PUBLIC STATEMENT REGARDING THE
LOWER CAPE MAY MEADOWS – CAPE MAY POINT
ENVIRONMENTAL RESTORATION PROJECT
(August, 2004)

As part of its Lower Cape May Meadows – Cape May Point Environmental Restoration Project, the U.S. Army Corps of Engineers is proposing to apply herbicide to remove Phragmites australis in order to establish other emergent wetland vegetation types in the area.  New Jersey Audubon Society (NJAS) supports responsible stewardship efforts which benefit wildlife and wildlife habitat.  Proper, long-term habitat management of the Cape May Meadows area could provide improved habitat for wildlife and rare plant species.

The Cape May Migratory Bird Refuge and Cape May Point State Park are of immense value to rare plant species, endangered and threatened wildlife and large populations of migratory birds, butterflies, and dragonflies.  NJAS believes it is crucial that management practices such as Phragmites eradication in these areas pay strict attention to potential impacts such practice may have on wildlife and habitats. 

NJAS has on several occasions requested assurance from the Corps that this project will not cause significant adverse impact on non-target flora and fauna in the area.  We remain unconvinced that this project includes sufficient wildlife safeguards, monitoring requirements or evaluation parameters.   

We will continue in our ongoing efforts to address the ecological impacts posed by this project and other Phragmites control projects throughout the state. 

A complete statement of New Jersey Audubon's position on the project may be found in the Conservation Opinion that follows, originally posted in September, 2003.

Information provided by the Corps on the project may be found at: www.nap.usace.army.mil/Projects/LCMM/index.htm*

(* This link is provided as a courtesy to the reader. NJAS is not responsible for information provided by the Corps.)

NJAS Opinion: September, 2003

Developed by:
            Matt Dufort, Conservation Associate
            Eric Stiles, Vice President for Conservation & Stewardship
            Dr. David Mizrahi, Vice President for Research

Synopsis

In general, New Jersey Audubon Society (NJAS) and its 20,000 members support responsible land stewardship efforts which benefit wildlife and wildlife habitat.  The Cape May Migratory Bird Refuge (Refuge) and Cape May Point State Park (State Park) are of immense value to rare plant species, endangered and threatened wildlife including the Southern Gray Treefrog, and large populations of migratory birds, butterflies, and dragonflies.  NJAS believes it is crucial that management practices in these areas pay strict attention to potential impacts on these wildlife and habitats.

The Refuge and State Park contain a mixture of woody vegetation, open water, and large areas of herbaceous emergent wetland.  Much of this wetland is now dominated by Phragmites australis (hereafter Phragmites).  As part of its Lower Cape May Meadows – Cape May Point Environmental Restoration Project, the U.S. Army Corps of Engineers (USACE) proposes to remove Phragmites from the Refuge and State Park and establish other emergent wetland vegetation types.

The long-term habitat management in these areas could provide improved habitat for wildlife and rare plant species.  However, NJAS is concerned about other impacts that may result from the planned Phragmites control.

The proposed project includes aerial and ground spraying of stands of Phragmites with the herbicide Rodeo and a surfactant (USACE 2003).  The Phragmites stands will then be burned or mowed to remove standing vegetation and create site conditions conducive to the establishment of other plant species.  These procedures have the potential to impact wildlife and plant populations.  NJAS is concerned that these effects are not being adequately addressed.

Wildlife Use of Phragmites

Phragmites stands are viewed by many as low-quality or degraded wetlands.  However, the true value of Phragmites to wildlife has been seriously underestimated.  Phragmites does provide significant habitat for wildlife, including several threatened and endangered bird species (Kane 2000).  Kane (2000) reported that 32 New Jersey bird species utilize Phragmites patches for nesting.  Many additional avian species will use these patches for roost and cover sites.  Additionally, the structure of Phragmites is suitable for perching Southern Gray Treefrogs and insects.  Phragmites patches can provide important habitat as part of a larger mosaic of wetland habitats.  Removal of Phragmites will reduce habitat for several wildlife species in the Refuge and the State Park, including Least Bittern, a state-listed species of special concern.

Variables Affecting Impacts of Herbicide Application

A number of factors can affect the magnitude of herbicide application impacts on wildlife and plant species.  The type of treatment to be used (e.g., aerial spraying, ground vehicle backpack sprayer, hand application) is a very important variable.  Each method has its own costs and benefits, and the method or methods selected will largely determine impacts on flora and fauna.  For example, aerial spraying allows quick application of herbicide to large areas, but increases exposure for non-target species.

Due to timing of wildlife migration and the annual life cycles of animals and plants, many species are much more susceptible to harm or disturbance at certain times of year.  For example, reptiles and amphibians would probably be affected less during the winter, when they are hibernating.  This seasonal variability in effects must be taken into account when setting treatment dates.  The between-year schedule for treatment is another factor to consider.  A treatment used once may have less impact than the same treatment applied year after year.  However, breaking a project into phases can reduce overall impacts by providing some refugia for wildlife and allowing for identification of problems before treatment of the entire area.

Direct mortality is the most obvious measure of herbicide and surfactant impacts on flora and fauna.  However, less apparent effects can also occur, including damage to an organism’s ability to grow or reproduce.  These sub-lethal effects can also reduce a population’s viability.

Means of Treatment

The current plan for Phragmites control in the Refuge and State Park includes spraying with the glyphosate-based herbicide Rodeo and a surfactant, followed by controlled burning or mowing to remove standing Phragmites (USACE 2003).  Large stands of Phragmites will be sprayed from a helicopter.  Smaller patches or areas close to known significant populations of rare plants will be treated by spraying from a low-pressure ground vehicle, backpack sprayers, or hand application.  The burning plan will be developed and implemented by the New Jersey Forest Fire Service, in coordination with USACE.  Mowing may be substituted for burning, but would likely be less effective in allowing growth of native plants because it does not remove the biomass from the site.

Timing of Herbicide Application

NJAS requested information from USACE regarding the planned timing for herbicide application.  The manufacturer of Rodeo recommends that Phragmites be treated during late summer or fall months for best results.  However, the effectiveness of the spraying on Phragmites must be weighed against impacts on flora and fauna.

September and October, the anticipated dates for spraying (USACE 2003), coincide with peak bird, butterfly, and dragonfly migration and prime season for birders.  This is also before all reptiles and amphibians have entered winter dormancy.  The USACE should consider conducting the spraying at a time when it may have fewer negative impacts on non-target species.  NJAS has requested additional information on the seasonal variation in effectiveness of this treatment on Phragmites.

Schedule and Long-term Management

Phragmites can quickly colonize new areas and become a competitive dominant species.  After removal from a site, it will continue to recolonize from remnant and neighboring populations and the existing seed bank.  Successful control of Phragmites requires first changing the site conditions to inhibit its establishment, then removing existing Phragmites stands.  This project focuses primarily on the second step, with inadequate attention given to the first.

The restoration project includes some measures aimed at changing site conditions to inhibit Phragmites.  Occasional incursion of seawater has created brackish conditions that strongly favor Phragmites over native freshwater wetland plants.  The USACE restoration project involves augmenting the beach dune and water control structures to reduce seawater incursion.  However, it is not clear that these measures will be effective in reducing salinity or inhibiting Phragmites growth.

The planned Phragmites treatment will be broken into two phases, with approximately half the project area to be treated in 2003-2004 and half in 2004-2005 (USACE 2003).  Treatment techniques for Phase II will be adapted based on information garnered during phase one.  This could prevent negative outcomes from impacting the entire Project Area and provide refugia for wildlife to utilize.

Without sufficient changes to site conditions, Phragmites will likely recolonize the site, and an ongoing control effort will be required for many years beyond the current treatment.  USACE will adopt an adaptive management program to control isolated individuals or stands of Phragmites for five years following initial treatments (USACE 2003).  Additional control efforts will also be necessary beyond that five year program.  Accordingly, the proposed treatment should be viewed as part of a management plan, not a short-term restoration project.

Rare Plant Species

New Jersey Audubon requested and received information from USACE on the potential impacts to rare plant species and plans to protect these rare plants.  The Refuge and State Park support at least 11 plant species listed as state endangered or state species of concern (USACE 2003).  Rodeo, the herbicide which is proposed for use in Phragmites control, has the potential to do serious damage to these rare plants.  The manufacturer states that “minute quantities of this product can cause severe damage or destruction to the… plants or other areas on which treatment was not intended” (Dow Agrosciences 2002).

Some populations of rare plants, particularly isolated populations within large stands of Phragmites, will undoubtedly be impacted by the spraying (USACE 2003).  The planned herbicide application does include several procedures to limit damage to rare plants.  Significant populations of rare plants will be marked, and buffer zones established around them where aerial spraying will not occur.  Herbicide application techniques in these buffer zones will be varied to attempt to minimize exposure of rare plants to the herbicide.  High priority species may be covered with tarps during spraying.  Any spraying must also take measures to minimize drift of the herbicide into neighboring areas.

Seeds and whole plants of these species are being collected, and the plants are also being propagated at local nurseries to provide a source for replanting the area after herbicide spraying (USACE 2003).  These sources could aid in mitigation if negative impacts to rare plants do occur.  However, ex-situ propagation and replanting are not guaranteed methods to re-establish these species, and may not prove effective.

Wildlife Impacts

The Project Area includes a significant breeding population of the state endangered Southern Gray Treefrog (Zappalorti et al. 2002).  This species was detected at 17 of 25 survey sites in Lower Cape May Meadows and Cape May Point during spring 2002.  This represents an important concentration of this endangered species.  Zappalorti et al. (2002) recommended Phragmites removal to maintain habitat for Southern Gray Treefrog.  However, this management must be done at a time and in a manner that limits negative impacts on the frogs.  Southern Gray Treefrogs would be least susceptible during their hibernation period, typically mid October to March.  Within their active season, treefrogs would be less vulnerable in late summer or fall, after breeding is completed and larvae (tadpoles) have matured to adults.  However, treefrogs are likely to be occupying Phragmites at this time, and risk for direct exposure to the herbicide and surfactant could be high.

During fall migration, the Project Area also supports some of the largest concentrations of birds, butterflies, and dragonflies on the Atlantic coast.  Any management practices in this area must carefully address potential impacts to these wildlife concentrations.

NJAS requested that the USACE detail expected impacts to wildlife, including documented ecotoxicological effects of the proposed herbicide treatment on birds, amphibians, reptiles, butterflies, and odonates (dragonflies and damselflies).  Information provided to us indicates that Rodeo is practically non-toxic to birds and slightly toxic to aquatic wildlife (Dow Agrosciences 2000).  However, there is no specific information on its effects on lepidopterans, odonates, reptiles, or amphibians.

We have not received detailed information on the toxicity of the surfactant to be used or the combination of herbicide and surfactant.  The active ingredient in Rodeo is much more toxic to aquatic animals in acidic water, and the surfactant proposed for use is an acidifier (SERA 1996; Loveland Industries 1999).  This combination could result in increased impacts to aquatic wildlife.

Human Visitors

Rodeo may present an inhalation risk to humans, and can cause eye irritation (Dow Agrosciences 2000).  NJAS is concerned that the anticipated dates of September or October for herbicide spraying coincide with a period of peak ecotourism visitors in the Cape May area.  Cape May is one of the top ecotourism destinations in North America, and draws hundreds of thousands of visitors annually.  The Cape May Migratory Bird Refuge and Cape May Point State Park, both within the Project Area, are two of the most popular sites for ecotourists.  The documents NJAS has received do not detail measures for minimizing impacts on people.

Post-Treatment Landscape

The Refuge and State Park wetlands are currently dominated by Phragmites.  Therefore, removal of Phragmites will involve significant changes to the local plant communities and landscape.  Plans for revegetation of the area after Phragmites removal are currently vague and inadequate (USACE 2003).  These plans must be more thoroughly described if quality habitat is to be established after treatment.  Additionally, all plants used in replanting should be of local genotypes, not from commercial stocks.

As addressed above, without sufficient changes to create conditions that inhibit Phragmites establishment, removal is unlikely to prevent recolonization.  A likely scenario for the treatment area is that Phragmites control will need to be done every year, though perhaps less intensively than in the first few years.

Monitoring and Evaluation of the Project

Documents provided to NJAS by USACE state that a detailed monitoring plan will be developed prior to implementation of the Phragmites control (USACE 2003).  To date, NJAS has not received this monitoring plan.  This component will provide critical information to evaluate the project’s success and revise management techniques.

None of the documentation received by NJAS states criteria or parameters for evaluating success or failure of the project in removing Phragmites, establishing native plant species, or safeguarding existing rare plants and wildlife, including endangered species.  Parameters for assessing success should be clearly defined before the project proceeds.

Summary

This project could potentially create a significant amount of valuable habitat in an area that is critically important to wildlife.  However, the proposed management strategies may negatively affect significant populations of wildlife, including endangered species, and rare plants.  Monitoring and evaluation plans must be developed before implementation to track and assess the progress of the project.  It must also be recognized that this treatment is the beginning of a long-term management effort, not a short, two-phase restoration project.

It is important to note that Phragmites stands do provide habitat for a variety of wildlife species.  Patches of Phragmites are valuable within a mosaic of habitats.  Complete removal of Phragmites from the Refuge and State Park could eliminate habitat for several species, unless structurally similar vegetation is established within a reasonable timeframe.

NJAS believes that additional attention should be given to expected impacts on wildlife and human visitors, timing of the herbicide application, and strategies for replanting and restoring the area after Phragmites removal.  Absent this additional information, New Jersey Audubon has serious reservations and concerns about the Phragmites removal project as planned.

Literature Cited

Dow Agrosciences. 2000. Rodeo herbicide. Material Safety Data Sheet. Dow Agrosciences LLC, Indianapolis, Indiana.

Dow Agrosciences. 2002. Rodeo herbicide. Specimen Label. Dow Agrosciences LLC, Indianapolis, Indiana.

Kane, Richard. 2000. Phragmites use by birds in New Jersey. Records of New Jersey Birds 26: 122-124.

Loveland Industries. 1999. LI 700. Material Safety Data Sheet. Loveland Industries, Inc. Greeley, Colorado.

Syracuse Environmental Research Associates (SERA). 1996. Selected commercial formulations of glyphosate – Accord, Rodeo, Roundup, and Roundup Pro. Unpublished report submitted to United States Department of Agriculture, Animal and Plant Health Inspection Service, Riverdale, Maryland

United States Army Corps of Engineers (USACE). 2003. Draft rare plant survey and protection measures report for the Lower Cape May Meadows – Cape May Point Environmental Restoration Project, Cape May, New Jersey. USACE, Philadelphia District.

Zappalorti, R.T., D.W. Schneider, and M.P. McCort. 2002. Cope’s Gray Treefrog (Hyla chrysoscelis) surveys at the Lower Cape May Meadows, Cape May County, New Jersey. Unpublished report submitted to USACE, Philadelphia District.