute an action that normally
requires preparation of an environmental impact statement (EIS). The
preferred alternative will not have a significant effect on the human
environment. Negative environmental impacts that could occur are
negligible to moderate. There are no unmitigated adverse impacts to
public health, public safety, threatened or endangered species, sites or
districts listed in or eligible for listing in the National Register of
Historic Places, or other unique characteristics of the region. No
highly uncertain or controversial impacts, unique or unknown risks,
cumulative effects, or elements of precedence were identified.
Implementation of the action will not violate any federal, state, or
local environmental protection law. In addition to reviewing the list of
significance criteria, the National Park Service has determined that
implementation of the proposal will not constitute an impairment to any
of the 13 parks' resources and values.

Based on the foregoing, it has been determined that an EIS is not
required for this project and thus will not be prepared.

Recommended:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Lisa Eckert Date

Superintendent, Devils Tower National Monument

(on behalf of 2 NPS Intermountain Region parks)

Recommended:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Todd Suess Date

Superintendent, Jewel Cave National Monument

(on behalf of 11 Midwest Region parks)

Approved:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Michael D. Snyder Date

Acting Director, NPS Intermountain Region

Approved:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Ernest Quintana Date

Director, NPS Midwest Region

**Errata Sheets**

**Northern Great Plains Exotic Plant Management Plan**

**and Environmental Assessment, March 2005**

#### ERRATA SHEETS

Page 1-30, Table 1-2

Add the following text as the first row under DETO:

Park Unit: DETO

Policy/Plan: Belle Fourche River Watershed Plan

Responsible Agency: Wyoming Department of Environmental Quality

Requirements/Goals/Objectives: The purpose of this plan is to: maintain
and/or improve the quality of the Belle Fourche River by identifying
possible human pollutant sources and to mitigate those pollutants to an
acceptable level; improve water quality and ultimately delist impaired
segments of the Belle Fourche River; promote the use of BMPs to improve
water quality; develop an effective public education and information
program; and continue to sample water quality to monitor implementation
of the watershed plan.

Relationship: The EPMP/EA is consistent with the goals within the Belle
Fourche River Watershed Plan.

Page 2-13

Modify the first paragraph as follows:

All parks also collaborate with tribal and other federal officials and
state, county, and private entities. The amount of collaboration varies
greatly among park units. In some cases, extensive collaboration is
necessary in parks with management partnerships such as Niobrara
National Scenic River and Missouri National Recreational River. Much of
the land included within these parks is privately owned, so exotic plant
management requires extensive coordination among the NPS, county weed
supervisors, **the U.S. Army Corps of Engineers,** and private
landowners.

Page 2-27

Add the following text to the end of the third paragraph:

**"Under the preferred alternative, resource specialists at each park
will consult with experts from local, state, and federal agencies and
universities to identify the most appropriate treatment method or
methods for that plant species. Resource specialists will consider the
life cycles of each species in selecting treatment methods. Each exotic
plant species' life cycle will directly affect the type and timing of
treatment methods that are most effective for that species in a specific
park's environment."**

Page 2-28, line 5

Add the following text to the end of the paragraph:

**If the proposed treatment complies with applicable policies and
regulations, the resource specialist will document this compliance with
a memo to file.**

Page 2-31, line 14

Add the following text:

**BMPs will be implemented as part of exotic plant management
treatments. The resource manager responsible for supervising exotic
plant management activities will be responsible for ensuring that
mitigation measures and BMPs occur.** Each of these treatments is
discussed in the following sections.

Page 2-48, line 28 and Page 4-40, line 29

Add the following text:

Highly water-soluble pesticides **that do not have aquatic labels** will
not be used in areas where there is potential to affect surface water or
ground water resources.

Page 2-52, line 8

Modify and add the following text:

Equipment would be maintained and calibrated**:** ~~prior to each
application of pesticides.~~

-   **On a regular basis, and at a minimum of the start of each season**

-   **Prior to an applicator operating new equipment or equipment on
    which they have not been calibrated**

-   **After equipment is repaired or replaced in a manner that could
    affect the application rate.**

Page 3-5, line 38

Add the following text:

Geological resources are documented in MNRR's General Management Plan
Environmental Impact Statement**s** (**NPS 1997:104 and** NPS 1999a:72)
and are directly quoted.

Page 3-6, Line 3

Modify text as follows:

Known fossil sites **in the 59-mile district of the MNRR** are **nearly
all** gravel pits and only four sites of the MNRR are documented in
scientific literature. **Fossils in the 39-mile district area
exceptionally illustrate the geologic history of the Eocene-Recent
epochs. Miocene epoch and similar Miocene fossils are believed to be
widespread in the area with potential for more discoveries, but there
has been little recent exploration.**

Page 3-18, Line 21

Modify text as follows:

MNRR's *Final General Management Plan**s***, *Environmental Impact
Statement**s*** (**NPS 1997:118** and NPS 1999a:85) documents air
resources as follows.

Page 3-30, Line 7

Add the following text:

"**The Wyoming Department of Environmental Quality's Belle Fourche River
Watershed Plan (WDEQ 2004) states that agricultural impacts "may have an
adverse and identifiable effect on water quality, especially fecal
coliform levels.**"

Page 3-32, Line 37

Modify text as follows:

MNRR's *Final General Management Plan**s***, *Environmental Impact
Statement* (**NPS1997:117** and NPS 1999a:71, 83, 84) documents water
resources and reads as follows.

Page 3-33, Line 5

Modify text as follows:

The **39-mile segment of the Missouri River from Fort Randall Dam, South
Dakota to Running Water, South Dakota and the** 59-mile segment of the
Missouri River from Gavins Point Dam in South Dakota to Ponca S**t**ate
Park in Nebraska **are two** ~~is one~~ **of the** few remaining
segments of the Missouri River that **are**~~is~~ not channeled or
**damm**~~n~~ed. The MNRR occurs along these~~is~~ segments of ~~the~~
Missouri River**, including the lower Niobrara River and lower Verdigre
Creek**. These~~is~~ sections of ~~the~~ river have~~s~~ been designated
as ~~a~~ national recreational river**s**. There are several large
islands within this segment. **Fort Randall and** ~~The~~ Gavins Point
Dam controls uniform river flow on the open Missouri, and the USACE
performs flow management.

Page 3-52, Line 2

Modify text as follows:

MNRR's *Final General Management Plan**s**, Environmental Impact
Statement**s*** (**NPS 1997:105**, NPS 1999a:73, 74, 83) describe~~s~~
vegetation resources and is updated as follows.

Page 3-61, Line 40

Modify text as follows:

Terrestrial wildlife resources are taken directly from MNRR's *Final
General Management Plan**s***, *Environmental Impact Statement**s***
(**NPS 1997:107,** NPS 1999a:75, 76).

Page 3-62, First Paragraph

Add following text to end of paragraph:

**However, the Yankton Sioux Tribe and other private ranches maintain
domestic herds of elk and bison, and an established free-roaming (wild)
herd of elk resides in the Boyd County, Nebraska and Gregory County,
South Dakota region adjacent to the 39-mile segment of MNRR.**

Page 3-83, Line 22

Modify text as follows:

Recreational resources are described in MNRR's *Final General Management
Plan**s***, *Environmental Impact Statement**s*** (**NPS 1997:28, 36
and** NPS 1999a:30, 100) and read as follows. The majority of visitation
in MNRR is by local residents~~, with the exception of Ponca State
Park~~.

Page 3-83, Line 40

Delete the following text:

~~The USACE, under cooperative agreement, manages bank stabilization,
land acquisition, and recreational facility development. The Gavins
Point project manager is part of the planning team.~~

Page 3-84, Line 3

Delete the following text:

~~Easement interests could be acquired, however none have been acquired.
In 1980, 55 of the 66 owners contacted signed a right-of-entry form for
stream bank protection and gave the NPS scenic easements.~~

Page 3-84, Line 10

Modify text as follows:

There are no zoning controls for Yankton ~~County~~, **Gregory, Bon
Homme, and Charles Mix Counties,** South Dakota or Cedar ~~and~~, Dixon,
**Boyd, and Knox** Counties, Nebraska.

There are more than ~~15~~20 public and private access areas **on the
designated National Recreational River reaches from Fort Randall Dam**
~~Missouri River from Gavins Point Dam~~ to Ponca State Park**,
including the lower Niobrara and Verdigre waterways**.

Page 3-100, Line 21

Modify text as follows:

This description of cultural resources is taken directly from the MNRR
*Final General Management Plan**s***, *Environmental Impact
Statement**s*** (**NPS 1997:119-127 and** 1999a:86-91) and is updated as
follows.

Page 3-100, Line 36

Modify text as follows:

Historic Indian tribes, including the Omaha, Ponca, **Yankton,** Santee
Dakota, Pawnee, Arikara, Ioway and the Brule and Oglala Divisions of the
Lakota, are also believed to have used the area.

Page 3-100, Line 40

Modify text as follows:

Several of these forts were situated along the 59-mile stretch of the
Missouri River, including Fort Vermillion I, McClellans Trading Post,
and a Columbia Fur Company Post**, as well as the 39-mile district on
the Missouri River, including Ponca Post, Fort Mitchell, and Le Clerc's
Post**.

Page 3-100, Line 18

Modify text as follows:

Ponca State Park**, Niobrara State Park, and Randall Creek Recreation
Area** demonstrate~~s~~ the growth of 20^th^ century tourism and
recreation along the Missouri River.

Page 3-100, Line 33

Modify text as follows:

In Nebraska, within or immediately adjacent to the recreational river
boundaries, ~~six~~several historic properties are listed on the
National Register **including:** the Bow Valley Mills, the Meridian
Bridge at Yankton, **the Niobrara River railroad bridge, Red Bird Fort,
Ponca Fort, and Schulte** Archaeological Site**s**, Wiseman
Archaeological Site, Ponca Historic District, and Indian Hill
Archaeological Districts.

Page 3-114, Line 28

Modify text as follows:

MNRR's *Final General Management Plan**s***, *Environmental Impact
Statement**s*** describes social and economic resources (**NPS 1997:139
and** NPS 1999a:101) and reads as follows. The regional population has
decreased 7 percent during the last 65 years. The 1990 census recorded
~~59~~**93**,000 people in the ~~five~~10-county region. There is
substantial immigration to the area. Only 61 percent of the current
residents were born in the region. The population **in the 59-mile
district** is 98 percent white and there are no Native American
reservations in the immediate area. **The population in the 39-mile
district is 91 percent white and 9 percent American Indian, with the
Yankton Sioux, Ponca, Santee reservations in the area.**

Total employment in 1990 was approximately ~~33~~50,000. The overall
employment in the region increased **10-**12 percent between 1975 and
1990. The primary sources of employment are **agriculture,** government,
manufacturing, service sector, and retail sales. Tourism makes a minor
contribution to the regional economy. Tourism for the area can be
overestimated because most visitor use is by local residents, which
provides no additional economic benefit to the region.

Regional per capita income is lower than in most surrounding counties or
in South Dakota, Nebraska, or the nation as a whole. The poverty rate is
15**-22** percent.

Page 4-69, Line 4

Modify text as follows:

Agricultural use (including the use of pesticides and fertilizers) ~~and
cattle grazing of lands surrounding DETO~~ have also degraded the
quality of the Belle Fourche River. Pesticide and fertilizer runoff from
agricultural lands ~~located outside DETO~~ degrade water quality in the
Belle Fourche River.

Page 4-69, Line 27-28:

Replace ~~Overgrazing by park neighbors creates disturbed areas adjacent
to the park, which also contributes to the reestablishment of exotic
plants.~~

with

Agricultural use creates disturbed areas near the park, which may also
contribute to the reestablishment of exotic plants.

Page 4-69, Line 36

Replace "~~livestock disturbance.~~" with "agricultural use."

Page 4-70, Line 20-23:

Replace:

~~Ranching activity has decreased the amount and quality of terrestrial
wildlife diversity and abundance outside DETO, which likely is having an
adverse effect on park wildlife. The park is fenced to the west and
north, which has also reduced natural wildlife migration into and out of
the park.~~

with

To protect park property, an 8 foot tall fence is located along the west
and north boundary of DETO. The fence is likely having an adverse effect
on park wildlife by reducing natural migration into and out of the park.

Page 4-71, Line 11:

Replace "~~External grazing sources~~..." with "Agricultural use..."

Page 4-80, Line 4

Modify text as follows:

The potential for pesticides to reach the ~~Knife~~ Missouri River may
be lower under Alternative 2 because of a number of BMPs would be
implemented to carefully control the conditions under which pesticides
are applied.

Page 6-1

Add the following references after the citation for Bluemle 2004:

Bovey, R. D 1987. Weed control problems, approaches, and opportunities
in rangeland. Review of Weed Science. 3:57-92.

Butler, Jack L., and Daniel R. Cogan. 2004. Leafy Spurge Effects on
Patterns of Plant Species Richness. Journal of Range Management.
57:305-311.

Page 6-3

Add the following references after the citation for Leafy Spurge
Scientific Advisory Panel (1994):

Lym, R. G. and K. C. Christianson. 2002. Evaluation of Imazapic and
Quinclorac applied under trees and other woody species. Research
Progress Report Western Society of Weed Science. 156-157.

Lym, R. G. and C. G. Messersmith. 1990. Cost-effective long-term leafy
spurge (*Euphorbia esula*) control with herbicides. Weed Technology.
4:635-641.

Lym, R. G. and C. G. Messersmith. 1987. Leafy spurge control and
herbicide residue from annual picloram and 2,4-D application. Journal of
Range Management. 40:194-198.

Lym, R. G. and C. G. Messersmith. 1985. Leafy spurge control and
improved forage production with herbicides. Journal of Range Management.
38:386-391.

Page 6-3

Add the following reference after the citation for Manasek (2004):

Markle, D.M. and R.G. Lym. 2001. Leafy Spurge (*Euphorbia esula*)
Control and Herbage Production with Imazapic. Weed Technology.
15:474-480.

Page 6-3

Add the following references after the citation for Marriott and DiSalvo
(2001):

Masters, R. A., D. Beran and F. Rivas-Pantoja. 1998. Leafy spurge
(*Euphorbia esula*) response to AC 263,222. Weed Technology. 12:602-609.

Masters, R. A., R. N. Stougaard, and S. J. Nissen. 1994. Leafy spurge
(*Euphorbia esula*) control with fall-applied imazapyr, imazaquin, and
imazethapyr. Weed Technology. 8:58-63.

Masters, R. A., K. P. Vogel, and R. B. Mitchell. 1992. Response of
central plains tallgrass prairie to fire, fertilizer, and atrazine.
Journal of Range Management. 45:291-295.

Page 6-7

Add the following reference after the citation for NPS 1998c:

NPS. 1997. Final General Management Plan. Environmental Impact
Statement. Missouri/Niobrara/Verdigre Creek. National Recreational
Rivers. Nebraska, South Dakota.

Page 6-11

Add the following reference after the citation for White et al. (2002):

Wyoming Department of Environmental Quality (WDEQ). 2004. Belle Fourche
River Watershed Plan. March.

Page 6-11

Add the following reference after the citation for USGS and NPS (2004):

Cheatham, J. 2005. Personal communication between Jim Cheatham and
Jennifer Vollmer. July 8.

Appendix F, page F-1

Add the following information after contact information for Ryan
Amundson:

Name: **Dr. Jack Butler**

Title: **Project Leader and Research Ecologist**

Area of Expertise: **Plant Ecology and Invasive Species**

Address: **USDA Forest Service**

**Rocky Mountain Research Station**

**1730 Samco Road**

**Rapid City, South Dakota, 57702**

Phone: **605-394-2670**

Email: **jackbutler@fs.fed.us**

#### Referred by: Chad Prosser

Appendix F, page F-3 -- add the following contact information to the
table before Dr. Ron Hiebert:

Name: **Steve Grube**

Title: **Missouri River Coordinator**

Area of Expertise: **Agencies' liaison to landowners within Missouri
National Recreational River**

Address: **88090 Spur 26-E**

**Ponca, NE 68770**

Phone: **402-755-4113**

Email: **steve.grube@ne.usda.gov**

Referred by: **Rebecca Latka, U.S. Army Corps of Engineers**

Appendix F, page F-6 -- add the following to the technical contact
information for Greg Pavelka:

Area of Expertise: Glyphosate-based herbicide on sandbar islands in
Missouri River**, technical contact for interior least tern and piping
plover nest location data within the Missouri National Recreational
River**

Appendix F, page F-6 -- add the following contact information will be
added to the table following Dr. Danny Walker:

Name: **Dr. Robert G. Wilson**

Title: **Professor and Extension Weed Specialist**

Area of Expertise: **Life cycles, seed germination, biology,
carbohydrate physiology, and competitiveness of economically troublesome
weeds found in western Nebraska.**

Address: **4502 Avenue I**

> **Panhandle Research and Extension Center, Department of Agronomy
> and**
>
> **Horticulture**

**University of Nebraska**

**Scottsbluff, Nebraska 69361-4939**

Phone: **(308) 632-1263**

Email: [**rwilson1@unl.edu**](mailto:rwilson1@unl.edu)

Referred by: **- -**

Appendix K, page K-1, add the following information after entry for
Tern, Black:

Species Name: **Dace, Northern redbelly (*Phoxinus eos*)**

General Habitat: **Beaver ponds, bogs, and clear streams**

#### RESPONSES TO COMMENTS

Public comments were carefully reviewed for substantive comments.
Substantive comments are those that challenge the accuracy of the
analysis; dispute information accuracy; suggest viable alternatives; or
provide new information that makes a change in the proposal. Of the
public comments received on the environmental assessment, the following
comments have been determined to be substantive. A response to the
comment follows.

**Commenter 1**

**Comment 1-1:** Crook County still has concerns about the "exotic
plants" definition and would like to see the definition and criteria
made more clear and concise. We are reassured somewhat by the language
on Page 1-6, and the statement on that page: "Only exotic plants that
meet the above NPS definition and criteria will be managed under the
EPMP/EA." However, the list of criteria presented includes
hard-to-quantify characteristics (i.e. "Disrupts the accurate
presentation of a cultural landscape..."). We highly recommend that,
prior to planning treatment of exotic plants, other than those on the
local and state noxious weed lists, Park resource managers consult with
local county weed and pest boards to make sure that control efforts are
complementary to local efforts as well as supported by local entities
and private landowners.

**Response to Comment 1-1:** Under the preferred alternative, the NPS
will solicit input from exotic plant management experts, coordinate
exotic plant management efforts with other land management agencies, and
solicit input from the general public and neighboring landowners.

However, each park must also comply with NPS policies. The NPS has a
mandate to preserve natural and cultural resources now and for future
generations. NPS Management Policies (2001) further states, "(e)xotic
species will not be allowed to displace native species if displacement
can be prevented." To comply with NPS policy, some parks may take
actions independent of those conducted by surrounding land management
agencies or neighboring landowners to prevent the displacement of native
species and to protect resources within the park unit boundaries for
future generations.

**Comment 1-2:** Crook County applauds the plan's utilization of an
integrated pest management approach. We think that a vital part of
making this effort a success is close coordination with local county
weed and pest agencies, local county commissions, the USDA Forest
Service, the Bureau of Land Management, state agencies involved with
land and resource management, and any other entities in the vicinity of
the Parks that are involved with area resource management efforts. Such
coordination and cooperation should also include research and monitoring
efforts. To our knowledge, there was no active collaboration for the
EPMP/EA between the Forest Service Research Station at Rapid City and
the NPS, even though we understand that various noxious weed studies
have been conducted on Theodore Roosevelt National Park by the Research
Station over the past decade or so. Drawing on existing knowledge and
resources in the region is of paramount importance to this effort. We
strongly encourage the NPS to participate in such coordination and
collaboration.

**Response to Comment 1-2:** Page 2-22 states, **"**Ongoing
collaboration with exotic plant management experts both within and
outside the NPS will also be conducted on a regular basis. This level of
collaboration is needed to help NPS resource managers keep informed on
the latest exotic plant management technologies available. Such
collaboration will also be an opportunity for individuals to share and
learn from their exotic plant management successes and challenges. A
list of technical expert contacts for exotic plant management
collaboration is provided in Appendix F."

Appendix F will be updated to add contact information for technical
experts from the Rocky Mountain Research Station Center for Great Plains
Ecosystem Research at Rapid City. Dr. Jack Butler of the Rocky Mountain
Research Station has been conducting research on the dynamics of exotic
plants at Theodore Roosevelt National Park since the 1980s. The
relationship the parks have with the research station is a valuable
asset for the Northern Great Plains parks. An example of benefits of
this relationship is information provided in *Leafy Spurge Effects on
Patterns of Plant Species Richness* (Butler and Cogan 2004). This
document provides insight into the impacts of leafy spurge on native
species at both the local and regional levels. The document also
provides useful information related to restoration efforts following
control of leafy spurge.

**Commenter 2**

**Comment 2-1:** The NPS\'s process for coordinating site-specific
annual efforts for exotic plant control within the MNRR \[Missouri
National Recreational River\] among the partnering agencies is alluded
to, but not clearly defined in the EA. Such coordination is important to
not only inform other managing agencies of annual exotic plant control
actions, but also to allow for opportunities to consolidate efforts
within a given reach or area. For instance, the Corps\' annual efforts
to control sandbar vegetation may potentially overlap with some of the
NPS\'s annual efforts to control exotic vegetation within the MNRR. We
think annual coordination needs to go beyond the existing weed boards in
order to encompass team members from our agency and other agencies that
are involved in other vegetation-based efforts within the reach. We use
many of the same chemicals and protocols for our vegetation control so a
consolidated effort may be feasible.

**Response to Comment 2-1:** Comment noted. The NPS is committed to
coordinating with the U.S. Army Corps of Engineers, county weed
supervisors, and private landowners for all exotic plant management
activities. This plan acknowledges the importance of partnering
agreements between Missouri National Recreational River and partnering
agencies. Page 1-5 states, "Parks would cooperate with state, county,
private, tribal, and federal officials, and would be necessary in parks
with management partnerships such as Niobrara National Scenic River and
Missouri National Recreational River. Page 2-13 further discusses the
importance of these relationships, "In some cases, extensive
collaboration is necessary in parks with management partnerships such as
Niobrara National Scenic River and Missouri National Recreational River.
Much of the land included within these parks is privately owned, so
exotic plant management requires extensive coordination among the NPS,
county weed supervisors, and private landowners." This text will be
revised to identify the U.S. Army Corps of Engineers as one of the
entities with whom extensive coordination will be conducted.

**Comment 2-2** Additionally, coordination should also include the newly
established Missouri River Coordinator, Steve Grube, who also serves as
the agencies\' liaison to the landowners within the MNRR. Since the MNRR
is a \"private lands park,\" all actions on private lands can only be
implemented through the cooperation of willing landowners. Mr. Grube
could be very useful in informing landowners of exotic weed issues and
possible methods of control.

**Response to Comment 2-2:** Comment noted. Contact information for Mr.
Steve Grube will be added to Appendix F of the plan to facilitate future
coordination and collaboration between agencies, including Missouri
National Recreational River, and private landowners.

**Comment 2-3:** It sounds as though an annual report will be prepared
on exotic plant control efforts, based on monitoring done. Does this
monitoring include the success of the treatment used on the targeted
species? For monitoring within the MNRR, we would recommend coordinating
with the Corps\' ongoing database that is being developed by the USGS.
Together we would be able to develop a good scientific database for
effective plant control to meet the management goals of both agencies.

**Response to Comment 2-3:** Comment noted. Monitoring will be used, as
part of adaptive management, to evaluate the success of the treatment on
the targeted exotic plant species. The NPS is committed to sharing data
among cooperators to foster collaboration and to increase the potential
success of exotic plant management programs.

**Comment 2-4:** The 1/4-mile buffer around active tern and plover nests
is the same as the Corps uses for construction actions. The Corps
monitors tern and plover nests annually within the MNRR, so can provide
MNRR staff with locational information as needed. The point of contact
for nest locations is Greg Pavelka (402) 667-2581.

**Response to Comment 2-4:** Comment noted. Contact information for Mr.
Greg Pavelka is included in Appendix F of the plan. The description of
his area of expertise will be expanded to identify him as the technical
contact for interior least tern and piping plover nest location data
within the Missouri National Recreational River.

**Commenter 3**

**Comment 3-1:** I full-heartedly support the project. I could not read
the entire document, but I did see you are prioritizing which weeds to
control. As you stated, the program must be long-term \... how can
adequate funding be assured each fiscal year?

**Response to Comment 3-1:** The 13 parks included in this plan already
allocate funds for management of exotic plants, and will continue to do
so in the future. Page 4-33 states, "Funding for its \[IPM\]
implementation would come from a continuation of existing funding used
for exotic plant management. There would likely be a negligible increase
in administrative support for personnel and procurement as well as
increased storage space needs and fuel use. However, parks already
provide these services and can absorb the small increases associated
with continuing existing exotic plant management programs."

To effectively manage exotic plant species, the NPS's Biological
Resources Management Division (BRMD) also established the Exotic Plant
Management Teams (EPMT) in 2000. EPMTs are part of the long-term control
of invasive species set by the Natural Resource Challenge. They also
satisfy agencies' needs to implement Executive Order 13112 on invasive
species, which includes the Invasive Species Council National Management
Plan. The Northern Great Plains Exotic Plant Management Team was funded
and consists of two permanent positions located at Theodore Roosevelt
National Park. The team hires a field season crew each year at Wind Cave
National Park, Badlands National Park, and Theodore Roosevelt National
Park to conduct invasive species control in 14 National Parks in the
Northern Great Plains (the EPMT also provides services to Badlands
National Park).

In addition, there are a number of funding sources available for
park-specific projects that protect, restore, or maintain natural
resources. Parks can apply for funding during the Service-wide
Comprehensive Call for projects that is issued each year.

**Commenter 4**

**Comment 4-1:** Starting in 2001 or 2002 the park \[Devils Tower\]
began an aggressive campaign with chemicals (primarily Plateau) to
control Leafy Spurge. They treated large acreages (map attached from
2002) with Plateau and possibly other chemicals. They treated under the
canopy of Oak, Ash, Cottonwood, Chokecherry, Plum and other deciduous
species as well as treating large open grassy areas. The results were
and are an environmental disaster that is ongoing to this day. There are
large areas of trees and brush that are dead and dying. (Many are ash,
cottonwood and oak that are 50+years old. The results were immediately
visible and are worsening year by year.

Subsequent years have not been much better. They have not gone back and
given a look at past results. What is happening is an environmental
disaster. There are acres and acres of dead trees and bare ground where
native grasses once stood.

Today 3-4 years after initial treatment many of the areas of bare ground
are coming back to such undesirable species as: Canada Thistle, Leafy
Spurge, Prickly Pear Cactus, Houndstongue, Milkweed and other nonnative
species.

Most of the species they have killed will not be back in my lifetime or
my children's for that matter.

The loss of any species that takes decades to grow is absolutely
unacceptable.

Even with their best efforts eradication will not be possible. Should
they continue to use present practices, over time they will lose large
parts of their native species. They already have a good start on this.

Plateau is a very rate sensitive chemical. Applied at as little as 20%
above rates can cause bareground and undesired results. They are doing
much of the work with backpacks and their rates obviously DO NOT fall
within label requirements. Anyone other than the government would have
been in severe trouble for this kind of work.

**Response to Comment 4-1:** In 2002, leafy spurge infestations at
Devils Tower National Monument were treated using Plateau at a rate of
10 ounces of product/acre + 32 ounces of Methylated Seed Oil (MSO)/acre.
Many areas (specifically the campground area) consisted of leafy spurge
with an understory of cheatgrass. Plateau is a herbicide that is used to
treat both species through a fall application (as indicated on the
label). In subsequent years, those areas were re-visited and retreated
to treat missed and regrowth areas of leafy spurge and/or cheatgrass.
The park reduced the application rate of Plateau beginning in 2003.
Acceptable efficacy was observed at lower rates for areas treated at
Theodore Roosevelt National Park in 2002. The Plant Science Department
at North Dakota State University also recommended using reduced rates.
ATV's were calibrated to apply 6 ounces of product/acre of Plateau + 32
ounces/acre of MSO. Backpacks were calibrated to apply 8 ounces of
product/acre + 32 ounces/acre of MSO. Park staff follows label
requirements for each herbicide used.

Treated areas mostly contained both leafy spurge and cheatgrass prior to
treatment. Following treatment, these areas contained little standing
plant biomass. Precipitation levels well below the 30-year average
during 2001-2004 also compounded recovery of these locations. The
relatively low rainfall levels during this period led to little natural
regeneration of native species in those areas. However, with adequate
rainfall in 2005, the areas are now recovering after being dominated by
leafy spurge and cheatgrass for many years. Natural regeneration is now
occurring with native and some exotic species. The park will control
exotic species in these areas as necessary to aid the recovery of native
plant species. The campground area now includes native species such as:
needle and thread (*Stipa comata*), green needlegrass (*Stipa
viridula*), prairie sandreed (*Calamovilfa longifolia*), western
wheatgrass (*Agropyron smithii*), prairie coneflower (*Ratibida
columnifera*) as well as other wildflowers and other grasses. This is an
example of many areas within the park where chemical treatment of exotic
plant infestations has resulted in the successful reestablishment of
native species. Given the variability between treated areas (each area
has different soil seedbanks and other factors), the reestablishment of
desirable native plant species is occurring at different rates
throughout the monument.

Chemicals were also used at "Tarpot Draw" to treat leafy spurge from
2002-2004. Today, leafy spurge is an incidental species within the draw.
However, species such as Canada thistle and houndstongue occur in
isolated patches within the draw. The park is actively controlling both
of these species to prevent their expansion. Leafy spurge now has high
biological control populations (*Aphthona lacertosa* and *Aphthona
nigriscutis*) in these areas. Therefore, the extent of leafy spurge
infestation in this draw is anticipated to be reduced in the near
future. Several native grasses and wildflowers are now present within
Tarpot Draw and adjacent native upland plant species that were not
present 5 years ago are now becoming reestablished.

Within the park, every precaution is taken by park personnel to minimize
the potential impact herbicides may have on non-target species. Before
any herbicide is used in the park, herbicide labels and scientific
literature is reviewed. In addition, the Regional Integrated Pest
Management (IPM) Coordinator reviews all proposed herbicide treatments.
Once a herbicide has been approved by the Regional IPM Coordinator, all
crew members attend training to ensure proper use of herbicides and
other training applicable to the position. The following is a partial
list of training that is provided by the NPS or other entities: standard
operating procedures, safety, training, licenses and qualifications,
personal protective equipment, ATV use, herbicide application, job
hazard analysis, herbicide handling and emergency response plan, labels
and Material Safety Data Sheets (MSDS), data management, activities log,
biocontrol release datasheet, description of biocontrol release
datasheet, herbicide application record, description of herbicide
application record, use of GPS units, plant identification, and
calibration (ATVs, backpacks, and truck mounted sprayers).

Tree mortality has been observed by park personnel within Devils Tower
National Monument in both treated and untreated areas. Tree mortality
has also been observed outside of park boundaries. Drought conditions
over the past 5 years have stressed certain tree species and have
promoted insect damage on chokecherry trees. At the present time, it is
difficult to assign tree mortality to any single factor other than the
drought, although it may be a combination of factors.

According to the Plateau herbicide label, "Plateau herbicide may be used
at rates up to 12 ounces per acre for weed control in and around
established trees on pasture, rangeland (see "GUIDELINES FOR RANGELAND
USE" section) and noncropland areas such as roadsides, prairies and
similar areas used for wildlife cover, erosion control, wind breaks,
etc". Page 12 and 13 of the Plateau label reports tree species that have
tolerance to Plateau directed below foliage and to foliage. All of the
herbicide applications at Devils Tower National Monument have been
directed below tree foliage. Many of the tree species listed as having
tolerance to Plateau (as indicated on the label) occur at the monument,
including: spruce species, green ash, choke cherry, cottonwood, juniper
species, and oak species. According to Dr. Jennifer Vollmer of BASF
Corporation, Plateau herbicide binds tightly to the top 10 inches of
soil and is mostly concentrated in the top 2 inches of soil, which is
out of reach of most tree roots. Also, the major absorption pathway is
foliar, which makes it unlikely that Plateau will impact trees when
areas beneath their foliage are treated (Vollmer 2005).

Lym and Christianson (2002) reported that Plateau can be used to treat
leafy spurge under certain tree species. In this study, Plateau did not
injure elm, oak, walnut, or cedar species at the 3 ounces/acre
application rate. The authors also concluded that both juniper and Black
Hills spruce were injured by Plateau. Although Plateau caused some
yellowing of the new growth, it had no long-term effect on growth.

Lym and Markle (2001) concluded "Fall-applied imazapic \[the active
ingredient in Plateau\] should become a useful tool for leafy spurge
management, as 140 grams/hectare plus MSO provided long-term leafy
spurge control similar to or better than the present standard of
picloram plus 2,4-D at 560 plus 1,120 grams/hectare. Also compared to
picloram, imazapic can be used near trees, is less likely to contaminate
groundwater, and is not a restricted use herbicide. Imazapic may reduce
herbage production temporarily; however, the grass species in this study
recovered by mid-summer."

**Comment 4-2:** The NPS schedules its crews for a set time each year.
Last year the NPS crew contacted my wife, Rosanne Driskill about
spraying an area next to the ranch that day. At the time the wind was
gusting in the 20 mph plus range. She told them no. They were quite put
out and commented that they would go to another area of the park to
spray. There was no area that could be sprayed that day without going
off label.

If you are to continue to bring in a team for a set time, then it is
imperative that they follow label instructions and do not spray when
conditions are wrong, just because they are short on time. Continued use
of Plateau when rates can not be accurately applied, should be stopped
immediately. I am surprised that Tordon is not considered at all in
areas where it can be applied according to its label (away from water
and away from deciduous species), as it is much more rate tolerant and
does not cause the bareground problem in open areas.

**Response to Comment 4-2:** Park staff always follows label
requirements for each herbicide used. Detailed records of spray
location, and weather (including, temperature, relative humidity, wind
speed and direction) are recorded every two hours.

Tordon is not applied at Devils Tower National Monument in open areas
away from water and trees due to its detrimental effect to species
richness and lower level of control when compared to Plateau (Master et
al. 1998). Also, most priority treatment areas lie either in the
floodplain or under trees where concerns about surface and groundwater
contamination and impacts to trees precludes its use.

While picloram (the active ingredient of Tordon) is often used to
control leafy spurge, scientific literature has reported it may not be
the most effective herbicide. "Picloram and 2,4-D are the most commonly
recommended herbicides to control leafy spurge. Picloram at 2.2
kilograms/hectare can provide good leafy spurge control for up to 36
months (Lym and Messersmith 1985). The high cost and restrictions in the
maximum amount of picloram that can be applied to a given area limits
the use of this treatment to small patches of leafy spurge. For large
infestations, 2,4-D plus picloram at 1,120 plus 280 grams/hectare or
2,4-D alone at 2,240 grams/hectare is commonly recommended. However,
these treatments provide only short-term leafy spurge control. Another
drawback of picloram and 2,4-D is the adverse effect these herbicides
have on desirable broadleaf species growing in leafy spurge
infestations."

Other studies have found that when compared to picloram (Tordon) and 2,
4-D, imazapic was observed to be most effective in treating leafy
spurge. "In 1995, leafy spurge control was greatest (90%) with AC
263,222 \[imazapic\] at 280 grams/hectare compared with all other
treatments\... AC 263,222 at 140 g/ha provided better control of leafy
spurge than picloram plus 2,4-D. Leafy spurge density was lowest where
AC 263,222 was applied at 280 g/ha compared with areas treated with AC
263,222 at 140 g/ha or picloram plus 2,4-D" (Masters et al. 1996). "In
1996, after two consecutive years of herbicide application, AC 263,222
at 140 or 280 g/ha provided at least 89% leafy spurge control compared
with only 34% control with picloram plus 2,4-D\... Leafy spurge density
was greatly reduced following two consecutive years of application of AC
263,222 at 140 grams/hectare. In contrast, density on picloram plus
2,4-D-treated plots was the same as areas that were not treated with
herbicide and greater than the density on areas treated with either rate
of AC 263,222. Leafy spurge biomass was less where AC 263,222 was
applied than where picloram plus 2,4-D was applied" (Masters et al.
1996). "Annual applications of 2,4-D combined with low rates of picloram
(0.28 to 0.56 kg ae ha-1 \[kilograms acid equivalent per hectare\]) are
commonly recommended for leafy spurge management (Lym and Messersmith
1990). Benefits of this treatment include increased forage yield (Lym
and Messersmith, 1985, Lym and Messersmith, 1987) and reduced leafy
spurge seed production; however, these herbicides suppress desirable
forbs and do not provide long-term control".

**Comment 4-3:** This is not an opinion-ANYONE can view the large
amounts of trees and brush dying along with large bareground areas
throughout the riparian area of the park \[Devils Tower\]. Areas all
around the administration area (highly visible from the highway), as
well as a large number of acres on the back of the campground have large
¼ acre+ to 2+ acre bareground areas. They are large enough to be visible
clearly from the air. To continue as the plan prescribes is criminal. It
took mother nature decades to create the environment that led Devils
Tower to become America's first national monument. It has taken less
than 5 yeas to do irreversible damage to the park.

If past history repeats itself, as I suspicion, the people responsible
for this environmental disaster will be safely in another park in
another area by the time most of the general public realizes what has
happened.

I encourage anyone to tour the park with a copy of the 2002 Chemical
Treatment of Plants in hand (as well as subsequent years and not be
shocked by the environmental destruction. Almost 100% of the areas
treated have some amount of bareground.

Please take a close look at the park and reconsider your plans to
continue this wreck.

**Response to Comment 4-3:** The areas mentioned above contained
monoculture stands of leafy spurge and cheatgrass. After treatment,
there was little standing plant biomass. Recovery of these locations
were slowed further by precipitation levels well below the 30 year
average. The relatively low rainfall levels from 2001-2004 led to little
natural regeneration of native species in those areas. However, with
adequate 2005 rainfall, the areas are now recovering after being
dominated by leafy spurge and cheatgrass for many years. Natural
regeneration is now occurring with native and some exotic species. The
park will control exotic species in these areas as necessary to aid the
recovery of native plant species. The campground area now dominated with
native species such as: needle and thread, green needlegrass, prairie
sandreed, western wheatgrass, prairie coneflower, and *Penstemon* spp.
as well as other wildflowers and other grasses. The use of Plateau has
helped these native species become reestablished in areas previously
infested by leafy spurge and cheatgrass. This is one of many areas like
this in the park that has resulted in the successful recruitment of
native species after herbicide treatment. Given that each location is
different depending on the soil seedbank, the establishment of desirable
native plant community species is occurring at different rates
throughout the monument.

**Commenter 5**

**Comment 5-1:** The Northern Great Plains Exotic Plant Management Plan
and Environmental Assessment lacks input from weed scientists located in
the states of Wyoming, Nebraska, North Dakota, and South Dakota. State
Universities located in each state have supported weed scientists who
have spent many years studying the life cycles and control of most of
the exotic plants listed in the document. It is deplorable that more of
this expertise was not utilized in the development of these plans.

**Response to Comment 5-1:** As previously stated in Response to Comment
#2, consultation and coordination with weed experts in the states of
Nebraska, North Dakota, South Dakota, and Wyoming is an inherent part of
this plan. Resource specialists at each park as well as the Northern
Great Plains Integrated Pest Management team currently consult with a
variety of experts at local, state, and federal agencies to stay abreast
of the latest exotic plant management techniques. Such consultation will
continue and will be expanded under the preferred alternative.

Contact information for a number of technical contacts is included in
Appendix F of the document. Contact information for Dr. Robert Wilson,
professor at the University of Nebraska Lincoln, will be added to
Appendix F as an exotic plant management expert.

**Comment 5-2:** The document provides little if any information on the
effectiveness of proposed treatments. An example would be the use of
*Ceutorhynchus litura* for Canada thistle suppression. Published data by
Hein and Wilson (2004, Weed Science 52:628-633) indicates that *C.
litura* does not provide satisfactory Canada thistle control.

**Response to Comment 5-2:** Analyzing the potential efficacy of each
treatment method *that may be implemented* at each park is outside of
the scope of this plan. Page 2-4 states, "The scope of this EPMP/EA is
to develop a long-term management plan that would reduce the impacts of
(or threats from) exotic plants to native plant communities and other
natural and cultural resources, including cultural landscapes, at 13
park units located in the NGP. Because this project involves multiple
parks, the approach is to develop a general plan that provides resource
managers with multiple treatment options for exotic plant management.
Resource managers can select the most appropriate treatment option or
combination of treatments included in the EPMP/EA to minimize potential
impacts and maximize overall management success."

As mentioned under the Response to Comment #11, resource specialists
will consult with weed management experts to initially identify
potential treatment methods. The preferred alternative also includes an
adaptive management program that will be implemented at each park to
evaluate the effectiveness of various treatments. Page 2-27 outlines how
adaptive management will be used under this plan, "Treated areas are
then monitored to determine whether management objectives established
during the initial planning stages were met. If management objectives
were met, the resource manager documents the results of monitoring. The
resource manager should, however, continue to consider other treatment
options as they become available to identify other alternatives that
might have even lower impacts. If management objectives are not met, the
selected treatment may be modified, or alternative treatments may be
considered through adaptive management." Adaptive management is a system
of management practices based on clearly identified outcomes; monitoring
to determine if management actions are meeting outcomes; and if not,
facilitating management changes that will best ensure that outcomes are
met or by reevaluating outcomes. Adaptive management recognizes that
knowledge about natural resource systems is sometimes uncertain and is
the preferred method of management in these cases.

**Comment 5-3:** The document suggests that a number of techniques are
going to be utilized to suppress exotic weeds but provides little
information on the expected results of these plans. After ten years of
implementation, what can we expect from these plans? A decrease in
infestation? No change? Or an increase in exotic weed populations?

**Response to Comment 5-3:** See Response to Comment #12.

**Comment 5-4:** The document should spend more time talking about life
cycles of exotic weeds and how this information can be helpful in
planning control programs instead of talking about noise pollution from
aircraft. How do aircraft taking off from a nearby airport influence
exotic plant management?

**Response to Comment 5-4:** Considering the life cycles of exotic weed
species is a crucial element of this plan. Page 1-4 and Page 2-19 state
that each exotic plant's natural history will be evaluated before
developing management strategies. Each exotic plant species' life cycle
will directly affect the type and timing of treatment methods that are
most effective for that species in a specific environment. Under the
preferred alternative, resource specialists at each park will consult
with experts from local, state, and federal agencies and universities to
identify the most appropriate treatment method or methods for that plant
species. Additional text will be added to Page 2-27 to more clearly
describe how exotic plant species life cycles will be considered in
selecting treatment methods.

The process that resource specialists will follow in selecting treatment
methods is further discussed on Page 2-27: "the resource manager
identifies a proposed treatment option that is feasible given potential
costs, available resources, potential impacts and effectiveness, and
applicable regulations and policies. The next step is to consider
whether there are any other treatment options, treatment agents, or
application methods available that will result in lower impacts when
compared to the proposed treatment option given potential costs,
available resources, impacts, and effectiveness. If there are no other
feasible options available, the resource manager selects the proposed
treatment. However, if the resource manager identifies an alternative
treatment that has lower impacts and that is feasible, the alternative
treatment option is selected."

While "aircraft taking off from a nearby airport" does not directly
influence exotic plant management, it does constitute a temporary impact
to the natural soundscapes within parks. NPS Management Policies (2001)
state, "The Service will restore degraded soundscapes to the natural
condition wherever possible, and will protect natural soundscapes from
degradation due to noise (undesirable human-caused sound)." Since NSP
management policy requires protection of soundscapes from degradation,
potential impacts to soundscapes from various activities, including
operation of aircraft, was analyzed in this document.