`

United States 

Department of 

Agriculture

Marketing and 

Regulatory Programs

Animal and Plant 

Health Inspection 

Service

Asian Longhorned Beetle Program 

in Charleston, Dorchester and 

Colleton Counties, South Carolina

Draft Environmental Assessment - August 2020

Agency Contact:

Paul Chaloux

National Policy Manager

Plant Protection and Quarantine-Plant Health Programs

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

4700 River Road

Riverdale, MD 20737
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Table of Contents

I. Introduction ............................................................................................................................. 2

A. Background............................................................................................................. 2

B. Purpose and Need ................................................................................................... 4

C. Outreach.................................................................................................................. 5

II. Alternatives.............................................................................................................................. 6

A. No Action Alternative............................................................................................. 6

B. Preferred Alternative............................................................................................... 7

III. Potential Environmental Consequences .................................................................................. 9

A. No Action Alternative............................................................................................. 9

1. Physical Environment .................................................................................... 12

2. Biological Resources...................................................................................... 14

3. Human Health and Safety .............................................................................. 17

4. Socioeconomic ............................................................................................... 17

5. Environmental Justice .................................................................................... 18

6. Tribal Consultation and Coordination............................................................ 18

7. Historic and Cultural Resources..................................................................... 18

B. Preferred Alternative............................................................................................. 19

1. Physical Environment .................................................................................... 19

2. Biological Resources...................................................................................... 21

3. Human Health and Safety .............................................................................. 24

4. Socioeconomic ............................................................................................... 25

5. Environmental Justice .................................................................................... 25

6. Tribal Consultation and Coordination............................................................ 26

7. Historic and Cultural Resources..................................................................... 26

C. Uncertainty and Potential Cumulative Impacts .................................................... 26

IV. Listing of Agencies Consulted .............................................................................................. 29

V. References ............................................................................................................................. 30

Appendix 1. Forest type covers for Charleston, Colleton, and Dorchester Counties, SC............ 33

Appendix 2. ALB infestations near forested wetlands ................................................................. 36
2

Asian Longhorned Beetle Program in Charleston, Dorchester and 

Colleton Counties, South Carolina Draft Environmental Assessment -

August 2020

I. Introduction

A. Background

The U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service 

(APHIS), in cooperation with the South Carolina’s Clemson University Department of Plant 

Industry (DPI), is considering actions to eradicate the invasive Asian longhorned beetle (ALB) 

(Anoplophora glabripennis (Motchulsky) (Coleoptera: Cerambycidae)). On May 29, 2020, a 

homeowner in Hollywood (Charleston County), South Carolina contacted DPI to report a suspect 

ALB. On that same day, DPI tentatively identified the insect as ALB. On June 4, USDA APHIS’ 

National Identification Services confirmed the specimen as ALB.

As of August 15, 2020, USDA APHIS has detected ALB in 1,641 trees out of 4,827 trees 

inspected in Charleston County (Figure 2). USDA APHIS continues to conduct delimiting 

surveys to determine the extent of the infestation.

To date, in the United States there have been ALB outbreaks in five states including Illinois, 

Massachusetts, New Jersey, New York, and Ohio. USDA APHIS, in collaboration with its state 

partners, eradicated ALB from Illinois and New Jersey as well as parts of Ohio, Massachusetts,

and New York (USDA APHIS 2020). ALB eradication programs are ongoing in areas of

Massachusetts, New York, and Ohio. 

The ALB is a large, shiny black beetle with white markings on the 

body and antennae (Figure 1). Adult females lay eggs on the bark 

of host trees. Within two weeks, the eggs hatch and the small 

white larvae feed on the vascular tissue of the tree and eventually 

bore into the tree. The larvae form tunnels (or galleries) in the 

trunk and branches. ALB pupates inside the tree and adults 

emerge by chewing their way out of the tree, forming 

characteristic round exit holes approximately 3/8 inch in diameter. 

The damage from larvae burrowing into the tree and adults 

burrowing out of the tree cuts off nutrient flow and weaken the 

tree. The tree will eventually die if the infestation is severe 

enough. Sawdust-like or thin wood shaving debris and insect 

waste (called frass) from the insect’s burrowing activity may be found at the base of infested 

trees. Infested trees are also prone to secondary attack by disease and other insects. In most 

Figure 1. Adult Asian 

longhorned beetle.
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locations, ALB produces one generation per year; however, in other countries where the pest is 

established, the number of annual generations varies with climate and latitude.

Figure 2. Current known ALB infested area in South Carolina as of August 15, 2020.
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B. Purpose and Need

USDA APHIS has the responsibility to take actions that exclude, eradicate, and control plant 

pests under the Plant Protection Act of 2000 (7 United States Code (U.S.C.) 7701 et seq.). The 

purpose of the ALB program is to work cooperatively with the DPI to detect and eradicate ALB. 

Due to the potential effects of ALB to several species of hardwood trees, USDA APHIS and the 

DPI need to be able to detect and eradicate ALB to prevent further spread in South Carolina and 

spread from South Carolina into other regions of the United States. 

South Carolina established the State Crop Pest Commission and delegated the commission the 

authority under Title 46 – Agriculture, Chapter 9, to enforce regulations that “may be necessary 

to eradicate or prevent the introduction, spread, or dissemination of plant pests [...]” and set 

quarantines (South Carolina Legislature 2020). The DPI carries out the pest management 

activities.

Quarantine is part of each alternative in this environmental assessment (EA), including the no 

action alternative (described below). Federal quarantine authority for ALB includes 7 CFR § 

301.51 for eradication programs, 7 CFR § 319.40 for solid wood packing material, and 7 CFR § 

330 for plant pests. Under these regulations, USDA APHIS establishes quarantines and regulates 

international and interstate movement of regulated plant host material, also referred to as 

regulated articles. USDA APHIS cannot regulate intrastate movement without the State Plant 

Regulatory Agency first establishing an intrastate quarantine. Intrastate quarantine facilitates 

regulatory activities within a geographical area less than an entire State. USDA APHIS and State 

plant regulatory agencies establish quarantine boundaries 1.5 miles from a tree with ALB-exit 

holes, and 0.5 miles from a tree with egg sites only. Under quarantine, USDA APHIS restricts 

the movement of regulated articles, which present a risk of spreading ALB interstate from the 

quarantine area. The regulated articles listed under the quarantine 7 CFR § 301.51 (last accessed 

6/23/2020) include firewood (all hardwood species, not restricted to ALB-host trees); green 

lumber, and other living, dead, cut, or fallen material, including nursery stock, logs, stumps, 

roots, branches, and debris from ALB-host trees of 1⁄2 inch or more in diameter. There are 12 

genera of host trees that USDA APHIS regulates for ALB and are considered at-risk hosts: Acer 

(maple and box elder), Aesculus (horse chestnut and buckeye), Albizia (mimosa), Betula (birch), 

Cercidiphyllum (katsura tree), Fraxinus (ash), Koelreuteria (golden raintree), Platanus 

(sycamore and London planetree), Populus (poplar), Salix (willow), Sorbus (mountain ash), and 

Ulmus (elm) (7 CFR § 301.51–2, last accessed 6/23/2020). The Program has found ALB egg 

sites and two larval entrance/exit holes on one Nyssa biflora (swamp tupelo) tree in Charleston 

County. Nyssa spp. are not confirmed hosts for ALB. The Program is conducting research on this 

find and will continue to monitor Nyssa spp. for ALB activity.
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This EA considers ALB detection and eradication efforts in Charleston, Dorchester, and Colleton

counties in South Carolina wherever ALB is detected. Currently, ALB is not known to occur in 

Dorchester and Colleton counties, but the USDA APHIS includes these counties in this EA due 

to their proximity to Charleston County and on its experience with ALB outbreaks elsewhere in 

the United States.

This EA was prepared consistent with the National Environmental Policy Act of 1969 (NEPA) 

and the USDA APHIS NEPA implementing procedures (7 Code of Federal Regulations (CFR) 

part 372) for the purpose of evaluating how the proposed action, if implemented, may affect the 

quality of the human environment. 

In September 2015, the USDA APHIS published a programmatic environmental impact 

statement (EIS) for the ALB eradication program (USDA APHIS 2015, 

https://www.regulations.gov/docket?D=APHIS-2013-0003). The programmatic EIS considers 

the impacts eradication efforts have on nontarget species, human health, and the environment. 

This EA tiers to that programmatic EIS. USDA APHIS posts site-specific environmental 

assessments for the ALB eradication program on the USDA APHIS ALB webpage at 

https://www.aphis.usda.gov/aphis/ourfocus/planthealth/plant-pest-and-disease-programs/pestsand-diseases/asian-longhorned-beetle. 

C. Outreach

In June 2020, USDA APHIS contacted residents in the outbreak area by going door-to-door in 

person and by email sent through homeowner association email distribution lists informing them 

of the infestation and the surveys, tree inspections, yard waste and tree markings. USDA APHIS 

also attended one homeowner association’s annual meeting and met with the mayor of 

Hollywood, South Carolina to discuss the ALB outbreak. 

On June 15, USDA APHIS sent a notice to stakeholders and DPI published a news release about 

the outbreak and the surveys taking place. USDA APHIS and DPI met with the Coastal 

Conservation League to discuss potential cooperative outreach efforts. USDA APHIS and DPI 

placed outreach materials in several community locations including local grocery stores, 

community centers, and town offices in Hollywood, Meggett, Ravenel, and Johns Island. USDA 

APHIS and DPI contacted higher-risk and green industry businesses in the 

Hollywood/Ravenel/Johns Island area to inform them of the ALB infestation. The businesses 

included 67 landscape/arborist companies, 15 stone/heavy equipment companies and 

campgrounds, and 8 garden centers.

USDA APHIS and DPI met with the Charleston County Park and Recreation Commission staff 

at an ALB-infested site in the Stono River County Park to show what an ALB infestation looks 
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like and to describe the ALB Program eradication methods being used in other ALB outbreaks in 

the United States. On a separate occasion, USDA APHIS, DPI, and Clemson University 

Extension met with several arborists and green industry professionals at the Stono River County 

Park and gave them a similar overview. USDA APHIS and DPI met with the SC Department of 

Agriculture staff to provide outreach and to show ALB damage in the field. Clemson University 

met with a representative from the SC Forestry Commission to provide outreach and show ALB 

damage in the field. USDA APHIS will continue to conduct outreach activities about ALB and 

the Program.

II. Alternatives

NEPA regulations (40 CFR §§ 1508.25) require the scope of analysis to include a no action 

alternative in comparison to other reasonable courses of action.

A. No Action Alternative

Under the no action alternative, USDA APHIS would not assist in the eradication of ALB in 

Charleston, Dorchester, and Colleton counties, South Carolina. Other Federal and non-federal 

government agencies and private landowners may work to eradicate ALB; however, there would

be no cooperative or coordinated efforts among USDA APHIS and other stakeholders. USDA 

APHIS could conduct surveys to determine the extent of an infestation and implement quarantine 

restrictions where ALB infestations occur.

ALB detection is by visual observation. Inspectors look for exit holes, egg-laying sites, frass, 

tunneling, and sap flow from damaged sites. Inspectors search for signs using binoculars from 

the ground and may conduct aerial tree inspections through trained professionals using bucket 

trucks to peer into trees from above, and by trained tree climbers to search for signs of an 

infestation within tree canopies.

ALB program inspectors conduct surveys to (1) determine the scope of the infestation; 

(2) establish the quarantine area; (3) determine that ALB has not spread outside of the 

established quarantine area and, if it has, to expand the quarantine area; and (4) determine when 

to release an area from quarantine. The Program’s survey areas may include residential, 

commercial, and public land; access to these properties is necessary for the Program. The 

programmatic EIS provides details of the surveys, which are summarized here. 

The Program follows two levels of survey. During the level 1 survey, inspectors visually look for 

signs of infestation on every regulated host tree and Nyssa spp. in a circular radius around the 

infestation, until they fail to find ALB within approximately a 1⁄2-mile radius of infested trees. If 

inspectors find additional infestations, APHIS extends the 1⁄2-mile radius from the outermost 
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find. The level 2 survey is a safeguard to ensure that ALB is not spreading beyond the 1⁄2-mile 

radius around infested host trees established during the level 1 survey. During the level 2 survey, 

also known as a buffer survey, inspectors survey host trees within a minimum of one mile 

beyond the survey boundary set during the level 1 survey. This results in approximately a 11⁄2-

mile radius from the point of infestation for trees with less than 100 exit holes. The Program 

expands the level 2 survey to a minimum of 2.5 miles from areas that are or were centers of high 

ALB populations, as denoted by the presence of a cluster of trees with many exit holes or one or 

more trees with >100 exit holes. The ALB program may conduct a level 3 survey, also called a 

high-risk site survey. This survey extends beyond established survey boundaries to inspect highrisk sites, as described in the programmatic EIS. To lift an area from quarantine, an area must 

return a negative survey, as described in the programmatic EIS.

B. Preferred Alternative

Under the preferred alternative, USDA APHIS proposes activities to detect and eradicate ALB

throughout Charleston, Dorchester, and Colleton Counties in South Carolina wherever it is 

found. USDA APHIS would conduct surveys as described under the no action alternative above 

and in the programmatic EIS.

In upland or dryland areas, the Program would remove and chip or incinerate infested trees to 

destroy ALB that may be within those trees, thus eliminating potential adult beetle emergence, 

dispersal, and mating. The Program chips trees in place or takes the tree to an approved facility

for chipping. The Program may also remove or treat with imidacloprid non-infested ALB highrisk host trees that are within a 1⁄2-mile radius of infested trees. High-risk host trees are those that 

belong to the 12 genera of trees that are preferred hosts of ALB and that the USDA APHIS 

regulates. The Program may include Nyssa spp. on the list of high-risk host trees due its recent 

find of eggs sites and two larval holes on Nyssa biflora. Applications of imidacloprid are through 

trunk or soil injection, according to product label requirements. Soil injection of imidacloprid is 

rarely, if ever used. See the programmatic EIS for additional information on tree removal and 

treatment.

After removing trees, the Program would either grind tree stumps or apply herbicide to tree 

stumps to prevent regrowth of the tree and potential reinfestation. The Program uses the 

herbicides triclopyr or triclopyr mixed with imazapyr and metsulfuron-methyl. Herbicide 

applications are through foliar applications to sprouting foliage or painting the root collar area, 

the sides of the stump, and the cut surface. In some locations, the Program may leave stumps and 

allow regrowth, particularly in areas prone to soil erosion or sensitive wildlife habitats. The 

programmatic EIS provides additional information on tree removal and insecticide and herbicide 

applications. After removing trees, the Program restores the area through grading and planting 

groundcover consistent with the area where removals took place. This reduces the opportunity 
8

for invasive weeds to become established and provides a groundcover that will help hold soil in 

place. In woodlot settings a seedbank already exists and planting groundcover may be 

unnecessary.

Removal or imidacloprid treatments of high-risk host trees and Nyssa spp. would be conducted 

only with permission from the landowner. If the landowner does not allow removal or 

imidacloprid treatment of select high-risk host trees, the Program will continue to survey host 

trees for presence of ALB. However, if the trees become infested, the Program will remove 

them.

In wetland areas where the infested area is approximately 3 acres or less in size, the Program 

would likely remove infested and high-risk host trees, which may include Nyssa spp., and move 

the tree debris to an offsite facility for chipping or incineration. The Program imposes this size 

limitation based on its experience in eradicating ALB from small wetland areas in the 

Northeastern United States. The Program would make herbicide treatments to tree stumps and 

sprouting foliage, following the herbicide label instructions. The Program would not treat highrisk host trees with imidacloprid in wetland areas. 

In wetland areas where the infested area is 3-acres or greater in size, the Program may girdle 

infested and high-risk host trees, which may include Nyssa spp. to kill the trees. At this time, the 

Program would not remove infested and high-risk host trees (or Nyssa spp.) or treat trees with 

imidacloprid. An exception to not removing trees is when an infested tree poses a risk to the 

public. The program may use herbicides to treat the trees below the area of girdling. The 

Program would only girdle trees in areas not accessible by the public due to tree-fall safety 

hazards. The Program is researching eradication methods in large wetland environments that 

minimize impacts to non-target terrestrial and aquatic species and that are cost-effective. 

Appendix 2 provides maps of forested wetland areas near the ALB outbreak.

The proposed ALB eradication program is an adaptive management program that is based on the 

pest response guidelines for ALB (USDA APHIS 2014). The ALB program will identify areas 

and host genera for either chemical and/or removal of high-risk host trees. Subject areas will be 

identified based on levels of infestation, host tree density and distribution, potential 

environmental impacts, and financial resources. This provides the most flexibility in selecting an 

appropriate control method for a location. It is also the most cost-effective method because this 

alternative does not prescribe that all high-risk host trees must be treated or removed; rather, it 

allows flexibility in focusing treatments on the high-risk host genera most preferred by ALB 

(i.e., Acer, etc.) or certain locations that would be higher risk than others. High-risk locations 

include, but are not limited to:

• Landscape and nursery businesses

• Tree and lawn care companies
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• Firewood producers and transporters

• State and local parks/forestry departments

• Local utility and sanitation services

• Parks and campsites

• Landfills and disposal sites

• Import facilities that receive or have received high-risk cargo from known source 

countries

• Stone dealers or stone cutting facilities, such as monument/headstone companies, near 

infestations because of the use of wood packing material to ship and store the stone

III. Potential Environmental Consequences

The sections below consider the potential environmental consequences under the no action and 

preferred alternative by summarizing information associated with the physical environment, 

biological resources (including nontarget species), human health and safety, socioeconomics, 

environmental justice, Tribal consultation, and any potential historic and cultural resources. The 

no action alternative presents a description of the environmental baseline, the current situation,

for each environmental resource analyzed, followed by an analysis of the potential 

environmental impacts of the preferred alternative to those resources. The potential impacts may 

be direct, indirect, or cumulative, and of short or long duration. The impacts may also be either 

beneficial or adverse.

A. No Action Alternative

The affected environment covers the counties of Charleston, Dorchester, and Colleton in South 

Carolina. Under the no action alternative, USDA APHIS may conduct surveys and establish 

quarantines, but would not assist in the eradication of ALB. Other Federal and non-federal 

government agencies and private landowners may work to eradicate ALB; however, there will be 

no cooperative or coordinated efforts among USDA APHIS and other stakeholders. 

Quarantine will reduce human mediated spread but does not prevent the natural spread of ALB. 

Not eradicating ALB will lead to the beetle infesting additional trees and its expansion into other 

non-infested areas of the three counties under consideration, and likely other counties in the state 

and locations elsewhere in the region. Given the known global distribution of ALB, the insect is 

probably capable of surviving anywhere in the United States where suitable host plants and 

climatic conditions are favorable. Without USDA APHIS participation in eradication, ALB will

spread and infest more trees when compared to the preferred alternative. Because of this, ALB 

may impact every resource evaluated below to a greater extent than the preferred alternative due 

to the possibility of more trees becoming infested.
10

Twelve tree genera are regulated hosts for ALB: Acer (maple and box elder), Aesculus (horse 

chestnut and buckeye), Albizia (mimosa), Betula (birch), Cercidiphyllum (katsura tree), Fraxinus 

(ash), Koelreuteria (golden raintree), Platanus (sycamore and London planetree), Populus 

(poplar), Salix (willow), Sorbus (mountain ash), and Ulmus (elm). These species are not 

dominant species in these three counties; dominant species are coniferous trees with other 

hardwood trees such as oak (Quercus), yellow poplar (Lirodendron), and walnut (Juglans)

(Figure 3; Appendix 1). The Program may include N. biflora to the list of regulated hosts if it 

confirms ALB can complete its lifecycle on this tree. The Program found egg sites and two larval 

entrance/exit holes on one N. biflora tree. ALB host species may be planted as ornamental and 

urban shade trees. Green spaces in these counties encompass city and county parks, and State 

and Federally managed lands and parks. For example, Charleston County has numerous parks, 

such as the Stono River County Park and Meggett County Park. The Audubon’s Francis Beidler

Forest falls within Dorchester County.

The Francis Marion National Forest falls within Charleston County and is comprised of the 

following forest-type groups: longleaf-slash pine, loblolly-shortleaf pine (the primary forest 

type), oak-pine, oak-hickory, and oak-gum-cypress (Oswalt 2005). Although these forest-type 

groups do not include one of the 12 genera of ALB host trees, it does not mean host trees are 

absent from the Francis Marion National Forest.
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Figure 3. Forest type cover for Charleston, Colleton, and Dorchester Counties, South Carolina

(USDA FS 2008)
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1. Physical Environment

Air

Trees intercept pollutants from the air, reducing human exposure and associated risks, such as 

respiratory illnesses (Beckett et al. 1998, Bell and Treshow 2002, Donovan et al. 2013, Kim and 

Bernstein 2009, Lovasi et al. 2008, Nowak et al. 2000, Nowak et al. 2006, Tiwary et al. 2009). 

Trees, including ALB-host trees, store carbon and play a role in the reduction of carbon dioxide 

(CO2) in the atmosphere, a gas that contributes to greenhouse gas levels. 

The U.S. Environmental Protection Agency (USEPA) uses Air Quality Index (AQI) values to 

indicate overall air quality. AQI takes into account all the air pollutants measured within a 

geographic area. In 2019, Charleston County reported one day where the AQI was considered 

unhealthy for sensitive groups (USEPA 2019). In Colleton County, no days were reported as 

unhealthy. Data for 2019 was unavailable for Dorchester County. Air quality data for South 

Carolina and other States are located at https://www.epa.gov/outdoor-air-quality-data/air-qualityindex-report.

The Clean Air Act (CAA) is the primary Federal law that protects the Nation’s air quality for the 

purposes of public health and welfare. The CAA requires the USEPA to establish National 

Ambient Air Quality Standards (NAAQS) for specific pollutants. These pollutants are known as 

criteria pollutants, and they include ozone, particulate matter, carbon monoxide (CO), nitrogen 

dioxide, sulfur dioxide (SO2), and lead. The NAAQS are intended to represent the maximum 

concentration of a particular pollutant in the ambient air that will not adversely impact public 

health or welfare. Charleston, Colleton, and Dorchester Counties meet NAAQS attainment 

standards (SCDHEC 2020b, USEPA 2020).

The loss of trees to ALB reduces carbon sequestration, and the decomposition of dead trees 

release CO2 into the atmosphere. The loss of trees from ALB would cause a reduction in the 

interception of air pollutants and other air quality improvements; however, through natural 

succession or replanting with non-host trees, the air quality contributions would recover over 

time. 

Other Federal and non-federal agencies and private landowners may choose to remove infested 

trees. Although the vehicles and machinery used during tree removal contribute particulates and 

other pollutants, these are not expected to contribute a significant amount compared to other 

vehicle and machinery usage in the area. Felled trees and tree debris may be chipped or 

incinerated. Incineration of ALB host material would increase temporarily air pollution 

particulates in the vicinity.
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The no action alternative is not expected to have any long-term or permanent impacts to air 

quality standards and greenhouse emissions or CO2 sequestration in these three counties because 

ALB host trees are not dominant tree species (Figure 3; Appendix 1) and we expect some tree 

replacement with non-host species to occur. The programmatic EIS provides additional details 

on the interaction of trees and air quality and greenhouse gas emissions in the context of ALB 

infestations.

Water

The Clean Water Act, the Safe Drinking Water Act, and the Water Quality Act are the primary 

Federal laws protecting the Nation’s waters. Federal activities also must seek to avoid or mitigate 

actions that will adversely affect areas immediately adjacent to wild and scenic rivers (National 

Wild and Scenic Rivers Act of 1968, as amended (16 U.S.C. §§ 1271-1287)). The 41.9 miles of 

river in South Carolina designated as a Federal wild and scenic river do not pass through the 

three counties covered in this EA (WSR 2020).

Polluted runoff, known as nonpoint source pollution, occurs when rainfall picks up contaminants 

such as insecticides, sediment, nutrients, or bacteria on its way to lakes, rivers, wetlands, coastal 

waters, and ground water. Nonpoint source pollution occurs from activities such as fertilizing a 

lawn, road construction, pet waste, and improperly managed livestock, crop, and forest lands. 

Today, States report that nonpoint source pollution is the leading cause of water quality problems 

(USEPA 2018). In South Carolina, the primary indicators for water impairment in rivers and 

streams were pathogens, organic enrichment/oxygen depletion, impaired biota, pH, various 

metals, turbidity and other impairments (USEPA 2012). Waterbodies that are impaired and do 

not meet water quality standards are listed under 303(d) of the Clean Water Act. Charleston, 

Colleton, and Dorchester Counties report 303(d) listed waters (SCDHEC 2020a). 

The no action alternative is not expected to result in significant impacts to water quality 

standards in South Carolina. The spread of ALB would likely result in other government

agencies, as well as private landowners, making insecticide treatments for suspected ALB.

Increased pesticide use would be expected to be minor relative to other registered uses but could 

result in increased risk to water quality, in particular under misuse. Removal of trees near a water 

resource could cause sedimentation and the reduced shade cover could cause stream temperature 

changes. However, these impacts will be localized and replacement vegetation would reduce 

sedimentation.

Soil

Soil health or soil quality is the ability of soil to function as a vital ecosystem, sustaining plants, 

animals, and humans (USDA NRCS 2020b). Soil is an ecosystem that provides nutrients for 
14

plant growth, absorbs and holds rainwater, filters and buffers potential pollutants, serves as a 

foundation for agricultural activities, and provides habitat for soil microbes to flourish (USDA 

NRCS 2020b). It is important to manage soils so they are sustainable for future generations.

South Carolina has a diverse range of soil types due to variations in climate and shifting of the 

shoreline from glaciation (Cooke 1936). USDA-NRCS provides detailed information regarding 

the types of soil found in the three counties and the characteristics of the various soil orders in 

South Carolina (USDA NRCS 2020a, USDA NRCS 2020c)

USDA APHIS considers impacts from the no action alternative to soil resources as significant if 

activities result in substantially increased erosion and sedimentation or adversely affect unique 

soil conditions. Tree removal does disturb soil; equipment can compact the soil and stump 

removal can cause soil erosion. Therefore, the removal of infested trees that may occur under 

this alternative may affect soil quality; however, the effects are likely to be localized. The likely 

spread of ALB under the no action alternative would result in additional infested trees that would 

require removal especially in situations where they may pose hazards to the public.

The spread of ALB would likely result in other government agencies, as well as private 

landowners, making insecticide treatments for suspected ALB. Increased pesticide use would be 

expected to be minor relative to other registered uses but could result in increased risk to soil

quality by harming soil-inhabiting insects, in particular under misuse.

2. Biological Resources

Biological resources include plant and animal species and the habitats where they live. For this 

EA, biological resources will focus on plants, wildlife, and protected species. The plant and 

wildlife subsections include both native and non-native species. Protected species refers to bald 

and golden eagles protected under the Bald and Golden Eagle Protection Act (BGEPA), 

migratory birds protected under the Migratory Bird Treaty Act of 1918 (MBTA), as amended, 

and threatened and endangered species and their critical habitats as protected under the 

Endangered Species Act (ESA).

Vegetation

Under the no action alternative, the presence of ALB is not expected to have significant direct 

effects to aquatic plants. Although trees that are hosts to ALB grow naturally or are planted in 

Charleston, Colleton, and Dorchester County, coniferous trees and other non-host hardwood 

trees are dominant tree types (Figure 3, Appendix 1). Hosts for ALB include Acer (maple and 

box elder), Aesculus (horse chestnut and buckeye), Albizia (mimosa), Betula (birch), 

Cercidiphyllum (katsura tree), Fraxinus (ash), Koelreuteria (golden raintree), Platanus 
15

(sycamore and London planetree), Populus (poplar), Salix (willow), Sorbus (mountain ash), and 

Ulmus (elm). The Program found egg sites and two larval entrance/exit holes on N. biflora; the 

Program is researching if ALB can complete its lifecycle on this tree. Other terrestrial plant 

species are not expected to be significantly impacted by the presence of ALB. Under the no 

action alternative, we expect the beetle to expand its distribution and infest a greater number of 

trees compared to the preferred alternative. The removal of trees could affect understory 

vegetation directly through disturbance and indirectly through a reduction in shade. Insecticide 

treatments are unlikely to harm vegetation, including those plant species reliant on insect 

pollinators. It is possible other Federal and non-federal agencies and private landowners would 

use herbicides to prevent tree stumps from sprouting. Herbicide applications may harm 

vegetation nearby through runoff or drift. Label instructions and requirements will reduce the 

exposure to nearby plants.

Wildlife

The diversity of ecosystems in Charleston, Dorchester and Colleton Counties support a variety of 

aquatic and terrestrial wildlife. Freshwater and marine ecosystems are not expected to be 

impacted by the presence of ALB based on the life history requirements for ALB. Impacts to 

terrestrial wildlife will depend on whether native wildlife species depend on host trees for food 

or shelter. The death of host trees in the three counties to ALB and the removal of host trees may 

have a localized impact to wildlife. Impacts to wildlife due to tree removal and loss of host trees 

would increase as ALB expands its range within the State and other regions under the no action 

alternative. 

The use of insecticides to manage for ALB and herbicides to prevent stumps from sprouting 

could affect wildlife, depending on the product used and the way it is applied. The programmatic 

EIS summarizes toxicity information for the insecticide imidacloprid and the herbicides triclopyr 

and triclopyr mixed with imazapyr and metsulfuron-methyl based on the Program’s proposed use 

pattern. It is possible that other Federal and non-federal agencies and private landowners use 

pesticides other than the four the Program proposes to use and these will have their own toxicity 

and exposure risks. The use of pesticides would be expected to increase under the no action 

alternative since ALB would be expected to spread resulting in attempts to protect trees using 

various insecticides, or using herbicides to treat stumps and vegetation that could serve as ALB 

host material. The increased use of pesticides over larger areas as a result of ALB expansion 

would increase risk to nontarget wildlife. 

Charleston, Colleton, and Dorchester counties have several species that are categorized as state 

endangered, threatened, sensitive, or are candidates for state-listing (SCDNR 2020a). Many of 

these species are also protected under the ESA. 
16

(1) Migratory Bird Treaty Act

Federal law prohibits an individual to pursue, hunt, take, capture, kill, attempt to take, capture or 

kill, possess, offer for sale, sell, offer to purchase, purchase, deliver for shipment, ship, cause to 

be shipped, deliver for transportation, transport, cause to be transported, carry, or cause to be 

carried by any means whatever, receive for shipment, transportation or carriage, or export, at any 

time, or in any manner, any migratory bird or any part, nest, or egg of any such bird (16 U.S.C. 

§§ 703-712; 50 CFR § 21). Birds that nest or forage in ALB host trees could be impacted if the 

trees become infested with ALB and die or are removed. Other Federal and non-federal agencies,

as well as private landowners, may use insecticides to treat for ALB or remove ALB infested 

trees.

(2) Bald and Golden Eagle Protection Act

The Bald and Golden Eagle Protection Act (16 U.S.C. 668–668c) prohibits anyone, without a 

permit issued by the Secretary of the Interior, from “taking” bald eagles, including their parts, 

nests, or eggs. During their breeding season, bald eagles are sensitive to a variety of human 

activities. Bald eagles nest in Charleston, Colleton, and Dorchester counties, South Carolina

(SCDNR 2020b). South Carolina is in the non-breeding, scarce range for the golden eagle (The 

Cornell Lab 2020). There are reports of golden eagles in Charleston County (The Cornell Lab 

2020). Bald eagles and golden eagles would not be impacted by the presence of ALB due to 

habitat and dietary preferences of eagles. Although bald eagles nest in forested areas, the death 

or removal of ALB host trees would not alter the eagle’s habitat, as there are other non-host trees 

and ALB host trees are not typically used for nesting. It is possible the sounds from tree removal 

would disturb the eagles, but this disturbance would be of short duration.

(3) Endangered Species Act

Section 7 of the ESA and ESA’s implementing regulations require Federal agencies to ensure 

that their actions are not likely to jeopardize the continued existence of federally listed threatened 

and endangered (T&E) species, or result in the destruction or adverse modification of critical 

habitat. The following T&E species or their critical habitats occur in at least one of the counties: 

American chaffseed (Schwalbea americana); Bachman’s warbler (Vermivora bachmanii); 

Canby’s dropwort (Oxyops canbyi); eastern black rail (Laterallus jamaicensis ssp. jamaicensis); 

frosted flatwood salamander (Ambystoma cingulatum); green sea (Chelonia mydas), hawksbill 

(Eretmochelys imbricata), Kemp’s ridley (Lepidochelys kempii), leatherback (Dermochelys 

coriacea), and loggerhead (Caretta caretta) sea turtles; northern long-eared bat (Myotis 

septentrionalis); piping plover (Charadrius melodus); pondberry (Lindera melissifolia); redcockaded woodpecker (Picoides (=Dendrocopos) borealis); red knot (Calidris canutus rufa); 

seabeach amaranth (Amaranthus pumilus), West Indian manatee (Trichechus manatus latirostris)

and the wood stork (Mycteria americana). 
17

3. Human Health and Safety

Under the no action alternative, potential human health impacts are related to the activities other 

Federal and non-federal agencies and private landowners take to manage ALB. The spread of 

ALB would likely result in these parties making insecticide treatments for suspected ALB on 

their property, as well as removing infested trees or trees that died from ALB infestation. 

Increased pesticide use would be expected to be minor but would result in some increase in

exposure and risk to human health. The potential of more trees becoming infested under this 

alternative may increase the risk of tree-falling hazards, such as when limbs or whole trees fall 

on power lines, cars, houses, or people.

4. Socioeconomic

Municipalities and property owners that lose trees to ALB may have costs associated with their 

removal and replacement. The loss of trees, particularly clusters of trees or mature trees, changes 

the landscape and can have aesthetic impacts. 

Forestry is an important industry in South Carolina. In 2014, forestry ranked first in 

manufacturing industry jobs and the forestry industry accounted for $17 billion annually (SCFC 

2014). Hardwood trees cover approximately 53% of the forestland in the state (SCFC 2014). In 

2016, the forest-type group makeup of timberland in the state was oak-hickory (22%), Oak-gumcypress (15%), Oak-pine (12%), elm-ash-cottonwood (3%), longleaf-slash pine (4%) and 

loblolly-shortleaf pine (44%) (Brandeis et al. 2017). In Charleston, Colleton, and Dorchester 

counties, coniferous trees comprise the majority of the tree canopy (Figure 3, Appendix 1); ALB 

host trees are not a prominent tree type. The commercial forestry industry in these three counties 

may feel some impacts from the loss of ALB host trees even if they are not dominant species.

Forest product mills located in the three counties may experience some loss due to quarantine 

restrictions imposed on the movement of ALB host material. It is possible that lightly infested 

trees could have salvageable wood timber and other end-use products; however, the quarantine 

does not allow the diversion of infested trees from chipping to saw mills because of the risk of 

spreading ALB. 

In South Carolina, ecosystem services such as carbon-sequestration credits and markets, natural 

forest processes such as water quality and quantity, and recreational activities have existing 

markets with the potential to grow (SCFC 2010). The loss of trees to ALB will have localized 

impacts to ecosystem services, but significant impacts are not expected unless ALB expands its 

current distribution in South Carolina and the region.
18

5. Environmental Justice

Federal agencies identify and address disproportionately high and adverse human health or 

environmental impacts of proposed activities, as described in Executive Order (EO) 12898, 

Federal Actions to Address Environmental Justice in Minority Populations and Low-Income 

Populations. Federal agencies also comply with EO 13045, Protection of Children from 

Environmental Health Risks and Safety Risks. This EO requires each Federal agency, consistent 

with its mission, to identify and assess environmental health and safety risks that may 

disproportionately affect children and to ensure its policies, programs, activities, and standards 

address the potential for disproportionate risks to children.

USDA APHIS has considered the potential environmental impacts of implementing the no action 

alternative on minority and/or low-income communities. The impacts would be similar to those 

described under the human health and safety section of the no action alternative. 

6. Tribal Consultation and Coordination

Executive Order 13175 "Consultation and Coordination with Indian Tribal Governments," calls 

for agency communication and collaboration with Tribal officials for proposed Federal actions 

with potential Tribal implications. The Archaeological Resources Protection Act of 1979 (16 

U.S.C. §§ 470aa-mm), secures the protection of archaeological resources and sites on public and 

Tribal lands. No Federally-recognized Tribes have been identified in the Counties of Charleston, 

Colleton, and Dorchester. Consultation with local Tribal representatives occurs prior to the onset 

of program activities to inform fully the Tribes of possible actions the Agency may take on or 

near Tribal lands. If USDA APHIS discovers any archaeological Tribal resources, it will notify 

the appropriate individuals. The no action alternative should not pose adverse effects to these 

resources.

7. Historic and Cultural Resources

The National Historic Preservation Act (NHPA) of 1966, as amended (16 U.S.C. §§ 470 et seq.), 

requires Federal agencies to consider the potential for impacts to properties included in, or 

eligible for inclusion in the National Register of Historic Places (36 CFR §§ 63 and 800) through 

consultation with interested parties where a proposed action may occur. This includes districts, 

buildings, structures, sites, and landscapes. A search for properties with a national register listing 

on the South Carolina Historic Properties Record online database (accessed August 5, 2020 at 

http://schpr.sc.gov/index.php) found 87 sites in Charleston County, 1 site in Colleton County, 

and 3 sites in Dorchester County (SC Department of Archives and History 2020). These 

properties are mostly historic buildings. The no action alternative would not pose direct adverse 

effects to historic buildings; however, ALB infested trees on historic properties could pose a 

danger to the public and removal of infested trees would alter the views of these properties. 
19

Anticipated impacts may be a localized and temporary change in aesthetics due to the loss of 

trees, particularly mature trees.

B. Preferred Alternative 

This section considers the potential environmental consequences for the preferred alternative by 

summarizing information associated with the physical environment, biological resources, human 

health and safety, socioeconomics, environmental justice, Tribal consultation, and historic and 

cultural resources. The preferred alternative is expected to further reduce the likelihood of ALB

populations becoming established when compared to the no action alternative, minimizing 

further impacts of ALB on the environment and the public. 

1. Physical Environment

USDA APHIS anticipates that the Program’s use of the insecticide imidacloprid and the 

herbicides triclopyr and triclopyr mixed with imazapyr and metsulfuron-methyl will have 

minimal impacts on the physical environment, provided the Program follows the pesticide labels 

for each chemical. Ecological and human health risk assessments for each pesticide are available 

in the programmatic EIS and are summarized below.

Air

USDA APHIS does not anticipate additional impacts to air when compared to the no action 

alternative. No impacts to air quality are anticipated for the proposed insecticide or herbicide

treatments. Drift is not anticipated based on the methods of application. The programmatic EIS 

provides additional information on the volatilization and drift potential of Program pesticides. 

Equipment used during tree removal and chipping or girdling will cause a temporary and 

localized increase in pollutants but is not expected to be a significant source of particulates and 

other pollutants. Similarly, incineration of tree debris would cause a temporary and localized 

increase in particulates.

Water

USDA APHIS does not anticipate additional impacts to water when compared to the no action 

alternative. USDA APHIS will consider impacts from the preferred alternative to water resources 

as significant if they exceed Federal or State water quality standards. Tree removal may cause a 

temporary change in water temperature due to reduced shade and increase sedimentation. The 

degradation of water quality can have direct and indirect impacts to aquatic species.
20

Pesticides, when used improperly, can end up in surrounding water bodies. Pesticides can reach 

waterways from spray drift, spills, or run-off either in solution or on soil particles that are moved

by hydraulic forces. Significant drift or runoff of herbicide is not expected as Program 

applications are not broadcast applied but are made either using a backpack sprayer to deliver a 

coarse droplet size, or by brushing the material on individual stumps and associated sprouting 

vegetation. The Program adheres to herbicide labels restrictions regarding applications in or near 

water resources. The Program makes imidacloprid applications using trunk or soil injection. 

Imidacloprid exhibits physical and chemical properties that suggest it could contaminate surface 

and ground water. Detections of imidacloprid in ground water have occurred in various parts of 

the United States, including States where ALB is present. Solubility and a lack of affinity for 

binding to soil or sediment suggest that imidacloprid could move offsite through runoff or 

leaching. The ability to leach into ground water would depend on site-specific conditions, such 

as soil type and depth to the water table. However, label restrictions regarding applications near 

surface water and other information regarding ground water reduces the potential for water 

contamination. In addition, the preferred use of tree injections of imidacloprid by the Program 

further reduces the possibility of impacts to water quality when compared to soil injection.

In wetland areas with ALB infestations 3-acres or greater in size and that are not accessible to 

the public, the Program would likely girdle infested and high-risk host trees, which may include

N. biflora. The Program would leave these trees in place, which minimizes soil disturbance and 

sedimentation. An exception to not removing trees is when an infested tree poses a risk to the 

public. The Program does not expect girdling to increase impacts to water resources any greater 

than the no action alternative, because under the no action alternative, infested host trees in 

wetlands would eventually die from ALB. In the long-term, the Program expects less impact 

from the preferred alternative because its goal is to eradicate ALB.

Soil

USDA APHIS does not anticipate additional impacts to soil when compared to the no action. 

Rather, we expect less impact in the long-term since we expect eradication compared to the no 

action alternative where ALB is expected to spread.

USDA APHIS considers impacts from the preferred alternative to soil resources as significant if 

proposed activities result in substantially increased erosion and sedimentation or adversely 

affected soil fauna. USDA APHIS expects the preferred alternative to have impacts in the 

immediate vicinity during and shortly after tree removal. Equipment may cause soil compaction 

and some erosion may occur until vegetation grows on the site and stabilizes the soil.

Surveyors and applicators may cause some local compaction when they walk across the ground, 

but the Program does not expect this to be significant. 
21

In wetlands with ALB infestations greater than 3 acres in size, the Program would likely not 

remove infested or high-risk host trees, which may include N. biflora. An exception to not 

removing trees is when an infested tree poses a risk to the public. The Program would girdle 

trees that are not accessible to the public. The Program would leave these trees in place, which 

does not disturb the soil.

Imidacloprid injections into trees will have no impact to soil fauna. However, soil injections 

made at the base of the tree could affect soil fauna in the treatment location, but this impact 

would be localized and of short duration. Herbicide applications to tree stumps are not expected 

to impact soil.

2. Biological Resources

Vegetation

Similar to the no action alternative, potential impacts to vegetation other than non-host trees 

from the preferred alternative are expected to be minimal. The removal of trees would cause 

damage to vegetation in the immediate vicinity of the tree. Any removal of infested or high-risk

host trees from local or State parks, as well as Federally-managed lands will be coordinated with 

the appropriate agencies.

The use of imidacloprid will have no impacts to surrounding vegetation. Trees treated with 

imidacloprid will have a small wound at the injection site but these areas on the tree are expected 

to heal. 

The Program uses herbicides when there are limitations to the physical removal of stumps. The 

limitations include those areas that are inaccessible to equipment used for stump grinding, and 

those areas that are sensitive to erosion or compaction. The herbicides triclopyr and triclopyr 

mixed with imazapyr and metasulfuron-methyl could harm non-target plants. However, the 

Program’s application methods and label directions minimize impacts to terrestrial plants, 

restricting potential harm to those plants that are immediately adjacent to treated stumps or 

sprouts. Exposure in aquatic systems is not expected to occur at levels that could result in any 

direct impacts to aquatic plants, or at levels that would suggest indirect impacts to aquatic 

organisms that depend on aquatic plants as a food source or as habitat.

The girdling of infested and high-risk host trees, which may include N. biflora, in wetlands with 

ALB infestations 3-acres or greater in size would kill these trees. The Program expects some 

damage to vegetation as they access these trees. The trees would not die immediately and the 

Program expects adult ALB to emerge from infested girdled trees. The Program also 

acknowledges that ALB could re-infest girdled trees and infest girdled high-risk host trees that 

are not dead. Tree girdling does not immediately remove ALB as with host removal. However, 
22

until the Program develops strategies to eradicate ALB from large wetland areas, it will likely 

use girdling to slow the spread of ALB.

Wildlife

Impacts to wildlife from the loss of trees will be similar or slightly greater temporarily to that

described in the no action alternative. The slightly greater impacts would be the result of the 

removal or girdling of both infested trees and high-risk host trees; however, in the long-term, the 

eradication of ALB will prevent its spread to unaffected areas. The programmatic EIS describes 

in more detail the impacts of tree removal on wildlife.

Actions associated with the preferred alternative will temporarily increase the presence or level 

of human activities (noise and visual disturbance) in the program area. Temporary adverse 

effects can include increased levels of stress hormones, disturbance or flushing of young broods, 

and decreased fitness. USDA APHIS expects the adverse effects associated with this concern to 

be localized and temporary, and the use of mitigation measures will further reduce the risks of 

adverse effects. 

Imidacloprid has low to moderate acute toxicity to mammals but is toxic to birds. It has low 

toxicity to fish, amphibians, and some aquatic invertebrates. The application method and the 

available effects data indicate low exposure and risk to terrestrial vertebrates (e.g., birds and 

mammals). The risk of imidacloprid exposure to aquatic species is negligible based on the 

Program’s use pattern and label instructions. 

Imidacloprid exposure to pollinators from the ALB Eradication Program, especially honey bees, 

is not expected to result in significant risk to pollinators. Pollinator exposure to imidacloprid is 

reduced because only treated trees and their associated flowers and pollen could have residues, 

while other flowering plants that have not been treated would not contain residues. Exposure and 

risk would increase in cases where large numbers of trees are treated over large areas prior to 

flowering, and in cases where only flowers from treated trees are the primary nectar source. Field 

monitoring data from trees treated with imidacloprid during the ALB eradication program 

suggest exposure levels will be low (Johnson 2012). Research indicates Program applications do 

not adversely impact honey bees and their hives, and levels of imidacloprid residue in pollen are

low. Exposure of honeybees to imidacloprid from water is expected to be minor based on the 

methods of application. The programmatic EIS provides further information on imidacloprid 

toxicity to wildlife and its impacts to pollinators.

Exposure to terrestrial and aquatic nontarget organisms to herbicide use is expected to be 

minimal from each proposed formulation and mix. Significant drift or runoff is not expected as 

applications are not broadcast applied, but are made using a backpack sprayer to deliver a coarse 

droplet size or by brushing the material on individual stumps and associated sprouting 
23

vegetation. The low probability of offsite transport for any of the products results in very low 

exposure to most nontarget organisms. The low probability of exposure and the favorable 

available effects data demonstrate that all products have a very low risk of causing adverse 

ecological risk.

(1) Migratory Bird Treaty Act 

Potential impacts to migratory birds are not expected to increase when compared to the no action 

alternative. As with the no action alternative, survey activities are not anticipated to impact 

migratory birds. The removal of trees causes noise and visual disturbance. It is possible the 

Program will remove more trees initially under the preferred alternative because of the potential 

removal of high-risk host trees. However, tree removal activities are localized and occur over a 

finite period.

Imidacloprid is toxic to birds based on available studies. Methods of application for imidacloprid

reduce the risks to migratory birds. This includes risk from exposure and impacts to food or 

habitat important for feeding and reproduction. Herbicide risk to migratory birds is low based on 

the favorable toxicity profile for each proposed herbicide and the method of application.

(2) Bald and Golden Eagle Protection Act 

Potential impacts to bald and golden eagles are similar to the no action alternative. If bald or 

golden eagles are discovered near a program action area, USDA APHIS, or its State cooperator,

will contact the U.S. Fish and Wildlife Service (USFWS) and implement recommendations for 

avoiding disturbance at nest sites. For bald eagles, USDA APHIS will follow the guidance in the 

National Bald Eagle Management Guidelines (USFWS 2007). USDA APHIS expects the use of 

imidacloprid and survey to pose a negligible risk and disturbance to bald eagles. The methods of 

application and survey for ALB are not expected to result in risks to food or habitat important to 

bald eagles. Herbicide risk to eagles is also low due to the proposed use patterns in the Program 

and low toxicity of each herbicide to birds.

(3) Endangered Species Act

Section 7 of the ESA and its implementing regulations require Federal agencies to ensure that 

their actions are not likely to jeopardize the continued existence of federally listed threatened and 

endangered species, or result in the destruction or adverse modification of critical habitat. USDA 

APHIS is conducting Section 7 consultation with the USFWS and National Marine Fisheries 

Service (NMFS) for ALB detection and eradication activities. USDA APHIS submitted a 

biological assessment to USFWS on July 15, 2020 that considers the actions under the preferred 

alternative to federally listed species within the three counties. USDA APHIS made a no effect 

determination for species under NMFS jurisdiction.
24

USDA APHIS has determined that the proposed ALB eradication program will have no effect on 

the West Indian manatee; Bachman’s warbler; eastern black rail; piping plover; red-cockaded 

woodpecker; red knot; hawksbill, green sea, Kemp’s ridley, loggerhead, and leatherback sea 

turtles; American chaffseed; Canby’s dropwort; and seabeach amaranth or their critical habitats. 

USDA APHIS has determined that with the implementation of protection measures, the proposed 

program may affect, but is not likely to adversely affect the northern long-eared bat, wood stork, 

frosted flatwood salamander, and pondberry. USDA APHIS received concurrence from the 

USFWS in a letter dated July 17, 2020.

3. Human Health and Safety

In the short term, tree removal activities may result in increased noise levels from equipment and 

vehicles, increased stress from having trees removed from properties, increased cooling and 

heating costs from the reduced tree buffer, and other localized negative human health 

consequences from the removal of trees. Emissions and particulates from tree removal activities 

may cause a short-term disturbance in air quality, particularly for sensitive groups. In the long 

term, the negative human health consequences could be less than the no action alternative 

because the overall tree loss is expected to decrease as ALB is eradicated.

The Program would not girdle trees in wetlands areas that are accessible to the public to prevent 

tree fall injuries. In these areas, the Program would remove the trees, leaving the stumps in place 

to minimize soil disturbance.

Pesticide applications for ALB are conducted in a manner that minimizes significant exposure to 

soil, water, and air, which in turn will minimize subsequent exposure to the general public.

Applicators in the ALB program are required to comply with all USEPA use requirements and 

meet all recommendations for personal protective equipment (PPE) during pesticide application.

The proposed methods of application for imidacloprid and the herbicides in the ALB program 

reduce the potential for exposure and risk to human health. Transport from drift or runoff is not 

expected based on the methods of application. The lack of runoff and drift will protect surface 

and ground water that may serve as a source for drinking water.

The programmatic EIS reviewed the exposure pathway in the use of imidacloprid-treated trees 

for firewood and found the levels of insecticide would be low because of the way the insecticide 

distributes to leaves and smaller branches and the removal of trees would not be expected to 

occur in the same growing season, allowing for degradation of imidacloprid residues.
25

4. Socioeconomic

The impact to municipalities and landowners is similar to those described under the 

environmental consequences for the no action alternative. However, the Program will remove 

infested trees rather than leaving them to die in place. Therefore, the Program will bear the cost 

of tree removal rather than property owners. The Program may also remove high-risk host trees, 

which may include N. biflora, in proximity to infested trees.

The impacts to the forestry industry in South Carolina will initially be similar to that described 

under the no action alternative, but in the long-term will be less as ALB is eradicated. The 

Program removes and chips or incinerates infested trees and high-risk host trees or girdles these 

trees, making them unavailable to the timber and forestry products industry. It is possible that 

lightly infested trees could have salvageable wood timber and other end-use products; however, 

the Program does not allow the diversion of infested trees from chipping to sawmills because of 

the risk of spreading ALB.

5. Environmental Justice

USDA APHIS has considered the potential environmental impacts of implementing the preferred 

action alternative on minority and/or low-income communities. USDA APHIS expects the 

distance from areas to environmental justice communities to influence if there are direct adverse 

impacts to those communities. In general, the Program and its cooperators will reach out to 

landowners prior to implementing eradication activities. USDA APHIS will encourage local 

Program personnel to engage with locally impacted people in collaborative decisions about the 

Program whenever possible. 

The preferred alternative is not likely to pose any highly disproportionate adverse effects to 

children because Program activities will not occur when children are present in the immediate

area. In the event that Program activities are required on school properties there will be 

coordination with the appropriate school administrators to ensure that activities do not occur on 

or near school properties during school operating hours, or while school buses are likely to be 

transiting around treatment areas.

Eradication of ALB will protect the public, including low-income communities and children, 

from adverse effects that have been associated with ALB, such as weakened trees that are at risk 

of falling.
26

6. Tribal Consultation and Coordination

USDA APHIS will provide the Federally-recognized Tribes in the region with information about 

the preferred alternative actions and will offer each Tribe the opportunity to consult with the 

Agency. Consultation with local Tribal representatives occurs prior to the onset of program

activities to inform fully the Tribes of possible actions the Agency may take on or near Tribal 

lands. If USDA APHIS discovers any archaeological Tribal resources, it will notify the 

appropriate individuals. No treatments or survey for ALB will occur on Tribal lands without 

coordination and approval.

7. Historic and Cultural Resources

USDA APHIS expects that the preferred alternative will not alter, change, modify, relocate, 

abandon, or destroy any historic buildings, edifices, or nearby infrastructure. Insecticides will not 

be applied to historic buildings and other anticipated program actions will not directly affect the 

buildings or their properties. If ALB infested trees are found on historic or cultural properties 

covered under the NHPA no treatments or tree removal would occur until the appropriate 

consultations are completed and any applicable mitigations applied. Removal of ALB-infested 

trees on these properties would protect the public who may visit historic and cultural properties 

by removing the threat of tree fall.

In accordance with Section 106 of the NHPA of 1966 and its implementing regulations, USDA 

APHIS prepared a Section 106 Project Review with the State of South Carolina. The document 

included a summary of the proposed action, the project location, a list of historic resources 

within the area of potential effect, as well as associated maps. APHIS sent the above-mentioned 

information and its analyses to the South Carolina State Historic Preservation Offices (SHPOs) 

for their reviews and determination whether the ALB program would affect these historic 

properties. 

The South Carolina SHPO also requires a Department of Health & Environmental Control Ocean 

and Coastal Resource Management (DHEC-OCRM) project review consultation when actions 

may impact coastal resources. In consideration of federal Coastal Zone boundary requirements, 

the South Carolina Coastal Zone is defined as “all coastal waters and submerged lands seaward 

to the State's jurisdictional limits and all lands and waters in the counties of the State which 

contain any one or more of the critical areas”.

C. Uncertainty and Potential Cumulative Impacts 

Uncertainty in this evaluation arises whenever there is a lack of information about the effects of a 

pesticide's formulation, metabolites, and properties in mixtures that have the potential to impact 
27

non-target organisms in the environment. These uncertainties are not unique to this assessment 

and are consistent with uncertainties in human health and ecological risk assessments with any 

environmental stressor. There is uncertainty in where ALB infestations may be detected within 

Charleston, Dorchester, and Colleton Counties in South Carolina. Currently the only positive 

detections are in Charleston County but detections may increase as survey expands to other 

areas. Uncertainty arises from the potential for cumulative impacts from using multiple 

pesticides, having repeat exposures, and co-exposure to other chemicals with similar modes of 

action. Theoretically, cumulative impacts may result in synergism, potentiation, additive, or 

antagonistic effects.

Cumulative impacts on the environment result from the incremental impact of the action when 

added to other past, present, and reasonably foreseeable future actions regardless of the entity 

conducting those other actions (40 CFR § 1508.7). Cumulative effects most likely arise when a 

relationship exists between a proposed action and other actions expected to occur in a similar 

location or during a similar period in time. Cumulative effects may not be reasonably foreseeable 

until a variety of direct and indirect impacts interact with each other or over time.

Cumulative impacts to soil, water, and air quality are not expected for the no action alternative. 

There may be additional insecticide treatments as ALB becomes established and expands its 

range in South Carolina. The lack of a coordinated eradication program would likely allow the 

threat from ALB to expand and serve as an additional stressor to the habitats that support ALBhost trees.

Cumulative impacts to soil, water, and air quality are not expected to be significant for the 

preferred alternative. Tree removal adjacent to water bodies or on soils that are erodible may 

increase transport of soil or sediment to water bodies, but these impacts will be short-term and 

incrementally negligible. Pesticide use from the preferred alternative is minor and is directed to 

individual trees. Imidacloprid is registered in South Carolina for various agriculture and nonagriculture uses. Environmental loading of imidacloprid will increase under the preferred 

alternative but the amount is incrementally negligible when compared to other uses in South 

Carolina. Survey is directed towards identifying ALB. ALB surveys are adaptive with survey 

boundaries expanding when ALB is detected, and stopped in areas confirmed free of ALB. The 

impacts from the actions discussed in this EA are expected to result in only minor or transient 

impacts; therefore, any increase in cumulative impacts will be negligible.

Vehicle emissions associated with getting to and from project sites will be minor relative to the 

ongoing and future emissions from urbanization, highway traffic, and agricultural production. 

Any increases in air pollutants associated with program activities and vehicle emissions will

cease upon completion of program activities at each site. Future actions that could increase 

emissions (e.g., housing developments and road expansions leading to more traffic) are difficult 
28

to quantify because emissions from mobile sources are subject to changing fuel mileage and 

emissions standards and regulations. Nevertheless, the contribution from the preferred alternative 

will remain minor compared to the overall emissions in the program area. 

USDA APHIS expects the potential human health impacts related to the preferred alternative to 

be minimal and in the context of potential cumulative impacts to past, present, and future 

activities, these impacts will be incrementally minor. The greatest sectors of the human 

population at risk of exposure to pesticides are program workers and applicators; however, these 

risks are minimized by using PPE. The lack of significant routes of exposure to human health 

and the environment, suggest cumulative impacts will not occur.
29

IV. Listing of Agencies Consulted

Environmental and Risk Analysis Services

Policy and Program Development

Animal and Plant Health Inspection Service 

U.S. Department of Agriculture

4700 River Road, Unit 149

Riverdale, MD 20737

Plant Protection and Quarantine

Emergency and Domestic Programs

Animal and Plant Health Inspection Service 

U.S. Department of Agriculture

4700 River Road

Riverdale, MD 20737

South Carolina Department of Plant Industry

Clemson University

Regulatory Services

511 Westinghouse Road 

Pendleton, SC 29670

U.S. Fish and Wildlife Service

176 Croghan Spur Road, Suite 200 

Charleston, South Carolina 29407 

NOAA Fisheries

Southeast Regional Office

263 13th Avenue South

St. Petersburg, FL, 33701
30

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33

Appendix 1. Forest type covers for Charleston, Colleton, and 

Dorchester Counties, SC

Charleston County
34

Colleton County
35

Dorchester County
36

Appendix 2. ALB infestations near forested wetlands

A. Topographic Map (as of July 28, 2020)
37

B. Satellite image map (as of July 28, 2020)