Recommended:

            Dr. John A. Latschar, Superintendent                                                   Date

            Gettysburg National Military Park

Certified for Technical Adequacy and Servicewide Consistency:

            Chief, Water Resources Division                                                          Date

            Approved:

            Mary Bomar, Regional Director                                                            Date

Northeast Region

STATEMENT OF FINDINGS

Introduction

The National Park Service (NPS) has prepared and made available for public review a General Management Plan/Environmental Impact Statement (GMP/EIS) that sets forth the basic management philosophy for Gettysburg National Military Park (GNMP) and provides a framework for future decision making.  A Record of Decision was signed on November 23, 1999.  The GMP/EIS and Record of Decision provide the compliance necessary to implement the actions outlined in the plan. 

The mission of GNMP is: To preserve and protect the resources associated with the Battle of Gettysburg and the Soldiers’ National Cemetery, and to provide understanding of the events that occurred here, within the context of American history (DOI 1999).  

Executive Order (EO) 11990 (“Protection of Wetlands”) requires the National Park Service and other Federal agencies to evaluate the likely impacts of their actions on wetlands.  The objectives of the EO are to avoid, to the extent possible, the long-term and short-term adverse impacts associated with the occupancy, modification, or destruction of wetlands. NPS Management Policies (2001) and Director’s Order 77-1, “Wetland Protection” (NPS 2002) reiterates the importance of safeguarding wetlands and provide agency-specific guidance for complying with the EO.   The purpose of this Statement of Findings is to present the rationale for undertaking a project with potential adverse impacts to wetlands and to document the anticipated effects.

Proposed Action

The purpose of the proposed action is to rehabilitate portions of the battlefield that figured prominently within the major battle action areas.  At the time of the battle, the project areas consisted of fields, pasture, orchards and meadows.  The openness that characterized this area in 1863 persisted until the 1930s.  However, in the last 60 to 70 years, woods have established in these once open fields. This action would remove maturing trees (60 to 80 feet tall) and replace them with meadows.  Within riparian corridors, and areas that were historically thickets, the maturing trees would be replaced with a woody buffer consisting of low growing native trees and shrubs species(less than 15 feet).  Removal of the non-historic vegetation will restore the historic avenues of approach and fields of fire that were important to the outcome of the battle on July 1-3, 1863. 

The GMP/EIS selected rehabilitation of both the significant large-scale and small-scale elements of the park’s historic landscape, including the pattern of open fields and wooded areas.  This will restore the fields of fire and the views that prevailed during the battle and allow the visitors to understand how the armies moved across the landscape.

Establishing permanent cover (versus crop fields or pasture) and woody buffers in riparian areas, regardless of historical accuracy, was recommended by the GMP/EIS and implemented through the 2003 Wetland Statement of Findings (SOF).  The 2003 SOF considered the potential impacts to wetlands within the first phase the parks’ landscape rehabilitation.  The 2003 wetland SOF used aerial photography from the United States Fish and Wildlife Services (USFWS) National Wetland Inventory maps.   The aerial photography provided the base for which to begin looking at wetlands within the project areas.  The boundaries of existing wetlands were delineated using the standard USFWS wetland delineation methods found in Cowardin’s Classification of Wetlands and Deep Water Habitats of the United States.  The landscape rehabilitation actions in relationship to wetlands were then reviewed by NPS Water Resources Division to determine mitigation actions.  The methods employed in the 2003 Wetland SOF where applied to the current Wetland SOF and are described in the following text.  The GMP/EIS suggested mitigation to limit erosion and to meet the guidelines set forth by NPS for riparian corridors within the Chesapeake Bay watershed. 

Alternatives Considered by the General Management Plan

The GMP/EIS defined four alternatives for the management of Gettysburg National Military Park and the Soldiers' National Cemetery.

Alternative A would have continued the existing management direction at the park and constituted the no-action alternative.  The alternative represents continued response to visitor use and resource management issues but proposed no changes in management direction or facilities.

Alternative B proposed the rehabilitation to reinstitute the pattern of open fields and wooded areas present in 1863 in the park’s major battle action area while managing contemporary agricultural uses to protect historic landscapes and resources.  This alternative would have moved most park facilities, including the Visitor Center and Cyclorama Center, to sites outside the major battle action Areas, enabling rehabilitation of the battle landscape at the sites of these facilities.  These actions would have improved interpretation park wide, and placed the events of Gettysburg in the larger context of the Civil War and the Gettysburg Campaign.

Alternative C, the selected alternative, incorporated nearly all of the elements of Alternative B, adding the rehabilitation of small-scale landscape elements and structures within the major battle action area in order to tell the stories of individual units and soldiers.

Alternative D incorporated all of the elements of Alternatives B and C, but added rehabilitation of large and small-scale features throughout the park.

Alternatives Considered for non-historic Tree Removal

One Phase Operation

This method would remove the non-historic trees in one operation followed immediately by planting shrubs and low growing tree seedlings in the riparian corridors. Historic fences would be replaced to exclude cattle. This would be the fastest approach and would be the most drastic change to the ecosystem and the landscape. While this would be the quickest alternative, it would also be the most disruptive to plant and animal communities.  It has the greatest risk of failure due to inadequate weed control or unfavorable weather conditions.

Sheltered Operation

This method would selectively remove non-historic trees, plant shrubs and low growing trees across the entire proposed action area88.65 acres, and replace historic fences in order to exclude cattle in year one.   As soon as the shrub community was established, the remaining trees would be removed.  This would be about three years after the initial removal and planting.  The selective cut would be designed to remove those trees that would limit the survival and growing of the planted shrubs.  It would also gradually change the landscape from its present condition to the historic condition.  Subsequent shrub planting would be used to augment any first year failures.

Multi-Phased Operation (Preferred Alternative)

This method is a combination of the two previous alternatives considered.   

This multi-year approach would reduce the impact of the tree cutting operation on plant and animal species, and is the mitigation included by NPS in the GMP/EIS.  In addition, this approach has the greatest flexibility in regards to how the tree removal activities can be designed.  It will give NPS managers a chance to review the progress of shrub plantings and make adjustments as needed to ensure successful establishment of native woody thickets and buffers.

Site Description

The project area encompasses approximately 56-acres (Overview Map).   Within the project area potential wetland impacts total 23.52-acres of palustrine and riverine wetland.  All tributaries are first order streams within the Potomac River and Chesapeake Bay watersheds. This project will result in no net loss of wetlands.  However, along specified stream corridors overstory canopies will be reduced in height from average of 75-feet to 15-feet.

In total, there are 5 wetland areas evaluated within this document.  Wetland areas may be contained within a single project area or within a group of project areas.  For the purposes of this document the name of the tributary and its’ associated wetland and project area numbers are combined to create 5 individual wetland ID numbers.  The wetland ID numbers are as follows.

Blocher Run (1).   Blocher Run creek basin stretches 1,975 linear feet.  The Corwardin et al (1979) classification is riverine, intermittent, streambed, mud, seasonally flooded (R4SB5C).  The associated wetland totals 2.07 –acres and is classified as a palustrine emergent, broad-leaved deciduous, scrub-shrub, seasonally flooded (PEM/SS) (Cowardin et al. 1979.  217-acres are drained into the Blocher creek basin. 

Historically, the “small tributary of Rock Creek drained the fields of the McClean and Poor Farm properties.  Located along and forming the south boundary of the pre-battle (1820s) Blocher farm, this tributary provided the water source to power cooper and wheelwright shops located on the farm along the Carlisle Road.  The run, not deep, follows an east-west direction, flowing in an eastward direction.  During the battle, the run and its accompanying wet swale became an obstacle during Confederate attacks against the Union Eleventh Corps on the first day of the battle.  The run follows the historic route and seems to retain historic associated wetlands that affected the movement of troops in 1863.”  (National Register, 2004).

E. Branch of Plum Run East (2).   The E. Branch of Plum Run East at Calvary Field stretches 808 linear feet through the project area.  The Cowardin et al (1979) classification is riverine, intermittent, streambed, mud, seasonally flooded (R4SB5C).  The associated wetland totals 0.91 –acres and is classified as a palustrine persistent, emergent, non-tidal, seasonally flooded (PEM1C) (Cowardin et al. 1979).   Approximately 129-acres are drained into the E. Branch of Plum Run East.

Historically the open farm fields at East Cavalry Field “provided avenues of approach for both Union and Confederate cavalry on July 3, and both sides fired artillery across these open fields against each other.  The comparatively large size of the fields permitted rapid and massed movement by mounted cavalry units from both sides.  These fields have remained in cultivation since the time of the battle.  Field patterns have remained static as well, and hedgerows growing along the historic fence lines yet define each historic field.  Commemorative-era United States Cavalry Avenue and Gregg Avenue traverse the fields of the Lott farm and several Union monuments, tablets, and cannon occupy those avenue corridors.” (National Register, 2004).

N. Branch of Pitzer Run (3).  The N. Branch of Pitzer Run stretches 1,380 linear feet through the project area.  The Cowardin et al (1979) classification is riverine, intermittent, streambed, mud, seasonally flooded (R4SB5C).  The associated wetland totals 10.10 –acres and is classified as a palustrine emergent, broad-leaved deciduous, scrub-shrub, seasonally flooded (PEM/SS) (Cowardin et al. 1979).  Approximately 333-acres are drained into the N. Branch of Pitzer Run.

Historically, this area was part of the John Horting farm.  “The open farm field was located adjacent to, and immediately west of, McMillan Woods.   It was occupied by various Confederate brigades throughout the battle behind the Confederate artillery on Seminary Ridge.  McMillan’s wood and the western slope of Seminary Ridge screened these brigades from enemy observation and in part provided some cover from Union artillery fire directed at Confederate batteries. Woods have encroached on the majority of this field.  It was the site of CCC Camp No. 2 and World War II-era camps.  It has been the site of the park’s organized youth campground since the 1960s.” (National Register 2004).

Stevens Run (4).  Stevens Run stretches 2,535 linear feet through the project area.   The Cowardin et al (1979) classification is riverine, intermittent, streambed, mud, seasonally flooded (R4SB5C).  The associated wetland totals 8.23–acres and is classified as a palustrine emergent, broad-leaved deciduous, scrub-shrub, seasonally flooded (PEM/SS) (Cowardin et al. 1979).  Approximately 255-acres drain into the area.

Historically, these fields where part of the McMillan farm. “The McMillan property had three farm fields not otherwise occupied by orchard or tree nursery. These fields were located on the crest and along the eastern slope of Seminary Ridge. They were just forward of the Confederate battle line from the evening of July 1 until the retreat of the army on July 5. They were crossed and recrossed throughout this duration by skirmishers, sharpshooters and picket reserves of the Confederate army, most times while under fire.  During Confederate attacks on July 2 and July 3, various brigades crossed these fields to reach positions in Long Lane and to assault Union positions on Cemetery Ridge and Cemetery Hill.  All three of these fields appear to have been in some type of grasses or grains during the battle, providing little cover for those occupying or crossing these fields but alternately providing excellent fields of fire across their open expanses.  Two of these fields, the southernmost, are in cultivation.  Woodland encroaches into the western edge of the southernmost field and a nonhistoric horse trail crosses the western edge of both of these fields.  The northern field, west of the McMillan farm buildings has grown into a densely wooded pasture, with deciduous and cedar trees encompassing its historic boundaries.  Historic fields of observation and avenues of approach have therefore been compromised.” (National Register, 2004).

Willoughby Run (5).  Willoughby Run stretches approximately 546 linear feet through the project area.  The Cowardin et al (1979) classification is riverine, intermittent, streambed, mud, seasonally flooded (R4SB5C).  The associated wetland totals 2.21–acres and is classified as a palustrine emergent, broad-leaved deciduous, scrub-shrub, seasonally flooded (PEM/SS) (Cowardin et al. 1979). Approximately 2,978-acres are drained into the project area.

Historically, Willoughby Run,  a tributary of Marsh Creek, runs in a north-south direction between Herr’s and McPherson’s Ridges from the Hagerstown Road to the Mummasburg Road.  “The water, the banks, and the intermittent vegetation that followed its watercourse became an obstacle to the attacking forces on July 1.  The run impeded the advances of the Confederate infantry in the successive attacks it made against Union defensive positions on the first day’s battle. In the latter phases of the first day’s battle, Union forces used the natural declivity (slope) of the course of Willoughby’s Run to provide cover and concealment as they awaited Confederate artillery shelling and infantry attacks.  The run follows its historic course through the park and, since it is weather-dependent for its water, maintains its seasonally changing appearance.”  (National Register, 2004).

The following table shows the common and scientific designations of dominant plant species at the five wetland sites (Tiner, 1988).

Dominant  Vegetation		Wetland Identification Number
Common Name	Scientific Name	1	2	3	4	5
pin oak	Quercus palustris	x	x	x	x	x
swamp white oak	Quercus bicolor	x	x	x	x
american elm	Ulmus americana			x	x
red maple	Acer rubrum			x	x	x
sycamore	Plantanus occidentalis					x
multi-flora rose	Rosa multiflora		x	x	x	x
alder	Alnus sp			x	x	x
box elder	Acer negundo			x	x	x
silky dogwood	Cornus amonmum	x
n. arrowwood	Viburnum recognitum	x
reed canary grass	Phalaris arundinacea	x
wool grass	Scripus cyperinus	x	x	x	x	x
joe-pye weed	Eupatorium maculatum	x	x	x	x	x
jewel weed	Impatiens capensis	x	x	x		x
arrow-leaved tear thumb	Polygonum sagittatum	x	x	x	x	x
soft-stemmed bulrush	Scripus validus		x	x	x	x
sort rush	Juncus effuses		x	x	x	x
pink smartweed	Polygonum pensylvanicum		x	x	x	x
skunk cabbage	Symplocarpus foetidus			x
rice rut grass	Leersia oryzoides			x	x
false nettle	Boehmeria cylindrica			x	x
sphagnum	Sphagnum sp.			x	x
sensitive fern	Onoclea sensibilis			x	x	x
cinnamon fern	Osmunda cinnamomea					x
narrow leaved sunflower	Helianthus angustifolius					x
bedstraw	Galium timonium					x

Mitigative Measures

Any tree deemed to be a witness tree (a tree or sapling that had the potential to be present during the time of the battle and is present today) would be retained and protected in the project area.  Tree removal in wetlands will be done by chainsaws and activities will be timed to minimize any impacts on wildlife species and wetlands (generally occurring after the ground has frozen or during dry periods.)  In areas where cattle have been removed over the past three years there will likely be an increase in production of autochthonous (native plant or animal) organic matter added to the stream since the current bare understory will be replaced with shrubs and herbaceous species (Dewalle1998).

Surveys of the flora (Kunsman 2005) and fauna (Van Fleet and Kirkland 1995) were conducted to evaluate the effects of the proposed tree removal.  No federally listed species were documented. The reports also concluded that the availability of other numerous woodlots nearby provide habitat opportunities for any wildlife species that might be displaced by the vegetation removal.  Additionally, removal of cattle from riparian zones would be beneficial to both the vegetation communities and water quality.

Compliance

Clean Water Act Section 404

The proposed actions have the potential for incidental impacts to waters of the United States as defined by the Clean Water Act and are therefore subject to review by the U.S. Army Corps of Engineers (COE).  The Clean Water Act Section 404 regulates the discharge of dredged or fill material into the waters of the United States.  This project proposes no fill or dredging of any stream.  Stream crossings will be avoided when possible.  However, in the event of any stream crossing metal plates will span the width of the stream, from bank to bank, and all equipment and debris will be transported across the metal plates.  This will reduce the potential for incidental sediment eroding into the streams.

Erosion and Sedimentation Control Plans will be completed to determine suitable landings or areas on the ground where trees will be temporarily stored while awaiting removal from the site.  Suitable landings will be determined by soil type and natural hydrology of the project area.  Stream crossings are not recommended, however in the event of a stream crossing metal/steel plates will be used to minimize the potential impacts to streams.

National Environmental Policy Act

This Statement of Findings for Executive Order11990 in conjunction with the parks’ 1999 General Management Plan and Environmental Impact Statement completes the requirements of the National Environmental Policy Act for this project.

Conclusion

This project will result in no net loss of wetlands; however, the overstory canopy will be reduced from 60- to 80-feet to 15 feet or less.   Although the wetlands are not being filled and the wetland hydrology is not being altered, replacement of the wetland forest with a scrub-shrub canopy will diminish some functional values.  Removal of the trees will reduce the opportunity for adding large woody debris to the stream channels, which is an important component of a healthy stream system. The loss of trees will eliminate canopy cover, nesting, and food sources used by some wildlife species. During the short-term transition period immediately after tree removal, the reduced canopy cover will likely increase soil and water temperatures, which may be harmful to the fish, reptiles, amphibians, and other water dependent wildlife.  During the short-term transition period there may be an increased potential for erosion of exposed soils. 

The National Park Service finds that there are no practicable alternatives to altering approximately 23.52-acres of wetlands within the project areas and that still meet park goals outlined in the General Management Plan/Environmental Impact Statement. Trees will be removed from the 23.52-acres of forested wetland and the area will be maintained as a scrub/shrub wetland.  In addition, a 70-foot or larger native scrub/shrub buffer (35 feet on either side) will be maintained along stream corridors and wetland boundaries.

As compensation:

§         6.26 acres of herbaceous or emergent stream corridor and riverine wetland will be replanted with native plant species to scrub/shrub habitat.  Scrub/shrub compensation plantings are indicated as “stream buffers” in Maps # 3, 4, and 5.

§         The 2003 Wetland Statement of Findings resulted in a surplus (17.95-acres greater than 1:1 no net loss) of wetland mitigation.  The surplus acreage is described in Map #6.  

§         Combined a total of 24.21-acres of emergent stream corridor and riverine wetland will be planted using native plant species to scrub/shrub habitat.

Care was taken to select an alternative that would minimize the impacts on natural resources, including wetlands, while still meeting project objectives. Wetland impacts have been avoided to the maximum practicable extent, and the wetland impacts that could not be avoided will be minimized.   Compensatory mitigation ratio for this project (for improvement over loss, i.e., the trade of functional loss for functional improvement from wetland enhancement or grazing impact removal) is greater than a 1:1 ratio.  This project is consistent with the NPS no net loss of wetlands policy.  The National Park Service, therefore, finds that this project is in compliance with Executive Order 11990: “Protection of Wetlands.”

References

Cowardin, L. M, V. Carter, F. C. Golet, and E. T. LaRoe. 1979.  Classification of wetlands and deepwater habitats of the United States. U.S. Dept. of the Interior. FWS/OBS-79/31.  131pp.

DeWalle, D. R. 1998.  Assessment of soil and water impacts of the General Management Plan at the Gettysburg National Military Park. Independent Consultant, Boalsburg, PA.  27pp.

Podniesinski, Greg PH.D, Hart, Jim .  2004.  Quarterly Progress Report Gettysburg Threatened and Endangered Species Surveys.  The Pennsylvania Science Office of The Nature Conservancy.

Tiner, Ralph W. Jr.  1988.  Field Guide to Nontidal Wetland Identification.  Maryland Department of Natural Resources, Annapolis, MD and U.S. Fish and Wildlife Service, Newton Comer, MA.  Cooperative publication.  283 pp.

National Park Service. 2002.  Field and Woodland: Reestablishing the Major Patterns that Organized the 1863 Battle Landscape Cultural Landscape Report and 5-year Treatment Plan, in Draft. National Park Service. 

National Park Service 1999.  Final General Management Plan and Environmental Impact Statement, Gettysburg National Military Park.  National Park Service. Vol. I.  441 pp.

National Park Service 1998. Director’s Order #77-1: Wetland Protection . U.S. Department of the Interior. Washington, DC. 4 pp.

National Register Documentation, Gettysburg National Military Park, 2004.

Van Fleet, P. K. and G. L. Kirkland. 1995.  Survey of the terrestrial vertebrates of Codori-Trostle Thicket, Gettysburg National Military Park.  18 pp.

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