DRAFT

Environmental Assessment

Submerged Aquatic Plant Management 

of Banks Lake 

Banks Lake NWR 

Lakeland, GA

Lanier County, Georgia 

United States Department of the Interior 

U.S. Fish and Wildlife Service 

Okefenokee National Wildlife Refuge 

Folkston, GA 

September 2007 
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 TABLE OF CONTENTS 

1.0 PURPOSE AND NEED FOR ACTION................................................................................4 

1.1 INTRODUCTION.....................................................................................................................4 

1.1.1 Banks Lake National Wildlife Refuge ......................................................................4 

1.1.2 Legal Context.............................................................................................................7 

1.2 NEED FOR ACTION ...............................................................................................................7 

1.3 PURPOSE OF ACTION........................................................................................................10 

1.4 PROJECT PLANNING ..........................................................................................................10 

1.4.1 Introduction..............................................................................................................10 

1.4.2 Public Involvement Process.....................................................................................10 

1.5 SCOPING THE ISSUES ........................................................................................................11 

1.5.1 Introduction..............................................................................................................11 

1.5.2 Issues and Concerns Identified.................................................................................11 

2.0 ALTERNATIVES.................................................................................................................12 

2.1 INTRODUCTION...................................................................................................................12 

2.2 ALTERNATIVE A: ..............................................................................................................12 

2.3 ALTERNATIVE B: ................................................................................................................12 

2.4 ALTERNATIVE C: ..............................................................................................................13 

2.5 ALTERNATIVE D: ..............................................................................................................13 

2.6 ALTERNATIVE E: ..............................................................................................................13 

3.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT ..............................................13 

3.1 INTRODUCTION...................................................................................................................13 

3.2 OVERVIEW OF THE GRAND BAY – BANKS LAKE ECOSYSTEM..............................13 

3.2.1 Geographic Description ...........................................................................................13 

3.2.2 Topography and Geology.........................................................................................14 

3.2.3 Soils .........................................................................................................................14 
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3.2.4 Climate.....................................................................................................................14 

3.2.5 Human Population ...................................................................................................14 

3.3 RESOURCES OF THE STUDY AREA ................................................................................15 

3.3.1 Hydrology ..............................................................................................................15 

3.3.2 Water Quality.........................................................................................................15 

3.3.3 Vegetation .............................................................................................................15 

3.3.4 Fire and Forestry ....................................................................................................16 

3.3.5 Fisheries ................................................................................................................16 

3.3.6 Wildlife .................................................................................................................16 

3.3.7 Threatened and Endangered Species......................................................................16 

3.3.8 Archeological/Historical Resources.......................................................................16 

3.3.9 Public Use and Recreation .....................................................................................17 

3.3.10 Local Economy ......................................................................................................17 

4.0 ENVIRONMENTAL CONSEQUENCES .........................................................................17 

4.1 INTRODUCTION...................................................................................................................17 

4.2 ALTERNATIVE A: NO ACTION ........................................................................................17 

4.3 ALTERNATIVE B: DRAWDOWN ....................................................................................18 

4.4 ALTERNATIVE C: CHEMICAL .......................................................................................19 

4.5 ALTERNATIVE D: MECHANICAL ..................................................................................19 

4.6 ALTERNATIVE E: BIOLOGICAL ...................................................................................20 

4.7 SUMMARY............................................................................................................................20 

5.0 CONSULTATION AND COORDINATION....................................................................21 

5.1 INTRODUCTION..................................................................................................................21 

5.2 MEETINGS, CONTACTS, PRESENTATIONS ...................................................................21 

5.3 LIST OF PREPARERS...........................................................................................................21 

REFERENCES.............................................................................................................................22 
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1.0 PURPOSE AND NEED FOR ACTION 

1.1. INTRODUCTION 

This Environmental Assessment is an analysis of five alternatives developed to address the 

management of the submerged aquatic plants of Banks Lake on Banks Lake National Wildlife 

Refuge, located in Lanier County, Georgia. This section includes a brief background description 

of the refuge mission and objectives, a summary of the legal context within which management 

options must be developed, a discussion of the need and purpose of aquatic plant management 

within Banks Lake, and a description of the planning process used to determine the appropriate 

management strategies. Lastly, the identification of issues and concerns expressed by the public, 

refuge staff, and other agencies with regard to future management and use of Banks Lake is 

summarized and major impact topics are identified and defined. 

1.1.1. Banks Lake National Wildlife Refuge 

Banks Lake National Wildlife Refuge (3,559 acres) is located in Lanier County near Lakeland, 

GA. The refuge contains a variety of habitat types including 1,459 acres of cypress swamp, 

1,000 acres of marsh and 900 acres of open water. Scattered through these habitat types are 

hardwood swamp, pine forest and other upland areas. The refuge was established for the 

protection and conservation of a unique environment as well as migratory and resident wildlife. 

On April 16, 1980, the U.S. Fish and Wildlife Service entered into a lease agreement with The 

Nature Conservancy to manage 3,559 acres of the Banks Lake/Grand Bay Wetlands complex, 

located in Lanier and Lowndes Counties in southeastern Georgia. The original intent of the lease 

was to establish a National Wildlife Refuge. Changes in the emphasis of the land acquisition 

program resulted in a lack of funds necessary to acquire the land. The area remained in a state of 

limbo during 1982 and 1983 with the Service maintaining a caretaker position over Banks Lake. 

In 1984, funds were added to the FY 1985 budget for the purchase at a value of $356,000. The 

refuge designation was authorized under the Fish and Wildlife Act of 1956 and funded through 

provisions of the Land and Water Conservation Fund Act of 1955 with strong local support from 

the Lakeland community and the congressional delegation. The area became Banks Lake 

National Wildlife Refuge (Banks Lake NWR) on February 22, 1985. 

The U.S. Fish and Wildlife Service is the primary federal agency responsible for the 

conservation, protection, and enhancement of the Nation’s fish and wildlife populations and their 

habitats. Although the USFWS shares some conservation responsibilities with other federal, 

state, tribal, local, and private entities, it has specific trustee obligations for migratory birds, 

threatened and endangered species, anadromous fish, and certain marine mammals. In addition, 

the USFWS administers a national network of lands and waters for the management and 

protection of these resources. 
Draft 

 Figure 1. Location of Banks Lake National Wildlife Refuge. 
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As part of its mission, the USFWS manages more than 540 national wildlife refuges covering a 

total of more than 95 million acres. These areas comprise the National Wildlife Refuge System, 

the world’s largest collection of lands and waters specifically managed for fish and wildlife. The 

System supports over 800 bird species, 220 mammal species, 250 reptile and amphibian species, 

1,000 fish species, and countless species of invertebrates and plants. 

The mission of the Refuge System, as defined by the National Wildlife Refuge System 

Improvement Act of 1997 is: 

...to administer a national network of lands and waters for the conservation, 

management, and where appropriate, restoration of the fish, wildlife and plant 

resources and their habitats within the United States for the benefit of present and 

future generations of Americans. 

The following goals for Banks Lake NWR have been developed by the USFWS and are 

intended to address the National Wildlife Refuge System Improvement Act of 1997 and 

FWS/BASS cooperative agreement. 

GOAL 1: Increase quality (trophy) fishing opportunities at Banks Lake National Wildlife 

Refuge. 

Objective 1.1: Improve public facilities to promote increased visitation. 

Objective 1.2: Promote private sector participation. 

GOAL 2: Enhance aquatic habitat at Banks Lake National Wildlife Refuge. 

 

 Objective 2.1: Improve water level manipulation in relation to fish, wading 

 birds, and vegetation. 

 Objective 2.2: Work towards improving water quality problems associated 

with septic tanks and/or stormwater. 

 Objective 2.3: Control invasive plant expansion. 

GOAL 3: Increase the quality of the fishery. 

 Objective 3.1: Monitor the fish assemblage. 

 Objective 3.2: Conduct water level drawdowns as needed to manage 

 vegetation. 

 Objective 3.3: Conduct angler need assessments. 

 Objective 3.4: Maintain law enforcement to control wildlife violations. 
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1.1.2 Legal Context 

The management of the aquatic vegetation at Banks Lake NWR must be accomplished within various 

legal and regulatory guidelines. Foremost among these legal guidelines is the National Wildlife Refuge 

Improvement Act and the establishing purposes of the refuge which provide an overall framework for 

the way in which Banks Lake NWR must be managed. 

1.2 NEED FOR ACTION 

It is known that moderate amounts (< 30%) of aquatic vegetation cover provides structure and 

food resources for fishes; and, excessive amounts (>40%) of aquatic vegetation cover can change 

prey assemblages, reduce growth rates, alter foraging behavior, shift population size-structure, 

and reduce relative condition of fish (Savino and Stein 1982; Bonvechio and Bonvechio 2006). 

Currently, 75% of Banks Lake is covered with aquatic vegetation. The submerged vegetation is 

primarily fanwort (Cabomba sp.) with some bladderwort (Utricularia sp). Emergent vegetation 

includes lemon bacopa (Bacopa caroliniana), dollar bonnet (Brasenia schreberi), fragrant water 

lily (Nymphaea odorata), banana-lily (Nymphoides aquatica), and spatterdock (Nuphar luteum). 

Water hyacinth (Eichhornia crassipes) is also present in floating mats. 

Previous drawdowns were accomplished in 1987, 1994, and 2001 (Table 1). These drawdowns 

resulted in improved fish habitat, improved fish size structure and relative condition, and 

increased fishing opportunities for 2-3 years (Table 2). 

Table 1. Previous drawdowns. 

Start of Drawdown Lowest Water Level 

Date Water Level Date Water Level 

November 2, 1987 189.00 ft msl December 4, 1987 181.74 ft msl 

October 18, 1994 190.66 ft msl January 11, 1995 183.70 ft msl 

October 1, 2001 191.40 ft msl December 2, 2001 Level unknown 

(100 acres 

remained) 

As of December 2006, the relative condition of largemouth bass collected from Banks Lake was 

below average. An electrofishing survey is conducted each year that water levels permit. Upon 

examining the data for Banks Lake, Herrington et al. (2005) found that the bluegill population 

appeared stunted and was characterized by low relative weights and proportional stock densities, 

while the largemouth bass population had low weights and medium to high proportional stock 

densities throughout the sample period. These conditions are characteristic of systems with 
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excessive vegetation. Comparing two transects that were most representative of one hour of 

pedal time, Georgia DNR found the following: 

FWS fish collection data for 2005 versus 2006 at sites 4 and 5: 

a) decrease in largemouth bass at site 5 

b) decrease in bluegill, black crappie, and warmouth (4 and 5) 

c) no flier or redfin pickerel collected in 2006 (sites 4 and 5). 

d) Florida gar collected at both sites in 2006 – none in 2005 

e) the percent of sportfish collected in 2006 at both sites made up 

 38-47% of the total catch (non-sportfish dominated collection) 

f) the percent of sportfish collected in 2005 at both sites made up 

 53-72% of the total catch. 
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Table 2. Electrofishing summary for Banks Lake. (CPUE=Catch per Unit Effort) 

Species June 

1992 

Oct 

1994 

Nov 

1995 

Nov 

1996 

Dec 

1997 

Nov 

1999 

AugSept 

2001 

Nov 

2001 

Feb 

2002 

Ap

200

Chain 

Pickerel 

3.14 2.43 6.5 7.71 7.67 11.14 8.57 

Bluegill 28.14 57.0 170.25 57.57 18.33 38.43 12.0 

Largemouth 

Bass 

15.29 30.71 35.25 18.71 15.33 15.0 13.57 

Lake 

Chubsucker 

8.43 9.29 50.5 0.43 3.67 51.14 8.86 

Gar 7.29 3.86 10.75 5.57 1.0 7.86 2.86 

Warmouth 2.43 2.0 9.75 4.86 4.67 7.71 2.57 

Golden 

Shiner 

6.14 65.86 1.5 0.71 1.17 5.14 2.86 

Black 

Crappie 

0 0 21.75 0.57 1.83 1.57 0 

Bowfin 0.71 2.14 27 3.29 1.83 4.71 0.43 

Drawdown 

New Water control Structure 

421,000 bluegill fingerlings released 

30,000 largemouth bass fingerlings released 
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1.3 PURPOSE OF ACTION 

The purpose of this action is to determine the most appropriate technique for managing the 

aquatic vegetation to enhance conditions for the fisheries and birds at Banks Lake. 

The environmental assessment is needed in order to determine and evaluate a range of reasonable 

management alternatives. The environmental assessment predicts and evaluates the biological, 

physical, and socioeconomic effects of implementing each alternative. From this range of 

alternatives, the USFWS’s proposed management action is then identified. 

The Service’s purposes for taking action at this time include: 

• To ensure that the action reflects the objectives of the refuge, the provisions of the 

National Wildlife Refuge Improvement Act, and all other legeal and policy requirements 

pertaining to Banks Lake NWR, and 

• Involve and inform the public determining the most appropriate management action to be 

taken. 

1.4 PROJECT PLANNING 

1.4.1 Introduction 

Planning for this project was carried out in compliance with the provisions of the National 

Environmental Policy Act (NEPA), Public Law 91-190, 42 U.S. Code Section 4321. NEPA 

requires the preparation of environmental documents to aid in the decision-making process and 

to assist in informing and involving the public. An environmental assessment (EA) is prepared 

to evaluate alternatives and environmental consequences in order to determine if the 

environmental impacts are significant enough to warrant preparation of an Environmental Impact 

Statement or if the impacts are not significant enough for such a document and the action can be 

implemented without further documentation. 

Following the release of the draft environmental assessment, the Service will conduct a public 

meeting to gather comments on the impacts of implementing the proposed action and make a 

determination whether or not an Environmental Impact Statement should be prepared or the 

proposed action should be implemented without additional documentation. 

1.4.2 Public Involvement Process 

In developing the EA, the Service held a public scoping meeting in Lakeland, GA, on June 26, 

2007. 

After the draft EA is released, there will be a 30-day public comment period and a public meeting 

to gather comments on the proposed action. In association with this, public outreach has been 

initiated to address questions and concerns and will continue through the monitoring and action 

phases. 
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1.5 SCOPING THE ISSUES 

1.5.1 Introduction 

The issues, concerns and general comments of the public along with technical issues were 

identified by refuge staff internally and through the public scoping meeting described above. All 

issues and concerns raised during scoping were reviewed and used to develop alternatives to 

address the need and purpose described above. 

1.5.2 Issues and Concerns Identified 

The following issues and concerns identified during internal and public scoping are addressed in 

this Environmental Assessment: 

• What is the minimum water level to prevent fish kills and accomplish goals? 

• Does the lake have to be drawdown as much as in the past to be effective? 

• Consider impacts to Lake Erma and downstream residences. 

• What is the length of time necessary to accomplish drawdown? 

• Is the cold weather necessary for desired vegetation kill? 

• If freezing temperatures do not occur, can chemical spraying of the vegetation occur? 

• What are the trigger points to indicate need for a drawdown? 

• What are the recreation opportunities during drawdowns? 

• Are there any concerns with the water hyacinth and the drawdown? 

The following issues and concerns identified during internal and public scoping have been 

addressed through the planning process but are not addressed specifically in this document: 

• Create a list of contacts that are affected by the drawdown. 

• Develop an outreach plan. 

• Develop water control structure protection and other protocols to prevent manipulation by 

the public. 

• Coordinate with members of Grand Bay/Banks Lake Council so they can prepare to 

accomplish habitat management activities during the drawdown. 

• Prepare for additional boundary marking. 

• Prepare for potential fire hazards. 

• Modify structure if needed. 

• Maintain wood duck boxes during drawdown if feasible. 

• Monitor vegetation before and after. 

• Determine if water level monitoring is adequate using staff gage readings once a day. Is a 

staff gage necessary in Lake Erma? 

• Determine the need for water quality monitoring. 

• Prepare to write a summary report of the drawdown. 
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2.0 ALTERNATIVES 

2.1. INTRODUCTION 

This section describes five alternatives developed after assessing the purpose and need for action 

and the issues and concerns raised by the public. 

The alternatives are: 

Alternative A. No Action (No manipulation) 

Alternative B. Lower the water level and allow the currently submerged vegetation to become 

stressed and then raise the water to normal levels. (Drawdown or Water Manipulation) 

Alternative C. Use herbicides to kill the aquatic plants (Chemical) 

Alternative D. Mechanically Remove Vegetation (Mechanical) 

Alternative E. Introduce Grass Carp to reduce aquatic plants (Biological) 

2.2. Alternative A. No Action (No manipulation) 

Under this alternative, the water level at full pool would be maintained to the best ability of the 

refuge staff considering weather conditions. Aquatic vegetation would not be managed. Access 

and mobility by boat would continue to be difficult reducing the opportunities for public fishing. 

 

2.3. Alternative B. Lower the water level and allow the currently submerged vegetation to 

become stressed and then raise the water to normal levels. (Drawdown or Water 

Manipulation) 

Water levels within Banks Lake would be lowered beginning in mid-October and would continue 

to be lowered until approximately 30% of the lake remains covered with water to maintain the 

fisheries. The lake level at this point would be approximately 183 ft amsl. It is estimated that 

the lowest level would be reached by mid-November to early December depending on the 

weather. It is hoped that temperatures would be sufficiently cold (freezing) for 2-3 weeks during 

December and January to kill the exposed aquatic vegetation or stress it before the gate within 

the water control structure is closed to capture the rainfall and bring up the water level in 

February. A gradual drawdown is necessary, where no more than 56 cubic feet/second (cfs) of 

water is released. This will prevent downstream flooding. At full pool with a nine foot head, a 

discharge of 56 cfs will occur with the water control gate opened approximately seven inches. 
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2.4. Alternative C. Use herbicides to kill the aquatic plants. (Chemical) 

A herbicide, such as Aquathol K, Hydrothol 191, Reward, or Sonar, would be placed in the water 

in an attempt to kill the aquatic vegetation. Several treatments may be required. 

2.5. Alternative D. Mechanically Remove Vegetation (Mechanical) 

Specialized equipment would be brought in to rake and/or seine the vegetation and dispose of it 

off site. 

2.6. Alternative E. Introduce grass carp to reduce the aquatic vegetation. (Biological) 

This alternative requires the introduction of the exotic grass carp that attacks nuisance aquatic 

plants. 

3.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT

3.1 INTRODUCTION 

Banks Lake is the northern most Carolina Bay of the Grand Bay-Banks Lake Ecosystem. It 

consists of approximately 900 acres of open water. Average water depth is five feet. A water 

control structure is located near the refuge entrance where overflow waters drain into a tributary 

of the Alaphaha River. Water is acidic and has low total alkalinity and hardness. Largemouth 

bass and bluegill are the predominant fish species sought. Over 20,000 anglers visit the refuge 

each year. Several bass fishing tournaments are also held annually. The ecosystem also provides 

important habitat for a wide diversity of wildlife including great egrets, cormorants, anhingas, 

pied-billed grebes, white ibis, great blue herons, wood ducks, over wintering sandhill cranes and 

wood storks. 

3.2 OVERVIEW OF THE GRAND BAY – BANKS LAKE ECOSYSTEM 

3.2.1 Geographic Description 

Banks Lake National Wildlife Refuge comprises a portion of the second-largest freshwater 

wetland system in Georgia known as Grand Bay-Banks Lake area (McGee and Black. 2003). It 

lies at the westernmost edge of the South Atlantic Coastal Plain ecoregion within the Suwannee 

River Basin. It is also within the Tifton Upland district of the East Gulf Coastal Plain Section of 

Georgia. 

The refuge is within Lanier County, one mile west of Lakeland, Georgia, on Highway #122 and 

encompasses 3,559 acres. It protects one of three largest Carolina Bays within the ecosystem. 
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3.2.2 Topography and Geology 

Banks Lake is a classic Carolina Bay with a sandy rim and an oval shape that is oriented from 

northwest to southeast. Because of the dam on the northwest side, the sandy rim has been 

inundated and a ring of pond cypress has become established. The south lobe of Banks Lake is 

known as Old Field Bay and thought to be one large sink. 

Elevation in the area is approximately 61m asl. The dominant landforms of the area include 

Carolina Bays, limesinks, creek swamps, open water shallow lakes, ponds, flatwoods, and an 

elevated hammock. 

3.2.3 Soils 

Banks Lake is situated on the Lakeland Series (USDA SCS 1973) that consists of excessively 

drained soils over thick beds of sand. The lake bed is lined with clayey sand. On top of this lays 

silty sand and a high humus layer. The submerged deposits are of Pleistocene age. 

The soils in the area are low in fertility and organic matter and strongly acidic. The permeability 

is considered rapid. 

3.2.4 Climate 

Summers within Lanier County are hot and humid. Temperatures may exceed 90o

 frequently and 

dip to 70o at night. Winters are mild. Temperatures may drop to freezing or below on about 30 

days in an average winter. These cold spells are generally short in duration between more mild 

weather. The freeze-free growing season is normally between mid-March to mid-November. 

Average rainfall for the area is 48 inches. The wettest month is July while the driest month is 

generally November. 

 

3.2.5 Human Population 

Valdosta and Lakeland are the largest cities in the area with populations of 43,724 and 2,730 

(2000 census). It is estimated that over the next 10 years, agricultural and silvicultural practices 

will decline by 26% and urban areas will increase by over 110%. 

There are numerous homes and vacation cabins along the northern edge of the lake. These 

residents have built docks that extend out into Banks Lake. 
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3.3 RESOURCES OF THE STUDY AREA 

3.3.1. Hydrology 

Originally in the landscape were the five natural bays as listed below and numerous smaller bays 

and lime sink depressions: 

 Milltown Bay 

 Banks Lake 

 Old Field Bay 

 Moody Bay 

 Grand Bay 

As settlers moved into the area, water levels within all the above bays were managed. In 1825, a 

dam was built on the northeastern edge of Banks Lake to create a mill pond. The dam was raised 

in 1848 to elevate the water level in the pond. Sixty percent of the water in Banks Lake is runoff 

from Grand Bay Creek. It also receives runoff from Milltown Bay, Gator Run, Lee Pond, and 

Berryhill Pond. Today, one water control structure is located near the refuge entrance where 

overflow waters drain into a tributary of the Alapaha River, passing through Lake Irma. 

As early as 1921, the lake was drained causing the dam at Lake Irma to fail. The dam at Banks 

Lake was rebuilt in 1926. According to local residents, since the water control structure was 

installed around 1940, the lake has been drained on a regular basis every eight to ten years to 

improve fishing. The dewatering would begin in early November and be completed in six weeks, 

after which rough fish would be removed using seines. From their accounts, the fishing would 

be greatly improved the spring following the drawdown. In 1941, Moody Bay was divided by 

Air Force crash trails into Moody Bay and Rat Bay. Other bays were created by impounding 

portions of the system. 

3.3.2. Water Quality 

Although the waters of Banks Lake are considered low in fertility and productivity, they appear 

to be adequate to sustain a warm water sport fish. Total alkalinity (50mg/l) and hardness (12 

mg/l) are at the lower range as compared to more productive lakes at 125-400 mg/l. 

 

3.3.3 Vegetation 

The refuge contains 3,559 acres of open water, marshes, hardwood swamps, flatwoods, 

hammocks, and creek swamps. The majority of wetland consists of pond cypress and swamp 

shrub around open water with an average depth of five feet. Approximately 13% of the lake is 

classified as a deep cypress pond, while 59% is shallow cypress pond and shrub swamp (Banks 

Lake Sport Fishing Plan, 1980). The Wetland Classification of the area is as follows: system – 

lacustrine; subsystems – limnetic, littoral; Classes – unconsolidated bottom, aquatic bed, 
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emergent wetland. Pond cypress and bald cypress-black gum are the dominant tree species along 

the margins of the Carolina Bays. Water lily, water shield, fanwort, and floating heart are found 

in open water areas. 

3.3.4 Fire and Forestry 

The Grand Bay/Banks Lake region is in the highest frequency band of the southern U.S.. 

Lightning caused the majority of the fires every 1-3 years. Within the area, the upland longleaf 

pine habitat and the creeks created fire corridors (Frost and Langley 2006). Grand Bay is 

considered the most fire-exposed of the wetlands. Being shallow, it experienced the highest fire 

frequency. Banks Lake had some protection from Grand Bay Creek when fires moved north 

through the area. 

3.3.5 Fisheries 

The fisheries within Banks Lake are electrofished by Georgia Department of Natural Resources 

and USFWS Panama City Fisheries Assistance Office every other year depending on water 

levels. The catch per unit effort for these surveys are summarized in Table 2 and discussed in 

Section 1.2. Need for Action. 

 

3.3.6 Wildlife 

Observation of wading birds and sandhill cranes are common in the Grand Bay-Banks Lake area. 

 They utilize shallow wetlands of the area along with the agricultural fields. The wood duck is a 

common species in the area. The refuge and GA DNR provides wood duck boxes for these birds. 

The bachman’s sparrow (Aimophila aestivalis), gopher tortoise (Gopherus polyphemus), and 

round-tailed muskrat (Neofiber alleni) are found in the Grand Bay – Banks Lake area as well and 

are globally rare. 

3.3.7 Threatened and Endangered Species 

Wood storks, Florida sandhill cranes, and bald eagles have been observed on the refuge. Wood 

storks use the shallow pools associated with Old Field Bay for foraging. The Florida sandhill 

crane was introduced to the area by Georgia DNR. They forage in Old Field Bay. Bald eagles 

have nested on Banks Lake and thus, obtain fish from the lake. 

3.3.8. Archeological/Historical Resources 

Activity around the lake’s dam has been documented as follows (TAI 1994). The site of Joshua 

Lee’s mill was located on the existing dam in 1825. The mill burned in 1848 and was quickly 

rebuilt with a sawmill added by William Lastinger. Around 1926, E.D. Rivers acquired the land 

and built a lodge on the site known as Banks Lake Tavern. This lodge burned in 1935. The 

Civilian Conservation Corps (CCC) then established a camp on the site until 1939. In 1937, 

Rivers built a house nearby. Following this, Highway 122 was re-routed to its current path in 

1940. 
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3.3.9 Public Use and Recreation 

The only public access to the refuge is at the entrance on Highway #122 west of Lakeland. Access to the 

refuge is primarily by boat and fishing is the most popular activity. Over 20,000 anglers visit the refuge 

each year. Several bass fishing tournaments are also held annually. Largemouth bass and bluegill are the 

predominant fish species sought. Other common fish species include chain pickerel, lake chubsucker, gar, 

warmouth, crappie, and bowfin. 

Facilities at Banks Lake NWR include a concession operation with restrooms, canoe and kayak rentals, 

boat ramp, short walking trail, boardwalk and platform, and accessible fishing dock. 

3.3.10 Local Economy 

Currently, agriculture (west side), forestry (east side) and an urban center (south side) 

characterize land use of the area (TNC, 2003). Moody AFB, Grand Bay WMA, and Banks Lake 

NWR comprise about 6,100 ha of publicly owned land. It is estimated that over the next 10 

years, agricultural and silvicultural practices will decline by 26% and urban areas will increase by 

over 110%. 

A concession is currently operating at the refuge’s entrance providing rental canoes/kayaks, bait 

and tackle, and snacks. Numerous other bait and tackle vendors in Lakeland supply fishermen 

with supplies. 

4.0 ENVIRONMENTAL CONSEQUENCES 

4.1 INTRODUCTION 

This section addresses the environmental consequences that can reasonably be expected to result 

from implementation of each of the alternatives. 

4.2 ALTERNATIVE A: NO ACTION

Under this alternative, the Service would take no action to manage submerged aquatic vegetation 

within the boundaries of Banks Lake. This would include the submerged fanwort. 

The result will be increasing amounts of submerged and emergent vegetation within the lake bed. 

Dissolved oxygen will be decreased and less available for the fisheries. At extreme low levels of 

dissolved oxygen during summer months, the fisheries could experience a die-off. Light 

penetration will be reduced causing less productivity and less food for the fisheries and other 

wildlife. Movement of fish and other wildlife is also limiting with increased vegetation. It has 

been shown that increased vegetation results in stunted growth, low weight and low proportional 

stock densities (Herrington et al, 2005). It is desirable to have less than 30% aquatic vegetation 

cover to benefit the fisheries. 
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In addition to having lower productivity of food resources, wading birds would have less success 

in capturing prey items with thicker growths of vegetation. 

Public access would be significantly impacted due to increased vegetation limiting movement 

throughout the lake. A thick bed of submerged vegetation also makes it difficult to fish. As word 

spread on the condition of the lake and the difficulty of travel and fishing, visitation will be 

reduced. This would lead to fewer sales of fishing tackle in the local area and the possible 

closing of the concession at Banks Lake NWR. 

4.3 ALTERNATIVE B: Lower the water level and allow the currently submerged vegetation to 

become stressed and then raise the water to normal levels. (Drawdown or Water Manipulation) 

It is widely considered that drawing down water levels to control aquatic vegetation is the most 

effective method and the most inexpensive if the mechanisms are in place to use this method 

(DES 2007). Not only does the water need to be lowered, freezing or desiccation is required. No 

machinery or chemicals are needed for this alternative. This method is standard for submergent 

vegetation while not as effective on water hyacinth. 

Banks Lake has a water control structure that is capable of drawing down the water level and 

passing the excess water to Lake Irma and on towards the Alapaha River. Planning is necessary 

to ensure Lake Irma can handle the outflows from Banks Lake. It is also necessary to maintain 

adequate water for the fisheries within Banks Lake so they can re-populate the lake once the 

water is allowed to rise. It has been proven by past drawdowns that in a normal precipitation 

year, enough rainfall and runoff is obtained to fill the lake after January to reach full pool by 

April or May. 

Due to additional water control structures and dikes within the other bays, the drawdown will not 

effect the water level at Moody Bay and Grand Bay unless desired. It will have an impact on Old 

Field Bay and Milltown Bay; however, it is believed that Old Field Bay retains water and fish to 

replenish Banks Lake once water levels return to normal. 

Water quality during the drawdown may be characterized by lower levels of oxygen as fish 

become more concentrated in the remaining pools of water. This has the potential of leading to a 

fish kill. As water returns, more nutrients are expected within the water column from the dead 

plant material that will be covered with water. Under these conditions, low oxygen levels could 

exist if algal blooms occur during the reflooding process. 

Although there can be expected a reduction in diversity and abundance of benthic invertebrates 

that may effect fish and wading bird populations temporarily, they will rebound rapidly with the 

release of nutrients within the system. Therefore, a drawdown creates a reduced density of 

submerged plants facilitating movement of fish, greater opportunities to catch prey by fish and 

birds, and improve the food resources for a number of wildlife species. Over a longer period, 

these improvements will increase growth rates, the relative condition of the fish, and shift 

population size-structure. 
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Along with the reduction of submerged vegetation that fowls motors and makes movement by 

the public difficult, the fisheries will be improved, increasing the catch rate. A more satisfying 

visit to the refuge will encourage return trips. The increase in visitors directly effects the 

concessionaire and local businesses. 

A drawdown also allows other management that is water level dependent to occur. This may be 

an opportunity to accomplish needed prescribed burns in areas normally covered with water. The 

refuge does not plan to conduct any prescribed burns on refuge lands during this time; however, 

partners within the area may decide to take advantage of the lower water levels. 

 

4.4 ALTERNATIVE C: Use herbicides to kill the aquatic plants (Chemical) 

Herbicides are effective in controlling aquatic plants if selected based on the target plant and 

used at the most vulnerable time of the plants’ life cycle. Herbicides are used primarily during the 

growing season when the chemical can be taken up through its leaves. Herbicides with endothall 

or fluridone are most effective on the submerged fanwort (Aquaplant 2007). Contact herbicides 

act quickly and kill all plants cells. Rodeo is currently being used on water hyacinth. 

The killing of large amounts of vegetation within the water column may cause water quality 

issues as the vegetation decomposes and reduces the dissolved oxygen. The chemicals may 

accumulate within the tissues of fish and other wildlife and cause long-term effects. 

With the use of chemicals, there is always the human health and environmental safety aspect that 

needs to be considered. During herbicide treatments, the water levels would remain high enough 

to provide access; however, there are restrictions or waiting periods before the water can be used 

for certain purposes (Ohio State University 2007). Aquathol K, Hydrothol 191, Reward, and 

Sonar all have water use restrictions and waiting periods related to irrigation uses. Aquathol K 

and Hydrothol 191 both have a waiting period of 3 days for fish consumption. Although a 

waiting period exists, this length of time would be less than the necessary time to accomplish a 

drawdown. This would have less impact on local tackle shops and restaurants. 

The use of herbicides is generally very expensive, especially within a lake the size of Banks 

Lake. It is used when other methods are not possible. The USFWS is concerned with herbicide 

use around water bodies and thus requires a strict review of the chemical and its effects on the 

system. 

4.5 ALTERNATIVE D: Mechanical Control 

Mechanical methods include seining and/or raking aquatic vegetation. This method requires 

special equipment to be used and thus very expensive, especially on a lake the size of Banks 

Lake. It is considered not appropriate for fanwort because fanwort can re-establish from any 

remaining roots or stem fragments (Mackey 1996). 
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4.6 ALTERNATIVE E: Biological Control 

This method generally involves the introduction of an exotic species or living agent such as fish, 

insect, or bacteria which is harmful to and attacks the nuisance aquatic plants. Grass carp are 

often introduced to a pond for plant control. They are an effective control of fanwort but results 

generally are not seen for about a year. Sterile fish are used to prevent expansion of the 

population. Initially, the introduction of the carp is expensive. There are indications within the 

literature that the negative impacts from introducing grass carp include the alteration of the 

pond’s food web, the vegetation structure, and invertebrate populations. This could have long 

term consequences on the natural system and native fauna. 

Generally, the introduction of exotic species would be in direct conflict of the legal context for 

which the refuge was established, as well as, establish policy. 

4.7 SUMMARY 

The preferred alternative is Alternative B. Lower the water level and allow the currently 

submerged vegetation to become stressed and then raise the water to normal levels. (Drawdown 

or Water Manipulation). The literature indicates that when this method is possible within a pond 

or a lake, it is the most effective and economical method to accomplish aquatic vegetation 

control. The amount of submerged vegetation cover (>70%) within Banks Lake indicates that 

control measures are needed. Past drawdowns have improved fish conditions and habitat in 

addition to improving public use opportunities. It is also speculated from observations of 

increased bird use, that the improved conditions have increased foraging opportunities for 

wading birds and other wildlife. 

Water will be released gradually to prevent downstream flooding and considering the capability 

of Lake Irma to pass water through to the river. To prevent excessive lowering of the water level 

in Banks Lake, a minimum of six boards will remain in the water control structure which will 

hold the water level at approximately 183 ft amsl. 

The effectiveness of a drawdown does depend on whether the plants can be stressed further by 

freezing and desiccation. This is dependent on weather conditions. Spraying a herbicide on the 

plants while they are exposed would not be effective due to the process in which plants take in 

the chemical. Chemicals are most effective on vigorously growing plants. Therefore, the refuge 

would not use chemicals at this time during the drawdown. 

Public access will be allowed on the refuge as limited by water levels throughout the drawdown. 

Fishing will be allowed to continue as normal until November 1, 2007 – March 31, 2008 when 

catch and release for game fish – largemouth bass, bluegill, crappie, and warmouth – will be 

initiated to preserve the fisheries for recovery after the drawdown. Other fish may be taken. 
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5.0 CONSULTATION AND COORDINATION

5.1 INTRODUCTION 

This section summarizes the consultation and coordination that occurred in the processes of 

identifying the issues, alternatives, and preferred alternative for this EA. 

5.2 MEETINGS, CONTACTS, PRESENTATIONS 

November 1, 2006 - Letter from Bert Deener, GA DNR-Fisheries Regional Supervisor, 

discussing current Banks Lake conditions 

January 16, 2007 – Meeting with refuge staff, GA DNR, USFWS Panama City Fisheries 

Assistance Office, and Banks Lake concessionaires 

June 26, 2007 – Public Scoping Meeting in Lakeland, GA 

September 25, 2007 – Public Meeting to hear comments on Environmental Assessment 

5.3 LIST OF PREPARERS 

Sara B. Aicher, Wildlife Biologist, Okefenokee National Wildlife Refuge, Folkston, GA 

prepared this document for review. 
Draft 22

REFERENCES

Aquaplant. 2007. Management Options: Fanwort (Cabomba). Texas Cooperative Extension. 

Dept. of Wildlife and Fisheries Sciences. 

http://aquaplant.tamu.edu/database/submerged_plants/fanwort_mgmt.htm. 

Bonvehio, K.I. and T.F. Bonvechio. 2006. Relationship between habitat and sport fish 

populations over a 20-year period at West Lake Tohopekaliga, Florida. North Amer. Journ. Fish. 

Mgmt. 26:124-133. 

Department of Environmental Science, New Hampshire. 2007. Lake drawdown for weed 

control. http://www.des.state.nh.us/factsheets. 

Frost, C.C. and S.K. Langley. 2006. Presettlement vegetation and natural fire regimes of the 

Grand Bay/Banks Lake Natural Area. Report prepared for The Nature Conservancy and the 

Grand Bay/Banks Lake Council. 

Herrington, S.J., K.J. Herrington, H.B. Herod, and D. Harrison. 2005. Fishery dynamics of 

macrophyte-dominated Banks Lake National Wildlife Refuge, Georgia. Proc. Annu. Conf. 

Southeast. Assoc. Fish and Wildl. Agencies: 59:292-302. 

McGee, A. and K. Black. 2003. Grand Bay-Banks Lake Stewardship Partnership – Phase I Final 

Report: The Grand Bay-Banks Lake Ecosystem Site Conservation Plan. 

Mackay, A.P. 1996. Cabomba (Cabomba sp.) in Queensland. Pest Status Review. Land 

Protection Branch, Department of Natural Resources, Brisbane. 

Moody Air Force Base. 2001. Integrated Natural Resource Management Plan, Moody Air Force 

Base, Georgia. Plan period 30 September 2001 – 30 September 2006. 344 pp. 

Nico, L. G., P. L. Fuller, and P. J. Schofield. 2007. Ctenopharyngodon idella. USGS 

Nonindigenous Aquatic Species Database, Gainesville, FL. 

<http://nas.er.usgs.gov/queries/FactSheet.asp?speciesID=514> Revision Date: 4/11/2006 

Ohio State University. 2007. Chemical control of aquatic weeds fact sheet. 

http://ohioline.osu.edu/a-fact/0004.html. 

Savino, J.F. and R.A. Stein. 1982. Predator-prey interaction between largemouth bass and 

bluegills as influenced by simulated, submersed vegetation. Trans. Amer. Fish. Soc. Vol. 

111/3:255-266. 

TIA Environmental Sciences Inc. 1994. Banks Lake boundary and lake height study. Final 

Report for USFWS, Real Estate Division, Atlanta, GA