2016 gypsy moth slow the spread treatment...

January 2016 Prepared in accordance with Section 102 © of the National Environmental Policy Act – 1969, the USDA Final Environmental Impact Statement – 1995 and the USDA Supplemental Environmental Impact Statement – 2012

2016 Gypsy Moth Slow the Spread Treatment Project

Athens Ranger District Wayne National Forest

Athens, Hocking, Morgan, Perry, and Vinton Counties in Ohio

Type of Statement:

Lead Agency:

Deciding Official:

For more information:

Environmental Assessment USDA Forest Service Jason Reed Athens District Ranger 13700 US Hwy 33 Nelsonville, OH 45764 740-753-0101 Rachel Orwan NEPA Coordinator 13700 US Hwy 33 Nelsonville, OH 45764 740-753-0101

2

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TABLE OF CONTENTS

INTRODUCTION .......................................................................................................................................................1

1.0 PURPOSE AND NEED FOR ACTION .................................................................................................................1 1.1 Need for Action ............................................................................................................................................1 1.2 Forest Plan Support for Action .......................................................................................................................3 1.3 Objectives of the Proposed Action ..................................................................................................................4 1.4 Relationship to Other Decisions .....................................................................................................................4 1.5 Decisions To Be Made...................................................................................................................................5 1.6 Summary of Public Involvement and Notification Process ................................................................................5 1.7 Key Issues ....................................................................................................................................................6

2.0 ALTERNATIVES, INCLUDING THE PROPOSED ACTION ................................................................................7 2.1 Alternatives Not Considered in Detail .............................................................................................................7 2.2 Alternatives Considered in Detail ...................................................................................................................8 2.3 Monitoring ................................................................................................................................................ 10

3.0 ENVIRONMENTAL CONSEQUENCES OF THE ALTERNATIVES.................................................................. 10 3.1 Wildlife ..................................................................................................................................................... 10 3.2 Plants – Federally Threatened and Endangered or Regional Forester Sensitive Species .................................... 21 3.3 Irreversible and Irretrievable Commitment of Resources ............................................................................... 22 3.4 Summary ................................................................................................................................................... 22

4.0 LIST OF AGENCIES AND PERSONS CONSULTED ........................................................................................ 22

5.0 LIST OF PREPARERS ...................................................................................................................................... 23

6.0 LITERATURE CITED ...................................................................................................................................... 23

APPENDIX A: STANDARD OPERATING PROCEDURES

APPENDIX B: MAPS

1

INTRODUCTION

The WNF is proposing to allow the Ohio Department of Agriculture and the USDA-Forest Service Forest

Health Protection Program to aerially treat populations of the non-native forest pest gypsy moth.

Treatments would be limited to the Athens Unit of the Athens Ranger District, with acceptable products

being limited to mating disruption pheromone and Gypchek. This project would reduce the need for

duplicative environmental analysis in the future. Btk is not included in this proposal.

1.0 PURPOSE AND NEED FOR ACTION

1.1 Need for Action

The gypsy moth (Lymantria dispar) is a non-native defoliator of forest, shade and ornamental trees

throughout the northeastern United States. Since its intentional importation and accidental release in

eastern Massachusetts in 1869, the gypsy moth has steadily expanded its range.

The gypsy moth produces one generation per year. Larvae begin hatching from egg masses at about the

same time redbuds begin to bloom. The larvae feed for a few weeks and then seek sheltered areas in

which to pupate. After emerging from the pupal case, the adult female moths, which cannot fly, crawl a

short distance and emit a pheromone scent to attract males. After mating, the female lays a single egg

mass that contains from 75 to 1,000 eggs, which she covers with hairs from her abdomen giving the egg

mass a fuzzy brown texture and color. The egg masses over winter and hatch the following spring.

Damage caused by gypsy moths is due to the feeding caterpillars. The number of host trees and shrubs

fed on by the gypsy moth caterpillar exceeds 300 species, with species of oaks (Quercus spp.) ranked

among the most favored (Leonard 1981). Gypsy moth is an outbreak species whose populations can

remain at low levels for several years, then undergo large population increases in a matter of one or two

years. After populations have increased to an outbreak density they can remain high for one to five

years. Outbreaks decline suddenly to low densities where it is difficult to find any life stage (Liebhold et

al. 2000).

Main effects of gypsy moth caterpillar feeding on individual trees involve the depletion of root

carbohydrate food resources leading to a reduction in growth, reproduction and increased vulnerability to

secondary agents that could cause mortality including drought, fire, acid deposition, diseases, and other

insects. Heavy defoliation forces trees to grow new leaves, which occurs when about 60 percent of the

foliage is lost (Liebhold et al. 1994). Defoliation and subsequent tree mortality can alter wildlife

habitats, change water quality and temperature; increase forest floor temperature and light levels; and

reduce aesthetic, recreational, and property values of forests and urban environments. Depending on

various other stressors, trees may die after a single year of heavy defoliation, with oak mortality at

approximately 20%. After two years of heavy defoliation, oak mortality jumps to approximately 90%

and after three years oak mortality may be 100%.

2016 Gypsy Moth STS Project Environmental Assessment Page 2

1.1.1 Contemporary Agency Response:

Gypsy Moth Slow the Spread (STS) pilot

project (1993-1999) demonstrated that the rate

of spread of the gypsy moth could be reduced

by approximately 60% through comprehensive

monitoring and management of recently

established populations in the transition area

(Liebhold et al 1992, Sharov et al 1998). The

benefits of reducing the rate of spread of the

gypsy moth exceed the costs of treatment and

monitoring by a ratio greater than three to one

(Leuschner et al 1996, Mayo et al 2003).

The STS pilot project successfully transitioned to operational status in 2000 and became part of the

national strategy for managing the gypsy moth. The national strategy includes suppression in the

generally infested area, eradication in the area that is not yet infested and STS in the transition area

(Figure 1). The transition area is defined as a band approximately 62 miles wide that is adjacent to the

area already infested by the gypsy moth. Gypsy moth populations located within the transition area are

characterized as recently established, separate from one another, and very low in density. The transition

area band covers approximately 78,000 square miles stretching across 11 states from northern Minnesota

to the coast of North Carolina (Figure 2). The goal of STS is to use integrated pest management

strategies throughout the transition area to slow the spread

of the gypsy moth in the United States.

Areas proposed for treatment as part of STS are selected

with the aid of a decision support system, the results of

which can be viewed online at www.gmsts.org. This

system uses data from more than 80,000 pheromone traps

that are deployed in the transition area annually to select

and prioritize dozens of infestations that are proposed for

treatment nationally each year.

State-wide, gypsy moths are established east of a band that

runs roughly diagonally from northwest Ohio to southeast

Ohio. The Athens Unit of the Athens Ranger District on

the Wayne National Forest (WNF) is currently within the transition zone (Figure 3). Since 1999, the

transition zone has been pushed back east approximately 46 miles through implementation of the STS

program in Ohio (Figure 4, ODA 2015).

In Ohio, the Ohio Department of Agriculture (ODA) is the lead agency working to administer the STS

Program. The USDA Forest Service Forest Health Program cooperates to provide technical and financial

assistance. The ODA extensively traps in 68 of Ohio’s 88 counties in an effort to detect and monitor

gypsy moth populations within the state. The trap catches are analyzed to determine if a potential

problem area is developing and if treatment is needed to reduce the impacts of the gypsy moth.

Figure 1: The different treatment programs are active in different zones

of gypsy moth population densities.

Figure 2: STS Program action area.

http://www.gmsts.org/


1.1.2 Project Purpose:

The purpose of this project is to reduce the impacts

locally of gypsy moths by eliminating their

caterpillars and/or preventing mating of adult moths,

thereby causing drastically reduced future numbers

of the pest. On a large scale, the purpose of the

project is to slow the spread of the gypsy moth by

treating populations on the leading edge of the

species range.

Trapping of gypsy moths within and around the

WNF has led to the completion of annual treatment

projects since 2012. Analyzing these treatments

every year has led to duplicative efforts. New treatment blocks

have been identified for treatment on the WNF in 2016 and are

likely to continue being needed in the future as long as the

transition area (STS area) overlaps with the Athens Unit.

1.2 Forest Plan Support for Action

This action is consistent with the 2006 Wayne National Forest

Land and Resource Management Plan goals to limit the spread

of non-native invasive species.

Goal 7.1 Protect Vegetation and Wildlife from Insects, Diseases and Wildfire

Limit the effects of insects, diseases and wildfire on forest vegetation and wildlife to within the range

of disturbances that occurred in forest ecosystems prior to the arrival of non-native insects and

diseases. Manage non-native invasive species (NNIS) populations, including gypsy moths, using

prevention, suppression, and restoration techniques to protect and restore natural communities on the

Forest.

Objective-7.1b – Cooperate with the ODNR and the State and Private Forestry Division of the

Forest Service to suppress insect populations to:

Retard advance of the gypsy moth. (USDA FS 2006, p 2-39)

Figure 3: State-wide gypsy moth program areas

Figure 4: The gypsy moth transition area has been

pushed backwards about 46 miles over 17 years


1.3 Objectives of the Proposed Action

The objectives for the proposed 2016 STS project are:

To prevent the local population of gypsy moths from building to defoliating levels, and

To minimize spread of the gypsy moth in Ohio.

1.4 Relationship to Other Decisions

This Environmental Assessment (EA) is associated with other environmental impact statements and

assessments. To understand how this EA fits into the overall picture, it is necessary to review the

relationships between the current proposal and others, both past and present.

1.4.1 National Programmatic Environmental Impact Statement

A nation-wide Environmental Impact Statement (EIS) and Record of Decision (ROD) entitled, “Gypsy

Moth Management in the United States: a Cooperative Approach” was completed by the USDA in 1995.

The alternative selected included the three gypsy moth management strategies described above –

suppression, eradication, and STS. The 1995 analysis was supplemented with the 2012 Supplemental

EIS (SEIS) and Supplemental ROD, which updated information and analyzed a new treatment product.

The 2012 SEIS contains the discussion of impacts from gypsy moth infestations and the risks and

benefits associated with the different treatment methods. Much of the needed analysis of this current

proposed activity is contained within that larger analysis. Thus, this EA tiers to the nation-wide SEIS in

order to reduce repetition and stream-line the analysis process (40 CFR 1502.20 and 1508.28). The SEIS

is available on the project webpage at:

http://www.fs.usda.gov/projects/wayne/landmanagement/projects

This current EA fulfills the site-specific analysis and planning necessary for the 2016 Gypsy Moth STS

Treatment Project activities proposed to take place on the WNF. Additional STS activities in the state

are analyzed in a separate EA completed by the ODA and USDA-FS Forest Health Protection Program.

1.4.2 Other Gypsy Moth Slow the Spread Treatments in Ohio

As part of the STS strategy, ODA, in cooperation with the USDA Forest Service Forest Health Protection

Program, proposes other treatments on lands not part of the WNF every year in Ohio. These proposed

applications are analyzed in a separate document prepared by ODA and USDA Forest Service Forest

Health Protection Program. More information about these treatments is available by contacting the ODA

a 1-614-728-6400, [email protected] or http://www.agri.ohio.gov

1.4.3 Prior Slow the Spread Projects on the Wayne National Forest

The WNF has worked together with ODA and USDA Forest Service Forest Health Protection Program to

allow for the treatment of thousands of acres of WNF in the past. Prior to this current project, mating

disruption pheromone treatment for gypsy moths occurred on the WNF near Hanging Rock in the Ironton

Ranger District in 2003, north of the community of Starr, OH, in 2012 and south of Nelsonville, OH, in

2013; both on the Athens Unit of the Athens Ranger District. In 2014, mating disruption pheromone was


mailto:[email protected]

http://www.agri.ohio.gov/


applied near New Straitsville, Shawnee, and Corning; Btk was applied near the same communities in

smaller areas; and Gypchek was applied west of Glouster, OH. In 2015, mating disruption pheromone

was applied near New Straitsville, Carbon Hill, Murray City, Buchtel, Nelsonville, Chancey, Union

Furnace, Starr, and New Plymouth, with smaller areas near Starr and Union Furnace also treated with

Gypchek.

1.5 Decisions To Be Made

State law authorizes the Director of ODA to control quarantined and dangerously destructive plant pests.

Each year, the ODA designates areas for gypsy moth STS treatments and analyzes the potential impacts

of treatment. When populations are found on the WNF, the Forest must also go through a site-specific

review to determine if the treatments proposed fit into the management strategy for the Forest and if

potential negative impacts exist.

Based on the information provided by ODA and included in this EA, the decisions to be made by the

WNF are:

1. Would the proposed action have significant impacts requiring further analysis in an EIS?

2. Should the Athens District Ranger decide to implement the proposed treatments on the WNF?

These decisions will be made by the Responsible Official in April, 2016. The responsible official for the

decisions described above is:

Jason Reed

Athens District Ranger

Wayne National Forest

13700 US Hwy 33

Nelsonville, OH 45764

If no EIS is required and the Athens District Ranger decides to authorize the project’s implementation,

the decision would be documented in a Decision Notice (DN) with a Finding of No Significant Impact

(FONSI). Following the DN and FONSI, the decision could be implemented as early as late April 2016;

however, treatments would be timed to occur when they will be most effective based on suitable foliage

development and the growth stage of the gypsy moth.

Further information regarding the 2016 Gypsy Moth STS Treatment Project on WNF can be obtained by

contacting Rachel Orwan, Forest NEPA Planner, at 740-753-0101 or [email protected] or by visiting the

WNF website at http://www.fs.usda.gov/projects/wayne/landmanagement/projects.

Information about the 2016 Gypsy Moth STS Treatment Project on state and private lands in Ohio can be

obtained through contacting the ODA Gypsy Moth Program Office by writing to 8995 East Main St.,

Reynoldsburg, Ohio 43068; by calling 1-614-728-6400; by emailing [email protected] or visiting

http://www.agri.ohio.gov .

1.6 Summary of Public Involvement and Notification Process

As part of public outreach, this project has been listed on the Schedule of Proposed Actions and the WNF




http://www.agri.ohio.gov/


public website since late December of 2015. WNF staff gave presentations about the project at public

meetings of the Athens, Hocking, and Perry County Commissioners and solicited feedback as part of the

scoping process. A scoping letter was sent via email and/or postal mail in December to those members

of the public thought to be interested in the project, including elected officials in the project area (197

individuals and organizations). A news release was also sent to media contacts and was published by at

least three local newspapers. All of these outreach documents are contained within the Project File.

During scoping there was one supportive response. The respondent did not give a name, but simply

stated that he supported the project, since he felt that oaks were important trees.

1.7 Key Issues

Public outreach efforts conducted to date have not result in the identification of any key issues to be

considered in depth. Impacts to federally endangered or threatened, as well as Regional Forester

sensitive wildlife and plant species are discussed in Chapter 3 of this EA. Other potential impacts that

have been considered are briefly discussed below.

1.8 Other Issues

The following issues have been raised during scoping in the past. They are summarized here, with an

explanation of how each issue has been addressed.

1. The impacts of the proposed treatments for gypsy moth on cultural resources were considered and

no effects on architectural, historic, or archaeological sites are anticipated as a result of aerial

application activities (Cultural Resource Input, Project Record).

2. The impacts of the proposed treatments for gypsy moths on water resources were considered and

no effects on the characteristics of these areas are anticipated. However, the No Action

Alternative does present potential negative impacts to water resources, including the potential for

increased stream temperatures if defoliation were to occur (Hydrology Input, Project Record).

Open water features are excluded from treatment (See Appendix A).

3. The impacts of the proposed treatments for gypsy moths on soil resources were considered and no

adverse effects are anticipated. Due to the method of application (aerial), the pesticides for the

most part do not come into contact with soil. (Soil Resource Input, Project Record).

4. Impacts to human health were not considered in detail in this site-specific EA because thorough

risk assessments were produced and analyzed for the nation-wide SEIS. No additional effects are

plausible beyond those analyzed and disclosed in the SEIS. In that document no serious adverse

effects were identified from the treatment products under consideration here (mating disruption

pheromone and Gypchek). There is the potential for temporary eye irritation from the Gypchek

application; however, this is not likely, and, if it did occur, would most likely affect product

handlers. The use of standard safety practices that are incorporated in the product label would

minimize the risk of exposure (USDA FS 2012a, Vol. III, Appendix G, pp vii, 3-1, 3-10, and 3-


11). For more information on human health and environmental consequences, see the risk

assessments located in the SEIS (USDA FS 2012a, Vol. III, Appendices F, G, H, I, and Vol. IV,

Appendix J). Also a summary of the findings in the risk assessments can be located in the SEIS

(USDA FS 2012a, Vol. II, Chapter 4, pp 1-31).

5. Impacts to the project area due to interactions between gypsy moth treatment and climate change

were not considered in detail. Treatment of this low-level gypsy moth population prevents

negative direct and indirect impacts to the ecosystem and helps to make the forest more resilient

in the face of potential climate change impacts. Since no direct or indirect effects to the

environment were identified through the analysis (Project Record and Chapter 3), there would be

no cumulative effects due to treatment in concert with climate change.

2.0 ALTERNATIVES, INCLUDING THE PROPOSED ACTION

2.1 Alternatives Not Considered in Detail

The uses of some treatment options were considered but eliminated from detailed study for this proposed

project.

2.1.1 Use of Btk

Bacillus thuringiensis var kurstaki (Btk) is a naturally-occurring bacterium that is toxic to gypsy moth

caterpillars if ingested at the right time. It can also be toxic to other species of butterflies and moths if

their caterpillars are present at the correct life stage and actively feeding within the 7-14 days following

application. At this time, other treatments that have fewer non-target impacts will meet STS project

objectives.

It is possible that treatment with Btk may be warranted in the future. If that is the case the WNF would

initiate an analysis for that treatment and would seek public input at that time.

2.1.2 Use of Mass Trapping

Mass trapping is a labor-intensive treatment, especially over large areas. It is typically used on small

infestations of less than 100 acres. The extent of acreage proposed for treatment here and the

inaccessibility of many areas within the proposed treatment blocks do not make mass trapping a viable

treatment option in these circumstances.

2.1.3 Use of Sterile Insect Techniques, or Sterile Release

The objective of the sterile insect technique is to reduce the chance that female moths will mate with

males. The result is progressively fewer and fewer fertile egg masses being produced, and eventual

elimination of the population.

The limited period during which pupae must be released and the need to synchronize rearing of mass

quantities of pupae for that release (treated pupae cannot be stockpiled) are obstacles to an operational


program. One major logistical difficulty is the need to repeatedly release the treated insects over the

four-week flight period because male moths live for only two or three days (USDA FS 1995, Vol. II,

Appendix A-10). Amount of acreage proposed for treatment, insufficient availability of treated pupae

and greatly increased application cost associated with a sterile insect release do not make this option a

viable one for a project of this magnitude.

2.1.4 Use of Diflubenzuron (Dimilin)

Dimilin is an effective treatment for all population densities of the gypsy moth but it can have impacts on

aquatic organisms and other insects. Other treatments that have fewer non-target impacts will meet STS

project objectives.

2.2 Alternatives Considered in Detail

This EA considers two alternatives in detail: 1) no action and 2) the proposed action.

2.2.1 Alternative 1 - No Action Alternative

In this alternative there would be no treatment for gypsy moth populations on the WNF. Consequently,

the population would likely continue to grow in density. If no treatment were conducted over a few

years’ timeframe there could be spots of tree defoliation. If allowed to progress further with no

treatment, large-scale defoliation could occur, potentially resulting in tree mortality.

2.2.2 Alternative 2 – Use Mating Disruption Pheromone and Gypchek

In the past, the WNF has worked together with ODA and USDA Forest Service Forest Health Protection

to allow for the treatment of thousands of acres of WNF to control gypsy moth populations. The STS

Program takes a pre-emptive approach to tackling gypsy moths, by targeting and treating populations

before they build to defoliation-causing densities.

WNF staff have considered and analyzed STS projects on the Athens Unit annually since 2012. This

year the approach is different – the analysis considers if impacts would be any different if they could

occur anywhere on the Athens Unit in the future. The reason for this different approach is to reduce

duplicative analysis overtime, since, as stated in Section 1.1.2 it is likely that the Athens Unit will be in

the transition zone for gypsy moth for many years in the future.

The proposed action would allow the ODA to aerially treat populations of gypsy moth anywhere on the

Athens Unit with mating disruption and/or Gypchek. The Athens Unit includes approximately 72,445

acres of National Forest System lands in Athens, Hocking, Morgan, Perry, and Vinton Counties. ODA

would be able to conduct the aerial applications on the WNF in the future, after annually coordinating

with the Forest on that year’s treatment proposal.

If the proposed action is approved, approximately 20,230 acres would be treated in 2016. This treatment

would include 2 applications of Gypchek in 1 area (totaling to 705 acres) in mid-late spring (mid-April –

mid-May) and 1 application of mating disruption in 4 larger areas (totaling to about 20,230 -


encompassing the smaller Gypchek treatment block) in late spring to early summer (May-June). The

exact timing of the application would be dictated by the observed life-stage of the gypsy moths in the

field. The treatments would be delivered aerially.

Effectiveness monitoring would be conducted during the year following treatment.

The following design criteria apply to this proposal:

The Research Natural Area (RNA), Buffalo Beats, is excluded from any treatment. RNAs

are established because the regional significance of the site presents opportunities for

research into natural processes.

Only mating disruption pheromone and Gypchek would be approved for application.

Other treatment products would need to be considered through additional environmental

analysis and public input and only if trap catches found them necessary.

Treatments on private lands are not included in this project. Often, treatment blocks that

include WNF lands also include private lands. The WNF has no decision authority over

actions on private lands, so inquiries related to private lands should be directed to the

ODA.

Open water and non-forested areas would not be treated.

Two Treatment Methods Being Considered

Mating disruption pheromone (Disparlure) is a synthetic formulation of the pheromone naturally

produced by the female gypsy moth. It targets the gypsy moth at the adult, moth life-stage and;

therefore, does not immediately prevent defoliation. By saturating the area with female gypsy moth

pheromone, reproduction is eliminated or drastically reduced because the males cannot find the females.

This will reduce caterpillar numbers in future years. At higher densities of gypsy moths, mating

disruption becomes less effective because male moths can find females visually, without the aid of a

pheromone. Mating disruption is 100% species-specific and is effective in lower density populations.

Because the effectiveness of mating disruption pheromone treatments drop off as the density of gypsy

moth increases, areas with higher trap catches may still be at risk. These areas are typically proposed to

also be treated with a larvacide. In this project the larvacide Gypchek would be the only one approved

for use.

Gypchek (Nucleopolyhedrosis virus product) is a larvacide that targets gypsy moth caterpillars and has

no effect on non-target insects, including other species of moths and butterflies. It is made from

laboratory-reared gypsy moth caterpillars that have been infected with the naturally-occurring virus.

Gypchek applications are usually completed in April and/or May. Two applications are typical, with the

second application occurring 3-5 days after the first. Production of Gypchek is limited annually to the

amount that would treat approximately 3,000 – 5,000 acres nation-wide, so its use is focused on areas of

particular sensitivity.


2.3 Monitoring

Monitoring of the Athens Unit for gypsy moths would continue regardless of which Alternative is

selected, as part of the state-wide gypsy moth program.

If Alternative 2 were selected, the area would be monitored by ODA and USDA Forest Service Forest

Health Protection Program after treatments with pheromone traps on a 500-meter or one kilometer grid

spacing to determine the effectiveness of each treatment. Treatment effectiveness would be monitored in

the summer and early fall of the year following treatment. This would allow aerially applied pheromone

time to dissipate from the block so it would no longer conflict with the pheromone in the monitoring

traps.

During treatment, ground observers and/or aerial observers would monitor the application for accuracy

within the block perimeters, swath widths and drift. Downloading of Differential Global Positioning

System information from application aircraft to an operations-base computer would also be conducted to

help determine swath widths, spray-on and spray-off, acreage treated and altitude during spray runs.

3.0 ENVIRONMENTAL CONSEQUENCES OF THE ALTERNATIVES

3.1 Wildlife

The information below about potential effects to wildlife is contained in a Wildlife Biological

Evaluation/Assessment that is found in the Project Record.

For all of the species considered below, the following paragraphs contain the analysis for Alternative 1,

the No Action Alternative.

In Alternative 1, the WNF would not allow the ODA to aerially apply treatment products to control a low

level population of gypsy moth. The population would likely continue to grow in density. If no

treatment were conducted over a few years’ timeframe, there could be tree defoliation. If allowed to

progress further with no treatment, large-scale defoliation could occur, potentially resulting in tree

mortality.

The implications of taking no action are far reaching on wildlife species, due to the devastating effects

the gypsy moth can have within the forested ecosystem. Tree defoliation can reduce hiding cover and

food availability, whether that food source is the leaves of trees or the insects which eat the leaves and

thus are eaten by birds, bats, and other wildlife. Oaks that are stressed or killed from defoliation and

secondary agents could have reduced or no mast production (e.g. acorns), which can greatly affect the


availability of food resources. Bear, turkey, and bats may migrate to non-defoliated areas or less

defoliated areas (USDA FS 2012a). Reported increases in nesting failures of various species of birds

appear to be due to increased predation, increased weather stress, or both, which are associated with

defoliation (Thurber and others 1994). The Gypsy Moth Management in the United States: a cooperative

approach, Supplemental Environmental Impact Statement Volume I of IV (USDA FS 2012a) discusses

the varying effects to wildlife species due to gypsy moth defoliation.

3.1.1 Federally Listed Wildlife Species

MAMMALS

Indiana Bat and Northern Long-Eared Bat

The Indiana bat (Myotis sodalis) and the northern long-eared bat (Myotis septentrionalis) hibernate in

caves and mines in the winter. During the remainder of the year they seek out trees with flaking bark,

crevices or cavities to roost and/or raise their young. These bats will forage within forest canopies with

open understories, along forest edges and over ponds. Belwood (1998) reports that these two bat species

appear to be opportunistic feeders feeding mainly on moths, caddisflies, and other soft-bodied bugs.

Beetles are also an important food item, particularly for female Indiana bats after lactation.

It is possible that Indiana bats and northern long-eared bats may be present during the treatments.

Effects of Treatment Products

Disparlure (mating disruption pheromone): “Results of acute toxicity studies for oral, dermal, ocular, and

inhalation exposure to disparlure demonstrate very low toxicity to mammals. Information is not available

regarding chronic toxicity, and no field studies exist assessing the impact of disparlure on mammals.

Disparlure does not attract any other insect found in North America.” (USDA FS 2012a, Vol I, Ch 4).

Gypchek: “Except for eye irritation, there is little indication that Gypchek has any effect in mammals,

even at extremely high levels of exposure. Barber and others (1993) found no indication that Gypchek is

pathogenic to any insect species except the gypsy moth. No adverse effects were observed in any species

tested. Additionally, a recent field study noted no effects in nontarget insects following the application of

Gypchek (Rastall and others 2003). There is no indication that adverse effects are caused in nontarget

insects at any level of exposure.”

(USDA FS 2012a, Vol I, Ch 4).

Determination

Based on the known available information, the implementation of Alternative 2 would have no adverse


impact on the Indiana bat or the northern long-eared bat.

MOLLUSKS

Rayed Bean, Fanshell, Snuffbox, Pink Mucket Pearly Mussel and Sheepnose

Mussels are found in medium to large rivers where the bottom is gravel or mixed gravel and sand. ODA

will maintain a no-treatment buffer along open water streams and water bodies. Mating disruption

pheromone and Gypchek are specific to gypsy moth and are unlikely to affect aquatics (USDA FS

2012a).

Determination

With the proposed treatment products of mating disruption pheromone and Gypchek, in combination

with the buffer established along open water streams and water bodies, there would be no adverse

impacts to these species from implementing Alternative 2.

INSECTS

American Burying Beetle

The American burying beetle is the largest carrion-frequenting insect in North America; it may reach a

length of l½ inches. Adult beetles are nocturnal and search widely for carrion. They are remarkably adept

at detecting the odor of recent death. Using the organs of smell located on their antennae, they can find a

dead mouse within an hour of death and from as far away as two miles. After flying to the vicinity of a

carcass, they drop to the ground and crash through the litter to get to it. They go under the body, turn

over onto their backs and experimentally lift the remains and begin to bury the carcass. The female will

then lay her eggs in a chamber created above the carcass. The adults remain to care for the larvae by

regurgitating food for them until the larvae are able to feed for themselves.

The American burying beetle has been reintroduced within a block proposed for treatment in 2016. If

approved, Alternative 2 would allow for possible future treatments using mating disruption pheromone or

Gypchek over the same reintroduction site or others located on the Athens Unit.

Effects of Treatment Products

Disparlure (mating disruption pheromone): “Disparlure does not attract any other insect found in North

America.” (USDA FS 2012a, Vol I, Ch 4)

Gypchek: “Barber and others (1993) found no indication that Gypchek is pathogenic to any insect species

except the gypsy moth. No adverse effects were observed in any species tested. Additionally, a recent


field study noted no effects in nontarget insects following the application of Gypchek (Rastall and others

2003). There is no indication that adverse effects are caused in nontarget insects at any level of

exposure.” (USDA FS 2012a, Vol I, Ch 4)

Determination

Due to the selectivity of the mating disruption pheromone and Gypchek, there would be no adverse

impact to the American burying beetle from Alternative 2.

3.1.2 Regional Forester Sensitive Species (wildlife)

Of those wildlife species on the Regional Forester sensitive species list for the WNF, the black bear, little

brown bat, tri-colored bat, cerulean warbler, Henslow’s sparrow, bald eagle, northern metalmark, and

grizzled skipper occur within, are likely to occur within, or are in the proximity of the project area.

MAMMALS

Black Bear (Ursus amercanus)

Black bear were thought to be extirpated from Ohio by 1850. In present day, bear sightings have been

steadily increasing since the mid-1980s, and evidence suggests Ohio may support a small breeding

population (ODNR DOW 2002). Black bear require a variety of seral stages and forest types for

foraging and denning. They prefer heavily wooded areas with a dense understory for foraging or

traveling, but they will also utilize forests with open areas, like meadows where they can find certain

food items. Stream and creek banks are often used as travel lanes because of thick undergrowth and a

barrier-free escape route. Black bear use dense thickets, hollow logs, tree or rock cavities, and

caves/mines for dens from November until mid-April. Black bears often consume berries, flowers,

grasses and sedges, herbs, tubers and roots, and nuts of all kind. Black bear also eat small mammals,

insects, and honey.

Effects of Treatment Products:

Disparlure (mating disruption pheromone): Results of acute toxicity studies for oral, dermal, ocular, and

inhalation exposure to Disparlure demonstrate very low toxicity to mammals. Information is not available

regarding chronic toxicity, and no field studies exist assessing the impact of Disparlure on mammals.

(USDA FS 2012a, Vol I, Ch 4)

Gypchek: Except for eye irritation, there is little indication that Gypchek has any effect in mammals, even

at extremely high levels of exposure. (USDA FS 2012a, Vol I, Ch 4)


Determination

Based on the information referenced above, there would be no adverse impact to the black bear from

Alternative 2.

Little Brown Bat (Myotis lucifugus)

Little brown bats can be found throughout North America, and are the most abundant bat in the United

States. During summer, female little brown bats form maternity colonies, mostly in barns and buildings,

often near bodies of water that support an insect population prey base. Maternity colonies have also been

found behind siding on buildings and under bridges. Numbers of individuals in a maternity roost can

range from 10 to 1,000 bats. Male little brown bats are more solitary in nature, roosting singly under

exfoliating bark, behind loose siding and shingles, in rock crevices, and in hollow trees. Little brown bats

forage for insects in many habitats including forest canopies, stream corridors, over lakes and ponds,

fields, parks, wooded edges, and suburban areas.


Disparlure (mating disruption pheromone): Results of acute toxicity studies for oral, dermal, ocular, and

inhalation exposure to Disparlure demonstrate very low toxicity to mammals. Information is not available

regarding chronic toxicity, and no field studies exist assessing the impact of Disparlure on mammals.

Disparlure does not attract any other insect found in North America. (USDA FS 2012a, Vol I, Ch 4)

Gypchek: Except for eye irritation, there is little indication that Gypchek has any effect in mammals, even

at extremely high levels of exposure. Barber and others (1993) found no indication that Gypchek is

pathogenic to any insect species except the gypsy moth. No adverse effects were observed in any species

tested. Additionally, a recent field study noted no effects in nontarget insects following the application of

Gypchek (Rastall and others 2003). There is no indication that adverse effects are caused in nontarget

insects at any level of exposure. (USDA FS 2012a, Vol I, Ch 4)

Determination

Based on the information referenced above, there would be no adverse impact to the little brown bat from

Alternative 2.

Tri-Colored Bat (Perimyotis subflavus)

Tri-colored bats (also known as eastern pipistrelles) range across the eastern United States and southern

Canada, south into Central America, and west into the central Great Plains. Although this species is

abundant in much of the eastern United States, little is known about summer roost sites (Harvey et al.,


1999). They are considered non-migratory, and remain near their winter caves/mines during the summer.

During summer, female tri-colored bats form small maternity colonies of approximately 20 individuals,

while males roost alone. Summer roost sites for tri-colored bats include caves/mines (often night roosts),

houses, and hollow trees. Tri-colored bats emerge early in the evening to forage at treetop level. Their

flight is erratic, resulting in their resemblance to a large moth. Tri-colored bats utilize a small foraging

area, usually in the forest understory, along riparian corridors, and along wooded edges. They are rarely

found foraging in dense forest or open fields.

Griffith and Gates (1985) found that Coleopterans and Homopterans were present in the stomachs of

more than 50% of the adult male tri-colored bat samples. Other important prey items for the tri-colored

bat were Dipterans, Hymenopterans, and Lepidopterans.

See little brown bat section for effects of Disparlure and Gypchek.

Determination

Based on the information referenced above, there would be no adverse impact to the tri-colored bat from

Alternative 2.

REPTILES

Timber Rattlesnake (Crotalus horridus)

The timber rattlesnake is currently found in widely scattered areas of southern unglaciated Ohio. The

Division of Wildlife describes this species as being a woodland species that utilizes sunlit gaps in the

canopy for basking and deep rock crevices for overwintering (den sites) (ODNR DOW 2016). They

typically eat mice, rats, chipmunks, and squirrels.

A small population of timber rattlesnakes is known to occur on the Athens Unit. This area is not within

any blocks slated for treatment in 2016; however, it is possible that in future years treatments would

overlap with this known population. Since mating disruption pheromone and Gypchek are specific to the

gypsy moth, no effects are expected on timber rattlesnakes.

Determination

All of the treatments are specific to moth and butterfly species. Alternative 2 would have no adverse

impact on timber rattlesnakes.

BIRDS


Bald Eagle (Haliaeetus leucocephalis)

The bald eagle has long been a winter resident in the vicinity of the WNF. Recently several nest sites

have been discovered in the region thus changing their status in the area to resident species. Nests are

usually located in supercanopy trees within ½ mile of large bodies of water. Eagle nests have recently

been reported and confirmed near the WNF from Hocking, Morgan, Washington and Fairfield counties

(Andrews 2016, personal communication). The waterbodies found near the nests are Lake Logan,

Hocking River, Burr Oak Reservoir and the Ohio River. Eagles are usually tolerant of human activity

except during nesting season.

Flights for the gypsy moth spraying are usually conducted when fledglings are in the nest which is

considered a very sensitive time. It is important that the pilots are aware of nest sites while flying low

over a nesting area either while in a treatment block or within their flight path to a treatment block. The

USFWS asks that no flights be flown within 1,000 feet of any nests, since the project will require

multiple aerial passes and not just a single event. The proposed application time occurs during a period

when the bald eagles will be actively feeding young and can be easily startled by approaching aircraft.

Low flying aircraft could also cause premature fledging of young eaglets.

The closest known active bald eagle nest site is approximately 1.5 miles south of one of the areas

proposed for treatment in 2016.


Disparlure (mating disruption pheromone); “There is no evidence that birds are affected by USDA

treatment projects using disparlure.” (USDA FS 2012a, Vol I, Ch 4)

Gypchek: “Few studies are available on birds, and the results of these studies are essentially identical to

those on mammals. The studies indicate exposures to Gypchek at levels that are substantially higher than

those likely to occur in the environment are not associated with any adverse effects (Podgwaite and

Galipeau 1978, Lautenschlager and others 1976). Barber and others (1993) found no indication that

Gypchek is pathogenic to any insect species except the gypsy moth. No adverse effects were observed in

any species tested. Additionally, a recent field study noted no effects in nontarget insects following the

application of Gypchek (Rastall and others 2003). There is no indication that adverse effects are caused

in nontarget insects at any level of exposure.” (USDA FS 2012a, Vol I, Ch 4)

Determination

Based on the information referenced above, there would be no adverse impacts to the bald eagle from

Alternative 2, provided the following mitigations are adhered to.

Mitigations:


1.) The ODA will share the annual treatment target areas with the WNF, so that wildlife biologists

can determine if there are any known eagle nests that should be avoided. If there are known sites,

the WNF will provide location information to ODA.

2.) No flights should be flown within 1,000 feet of any nests, since the project will require multiple

aerial passes and not just a single event. The proposed application time occurs during a period

when the bald eagles will be actively feeding young and can be easily startled by approaching

aircraft.

3.) In the event that any previously unknown nests are found during project implementation both the

USFS and USFWS will be immediately contacted. If any nests are located within a treatment

block, ODA will follow the federal guidelines and leave a buffer around the nest.

Cerulean Warbler (Setophaga ceruleana)

The cerulean warbler is a neotropical migrant and occurs throughout the eastern United States in

summer. It is a species of special interest in Ohio, and eastern Ohio is in the core area of the bird’s

breeding range. Approximately 70% of the cerulean warbler population is concentrated in the North

Cumberland and Ohio Hills physiographic region (Federal Register Volume 67, No. 205, 2002). The

cerulean warbler prefers large tracts of mature deciduous woods. In southeast Ohio, it is found in mixed

mesophytic upland and floodplain forests. Nests are located in the canopy of tall trees. Nesting likely

occurs in Ohio from May through mid-July. They are known to occur throughout all units on the Wayne

NF and are relatively common. Population declines have been documented for this species, especially in

the eastern U.S. (NatureServe 2015).

NatureServe (2016) specifies the following related to prey species:

Cerulean warblers are insectivores, foraging in and about the foliage of deciduous trees for small

arthropods which they capture by gleaning and by sallying (Hamel 1992, Terres 1980, Bent 1953). A

sample of four stomachs taken in Alabama in April 1912 (Howell 1924) contained Hymenoptera

(42%); Coleoptera, including weevils (23%); and Lepidoptera (35%). These are the only quantitative

data on the diet. Warren (1890) mentions a stomach (presumably from a bird taken in Pennsylvania)

that contained fragments of spiders and small beetles. In Nebraska, S. Aughey in June 1865 watched

an adult bring locusts to its young (Robbins, pers. communication).


Disparlure (mating disruption pheromone): There is no evidence that birds are affected by USDA

treatment projects using Disparlure. (USDA FS 2012a, Vol I, Ch 4)

Gypchek: Few studies are available on birds, and the results of these studies are essentially identical to




Gypcheck is pathogenic to any insect species except the gypsy moth. No adverse effects were observed in




in nontarget insects at any level of exposure. (USDA FS 2012a, Vol I, Ch 4)

Determination

Based on the information referenced above, there would be no adverse impacts to the cerulean warbler

from Alternative 2.

Henslow’s Sparrow (Ammodromus henslowii)

Henslow’s sparrows (Henslow’s) are birds that inhabit grassland habitats. On the Athens Unit these

birds are found mainly in reclaimed strip-mined lands. They require large tracts of grassy habitat with a

well-developed litter layer and some standing dead vegetation (Burhans 2002). A few shrubs may be

tolerated and used as singing perches, but if too many are present the Henslow’s will abandon the area.

Hyde (1939) found that food brought to Henslow’s nestlings was predominantly Lepidoptera larvae,

spiders, adult sawflies and grasshoppers. Additional studies by Robins (1971) found that Lepidopteran

larvae made up 35% of food delivered to nestlings.

The Henslow’s sparrow is known to occur within one of the mating disruption pheromone proposed

treatments blocks for 2016. It’s possible that this same area or other potential habitat for the Henslow’s

may be included in a treatment block in the future. Generally, even if large expanses of grassy open

areas are within treatment blocks they are not treated, since gypsy moths (and their caterpillars) do not

inhabit non-forested areas.


Disparlure (mating disruption pheromone): There is no evidence that birds are affected by USDA

treatment projects using Disparlure. (USDA FS 2012a, Vol I, Ch 4)

Gypchek: Few studies are available on birds, and the results of these studies are essentially identical to




Gypcheck is pathogenic to any insect species except the gypsy moth. No adverse effects were observed in



in nontarget insects at any level of exposure. (USDA FS 2012a, Vol I, Ch 4)

Determination


Based on the information referenced above, there would be no adverse impacts to the Henslow’s sparrow

from Alternative 2.

BUTTERFLIES

Northern Metalmark (Calephelis borealis)

The northern metalmark has not been found in Hocking County but has been located in Athens and Perry

Counties (Iftner et al 1992, Parshall 2010, personal communication). Extensive surveys for this species

were conducted in 2014 and 2015 in the Utah Ridge/Bailey’s area (Athens County) of the Athens Unit.

The northern metalmark butterfly was found at four sites in this area. Additional surveys were conducted

in the Stone Church area (2014 – Perry County), in the Irish Ridge area (2015 – Perry County), and in the

Wildcat Hollow area (2014 and 2015 – Morgan County) with no northern metalmarks located. A day

was also spent in the Archer’s Fork area (Washington County) of the Marietta Unit of the Athens Ranger

District to no avail. Parshall (2010, personal communication) reported two known sites, at that time, on

the WNF as being on the Ironton Ranger District. In 2014, Patrick Mercer, Ironton District Wildlife

Biologist, visited one of the past reported sites and was unable to detect any northern metalmarks in the

area.

The currently known sites of the northern metalmark on the Athens Unit are in the area where mating

disruption pheromone was applied in 2015. Coincidentally, the wildlife biologist was doing a survey for

northern metalmarks as the pheromone was being released by the aircraft. The pheromone did contact

northern metalmarks and the biologist with no apparent ill effects. A visit was made to the same site two

weeks later and northern metalmarks continued to be present and nectaring on black-eyed Susans.

Iftner et al (1992) reports that this butterfly is generally found in southern Ohio on south to southeast

facing slopes and road banks that cut through open habitats. In the surveys conducted on the Athens

Ranger District the following was found:

All occupied sites were on brushy roadside slopes that were somewhat shaded in spots with

adjacent forest. One site was directly across from a 6-acre wetland.

The majority of butterflies were found on orange butterfly weed or black-eyed Susans.

Stops were specifically made at open areas (maintained openings and under powerlines) that were

in full sun and contained an abundance of black-eyed Susans and butterfly weed present. No

northern metalmarks were found in these more open areas.

All occupied sites were in the bottoms; none occurred on ridges.

All occupied sites were south-west facing road embankment slopes

The area of known northern metalmark populations are not slated for treatment in 2016; however, it is

possible that this location may be treated in the future with mating disruption pheromone or Gypchek.

NatureServe (2016) reports that a combination of small population size and limited dispersal makes this


species vulnerable to local extirpation. It is also suggested that published information shows the State of

Ohio as being, or have been, a possible stronghold for this butterfly.


Disparlure (mating disruption pheromone): Disparlure does not attract any other insect found in North

America. (USDA FS 2012a, Vol I, Ch 4)

Gypchek: Barber and others (1993) found no indication that Gypchek is pathogenic to any insect species



2003). There is no indication that adverse effects are caused in nontarget insects at any level of exposure.


Determination

Based on the information referenced above there would be no adverse impact to the northern metalmark

from Alternative 2.

Grizzled Skipper (Pyrgus centaureae wyandot)

The grizzled skipper is a small butterfly that is currently known to occur in one location in the State of

Ohio. That site is located on a maintained gas pipeline a near Nelsonville. Historically, the grizzled

skipper was found in Vinton County on April 16, 1971 near Lake Hope State Park in Zaleski State

Forest. The colony was said to be active until 1983 (Parshall 2002). The grizzled skipper is not known

to be located on the WNF within the treatment blocks proposed for treatment in 2016; the known

population lies approximately 2.5 miles from a proposed mating disruption pheromone treatment block

and approximately 15 miles from the proposed Gypchek block. However, it is possible that the known

grizzled skipper site may be included in a treatment block in the future. It should be noted that the site

was treated with mating disruption pheromone in 2015. Due to the species specific nature of both the

mating disruption pheromone and Gypchek, neither treatment product would be expected to cause

adverse effects to the grizzled skipper.

NatureServe (2016) specifies the following related to habitat:

Typical Appalachian habitat is/was shale barrens, pastures and powerlines on south to west facing

shale slopes, always with much bare rock or soil. Key features were plentiful Potentilla canadensis,

the larval foodplant, and nectar flowers, and also some source of moisture such as a streamlet at the

base of the hill, or even deep wheel ruts. See Schweitzer (1989) for more detailed discussion of

habitat. Adults seldom occur more than about 30 meters from woods and sometimes occur in the

woods. Shale barrens and other habitats tend to be surrounded by scrubby oak woodland or forest

with some to a lot of Virginia pine. Oaks in such xeric habitats leaf out late, leaving no canopy for


much of the flight season making these woods less of a barrier to adults than one would expect. When

the trees are bare adults can be found in the forest occasionally.


Disparlure (mating disruption pheromone): Disparlure does not attract any other insect found in North

America. (USDA FS 2012a, Vol I, Ch 4)

Gypchek: Barber and others (1993) found no indication that Gypchek is pathogenic to any insect species



2003). There is no indication that adverse effects are caused in nontarget insects at any level of exposure.


Determination

Based on the information referenced above there would be no adverse impact to the grizzled skipper

from Alternative 2.

3.2 Plants – Federally Threatened and Endangered or Regional Forester Sensitive Species

Alternative 1 - No Action

This alternative would result in no application of mating disruption pheromones or Gypchek and;

therefore, would have no direct impacts on any Federally-listed threatened or endangered (T & E) or

Regional Forester Sensitive (RFSS) plant species on the WNF. This alternative over the long term could

result in overstory defoliation of oaks and other tree species, changes to forest floor light intensities and

eventual changes in forest structure if oaks die out and their percentage cover in the WNF decreases.

Loss of overstory trees would increase light intensities to the understory for short periods of time until

tree species not susceptible to the gypsy moth grew into new spaces. Other changes to forest ecosystem

function (erosion, soil chemistry) could have indirect impacts to T & E and RFSS, but what those might

be is unknown. Choosing the No Action Alternative would allow gypsy moth populations to spread,

leading to greater wide-spread, ecosystem–level impacts. (Botany Resource Input, Project Record).

Alternative 2 - Proposed Action

Mating disruption pheromone and Gypchek are both non-toxic to plants. Mating disruption pheromone

does not kill moths or butterflies, so there would be no reduction in potential pollinators. Gypchek does

kill gypsy moth caterpillars. Since Gypchek is specific to gypsy moth caterpillars, which are not known


to pollinate any of the T & E or RFSS plants, there would be no reduction in potential pollinators.

Therefore, this alternative would have no impact on RFSS. (Botany Resource Input, Project Record).

3.3 Irreversible and Irretrievable Commitment of Resources

Irreversible commitments of resources results in the permanent loss of nonrenewable resources, such as

minerals or cultural resources; resources that are renewable only over long periods of time, such as soil

productivity and removing old growth forests. An irretrievable commitment of resources is one which a

resource product or use is lost for a period of time while managing for another. Implementing Alternative

2 would not result in a change in land use or in an irreversible commitment of ecological resources.

3.4 Summary

The biological, chemical, and physical consequences of the use of mating disruption pheromone and

Gypchek, when applied properly, are minimal. A properly conducted treatment program would

accomplish the objectives of slowing the spread of gypsy moths in southern Ohio.

4.0 LIST OF AGENCIES AND PERSONS CONSULTED

United States Department of Agriculture

Amy Hill, Forest Service, Forest Health Protection

Louis Iverson, Forest Service, Northern Research Station

United States Department of Interior

Jennifer Finfera, Fish and Wildlife Service

Ohio Department of Agriculture

Dave Adkins

Brian Burke

Ohio Department of Natural Resources

Dave Graham, Division of Wildlife

Jenny Norris, Division of Wildlife

Mike Reynolds, Division of Wildlife

Tim Parrett, Division of Wildlife

Ohio Department of Mineral Resources Management

Mary Ann Borch


Ben McCament

West Virginia Division of Natural Resources

Robert Beanblossom

5.0 LIST OF PREPARERS

Name: Rachel Orwan

Position: Forest NEPA Planner – Wayne National Forest

Name: Lynda Andrews

Position: Athens Ranger District Wildlife Biologist – Wayne National Forest

Name: Gerald Scott

Position: Zone Botanist – Wayne National Forest

Name: Matt Karrer

Position: Acting Hydrologist – Wayne National Forest

Name: Latasha Lyte

Position: Soil Scientist – Wayne National Forest

Name: Ann Cramer

Position: Forest Archaeologist – Wayne National Forest

6.0 LITERATURE CITED

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Biologist, Wayne National Forest. January 14, 2016.

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APPENDIX A: Standard Operating Procedures

Mitigating measures are designed to reduce adverse environmental effects that might result from

conducting the proposed action (aerial application of pesticides). Specific safety procedures and

guidelines are presented in the 2013 STS Project Work, Safety, and Security Plans prepared by the ODA

and the USDA Forest Service Project. Copies of the Work, Safety, and Security Plans are available from

the address found on the cover page of this EA.

Application Constraints

By adhering to the following procedures during aerial application, a safe, consistent and effective spray

project can be implemented that also minimizes spray drift.

Procedures that apply to all treatments

Personnel from the ODA would select a treatment time to coincide with suitable foliage

development and the most vulnerable stage of the gypsy moth.

A private aerial contractor under the supervision of government personnel would conduct pesticide

spraying and government personnel would inspect and calibrate the contractor’s application

equipment prior to treatment.

No applications would be made over open water.

Personnel on the ground in the treatment block would continually monitor application conditions

and advise the project supervisor on weather conditions, foliage development, and insect

development.

The observation aircraft would maintain communications between ground personnel in the spray

block and the personnel at the base. The observation pilot will inform the spray pilot when

environmental conditions, such as inversions, wind, or rain requires that spraying is discontinued.

The observation aircraft will also assist the application aircraft pilot on potential aerial hazards.

Aircraft used in the application of insecticides are required to be equipped with Differential Global

Positioning System (DGPS) to assist the pilot in locating treatment blocks, identifying block

boundaries, and ensuring even coverage throughout the block.

Application pilots are required to conduct a pre-treatment flight of the proposed treatment areas to

become familiar with the treatment boundaries, restricted sites, or potential hazards. Topographic

maps would be provided to the application pilots and/or observation pilots to assist in identifying

boundaries, restricted sites, and hazards.

Pilots would have radio communication with each other and with the operations base to assure

compliance with all application constraints and safety requirements.

The larvacide would be applied according to label directions. All label warnings and restrictions

would be strictly followed by the applicator.

Weather conditions during application of mating disruption pheromone

Application of mating disruption would be suspended when winds are above 15 mph, foliage is

dripping wet, or the threat of rain is imminent.

Weather conditions during application of Gypchek

Applications would be made when wind speeds are less than 10 mph, temperatures are between 35

and 75oF, and relative humidity is above 60%.

Foliage must be dry and no threat of rain should exist for one hour following application to ensure

good drying time for the droplets and prevent wash off.

Application would be suspended if thermal inversion conditions cause the spray to rise during

application.

Height of the application aircraft would range between 50 and 100 feet above treetop.

Human health precautions

Several precautions are used in the program to minimize exposure of the people handling the insecticide

during loading operations and those in the treatment areas.

At the loading site, standard pesticide mixing and handling precautions would be followed as

specified on the product label.

Letters and public notices were used to inform the public about the proposed treatments.

News release would be sent to the media prior to treatments so residents within the treatment blocks

that may be hypersensitive or immune-compromised can take common sense precautions such as

avoiding exposure to the spray material, leaving the area if they believe they are sensitive to the

pesticide, and removing articles such as drying clothes and children’s toys from exposure to spray.

2016 gypsy moth slow the spread treatment...

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