CHRONIC WASTING DISEASE
DETECTION AND ASSESSMENT PLAN /
ENVIRONMENTAL ASSESSMENT
Shenandoah National Park, Virginia
DRAFT FINAL
July 2012
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Cover photo: Deer at Big Meadows, Shenandoah National Park
Photograph by: D. Tuttle, Amateur Wildlife Photographer, June 2006.
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CONTENTS
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Figures........................................................................................................................................... vii Tables ............................................................................................................................................ vii Appendixes ................................................................................................................................... vii Acronyms ..................................................................................................................................... viii Glossary ......................................................................................................................................... ix Purpose and Need ........................................................................................................................... 1 Purpose and Need for Action .....................................................................................................1 Objectives in Taking Action ......................................................................................................3 Deer ..................................................................................................................................... 3 Human Health and Safety ................................................................................................... 3 Visitor Experience and Involvement of Interested Parties ................................................. 3 Park Management and Operations ...................................................................................... 3 Park Purpose and Significance...................................................................................................4 Park Purpose ....................................................................................................................... 4 Park Significance ................................................................................................................ 4 Project Location .........................................................................................................................5 Chronic Wasting Disease Summary ..........................................................................................6 Clinical Signs ...................................................................................................................... 6 Diagnosis and Testing ......................................................................................................... 7 Transmission ....................................................................................................................... 7 Disposal of CWD-Infected Material ................................................................................... 9 CWD Testing Efforts Near the Park ..........................................................................................9 Related Laws, Policies, Plans, and Guidance ..........................................................................10 NPS Related Laws, Policies, Plans, and Guidance ........................................................... 10 Shenandoah National Park General Management Plan/Environmental
Assessment (1981a) .......................................................................................................... 13 Shenandoah National Park Resource Management Plan (1998) ...................................... 13 Shenandoah National Park Deer Management Plan (1987) ............................................. 14 Other Federal Related Laws, Policies, Plans, and Guidance ............................................ 15 iii
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State-Related Regulations and Plans ................................................................................ 17 Scoping Process and Impact Topics ........................................................................................19 Scoping ............................................................................................................................. 19 Issues ................................................................................................................................. 19 Impact Topics.................................................................................................................... 20 Alternatives ................................................................................................................................... 26 Thresholds for Taking Action under the Action Alternatives .................................................26 Sample Size Requirements ......................................................................................................27 Detection ........................................................................................................................... 27 Assessment ........................................................................................................................ 31 Sampling Period .......................................................................................................................31 Tissue Sampling and Carcass Handling Requirements ...........................................................31 Elements Common to All Alternatives ....................................................................................32 Alternative A: No Action (Continue Current Actions) ...........................................................32 Detection ........................................................................................................................... 33 Assessment ........................................................................................................................ 34 Implementation Costs ....................................................................................................... 34 Alternative B: Enhanced Detection and Assessment, Including Lethal
Removal for Testing ................................................................................................................34 Detection ........................................................................................................................... 34 Assessment ........................................................................................................................ 37 Implementation Costs ....................................................................................................... 38 Alternative C: Enhanced Opportunistic and Targeted Surveillance but No
Lethal Removal for Testing .....................................................................................................38 Detection ........................................................................................................................... 39 Assessment ........................................................................................................................ 39 Implementation Costs ....................................................................................................... 39 Use of Adaptive Management in the CWD Detection and Assessment Plan .........................40 How Alternatives Meet Objectives ..........................................................................................43 Alternatives or Alternative Elements Considered But Dismissed from Detailed
Analysis....................................................................................................................................43 Decreasing Deer Congregation through Habitat Modification ......................................... 43 Deer Dispersal through Hazing to Reduce Disease Transmission.................................... 43 iv
CWD Detection and Assessment Plan and EA
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Predator Management to Reduce Deer Densities and Therefore Disease
Transmission ..................................................................................................................... 58 Hunting to Reduce Deer Densities and Therefore Disease Transmission ........................ 58 Eliminate the Deer Population .......................................................................................... 58 Do Nothing for Either Detection or Assessment .............................................................. 58 Use of Volunteers as Sharpshooters ................................................................................. 58 Environmentally Preferred Alternative ....................................................................................59 NPS Preferred Alternative .......................................................................................................59 Affected Environment ................................................................................................................... 60 White-tailed Deer .....................................................................................................................60 General Ecology................................................................................................................ 60 Population Densities ......................................................................................................... 60 Deer Movement ................................................................................................................ 61 Deer Herd Health .............................................................................................................. 61 Vegetation ................................................................................................................................62 State-listed Plant Species .................................................................................................. 63 Other Wildlife ..........................................................................................................................64 Mammals........................................................................................................................... 64 Birds .................................................................................................................................. 65 Socioeconomics .......................................................................................................................65 Visitor Use and Experience .....................................................................................................66 Health and Safety .....................................................................................................................67 Park Management and Operations ...........................................................................................67 Environmental Consequences ....................................................................................................... 69 Methodology ............................................................................................................................69 Duration and Type of Impacts .......................................................................................... 69 Impact Thresholds and Impact Intensity Definitions ........................................................ 69 Compliance with Section 106 of the National Historic Preservation Act ...............................70 Cumulative Impacts .................................................................................................................70 Impacts on Physical and Natural Resources ............................................................................78 White-tailed Deer Population ........................................................................................... 78 Vegetation ......................................................................................................................... 84 v
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Other Wildlife ................................................................................................................... 89 State-listed Plant Species .................................................................................................. 94 Socioeconomics ................................................................................................................ 98 Visitor Use and Experience ............................................................................................ 103 Human Health and Safety ............................................................................................... 107 Park Management and Operations .................................................................................. 111 Consultation and Coordination ................................................................................................... 116 Brief History of Scoping and Public Involvement .................................................................116 The Scoping Process ....................................................................................................... 116 Internal Scoping .............................................................................................................. 116 Agency Consultation ....................................................................................................... 117 Public Scoping ................................................................................................................ 117 Science Team Members .........................................................................................................118 List of Preparers and Consultants ..........................................................................................118 List of Recipients of the Plan / Environmental Assessment ..................................................119 References Cited ......................................................................................................................... 120 vi
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FIGURES
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Figure 1. A Map depicting the proximity of Shenandoah National Park and other
NPS units to CWD positive deer in Hampshire County, West Virginia, and
Frederick County, Virginia. ............................................................................................................ 2 Figure 2. Map showing the 30-mile and 5-mile buffers around Shenandoah
National Park which represent thresholds for initiating intensified detection and
assessment actions, respectively. .................................................................................................. 28 Figure 3. The Adaptive Management Approach........................................................................... 42 TABLES
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Table 1. Sections of 36 Code of Federal Regulations applicable to this project. ......................... 17 Table 2. Action thresholds for disease detection and assessment. ................................................ 29 Table 3. Cost estimates for implementing Alternative A. ............................................................ 34 Table 4. Criteria for ssing lethal removal for CWD detection by action zone
under Alternative B. ...................................................................................................................... 36 Table 5. Criteria for using lethal removal for CWD assessment by action zone. ........................ 38 Table 6. Cost estimates for implementing Alternative B. ............................................................. 38 Table 7. Cost estimates for implementing Alternative C. ............................................................. 40 Table 8. Summary of alternatives. ................................................................................................ 44 Table 9. How the alternatives meet the objectives in taking action.............................................. 46 Table 10. Summary of environmental consequences of the alternatives. Note from
John: Put this table at the end of Chapter 4. ................................................................................. 51 Table 11. Cumulative action scenario. .......................................................................................... 71 APPENDIXES
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Appendix A. Sample prevalence and sample weights for CWD surveillance. ........................... 123 Appendix B. Deer Sampling Limits............................................................................................ 124 vii
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ACRONYMS
BRMD
BSE
CEQ
CFR
CWD
EA
EIS
GMP
NEPA
NPS
PEPC
TSE
USC
VDGIF
Biological Resources Management Division (National Park Service)
bovine spongiform encephalopathy (mad cow disease)
Council on Environmental Quality
Code of Federal Regulations
Chronic Wasting Disease
Environmental Assessment
Environmental Impact Statement
General Management Plan
National Environmental Policy Act
National Park Service
Planning, Environment, and Public Comment
transmissible spongiform encephalopathy
United States Code
Virginia Department of Game and Inland Fisheries
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GLOSSARY
Action Alternative — An alternative that proposes a different management action or actions to address
the purpose, need, and objectives of the plan; one that proposes changes to the current management.
Alternatives B and C are the action alternatives in this planning process. See also: No-Action Alternative.
Adaptive Management — The rigorous application of management, research, and monitoring to gain
information and experience necessary to assess and modify management activities. A process that uses
feedback from research and the period of evaluation of management actions and the conditions they
produce to either reinforce the viability of objectives, strategies, and actions prescribed in a plan or to
modify strategies and actions in order to more effectively accomplish management objectives.
Affected Environment — A description of the existing environment that may be affected by the
proposed action (40 CFR 1502.15).
Authorized Agent — For the purposes of this plan, authorized agents could include, but are not limited
to, other agency personnel and contractors.
Bluetongue Virus — An insect-transmitted viral disease of ruminant animals, including white-tailed
deer, which causes inflammation, swelling, and hemorrhage of the mucous membranes of the mouth,
nose, and tongue.
Carrying Capacity — The maximum number of organisms that can be supported in a given area or
habitat.
Cervid — A member of the deer family, such as white-tailed deer, mule deer, elk, moose, and caribou.
Chronic Wasting Disease (CWD) — A slowly progressive, infectious, self-propagating, neurological
disease of captive and free-ranging deer, elk, and moose. CWD belongs to the transmissible spongiform
encephalopathy (TSE) group of diseases and is characterized by accumulations of abnormal prion
proteins in neural and lymphoid tissue.
Contractor — For the purposes of this plan, a contractor would be a fully insured business entity,
nonprofit group, or other entity engaged in wildlife management activities that include the direct
reduction with firearms.
Cultural Landscape — A geographic area (including both cultural and natural resources and the wildlife
or domestic animals therein) associated with a historic event, activity, or person or exhibiting other
cultural or aesthetic values.
Cumulative Impacts — Those impacts on the environment that result from the incremental effect of the
action when added to the past, present, and reasonably foreseeable future actions regardless of what
agency (federal or nonfederal) or person undertakes such other actions. Cumulative impacts can result
from individually minor but collectively significant actions taking place over a period of time (40 CFR
1508.7).
Deer Herd or Population — The group of deer that have common characteristics and interbreed among
themselves.
Depopulation — Elimination of a population.
Ecosystem — An ecological system; the interaction of living organisms and the nonliving environment
producing an exchange of materials and energy between the living and nonliving.
Encephalopathy — Any disorder or disease of the brain.
Endemic — Native to or confined to a particular region.
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Environment — The sum total of all biological, chemical, and physical factors to which organisms are
exposed; the surroundings of a plant or animal.
Environmental Assessment (EA) — A concise public document, prepared in compliance with NEPA,
that briefly discusses the purposes and need for an action and provides sufficient evidence and analysis of
impacts to determine whether to prepare an environmental impact statement or finding of no significant
impact (40 CFR 1508.9).
Environmental Consequences — Environmental effects of project alternatives, including the proposed
action, any adverse environmental effects which cannot be avoided, the relationship between short-term
uses of the human environment, and any irreversible or irretrievable commitments of resources which
would be involved if the proposal should be implemented (40 CFR 1502.16).
Environmental Impact Statement (EIS) — A detailed written statement required by Section 102(2)(C)
of NEPA, analyzing the environmental impacts of a proposed action, adverse effects of the project that
cannot be avoided, alternative courses of action, short-term uses of the environment versus the
maintenance and enhancement of long-term productivity, and any irreversible and irretrievable
commitment of resources (40 CFR 1508.11).
Epizootic Hemorrhagic Disease (EHD) — An insect-borne viral disease of ruminants that causes
widespread hemorrhages in mucous membranes, skin, and visceral organs.
Ethnographic Resource — Any site, structure, object, landscape, or natural resource feature assigned
traditional legendary, religious, subsistence, or other significance in the cultural system of a group
traditionally associated with it.
Euthanasia — Ending the life of an animal by humane means.
Habitat — The environment in which a plant or animal lives (includes vegetation, soil, water, and other
factors).
Herbaceous Plants — A non-woody plant; includes grasses, wildflowers, and sedges and rushes; does
not include trees or shrubs.
Hemorrhage — Uncontrolled bleeding or loss of a large amount of blood.
Homogeneous – Having the same genetic structure.
Heterogeneous – Derived from a different individual or species.
Impairment (NPS Policy) — As used in NPS Management Policies, “impairment” means an adverse
impact on one or more park resources or values that interferes with the integrity of the park’s resources or
values, or the opportunities that otherwise would exist for the enjoyment of them, by the present or a
future generation. Impairment may occur from visitor activities, NPS activities in managing a park, or
activities undertaken by concessioners, contractors, and others operating in a park. As used here, the
impairment of park resources and values has the same meaning as the phrase “derogation of the values
and purposes for which these various areas have been established,” as used in the General Authorities
Act.
Monitoring — A process of collecting information to evaluate if an objective and/or anticipated or
assumed results of a management plan are being realized (effectiveness monitoring) or if implementation
is proceeding as planned (implementation monitoring).
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National Environmental Policy Act of 1969 — A law that requires all Federal agencies to examine the
environmental impacts of their actions, incorporate environmental information, and utilize public
participation in the planning and implementation of all actions. Federal agencies must integrate NEPA
with other planning requirements and prepare appropriate NEPA documents to facilitate better
environmental decision making. NEPA requires Federal agencies to review and comment on Federal
agency environmental plans/documents when the agency has jurisdiction by law or special expertise with
respect to any environmental impacts involved (42 U.S.C. 4321-4327) (40 CFR 1500-1508).
No-Action Alternative — The alternative in which baseline conditions and trends are projected into
the future without any substantive changes in management (40 CFR 1502.14(d)). Alternative A is the
no-action alternative in this planning process.
Nonnative Species — Any introduced plant, animal, or protist species that is not native to the area and
may be considered a nuisance; also called exotic or alien species.
Opportunistic Surveillance — Taking diagnostic samples for CWD testing from deer found dead or
harvested through a management activity within a national park unit.
Parasitism — A symbiotic relationship in which one species, the parasite, benefits at the expense of the
other, the host.
Population (or Species Population) — A group of individual plants or animals that have common
characteristics and interbreed among themselves and not with other similar groups.
Population Reduction — Removing animals randomly within a population in an attempt to reduce
animal density, and thus decrease CWD transmission rates.
Prion — Protinaceous infectious particle; a microscopic particle similar to a virus but lacking nucleic
acid, thought to be the infectious agent for certain degenerative diseases of the nervous system such as
CWD.
Ruminant — An animal that chews the cud and has a complex digestive system with a four-part stomach
enabling bacteria to break down food. Ruminants lack upper incisor teeth and their complex stomach
allows them to store and digest large amounts of bulky and fibrous food.
Scoping — An early and open process for determining the extent and variety of issues to be addressed
and for identifying the significant issues related to a proposed action (40 CFR 1501.7).
Successional — Successional refers to the process of ecosystem development as brought about by
changes in the populations of species that results in the creation of a geographic region with particular
characteristics. Early successional refers to species that tend to more quickly give way to other species
(weeds, nonnative varieties, etc.), typically representing lower quality habitat. Late-successional refers to
more persistent species, and tends to be associated with higher value habitat.
Targeted Surveillance — Lethal removal of deer that exhibit clinical signs of CWD, such as changes in
behavior and body condition, and testing to determine if CWD is present.
Transect — A line along which sampling is performed.
Transmissible Spongiform Encephalopathies (TSEs) — A group of diseases characterized by
accumulations of abnormal prion proteins in neural and lymphoid tissues, which cause distinctive lesions
in the brain and result in death.
Ungulate — A hoofed, typically herbivorous, animal; includes horses, cows, deer, elk, and bison.
Vaccine — A suspension of killed or attenuated microorganisms that, when introduced into the body,
stimulates an immune response against that microorganism.
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Vascular Plant — A plant that contains a specialized conducting system consisting of phloem
(food-conducting tissue) and xylem (water-conducting tissue). Ferns, trees, and flowering plants are all
vascular plants.
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PURPOSE AND NEED
Chronic wasting disease (CWD) is a fatal neurological disease of deer, elk, and moose. At the
present time, there is no known cure for the disease, and many aspects of disease dynamics are
still unknown. In 2005, CWD was discovered in white-tailed deer in West Virginia,
approximately 35 miles from Shenandoah National Park (Park). CWD is considered a nonnative
disease process (i.e., the spread of the disease is aided by anthropogenic factors). Guidance from
the National Park Service (NPS) (Director’s CWD Guidance Memorandum 2002) provides
direction to parks on management of this disease. This document describes the reasons why the
NPS proposes to undertake detection and assessment actions to respond to the potential threat of
CWD near the Park.
This CWD Detection and Assessment Plan/Environmental Assessment (Plan/EA) analyzes a noaction alternative and two action alternatives and their potential impacts on the environment.
This Plan/EA has been prepared in accordance with the National Environmental Policy Act of
1969 (NEPA), the implementing regulations of the Council on Environmental Quality (40 CFR
1500-1508), NPS Management Policies 2006, and NPS Director’s Order #12: Conservation
Planning, Environmental Impact Analysis and Decision-Making (DO-12), and accompanying
DO-12 Handbook (2001). It should be noted, that the implementation of any given alternative is
subject to future availability of funds. Additionally, this plan will remain in effect until a)
conditions change to a point at which the detection and assessment actions are no longer useful,
or b) the Virginia Department of Game and Inland Fisheries stops CWD surveillance, or c) a
long-term CWD management plan for the Park is in place.
PURPOSE AND NEED FOR ACTION
The purpose of this Plan/EA is to establish a framework for the detection and assessment of
CWD in white-tailed deer in Shenandoah National Park that 1) allows the NPS to determine with
a high level of confidence whether CWD is present in the Park’s white-tailed deer population, 2)
allows the NPS to understand the prevalence and distribution of CWD if it is detected in the
Park, 3) supports future decision-making relative to long-term management of CWD in the
Park’s white-tailed deer population, and 4) allows the NPS to cooperate/coordinate to a greater
degree with the state in its surveillance efforts.
In September 2005, CWD was diagnosed in a free-ranging white-tailed deer in Hampshire
County, West Virginia (an area within 35 miles of the Park). Subsequently, 74 deer have tested
positive for CWD in Hampshire County. In January 2010, a deer tested positive for CWD in
Frederick County, Virginia, less than a mile from the West Virginia border and within 23 miles
of the Park (Figure 1). Therefore, a CWD Detection and Assessment Plan is needed because
CWD represents a potential threat to Park resources, primarily white-tailed deer, and the Park’s
proximity to known positive CWD cases represents a risk factor for disease introduction.
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Figure 1. Map depicting the proximity of Shenandoah National Park and other NPS units to CWD- positive
deer in Hampshire County, West Virginia, and Frederick County, Virginia.
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OBJECTIVES IN TAKING ACTION
Objectives are “what must be achieved, to a large degree, for the action to be considered a
success” (Director’s Order 12, NPS 2001). Objectives for detecting and responding to CWD
must be grounded in the Park’s enabling legislation, purpose, and significance, and must be
compatible with direction and guidance provided by the Park’s general management plan,
resource management plan, wilderness management plan, and other management guidance.
Alternatives selected for detailed analysis in this Plan/EA must meet all objectives to a large
degree and resolve the purpose of, and need for, action.
Shenandoah National Park’s enabling legislation, purpose, and significance were considered in
developing the following objectives related to CWD detection and assessment:
Deer


Estimate risk of CWD infection in the white-tailed deer population of the Park based on
known disease risk factors.
Appropriate to the level of risk, develop and implement:
 protocols for detection of CWD presence using a scientifically and statistically based
sampling strategy; and
 actions for the assessment of disease prevalence and distribution amongst deer within the
Park.
Human Health and Safety

Minimize the potential for health and safety issues for Park staff and visitors associated with
CWD detection and assessment activities.
Visitor Experience and Involvement of Interested Parties


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Cooperate and coordinate with appropriate state and federal resource management agencies,
as well as other interested parties, with respect to detection and assessment of CWD.
Enhance the awareness and understanding among visitors and interested parties of CWD and
NPS resource management issues, policies, and mandates as they pertain to prevention,
detection, and response to the disease.
Minimize disruption to visitor use and experience during implementation of CWD detection
and assessment activities.
Park Management and Operations
Minimize impacts of CWD detection and assessment activities on current Park operations,
including budget and workload. Therefore, the implementation of any given alternative (action
plan) is subject to future availability of funds.
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PARK PURPOSE AND SIGNIFICANCE
The Park purpose and significance are key elements that help shape the management of a Park.
The purpose describes why the Park was set aside as a NPS unit. Significance addresses why the
Park is unique – the cultural heritage and natural features. Park significance statements capture
the essence of the Park’s importance to the nation’s natural and cultural heritage. Understanding
Park significance helps managers make decisions that preserve the resources and values
necessary to the Park’s purpose.
Congress established Shenandoah National Park on February 21, 1925, declaring:
…the Secretary of the Interior is hereby authorized and directed to determine the
boundaries and area of such portion of the Blue Ridge Mountains of Virginia
lying east of the South Fork of the Shenandoah River and between Front Royal on
the north and Waynesboro on the south as may be recommended by him to be
acquired and administered as a national park, to be known as the Shenandoah
National Park…(43 Stat. 955)
Park Purpose
Legislation related to Shenandoah National Park provides very limited insight into the Park
purpose. The following purpose statements were developed as part of a strategic planning
analysis conducted by Shenandoah National Park:




Maintain a scenic “Skyline Drive” to provide views of the Shenandoah Valley and Piedmont
of Virginia;
Protect and preserve the aesthetic values, natural and cultural resources within the Park;
Provide recreational opportunities and traditional visitor amenities; and
Preserve the wilderness character of designated wilderness.
Park Significance
Park significance statements capture the essence of the Park’s importance to the nation’s natural
and cultural heritage. Understanding Park significance helps managers make decisions that
preserve the resources and values necessary to achieve the Park’s purpose. Based on the Park’s
Comprehensive Interpretive Plan (2006), Shenandoah National Park is significant because




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this Park provides a traditional “national park experience” in the east;
the Park has become a sizeable “natural area” with large areas of designated wilderness and
is an outstanding example of the Blue Ridge/Central Appalachian biome;
this national Park is near large metropolitan populations, providing relatively good
accessibility to millions of citizens;
it provides recreation and “re-creation,” in the historic context of personal contemplative
pleasure;
within the historic context of the time in which the Park was established, the Park represented
a conscious change in human use of the land rather than the preservation of unimpaired
resources;
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Shenandoah National Park
the Appalachian Trail is the backbone of the Park’s trail system; it includes fine examples of
early trail construction techniques and is the longest segment of the Appalachian Trail in a
national park;
Skyline Drive National Historic Landmark and the associated developed areas at Simmons
Gap, Lewis Mountain, Big Meadows, Skyland, Piney River, Pinnacles, Dickey Ridge, and
Park Headquarters are listed on the National Register. Their national significance is their
association with the Civilian Conservation Corps, the Works Progress Administration, and
several hundred architectural and landscape architectural structures and features that are
highly representative of their type; and
Rapidan Camp, the summer retreat of Herbert and Lou Henry Hoover from 1929 to 1933, is a
National Historic Landmark. It served as the “summer White House” during the Hoover
presidency, was the site of many national and international policy meetings, and retains
significant rustic architectural and landscape structures and features.
PROJECT LOCATION
Shenandoah National Park is located in the Blue Ridge Mountains of Virginia just west of
Washington, DC, and stretches over 100 miles from its northern entrance at Front Royal,
Virginia, to its southern entrance near Waynesboro, Virginia. The Park encompasses more than
197,000 acres in eight Virginia counties, including Albemarle, Augusta, Green, Madison, Page,
Rappahannock, Rockingham, and Warren. The Park is located in the Central Appalachian
biogeographic region and separates a portion of the Piedmont Region (to the east) from much of
the Shenandoah Valley.
The Park encompasses over 200 miles of roads (including 105 miles of the Skyline Drive Scenic
Byway), approximately 516 miles of trails (including 101 miles of the Appalachian Trail), and
numerous visitor centers, campgrounds, and concessioner-operated facilities, including lodges.
Approximately 50 species of mammals, 32 fish, 27 reptiles, 24 amphibians, and more than 200
species of birds occur in the Park (NPS 2006b).
Deer are an integral component of the native communities and are the largest herbivore in the
Park. Deer are a source of enjoyment for Park visitors (e.g. wildlife observers or photographers)
that visit the Park specifically to view deer. Visitors may also view deer incidentally when
camping, hiking, or driving in the Park. These opportunities to view deer populations are popular
activities and are seen as valuable recreational, aesthetic, and educational experiences at the Park
(Haskell, 1986). However, as deer populations have increased, issues related to disease
transmission within these larger populations have become a concern, including the potential for
the transmission of CWD.
A deer management plan for the Park was completed in 1986 and requires some updating.
Regardless, one of the Park’s standing deer management objectives is to develop and support
cooperative deer research on population dynamics, landscape effects, and disease issues
(Haskell, 1986). Other objectives include:


Allowing natural processes to prevail to the greatest degree possible, and
In developed areas,
 managing/mitigating issues associated with deer that have become habituated to people,
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
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Shenandoah National Park
developing and supporting research and monitoring programs specific to issues in
developed areas, and
conducting surveillance for CWD (CWD Science Team, 2006).
CHRONIC WASTING DISEASE SUMMARY
Chronic wasting disease is in a family of diseases known as transmissible spongiform
encephalopathies (TSEs) and is an infectious, self-propagating, neurological disease. CWD
causes brain lesions in deer, moose, and elk that result in progressive weight loss, behavioral
changes, and eventually death. There is no treatment or vaccine available to address CWD. The
disease is in the same family as other TSEs such as bovine spongiform encephalopathy (BSE),
also known as “mad cow,” and sheep scrapie (NPS 2007).
The exact origin of CWD is unknown and the time and place of emergence cannot be determined
with certainty (Spraker et al. 1997; Williams et al. 2002). It is possible that CWD resulted from
spontaneous changes in the folding of a normal prion (protein containing no genetic material) to
an infectious, rogue prion with subsequent transmission to susceptible species (Williams et al.
2002). Alternatively, CWD could be a mutated form of domestic sheep scrapie that has adapted
to deer, moose, and elk (Raymond et al. 2000; Race et al. 2002). Both CWD and scrapie are
infectious, contagious TSEs, and scrapie has been implicated in the BSE outbreak in Great
Britain (Wilesmith et al. 1988; Collinge et al. 1996; Bruce et al. 1997).
CWD has likely been present in northeastern Colorado, southeastern Wyoming, and the
southwest corner of Nebraska since the 1960s or earlier (Miller et al. 2000). CWD was first
observed clinically in 1967 in captive mule deer in a wildlife research facility in Colorado. More
than 80% of mule deer over the age of 2 years, held in the Colorado facility from 1974 to 1979,
died or were euthanized following signs consistent with CWD. By 1979, brain lesions had been
identified and the disease had been described as a spongiform encephalopathy (Williams and
Young 1980, 1992).
While there are many unknowns surrounding CWD, what is known is that human-associated
movement of these diseased animals has aided in the spread of CWD in captive, and likely freeranging, deer and elk (Miller and Williams 2003; Salman 2003; Williams and Miller 2003). The
rate of transmission of CWD appears to be greater when concentrations of deer are greater
(Samuel et al. 2003; Farnsworth et al. 2005), as is the case with white-tailed deer in eastern
national parks. There is also evidence that other human-caused factors, such as already said
changes in land use patterns, influence the spread of CWD (Farnsworth et al. 2005).
Clinical Signs
Animals infected with CWD exhibit the disease through changes in behavior and body condition.
Some signs of CWD include animals losing their fear of humans, showing repetitive movements,
and/or appearing depressed but becoming quickly alert if startled. In addition to these behavioral
signs, physical signs include losing weight or poor body condition, despite having an appetite. In
the beginning, these signs may be very subtle, and then over several weeks to several months the
signs may increase and become more pronounced. Other signs of CWD include lowered
head/ears, increased urination, stumbling, “star-gazing,” increased salivation, wide-based stance,
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increased drinking, loss of coordination, and regurgitation. These behavioral changes could result
in physical changes such as pneumonia, staying by water for long periods of time, etc. While any
of these may give an observer an indication that an animal might have CWD, the disease can
only be diagnosed through laboratory testing (NPS 2007).
Diagnosis and Testing
The two most common tests for diagnosis of CWD use histopathology techniques which look at
the microscopic changes in diseased tissues and immunohistochemistry which uses antibody
markers to identify CWD prions. Both techniques use a specific portion of the brain to observe
pathologic changes or prion accumulation. Immunohistochemistry is considered the gold
standard in CWD diagnosis. Unlike histopathology, this process can use tissues from a variety of
places, not just the brain; the lymph nodes and tonsils are preferred tissues. A series of stains
applied to the slide will turn any prions responsible for the disease deep red, resulting in a
positive diagnosis of CWD for the animal being tested. Finally, rapid tests using Enzyme Linked
Immunosorbent Assay (ELISA) techniques can be used on any of the above- mentioned tissues
for a more timely diagnosis. None of these methods are 100% sensitive. This means that a
negative test result does not guarantee a CWD-free animal (NPS 2007). False positive test results
are believed not to occur (Miller and Williams 2002).
Transmission
Although originally detected in the western U.S., CWD has been found in 18 states and two
Canadian provinces in free-ranging and captive populations. In free-ranging populations, CWD
has been found in 13 states and two provinces. In captive populations, CWD has been found in
11 states and two provinces (as of November 2010). The natural path of transmission of CWD in
deer and other affected animals is unknown, but studies have been conducted that suggest
various direct and indirect paths of transmission. Environmental contamination, such as being in
the vicinity of dead or live animals with CWD, or being in the areas that the infected animal
previously inhabited contributes to the spread of CWD (NPS 2007). In addition, bodily
secretions such as feces, urine, and saliva are capable of transmitting the disease (Mathiason et
al. 2006).
Based on current research, transmission of CWD in white-tailed deer populations is not uniform
across the landscape. CWD surveillance in Wisconsin shows that there is a clustered distribution
of diseased animals in the CWD-affected area of the state, indicating that deer in proximity to
positive cases are more likely to have the disease (Joly et al. 2006). In addition, this research has
shown that prevalence is related to deer density, based on correlations with the abundance of
deer habitat.
Although direct evidence of a density-dependent transmission relationship is weak (Joly et al.
2006), studies have shown that CWD can be very efficiently transmitted between animals in
captive herds (Williams and Young 1980; Miller et al. 1998; Miller and Wild 2004). This finding
may be similar in free-ranging herds in urban or developed environments that are confined by
land use patterns, where, like with other contagious diseases, CWD transmission increases when
animals are concentrated. Increased mortality in these populations, such as through management
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CWD Detection and Assessment Plan and EA
Shenandoah National Park
actions, may slow transmission by limiting the number of individuals a diseased animal can
infect via a reduction in population density.
Based on differences in prevalence rates between age and sex classes, recent research also
indicates that CWD transmission in white-tailed deer is likely affected by social behavior. A
Wisconsin study found that CWD prevalence was 3% to 4% in yearling males and females, but
this increased to 13% for three-year-old males and 7% for three-year-old females (Grear et al.
2006). These differences may be attributed to direct transmission in male groups from late winter
through early summer; transmission during the breeding season when males come into close
contact with many more potentially infected females; or the fact that males have larger home
ranges and broader movements during the breeding season, which increases the chances of
infectious contacts (Grear et al. 2006).
The spread and transmission of CWD in white-tailed deer populations can be attributed to a
range of risk factors. With CWD spreading to new areas, it is thought that by identifying these
risk factors, wildlife managers can better predict which populations are susceptible to CWD.
Risk factors fall into two categories: exposure related and amplification related. The first
category (i.e. exposure) addresses the likelihood that CWD will be introduced to a given
population and includes identifying the following:






areas adjacent to CWD-positive wildlife;
areas with CWD-positive farmed or captive deer or elk;
areas with concentrations of farmed or captive deer or elk;
areas that have received translocated deer or elk from CWD-affected regions;
areas permitting transport of hunter-killed deer or elk carcasses from CWD identified areas;
and
areas adjacent to land on which farmed or wild animals which have tested positive to
transmissible spongiform encephalopathy (e.g., bovine spongiform encephalopathy (BSE)
and sheep scrapie) have lived.
The second set of risk factors addresses how CWD can spread once it is in a population (i.e.
amplificiation) and includes:




areas with a history of CWD animals or CWD contaminated environments;
areas with high deer or elk population density;
areas with low abundance of large predators; and
areas where free-ranging deer or elk are artificially concentrated (baiting, feeding, water
development, and other human-related habitat modifications).
As of November 2010, CWD has been found in 13 states and two Canadian provinces in freeranging deer and elk populations. However, CWD has been found within only two national
parks: Rocky Mountain National Park, Colorado, and Wind Cave National Park, South Dakota.
In 2005, CWD was detected in Hampshire County, West Virginia, within 60 miles of several
national park units, including Shenandoah National Park. In January 2010 and November 2010,
CWD was detected in Frederick County, Virginia, ten miles southeast of the Hampshire County,
West Virginia detection and within 23 miles of the Park.
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CWD Detection and Assessment Plan and EA
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The NPS formed a team of technical experts called the Science Team to engage in the discussion
of CWD and potential detection and assessment options available to the NPS. The team
participants were limited to people with scientific background in CWD and deer management
and research, and NPS staff. The purpose of science team discussions was to provide a technical
framework for the development of action thresholds and alternatives for the CWD detection and
assessment plan. The team convened via conference calls, meeting six times over a 5-month
period in 2007. The topics of discussion included the following:





existing conditions surrounding the Park;
existing data and CWD monitoring;
CWD detection and assessment goals;
approach to establishing action thresholds for detection and assessment; and
issues related to implementation of various actions.
Disposal of CWD-Infected Material
Because infected carcasses serve as a source of environmental contamination (Miller et al. 2004)
and soils may act as a reservoir for prion infectivity (Johnson et al. 2006), it is recommended that
known and suspect CWD positive animals be removed from the environment. Alkaline digestion
and incineration are two of the most effective ways of destroying contaminated organic material.
Arrangements can often be made with laboratories to test and then dispose of animals. Another
option, depending on the region, is landfill disposal; however, local landfills must be contacted
for more information regarding carcass disposal. There is currently no national standard for
disposal of known or suspect CWD-contaminated organic material, such as whole or partial
carcasses. Each refuse disposal area is likely to have different regulations and restrictions for
disposal of potentially infected tissues. Therefore, options for carcass disposal include licensed
landfills or other permitted facilities, as well as laboratories with incineration or alkaline
digestion capabilities.
CWD Testing Efforts Near the Park
Since 2002, VDGIF has tested over 5,000 samples for CWD from wild white-tailed deer, captive
deer of several species, and elk, with the large majority of samples coming from free-ranging
white-tailed deer. In both 2002 and 2007, VDGIF performed statewide CWD surveillance in
free-ranging white tailed deer. During other years, beginning in 2005 when CWD was first
detected in Hampshire County, West Virginia, VDGIF has focused CWD surveillance in
counties adjacent to WV. Virginia’s first case of CWD was confirmed January 19, 2010 in a twpand-a-half- year-old female white-tailed deer harvested by a hunter on November 14, 2009 in
western Frederick County, Virginia (within 11 miles of the West Virginia CWD endemic area).
The only other CWD detection in Virginia was in November 2010 from the same Frederick
County area..
The states of Maryland, Pennsylvania, and West Virginia have also developed response plans to
address CWD in white-tailed deer populations. Over 6,700 Maryland free-ranging deer have
been tested for CWD since 2002 with no positive results. Pennsylvania has been testing hunterkilled deer and elk for CWD for eight years, and in total more than 27,000 cervids have been
tested with no positives detected. In West Virginia, surveillance efforts conducted by the state as
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CWD Detection and Assessment Plan and EA
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of October 27, 2010 have resulted in a total of 74 deer being confirmed positive for CWD in
Hampshire County, the first in 2005. Surveillance efforts are ongoing.
RELATED LAWS, POLICIES, PLANS, AND GUIDANCE
The following laws, policies, and plans associated with the NPS, the state of Virginia, or
agencies with neighboring land or relevant management authority are described in this section in
order to identify constraints on the development and implementation of this Plan/EA and the
goals and policies with which the Plan/EA must conform. It should be noted that the state of
Virginia does not have land or wildlife management authority on Shenandoah National Park
lands.
NPS Related Laws, Policies, Plans, and Guidance
NPS Organic Act of 1916
Congress directed the U.S. Department of the Interior and the NPS to manage units “to conserve
the scenery and the natural and historic objects and wild life therein and to provide for the
enjoyment of the same in such a manner and by such a means as will leave them unimpaired for
the enjoyment of future generations” (16 USC 1). The Organic Act and its amendments afford
the NPS latitude when making resource decisions. Because conservation remains predominant,
the NPS seeks to avoid or to minimize adverse impacts on Park resources and values. However,
the NPS Organic Act does give the Secretary of the Interior discretion to provide “for the
destruction of such animal and of such plant life as may be detrimental to the use of any of said
parks, monuments, or reservations” (16 USC 3). The Organic Act prohibits actions that impair
park resources unless a law directly and specifically allows for such actions (16 USC 1 a-1).
Redwood Amendment (1978) to the General Authorities Act (1970)
Reasserting the system-wide standard of protection established by Congress in the original
Organic Act, the Redwood Amendment stated:
The authorization of activities shall be construed and the protection, management,
and administration of these areas shall be conducted in light of the high public
value and integrity of the National Park System and shall not be exercised in
derogation of the values and purposes for which these various areas have been
established, except as may have been or shall be directly and specifically provided
by Congress” (P.L. 95-250, USC Sec 1a-1).
Congress intended the language of the Redwood Amendment to reiterate the provisions of the
Organic Act, not to create a substantively different management standard. Under the Redwood
Amendment, “The Secretary has an absolute duty, which is not to be compromised, to fulfill the
mandate of the 1916 Act to take whatever actions and seek whatever relief as will safeguard the
units of the national park system.” Although the Organic Act and the General Authorities Act, as
amended by the Redwood Amendment, use different wording (“unimpaired” and “derogation”)
to describe what the NPS must avoid, they define a single standard for the management of the
national park system—not two different standards. For simplicity, the NPS Management Policies
2006 uses “impairment,” not both statutory phrases, to refer to that single standard.
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CWD Detection and Assessment Plan and EA
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NPS Management Policies 2006, Section 1.4: The Prohibition on Impairment of Park
Resources and Values
By enacting the NPS Organic Act of 1916 (Organic Act), Congress directed the U.S. Department
of Interior and the NPS to manage units “to conserve the scenery and the natural and historic
objects and wildlife therein and to provide for the enjoyment of the same in such a manner and
by such a means as will leave them unimpaired for the enjoyment of future generations” (16
USC § 1). Congress reiterated this mandate in the Redwood National Park Expansion Act of
1978 by stating that NPS must conduct its actions in a manner that will ensure no “derogation of
the values and purposes for which these various areas have been established, except as may have
been or shall be directly and specifically provided by Congress” (16 USC 1a-1).
NPS Management Policies 2006, Section 1.4.4, explains the prohibition on impairment of park
resources and values:
“While Congress has given the Service the management discretion to allow impacts within parks,
that discretion is limited by the statutory requirement (generally enforceable by the federal
courts) that the Park Service must leave park resources and values unimpaired unless a particular
law directly and specifically provides otherwise. This, the cornerstone of the Organic Act,
establishes the primary responsibility of the Nation Park Service. It ensures that park resources
and values will continue to exist in a condition that will allow the American people to have
present and future opportunities for enjoyment of them.”
The NPS has discretion to allow impacts on Park resources and values when necessary and
appropriate to fulfill the purposes of a Park (NPS 2006 sec. 1.4.3). However, the NPS cannot
allow an adverse impact that would constitute impairment of the affected resources and values
(NPS 2006 sec 1.4.3). An action constitutes an impairment when its impacts “harm the integrity
of Park resources or values, including the opportunities that otherwise would be present for the
enjoyment of those resources or values” (NPS 2006 sec 1.4.5). In making a determination of
whether there would be an impairment, an NPS decision-maker must use his or her professional
judgment (NPS 2006 sec 1.4.7). This means that the decision-maker must consider any
environmental assessments or environmental impact statements required by NEPA; consultations
required under section 106 of the NHPA; relevant scientific and scholarly studies; advice or
insights offered by subject matter experts and others who have relevant knowledge or
experience; and the results of civic engagement and public involvement activities relating to the
decision (NPS 2006 sec 1.4.7). At the time that a decision is made, a non-impairment
determination will be prepared for the selected action and appended to the decision document.
Director’s Order 77: Natural Resource Management
This Natural Resource Management Reference Manual #77 offers comprehensive guidance to
National Park Service employees responsible for managing, conserving, and protecting the
natural resources found in National Park System units. This Reference Manual serves as the
primary Level 3 guidance on natural resource management in units of the National Park System,
replacing NPS-77, The Natural Resource Management Guideline, issued in 1991 under the
previous NPS guideline series.
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CWD Detection and Assessment Plan and EA
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Natural Resource Management Reference Manual, NPS-77
Managers must follow all federal laws, regulations, and policies, plus guidelines established in
the Natural Resource Management Reference Manual which is being updated to replace the
Natural Resources Management Guideline (1991). Guidance is provided to park managers for all
planned and ongoing natural resource management activities. This document provides the
direction for park management to design, implement, and evaluate a comprehensive natural
resource management program.
A National Park Service Manager’s Reference Notebook to Understanding CWD, Version
4 (May 2007)
Although not a policy or directive, this document provides NPS managers with an informational
reference that summarizes some of the most pertinent CWD literature, management options and
policy as they pertain to NPS units (NPS 2007a). It includes discussions of CWD, its ecology,
equipment decontamination and disposal, implications of CWD on cervid management,
management options, cooperation/coordination with other agencies, data management, sample
collection, handling, and storage, NPS CWD policy and recommendations, as well as several
appendixes.
NPS wildlife managers in other parks are developing plans to detect and address CWD. Antietam
National Battlefield and Monocacy National Battlefield, both in Maryland, have completed a
CWD Plan/EA because, like Shenandoah, they are close to known CWD cases.
The NPS CWD Handbook (NPS 2007) has identified numerous management options that can be
implemented if CWD is found in or near a park unit, considering the site-specific CWD goals
and objectives of the park unit. Those discussed in the handbook are listed below:

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

no action;
opportunistic surveillance (taking samples for CWD testing from deer found dead or
harvested within the unit);
targeted surveillance (performing lethal removal of deer that exhibit clinical signs consistent
with CWD);
test and cull (test and remove any deer found to be diseased);
“hot-spot” culling (removing all deer in high incidence areas);
population reduction (decreasing the number of deer in the population);
wolf predation as a stewardship tool; and
de-population (removal of all deer).
Details about each of these can be found in the handbook, which is provided at
http://www1.nrintra.nps.gov/BRMD/nativespecies/Wildlifehealth/Documents/CWD_notebook_v
ersion 4_7_07_.pdf
Director’s CWD Guidance Memorandum (2002)
This memo (NPS 2002b) provides guidance to regions and parks on the NPS response to CWD,
including:
12
CWD Detection and Assessment Plan and EA







Shenandoah National Park
Cooperate and coordinate with state wildlife and agriculture agencies regarding proposed
prevention, surveillance, research, and control actions for CWD.
Parks in close proximity (60 miles) to areas where CWD has been detected should initiate a
targeted surveillance program to monitor for deer and elk with clinical signs of the disease
and submit samples for diagnostic testing from all deer and elk found dead.
Immediate action should be taken, on a limited scale, to address imminent threats such as a
deer or elk exhibiting clinical signs of CWD. Euthanasia of CWD- suspect deer or elk with
samples submitted for diagnostic evaluation is a reasonable response.
Prior to undertaking larger scale or multiple animal actions within a park (e.g., population
reduction of deer and elk), environmental planning documents, including NEPA and, if
applicable, Section 7 consultation with the U.S. Fish and Wildlife Service, will need to be
prepared.
Proposed translocations of live deer or elk into or out of NPS units must receive critical
review and CWD risk assessment. Deer or elk will not be translocated from areas where
CWD is known to occur or where there is inadequate documentation to confirm absence of
the disease (i.e., 99% confident that CWD prevalence (proportion infected) is <1%).
Use of park or regional public affairs staff to assist in outreach to surrounding communities
and communications to park visitors regarding CWD and CWD management is encouraged.
Remain alert to potential threats from CWD and contact the NPS Biological Resource
Management Division (BRMD) or state wildlife agencies if further information or animal
testing is needed.
Shenandoah National Park General Management Plan/Environmental Assessment (1981a)
The Shenandoah National Park General Management Plan/Environmental Assessment
(GMP/EA) was approved for public review in June 1981. The GMP/EA identifies issues
associated with the Park’s:
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

land base (irregular boundary and shape of the Park, surrounding land use and development);
resource management (natural and cultural resources);
visitor use and interpretation (increased visitation, visitor use conflicts, illegal activities); and
development (facility conditions, demand for recreation facilities, automobile use) (NPS
1981a).
The GMP/EA provides alternatives specific to resolving the issues and makes an assessment of
the compatibility of each of them when combined with another. Although wildlife disease
management is not specifically addressed in the document under Natural Resources, all
alternatives considered for this CWD detection and assessment plan will be developed within the
overall framework of the Park’s GMP/EA.
Shenandoah National Park Resource Management Plan (1998)
The resource management plan was developed and presents a sound and scientific rationale for
ongoing resource management practices, recommends additional resource management practices
(where knowledge permits), and develops a program of additional projects and research.
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CWD Detection and Assessment Plan and EA
Shenandoah National Park
Although it does not address disease management, the plan lists several related objectives for
managing the natural resources in Shenandoah National Park:




To manage native Park wildlife so that it occupies its proper environmental niche.
To secure, through research or other means, adequate information on the Park’s natural
resources, cultural resources, and visitor use to develop the best possible Park management
strategies.
To encourage appropriate, safe, year-round use of the Park’s natural, cultural, recreational,
and wilderness resources in a manner that minimizes conflicts between visitor groups and
adverse effects on Park resources.
To foster public understanding and appreciation of the historical and present role of man and
natural process in shaping the changing environment of the Blue Ridge Mountains through
innovative environmental education and interpretive programs (NPS 1998).
The plan does address specific deer management issues and recommends that the Park collect
data on the health of the deer population at Shenandoah (NPS 1998).
Shenandoah National Park Deer Management Plan (1987)
Although there did not appear to be an excessive number of deer in the Park at the time of the
Park’s 1987 Deer Management Plan preparation, there was a concern that a concentration of deer
in developed frontcountry areas presents a safety hazard to visitors. Openings in the forest
created by campgrounds, picnic areas, concessions, and Skyline Drive provide an excellent
environment for growth of a diversity of browse, forbs, and grass. The result is a high population
of deer in developed areas where forage is abundant and human use is greatest (NPS 1987). As a
result, the Park developed a deer management plan that proposed several actions to address this
issue and to monitor the deer population at the Park. Selected management actions included nonlethal options such as:

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
Education;,
law enforcement (especially as it pertained to feeding of wildlife);
vegetation modification (mowing regimes in developed areas), the use of reflective devices
(to reduce safety hazards);
aversive conditioning (using noise, chemical repellents, or other methods to discourage
deer/human interactions);
capture of individual problem deer; and
annual relocation of “tame deer” from developed areas.
Since fall 2005, all deer relocation activities have been stopped at the Park in light of the
discovery of CWD in Hampshire County, West Virginia. While the plan does not address disease
management for white-tailed deer, it does list some objectives that would be considered in
developing CWD detection and assessment activities, including:

In backcountry and wilderness areas, allow the deer population to be regulated by natural
processes to the greatest extent possible.
14
CWD Detection and Assessment Plan and EA


Shenandoah National Park
Monitor the deer population and habitat condition to evaluate management actions and to
gather baseline data.
Work closely with local universities and state and federal resource management agencies to
develop needed research and cooperative deer management programs (NPS 1987).
Other Federal Related Laws, Policies, Plans, and Guidance
National Environmental Policy Act, 1969, as Amended
The National Environmental Policy Act (NEPA) was passed by Congress in 1969 and took effect
on January 1, 1970. This legislation established this country’s environmental policies, including
the goal of achieving productive harmony between human beings and the physical environment
for present and future generations. It provided the tools to implement these goals by requiring
that every federal agency prepare an in-depth study of the impacts of “major federal actions
having a significant effect on the environment” and alternatives to those actions. It also required
that each agency make that information an integral part of its decisions. NEPA also requires that
agencies make a diligent effort to involve the interested members of the public before they make
decisions affecting the environment. NEPA is implemented through regulations of the Council
on Environmental Quality (CEQ) [40 CFR 1500-1508]. The NPS has in turn adopted procedures
to comply with the act and the CEQ regulations, as found in Director's Order #12: Conservation
Planning, Environmental Impact Analysis, and Decision Making (DO-12) and accompanying
DO-12 handbook (NPS 2001).
Code of Federal Regulations, Title 43
Title 43 of the Code of Federal Regulations (CFR), Part 24 describes the four major systems of
Federal lands administered by the Department of the Interior. Section 24.4(f) states that “Units of
the National Park System contain natural, recreation, historic, and cultural values of national
significance as designated by Executive and Congressional action.” In describing appropriate
activities, it states that “[a]s a general rule, consumptive resource utilization is prohibited.” In
addition, Section 24.4 (i) instructs all Federal agencies of the Department of the Interior, among
other things, to “[p]repare fish and wildlife management plans in cooperation with State fish and
wildlife agencies and other Federal (non-Interior) agencies where appropriate.” It also directs
agencies to “[c]onsult with the States and comply with State permit requirements … except in
instances where the Secretary of the Interior determines that such compliance would prevent him
from carrying out his statutory responsibilities.”
Code of Federal Regulations, Title 36
Title 36 provides the regulations “for the proper use, management, government, and protection of
persons, property, and natural and cultural resources within areas under the jurisdiction of the
National Park Service” (36 Code of Federal Regulations (CFR) 1.1(a)). The applicable sections
of 36 CFR are summarized in Table 1.
15
CWD Detection and Assessment Plan and EA
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Executive Order 13112, Invasive Species
This executive order requires the NPS to prevent the introduction of invasive species, provide for
their control, and to minimize the economic, ecological, and human health impacts that invasive
species cause.
Animal Welfare Act (7 USC 2131-2159), as Amended
The Animal Welfare Act requires that minimum standards of care and treatment be provided for
certain animals bred for commercial sale, used in research, transported commercially, or
exhibited to the public. Individuals who operate facilities in these categories must provide their
animals with adequate care and treatment in the areas of housing, handling, sanitation, nutrition,
water, veterinary care, and protection from extreme weather and temperatures. CWD detection
and assessment activities with a research component would be regulated by this act.
National Chronic Wasting Disease Plan (2002)
The Plan for Assisting States, Federal Agencies, and Tribes in Managing Chronic Wasting
Disease in Wild and Captive Herds was released in June 2002. This plan is a result of a task
force made up of representatives from the U.S. Department of Agriculture, U.S. Department of
Interior, and various state wildlife and agriculture management agencies, as well as universities
from Arizona, Colorado, Iowa, Louisiana, Michigan, Missouri, Nebraska, South Dakota,
Georgia, Wisconsin, and Wyoming. To create this report, six working groups were created, each
of which developed goals for addressing CWD and actions to meet those goals. These issues
included communications, scientific and technical information dissemination, improving
diagnostics, disease management, identifying research needs, and developing consensus
standards for surveillance of both captive and free-ranging herds. This report also provided a
summary of existing state regulations and activities as they relate to CWD surveillance and
response (CWD Task Force 2002).
16
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Table 1. Sections of 36 Code of Federal Regulations applicable to this project.
Applicable
36 CFR Sections
Summary
36 CFR 1.1 (a, b)
These provisions state that the regulations are intended for the proper use,
management, and protection of property and natural resources within the jurisdiction of
the NPS. These regulations will be utilized to fulfill statutory purposes of the NPS,
including conservation of wildlife and providing for the enjoyment of resources in a
manner that will enable future generations to receive the same benefits.
36 CFR 2.1 (a)(1)(i)
This provision states that destroying or harming any living or dead wildlife (parts or
products thereof) is prohibited.
36 CFR 2.2 (a)(1-3)
These provisions state that the taking, feeding, touching, teasing, frightening,
intentionally disturbing or possessing wildlife or nesting habitats, except by authorized
hunting, is prohibited.
36 CFR 2.2 (b)(2); (d)
These provisions state that hunting is allowed within Park areas where the activity is
mandated in specific areas by Federal statutory law, if the superintendent determines
that such activity is consistent with public safety and enjoyment and sound resource
management principals. Hunting shall be allowed only pursuant to a special regulation.
The superintendent may establish procedures by which to transport lawfully taken
wildlife throughout the Park. Note: This regulation does not apply to Shenandoah
because hunting is prohibited by statute.
State-Related Regulations and Plans
Virginia Deer Hunting Regulations
Although state regulations do not apply on Park lands, they are the rules that govern wildlife
management on adjacent lands and are provided for clarity. The VDGIF, under the direction of a
governor-appointed board of directors, is specifically charged by the General Assembly with the
management of the state's wildlife resources, including white-tailed deer. Currently, in most parts
of the state, deer management objectives in Virginia are to control and stabilize populations.
These objectives are based on what the state calls a “cultural carrying capacity” - the maximum
number of deer that can coexist compatibly with humans. This management direction has
resulted in liberal deer hunting regulations and an increased kill of antlerless deer over the past
decade that appear to have stabilized herd growth in most areas. Based on their experience, the
state of Virginia has determined that deer hunting is a viable, cost- efficient management tool
that not only maintains a healthy deer resource but also diminishes deer crop damage levels,
deer-vehicle collision rates, and deer-ecosystem impacts (VDGIF 2006). Regulated deer hunting
provides over 2 million hunter days of recreation in Virginia. Hunters may take deer during
urban archery, early and late archery, early and late muzzle-loading, and general firearms
seasons. Deer regulations, which are summarized each year in a pamphlet published by the
VDGIF, cover bag limits, tag requirements, season dates, and legal methods and restrictions for
each season (VDGIF 2006). In Virginia, deer management objectives and regulations are set on a
county basis. At the state level, deer regulations are evaluated and amended every other year on
17
CWD Detection and Assessment Plan and EA
Shenandoah National Park
odd years; depending on management goals and the current status of the deer herd; amendments
may involve an adjustment in season lengths, bag limits, and/or the number of firearms season
either-sex deer hunting days. Deer management in Virginia is predicated on the fact that herd
density and health are best controlled by regulating antlerless deer kill levels (VDGIF 2006).
New regulations identified in the pamphlet for the 2006–2007 seasons included two regulations
to help control the introduction or spread of CWD in Virginia. The first prohibits placing or
distributing food, salt, or minerals to feed or attract deer (between September 1 and January 6);
thereby, limiting activities that concentrate deer and may increase the rate of transmission of the
disease. The second regulation prohibits the importation or possession of whole carcasses or
specified parts of carcasses from any cervid originating from a state or Canadian province in
which CWD has been found in free-ranging or captive deer (VDGIF 2006). The pamphlet has an
entire section dedicated to CWD and its management in Virginia, including information on the
surveillance efforts taken to date per the response and surveillance plans briefly discussed below
and covered in more detail in the section on Chronic Wasting Disease Response and Surveillance
Plans. Response Management Actions established in 2010 have the full force of the law, per
Director's authority in 4VAC-15-20-220 (see section on Response Management Actions below).
Virginia Department of Game and Inland Fisheries Chronic Wasting Disease Response
Plan (2009)
This response plan, developed by the VDGIF, outlines management activities to determine the
magnitude and geographic extent of CWD infection and control transmission. It addresses
general response activities (e.g., notification procedures, media/public relations), responses to
positive CWD cases in free-ranging and captive deer in Virginia, and responses to the discovery
of CWD within 20 miles of the Virginia border (VDGIF 2009). For more information, please
reference http://www.dgif.virginia.gov/wildlife/diseases/cwd/
Virginia Department of Game and Inland Fisheries Chronic Wasting Disease Surveillance
Plan (2005, 2007, and 2010)
The VDGIF developed this plan to address the positive detection of CWD in Hampshire County
(September 2005), West Virginia, within 50 miles of the Virginia border. It was subsequently
updated in August 2007 and is designed to detect CWD in separate geographic surveillance areas
that have been stratified as high, medium, or low-risk based on the presence of CWD in West
Virginia and the presence of captive cervid facilities. The 2007 plan expanded CWD surveillance
to encompass a larger portion of Virginia following the discovery of a positive deer 10 miles
southeast of Slanesville, West Virginia.
In July 2010, it was updated again to address the January 2010 positive detection of a hunterkilled deer in Frederick County, Virginia (less than one mile from the West Virginia border and
less than 12 miles from the Hampshire County, West Virginia CWD endemic area). The plan
identifies a range of potential measures and specific surveillance strategies that will be used in
each of these areas (VDGIF 2010). For more information, please reference
http://www.dgif.virginia.gov/wildlife/diseases/cwd/
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CWD Detection and Assessment Plan and EA
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Virginia Department of Game and Inland Fisheries CWD Response Team
Response Management Actions (2010)
These Recommended Management Actions were developed by the VDGIF CWD Response
Team following confirmation of CWD in a hunter-killed deer from western Frederick County in
January 2010. These recommendations include designating a Containment Area around the
CWD positive case, conducting mandatory hunter-killed deer testing in the Containment Area,
prohibitions on deer feeding and carcass transport, etc. For the full list of recommendations go
to: http://www.dgif.virginia.gov/wildlife/diseases/cwd/.
SCOPING PROCESS AND IMPACT TOPICS
Scoping
Scoping is an early and open process to determine the breadth of environmental issues and
alternatives to be addressed in a NEPA document. Scoping is used to identify which issues need
to be analyzed in detail and which can be eliminated from in-depth analysis. Internal scoping
typically includes NPS staff (park, region and WASO) and may also include federal, state or
local agencies with jurisdiction by law or special expertise. External scoping includes other
interested federal, state or local agencies, interested organizations or individuals, and the general
public.
The scope of issues to be addressed was discussed at an internal scoping meeting held when the
NPS Interdisciplinary Team (IDT) convened for this plan on November 13 and 14, 2006. The
NPS IDT consisted of Washington and Regional subject matter experts and Park staff with
knowledge and expertise of Park resources. Public meetings were held on March 28 and 29,
2007, at two locations near the Park to solicit public input on issues related to CWD and possible
management actions (see the Consultation and Coordination section for more information on
public scoping). In addition, the Park has been in communication with the VDGIF since the
CWD positive discovery in West Virginia.
Issues
Issues describe problems or concerns associated with current impacts from environmental
conditions or current operations, as well as problems that may arise from the implementation of
any of the alternatives. Issues can usually be described in terms of cause and effect; e.g., lack of
formalized access trails to historic sites results in formation of informal trails that result in
adverse impacts to the sites.
As a result of the Park’s internal and public scoping effort, several issues were identified
requiring further analysis in this plan. These issues represent existing concerns, as well as
concerns that may arise during consideration and analysis of alternatives.


Concern that CWD may spread into the Park from the CWD endemic area in Hampshire
County, West Virginia, or from Frederick County, Virginia.
Concern that spread of the disease into Shenandoah will result in a considerable impact to the
white-tailed deer population. This in turn could affect the Park’s vegetation dynamics, other
wildlife populations, wildlife viewing opportunities (visitor experience), hunting
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CWD Detection and Assessment Plan and EA

Shenandoah National Park
opportunities on adjacent private lands, businesses that rely on deer hunting (taxidermists,
hunting stores, check stations), crop depredation, and overall tourism in the Park and
surrounding areas (visitor use and socioeconomics).
Concern that, as the Park begins to implement actions to assess the disease once it is found,
there will be impacts on human health and safety and overall Park operations (including
budget).
Impact Topics
Based on the issues and concerns identified during scoping, specific impact topics were
developed to focus the environmental impact analysis. Impact topics are resources of concern
that could be affected, either adversely or beneficially, by the range of alternatives presented in
this EA. The use of specific impact topics allows comparison of the environmental consequences
of each alternative based on the most relevant topics. The impact topics are based on federal
laws, regulations, and Executive Orders, NPS Management Policies 2001, and NPS knowledge
of limited or easily impacted resources. Following is a list of the impact topics retained for
analysis, with a rationale for their selection, as well as a list of impact topics that were dismissed
from detailed analysis, with the rationale for dismissal.
Impact Topics Retained for Analysis
The impact topics selected for analysis in this Plan/EA include:








White-tailed Deer
Vegetation
Other Wildlife
State-listed Plant Species
Socioeconomics
Visitor Use and Experience
Human Health and Safety
Park Management and Operations
Chapter 3 describes the affected environment for each impact topic analyzed and presents the
potential impacts of implementing any of the alternatives.
White-tailed Deer
Options for CWD detection and assessment that would involve live testing or removing
presumably healthy animals may affect the white-tailed deer populations in the Park. In addition,
assessment activities may be implemented that would reduce the number of deer in a localized
area to try to ascertain prevalence of the disease. This would have an effect on the deer
population in that area; therefore, this impact topic was retained for further analysis.
Other Wildlife
According to the NPS Management Policies 2006, the NPS strives to maintain all components
and processes of naturally evolving park unit ecosystems, including the natural abundance,
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CWD Detection and Assessment Plan and EA
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diversity, and ecological integrity of animals. Studies have linked deer densities to effects on
other wildlife species such as birds (deCalesta 1994; McShea 2000; McShea and Rappole 2000).
As deer populations increase, increased browsing removes vegetation that provides cover,
forage, and nesting habitat for birds that nest on the ground or in the understory. CWD detection
and assessment activities could reduce the level of browsing (as a result of removing deer for
CWD testing), which could indirectly affect other wildlife. In addition, in some cases, deer
carcasses of CWD negative deer could be left on the ground after lethal CWD testing activities,
which would increase food resources for other wildlife (e.g., coyotes, vultures). These actions
may have measurable effects; therefore, this impact topic was retained for further analysis.
Vegetation
According to the NPS Management Policies 2006, the NPS strives to maintain all components
and processes of naturally evolving park unit ecosystems, including the natural abundance,
diversity, and ecological integrity of plants. Options for CWD detection and assessment that
would involve removing presumably healthy deer could reduce the number of deer that browse
in certain areas of the Park. These actions may have measurable effects on vegetation; therefore,
this impact topic was retained.
State-listed Plant Species
NPS Management Policies 2006 requires the Park to examine the impacts on state-listed
threatened, endangered, candidate, rare, declining, and sensitive species. It is possible that CWD
detection and assessment activities could affect some listed or rare plant species; therefore, the
impact topic of state-listed plant species was retained for further analysis.
Socioeconomics
Deer hunting contributes to the local economy of the area surrounding the Park. Options for
CWD detection and assessment that would affect the number of deer around the Park could
affect individuals and the local economy, including local sustenance hunting opportunities and
guided operations, by reducing animals available for hunting. If CWD is discovered in the area,
it could possibly influence hunting-related tourism around the Park due to the uncertainties
surrounding the disease. This could impact firearms stores, taxidermists, hotels, restaurants, and
hunting outfitters. Should there be any changes in visitation to the Park as a result of CWD
detection and assessment activities, it could have effects on local socioeconomics. This impact
topic is retained for analysis.
Visitor Use and Experience
Implementation of CWD detection and assessment activities may require certain areas of the
Park to be closed to public use during such activities, which would affect visitor use and
experience. Recreational resources in the Park that could be affected include trails, campgrounds,
access roads, and the Skyline Drive. CWD detection and assessment activities that result in fewer
deer in a particular area could reduce the opportunity to view deer, which may affect visitor use
and experience. The use of firearms could influence the soundscape at the Park which could also
impact visitor experience. This impact topic is retained for further analysis.
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CWD Detection and Assessment Plan and EA
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Human Health and Safety
CWD detection and assessment activities that involve capturing and immobilizing live animals
and performing tonsillar biopsies have the potential to affect the health and safety of the
individuals involved. Options that involve the use of firearms also have the potential to affect the
safety of Park staff, visitors, and adjacent landowners. These actions may have measurable
effects; therefore, this impact topic was retained for further analysis.
Park Management and Operations
In response to the detection of CWD in white-tailed deer less than 60 miles from the Park, the
Park has implemented opportunistic and targeted detection activities. In addition, the Park
conducts deer monitoring activities that require Park staff and funds. CWD detection and
assessment activities proposed in this Plan/EA would require additional staff time and
expenditures that could affect Park management and operations. Increased communication and
coordination with the state, as well as educating the public and other interested parties about
CWD detection and assessment, would also require additional staff time. These actions may have
measurable effects; therefore, this impact topic was retained for further analysis. It should be
noted that implementation of any alternative (plan) is contingent on future available funds.
Impact Topics Considered but Dismissed from Further Analysis
During scoping, several impact topics were identified that were initially considered but then
dismissed from further analysis in the Plan/EA. Impact topics dismissed from detailed
consideration are described below with the rationale for their dismissal.
Geology
No CWD detection or assessment activity proposed in the alternatives would be expected to have
any impact on the geology of the Park, therefore, this topic is not considered further in this EA.
Soils
Infected carcasses serve as a source of prions that persist in the environment and may serve as a
source of the disease following removal of CWD-positive deer (Miller et al. 2004). Results of
recent studies suggest that these prions bind to soil particles and continue to be infectious, and
can remain in soil environments for at least three years (Johnson et al. 2006; Schramm et al.
2006). These prions, however, do not cause erosion or change the physical properties of soils. In
addition, none of the alternatives presented would impact soils to a level that could be measured
or evaluated. Therefore, this impact topic was dismissed from further analysis.
Air Quality
Sources of air quality emissions from the implementation of CWD detection and assessment
activities include the potential for the use of incinerators to dispose of carcasses from CWD
testing. Virginia Department of Agriculture Regional Animal Health Laboratories, which have
the appropriate incinerators, are located in Harrisonburg and Warrenton. Incineration of
carcasses could have some measurable effects; however, these facilities are both approximately
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CWD Detection and Assessment Plan and EA
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25 miles from the Park, and they would have the proper permits for emission release. Therefore,
this topic was dismissed.
Water Quality
There is a lack of science indicating water as a method of CWD transmission (NPS Wildlife
Veterinarian Jenny Powers, personal communication). In addition, none of the proposed actions,
if implemented, would affect water quality; therefore, the topic of water quality was dismissed
from further analysis.
Floodplains or Wetlands
The implementation of CWD detection and assessment activities would not have any effects on
floodplains or wetlands in the Park; therefore, this topic was dismissed from further analysis.
Federally Listed Threatened and Endangered Species
Federally listed species or those proposed to be listed are protected under the Endangered
Species Act of 1973. The Shenandoah salamander (Plethodon shenandoah) and the small
whorled pogonia (Isotria medeoloides) are the only federally listed species in the Park. The Park
has determined that there will be no effect to either species as a result of any actions from this
Environmental Assessment. In the case of the Shenandoah salamander, this species is largely
subterranean and is found primarily in isolated high-elevation talus slopes in the Central District.
These areas are considered poor habitat for deer. In the case of the small whorled pogonia, it is
possible that the removal of a concentrated number of deer could have a negligible positive
impact because of reduced browse pressure. However, the likelihood of widely dispersed
potential deer removal influencing the historically-documented small whorled pogonia
population is extremely small. The small whorled pogonia occurrence is known historically from
only one location in the Park and was last seen in 1997. The proposed dispersed removal of a
relatively small number of deer will have little direct influence on the vegetation growth or
species composition in any one area. Therefore, this topic has been dismissed from further
analysis with a No-Effect Section 7 determination.
Reptiles, Amphibians, Fish and Aquatic Invertebrates
Implementation of any of the CWD detection and assessment activities would have negligible
impacts to reptile, amphibian, and fish species; therefore, this topic was dismissed from further
analysis.
Unique Ecosystems, Biosphere Reserves, and World Heritage Sites
There are no known Biosphere Reserves, World Heritage Sites, or unique ecosystems listed in
the Park; therefore, this topic was dismissed from further analysis.
Wilderness
The NPS has decided not to conduct any CWD detection and assessment actions within the
designated wilderness areas of the Park for two reasons. Foremost, activities conducted in
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CWD Detection and Assessment Plan and EA
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designated wilderness are to be “for the purposes of wilderness” (NPS 1998). Secondly, deer in
wilderness are more dispersed and at a lower density. Frontcountry deer densities exhibited a
clumped distribution pattern with deer most frequently using areas receiving intense human use
(Scanlon and Vaughan 1987). These areas also have the highest densities of deer, so testing in
these areas versus wilderness would increase the likelihood of detecting the disease presence. In
addition, it is believed that road-killed animals, such as those found along Skyline Drive, have a
higher probability of being positive for CWD than others, but data do not exist to show how
much higher. Because testing deer in the wilderness areas as part of this plan is not directly tied
to wilderness management, and animals located in wilderness would contribute a very minimal
amount to the testing efforts, wilderness areas are not included in this Plan/EA.
Cultural Resources
Section 106 of the National Historic Preservation Act of 1966, as amended, requires federal
agencies to take into account the effects of their undertakings on historic properties and afford
the Advisory Council on Historic Preservation (ACHP) a reasonable opportunity to comment.
The historic preservation review process mandated by Section 106 is outlined in regulations
issued by ACHP. NPS Management Policies (2006) states that the NPS will endeavor to protect
cultural resources against overuse, deterioration, environmental impacts, and other threats
without compromising the integrity of cultural resources (Section 5.3.1). None of the proposed
actions under any of the alternatives evaluated in this Plan/EA would have any effects on
archeology, cultural landscapes, historic structures, ethnographic resources, or museum
collections; therefore, these impact topics were dismissed from further analysis.
Environmental Justice in Minority and Low-Income Populations
Presidential Executive Order 12898 requires Federal agencies to identify and address
disproportionately adverse impacts of their programs, policies, and activities on minority
populations and low-income populations. None of the alternatives would result in
disproportionately adverse health or environmental effects on minorities or low-income
populations as defined in the EPA Environmental Justice Guidance because, although such
populations exist, the effects of the alternatives would be equal across all populations. Therefore,
this topic was dismissed from further analysis.
Protection of Children
Executive Order 13045 requires Federal actions and policies to identify and address
disproportionately adverse risks to the health and safety of children. Since none of the CWD
management alternatives involves disproportionate risks to the well-being of children, this was
dismissed from further analysis.
Indian Trust Resources
Secretarial Order 3175 requires that agencies assess environmental impacts of proposed actions
on Indian trust resources. The federal Indian trust responsibility is designed to protect tribal
lands, assets, resources, and treaty rights, and it represents a duty to carry out the mandates of
federal law with respect to American Indian and Alaska Native tribes. There are no Indian trust
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CWD Detection and Assessment Plan and EA
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resources within or adjacent to the Park, therefore, this topic was dismissed from further
analysis.
Land Use
The majority of land adjacent to Park boundaries is in private ownership. Primary land uses
currently are forests (approximately one half of the land area), agriculture and idle open fields
(approximately one third of the land area), residential, and commercial and industrial sites.
During the last 10 years a shift has taken place in the demographics of boundary residents
towards greatly increased numbers of individual and organized multi-dwelling residences. None
of the alternatives would have any impact on the way landowners around the Park use their
lands, therefore, the topic of land use was dismissed from detailed analysis.
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CWD Detection and Assessment Plan and EA
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ALTERNATIVES
This Alternatives section describes a range of possible actions that could be implemented for
detection and assessment of CWD in the Park. NEPA requires federal agencies to explore a
range of reasonable alternatives, meaning alternatives that would meet the Park's objectives and
be technically and economically feasible, and to analyze what impacts the alternatives could
have on the human environment, which is defined as the natural, cultural, and physical
environment, and the relationship of people with that environment.
The alternatives under consideration include the “No Action” alternative (Alternative A) as
prescribed by NEPA. The No Action alternative is the continuation of the current Park CWD
detection practices and provides a baseline of existing conditions and actions for evaluating
changes and impacts of the action alternatives.
Two action alternatives (Alternatives B and C) are analyzed in this EA. The action alternatives
were developed based on scoping by the interdisciplinary team, information provided by the
science team, and public input. These alternatives meet, to a large degree, the management
objectives for the Park and also the purpose of and need for action. It should be noted that the
implementation of any given alternative is subject to future availability of funds.
The planning process incorporates the use of an adaptive management approach. Thresholds for
taking action are described first because this information is needed to fully understand the action
alternatives. Detailed descriptions of each alternative are presented next, followed by a
comparison of how well each alternative meets the objectives and a summary comparison of the
impacts of the alternatives. The remainder of the chapter addresses alternatives that were
considered but eliminated from detailed analysis, and the identification of the NPS preferred
alternative and the environmentally preferred alternative.
THRESHOLDS FOR TAKING ACTION UNDER THE ACTION ALTERNATIVES
The action thresholds define points when detection or assessment actions are taken or altered. In
this Plan/EA, four distinct action thresholds determine the detection and assessment actions
available for use under the action alternatives (alternatives B and C). The thresholds, indicated
by distance of the nearest positive CWD detection to the Park, are keyed to the level of CWDassociated risk to white-tailed deer populations within the Park. It is important to note that
although NPS actions may be triggered by CWD detections outside the Park, the NPS would
only conduct detection and assessment actions on federal lands within the legislated boundary of
the Park, excluding designated wilderness.
The first threshold is defined when the nearest positive CWD detection occurs greater than 60
miles from the nearest park boundary. NPS guidance recommends certain CWD related actions
for NPS units located within 60 miles of a positive CWD case, and therefore, the second action
threshold is met when the nearest positive CWD detection is between 30 to 60 miles from the
Park. The third action threshold is defined to be consistent with the mean maximum distance
traveled by deer in the region, and is met when the nearest positive CWD detection is five to 30
miles from the Park. The fourth action threshold is defined to be consistent with the five-mile
radius distance around a known infected animal applied by Virginia and neighboring states when
26
CWD Detection and Assessment Plan and EA
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establishing their zones for taking action related to CWD assessment and is met when the nearest
positive CWD detection is less than 5 miles from the Park or within the Park (Figure 2)
In accordance with the purpose of and need for this plan, the alternatives describe activities
meant to detect CWD and those meant to assess the intensity and extent of the disease. Detection
activities are those taken for the purpose of determining whether the disease is present or
absent within a biologically defined population. Assessment activities are those taken for
the purpose of determining the prevalence and distribution (i.e., proportion infected and
extent) of the disease once it has been detected within a biologically defined population. Deer
at Shenandoah National Park are, largely, part of a larger regional deer population which
includes deer often found near but outside of the Park. Because biological population boundaries
are vague and often influenced by environmental factors (e.g., weather, forage availability) and
human factors (e.g., hunting pressure) which are difficult to predict or control, we have chosen to
define the biological population as deer found within the Park or neighboring counties.
SAMPLE SIZE REQUIREMENTS
Detection
The number of samples needed to determine presence or absence of the disease, with relative
certainty is based on the size of a population. In defining a “population,” it makes sense to
consider deer that congregate together as a biological population. Meaningful biological
populations of free-ranging white-tailed deer are difficult if not impossible to define. For
purposes of this plan, we have chosen to include deer within counties adjacent to the Park as part
of the Park’s biological population, acknowledging that those closest to the Park are more likely
to be mixing/assimilating with the resident Park deer most frequently. Since there is known
movement of deer across Park boundaries in addition to deer that reside solely in the Park, it is
reasonable to assume that some of the deer tested by the state outside of the Park represent
samples taken from the Park’s biological population of deer.
We have chosen to begin intensive CWD detection actions within the deer population when a
known CWD case is within 30 miles of the Park based on estimated maximum deer movement
(Scanlon and Vaughan, 1981). The disease is most likely to be detected in Park district(s) closest
to the CWD case. Therefore, sampling efforts will be concentrated in Park district(s) within 30
miles of the case. CWD samples collected by VDGIF from deer residing in counties bordering
these districts will be combined with Park samples to meet sample size requirements. Our goal
is to meet statistically valid sampling requirements to have a 95% probability of detecting
the disease if it is present within the population at or above 2% prevalence (i.e., 2 in 100
deer have the disease) over a three-year sampling period. To be conservative in our ability to
detect the disease if it is present, we have assumed an infinite deer population, which will lend
more certainty to our findings if we fail to detect CWD. This sampling effort gives the option of
testing a “weighted total” (Walsh and Miller 2010) of 300 deer (Samuel et al. 2003) from Park
district(s) and adjacent counties. Because the samples may be weighted, fewer than 300
individual deer may actually have to be sampled to meet the above sampling requirements – see
below and Appendix B for more detail.
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Figure 2. Map showing the 30-mile and five-mile buffers around Shenandoah National Park which represent thresholds for initiating intensified
detection and assessment actions.
CWD Detection and Assessment Plan and EA
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Table 2. Action thresholds for disease detection and assessment.
Threshold
Disease Detection Activities
Disease Assessment Activities
No assessment action
Positive CWD
No required detection actions, although Park units are
Detection
encouraged to conduct opportunistic and targeted
greater than 60 surveillance of susceptible populations, regardless of their
miles from
distance from a known case (NPS 2002a). (Alt. a, b, c)
Park.
If positive sample is found, move to assessment actions (i.e.,
actions that occur if CWD is found within five miles of the
Park).
Positive CWD
Detection 30 to
60 miles from
Park.
Positive CWD
Detection five
to 30 miles
from Park.
1. Opportunistic surveillance (Alt. a, b, c) throughout the No assessment action
Park
2. Targeted surveillance (Alt. a,b, c) throughout the
Park
3. Live test if opportunity arises (Alt. b, c) throughout the
Park
If positive sample is found move to assessment actions.
1. Enhanced opportunistic surveillance (Alt. b,c)
throughout the Park
No assessment
2. Enhanced targeted surveillance (Alt. b,c) throughout
the Park
3. Enhanced live test (Alt. b,c) throughout the Park
4. Lethal removal of healthy appearing deer if needed to
meet sample size requirements. (Alt. b) in districts
and counties within 30 miles of the CWD detection.
 All activities will be used to obtain a statistically
valid sample size (95/1) for disease detection
over a period of three years (Walsh and Miller
2010), and will be repeated if positive cases of
CWD continue to be found outside of the Park.
 Deer sampled by VDGIF from counties
bordering affected Park districts during the same
time period will be considered part of the sample
If positive sample is found, move to assessment actions (i.e.,
actions that occur if CWD is found within five miles of the
Park).
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Threshold
Disease Detection Activities
Disease Assessment Activities
Positive CWD
Detection
within five
miles of Park
or in Park.
Assume disease is within Park and move to assessment
mode.
1. Enhanced opportunistic surveillance (Alt. b, c) (to assess
distribution)
2. Enhanced targeted surveillance (Alt. b, c) (to assess
distribution)
3. Live test (Alt. b, c)
4. Lethal removal of healthy appearing animals (Alt. b)
 Live test and lethal removal activities will be used to
obtain a statistically valid sample to estimate the
prevalence ± 2% with 95% confidence interval within
the population bounded by a Park district(s) within
five miles of the case within two years.
 Samples collected by VDGIF will be considered part
of the sample if they are taken from within five miles
of the CWD case.
If assessment indicates disease is established or spreading,
move to long-term management. (Long-term management
options will be specified in future planning documents.)
CWD Detection and Assessment Plan and EA
Shenandoah National Park
It is assumed that samples will be equally distributed across the landscape. While this is not
always possible, an effort must be made to sample throughout the sampling area. These samples
could be collected in a variety of ways including targeted, opportunistic, live, and lethal
surveillance as outlined in the alternatives below. Each method of sample collection is weighted,
with targeted and opportunistic samples adding more to the total sample size than those collected
from apparently healthy deer (Walsh and Miller 2010). For example, road-killed animals
(Krumm et al. 2005) and those demonstrating clinical signs of CWD (Miller et al. 2000) are
more likely to test positive for the disease and represent a more valuable diagnostic sample to
detect new foci of disease. Sampling animals with a higher likelihood of having the disease will
reduce the number of samples needed from the Park. The only available CWD sample weighting
system was created by Walsh and Miller (2010). While this system was modeled on data derived
from mule deer within the CWD endemic region of Colorado and the weighting may not be
entirely accurate for eastern white-tailed deer, it represents the best available science to optimize
CWD surveillance efforts. If similar sample weighting schemes are created using white-tailed
deer specific data they will be adopted during the lifetime of this plan.
Assessment
To assess disease intensity once it has been detected within five miles of the Park, we will
estimate the prevalence (± 2% with a 95% confidence interval) in deer residing within a 5-mile
radius of the index case (working cooperatively with VDGIF on lands outside SHEN). Samples
from inside the Park will be collected based on area extent and estimated deer density within and
outside of the Park. The maximum number of samples the NPS would contribute to the 5-mile
radius (79-mi2 area) established by the VDGIF around each positive case would be 69 deer for
the first positive CWD case and 97 deer for the second positive case (based on likely scenario
estimates). As the number of cases detected increases, additional samples are needed to
accurately estimate prevalence and sample size would increase accordingly (Appendix B).
Assessment samples will not be weighted because it could bias estimates of prevalence (i.e.,
percent of deer with the disease).
SAMPLING PERIOD
Sampling periods have been defined for both detection and assessment activities. Detection
sampling will occur on a three-year cycle. If sample size is achieved in year one, no additional
samples will be taken in year two or three. Assessment sampling will occur on a two year cycle.
If sample size is achieved in year one, no additional samples will be taken in year two. Calendar
years will be used for data analysis consistency with state agencies.
TISSUE SAMPLING AND CARCASS HANDLING REQUIREMENTS
Deer killed as part of targeted surveillance (i.e., deer with clinical signs of CWD) would be
placed in a plastic bag and taken to a designated holding area with an impervious surface where
they will be kept until test results are received. Carcasses that are CWD negative would be
disposed of using traditional methods (i.e., decompose on the landscape for small numbers of
carcasses or landfill for large numbers). The NPS will adopt the state’s preference to landfill any
diseased carcasses. However, if landfill is not possible, other options would be considered,
including incineration or alkaline digestion. Virginia Department of Agriculture Regional
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CWD Detection and Assessment Plan and EA
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Animal Health Laboratories operates incinerators located in nearby Harrisonburg and Warrenton,
Virginia. Deer recovered from opportunistic sampling will be left onsite (in forest settings) to
decompose naturally and their location will be noted using a global positioning system (GPS). If
an opportunistically collected sample tests positive for CWD, the carcass remains will be
collected and disposed of above. If CWD is found within the Park, all carcasses will be handled
as targeted surveillance.
NPS will regularly coordinate and cooperate with appropriate state and federal agencies on test
results. The NPS Biological Resource Management Division tracks samples and maintains a
CWD testing database. All positive detections would be reported to the Park, NPS regional staff
and the Regional Director. Due to the proximity of Northeast Region and National Capital
Region park units, a positive CWD test result would be reported to both regions. All test results
would also be reported to the state. Shenandoah National Park currently coordinates their CWD
surveillance efforts with the state primarily through communications with the state CWD
coordinator to share test results. The Park also maintains a deer mortality database and tracks the
results of CWD testing.
ELEMENTS COMMON TO ALL ALTERNATIVES
The following actions would be common to all alternatives:


Provide training for staff and volunteers conducting observations for targeted surveillance.
Provide education/outreach:
 The Park conducts public outreach and education regarding CWD using a variety of
posters, publications (including state brochures on CWD), and personal interpretation and
by guiding individuals to resources such as the VDGIF and CWD Alliance websites.
Information may also be made available on the Park website.

In addition to public education/outreach, information would be made available to Park
staff to improve interpretation for the public.

The NPS would also coordinate with the state education/outreach programs related to
CWD (e.g., participate in meetings held by the state on the subject).
ALTERNATIVE A: NO ACTION (CONTINUE CURRENT ACTIONS)
Section 1502.14(d) of the Council on Environmental Quality (CEQ) regulations for
implementing NEPA requires that the alternatives analysis in an EA include the alternative of no
action. In the case of developing a plan for CWD detection and assessment, the No Action
alternative represents no change from current activities being conducted by Park staff. The No
Action alternative also includes any actions that the Park would undertake if the opportunity
presented itself. Three detection or assessment options are presented.
32
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Detection
Opportunistic Surveillance
Opportunistic surveillance includes taking diagnostic samples for CWD testing from deer found
dead—that is, deer that have died in the Park due to disease, predators, vehicle collisions, other
trauma-related mortality, or those killed in the Park for other purposes (e.g., injured deer
euthanasia). If an employee finds a dead deer in the Park or along Skyline Drive, it is reported to
the Park Biologist or Chief of Natural and Cultural Resources and a determination would be
made as to whether or not samples should be taken and sent for CWD testing as part of
opportunistic surveillance. Presently, approximately 80% of the deer killed in the Park are tested.
Due to staffing limitations, not all samples are located or collected - especially on weekends. As
of October 19, 2010, 57 animals have been tested since 2006.
Targeted Surveillance
Targeted surveillance involves lethal removal of deer that exhibit clinical signs consistent with
CWD for testing (NPS 2007). Targeted surveillance removes a potential source of CWD
infection and is an efficient means of detecting new infections (Miller et al. 2000). Since 2008,
the Park has used two seasonal, summer staff to look for deer with clinical signs of CWD. In all
instances, Park staff contact the Park Biologist or Chief of Natural Resources to report clinically
suspect deer. The Biologist or Chief of Natural and Cultural Resources decides if the animal has
clinical signs consistent with CWD and is appropriate for lethal removal. Law enforcement
rangers or Park Biologists are authorized to kill a suspect deer. Procedures for shooting,
collecting samples, handling, cleanup, and storage are based on information provided in A
National Park Service Manager’s Reference Notebook to Understanding Chronic Wasting
Disease, Version 4 (NPS 2007). To protect visitor health and safety during targeted surveillance,
any area where firearms are used is closed to visitors. To date (October 2010), no deer exhibiting
clinical signs of CWD have been observed in or near the Park. Lethal removal of sick individuals
from a population is currently approved under NEPA by a categorical exclusion 3.4E (3) with
documentation (NPS 2001).
Live Testing and Removal of Positives
A live CWD test available for deer will be used as part of detection actions if the opportunity
arises through other research opportunities. The live test requires anesthetizing the animal,
conducting a tonsillar biopsy or a rectal mucosal biopsy, and radio-collaring the animal so it can
be tracked and removed if the test is positive for CWD. Live-testing would only be used for
detection efforts when animals are being collared in the Park by either NPS staff or researchers
as part of other projects.
Live testing for CWD detection would be conducted on both male and female deer. Live tests
would typically be taken in the fall/winter to avoid causing an animal heat stress or handling latestage pregnant females. Samples would only be taken once every one to two years to avoid
undue stress on a given animal and to avoid re-testing deer that were CWD negative before the
disease may have had the chance to emerge. Positive animals would be relocated using telemetry
and lethally removed from the population.
33
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Assessment
No prevalence assessment actions will take place because opportunistic and targeted surveillance
activities provide inherently biased samples and are not appropriate for determining the intensity
of the disease. However, standard opportunistic and targeted surveillance will continue to be
used to attempt to find new areas within the Park where CWD occurs and therefore minimal
distribution assessment actions will be conducted.
Implementation Costs
Implementation costs of Alternative A are summarized in Table 3.
Table 3. Cost estimates for implementing Alternative A.
Annual
Cost
Cost for the
10-Year
Planning Period*
Action
Assumptions
Opportunistic surveillance
Sampling ~ 15 deer per year
$1700
$19,000
Targeted surveillance
Incidental survey by temp wildlife techs
$5000
$55,000
*allowing for inflation
ALTERNATIVE B: ENHANCED DETECTION AND ASSESSMENT, INCLUDING
LETHAL REMOVAL FOR TESTING
Alternative B incorporates an adaptive management approach which includes four options for
both detection and assessment that may be selected based on the current status of CWD
occurrence in the vicinity of the Park and the relative risk of infection.
Detection
Enhanced Opportunistic Surveillance
If a detection occurs between 30 and 60 miles of the Park opportunistic surveillance is the same
as described under Alternative A, taking advantage of deer that die in the Park due to disease,
predators, vehicle collisions, other trauma-related mortality, and lethal removal for other
purposes (e.g., research). If a positive CWD detection occurs in between five and 30 miles,
opportunistic surveillance is enhanced. To enhance opportunistic surveillance the NPS would
increase the number of samples for CWD testing by testing all deer found dead (that includes all
deer from the South District). In addition, Park staff would coordinate with the state and/or
county that samples be taken from carcasses found on state/county roads either by state/county or
Park employees. Park neighbors will also be encouraged to report the location of any deer found
dead in the state/county or the Park.
34
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Enhanced Targeted Surveillance
As described under Alternative A, this technique would involve Park staff looking for deer
showing clinical signs of CWD. These deer would be lethally removed for testing. If a positive
detection occurs in between 30 and 60 miles from the Park, targeted surveillance would be
conducted as described under Alternative A. If a positive CWD detection occurs in between five
and 30 miles from the Park, targeted surveillance would be enhanced by dedicating a full-time
employee (NPS or contractor) to look for animals displaying clinical signs of CWD from March
through November for two days a week. Enhanced targeted surveillance would be limited to
federal lands within the legislated boundaries excluding wilderness areas. The individual would
be qualified to kill deer and take appropriate CWD samples. In addition, the Park will encourage
local visitors, volunteers, and other NPS staff or researchers working in the Park to look for deer
with clinical signs of the disease.
As described under Alternative A, deer removed as part of enhanced targeted surveillance would
be shot, sampled, and taken to a designated holding area until test results were received. Any
area where firearms are used will be closed and visitors notified of the reasons for the closure.
Enhanced Live Testing and Removal of Positives
A live CWD test available for deer will be used as part of detection actions if the opportunity
arises through other management or research actions. The live test requires anesthetizing the
animal, conducting a tonsillar biopsy, and radio-collaring the animal so it can be tracked and
removed if the test is positive for CWD. Live testing would only be used for detection efforts
when animals are being collared in the Park by either NPS staff or researchers as part of other
projects.
Live testing for CWD detection would be conducted on both male and female deer. Live tests
would be taken in the fall/winter to avoid causing an animal heat stress or handling late-stage
pregnant females. Samples would only be taken once every 1-2 years to avoid undue stress on a
given animal and to avoid re-testing deer that were CWD-negative before the disease may have
had the chance to emerge. However, this would not preclude the NPS from sampling deer at
other times of the year. Positive animals would be relocated using telemetry and lethally
removed from the population. Live testing could be enhanced by testing any deer in hand and
pursuing additional opportunities (e.g., research projects, BRMD assistance) for live testing.
Lethal Removal of Healthy Appearing Animals
This alternative would involve killing deer that appear healthy and testing them for CWD. Lethal
removal for detection is only appropriate when CWD is found within 5-30 miles of the Park.
This differs from targeted surveillance which lethally removes and tests only deer that show
clinical signs of CWD. The purpose of the removal of healthy appearing animals for testing is to
detect the presence of CWD, not for reducing the deer population. A CWD case could occur
outside the Park and prompt this action (see Table 2); however, NPS actions would only occur
on federal lands within the legislated boundary of the Park excluding wilderness areas.
Designated wilderness areas were removed from consideration for CWD sampling due to limited
access and the fact that deer removal work is inconsistent with wilderness values. Lethal
35
CWD Detection and Assessment Plan and EA
Shenandoah National Park
removal will contribute to disease detection sampling to be 95% confident of identifying the
disease if it is present in at least a 2% of the deer population (95/1) within three years, as
described under the ‘Detection’ section above (Appendix B).
During detection efforts, lethal removal will concentrate on testing deer from high density areas
(e.g., Big Meadows, Skyline Drive). To achieve the numbers required to ultimately meet the 95/1
goal during the sampling period, the NPS will conduct generally distributed testing of both male
and female deer with emphasis given to those samples which will give the largest amount of
information on a weighted sampling scale (e.g., adult males greater than one year of age).
Lethal removal activities would be conducted by qualified NPS employees or authorized agents
(e.g. professional sharpshooter contractors). Training will include actions related to firearms
safety, sample collection, carcass disposal and decontamination. Lethal removal may be
conducted at any time of the year as approved by the superintendent to allow flexibility to take
these actions whenever thresholds are met. Lethal removal with firearms may be conducted from
stands and blinds. Lethal removal actions conducted at night may also be conducted using
spotlights or night vision equipment. The NPS will coordinate the timing of lethal removal with
the state to maximize efforts by both agencies. Comprehensive safety measures will be taken
before any removal action to maximize employee and visitor safety.
During lethal removals, if necessary, Park staff would clear or close an area to all visitors to
protect visitor health, safety, and experience. The Park would use public postings, web notices,
and press releases to notify the public of the closure.
Table 4. Criteria for using lethal removal for CWD detection by action zone under Alternative
B.
Lethal removal
for detection
within the Park
CWD
CWD
CWD
Case between 5 and Case between 30
Case within 5 miles 30 miles of the
and 60 miles of
of the Park
Park
the Park
CWD
Case further than 60
miles from the
Park
Not appropriate
Yes
Not appropriate
if CWD is found in this
Zone, initiate
assessment action
Lethal removals for
testing would be used
to supplement other
samples taken from the
Park (and/or by the
VDGIF) to meet the
detection goal of 95/1
over three years.
Not appropriate
36
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Assessment
Enhanced Opportunistic Surveillance
Enhanced opportunistic surveillance for assessment would occur in the same manner as
previously described under detection. The goal of enhanced opportunistic surveillance as an
assessment action is to provide samples to assess the distribution of the disease.
Enhanced Targeted Surveillance
Enhanced targeted surveillance for assessment would occur in the same manner as previously
described under detection. The goal of enhanced targeted surveillance as an assessment action is
to provide samples to assess the distribution of the disease.
Enhanced Live Testing and Removal of Positives
Enhanced live testing for assessment would occur in the same manner described under detection.
The goal of enhanced live testing as an assessment action is to provide samples to assess the
prevalence and distribution of the disease.
Lethal Removal of Healthy Appearing Animals
When a positive CWD detection occurs within five miles of the Park, it is assumed that CWD is
within the Park. The immediate focus shifts to assessment of CWD prevalence and distribution.
The purpose of the removal of healthy appearing animals is for CWD assessment, not for
reducing the deer population. Park staff would coordinate with the state regarding the number of
samples required to assess the distribution and prevalence of CWD within a given area. The Park
would maximize the number of samples taken from enhanced opportunistic and targeted
surveillance, and live testing before taking samples by lethal removal. Test results from deer
sampled by the state within five miles of the index case would be pooled with Park samples to
assess disease prevalence. Park sample contribution would be appropriate to land mass or
proportion of the Park within five miles of the detected CWD positive animal, and deer density
estimates in that area of the Park. The maximum number of deer removed to estimate disease
prevalence ± 2% with a 95% confidence interval is 69 animals for the first positive CWD
detection (see Appendix B).
37
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Table 5. Criteria for using lethal removal for CWD assessment by action zone.
Lethal removal
for assessment
within the Park
CWD
CWD
Case between 5 and
Case within 5 miles 30 miles of the
of the Park
Park
CWD
Case between 30
and 60 miles of the
Park
CWD
Case further than
60 miles from the
Park
Yes
Not appropriate
Not appropriate
Not appropriate
Ideally evenly
distributed samples will
be collected to achieve
a statistically valid
sample to estimate the
prevalence ± 2% (95%
confidence interval).
Samples collected by
VDGIF will be
considered part of the
sample if biologically
relevant (i.e., if they are
taken within five miles
of the index case).
Implementation Costs
Implementation costs of Alternative B are summarized in Table 6.
Table 6. Cost estimates for implementing Alternative B.
Cost for
10-Year
Planning
Period*
Action
(all for detection and assessment)
Assumptions
Annual
Cost
Enhanced Targeted Surveillance
More NR temp. staff tasked w/this
$9,000 $95,000
Enhanced Opportunistic Surveillance
20-25 deer sampled per year
$2,825 $30,250
Enhanced Live Testing
e.g. test approx. 30% of Big
Meadows Popn. =
80 deer (max #) @$800/deer
Lethal Removal of Healthy Appearing Deer Assume 80 deer removed &
tested/yr
*allowing for inflation
$68,000 $68,000 (1yr)
$20,000 $104,000 (5 yr)
ALTERNATIVE C: ENHANCED OPPORTUNISTIC AND TARGETED
SURVEILLANCE BUT NO LETHAL REMOVAL FOR TESTING
Alternative C would include three options for both detection and assessment that could be
selected for use based on the current status of CWD occurrences in the vicinity of the Park and
38
CWD Detection and Assessment Plan and EA
Shenandoah National Park
the relative risk of infection. This alternative differs from Alternative B in that there would be no
lethal removal of healthy appearing deer. Therefore, even if CWD were detected within 5 miles
of the Park, assessment options to determine the prevalence and distribution of the disease would
not include lethal removal of deer.
Detection
Opportunistic Surveillance
Regular between 30 and 60 miles of the Park and Enhanced (i.e., increased effort) between 5
and 30 miles of the Park, as described in Alternative B.
Targeted Surveillance
Regular between 30 and 60 miles of the Park and Enhanced (i.e., increased effort) between 5
and 30 miles of the Park, as described in Alternative B.
Live Testing and Removal of Positives
Regular between 30 and 60 miles of the Park and Enhanced (i.e., increased effort) between 5
and 30 miles of the Park, as described in Alternative B except that live testing would be essential
to meet sample size requirements for estimating prevalence. Any CWD test positive deer would
be removed as described above.
Assessment
Enhanced Opportunistic Surveillance
As described under Alternative B.
Enhanced Targeted Surveillance
As described under Alternative B.
Enhanced Live Testing and Removal of Positives
As described under Alternative B except that live testing would be essential to meet sample size
requirements for estimating prevalence.
Implementation Costs
Implementation costs of Alternative C are summarized in Table 7.
39
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Table 7. Cost estimates for implementing Alternative C.
Action
(all for detection
with limited assessment)
Assumptions
Annual
Cost
Cost for
10-Year
Planning
Period*
Enhanced targeted surveillance
More NR temp staff tasked with this
$9,000
$95,000
Enhanced opportunistic
surveillance
~25 deer sampled per year
$2,825
$30,250
Enhanced live testing
Test about 30% of Big Meadows pop. =
80 deer at BMA ($800/deer)
$68,000
$685,000
*allowing for inflation
USE OF ADAPTIVE MANAGEMENT
IN THE CWD DETECTION AND ASSESSMENT PLAN
Successful management of natural systems is a challenging and complicated undertaking.
Adaptive management is based on the assumption that current resources and scientific
knowledge is limited and that a certain level of uncertainty exists. Nevertheless, an adaptive
management approach attempts to apply available resources and knowledge and adjusts
management techniques as new information is revealed. Holling (1978) first described the
principle of adaptive management as requiring management decisions and policies to be viewed
as hypotheses subject to change—as sources of continuous, experimental learning.
The Department of the Interior requires that its agencies “. . . use adaptive management, as
appropriate, particularly in circumstances where long-term impacts may be uncertain and future
monitoring will be needed to make adjustments in subsequent implementation decisions” (46
CFR 46.125). The Department of the Interior has outlined the adaptive management approach in
a technical document developed to provide guidance to all department bureaus and agencies
(Williams et al. 2007).
The adaptive management process has six steps: assessing the problem; designing management
actions; implementing those actions; monitoring the effects of the actions; evaluating the
monitoring data; and adjusting future actions based on those data. This process works well when
integrated with the process required by NEPA. As with adaptive management, the primary goal
of NEPA is informed decision-making by understanding the impacts of a proposed federal
action. The NEPA process can provide an adaptive management framework, define thresholds,
outline actions, and assess their potential impacts, thereby allowing for the implementation of
subsequent actions described in the adaptive management component of the plan. This approach
allows resource managers more flexibility and a better chance of achieving the desired condition
stated in the plan and can reduce or limit future environmental review requirements.
40
CWD Detection and Assessment Plan and EA
Shenandoah National Park
The action alternatives (alternatives B and C) in this plan incorporate adaptive management
approaches to meet the objectives of the plan. Under the action alternatives, the NPS would
monitor the results of CWD testing from inside and outside the Park. Based on this monitoring,
the NPS would evaluate what action thresholds had been met to determine available tools for
detection actions. If monitoring indicated a CWD-positive case in or within 5 miles of the Park,
detection actions would be ended and assessment actions would be undertaken.
The NPS would also take an adaptive approach under the action alternatives in determining the
extent to which detection and assessment activities continue into the future. If detection actions
did not reveal a CWD-positive deer for five consecutive years, most sampling would be
discontinued and the Park would be considered CWD free (opportunistic and targeted
surveillance would continue). Alternatively, if monitoring of test results indicated that the
disease was “spreading” or “established,” disease management activities outside the scope of this
plan/EA may need to be implemented, which would require additional planning and NEPA
analysis. For the purposes of this plan/EA, spreading is defined as when the five-mile radius
surveillance areas established around individual positive CWD cases extends beyond 30 miles
41
ent Plan and EA
Shenandoah National Park
Assess problem/develop actions
Implement selected action alternative
ns outside the park. Is a
within five miles?
s
No
Enhance detection efforts if
positive case is w/in five-30 miles
of Park (95:1 confidence level with
three years to reach sample size).
Repeat every three years if no
positives found during first
sampling period within SHEN and
positives continue to be identified
No
Monitor CWD surveillance inside the park. Do they
identify a positive CWD case?
Yes
Begin assessment actions (estimate CWD prevalence
with an error of plus or minus 2% at 95%
confidence).
Monitor and evaluate: Is the desired outcome being
accomplished? Example-does monitoring indicate
that CWD is becoming established?
No
ue with assessment actions.
Management Approach
Yes
Complete long-term planning for CWD management.
Implement CWD EIS action plan.
CWD Detection and Assessment Plan and EA
Shenandoah National Park
from the first index (initial) case. Established is defined as when the disease becomes endemic or
is sustained in a population over a period of time (NPS 2007).
HOW ALTERNATIVES MEET OBJECTIVES
As stated in the previous chapter, all action alternatives selected for analysis must meet all
objectives to a large degree. The action alternatives must also address the stated purpose of
taking action and resolve the need for action; therefore, the alternatives were individually
assessed in light of how well they would meet the objectives for this Plan/EA which are stated in
Purpose and Need. Alternatives that did not meet the objectives were not analyzed further (see
the Alternatives or Alternative Elements Considered but Rejected section).
Table 8 compares the alternatives by summarizing the elements being considered, while Table 9
compares how each of the alternatives described in this chapter would meet the plan objectives.
ALTERNATIVES OR ALTERNATIVE ELEMENTS CONSIDERED BUT DISMISSED
FROM DETAILED ANALYSIS
Six other preliminary alternatives and one alternative element were also considered during the
planning process. Five of these six preliminary alternatives are deer management activities that
are outside the scope of this EA, which is limited to the detection of CWD and determination of
its prevalence and distribution, not on disease management. The rationale for dismissing these
six alternatives and one alternative element is given below:
Decreasing Deer Congregation through Habitat Modification
One option suggested was to modify the landscape by removing elements that attract deer, which
could reduce deer densities and the potential for CWD transmission. Habitat modification could
be accomplished by cutting trees or burning vegetation. However, the planning team agreed that
these methods could also attract deer to the new vegetative growth. If deer did disperse from
habitat modification, this would disperse problems associated with deer as well. Therefore, this
alternative was dismissed from further consideration.
Deer Dispersal through Hazing to Reduce Disease Transmission
Hazing or aversive conditioning uses painful stimuli (e.g. sirens, paintballs, bean bag rounds) to
(re)instill some fear of humans into habituated wildlife. It is most effective on habituated wildlife
such as bears or coyotes. Hazing generally disperses problems associated with deer, but it is
mostly ineffective as deer tend to return to the areas they like once hazing has stopped.
Therefore, this alternative was dismissed from further consideration
43
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Table 8. Summary of alternatives.
44
Alternative A:
No Action (Continue Current Actions)
Tools available for Opportunistic surveillance
Targeted surveillance
detection
Live testing
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Alternative C:
Enhanced Detection and Assessment
with no lethal removal
Enhanced opportunistic surveillance
Enhanced targeted surveillance
Enhanced live testing
Lethal removal of healthy appearing
deer
Enhanced opportunistic surveillance
Enhanced targeted surveillance
Enhanced live testing
Number of deer
Few – only those showing clinical signs of A maximum sample of 300 deer
Few - only those showing clinical signs or
potentially
CWD or those that test positive with a
(assuming no contributions from the
those that test positive with a live test.
lethally removed
live test
state).
However, more deer showing clinical
during detection
signs may be found with enhanced
Note: Lethal removal may only be
surveillance.
used in a five-to-30-mile CWD
case scenario
Tools available for None for assessing disease intensity;
however opportunistic and targeted
assessment
surveillance would continue for limited
assessment of disease distribution
Enhanced opportunistic surveillance
Enhanced targeted surveillance
Enhanced live testing
Lethal removal of healthy appearing
deer
Enhanced opportunistic surveillance
Enhanced targeted surveillance
Enhanced live testing
Number of deer
Very few – only those showing clinical
potentially
signs of CWD
lethally removed
during
assessment
A maximum of 69 deer for the first
Few - only those showing clinical signs,
positive detection (a max of 97 deer
already dead, or those that test positive
if two positives detected at once)
with a live test. More deer showing
signs may be found with enhanced
Note: Lethal removal may only be
surveillance
used in a zero-to-five-mile CWD
case scenario
CWD Detection and Assessment Plan and EA
45
Coordination with
the State and
other groups
Education
measures
Shenandoah National Park
Alternative A:
No Action (Continue Current Actions)
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Alternative C:
Enhanced Detection and Assessment
with no lethal removal
Communication and coordination
would be enhanced based on the
type of actions taken
Same as Alternative B
Continue current communication and
coordination effort
Posting information on the internet and in
storefronts in the vicinity of the Park,
issuing press releases, and conducting
outreach efforts to various groups
Same as Alternative A, plus the NPS Same as Alternative B
would coordinate with state
education/outreach programs related
to CWD (e.g., participate in meetings
held by the state on CWD); more
NPS training
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Table 9. How the alternatives meet the objectives in taking action.
46
Objectives
in taking action
Alternative A:
No Action (Continue Current
Actions)
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Alternative C:
Enhanced Detection and
Assessment with no lethal
removal
Deer Populations at Shenandoah National Park
Estimate ongoing risk of
CWD infection in the
white-tailed deer
population of
Shenandoah National
Park based on known
disease risk factors.
Partially meets objective:
Recognizing that CWD risk factors
are currently present in the vicinity
of the Park, this alternative limits
the opportunities for CWD
detection; and assessment of
prevalence and distribution if CWD
is detected.
Fully meets objective:
This alternative provides the most
tools for detecting and assessing
(prevalence and distribution) CWD
based on the proximity of
detections.
For example, if CWD is detected five30 miles from the Park, lethal
removals for detection surveillance
would increase the potential for
detections and sampling
confidence. For cases detected
within five miles of the Park.
Assessment sampling would
provide confidence when
assessing the prevalence and
distribution of the disease.
Fully meets objective:
This alternative provides enough
tools for detecting and assessing
CWD based on the proximity of
detections (although it may take
longer to do this using Alt C as
compared to Alt B).
This option should provide nearly the
same level of confidence as
alternative B when trying to detect
the disease or when assessing
prevalence and distribution of the
disease (if it is detected in or near
the Park).
Appropriate to the level of
risk, develop adaptive
management protocols
for the detection of
CWD presence,
prevalence, and
distribution, as well as
an initial response to
the disease.
Does not meet objective:
Alternative A provides the fewest
tools for determining if CWD is
present and for assessing
prevalence/distribution.
This alternative does not provide a
framework for changing detection
or assessment actions based on
proximity to known detections or
state actions.
Fully meets objective:
This alternative provides a framework
for taking actions based on factors
including proximity of the disease
and actions of the state.
This alternative also provides more
opportunity to conduct CWD
sampling in conjunction with the
state.
Partially meets objective:
Alternative C provides a somewhat
limited framework for the detection
and assessment of the disease.
It provides more opportunity to
conduct opportunistic/targeted
surveillance and live-testing than
Alternative A, but with a longer time
frame than alternative B.
CWD Detection and Assessment Plan and EA
47
Objectives
in taking action
Shenandoah National Park
Alternative A:
No Action (Continue Current
Actions)
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Alternative C:
Enhanced Detection and
Assessment with no lethal
removal
Health and Safety
Minimize the potential for
health and safety
issues for Park staff
and visitors associated
with CWD surveillance
and lethal removal
activities.
Fully meets objective:
Because alternative A would involve
the fewest tools for CWD detection
and assessment, it has the least
potential for health and safety
issues. In addition, requirements
for personnel using firearms during
targeted surveillance, as well as
requirements for carcass handling
and disposal, would minimize
potential health and safety issues
for staff.
Closures, if needed, for targeted
surveillance, as well as educational
and interpretive measures about
the disease, would minimize the
potential for visitor health and
safety issues.
Fully meets objective:
Because this alternative involves
potential lethal removal actions, it
has the potential for the greatest
health and safety risks.
However, requirements for qualified
personnel (including authorized
agents and skilled sharp shooters)
involved in the use of firearms, as
well as proper carcass handling/
disposal would minimize the
potential health and safety issues
for staff. Detection or Assessment
removal actions would be
conducted during periods of very
low visitor use or when the Park is
closed, which would minimize
potential visitor safety issues. In
addition, targeted area closures
may be implemented to ensure
visitor safety. Additionally, job
hazard analyses would be
conducted to minimize safety
issues to staff. Educational and
interpretive measures about the
disease would also minimize the
potential for visitor health and
safety issues.
Fully meets objective:
Alternative C allows for enhanced
targeted surveillance under
detection. As such, that may result
in more lethal removals of CWD
symptomatic deer than in
alternative A. However, this
alternative still has a relatively low
risk of potential health and safety
issues. In addition, requirements
for personnel using firearms during
targeted surveillance, as well as
requirements for carcass handling
and disposal, would minimize
potential health and safety issues
for staff.
Closures, if needed, for targeted
surveillance, as well as educational
measures about the disease, would
minimize the potential for visitor
health and safety issues.
CWD Detection and Assessment Plan and EA
48
Objectives
in taking action
Shenandoah National Park
Alternative A:
No Action (Continue Current
Actions)
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Alternative C:
Enhanced Detection and
Assessment with no lethal
removal
Visitor Use and Experience
Enhance the awareness
and understanding of
CWD and NPS
resource management
issues, policies, and
mandates as they
pertain to prevention,
detection, and
assessment of the
disease for visitors and
other interested parties.
Partially meets objective:
Alternative A includes some
educational measures (e.g.,
posting information online or in
storefronts; press releases, civic
engagement presentations) that
would focus mostly on the disease
and the Park’s opportunistic and
targeted surveillance program.
Fully meets objective:
Educational measures would be
expanded under this alternative to
include not only information about
the disease, but also information
about the purpose for the additional
actions being taken, and what the
results might be. More tools would
be used to communicate with
visitors and the public in general,
including more ways to
communicate information to the
public, educating/training staff so
accurate information is
disseminated and targeted
surveillance is enhanced;
coordinating with state educational
and outreach efforts related to
CWD; and coordinating with other
stakeholders to reduce CWD risk
factors.
Fully meets objective:
This alternative would expand
education measures to enhance
public and staff awareness and
understanding of CWD as
described under alternative B (but
excluding the discussion of lethal
removal as an option).
CWD Detection and Assessment Plan and EA
49
Objectives
in taking action
During implementation of
CWD detection and
assessment activities,
minimize disruption to
visitor use and
experience.
Shenandoah National Park
Alternative A:
No Action (Continue Current
Actions)
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Fully meets objective:
Currently, Park staff is able to
conduct opportunistic and targeted
surveillance with no closures.
Although targeted surveillance could
require closures to protect visitor
safety, it would not be routine, and
disruption would be minimized by
educating the public and by
providing advanced notice.
Fully meets objective:
Because this alternative may involve
lethal removal, it has the most
potential to disrupt visitor use and
experience. However, detection
and assessment actions could be
taken during closure periods (e.g.
at night during hunting season
closures or during winter weather
closures), which would minimize
this potential. In addition,
educational and interpretive
measures, as well as the clearly
articulated need for management
and closures (including advance
notice closures), would minimize
disruption by increasing public
understanding.
Alternative C:
Enhanced Detection and
Assessment with no lethal
removal
Fully meets objective:
This alternative would have more
visitor use disruption potential than
Alternative A but less than
Alternative B. Enhanced targeted
surveillance would be the only
source of potential lethal removals
(possible use of firearms) and
potential disturbance to visitor use
and experience. Conducting
enhanced opportunistic
surveillance and live-testing
actions, as well as additional
education and interpretive
measures about CWD (including
advance notice closures) would
also minimize the potential for
disruptions to visitor use and
experience.
CWD Detection and Assessment Plan and EA
50
Objectives
in taking action
Shenandoah National Park
Alternative A:
No Action (Continue Current
Actions)
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Alternative C:
Enhanced Detection and
Assessment with no lethal
removal
Park Management and Operations
Minimize impacts of CWD
detection and
assessment activities
on current Park
operations, including
budget and workload.
Fully meets objective:
This alternative has the least
potential for impacts on Park
management and operations.
Opportunistic surveillance, involves
sampling deer found dead during
the Park staff’s routine duties.
Targeted surveillance is conducted
by trained field staff with more
focus on the spring and summer
seasons (support and staffing are
somewhat variable based on
funding and staff availability).
However, if CWD is detected and
becomes established, managing
the disease (long-term) could have
the most impact on Park
management and operations.
Partially meets objective:
Although Alternative B would have
moderate impacts on Park
operations, including budget and
workload, steps would be taken to
minimize these impacts, and the
NPS would still be able to
adequately manage and operate
the Park to meet its mission. Steps
that can be taken include analyzing
the extent of actions needed based
on disease proximity and actions of
the state; and using contractors for
lethal removal to minimize impacts
on workloads (although this would
increase costs).
Partially meets objective:
This alternative would have moderate
impacts on Park management and
operations. Enhanced
Opportunistic surveillance would
involve somewhat more staff time
than in Alternative A. Enhanced
targeted surveillance would be
conducted by dedicated field staff
with more focus on year-round
surveillance. This would have a
moderate effect on Park operations
and budget. Enhanced live-testing
may be necessary to meet sample
size requirements. If so, this could
have moderate-high impacts on
Park management, budget, and
operations.
Cooperate and coordinate
with state resource
management agencies,
as well as other
interested parties, with
respect to CWD
detection and
assessment activities.
Partially meets objective:
Although cooperation and
coordination occurs now regarding
test results and sharing of
information, there is minimal
opportunity under alternative A to
work cooperatively with the state
on CWD detection and assessment
activities.
This option would give us the least
information for future decisionmaking.
Fully meets objective:
Alternative B would provide the most
tools to enhance cooperation and
coordination with the state
regarding CWD detection and
assessment activities. This option
would give us the most information
for future decision-making.
Partially meets objective:
This alternative would increase the
potential for cooperation and
coordination with the state in
comparison to Alternative A.
However, there would be fewer
tools to collect information due to
the lack of a lethal removal option.
This option would give us adequate
information for future decisionmaking.
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Table 10. Summary of environmental consequences of the alternatives.
51
Impact
Topic
Alternative A:
No Action (Continue Current Actions)
White-tailed Deer Actions directly associated with
opportunistic and targeted surveillance,
and possibly live testing, would have
short-term, negligible adverse impacts on
white-tailed deer from temporary
disturbances during implementation.
There would be long-term, moderate,
adverse impacts because Alternative A
would have minimal effects on CWD risk
factors and the potential for amplification,
spread, and establishment of the disease.
Exposure to possible population level
effects would remain high. Actions directly
associated with assessment actions
would have temporary negligible
contributions to cumulative impacts on
white-tailed deer populations, which
would be long-term, moderate, and
adverse. However, this alternative would
have moderate contributions to
cumulative impacts from the potential for
CWD amplification, spread, and
establishment.
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Alternative C:
Enhanced Detection and
Assessment with no lethal removal
Detection and assessment actions under Actions directly associated with
enhanced detection and assessment
this alternative would have short-term,
would have short-term, negligible to
minor, adverse impacts on white-tailed
minor, adverse impacts on white-tailed
deer movement, density, and health.
deer movement, density, and health.
There would be long-term, moderate,
There would be long-term, minor to
adverse impacts on deer because
Alternative B would have minor-moderate moderate, adverse impacts on deer
because Alternative C would have limited
effects on CWD risk factors and the
effects on CWD risk factors and the
potential for amplification, spread, and
establishment of the disease. Alternative potential for amplification, spread, and
establishment of the disease. Exposure
B would have both adverse and
to possible population level effects would
beneficial contributions to cumulative
impacts on white-tailed deer populations, remain high. Actions directly associated
with enhanced detection and assessment
which would be long-term, minor to
activities would have temporary
moderate, and adverse. However, this
negligible contributions to cumulative
alternative would not contribute to
impacts on white-tailed deer populations,
cumulative impacts for the potential for
which would be long-term, moderate, and
CWD amplification, spread, and
adverse. However, this alternative would
establishment in and near the Park.
have some contributions to cumulative
impacts from the potential for CWD
amplification, spread, and establishment.
CWD Detection and Assessment Plan and EA
Impact
Topic
52
Vegetation
Shenandoah National Park
Alternative A:
No Action (Continue Current Actions)
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Actions associated with opportunistic and
targeted surveillance and live testing
would have short-term, negligible to
minor, adverse impacts on vegetation
from temporary disturbances during
implementation. Because these
surveillance efforts would not measurably
affect deer densities across the Park,
CWD surveillance actions that would
occur under Alternative A would not result
in any indirect effects (i.e., herbivory) to
existing vegetative conditions. Cumulative
impacts on vegetation would be longterm, moderate, and adverse; however,
surveillance actions under Alternative A
would contribute minimally to these
effects.
Detection and assessment actions would
have short-term, negligible to minor,
adverse impacts on vegetation from
temporary disturbances during
implementation. After implementation,
reductions in deer density from lethal
removal of deer for CWD detection
and/or assessment would have long-term
beneficial effects (e.g. reduced
herbivory). Cumulative impacts on
vegetation would be long-term, minor to
moderate, and adverse. Detection and
assessment actions under Alternative B,
including benefits from reduced deer
densities in certain areas of the Park,
would contribute minimally to these
effects.
Alternative C:
Enhanced Detection and
Assessment with no lethal removal
Enhanced detection and assessment
actions would have short-term, negligible
to minor, adverse impacts on vegetation
from temporary disturbances during
implementation. Cumulative impacts on
vegetation would be long-term,
moderate, and adverse. Detection and
assessment actions under Alternative C
would contribute minimally to cumulative
impacts.
CWD Detection and Assessment Plan and EA
Impact
Topic
53
Other Wildlife
Alternative A:
No Action (Continue Current Actions)
Actions directly associated with
opportunistic and targeted surveillance
and potentially live testing would have
short-term, negligible, adverse impacts on
wildlife and wildlife habitat, mainly from
temporary disturbances and trampling
during implementation. Potential shortterm, negligible to minor, beneficial
impacts would occur for carrion eaters
from the possible availability of CWD
negative carcasses on the landscape.
Sustained deer browsing in areas of the
Park with high population densities (e.g.
Big Meadows) would continue to
contribute substantially to long-term
adverse effects on wildlife and wildlife
habitat in these areas as a result of
impacts on diversity and abundance of
understory shrubs and grasses. In
addition, prescribed burns (a possible
management action) would have shortterm adverse impacts (including field
activities), there would be long-term
beneficial effects on wildlife habitat from
regrowth of mostly native plants/shrubs
and by the creation of forest gaps.
Cumulative impacts on wildlife and wildlife
habitat would be long-term, negligible to
minor, and adverse. Surveillance actions
under Alternative A would contribute
minimally to these effects.
Shenandoah National Park
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Alternative C:
Enhanced Detection and
Assessment with no lethal removal
Actions directly associated with
Detection and initial response actions
enhanced opportunistic and targeted
would have short-term, negligible to
surveillance and enhanced live testing
minor, adverse impacts on wildlife and
would have short-term, negligible to
wildlife habitat from temporary
minor, adverse impacts on wildlife and
disturbances during implementation.
After implementation, reductions in deer wildlife habitat, mainly from temporary
disturbances and trampling during
density from lethal removal of deer for
CWD detection and/or assessment would implementation. Some minimal benefits
would occur for carrion eaters from the
have long-term beneficial effects.
possible availability of CWD negative
Cumulative impacts on wildlife and
wildlife habitat would be long term, minor, carcasses on the landscape. Sustained
deer browsing in areas of the Park with
and adverse, and detection and
assessment actions under Alternative B high population densities (e.g., Skyline
Drive, Big Meadows) would continue to
would contribute minimally to these
contribute substantially to long-term
effects.
adverse effects on wildlife and wildlife
habitat in these areas as a result of
impacts on diversity and abundance of
understory shrubs and plants. In addition,
although fire management would have
short-term adverse impacts from
prescribed burns (including associated
field activities), there would be long-term
beneficial effects on wildlife habitat from
regrowth of mostly native plants and the
creation of canopy gaps in the forest.
Cumulative impacts on wildlife and
wildlife habitat would be long-term,
negligible to minor, and adverse.
Surveillance actions under Alternative C
would contribute minimally to these
effects.
CWD Detection and Assessment Plan and EA
Impact
Topic
54
Alternative A:
No Action (Continue Current Actions)
State-listed Plant Actions associated with opportunistic and
targeted surveillance and live testing
Species
would have short-term, negligible to
minor, adverse impacts on state-listed
plant species from potential trampling and
spread of nonnative plant species.
Because these surveillance efforts would
not measurably affect deer densities
across the Park, CWD surveillance
actions that would occur under Alternative
A would not result in any indirect effects
(i.e., reduced herbivory) to existing statelisted plant species. Cumulative impacts
on state-listed species would be longterm, minor, and adverse; however,
surveillance actions under Alternative A
would contribute minimally to these
effects.
Shenandoah National Park
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Detection and assessment actions would
have short-term, negligible to minor,
adverse impacts on state-listed plant
species from potential trampling and
potential spread of nonnative plant
seeds. After implementation, reductions
in deer density from lethal removal of
deer for CWD detection and/or
assessment would have long-term
beneficial effects (e.g. reduced herbivory
in some areas). Cumulative impacts on
state-listed plant species would be longterm, minor, and adverse. Detection and
assessment actions under Alternative B,
including benefits from reduced deer
densities in certain Park areas, would
contribute minimally to these effects.
Alternative C:
Enhanced Detection and
Assessment with no lethal removal
Enhanced detection and assessment
actions which do not include lethal
removals would have short-term,
negligible to minor, adverse impacts on
state-listed plant species from trampling
and potential spread of nonnative plant
seed during implementation. Cumulative
impacts on state-listed plant species
would be long-term, minor, and adverse.
Detection and assessment actions under
Alternative C would contribute minimally
to cumulative impacts.
CWD Detection and Assessment Plan and EA
Impact
Topic
55
Alternative A:
No Action (Continue Current Actions)
Socioeconomics Actions associated with opportunistic and
targeted surveillance and possibly live
testing would have long-term, negligible
to minor, adverse impacts on
socioeconomics. CWD surveillance
actions that would occur under Alternative
A would not result in any changes to the
existing socioeconomic conditions, and
adverse impacts resulting from deerrelated crop damage would continue.
Because Alternative A would have
minimal effects on CWD risk factors
allowing the potential for amplification,
spread, and establishment, as well as
exposure to possible population level
effects to remain high, there could be
negligible to minor, adverse impacts to
hunting and tourism due to changes in
deer numbers and/or the presence of the
disease. However, the exact nature and
level of impact would depend on what
actions the state has taken in the
communities surrounding the Park in
response to the presence of CWD.
Overall cumulative impacts on the local
socioeconomic resources would be longterm and beneficial.
Shenandoah National Park
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Alternative C:
Enhanced Detection and
Assessment with no lethal removal
The same past, present, and future
CWD surveillance actions that would
adverse and beneficial impacts from
occur under Alternative C would not
cumulative actions described under
result in changes to the existing
Alternative A would also occur under
socioeconomic conditions, and adverse
Alternative B. Actions taken under
impacts resulting from deer-related crop
Alternative B contribute both adverse and damage would continue. Because
beneficial impacts to the socioeconomic Alternative A would have minimal effects
resource. Adverse impacts resulting from on CWD risk factors allowing the
potential for amplification, spread, and
actions taken under Alternative B and
establishment, as well as exposure to
adverse impacts from other past,
present, and future actions would not be possible population level effects to
enough to outweigh the benefits provided remain high, there could be negligible to
by development in the local area and the minor, adverse impacts to hunting and
tourism due to changes in deer numbers
economic contributions of the Park.
Therefore, the overall cumulative impacts and/or the presence of the disease.
However, the exact nature and level of
on the local socioeconomic resources
impact would depend on what actions the
would be long-term and beneficial.
state has taken in the communities
surrounding the Park in response to the
presence of CWD. Actions taken under
Alternative C would result in short-term,
negligible to minor, adverse impacts to
the socioeconomic resource with the
level of adverse impacts dependent upon
the perceptions of visitors and hunters,
the number of deer potentially affected
by CWD, and the actions the state has
taken in the communities surrounding the
Park in response to CWD. Overall
cumulative impacts on the local
socioeconomic resources would be longterm and beneficial.
CWD Detection and Assessment Plan and EA
Impact
Topic
56
Alternative A:
No Action (Continue Current Actions)
Shenandoah National Park
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Alternative C:
Enhanced Detection and
Assessment with no lethal removal
Visitor Use and
Experience
Actions associated with opportunistic and
targeted surveillance and possibly live
testing would have short-term, negligible
to minor, adverse impacts on visitor use
and experience. If CWD were to occur in
or near the Park, those impacts would
increase to minor due to the likely
increase in seeing sick or dead deer. The
overall cumulative impacts of all past,
present, and future actions at the Park
would be long-term and beneficial.
Similar to Alternative A, actions
associated with enhanced opportunistic
and targeted surveillance and enhanced
live testing would have short-term,
negligible to minor, adverse impacts on
visitor use and experience. Lethal
removal of healthy appearing deer for
detection and/or assessment would have
short-term, minor, adverse impacts.
Long-term beneficial effects would occur
from reduced deer densities in some
areas of the Park which would decrease
the potential for CWD to become
established. In addition, beneficial effects
would occur from knowing that the NPS
is taking actions to protect the deer in the
Park. Cumulative effects on visitor use
and experience would be long-term and
beneficial.
Similar to Alternative B, actions
associated with enhanced opportunistic
and targeted surveillance would have
short-term, negligible to minor, adverse
impacts on visitor use and experience.
Live testing would have no impacts on
visitor use and experience. Although not
as extensive as Alternative B, long-term
beneficial effects to visitor use and
experience could occur from decreased
potential for seeing deer infected with
CWD and from knowing that the NPS is
taking actions to protect the deer in the
Park. Cumulative effects on visitor use
and experience would be long-term and
beneficial.
Human Health
and Safety
Opportunistic and targeted surveillance
activities and potentially live testing
employed under Alternative A would
result in long-term, negligible, adverse
impacts on human health and safety.
Cumulative impacts on health and safety
would be long-term, minor to potentially
moderate and adverse; however,
Alternative A would contribute very little to
any overall adverse impacts.
Opportunistic and targeted surveillance
activities employed under Alternative B
would result in long-term, negligible,
adverse impacts on health and safety, as
would live testing; lethal removal of
healthy appearing deer for both detection
and assessment would have negligible to
minor, adverse effects. Alternative B
would have negligible contributions to
cumulative impacts on health and safety,
which would be long-term, minor to
potentially moderate, and adverse.
Enhanced opportunistic and targeted
surveillance activities employed under
Alternative C would result in long-term,
negligible, adverse impacts on human
health and safety, as would enhanced
live testing. Alternative C would have
negligible contributions to cumulative
impacts on health and safety, which
would be long-term, minor to potentially
moderate, and adverse.
CWD Detection and Assessment Plan and EA
Impact
Topic
57
Alternative A:
No Action (Continue Current Actions)
Park Management Actions associated with opportunistic and
targeted surveillance would have shortand Operations
term, negligible to minor, adverse impacts
on Park management and operations.
Alternative A would have negligible
contributions to cumulative impacts on
Park management and operations, which
would be long-term, moderate, and
adverse.
Shenandoah National Park
Alternative B:
Enhanced Detection and
Assessment with lethal removal
Detection and assessment actions would
have short- and long-term, negligible to
moderate, adverse impacts on Park
management and operations, with more
intense impacts related to the lethal
removal actions included in this
alternative and the need for additional
public education and outreach.
Cumulative effects on Park management
and operations would be long-term,
moderate, and adverse.
Alternative C:
Enhanced Detection and
Assessment with no lethal removal
Detection and assessment actions would
have short- and long-term, negligible to
minor, adverse impacts on Park
management and operations. Cumulative
effects on Park management and
operations would be long-term, minor to
moderate, and adverse.
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Predator Management to Reduce Deer Densities and Therefore Disease Transmission
The intent of increasing existing predators (e.g., bear, coyote) or reintroducing lost predators
(e.g., wolves, cougar) would be to reduce the force of infection (rate at which susceptible deer
are infected) of CWD in deer populations (Miller et al., 2008). The current black bear
populations in the Park are already at a relatively high density (but not true of coyotes parkwide).
Large predators such as wolves and cougar require vast landscapes to thrive. The Park is not
large enough to maintain predator reintroduction without full support and cooperation from the
state and neighboring landowners to succeed. Current surrounding land use (agricultural and
high density human development) is not favorable for predator reintroduction. Therefore this
alternative was dismissed from further consideration.
Hunting to Reduce Deer Densities and Therefore Disease Transmission
NPS regulations 36 CFR 2.2 and NPS Management Policies 2006(a) state that hunting is
prohibited in national parks unless specifically authorized as a discretionary activity under
federal statutory law or treaty rights and may take place only after the NPS has determined that it
is consistent with resource management principles (NPS 2006b). The enabling legislation of
Shenandoah National Park specifically does not allow hunting in the Park. Therefore, this
alternative was dismissed from further consideration.
Eliminate the Deer Population
Elimination of a native species would be inconsistent with NPS Management Policies 2006 (a)
which prescribes that “The National Park Service will maintain as parts of the natural ecosystems
of parks all plants and animals native to Park ecosystems” (NPS 2006b). In addition, elimination
of white-tailed deer in the Park would likely have significant impacts and is outside the scope of
this environmental assessment. Finally, elimination of deer is not feasible because deer would
quickly return to the Park from surrounding areas. Therefore, this alternative was dismissed from
further consideration.
Do Nothing for Either Detection or Assessment
One option was to do nothing to detect CWD or to assess its prevalence and distribution in the
Park. Detection actions (opportunistic and targeted surveillance) are required by NPS policy at
Shenandoah National Park due to the proximity (less than 60 miles) from a known CWD case. In
addition, this would not meet the purpose, need, and many of the objectives of this Plan/EA.
Therefore, this alternative was dismissed from further consideration.
Use of Volunteers as Sharpshooters
This implementation idea was rejected because of the nature of the unconfined recreational
activities that occur in the Park, landform restrictions which would not enable complete closure
of access, and related safety concerns. While some other areas administered by the NPS have
proposed or begun the use of volunteers as sharpshooters in lethal reduction activities, not all
locations within NPS units are suitable for use of volunteers to engage in such activities.
Typically, those NPS units that allow for participation of volunteers as sharpshooters are located
in areas with scattered and sparse human populations. Additionally, these areas have large
58
CWD Detection and Assessment Plan and EA
Shenandoah National Park
expanses of wilderness and backcountry that are less likely to have concentrations of visitors that
may inadvertently enter closed areas. As a result of challenges associated with Park topography,
human population density along the Park boundary, the nature of recreational use in the Park,
and the number of deer to be removed, it is essential that the Park use staff or contractors (sharp
shooters) that are knowledgeable/trained about these issues to be assured for maximum success
in lethal removal and to ensure public safety. Therefore, use of volunteer sharpshooters for lethal
removals is considered inappropriate at Shenandoah National Park and was dismissed from
further consideration.
ENVIRONMENTALLY PREFERRED ALTERNATIVE
In accordance with the DO-12 Handbook, the NPS identifies the environmentally preferable
alternative in its NEPA documents for public review and comment [Sect. 4.5 E(9)]. The
environmentally preferable alternative is the alternative that causes the least damage to the
biological and physical environment and best protects, preserves, and enhances historical,
cultural, and natural resources. The environmentally preferable alternative is identified upon
consideration and weighing by the Responsible Official of long-term environmental impacts
against short-term impacts in evaluating what is the best protection of these resources. In some
situations, such as when different alternatives impact different resources to different degrees,
there may be more than one environmentally preferable alternative (43 CFR 46.30).
Alternative B best protects and preserves park natural resources with an adaptive management
approach which offers the widest array of options for the initial detection and/or assessment of
CWD within the Park. Alternative B allows the Park to be an active partner along with other
wildlife agencies in the surrounding areas and allows the Park to contribute to the regional effort
to understand and manage CWD within the area. This adaptive approach will allow for more
informed long-term management of CWD and white-tailed deer within Shenandoah National
Park. Based on the analysis of environmental consequences of each alternative in Chapter 4,
Alternative B is the environmentally preferable alternative.
NPS PREFERRED ALTERNATIVE
Alternative B is the NPS preferred alternative because it provides park managers an adaptive
management approach with the widest array of options (see above) for the initial detection and/or
assessment of CWD within the Park. Targeted management actions can be taken depending on
the current status of CWD occurrence in the vicinity of the Park and the relative risk of infection.
Alternative B provides for a lethal sampling option that may be necessary to achieve sample size
requirements. A key Alternative B provision allows the Park to be an active partner with the
VDGIF in the surrounding areas to utilize off-park samples in calculating the total samples
required for a statistically-sound estimate to address this threat.
59
CWD Detection and Assessment Plan and EA
Shenandoah National Park
AFFECTED ENVIRONMENT
This chapter describes the Park resources that could be impacted by the proposed actions.
Resources examined in detail include white-tailed deer, vegetation, other wildlife, threatened and
endangered species, socioeconomics, visitor use and experience, health and safety, and Park
management and operations. Resources dismissed from further consideration were discussed in
Chapter 1: Purpose and Need. The first paragraph of each environmental resource describes why
that element may be affected by the alternatives being considered and is followed by a
description of the resource. Impacts of the alternatives on each of these resources are discussed
in Chapter 4: Environmental Consequences.
WHITE-TAILED DEER
Options for CWD detection and assessment that would involve killing presumably healthy
animals for testing would affect the deer populations at the Park. Killing unhealthy deer would
also affect the deer populations and effects would likely be positive on population health.
Capturing and immobilizing deer for taking biopsies of their tonsils (i.e., live testing) would also
have an effect on the deer, therefore, impacts to deer are analyzed.
General Ecology
White-tailed deer are medium-sized ungulates (hoofed animals) native to North America and
regarded as one of the most adaptable mammals in the world (Hesselton and Hesselton 1982).
Among the reasons for this adaptability are the hardiness, reproductive capability, wide range of
plant species accepted as food, and the tolerance deer express for close contact with humans.
Virginia Department of Game and Inland Fisheries (1999) estimated the state population of
white-tailed deer to be 400,000–800,000 individuals.
The diet of white-tailed deer consists of twigs from shrubs and trees, as well as herbaceous (nonwoody) plants, which are eaten frequently in spring and summer when they are abundant.
Acorns, nuts, and fruits are consumed in late summer and fall. Some of the plants that deer
browse heavily in the winter season are selected by necessity rather than choice (Martin et al.
1951).
Most abundant in the eastern woodlands, white-tailed deer are typically forest dwellers, but often
frequent wetlands or woodland openings while feeding. Deer also forage along forest margins, in
orchards, and on farmlands. When deer populations become excessive, damage to crops and
forests may result, and, in addition, their winter food may be reduced to the point where
starvation results (Martin et al. 1951).
Population Density Estimates
According to the VDGIF estimates (no empirical data), the Park contains deer densities of
approximately 25–30 deer/mi2 (Lafon, VDGIF, pers. comm., 2005 in Mahan, C. G. 2006). Based
on these density estimates, the total number of deer in the Park (320 mi2) may be 8,000 to 9,600
individuals. However, NPS information indicates densities vary within the Park by location and
season. In the backcountry, we believe deer densities to be at five–25 deer per square mile
60
CWD Detection and Assessment Plan and EA
Shenandoah National Park
(variations are based on habitat conditions such as aspect, elevation, and soils), which is
consistent with densities in forested areas west of the Blue Ridge in Virginia. Frontcountry (e.g.,
areas along Skyline Drive and at major campgrounds and visitor centers) deer densities
consistently exceed backcountry (wilderness) densities (Scanlon and Vaughan 1987). For
example, deer abundance estimates by Park biologists using roadside survey counts in 2003 were
extrapolated to be 176 deer/mi2 in the Big Meadows area, with spring estimates of 210 deer/mi2,
and fall estimates of 159 deer/mi2 (Gubler 2004). Big Meadows consistently supports the
densest deer population in the Park’s frontcountry areas. In the approximately 2,000 acres of
developed areas, including the Skyline Drive corridor, deer densities are much higher than
adjacent dense forests. This abundance is due to the presence of open/edge habitat that provides
ideal browsing and grazing opportunities for deer. Openings in the forest provide an excellent
environment for growth of a diversity of browse, forbs, and grass. The availability of food
resources, combined with the prohibition on hunting in the Park, results in a high population of
deer, particularly in developed areas where forage is abundant (Haskell 1986). Higher deer
densities increase disease amplification potential. In addition, frontcountry deer densities seem to
exhibit a clumped distribution pattern with deer most frequently using areas receiving intense
human use (Scanlon and Vaughan 1987). This distribution pattern increases the likelihood of
deer-human interaction within the Park.
Deer Movement
Sixty deer were captured along Skyline Drive and in the backcountry between October 1981 and
January 1983 and were collared to document deer movements and range areas (Scanlon and
Vaughan 1985). Seasonal movements and mean total range areas were smaller for female deer
along Skyline Drive than for females in backcountry areas of the Park (1,097 acres versus 2,172
acres, respectively). Mean total range areas were smaller for males captured in backcountry areas
than males captured on Skyline Drive (3,919 acres and 4,562 acres, respectively). There was no
difference in their mean seasonal ranges.
Many females concentrated their movements near Skyline Drive throughout most of the year,
however, some female deer did move long distances (up to 26 miles) along the Drive. Males
were more confined to a 1.25- to 2-mile section of the drive primarily when females were in
estrus. Males moved repeatedly between the Drive and the backcountry throughout much of the
year, however, such repeated movements were not observed for females. Deer move in and out
of the Park on a regular basis and movement of up to 30 miles has been observed (Scanlon and
Vaughan 1985).
Deer Herd Health
There are a number of health problems that can affect eastern deer populations. These include
parasites, malnutrition, bluetongue virus, pleuritis, epizootic hemorrhagic disease, and CWD.
Chronic wasting disease was documented in 2005 within 60 miles of the Park. Road-killed deer
within the Park have been tested for CWD since April 2006. A total of 16 samples were collected
in 2006, 19 in 2007, 12 in 2008, five in 2009, and six in 2010. All tests have returned negative
results for the disease.
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Nineteen deer killed by cars along Skyline Drive were examined in 1981–82 to get an indicator
of deer herd health. Kidney fat indices and percent fat content of bone marrow revealed that deer
had abundant to sparse fat reserves and thus differed in physical condition (Scanlon and Vaughn
1987). Abomasal parasite counts were taken from two deer and resulted in 40 and 140 parasites
discovered. These are very low levels indicating no problems with abomasal parasites in the two
deer. Seasonal variability and small sample size were attributed to the largely inconclusive
results for population condition. It was noted that deer associated with Skyline Drive may be
obtaining substantial benefits from foraging on grass along the roadsides. These grasses supply
high protein content in spring and fall seasons and may lessen the adverse effects of failing
native forages in the fall as well as for a late arrival of spring (Scanlon and Vaughn 1987).
In addition, a deer health assessment was conducted by the VDGIF in 1993 near Piney Ridge.
Most of the study was conducted in backcountry areas. This information was gathered after the
discovery of several deer that were found dead after a severe winter storm event. Six female
white-tailed deer were collected and necropsied (animal autopsy) in early September. Average
age was four years. No evidence of disease was found and all deer ranked fair or good based on
carcass fat and kidney fat. The mean abomasal parasite count was 620 (range 320–980)
indicating a deer population at biological carrying capacity (VDGIF Deer Health Assessment at
Piney Ridge, 1993).
VEGETATION
Options for CWD detection and assessment that would involve removing a number of
presumably healthy deer could affect vegetation by changing the number of deer that browse on
vegetation in a particular area.
Most of the Park is covered by second-growth forest whose composition has been influenced by
the topography, climate, geology, and natural disturbance regimes of the northern Blue Ridge
Mountains, as well as by historic land use and other anthropogenic disturbances. Once
considered an outstanding example of the Northern Blue Ridge Forest (Braun 1950 in Mahan, C.
G. 2006), major disturbances have impacted the forest in the last 60 years. Impacts from insects
and disease such as gypsy moth, dogwood anthracnose, butternut canker, and hemlock woolly
adelgid have resulted in periodic high tree mortality in the Park. For example, at one time
hemlock forests existed in fairly large contiguous blocks throughout the Park and some were
considered old growth (>200 years old) forest. However, approximately 90% of the eastern
hemlocks at lower to mid elevations (1200-3200 ft) have succumbed to the exotic hemlock
woolly adelgid (NPS, R. Gubler, Biologist, pers. comm., 2008). Other natural and anthropogenic
causes that have negatively impacted the vegetation include fires, tropical storms, ice, and
impacts from ozone and acid precipitation deposition.
Despite a history of disturbance, the Park represents one of the nation’s most diverse botanical
reserves and contains globally rare plant communities. NPSpecies (NPS Natural Resources
Biological Inventory System) documents the occurrence of 1413 vascular and nonvascular plant
species in the Park (Current Park list, Certified in NPSpecies in 2008.). Eighty species that are
considered state or globally rare have been documented by the Virginia Natural Heritage
Program (Townsend, John F. 2009. Natural Heritage Resources of Virginia). The small whorled
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pogonia is a Federally-listed species that was historically found in the Park, however, recent
surveys for the species have not been able to document its presence in the Park.
Approximately 93% of the Park is covered by upland forests and is maintained in a natural state.
Wetland communities make up 2%, and about 3% of the area is occupied by other communities
such as barrens. The remaining 2% of the Park is currently developed. The vegetation around
developed areas, along roadsides, at certain cultural areas and historic structures, and at
overlooks is managed for a variety of purposes, including cultural landscape values, safety and
visitor enjoyment.
Forests that contain oak as a dominant component occupy approximately 69% of the Park or
136,402 acres. These oak forests are found at all elevations and are dominated by northern red
oak (Quercus rubra), chestnut oak (Quercus prinus), white oak (Quercus alba), black oak
(Quercus velutina), and scarlet oak (Quercus coccinia) with hickory (Carya spp.) and pine (Pinus
spp.) mixed in. Approximately 17% of the Park or 33,606 acres is a mesic/rich cove forest.
Represented plant communities are dominated by white ash (Fraxinus americana), tulip popular
(Liriodendron tulipifera), sugar maple (Acer saccharum), basswood (Tilia americana), bitternut
hickory (Carya cordiformis), birches (Betula spp.), and, rarely, American beech (Fagus
grandifolia).
The occurrence of black locust in 39% of forest monitoring plots (from 2007 SHEN forest longterm monitoring data) reflects the past land use history at the Park, especially the prevalence of
small homesites and fields that are now abandoned. Several pine species can also be found in the
Park either singly or in small groups.
Wetland vegetation composes about 2% of the land cover or 3,584 acres in the Park. Big
Meadows is a 134-acre ridge-top meadow and is the only large non-forested (managed as such)
area in the Park. It contains many rare plant populations and the 25-acre central wetland is
classified as a globally rare Northern Blueridge Mafic Fen plant community.
Due to past land use, including European settlement and associated homesites, nonnative plants
have been present in the Park since its establishment as a national park in 1935 (Mazzeo 1966 in
Mahan, C. G. 2006). Approximately 23% of known plant species in the Park are nonnative or
naturalized (Comiskey et al. 2005 in Mahan, C. G. 2006). Only a subset of these species,
however, are aggressively spreading in the Park. Tree-of-heaven (Ailanthus altissima), mile-aminute weed (Polygonum perfoliatum), garlic mustard (Alliaria petiolata), Japanese stiltgrass
(Microstegium vimenium), Oriental lady’s thumb (Polygonum caespitosum), Oriental bittersweet
(Celastrus orbiculatus), and Japanese honeysuckle (Lonicera japonica) threaten natural forested
habitats throughout the Park (NPS 2005b). Since 1997, a total of 1,245 acres have been initially
treated (using a variety of methods) and 1,401 acres have been re-treated to control nonnative
plants (NPS 2005b). The proliferation and spread of invasive nonnative plants may be the
biggest threat to maintaining native forests and plant communities at the Park.
State-listed Plant Species
The Park has two state- listed plant species and numerous rare plant species. These species could
be affected if CWD testing changed the number of deer that browse on vegetation in a particular
area.
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Ninety-three plant species considered rare or species of special concern have been documented
by the Virginia Natural Heritage Program (2006 in Mahan, C. 2006), including two state-listed
species. Big Meadows contains many of the rare plant populations in the Park and has the
highest density of deer. The Natural Heritage Report (1993) which reported a dramatic decline in
the diversity and vigor of native herbaceous species at Big Meadows caused in part by heavy
deer grazing/browsing, but also by vegetation management, trampling by humans, and invasion
of aggressive exotic plants.
OTHER WILDLIFE
Studies have linked levels of deer densities to effects on other wildlife species. As deer
populations increase, increased browsing reduces the amount of vegetation that provides cover,
forage, and nesting habitat, particularly for birds (DeCalesta 1994; McShea 2000; McShea and
Rappole 2000). CWD detection and assessment activities could reduce deer densities in a
particular area (as a result of removing deer for CWD testing) which could affect other wildlife
using that area. In addition, some deer carcasses could be left on the ground in the Park after
lethal CWD testing activities which would increase the availability of carrion for other wildlife
(e.g., coyotes, bears).
The mix of wetland, mountain, and lowland vegetation provide habitat for a variety of mammals
and bird species, which could be affected by actions taken for CWD detection and assessment.
Because impacts to reptile, amphibian, fish, and aquatic invertebrates would not occur, as
described in the Issues Considered but Dismissed from Further Analysis section, reptile,
amphibian, fish, and aquatic invertebrates are not discussed below.
Mammals
There is some disagreement as to the exact number of mammals known from the Park. Manville
(1956 in Mahan, C. G. 2006) confirmed the presence of 49 mammals from the Park but
estimated that 10 others occur in the Park because they were documented in neighboring
counties. Burns et al. (2003 in Mahan, C. G. 2006) listed 33 species of mammals from the Park.
NPSpecies (2005a) documents 53 species of mammals from the Park, and the Virginia Gap
Analysis Program (2005 in Mahan, C. G. 2006) predicts the Park to contain 50% (57 of 114
species) of the mammalian fauna known to occur in Virginia (Linzey 1998 in Mahan, C. G.
2006). There are no federally listed endangered species of mammals in the Park.
The Park supports a large number (300–600) of black bears and may be a source population for
the Blue Ridge Mountains (Brown 1985; Carney et al. 1987 in Mahan, C. G. 2006). Other furbearing mammals include coyote, beaver, bobcat, muskrat, red fox, gray fox, skunks,
woodchuck, eastern cottontail, gray squirrel, red squirrel, opossum, mink, northern river otter,
and weasels.
A species list in Webster et al. (1985 in Mahan, C. G. 2006) suggests that 18 species of native
mice, moles, voles, and shrews occur within the Park. Small mammals include the star-nosed
mole, southeastern shrew, pygmy shrew, southern red-backed vole, white-footed mouse,
southern flying squirrel, and the rare Appalachian cottontail.
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Birds
Simpson (1992 in Mahan, C. G. 2006) documents a total of 205 species of birds known to occur
in the Park. However, only 175 species of birds were predicted to occur in and around the Park
by the Virginia Gap Analysis (VA Gap 2005 in Mahan, C. G. 2006), and only 192 species are
listed in NPSpecies for the Park (2005a). The Park contains 53% of the 390 species of birds
known to occur regularly in Virginia (Johnston 1997 in Mahan, C. G. 2006). There are no
federally listed bird species in the Park, however, there are three state listed species.
At least 41 species of neotropical migratory birds, including many ground-nesting species, visit
the Park annually (DeSante et al. 2004 in Mahan, C. G. 2006). DeSante et al. (2004 in Mahan, C.
G. 2006) indicate that the Park is globally significant in providing habitat for neotropical
migrants.
Few waterfowl species occur in the Park due to the small number of ponds and other open water
bodies within Park boundaries. However, several species use riparian (interface between land
and stream) corridors along mountain streams, especially at low elevations.
The spine of the Blue Ridge Mountains creates a pathway along which several species of raptors
fly during fall migration periods (B. Watts, College of William & Mary, Center for Conservation
Biology, pers. comm., 2005 in Mahan, C. G. 2006). At least 10 species are known from the Park
(Wetmore 1950; Simpson 1992 in Mahan, C. G. 2006). Resident species include sharp-shinned
hawk, Cooper's hawk, broad-winged hawk, northern harrier, and red shouldered hawk. The Park
is one of the few places in the Eastern U.S. where peregrine falcons can be periodically observed
nesting in their natural and historic habitat.
Wild turkey, ruffed grouse, and American woodcock are some of the gound-nesting species that
occur in the Park (Wetmore 1950; Simpson 1992 in Mahan, C. G. 2006).
A diversity of bird species that are found in the Park, including turkey vulture, black vulture,
American crow, common raven, and black-capped chickadee, feed on carcasses when available.
SOCIOECONOMICS
White-tailed deer hunting contributes to the local economy of the area surrounding the Park.
Options for CWD detection and assessment that would affect deer (e.g., those that would involve
removing presumably healthy animals) could affect the local economy, including businesses that
rely on deer hunting (e.g. firearms stores) and local hunting opportunities (e.g. sustenance-based
hunting) , by reducing animals available for hunting. If CWD is discovered in the area, it could
possibly influence hunting-related and wildlife-viewing tourism around the Park due to the
uncertainties surrounding the disease. The Park also attracts visitors to the local area,
contributing to tourism around the Park and in gateway communities. In summary, 1) there could
be a reduction in sustenance-based hunting opportunities affecting local residents, 2) a reduction
in Park visitation (and fees) due to reduced/impaired deer viewing opportunities, 3) which could
lead to a loss of revenues to local businesses (e.g. restaurants, lodging, shops), and a loss of
revenues to businesses that depend on deer hunting (e.g. hunting/firearms stores, guide services,
check stations, taxidermists). Should there be any changes in visitation to the Park as a result of
CWD detection and assessment activities, it could have effects on local socioeconomics. The
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focus of this overview is the area immediately surrounding the Park (e.g. surrounding towns,
etc.).
Shenandoah National Park stretches over 100 miles from its northern entrance at Front Royal,
Virginia, to its southern entrance near Waynesboro, Virginia. The Park encompasses more than
197,000 acres in eight counties (Albemarle, Augusta, Green, Madison, Page, Rappahannock,
Rockingham, and Warren). There are four independent cities, Harrisonburg, Staunton,
Waynesboro, and Charlottesville, and numerous incorporated towns in the immediate area of the
Park. The local region is predominantly rural, with approximately one-third of the population
living in urban communities and the remainder in rural areas. The regional economy has been
shifting in recent decades, from a subsistence farming economy to a more balanced economy
including farming, light industry, tourism, and providing goods and services to Washington, DC
commuters. The Park represents a substantial component of local and regional tourism.
Shenandoah National Park is highly accessible. Two U.S. highways parallel the Park closely,
Route 340 along the west side and Route 522 along the east side. Interstate Highway 66 passes
near the north end of the Park, and Interstate Highway 64 and U.S. Highway 250 pass near the
south end. There are over 200 miles of NPS-owned roads, including the 105-mile Skyline Drive,
which traverses the entire length of the Park; 55 other paved roads; and 91 unpaved roads,
including 78 miles of fire roads.
VISITOR USE AND EXPERIENCE
Implementation of CWD detection and assessment activities may require certain areas of the
Park to be closed to public use during such activities, which would affect visitor use and
experience. Recreational resources in the Park that could be affected include trails, campgrounds,
and Skyline Drive. CWD detection and assessment activities that result in fewer deer in a
particular area could reduce the opportunity to view deer, which may affect visitor use and
experience. The use of firearms for sampling purposes could influence the soundscape at the
Park which could also impact visitor experience and adjacent landowners. Enhanced visitor
awareness with respect to detection of CWD and assessments to positive cases could also have
an effect.
Shenandoah National Park receives approximately 1.1 million recreational visits per year. Most
of the visitors to the Park come during the months of July through October. The majority of
visitors arrive by vehicle. Visitors can enter the Park at Front Royal, Thornton Gap, Swift Run
Gap, and Rockfish Gap. Two additional boundary contact stations are staffed on summer
weekends. There are two visitor centers, four campgrounds, and seven picnic areas. ARAMARK
manages three lodging facilities, five food service outlets, three service stations, and six
merchandise outlets. Approximately 516 miles of trails are in the Park, including 101 miles of
the Appalachian Trail and 200 miles of designated horse trails.
Many visitors experience the Park from their vehicles by driving the Skyline Drive. Some of the
most popular out-of-the-car activities are hiking, picnicking, camping in developed campgrounds
or in the backcountry, participating in ranger-guided activities, viewing audio-visual programs or
exhibits at visitor centers, fishing, enjoying the panoramic views from overlooks, or just relaxing
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in the peaceful surroundings. Other opportunities include auto touring, backpacking, biking, bird
watching, climbing, horseback riding, stargazing, and wildlife viewing.
HEALTH AND SAFETY
CWD detection and assessment activities that involve capturing and immobilizing live animals
for marking/collaring and performing tonsillar or rectal biopsies have the potential to affect the
health and safety of the employees involved. The options that involve the use of firearms have
the potential to affect the safety of Park staff, visitors, and adjacent landowners.
Protection Rangers (Law Enforcement) are responsible for visitor safety monitoring and
management on a daily basis and provide visibility and investigation for the protection of
persons and property, traffic safety programs, and monitoring of visitor activity patterns. The
Park provides information about visitor safety to the public through pre-visit information by mail
and on the Internet. In addition, visitor contact and orientation bulletin boards notify visitors of
dangers (e.g., bear) in the Park. One safety concern is the number of deer/vehicle collisions in the
Park. For the years 2005–2007, the number of incidents reported was 29, 27, and 34, respectively
(NPS, J. Chorley, Telecommunications Manager, 2008).
Safe work practices are a primary element of all Park management activities. For example, the
Park has safety plans that address winter operations, hazardous tree management, search and
rescue, and emergency medical services. Specifically related to CWD Detection and Prevalence
Determination are written plans that employees use related to wildlife handling and
immobilization. These plans emphasize employee and visitor safety. There is minimal ranger
presence in the backcountry and primitive areas except for emergency response.
PARK MANAGEMENT AND OPERATIONS
In response to the 2005 detection of CWD in white-tailed deer in Hampshire County, West
Virginia, less than 60 miles from the Park, the Park has implemented opportunistic and targeted
surveillance activities. In addition, the Park currently conducts deer monitoring activities that
require Park staff and funds. CWD detection and assessment activities proposed in this plan
would require additional staff time and expenditures that could affect Park management and
operations. Increased communication and coordination with the state, as well as educating the
public and other interested parties about CWD, its detection, and assessment, would also require
additional staff time.
Shenandoah National Park is divided into three administrative districts. The North District
extends from the northern terminus of the Park south to Thornton Gap near milepost 32. The
Central District extends from Thornton Gap south to Swift Run Gap near milepost 65. The South
District extends from Swift Run Gap south to the southern terminus of the Park at Rockfish Gap
near milepost 105.
Park staff is separated into five management divisions: Administration, Interpretation and
Education, Maintenance, Natural and Cultural Resources, and Ranger Activities. Numbers of
employees tend to change over time but in general, the Park has approximately 142 permanent
employees and generally hires about 100 temporary employees each year. The total 2007 fiscal
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year appropriation for the Park was $10,627,000. The budget for the previous six years was
approximately $10 million annually.
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ENVIRONMENTAL CONSEQUENCES
This chapter describes the potential environmental consequences associated with the no-action
and action alternatives. The overall methodology for assessing impacts is presented below. The
chapter is organized by resource topic and provides a standardized comparison between
alternatives based on the most relevant impact topics described in Chapter 1. The analysis period
used for assessing impacts is up to 10 years, which is the life of this plan. It should be noted, that
the implementation of this plan (any of the three alternatives) is subject to future available funds.
The geographic study area (or area of analysis) for this plan is the boundary of the Park. The area
of analysis may extend beyond the Park boundary for some cumulative impact assessments. The
specific area of analysis for each impact topic is defined at the beginning of each topic
discussion. Mitigating measures for adverse impacts are also described. NPS policy also requires
a determination of whether any impacts would result in the impairment of Park resources or
values.
METHODOLOGY
As required by NEPA, potential impacts are described in terms of duration, type, context, and
level of intensity. These terms are defined below. Overall, these impact analyses and conclusions
were based on the review of the existing literature and Park studies, information provided by onsite experts and other agencies, professional judgment, and Park staff knowledge and insight.
Duration and Type of Impacts
The following assumptions are used for all impact topics (the terms “impact” and “effect” are
used interchangeably throughout this document):
1. Short-term impacts — Impacts would last from a few days up to three years following an
action.
2. Long-term impacts — Impacts would last longer than three years up to the life of the plan
(approximately 10 years).
3. Direct impacts — Impacts would immediately occur as a direct result of CWD detection or
assessment actions.
4. Indirect impacts — Impacts from CWD detection or assessment actions that would occur
later in time or farther in distance from the action.
Impact Thresholds and Impact Intensity Definitions
Determining impact thresholds is a key component in applying NPS Management Policies and
Director’s Order #12. These thresholds provide the reader with an idea of the intensity of a
given impact on a specific topic. The impact threshold is determined primarily by comparing the
effect to a relevant standard based on regulations, scientific literature and research, or best
professional judgment. The intensity of the impact is then defined by the standard terms
“negligible,” “minor,” “moderate,” or “major.” Because impact thresholds may be different for
different resources, intensity definitions are provided separately for each impact topic analyzed
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in this plan. In all cases, the impact thresholds are defined for adverse impacts. Beneficial
impacts are addressed qualitatively and are not described by intensity definitions.
COMPLIANCE WITH SECTION 106 OF THE
NATIONAL HISTORIC PRESERVATION ACT
All cultural resources were dismissed from analysis. The Park did an in-house assessment of “No
Historic Properties Affected.” There were no historic properties affected. The project has no
potential to cause effects on cultural resources [(800.3 (a) (1)].
CUMULATIVE IMPACTS
The Council on Environmental Quality regulations, which implement NEPA, requires
assessment of cumulative impacts in the decision-making process for federal projects.
Cumulative impacts are defined as "the impact on the environment which results from the
incremental impact of the action when added to other past, present, and reasonably foreseeable
future actions regardless of what agency (federal or non-federal) or person undertakes such other
actions" (40 CFR 1508.7). Cumulative impacts are considered for both the no-action and action
alternatives. Cumulative impacts were determined by combining the impacts of the alternatives
with the impacts of other past, present, and reasonably foreseeable future actions. Therefore, it
was necessary to identify other ongoing or reasonably foreseeable future projects at the Park and,
if applicable, the surrounding region. Table 11 summarizes the actions that could affect Park
resources.
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Table 11. Cumulative action scenario.
Impact Topic
Study Area
White-tailed deer Boundary of
Shenandoah
National Park
and adjacent
landowners
Temporal
Boundaries
Late 1970s
(impacts from
deer evident) – life
of the plan (10
years)
Past Actions
Current Actions
Prescribed fire
Introduction of gypsy moth
Introduction of hemlock wooly
adelgid
Exotic plant management (since
1991)
Mowing/burning in areas such as
Big Meadows / vista
Maintenance of Skyline Drive
corridor
Maintenance of other road / utility
corridors
Hazard tree management
Restoration – plantings
Removal of Panorama (old
concessions facility) and site
restoration
Big Meadows campground
construction
Herbivory (domestic livestock)
Construction-bridge repair/
replacements
Deer management (NPS)
Social trails and illegal campsites
in backcountry
Implementation of Wilderness
Management Plan
State Bear Management Plan
Farming
Feeding of deer
Development around Park
Nuisance wildlife relocation
Poaching / illegal harvest
Vehicle / wildlife collisions
Non-observational research
Non-observational monitoring
Air quality – acid deposition,
Prescribed fire
Fire Management Plan – lightningcaused fires, mechanical
manipulation
Exotic plant management
Mowing / burning in areas such as
Big Meadows / vista
Maintenance of Skyline Drive
corridor
Maintenance of other roads / utility
corridors
Hazard tree management
Restoration – plantings,
rehabilitation of camp sites,
stream / terrestrial restoration
Herbivory (domestic) – intermittent
compared to the past
Establishment of exclosures for
research activities
Trails maintenance, relocation,
and closure.
Rock Outcrop Planning
Administrative Road Planning
Deer management (NPS)
Reintroduction of landscaping at
Camp Rapidan
Maintenance and upkeep of
developed areas
Implementation of Wilderness
Management Plan
State Bear Management Plan
State Draft Deer Management
Plan
State CWD Response /
Surveillance Plan
Farming
Feeding of deer
Future Actions
(10 years)
Same as present except
administrative road planning:
Administrative road closures
Overlook rehabilitation
Skyline Drive rehabilitation
Rehabilitation of potable water
systems
Increased development around the
Park
CWD Detection and Assessment Plan and EA
Impact Topic
Study Area
Temporal
Boundaries
Shenandoah National Park
Past Actions
ozone, particulate matter
Vegetation
Boundary of
Shenandoah
National Park
Late 1970s
(impacts from
deer evident) – life
of the plan (10
years)
Prescribed fire
Introduction of gypsy moth
Introduction of hemlock wooly
adelgid
Exotic plant management (since
1997)
Mowing / burning in areas such as
Big Meadows / vista
Maintenance of Skyline Drive
corridor
Maintenance of other roads / utility
corridors
Hazard tree management
Restoration – plantings
Big Meadows campground
construction
Removal of Panorama (old
concessions facility), and site
restoration
Herbivory (domestic livestock)
Construction-bridge repair /
replacements
Deer management (NPS)
Social trails and illegal campsites
in backcountry
Implementation of Wilderness
Management Plan
Non-observational research
Non-observational monitoring
Poaching / illegal harvest
(individual and commercial) ginseng, black cohosh, slippery
elm
Current Actions
Future Actions
(10 years)
Development around the park
Poaching / illegal harvest
Vehicle / wildlife collisions
Non-observational research
Non-observational monitoring
Prescribed fire
Fire Management Plan – lightningcaused fires, mechanical
manipulation
Exotic plant management
Mowing / burning in areas such as
Big Meadows / vista
Maintenance of Skyline Drive
corridor
Maintenance of other roads / utility
corridors
Hazard tree management
Restoration – plantings,
rehabilitation of camp sites,
stream / terrestrial restoration
Herbivory (domestic) – intermittent
compared to the past
Establishment of exclosures for
research activities
Trails maintenance, relocation,
and closure
Rock Outcrop Planning
Administrative Road Planning
Deer management (NPS)
Reintroduction of landscaping at
Camp Rapidan
Maintenance and upkeep of
developed areas
Non-observational research
Non-observational monitoring
Poaching / illegal harvest
(individual and commercial)
Same as current except for rock
outcrop and administrative road
planning.
Plus:
Administrative road closures
Implementation of rock outcrop
plan
Overlook rehabilitation
Skyline Drive rehabilitation
Rehabilitation of potable water
systems
Increased development around the
Park
CWD Detection and Assessment Plan and EA
Impact Topic
Study Area
Other Wildlife
Boundary of
Shenandoah
National Park
Temporal
Boundaries
Late 1970s
(impacts from
deer evident) – life
of the plan (10
years)
Shenandoah National Park
Past Actions
Current Actions
Prescribed fire
Introduction of gypsy moth
Introduction of hemlock wooly
adelgid
Exotic plant management (since
1997)
Mowing / burning in areas such as
Big Meadows
Maintenance of Skyline Drive
corridor
Maintenance of other roads / utility
corridors
Hazard tree management
Restoration – plantings
Big Meadows campground
construction
Herbivory (domestic livestock)
Construction-bridge repair /
replacements
Deer management (NPS)
Social trails and illegal campsites
in backcountry
Implementation of Wilderness
Management Plan
State Bear Management Plan
Farming
Feeding of deer
Development around the Park
Nuisance wildlife relocation
Poaching / illegal harvest
Vehicle / wildlife collisions
Non-observational research
Non-observational monitoring
Air quality – acid deposition,
ozone, and particulate matter
Peregrine falcon restoration
Prescribed fire
Fire Management Plan – lightningcaused fires, mechanical
manipulation
Exotic plant management
Mowing/burning in areas such as
Big Meadows / vista/
Maintenance of Skyline Drive
corridor
Maintenance of other roads / utility
corridors
Hazard tree management
Restoration – plantings,
rehabilitation of camp sites,
stream / terrestrial restoration
Herbivory (domestic) – intermittent
compared to the past
Establishment of exclosures for
research activities
Trails maintenance, relocation,
and closure.
Rock Outcrop Planning
Administrative Road Planning
Deer management (NPS)
Reintroduction of landscaping at
Camp Rapidan
Maintenance and upkeep of
developed areas
Implementation of Wilderness
Management Plan
State Bear Management Plan
State Draft Deer Management
Plan
State CWD Response /
Surveillance Plan
Farming
Feeding of deer
Development around the Park
Poaching / illegal harvest
Future Actions
(10 years)
Same as present except for
administrative road planning:
Administrative road closures
Implementation of rock outcrop
plan
Removal of Panorama (old
concessions facility), and site
restoration
Overlook rehabilitation
Skyline Drive rehabilitation
Rehabilitation of potable water
systems
Increased development around the
Park
Potential for avian flu
CWD Detection and Assessment Plan and EA
Impact Topic
Study Area
Temporal
Boundaries
Shenandoah National Park
Past Actions
Current Actions
Future Actions
(10 years)
Vehicle / wildlife collisions
Non-observational research
Non-observational monitoring
Air quality – acid deposition,
ozone, and particulate matter
Threatened and Boundary of
Endangered
Shenandoah
Species
National Park
Late 1970s
(impacts from
deer evident) – life
of the plan (10
years)
Prescribed fire
Introduction of gypsy moth
Introduction of hemlock wooly
adelgid
Exotic plant management (since
1997)
Mowing/burning in areas such as
Big Meadows / vista
Maintenance of Skyline Drive
corridor
Maintenance of other road / utility
corridors
Hazard tree management
Restoration – plantings
Big Meadows campground
construction
Removal of Panorama (old
concessions facility), and site
restoration
Herbivory (domestic livestock)
Construction-bridge repair /
replacements
Deer management (NPS)
Social trails and illegal campsites
in the backcountry
Implementation of the Wilderness
Management Plan
State Bear Management Plan
Farming
Feeding of deer
Development around the Park
Nuisance wildlife relocation
Poaching / illegal harvest
Prescribed fire
Fire Management Plan – lightningcaused fires, mechanical
manipulation
Exotic plant management
Mowing / burning in areas such as
Big Meadows / vista
Maintenance of Skyline Drive
corridor
Maintenance of other road / utility
corridors
Hazard tree management
Restoration – plantings,
rehabilitation of camp sites,
stream / terrestrial restoration
Herbivory (domestic) – intermittent
compared to the past
Establishment of exclosures for
research activities
Trails maintenance, relocation,
and closure
Rock Outcrop Planning
Administrative Road Planning
Deer management (NPS)
Reintroduction of landscaping at
Camp Rapidan
Maintenance and upkeep of
developed areas
Implementation of Wilderness
Management Plan
State Bear Management Plan
State Draft Deer Management
Plan
Same as present except
administrative road planning:
Administrative road closures
Overlook rehabilitation
Skyline Drive rehabilitation
Rehabilitation of potable water
systems
Increased development around the
Park
Changes in listing status (state)
CWD Detection and Assessment Plan and EA
Impact Topic
Study Area
Socioeconomics Boundary of
Shenandoah
National Park
and gateway
communities
Temporal
Boundaries
Shenandoah National Park
Past Actions
Current Actions
Vehicle / wildlife collisions
Non-observational research
Non-observational monitoring
Exotic fish removal
Air quality – acid deposition,
ozone, and particulate matter
Peregrine falcon restoration
Shenandoah Salamander
Recovery Plan
State CWD Response /
Surveillance Plan
Farming
Feeding of deer
Development around the park
Poaching / illegal harvest
Vehicle / wildlife collisions
Non-observational research
Non-observational monitoring
Exotic fish removal
Air quality – acid deposition,
ozone, and particulate matter
Peregrine restoration
Shenandoah Salamander
Recovery Plan
Programmatic Consultation with
USFWS for Parkwide
Operations
Increased wildlife viewing
Late 1970s
(impacts from
opportunities (e.g., watchable
deer evident) – life wildlife trails) in the Park
of the plan (10
Main Street planning in gateway
years)
communities / community
revitalization
Designation of Skyline Drive as
National Scenic Byway
Migration of bedroom communities
from Washington, DC, to the
west – land conversion from
agricultural uses to small
farmettes and small forested
residential lands
Migration of some industries out of
gateway communities
(increased unemployment)
Tax shelters for conservation
easements
Enhanced partnership with
Shenandoah Valley Travel
Association to obtain marketing
grants to increase tourism
Civic engagement seminars
Migration of bedroom communities
from Washington, DC, to the
west - land conversion from
agricultural uses to small
farmettes and small forested
residential lands
Tax shelters for conservation
easements
Hunting
Reductions of rights-of-way into
Park
Reductions in public access to
Park boundary
Future Actions
(10 years)
Enhanced partnership with
Shenandoah Valley Travel
Association to obtain marketing
grants to increase tourism
Civic engagement seminars
Migration of bedroom communities
from Washington, DC, to the
west - land conversion from
agricultural uses to small
farmettes and small forested
residential lands
Tax shelters for conservation
easements
Socioeconomic study of
Appalachian Trail
Tax shelters for conservation
easements
Hunting
CWD Detection and Assessment Plan and EA
Impact Topic
Study Area
Temporal
Boundaries
Shenandoah National Park
Past Actions
Current Actions
Future Actions
(10 years)
Hunting
Commercialization of Park
resources (ginseng, animal
parts)
Reductions in public access to
Park boundary
Human Health
and Safety
Boundary of
Shenandoah
National Park
Visitor Use
Boundary of
and Experience Shenandoah
National Park
Late 1970s
Educational / interpretive programs
(impacts from
(personal and non-personal)
deer evident) – life Operational / Administrative
functions (routine preventive
of the plan (10
years)
maintenance to minimize risks,
routine patrols, plowing / salting
roads, hazard tree removal, etc.)
Traffic / Traffic jam intervention
Multiple recreational uses
Air pollution / ozone
Emergency response
Job hazard analysis
Oral Rabies Vaccinations
Nuisance animal relocations
Vector borne diseases
Wildlife interactions
Vehicle/wildlife collisions
Trail maintenance
Criminal Activity and Crime
Prevention
Same as past plus:
Development of Backcountry
Safety Plan
Improvement of radio system
Avian flu planning
Late 1970s
Educational / interpretive programs Same as past plus:
(impacts from
(personal and non-personal)
Motorcycle noise abatement
deer evident) – life Operational / Administrative
of the plan (10
functions-noise and other
years)
disturbances (e.g., limiting
access or other disruptions;
prescribed burns and effects on
visibility)
Traffic / Traffic jam intervention
Multiple recreational uses
Same as past plus:
Improvement of Radio System
Same as past plus:
Motorcycle noise abatement
CWD Detection and Assessment Plan and EA
Impact Topic
Study Area
Temporal
Boundaries
Shenandoah National Park
Past Actions
Current Actions
Future Actions
(10 years)
Special Use Permits
Trail closures
Park
Management
and
Operations
Boundary of
Shenandoah
National Park
Late 1970s
Staff reduced by more than 40
(impacts from
full-time employees (FTE) over
deer evident) – life a few decades and associated
of the plan (10
reductions in services and
years)
monitoring / management
Periodic monitoring programs
Visitation decreasing
Changing visitor use seasons
Potential staff reductions and
associated reductions in
services and monitoring /
management
Periodic monitoring programs
Periodic monitoring programs
CWD Detection and Assessment Plan and EA
Shenandoah National Park
IMPACTS ON PHYSICAL AND NATURAL RESOURCES
White-tailed Deer Population
The evaluation of impacts to deer was based on a qualitative assessment of how actions directly
related to CWD detection and assessment, and the outcome of these actions, could affect the
white-tailed deer populations in the Park. Although researchers believe CWD could have
population level effects on deer herds, it is still unknown if these would include dramatic effects
on localized populations as a result of large scale declines, or if the disease would eventually
reach equilibrium and stabilize at an endemic level. As a result, the analysis considered how each
alternative would influence risk related to amplification, spread, and establishment of CWD, as
well as exposure to possible population level effects, should the disease be detected inside or
near the Park.
Available information on the white-tailed deer populations (density, movement, condition, and
disease) in the Park was compiled and analyzed in relation to the management actions.
Information on the risk factors for amplification and spread of CWD was also considered. These
risk factors are found in areas with the following characteristics:
•
•
•
•
a history of CWD animals or CWD-contaminated environments;
high deer population density;
low abundance of large predators; and
free-ranging deer are artificially concentrated (baiting, feeding, water development, and other
human-related habitat modifications) (Samuel et al. 2003).
The thresholds for the intensity of an impact on the deer population were based on this available
information, as follows:
Negligible:
Minor:
Moderate:
Major:
There would be no observable or measurable impacts to the deer population (e.g.,
density, movement, herd health, risk of diseases). Impacts would be well within
natural fluctuations.
Small changes to the deer population (e.g., density, movement, herd health, or risk
of diseases) might occur from implementation or outcome of management
actions. Occasional responses to disturbance by some individuals could be
expected but without interference to factors affecting population levels. Impacts
would be detectable but would not be outside the natural range of variability.
Impacts on the deer population (e.g., density, movement, herd health, risk of
diseases) could be outside the natural range of variability, but the deer population
would remain stable and viable. Frequent responses to disturbance by some
individuals could be expected, with some adverse impacts to factors affecting
population levels.
Impacts on the deer population (e.g., density, movement, condition, risk of
diseases) would be detectable, would be expected to be outside the natural range
of variability, and would be extensive. Impacts would potentially result in
decreased viability or stability of the deer population. Frequent responses to
disturbance by some individuals would be expected with adverse impacts to
factors negatively affecting population levels.
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CWD Detection and Assessment Plan and EA
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Area of Analysis
The area of analysis for assessment of impacts is the land within the Park. The area of analysis
for cumulative impacts consists of the Park and the area within 5 miles of the boundaries, which
is based on the Virginia CWD response plan surveillance area.
Impacts of the Alternatives
Alternative A: No Action (Continue Current Actions)
Specific Impacts to Deer
Under this alternative, opportunistic and targeted surveillance with the potential for live testing
for CWD would continue in the Park. It is assumed that approximately 14 deer would be
removed annually during opportunistic surveillance, and potentially one deer would be removed
by targeted surveillance. With the exception of using firearms for targeted surveillance, activities
directly associated with these actions would have impacts similar to those associated with routine
field work conducted in the Park. For example, the presence of people could disturb deer,
causing them to temporarily disperse. Although the use of firearms in the Park would cause more
changes in deer movement, they would be temporary. Ultimately, these changes would be
detectable during opportunistic and targeted surveillance efforts but would return to predisturbance levels once actions are finished. Samples for live CWD tests would only be taken
when deer are captured and collared in the Park as part of other research projects. Therefore, this
would not increase impacts on deer movement beyond those associated with these other projects.
These actions would not cause deer to disperse further than they do naturally and would not have
any measurable, long-term population level impacts and would not increase the short-term
potential for infectious contacts outside the Park.
Because opportunistic surveillance involves removing deer that have died for other reasons, it
would not affect the density of the Park deer populations. Targeted surveillance could result in
the removal of deer that show clinical signs of CWD, but is not likely to influence deer density in
the Park. No deer were removed using targeted surveillance since surveillance was started in
2008. Live testing activities for CWD would be relatively small-scale and short in duration, and
therefore would not change Park deer densities.
Although the potential for live testing would not change, if CWD is detected in or near the Park,
opportunistic and targeted surveillance would likely increase which could increase the frequency
of impacts that result from these actions. However, the changes to the deer population (e.g.,
density, movement, herd health, or risk of diseases other than CWD) would be small, would not
have population level effects, and would not be considered outside the natural range in
variability. As a result, activities directly associated with opportunistic and targeted surveillance
would have short-term, negligible to minor (depending on whether or not CWD is detected)
adverse impacts on white-tailed deer. There would be no change in risks associated with diseases
of concern other than CWD.
In the event CWD is introduced in or near the Park, detection prior to the point at which clinical
signs become apparent would provide an early opportunity to remove diseased deer. This could
ultimately affect the amplification and spread of the disease by removing a source of CWD
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CWD Detection and Assessment Plan and EA
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prions that could be transmitted to other deer indirectly (through the environment) or directly
(animal to animal contact). Continued opportunistic and targeted surveillance under Alternative
A would facilitate detection of CWD positive deer, but primarily after clinical signs are apparent,
which could be up to one year after an individual deer becomes infected. Although this would
still have the effect of removing some diseased animals, once CWD is detected under Alternative
A, the NPS could not implement any actions beyond continued opportunistic and targeted
surveillance and possibly live testing. Therefore, this alternative would provide limited
opportunity for early detection and removal of diseased deer, which would have a limited effect
on the potential for amplification and spread of CWD.
CWD infected deer serve as a source of prions that persist in the environment and may serve as a
source of the disease following removal of CWD positive deer (Miller et al. 2004). These prions
bind to soil particles, continue to be infectious, and can remain in soil environments for at least
three years (Johnson et al. 2006; Schramm et al. 2006). Therefore, prions from CWD positive
deer could remain in the soil or water, which could serve as reservoirs or pathways for spread of
the disease to exposed healthy deer. Also, high deer densities such as those found in some areas
of the Park (e.g., Skyline Drive, Big Meadows) are an amplification risk factor for CWD.
Opportunistic surveillance and live testing would not affect the density of the deer populations in
the Park. Although targeted surveillance has the potential to remove some deer, it would result in
imperceptible changes to these areas with relatively high deer densities.
Considering the minimal effect this alternative would have on risk factors, the potential for CWD
amplification and spread (which could lead to establishment of the disease) would be high.
Although the exact effects are unknown at this time, establishment of the disease could
eventually impact survival rates of the deer herd. These effects would not affect the stability and
viability of the deer herd during the life of this plan. The impacts from Alternative A would be
long-term, moderate, and adverse. Note: The Park recognizes that CWD may affect the stability
and viability of the herd beyond the life of this plan; this topic will be addressed by long-term
management planning efforts and is not appropriate to evaluate here.
Cumulative Impacts
Actions that have contributed to adverse cumulative effects on deer surrounding the Park include
loss and fragmentation of habitat that result from clear cutting of forests, loss of agricultural land
uses, suburban/rural developments, past highway expansion, and potential over-hunting in some
areas. This habitat loss is expected to continue into the future with continued development,
especially in the towns of Harrisonburg, Staunton, Waynesboro, and Charlottesville. Increased
VDGIF CWD surveillance activities (testing hunter and road-killed deer plus increased targeted
surveillance) outside the Park are not expected to have adverse cumulative effects on the deer
surrounding the Park. Right-of-way maintenance and Park operations (e.g., mowing,
maintenance setbacks) also reduce woody vegetative cover available to deer in some areas of the
Park. Manipulation of Park vegetation also creates enhanced ecological conditions (increased
edge habitat and grasses/forbs) that foster deer overabundance. Increased traffic in the Park and
higher deer densities may also contribute to cumulative effects as a result of the increased
potential for deer–vehicle collisions. High deer density areas (e.g., Skyline Drive, Big Meadows)
produce a higher risk factor for the amplification and spread of CWD. In addition, areas of the
Park near captive deer facilities have an increased risk factor for CWD. Despite some predation
80
CWD Detection and Assessment Plan and EA
Shenandoah National Park
on deer fawns (e.g., bear, coyote), they are taken at a rate which is not likely to reduce the
likelihood of CWD establishment, amplification, or spread. Cumulative impacts to white-tailed
deer would be long-term, moderate, and adverse. Actions directly related to Alternative A would
have negligible contributions to impacts on white-tailed deer populations. However, this
alternative would have substantial contributions to the potential for CWD amplification, spread,
and establishment, as well as exposure to possible long-term population level effects. Although
population level effects could occur, the deer population would be expected to remain viable.
Conclusion
Actions directly associated with opportunistic and targeted surveillance, and possibly live
testing, would have short-term, negligible adverse impacts on white-tailed deer from temporary
disturbances during implementation. There would be long-term, moderate, adverse impacts
because Alternative A would have minimal effects on CWD risk factors and the potential for
amplification, spread, and establishment of the disease. Exposure to possible population level
effects would remain high.
Actions directly associated with assessment actions would have temporary negligible
contributions to cumulative impacts on white-tailed deer populations, which would be long-term,
moderate, and adverse. However, this alternative would have moderate contributions to
cumulative impacts from the potential for CWD amplification, spread, and establishment.
Alternative B: Enhanced Detection and Assessment, Including Lethal Removal for Testing
Specific Impacts to Deer
Under Alternative B, enhanced opportunistic and targeted surveillance would be used for CWD
detection and could be supplemented with live testing and lethal removal of healthy-appearing
deer for CWD testing under specific criteria. Effects on deer movement (temporary dispersal
from the presence of people) during targeted surveillance would be somewhat more than those
associated with routine field work conducted in the Park since more people would be looking for
deer (overall, still negligible though). Although the limited use of firearms for enhanced targeted
surveillance could cause more deer movement, it would be temporary and would return to predisturbance levels once the actions are complete. As with Alternative A, samples for live CWD
testing would only be taken when deer are captured and collared in the Park as part of other
projects. Therefore, this would not increase impacts on deer movement beyond those associated
with these other projects.
As with enhanced targeted surveillance, the use of firearms to lethally remove deer for detection
surveillance would result in more changes to deer movement. Although lethal removal of healthy
appearing deer would involve a larger, more sustained effort than enhanced targeted surveillance
(a maximum weighted sample equivalent to 300 deer could be removed within two years) these
impacts would be temporary and would dissipate once these activities are complete.
All of these options would also be available as assessment tools should the disease be detected
within 30 miles of the Park, although the focus of lethal removals would shift from detection to
assessment of disease prevalence and distribution. Lethal removals for assessment would involve
removing a maximum of 69 deer for the first detection (sample size would increase as the
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CWD Detection and Assessment Plan and EA
Shenandoah National Park
number of positive detections increases according to Appendix B) over a one-year period, and
these assessment actions would have the same impacts.
Changes in movement would be detectable during both detection and assessment actions, but
movement would return to pre-disturbance levels once the associated actions are finished. Deer
would not be expected to disperse further than they do naturally. Taking into consideration these
potential changes in deer movement, the detection and assessment actions themselves under
Alternative B would have short-term, minor, adverse impacts on the deer population, notably in
areas of higher deer densities (i.e., Skyline Drive, Big Meadows).
As described for Alternative A, opportunistic and targeted surveillance would have little effect
on deer densities even when enhanced by additional personnel looking for deer. This would also
hold true for live testing, which would result in deer being removed only if positive results are
received. However, lethal removal of healthy deer as a detection and/or assessment tool could
affect deer densities in some areas of the Park (e.g., Skyline Drive, Big Meadows). These
changes to deer density in these areas would be detectable; however, they would not be outside
the natural range of variation, given densities would still be well above or similar to those found
surrounding the Park.
Although deer survival rates would be affected, sustained lower densities would result in longterm beneficial impacts to the deer herd. These long-term benefits would primarily result from
changes to the potential for CWD amplification, spread, and establishment. The use of live tests
and lethal removal of healthy appearing deer for detection surveillance would increase the
potential for early detection if CWD is found in or near the Park. This would provide an early
opportunity to remove diseased deer, which would ultimately reduce the potential amplification
and spread of the disease by removing a source of CWD prions that could be transmitted to
healthy deer indirectly (through the environment) or directly (animal to animal contact).
Considering the potential for early detection and the potential to reduce the risk factor associated
with high density deer herds, the potential for CWD amplification and spread would be reduced
compared to Alternative A. In addition, the increased opportunity for coordinating actions with
the VDGIF would also reduce the potential for amplification or spread of the disease. As a result,
Alternative B would reduce the potential for CWD establishment and exposure to possible
population level effects.
Cumulative Impacts
The same past, present, and future impacts from cumulative actions described for Alternative A
would also occur under Alternative B. Alternative B would have minor short-term adverse
impacts on white-tailed deer movements, density, and health, particularly in areas of the Park
with higher deer densities (i.e., Skyline Drive, Big Meadows). Changes in deer density, however,
would have long-term beneficial effects due to reduced competition for food and lower potential
for disease transmission. Coupled with other cumulative impacts to white-tailed deer (e.g.
potential lethal removals, winter die-offs), long-term, minor to moderate, adverse effects would
still occur (although population level effects could occur, the deer population would be expected
to remain viable).
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CWD Detection and Assessment Plan and EA
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Conclusion
Detection and assessment actions under this alternative would have short-term, minor, adverse
impacts on white-tailed deer movement, density, and health. After implementation, impacts on
deer density would have long-term beneficial effects on the population as a whole, primarily by
increasing the potential for early detection of CWD and reducing the potential for amplification,
spread, and establishment of the disease.
Alternative B would have both adverse and beneficial contributions to cumulative impacts on
white-tailed deer populations, which would be long-term, minor to moderate, and adverse.
However, this alternative would not contribute to cumulative impacts for the potential for CWD
amplification, spread, and establishment in and near the Park.
Alternative C: Enhanced Detection and Assessment but No Lethal Removal for Testing
Specific Impacts to Deer
Detection and assessment activities described for Alternative B enhanced opportunistic and
targeted surveillance and enhanced live testing would also be available under Alternative C;
however, this alternative would not involve lethal removal of healthy appearing deer for CWD
testing for detection or assessment. As described for Alternative B, these activities would result
in temporary dispersal of deer from the presence of people. Since there would be no lethal
removals for testing, this alternative would cause less deer movement than Alternative B. As
with Alternative A, samples for live CWD testing would only be taken when deer are captured
and collared in the Park as part of other projects. Therefore, this would not increase impacts on
deer movement beyond those associated with these other projects. These changes in deer
movement would be detectable during both phases but would not cause deer to disperse further
than they do naturally, and movements would return to pre-disturbance levels once the associated
actions are finished. Taking these potential changes in deer movement into consideration, the
detection and assessment actions under Alternative C would have short-term, negligible to
minor, adverse impacts on the deer population.
As described for Alternative A, opportunistic and targeted surveillance would have little effect
on deer densities even when enhanced by additional personnel looking for deer. This would also
hold true for enhanced live testing, which would result in deer being removed only if positive
results are received.
There would be no change in risks associated with diseases of concern other than CWD. This
alternative would have limited impact on the potential for CWD amplification, spread, and
establishment. The potential for early detection of CWD would be more than Alternative A
because of the use of enhanced detection and assessment options and enhanced live testing, but
less than Alternative B which includes lethal testing.
If CWD is detected in or near the Park, enhanced opportunistic/targeted surveillance and
enhanced live-testing would likely increase, which could increase the frequency of impacts that
result from these actions. However, the changes to the deer population (e.g., density, movement,
herd health, or risk of diseases other than CWD) would be small, would not have population
level effects, and would not be considered outside the natural range in variability. As a result,
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CWD Detection and Assessment Plan and EA
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activities directly associated with enhanced opportunistic and targeted surveillance and enhanced
live testing would have short term, negligible to minor (depending on whether or not CWD is
detected), adverse impacts on white-tailed deer.
Cumulative Impacts
The same past, present, and future impacts from cumulative actions described for Alternative A
would also occur under Alternative C. Actions directly related to Alternative C would have
negligible to minor contributions to impacts on white-tailed deer movements, density, and health.
Coupled with other cumulative impacts to white-tailed deer, long-term, minor to moderate,
adverse effects would still occur. This alternative would somewhat reduce the potential for CWD
amplification, spread, and establishment, and possibly long-term population level effects.
Although population level effects could occur, the deer population would be expected to remain
viable.
Conclusion
Actions directly associated with enhanced detection and assessment would have short-term,
negligible to minor, adverse impacts on white-tailed deer movement, density, and health. There
would be long-term, minor to moderate, adverse impacts on deer because Alternative C would
have limited effects on CWD risk factors and the potential for amplification, spread, and
establishment of the disease. Exposure to possible population level effects would remain high.
Actions directly associated with enhanced detection and assessment activities would have
temporary negligible contributions to cumulative impacts on white-tailed deer populations,
which would be long-term, moderate, and adverse. However, this alternative would have some
contributions to cumulative impacts from the potential for CWD amplification, spread, and
establishment.
Vegetation
Various actions taken as part of CWD detection and assessment could affect native vegetation by
changing the number of deer that graze on vegetation or could inadvertently cause the spread of
exotic plant species. Maps showing vegetation cover types, communications with NPS staff, and
past surveys were used to identify baseline conditions within the study area. Although
researchers believe that if it becomes established, CWD could have population level effects on
deer herds, it is still unknown if these would include dramatic effects on localized populations as
a result of large scale declines, or if the disease would eventually come to an equilibrium state
and stabilize at an endemic level. Therefore, the evaluation does not address impacts to
vegetation as a result of changes in deer populations should CWD become established.
The thresholds for the intensity of an impact were defined as follows:
Negligible:
Minor:
Actions would cause no measurable or perceptible changes in plant community
size, integrity, or continuity. Any reduction in vegetation would be so small that it
would not be of measurable or perceptible consequence.
Actions would cause perceptible changes but would be localized within a
relatively small area. The overall viability of the plant community would not be
affected, and if left alone would recover.
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CWD Detection and Assessment Plan and EA
Moderate:
Major:
Shenandoah National Park
Actions would cause a change in the plant community (e.g., abundance, density,
distribution, or quality); the impact would be measurable and of consequence to
the resource but localized.
Actions would cause changes in plant community properties that would be readily
apparent over a large area. The natural character of the plant community would be
substantially altered.
Area of Analysis
The area of analysis for assessing impacts on vegetation is the area contained within the
boundary of the Park.
Impacts of the Alternatives
Alternative A: No Action (Continue Current Actions)
Specific Impacts to Vegetation
Continued opportunistic and targeted surveillance and possibly live testing conducted when deer
are captured and collared for other projects under Alternative A would result in limited impacts
to vegetation. Impacts would be from occasional trampling by people such as would occur
during routine field work and research in the Park. Trampling would also occur during the
periodic removal of deer carcasses found dead or lethally removed as part of targeted
surveillance. In forested and wetland areas, this would impact herbaceous and short woody
plants (e.g., shrubs or tree saplings), but would not alter the overall vegetative structure.
Surveillance could occur during the growing season and there would be a perceptible reduction
in vegetation in small areas where trampling occurs. In addition, vegetation under carcasses left
to decompose would temporarily die back. These impacts would be temporary, and if left alone,
vegetation would recover and there would be no long-term, measurable consequences to the
overall viability of the plant communities. As described in the analysis of impacts to white-tailed
deer, any changes in movement as a result of surveillance activities would be expected to be
within the range of natural variation. Therefore, deer dispersal would not increase impacts to
vegetation. People and vehicles associated with surveillance actions could inadvertently transport
seeds of nonnative species. These introductions could cause changes in species diversity or
abundance of native plants, which would have perceptible effects on native plant communities.
The potential for long-term impacts to the size, integrity, continuity, and, ultimate viability of
these plant communities would be limited by nonnative species control programs in the Park.
Considering these effects, actions directly related to opportunistic and targeted surveillance and
live testing would have short-term, negligible to minor, adverse impacts on vegetation. Should
CWD be detected in or near the Park, opportunistic and targeted surveillance would likely
increase, which could increase the frequency of impacts that result from these actions; however,
these impacts would remain short-term and would not affect the overall viability of the plant
communities.
As described in the impacts analysis for white-tailed deer, there would be minimal change in
deer density under Alternative A, unless CWD effects reduced the number of deer through death.
This would also be true for live-testing, which would only result in some deer being removed if
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positive results are received. Sustained browsing in areas with higher population densities would
continue to have measurable effects on the diversity and abundance of understory shrubs and
grasses found in forested and wetland areas. Therefore, the CWD surveillance actions that would
occur under Alternative A would not result in any effects to the existing conditions.
Cumulative Impacts
Adverse cumulative effects on vegetation include past land use, natural and anthropogenic
disturbances, and increasing competition with nonnative vegetation. In addition, fires, tropical
storms, ice, and impacts from ozone and acid precipitation deposition continue to adversely
affect the vegetation. Insects and disease will continue to influence the health of forest and
wetland communities. Herbivory, primarily in areas of the Park with high deer densities (e.g.
developed areas), continues to contribute substantially to adverse effects on diversity and
abundance of understory shrubs and grasses. Current and past Park operations, such as mowing,
burning, vegetative rehabilitation (e.g., Skyline Drive, Panorama), and road, trail and campsite
maintenance have also altered vegetative cover. Future Park actions associated with trail
relocations and other disturbance-creating projects will change vegetative communities in these
areas. All of these actions would be expected to result in vegetation loss and fragmentation of
plant communities into the future.
Although fire management would have short-term adverse impacts from prescribed burns
(including associated field activities), there would be long-term beneficial effects on vegetation
from nutrient release and regrowth of native plants. In light of the adverse and beneficial effects
from past, present, and reasonably foreseeable future actions, cumulative impacts on vegetation
in the Park would be long-term, moderate, and adverse (there would be measurable consequence
to localized plant communities). Actions directly related to surveillance under Alternative A
would have negligible to minor contributions to these impacts on vegetation.
Conclusion
Actions associated with opportunistic and targeted surveillance and live testing would have
short-term, negligible to minor, adverse impacts on vegetation from temporary disturbances
during implementation. Because these surveillance efforts would not measurably affect deer
densities across the Park, CWD surveillance actions that would occur under Alternative A would
not result in any indirect effects (i.e., herbivory) to existing vegetative conditions. Cumulative
impacts on vegetation would be long-term, moderate, and adverse; however, surveillance actions
under Alternative A would contribute minimally to these effects.
Alternative B: Enhanced Detection and Assessment, Including Lethal Removal for Testing
Specific Impacts to Vegetation
Under Alternative B, enhanced opportunistic and targeted surveillance would be used for CWD
detection and could be supplemented with live tests and lethal removal of healthy appearing deer
for CWD testing under specific criteria. As described for Alternative A, effects on vegetation
during enhanced opportunistic and targeted surveillance and live testing would be similar to
those associated with routine field work conducted in the Park. This would include temporary
reductions in vegetation in small areas from trampling and the potential for the inadvertent
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introduction or spread of nonnative plants. Lethal removal of healthy appearing deer for testing
would involve a larger, more sustained effort for detection (a maximum sample of 300 deer
could be removed over three years). The vegetation impacts would also be the same, but would
likely occur in more parts of the Park and more frequently. All of these options would also be
available in the assessment mode should the disease be detected zero to five miles from Park,
although the focus of lethal removals would shift from detection to assessment. Lethal removals
for assessment purposes would involve removing the Park’s “fair share” portion of samples (up
to 69 deer for one detection – Appendix B) in one year, and these assessment options would have
the same impacts as detection.
This Alternative would have the same effects as Alternative C in addition to potential vegetation
impacts because of the lethal removal options under the Detection (five-30 miles) and
Assessment (zero to five miles) scenarios. Detection and assessment activities would result in
perceptible impacts to shrub and herbaceous species in forested and wetland areas. But these
activities would not alter the vegetative structure of native plant communities, which would
remain viable. If left alone, vegetation would recover where carcasses decomposed or trampling
had occurred. The potential for long-term impacts to the size, integrity, continuity, and ultimate
viability of the plant communities from nonnative species introduction or spread would be
limited by the nonnative species control programs in the Park. Therefore, impacts of activities
directly related to detection and assessment would have short-term, negligible to minor, adverse
impacts on vegetation. As described for Alternative A, deer dispersal during these types of
actions would not increase impacts to vegetation outside the Park.
As described in the impacts analysis for white-tailed deer, enhanced opportunistic and targeted
surveillance would have little effect on deer densities. This would also hold true for enhanced
live testing, which would only result in deer being removed if positive results are received.
However, lethal removal of healthy deer if used for detection and/or assessment would reduce
deer densities in certain areas (e.g., Big Meadows, Skyland, Skyline Drive) of the Park. Reduced
browsing pressure associated with lower deer densities would decrease potential impacts to
understory plants (shrubs and herbaceous species) that provide deer forage in forested and
wetland areas. However, potential benefits on the regeneration of tree and shrub species, as well
as forest community structure, would not be realized during the life of this plan (10 years).
Although the deer population may increase after lethal removals (from initial increased
productivity), additional possible assessments could maintain a lower deer density when
compared to Alternative A. Therefore, reduced deer browsing as a result of lower deer densities
would be expected to have long-term beneficial effects on vegetation.
Cumulative Impacts
The same past, present, and future impacts from cumulative actions described for Alternative A
would occur under Alternative B. Detection and assessment actions under Alternative B would
have negligible to minor contributions to adverse cumulative impacts on vegetation, but changes
in density associated with lethal removal of deer would have long-term beneficial effects.
Coupled with other cumulative impacts to vegetation, long-term, minor to moderate, adverse
effects would occur (localized impacts would cause perceptible if not measurable changes, but
would not affect the overall viability of the vegetative communities).
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Conclusion
Detection and assessment actions would have short-term, negligible to minor, adverse impacts on
vegetation from temporary disturbances during implementation. After implementation,
reductions in deer density from lethal removal of deer for CWD detection and/or assessment
would have long-term beneficial effects (e.g. reduced herbivory). Cumulative impacts on
vegetation would be long-term, minor to moderate, and adverse. Detection and assessment
actions under Alternative B, including benefits from reduced deer densities in certain areas of the
Park, would contribute minimally to these effects.
Alternative C: Enhanced Detection and Assessment but No Lethal Removal for Testing
Specific Impacts to Vegetation
Detection and assessment actions described under Alternative B – enhanced opportunistic and
targeted surveillance and live testing – would also be available under Alternative C; however,
this alternative would not involve lethal removal of healthy appearing deer for CWD testing for
detection or assessment. As described for alternatives A and B, these activities would result in
effects on vegetation similar to those associated with routine field work conducted in the Park
and would include temporary reductions in vegetation in small areas from trampling and the
potential for the inadvertent introduction or spread of nonnative plant species in the Park.
As with Alternative B, detection and assessment activities would result in perceptible impacts to
shrub and herbaceous species in forest and wetland areas. However, native plant communities
would remain viable, vegetation affected by trampling would recover if left alone, and there
would be few or no impacts to native vegetation from carcasses left to decompose on the
landscape. The potential for long-term impacts to the size, integrity, continuity, and ultimate
viability of these plant communities from nonnative species introduction or spread would be
limited by the nonnative species control programs in the Park. Therefore, impacts of activities
directly related to CWD detection and assessment would have short-term, negligible to minor,
adverse impacts on vegetation. As with Alternative A, deer dispersal during these types of
actions would not increase impacts to vegetation outside the Park as a result of deer being
dispersed.
As described in the impacts analysis for white-tailed deer, enhanced opportunistic and targeted
surveillance would have little effect on deer densities unless CWD effects reduced the number of
deer through death. This would also hold true for enhanced live testing, which would only result
in deer being removed if positive results are received. Compared to Alternative A there is the
potential for slightly more deer to be removed because of enhanced detection and assessment
actions. Compared to Alternative B, there would be much fewer deer removed. Therefore,
browsing in areas with higher population densities would continue to have measurable effects on
the diversity and abundance of understory shrubs and grasses found in forested and wetland
areas. Therefore, the CWD surveillance actions that would occur under Alternative C are similar
to Alternative A and would not result in any effects to the existing conditions.
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Cumulative Impacts
The same past, present, and future impacts from cumulative actions described for Alternative A
would also occur under Alternative C. Detection and assessment actions under Alternative C
would have negligible to minor contributions to cumulative impacts on vegetation. Very limited
changes in deer density associated with enhanced detection and assessment would have
negligible effects. Considering other cumulative impacts to vegetation, long-term, moderate,
adverse effects would occur (localized impacts would cause measurable changes).
Conclusion
Enhanced detection and assessment actions would have short-term, negligible to minor, adverse
impacts on vegetation from temporary disturbances during implementation. Cumulative impacts
on vegetation would be long-term, moderate, and adverse. Detection and assessment actions
under Alternative C would contribute minimally to cumulative impacts.
Other Wildlife
The evaluation of wildlife (other than deer) was based on available information on the wildlife
species in the Park and their habitat and was compiled and analyzed in relation to the
management action. The thresholds for the intensity of an impact are defined as follows:
Negligible:
Minor:
Moderate:
Major:
There would be no observable or measurable impacts to native species, their
habitats, or the natural processes sustaining them. Impacts would be well within
natural fluctuations.
Impacts would be detectable, but would not be outside the natural range of
variability. Small changes to population numbers, population structure, genetic
variability, and other demographic factors might occur. Occasional responses to
disturbance by some individuals could be expected, but without interference to
factors affecting population levels. Sufficient habitat would remain functional to
maintain viability of all species. Impacts would be outside critical reproduction
periods for sensitive native species.
Impacts on native species, their habitats, or the natural processes sustaining them
would be detectable and could be outside the natural range of variability. Changes
to population numbers, population structure, genetic variability, and other
demographic factors would occur, but species would remain stable and viable.
Frequent responses to disturbance by some individuals could be expected, with
some negative impacts to factors affecting population levels. Sufficient habitat
would remain functional to maintain the viability of all native species. Some
impacts might occur during critical periods of reproduction or in key habitat.
Impacts on native species, their habitats, or the natural processes sustaining them
would be detectable, would be expected to be outside the natural range of
variability, and would be permanent. Population numbers, population structure,
genetic variability, and other demographic factors might experience large
declines. Frequent responses to disturbance by some individuals would be
expected, with negative impacts to factors resulting in a decrease in population
levels. Loss of habitat might affect the viability of at least some native species.
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Area of Analysis
The area of analysis for assessing impacts on other wildlife is the area contained within the
boundary of the Park.
Impacts of the Alternatives
Alternative A: No Action (Continue Current Actions)
Specific Impacts to Other Wildlife
Continued opportunistic and targeted surveillance activities and possibly live testing under
Alternative A would result in limited impacts to wildlife and wildlife habitat. There would be
indirect effects such as occasional trampling of soils and ground vegetation and inadvertent
spread of nonnative plant seeds by staff involved in these actions. Trampling and nonnative seed
spread could also occur during the periodic removal of deer carcasses found dead or lethally
removed as part of targeted surveillance. The spread of nonnative plants could cause changes in
diversity or abundance of native plants, which would have perceptible effects on native plant
communities and the quality and type of wildlife habitat in the Park. The potential for long-term
impacts to the size, integrity, continuity, and ultimate viability of these plant communities would
be limited by exotic species control programs. As described in impacts analysis for vegetation,
mostly herbaceous and short woody plants would be affected, which could temporarily disturb
wildlife that are ground, herbaceous layer, and shrub dwellers such as mice and screws, rabbits,
and foxes, as well as ground/shrub-nesting birds. Surveillance could occur during the growing
season, and there would be a perceptible reduction in vegetation in small areas where trampling
occurs. Trampling could also affect small burrows used by mice, shrews, and voles. These
indirect impacts would be temporary, and if left alone, habitat would recover and there would be
no long-term, measurable consequences to the overall wildlife community.
The presence of people could also directly disturb wildlife, and the use of firearms for targeted
surveillance would cause short-term noise disturbance and result in mobile wildlife dispersing
from the area. Impacts related to noise are usually temporary, with wildlife avoiding or moving
away from the source but returning after noise is reduced or eliminated. In addition, carrion
eaters (e.g., fox, raptors) would benefit from the availability of CWD negative carcasses left to
decompose on the landscape. These direct effects would not have measurable, long-term
population level impacts, and any changes in movement as a result of surveillance activities
would be within the range of natural variation.
Considering these effects, actions directly related to opportunistic and targeted surveillance
would have short-term, negligible to minor, adverse impacts on wildlife and wildlife habitat.
Impacts would be detectable on a small scale (i.e., when standing over it), but would not be
outside the natural range of variability. Occasional responses to disturbance by some individuals
could be expected but without interference to factors affecting population levels, sufficient
habitat would remain functional to maintain viability of all species. Should CWD be detected in
or near the Park, opportunistic and targeted surveillance may increase, which could increase the
frequency of impacts that result from these actions; however, these impacts would remain shortterm and would not affect the overall viability of any wildlife species or habitat.
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As described in the impacts analysis for white-tailed deer, there would be minimal change in
deer density under Alternative A, unless CWD effects reduced the number of deer through death.
Sustained browsing at high population densities would continue to have measurable effects on
the diversity and abundance of understory shrubs and grasses found in some areas of the Park
(e.g., Skyland Drive, Big Meadows), and the CWD surveillance actions that would occur under
Alternative A would not result in any long-term effects to existing wildlife habitat conditions.
Cumulative Impacts
Adverse cumulative effects on wildlife and wildlife habitat would include loss and fragmentation
of habitat from past clear cutting of forests, herbivory, fire, and highway expansion.
Development within and around the Park, including private activities, also contributes to these
effects, and future growth expected in communities around the Park is expected to continue to
reduce the amount of natural wildlife habitat. Future impacts also include road
construction/maintenance, rock outcrop management, site rehabilitation and continued deer
herbivory. Actions directly related to surveillance under Alternative A would have negligible
contributions to overall cumulative impacts on wildlife and habitat. Overall cumulative impacts
on wildlife and wildlife habitat would be long-term, negligible to minor, and adverse, primarily
due to the effects of continued herbivory and Park maintenance/development.
Conclusion
Actions directly associated with opportunistic and targeted surveillance and potentially live
testing would have short-term, negligible, adverse impacts on wildlife and wildlife habitat,
mainly from temporary disturbances and trampling during implementation. Potential short-term,
negligible to minor, beneficial impacts would occur for carrion eaters from the possible
availability of CWD negative carcasses on the landscape. Sustained deer browsing in areas of the
Park with high population densities (e.g. Big Meadows) would continue to contribute
substantially to long-term adverse effects on wildlife and wildlife habitat in these areas as a
result of impacts on diversity and abundance of understory shrubs and grasses. In addition,
prescribed burns (a possible management action) would have short-term adverse impacts
(including associated field activities), there would be beneficial effects on wildlife habitat from
nutrient release (short-term), regrowth of mostly native plants/shrubs (long-term), and by the
creation of beneficial forest gaps (long-term).
Cumulative impacts on wildlife and wildlife habitat would be long-term, negligible to minor, and
adverse. Surveillance actions under Alternative A would contribute minimally to these effects.
Alternative B: Enhanced Detection and Assessment, Including Lethal Removal for Testing
Specific Impacts to Other Wildlife
Under Alternative B, enhanced opportunistic and targeted surveillance would be used for CWD
detection and could be supplemented with enhanced live testing and lethal removal of healthy
appearing deer for CWD testing under specific criteria. As described for Alternative A, some
wildlife would be affected by direct disturbance and possible availability of additional food
resources (i.e., carrion eaters). Indirect effects would occur to wildlife habitat from these
detection activities, including temporary impacts to vegetation and soils/ground cover in small
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areas from trampling and possible spread of nonnative seeds. Lethal removal of healthy
appearing deer for testing would involve a much larger, more sustained effort than enhanced
targeted surveillance and the vegetation and associated habitat and noise impacts would likely
occur in more areas of the Park and more frequently.
All of these options would also be available as CWD assessment tools should the disease be
detected within five miles of the Park, although the focus of lethal removals would shift from
detection to assessment. These assessment actions would have the same impacts as detection and
would cause the most impacts directly and indirectly to wildlife because it is the largest effort in
terms of scope.
The effects of detection and assessment activities would result in slight but perceptible impacts
to shrubby and herbaceous species in forested and wetland areas and create temporary noise
disturbance to species that use these areas for nesting, food, and cover (e.g., rabbits, foxes, mice,
and ground-nesting birds). Any CWD negative carcasses left on the landscape would provide
food for species that eat carrion.
Wildlife could also be temporarily disturbed by the presence of humans placing bait stations and
shooting deer (activities that typically occur most often outside of the Park). These disturbances
would be adverse, but temporary and negligible to minor, as they would not cause any
measurable change to the habitat or responses by other wildlife species. Bait could provide a
beneficial food source to other wildlife during the time when testing activities are conducted;
however, the small quantity and short time periods that bait would be available would be of
minimal benefit to any species at the population level.
As described in the impacts analysis for white-tailed deer, enhanced opportunistic and targeted
surveillance and enhanced live testing would have little effect on deer densities. However, lethal
removal of healthy deer for detection and assessment could reduce deer densities in some parts
of the Park (Skyline Drive, Big Meadows) which would lead to reduced deer browsing on
understory shrubs and herbaceous species that provide wildlife habitat. This would increase the
availability of food and cover for species that depend on ground/shrub layer vegetation for
survival. Species such as ground- and/or shrub-nesting birds and some mammals (rabbits, mice)
could benefit from these changes. Although the deer population may increase after lethal
removals (due to increased productivity), subsequent assessment actions (where CWD is zero to
five miles away) would maintain a lower deer density when compared to Alternative A.
Therefore, reduced deer browsing and grazing pressure from lower deer densities would have
long-term beneficial effects on wildlife.
Predators that use deer as an occasional food source, such as coyotes, could be somewhat
adversely affected by the reduced deer density and denser understory conditions in some parts of
the Park. Other animals that feed on deer carcasses, such as crows and turkey vultures, could also
be affected, both beneficially from the carcasses that are not immediately removed, as well as
adversely in the longer term from the reduced number of deer. However, none of these species
solely depend on deer as a food source, so the adverse impacts to these species would be longterm and minor at most.
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Cumulative Impacts
The same past, present, and future impacts from cumulative actions described for Alternative A
would occur under Alternative B. Detection and assessment actions under Alternative B would
have negligible to minor contributions to cumulative impacts on wildlife and wildlife habitat, and
changes in density associated with lethal removal of deer would have long-term beneficial
effects. Coupled with other cumulative impacts, long-term, minor, adverse effects would still
occur to wildlife and wildlife habitat in and around the Park.
Conclusion
Detection and initial response actions would have short-term, negligible to minor, adverse
impacts on wildlife and wildlife habitat from temporary disturbances during implementation.
After implementation, reductions in deer density from lethal removal of deer for CWD detection
and/or assessment would have long-term beneficial effects. Cumulative impacts on wildlife and
wildlife habitat would be long term, minor, and adverse, and detection and assessment actions
under Alternative B would contribute minimally to these effects.
Alternative C: Enhanced Detection and Assessment but No Lethal Removal for Testing
Specific Impacts to Other Wildlife
Detection and assessment actions described under Alternative B—enhanced opportunistic and
targeted surveillance and enhanced live testing would also be available under Alternative C.
Impacts of this alternative are more similar to Alternative A, since this alternative does not
include lethal removal of healthy appearing deer for CWD detection or assessment. Impacts to
wildlife and wildlife habitat would be more than in Alternative A because detection and
assessment would be enhanced but much less than described in Alternative B. Indirect effects
include occasional trampling of soils and ground vegetation and inadvertent spread of nonnative
plant seeds. The spread of nonnative plants would be limited by exotic plant species control
programs. Wildlife that are ground, herbaceous layer, and shrub dwellers, as well as groundnesting birds, would be temporarily disturbed. These indirect impacts would be temporary, and if
left alone, habitat would recover and there would be no long-term, measurable consequences to
the overall wildlife community.
Direct effects include temporary disturbance from people and noise that may result in wildlife
dispersing from the area. Carrion eaters would benefit from the availability of CWD negative
carcasses left to decompose on the landscape. These direct effects would not have measurable,
long-term population level impacts and any changes in movement as a result of surveillance
activities would be within the range of natural variation.
Actions directly related to enhanced opportunistic and targeted surveillance and live testing
would have short-term, negligible to minor, adverse impacts on wildlife and wildlife habitat.
Impacts would be detectable, but would be within the natural range of variability.
There would be minimal change in deer density unless CWD effects reduced the number of deer
through death. Sustained browsing at high population densities would continue in some areas of
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the Park and the CWD surveillance actions that would occur under Alternative C would not
result in any long-term effects to existing wildlife habitat conditions.
Cumulative Impacts
The same past, present, and future impacts from cumulative actions described for Alternative A
would also occur under Alternative C. Detection and assessment actions under Alternative C
would have negligible to minor contributions to cumulative impacts on wildlife and habitat.
Overall cumulative impacts on wildlife and wildlife habitat would be long-term, negligible to
minor, and adverse, primarily due to the effects of continued deer herbivory and Park
maintenance/development.
Conclusion
Actions directly associated with enhanced opportunistic and targeted surveillance and enhanced
live testing would have short-term, negligible to minor, adverse impacts on wildlife and wildlife
habitat, mainly from temporary disturbances and trampling during implementation. Some
minimal benefits would occur for carrion eaters from the possible availability of CWD negative
carcasses on the landscape. Sustained deer browsing in areas of the Park with high population
densities (e.g., Skyline Drive, Big Meadows) would continue to contribute substantially to longterm adverse effects on wildlife and wildlife habitat in these areas as a result of impacts on
diversity and abundance of understory shrubs and plants. In addition, although fire management
would have short-term adverse impacts from prescribed burns (including associated field
activities), there would be long-term beneficial effects on wildlife habitat from regrowth of
mostly native plants and the creation of canopy gaps in the forest. Cumulative impacts on
wildlife and wildlife habitat would be long-term, negligible to minor, and adverse. Surveillance
actions under Alternative C would contribute minimally to these effects.
State-listed Plant Species
The Park has two state listed plant species and numerous rare plant species that could be affected
if CWD testing changed the number of deer that browse on vegetation in a particular area. Big
Meadows Area contains examples of 18% of the Park’s rare plant populations and has the
highest density of deer. The thresholds for the intensity of an impact are defined as follows:
Negligible
Minor
Moderate
Major
Impacts would result in no measurable or perceptible changes to a population or
individuals of a species or its habitat.
Impacts would result in measurable or perceptible changes to individuals of a
species, a population, or its habitat, but would be localized within a relatively
small area. The overall viability of the species would not be affected.
Impacts would result in measurable and or consequential changes to individuals
of a species, a population, or its habitat; however, the impact would remain
relatively localized. The viability of the species would be affected, but the species
would not be permanently lost.
Impacts would result in measurable and/or consequential changes to a large
number of individuals of a species or a population or a large area of its habitat.
These changes would be substantial, highly noticeable, and permanent, occurring
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over a widespread geographic area, resulting in a loss of species viability and
potential extirpation from the Park.
Area of Analysis
The area of analysis for assessing impacts on state-listed plant species is the area contained
within the boundary of the Park.
Impacts of the Alternatives
Alternative A: No Action (Continue Current Actions)
Specific Impacts to State-listed Plant Species
Continued opportunistic and targeted surveillance and possibly live testing conducted when deer
are captured and collared for other projects under Alternative A would result in limited impacts
to state-listed plant species. Trampling of a state listed plant species by people during the
removal of deer carcasses found dead or lethally removed as part of targeted surveillance could
potentially occur. People and vehicles associated with surveillance actions could inadvertently
transport nonnative plant seeds which could increase competition for a listed plant species. The
potential for long-term impacts to the size, integrity, continuity, and ultimate viability of these
plant communities would be limited by nonnative species control programs in the Park. In
addition, the potential for deer to browse a listed plant species would not be expected to change.
Considering these effects, actions directly related to opportunistic and targeted surveillance and
live testing would have short-term, negligible to minor, adverse impacts on state-listed plant
species. Should CWD be detected in or near the Park, opportunistic and targeted surveillance
would likely increase, which could increase the frequency of impacts that result from these
actions; however, these impacts would remain short-term and would not affect the overall
viability of a listed species.
As described in the impacts analysis for white-tailed deer, there would be minimal change in
deer density under Alternative A, unless CWD effects reduced the number of deer through death.
This would also be true for live-testing, which would only result in deer being removed if
positive test results are received. Areas of the Park with higher population densities (Big
Meadows Area, Skyline Drive) would have a higher likelihood for potential browsing of a listed
species.
Cumulative Impacts
Adverse cumulative effects on state-listed plant species include past land use, exotic species,
development, and deer browsing. In addition, fires, tropical storms, ice, and impacts from ozone
and acid precipitation deposition continue to adversely affect listed plant species. Current and
past Park operations such as mowing; burning; vegetative rehabilitation (e.g., Skyline Drive,
Panorama); and road, trail and campsite maintenance have also altered vegetative cover. Future
Park actions associated with increased development and rehabilitation will change vegetative
communities in some areas; however, listed plant communities would be avoided. All of these
actions would be expected to result in some plant loss into the future.
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Although fire management would have short-term adverse impacts from prescribed burns
(including associated field activities), there may be long-term beneficial effects on vegetation
from regrowth of mostly native plants and the creation of canopy gaps in the forest. In light of
the adverse and beneficial effects from past, present, and reasonably foreseeable future actions,
cumulative impacts on state-listed plant species in the Park would be long-term, minor, and
adverse. Actions directly related to surveillance under Alternative A would have negligible to
minor contributions to these impacts on state-listed plant species.
Conclusion
Actions associated with opportunistic and targeted surveillance and live testing would have
short-term, negligible to minor, adverse impacts on state-listed plant species from potential
trampling and spread of nonnative plant species. Because these surveillance efforts would not
measurably affect deer densities across the Park, CWD surveillance actions that would occur
under Alternative A would not result in any indirect effects (i.e., reduced herbivory) to existing
state-listed species. Cumulative impacts on state-listed plant species would be long-term, minor,
and adverse; however, surveillance actions under Alternative A would contribute minimally to
these effects.
Alternative B: Enhanced Detection and Assessment, Including Lethal Removal for Testing
Specific Impacts to State-listed Plant Species
Under Alternative B, enhanced opportunistic and targeted surveillance would be used for CWD
detection and could be supplemented with live testing and lethal removal of healthy appearing
deer for CWD testing under specific criteria. Effects on state-listed plant species during
opportunistic and targeted surveillance and live testing, even when enhanced, would be similar to
those associated with routine field work conducted in the Park (and similar to Alternatives A and
C). This would include the potential for trampling and spread of nonnative plant species.
Lethal removal of healthy appearing deer for detection testing (where a CWD positive is five-30
miles from Park) would involve a larger, more sustained effort (a maximum sample of 300 deer
could be removed over three years). Should the disease be detected within five miles of the Park,
the focus of lethal removals would shift from detection to assessment. Lethal removals for
assessment purposes would involve removing the Park's portion of samples (up to 69 deer for
one positive CWD case within five miles from the Park – Appendix B) in one year. These lethal
removal actions (along with live-testing and enhanced opportunistic sampling, etc.) would have
the same impacts on state-listed plants whether in a detection mode or in an assessment mode.
The direct effects on state-listed species would be the same (trampling, spread of nonnative
plants), but would likely occur in more parts of the Park and more frequently. The potential for
long-term impacts to the size, integrity, continuity, and ultimate viability of the plant
communities from nonnative species introduction or spread would be limited by the nonnative
species control programs in the Park.
This alternative would have the most potential for indirect impacts to state-listed species because
it is the largest effort in terms of scope. Lethal removal of healthy deer if used for detection
and/or assessment would reduce deer densities in certain areas (e.g., Big Meadows Area, Skyline
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Drive) of the Park. Lower deer densities would decrease potential browsing impacts to listed
plant species. Therefore, impacts of activities directly related to detection and assessment would
have short-term, negligible to minor adverse impacts on state-listed species. Although the deer
population may eventually increase after lethal removals (due to increased productivity),
subsequent assessment activities would potentially maintain a lower deer density in these Park
areas when compared to Alternative A. Therefore, reduced deer browsing from lower deer
densities would be expected to have long-term beneficial effects on threatened and endangered
plant species.
Cumulative Impacts
The same past, present, and future impacts from cumulative actions described for Alternative A
would occur under Alternative B. Detection and assessment actions under Alternative B would
have negligible to minor contributions to adverse cumulative impacts on threatened and
endangered species, but changes in deer density associated with lethal removal of deer would
have long-term beneficial effects. Coupled with other cumulative impacts to threatened and
endangered species, the long-term, minor, adverse effects may be offset by the reduced potential
for browsing.
Conclusion
Detection and assessment actions would have short-term, negligible to minor, adverse impacts on
state-listed plant species from potential trampling and potential spread of nonnative plant seeds.
After implementation, reductions in deer density from lethal removal of deer for CWD detection
and/or assessment would have long-term beneficial effects (e.g. reduced herbivory). Cumulative
impacts on state-listed species would be long-term, minor, and adverse. Detection and
assessment actions under Alternative B, including benefits from reduced deer densities in certain
areas of the Park, would contribute minimally to these effects.
Alternative C: Enhanced Detection and Assessment but No Lethal Removal for Testing
Specific Impacts to State-listed Plant Species
Detection and assessment actions described under Alternative B—enhanced opportunistic and
targeted surveillance and live-testing would also be available under Alternative C; however, this
alternative would not involve lethal removal of healthy appearing deer for CWD testing for
detection or assessment. As described for alternatives A and B, these activities would result in
effects on state-listed plant species similar to those associated with routine field work conducted
in the Park and would include potential trampling and the potential for the inadvertent
introduction or spread of nonnative plant species in the Park. The potential for long-term impacts
to the size, integrity, continuity, and ultimate viability of these listed plant communities from
nonnative species introduction or spread would be limited by the nonnative plant species control
program in the Park. Therefore, impacts of activities directly related to CWD detection and
assessment would have short-term, negligible to minor, adverse impacts on state-listed plant
species.
As described in the impacts analysis for white-tailed deer, enhanced opportunistic and targeted
surveillance would have little effect on deer densities unless CWD effects reduced the number of
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deer through death. This would also hold true for enhanced live testing, which would only result
in deer being removed if positive results are received. Compared to Alternative A, there is the
potential for slightly more deer to be removed because of enhanced detection and assessment
actions. Compared to Alternative B, there would be much fewer deer removed. Therefore, areas
of the Park with higher deer densities (Big Meadows Area, Skyline Drive) would continue to
have a greater potential for browsing impacts on state-listed vegetation. Therefore, the CWD
detection and assessment actions that would occur under Alternative C are fairly similar to
Alternative A and would not result in any effects to the existing conditions.
Cumulative Impacts
The same past, present, and future impacts from cumulative actions described for Alternative A
would also occur under Alternative C. Detection and assessment actions under Alternative C
would have negligible to minor contributions to cumulative impacts on state-listed plant species.
Very limited changes in deer density associated with enhanced detection and assessment would
have negligible effects. Considering other cumulative impacts to listed plant species, long-term,
minor, adverse effects would occur.
Conclusion
Enhanced detection and assessment actions which do not include lethal removals would have
short-term, negligible to minor, adverse impacts on state-listed plant species from trampling and
potential spread of nonnative plant seed during implementation. Cumulative impacts on statelisted species would be long-term, minor, and adverse. Detection and assessment actions under
Alternative C would contribute minimally to cumulative impacts.
Socioeconomics
Options for CWD detection and assessment could affect deer populations both within and
outside the Park with associated impacts on hunting (loss of sustenance-based hunting
opportunities and hunting-related tourism) and Park visitation, which contribute to the local
economy. The focus of this overview is the area immediately surrounding the Park. Impact
threshold definitions for socioeconomic conditions focus on possible loss of revenues to the
Park, surrounding towns, local businesses, and lost local hunting opportunities and were defined
as follows:
Negligible:
Minor:
Moderate:
No effects would occur, or the effects on neighboring landowners, sustenancebased hunters, businesses, towns, or other socioeconomic conditions would be
below or at the level of detection.
The effects on neighboring landowners, sustenance-based hunters, businesses,
towns or other socioeconomic conditions would be small but detectable. The
impact would be slight, but would not be detectable outside the neighboring lands
and would affect only a few adjacent landowners.
The effects on neighboring landowners, sustenance-based hunters, businesses,
towns or other socioeconomic conditions would be readily apparent. Changes in
economic or social conditions would be limited and confined locally, and they
would affect more than a few landowners, local hunters, or businesses.
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The effects on neighboring landowners, sustenance-based hunters, businesses,
towns, or other socioeconomic conditions would be readily apparent. Changes in
social or economic conditions would be substantial, extend beyond the local area,
and affect the majority of landowners, local hunters, and businesses.
Area of Analysis
The area of analysis includes the Park and the surrounding area within 5 miles of the boundaries.
Impacts of the Alternatives
Alternative A: No Action (Continue Current Actions)
Specific Impacts to Socioeconomics
Given the limited number of deer expected to be taken by continued opportunistic and targeted
surveillance and possibly live testing under Alternative A, there would be few impacts to
regional socioeconomic resources. As described in the impacts analyses for deer and vegetation,
there would be minimal change in existing deer density due to actions taken under Alternative A
unless CWD drastically reduced survival rates. Sustained browsing in areas of the Park with high
population densities (Big Meadows, Skyline Drive) would continue to have measurable effects
on surrounding vegetation in those areas. These areas, however, have no nearby private lands.
The CWD surveillance actions that would occur under Alternative A would not result in any
change to the existing conditions.
Should CWD be detected in or near the Park, opportunistic and targeted surveillance and
possibly live-testing may increase, but increasing these activities would only have limited effects
on minimizing the potential for CWD amplification and spread. Therefore, if CWD is detected in
or near the Park the potential for the establishment of CWD and possible exposure to population
level effects for deer would be high. If CWD becomes prevalent in the deer populations of the
Park and nearby lands, it is uncertain whether deer densities would decrease or if the herd would
initially decrease and then stabilize at an endemic level. If CWD has population effects on deer,
this could possibly influence hunting-related tourism or sustenance-based hunting by reducing
the number of animals available to hunt or making it less desirable to hunt. Impacts would likely
be long-term, minor, and adverse to the local economy immediately surrounding the Park from
these effects. However, the exact nature and level of impact would depend on what actions the
state has taken in the communities surrounding the Park in response to the presence of CWD.
Population level impacts to deer from CWD could have an adverse impact on visitor experience
from potentially fewer deer seen and an increase in the number of dead or sick deer observed.
The presence of CWD could deter visitation in the Park and in the surrounding communities, if
the disease and its health implications were not fully understood. Public information and
outreach would help mitigate adverse perceptions; however, impacts related to tourism could
range from negligible impacts to long-term, minor, adverse effects.
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Cumulative Impacts
Actions that have contributed to long-term beneficial cumulative effects on socioeconomic
resources include increased wildlife viewing opportunities, designation of Skyline Drive as
National Scenic Byway, Main Street planning in gateway communities, enhanced partnerships to
obtain marketing grants to increase tourism, migration of bedroom communities from
Washington, DC, and reduction of rights-of-way into the Park. Hunting also contributes
beneficially to the cumulative impact on local socioeconomic resources, with deer hunting in
Virginia generating over $250 million annually. Actions that contribute adverse impacts to the
local socioeconomic resources include migration of some industries out of gateway communities,
loss of agricultural land use, and wildlife-related crop damage.
Alternative A would contribute long-term, negligible to minor, adverse impacts to the
socioeconomic resource. Despite this and adverse impacts from other past, present, and future
actions, they would not be enough to outweigh the benefits provided by development in the local
area and the economic contributions of the Park. Therefore, the overall cumulative impacts on
the local socioeconomic resources would be long-term and beneficial.
Conclusion
Actions associated with opportunistic and targeted surveillance and possibly live-testing would
have long-term, negligible to minor, adverse impacts on socioeconomics. CWD surveillance
actions that would occur under Alternative A would not result in any changes to the existing
socioeconomic conditions, and adverse impacts resulting from deer-related crop damage would
continue. Because Alternative A would have minimal effects on CWD risk factors allowing the
potential for amplification, spread, and establishment, as well as exposure to possible population
level effects to remain high, there could be negligible to minor, adverse impacts to hunting and
tourism due to changes in deer numbers and/or the presence of the disease. However, the exact
nature and level of impact would depend on what actions the state has taken in the communities
surrounding the Park in response to the presence of CWD. Overall cumulative impacts on the
local socioeconomic resources would be long-term and beneficial.
Alternative B: Enhanced Detection and Assessment, Including Lethal Removal for Testing
Specific Impacts to Socioeconomics
Under Alternative B, enhanced opportunistic and targeted surveillance would be used for CWD
detection, and could be supplemented with live testing and lethal removal of healthy appearing
deer for CWD testing under specific criteria. Impacts from opportunistic and targeted
surveillance even when enhanced would be similar to those under Alternative A with long-term,
negligible to minor, adverse impacts.
Lethal removal of healthy appearing deer as a detection method would involve a larger, more
sustained effort (a maximum of 300 deer could be removed over three years). For assessment, a
maximum of 69 deer would be removed per detection (when found zero to five miles from the
Park). These actions would be conducted over a one- to three-year period and could reduce the
deer densities in some areas of the Park. If lethal removal of deer within the Park is conducted
during the normal operating hours, some areas would be closed to visitors for their safety. The
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public would be notified of the closures ahead of time. Depending on the number and location of
the closures at any given time, some visitors may avoid going to the Park on the days of the
closures. Impacts due to closures would be temporary and would not likely deter people from
visiting the Park at another time. However, as described under Alternative A, some visitors may
stay away because of the presence of the disease. Public information and outreach would be used
to help mitigate this situation. Therefore, the impact from the change in visitor use on
socioeconomics would range from short to long-term, negligible to minor, and adverse.
Lower densities of deer could have short-term minor adverse impacts on hunting outside the Park
by potentially reducing the number of deer available to hunters. The nature and level of this
impact would depend on what actions the state has taken in response to the presence of CWD,
and the effect of CWD itself on hunting in the area. As discussed in the analysis for white-tailed
deer, Alternative B could result in lower deer densities in some areas of the Park (Big Meadows,
Skyline Drive) when compared to Alternative A. These areas are not near farmable private land,
so there would be no reduction in the amount of deer-related damage to crops in the areas
surrounding the Park. Should assessment activities help preclude CWD from becoming
established, this could possibly offset potential losses in sustenance-based hunting opportunities
or hunting-related tourism described for Alternative A. As a result, there would be long-term
beneficial effects on socioeconomics under Alternative B. Relatively minor beneficial effects
could also occur as a result of the potential for hiring deer removal contractors that would spend
money in local communities; the potential to donate deer meat; and the potential expenditures
associated with disposal activities.
Cumulative Impacts
The same past, present, and future adverse and beneficial impacts from cumulative actions
described under Alternative A would also occur under Alternative B. Actions taken under
Alternative B contribute both adverse and beneficial impacts to the socioeconomic resource.
Adverse impacts resulting from actions taken under Alternative B and adverse impacts from
other past, present, and future actions would not be enough to outweigh the benefits provided by
development in the local area and the economic contributions of the Park. Therefore, the overall
cumulative impacts on the local socioeconomic resources would be long-term and beneficial.
Conclusion
Actions taken under Alternative B would result in short-term, negligible to minor, adverse
impacts to the socioeconomic resource with the level of adverse impacts dependent upon the
perceptions of visitors and hunters, the number of deer potentially affected by CWD, and the
actions the state has taken in the communities surrounding the Park in response to CWD.
Long-term beneficial effects could occur primarily if CWD is precluded from becoming
established, offsetting potential reductions in sustenance-based hunting and hunting-related
tourism, and as a result of reduced deer damage to crops in the areas surrounding the Park due to
lower deer densities. Overall cumulative impacts would be long-term and beneficial.
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Alternative C: Enhanced Detection and Assessment but No Lethal Removal for Testing
Specific Impacts to Socioeconomics
Detection and assessment activities under Alternative C would be the same as those described
under Alternative B—enhanced opportunistic and targeted surveillance and enhanced livetesting. Alternative C, however, would not involve lethal removal of healthy appearing deer for
CWD testing and assessment. Impacts from opportunistic surveillance, targeted surveillance, and
live-testing even when enhanced would be similar to those under Alternative A with long-term,
negligible to minor, adverse impacts. Detection or assessment activities in the Park would have
negligible to minor, adverse effects on sustenance-based hunting opportunities and huntingrelated tourism due to the low number of deer tested. Deer densities in the Park would not be
expected to change. The nature and level of this impact would depend on what actions the state
has taken in the communities surrounding the Park in response to the presence of CWD and the
effect of the disease itself.
Detection and assessment activities would not likely preclude CWD from becoming established,
therefore, there would not be any potential offset of losses in sustenance-based hunting
opportunities or hunting-related tourism as described for Alternative B. Impacts would likely be
long-term, minor, and adverse to the local economy immediately surrounding the Park from
these effects.
The presence of CWD could deter visitation in the Park and in the surrounding communities if
the disease and its health implications were not fully understood. Public information and
outreach would help mitigate adverse perceptions; however, impacts related to tourism could
range from negligible impacts to long-term, minor, adverse effects.
Cumulative Impacts
The same past, present, and future beneficial and adverse impacts from cumulative actions
described for alternatives A and B would also occur under Alternative C. The adverse impacts
resulting from actions taken under Alternative B and adverse impacts from other past, present
and future actions would not be enough to outweigh the benefits provided by development in the
local area and the economic contributions of the Park. Therefore, the overall cumulative impacts
on the local socioeconomic resources would be long-term and beneficial.
Conclusion
CWD surveillance actions that would occur under Alternative C would not result in changes to
the existing socioeconomic conditions, and adverse impacts resulting from deer-related crop
damage would continue. Because Alternative A would have minimal effects on CWD risk
factors allowing the potential for amplification, spread, and establishment, as well as exposure to
possible population level effects to remain high, there could be negligible to minor, adverse
impacts to hunting (and sustenance-based hunting) and tourism due to changes in deer numbers
and/or the presence of the disease. However, the exact nature and level of impact would depend
on what actions the state has taken in the communities surrounding the Park in response to the
presence of CWD. Actions taken under Alternative C would result in short-term, negligible to
minor, adverse impacts to the socioeconomic resource with the level of adverse impacts
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dependent upon the perceptions of visitors and hunters, the number of deer potentially affected
by CWD, and the actions the state has taken in the communities surrounding the Park in response
to CWD. Overall cumulative impacts on the local socioeconomic resources would be long-term
and beneficial.
Visitor Use and Experience
Several of the potential CWD detection or assessment actions may require limiting access within
the Park. Other actions, including potential lethal removal of deer, could affect visitor experience
in the Park. Past visitor use data, comments from the public, and personal observations of
visitation patterns were used to estimate the effects of the alternative actions on visitors. The
impact on the ability of visitors to experience a full range of Park resources and facilities was
analyzed by examining resources mentioned in the Park’s significance statement and making
assumptions about the likely effects of disease-related detection and assessment on visitation,
assuming that visitation would likely continue to fluctuate, but slowly increase, as it has for the
past 10 years. Beneficial impacts are described but are not assigned intensity levels. Impairment
determinations are not made for visitor use and experience because impairment findings relate
back to Park resources and values and these impact areas are not generally considered to be Park
resources or values and, according to the Organic Act, cannot be impaired in the same way that
an action can impair Park resources and values. The thresholds for the intensity of an impact are
defined as follows:
Negligible:
Minor:
Moderate:
Major:
The impact would be barely detectable and/or would affect few visitors. Visitors
would not likely be aware of the effects associated with management actions.
The impact would be detectable and/or would only affect some visitors. Visitors
would likely be aware of the effects associated with management actions. The
changes in visitor use and experience would be slight but detectable; however,
visitor satisfaction would not be measurably affected.
The impact would be readily apparent and/or would affect many visitors. Visitors
would be aware of the effects associated with management actions. Visitor
satisfaction might be measurably affected (visitors could be either satisfied or
dissatisfied). Some visitors would choose to pursue activities in other available
local or regional areas.
The impact would affect the majority of visitors. Visitors would be highly aware
of the effects associated with management actions. Changes in visitor use and
experience would be readily apparent. Some visitors would choose to pursue
activities in other available local or regional areas.
Area of Analysis
The area of analysis, including cumulative analysis, is the lands within the boundaries of the
Park.
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Impacts of the Alternatives
Alternative A: No Action (Continue Current Actions)
Specific Impacts to Visitor Use and Experience
Under this alternative, opportunistic and targeted surveillance and possibly live testing for CWD
would continue at the Park, and it is expected that the deer populations would stay at relatively
higher levels than outside the Park. About 14 deer per year are removed opportunistically at the
Park while no deer have been removed using targeted surveillance since it was started in 2006.
For this plan, it is assumed that opportunistic surveillance would continue at about its current rate
and about one deer would be taken annually with targeted surveillance. Samples for live CWD
tests would only be taken when deer are being captured and collared in the Park as part of other
projects and would have no impact on visitor use or experience.
Opportunistic surveillance of deer would continue to have a beneficial impact on visitor use and
experience by removing dead deer carcasses visible along road and trail sides. Depending on the
location of a deer exhibiting clinical signs of CWD, sampling deer through targeted surveillance
may require the temporary closure of selected trail areas if sampling were to occur during normal
daytime operating hours. If sampling were to take place during low visitor use periods, very few
closures would be necessary. The sound of gunshots from firearms would temporarily impact the
soundscape of the Park and possibly adjacent neighbors; however, with the assumed removal of
about one deer per year, the number of closures would be minimal and temporary in nature, as
would the number of gunshot sounds. For their safety, visitors at the Park would be informed of
the closures, where they are located, and the reason for closure. Overall, targeted surveillance
actions would have short-term, negligible to minor, adverse impacts on visitor use and
experience. The removal of deer showing clinical signs of CWD would provide some benefits to
visitor experience by helping to prevent visitors from seeing sick deer; however, given the small
number of deer assumed to be removed under this alternative, benefits would be negligible.
Should CWD be detected in or near the Park, opportunistic and targeted surveillance may
increase, which could increase the impacts that result from these actions, but not substantially.
As described under the analysis for white-tailed deer for Alternative A, opportunistic and
targeted surveillance would only have limited effects on minimizing the potential for
amplification and spread of CWD. Therefore, if CWD is detected in or near the Park the
potential for the establishment of CWD and possible exposure to population level effects for deer
would be high. This would likely result in a greater frequency of seeing sick or dead deer and
could adversely affect visitor experience. Therefore, if CWD were to be detected in or near the
Park, impacts to visitor use and experience would be long-term, minor, and adverse.
Cumulative Impacts
Many past, current and future actions, plans, and programs at the Park enhance the visitor’s
experience and contribute to beneficial cumulative effects on visitor use and experience. These
include noise abatement, special interpretive/education programs, recreational opportunities, and
traffic control. There are also some past, current, and future actions that contribute to adverse
cumulative effects on visitor use and experience. These include vandalism and crime, reduced
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maintenance schedules which may allow some facilities to become rundown, and increased
visitation. With increases in visitation also come some crowding and a decrease in satisfaction at
busy times for some Park users. In addition, deer and bear management activities and fire
management may require temporary closures, or in the case of prescribed burning, could
temporarily affect the visual quality in the Park.
Overall, when the adverse impacts of CWD management under Alternative A are considered
with all other actions that affect visitor use and experience, cumulative impacts to visitor use and
experience would be long-term and beneficial.
Conclusion
Actions associated with opportunistic and targeted surveillance and possibly live testing would
have short-term, negligible to minor, adverse impacts on visitor use and experience. If CWD
were to occur in or near the Park, those impacts would increase to minor due to the likely
increase in seeing sick or dead deer. The overall cumulative impacts of all past, present, and
future actions at the Park would be long-term and beneficial.
Alternative B: Enhanced Detection and Assessment, Including Lethal Removal for Testing
Specific Impacts to Visitor Use and Experience
Under Alternative B, enhanced opportunistic and targeted surveillance and enhanced live testing
would be used for CWD detection in addition to lethal removal of healthy appearing deer for
CWD testing under specific criteria. For this plan, it is assumed that under Alternative B more
deer would be taken via enhanced opportunistic surveillance and enhanced targeted surveillance
because of the commitment of more people to these tasks. As described for Alternative A, taking
deer by opportunistic surveillance would be beneficial to visitor experience, as it would remove
dead dear from road sides. The impacts from enhanced targeted surveillance would also be
similar to those under Alternative A, with very few effects if the lethal taking of deer were to
occur during low visitor use periods, and short-term, negligible to minor, adverse impacts if a
few areas needed to be temporarily closed for safety reasons while deer were lethally taken
during moderate visitor use periods. Similar to Alternative A, visitors would be notified of any
closures and why. Should CWD be detected in or near the Park, opportunities for opportunistic
and targeted surveillance may increase, which could increase the impacts that result from these
actions, but not substantially. Samples for live CWD tests would only be taken when deer are
being captured and collared in the Park as part of other projects and would have no impact on
visitor use or experience. Therefore, impacts on visitor use and experience from enhanced
targeted and opportunistic surveillance and enhanced live testing would be limited to short-term,
negligible to minor, adverse effects.
Lethal removal of “healthy appearing” deer for detection and assessment would involve a larger,
more sustained, effort. A maximum of 300 deer could be removed per detection (through
combined Park and State programs) when CWD is found five to 30 miles from the Park (up to
three years to meet sample size). A maximum of 69 deer could be removed when a positive
detection is found within five miles of the Park (assessment). These efforts may require more
temporary fire road or area closures if the activities were to take place during moderate visitor
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use periods. This would result in short-term, minor, adverse impacts. If lethal removal activities
were to take place during low visitor use periods, very few closures would be needed. Additional
public information about the need for the action and the logistics would help alleviate some of
the adverse visitor use effects.
Should lethal removals for detection and assessment be implemented, deer densities would be
reduced in some areas of the Park and would result in a decreased ability to view deer in these
locations. Although deer viewing opportunities would initially be reduced, the deer population
would rebound and remain viable. Implementation of actions that reduce deer density would
decrease the potential for CWD to become established and would reduce the likelihood of seeing
sick or dead deer, which would positively affect visitor experience. Visitors may also benefit
from knowing that the NPS is taking actions to protect the deer in the Park from the spread of
CWD. This alternative would also involve increased educational and interpretive activities;
therefore, Alternative B would also have long-term benefits.
Cumulative Impacts
The same past, present, and future beneficial and adverse impacts from cumulative actions
described for Alternative A would also occur under Alternative B. The adverse impacts from
actions taken under Alternative B would not outweigh the beneficial impacts from the other
past, present, and future actions at the Park; therefore, the overall cumulative impacts would be
long-term and beneficial.
Conclusion
Similar to Alternative A, actions associated with enhanced opportunistic and targeted
surveillance and enhanced live testing would have short-term, negligible to minor, adverse
impacts on visitor use and experience. Lethal removal of healthy appearing deer for detection
and/or assessment would have short-term, minor, adverse impacts. Long-term beneficial effects
would occur from reduced deer densities in some areas of the Park which would decrease the
potential for CWD to become established. In addition, beneficial effects would occur from
knowing that the NPS is taking actions to protect the deer in the Park. Cumulative effects on
visitor use and experience would be long-term and beneficial.
Alternative C: Enhanced Detection and Assessment but No Lethal Removal for Testing
Specific Impacts to Visitor Use and Experience
Detection and assessment activities under Alternative C would be the same as those described
under Alternative B—enhanced opportunistic and targeted surveillance and enhanced live
testing, but there would be no lethal removal of deer. Impacts of Alternative C would be
essentially the same as for Alternative B for these aspects, except without the added short-term,
minor, adverse impacts associated with lethal removal. Actions associated with enhanced
opportunistic and targeted surveillance would have short-term, negligible to minor, adverse
impacts on visitor use and experience. Live testing would have no impacts on visitor use and
experience. Compared to Alternative A, this alternative would somewhat decrease the potential
for CWD to become established in the Park. In addition, visitor experience would benefit more
because of the reduce likelihood of seeing sick or dead deer. Visitors may also benefit somewhat
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from knowing that the NPS is taking less drastic actions to protect the deer in the Park from
CWD. Combined with increased educational and interpretive activities, Alternative C would
result in long-term beneficial impacts to visitor use and experience.
Cumulative Impacts
The same past, present, and future beneficial and adverse impacts from cumulative actions
described for alternatives A and B would also occur under Alternative C. The adverse impacts
from actions taken under Alternative C are not enough to outweigh the beneficial impacts from
the other past, present, and future actions in the Park; therefore, the overall cumulative impacts
would remain long-term and beneficial.
Conclusion
Similar to Alternative B, actions associated with enhanced opportunistic and targeted
surveillance would have short-term, negligible to minor, adverse impacts on visitor use and
experience. Live testing would have no impacts on visitor use and experience. Although not as
extensive as Alternative B, long-term beneficial effects to visitor use and experience could occur
from decreased potential for seeing deer infected with CWD and from knowing that the NPS is
taking actions to protect the deer in the Park. Cumulative effects on visitor use and experience
would be long-term and beneficial.
Human Health and Safety
The safety of both visitors and NPS employees at the Park could be affected by implementation
of the proposed detection and assessment actions. CWD detection and assessment activities that
involve capturing and immobilizing live animals for marking/collaring and performing tonsillar
biopsies have the potential to affect the health and safety of the individuals involved (e.g.
wildlife handling, exposure to tissues/fluids). Options that involve the removal of deer and the
use of firearms also have the potential to affect the safety of Park staff and possibly visitors.
The purpose of this analysis is to identify the level of impact that implementing each of the
proposed alternatives would have on the safety of visitors and employees at the Park. Past
accident data, Park goals, and personal observations of safety issues, as well as current
knowledge of CWD health effects, were used to assess the effects of the alternative actions on
the safety of visitors and employees. The impact thresholds for health and safety are defined
below.
Negligible:
Minor:
Moderate:
Major:
There would be no discernible effects to human health or safety; slight injuries
could occur and may be reportable.
Any reported injury would require first aid provided by Park staff or require a
doctor’s attention.
Any reported injury would require further medical attention beyond what was
available at the Park and would result in time off.
An injury would result in permanent disability or death.
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Area of Analysis
The study area for this analysis including analysis of cumulative impacts is within the boundaries
of the Park.
Impacts of the Alternatives
Alternative A: No Action (Continue Current Actions)
Specific Impacts to Human Health and Safety
Under this alternative, opportunistic and targeted surveillance and potentially live testing for
CWD would continue at the Park. For this plan, it is assumed that opportunistic surveillance
would continue at about its current rate (14 deer) and about one deer would be taken annually
with targeted surveillance. Opportunistic surveillance includes taking diagnostic samples for
CWD testing from deer that have died in the Park due to disease, predators, vehicle collisions,
other trauma-related mortality; those lethally removed from the Park for other purposes (e.g.,
research); and those that die in the Park as a result of injuries from hunting outside the Park.
There are standard operating procedures in place for this sampling. Since opportunistic
surveillance began in 2006 a total of 57 samples (as of October 31, 2010) have been taken
opportunistically and no accidents or injuries have occurred as a result of these activities, and no
accidents are anticipated from their continuation. These activities would result in long-term,
negligible, adverse impacts on human health and safety.
Since 2006, there have been no deer removed by targeted surveillance at the Park. Targeted
surveillance involves identifying deer with clinical signs of CWD, and then either the Park
Biologist or Chief of Natural Resources making a determination as to whether or not a suspect
deer should be lethally removed for CWD testing as part of targeted surveillance. To ensure the
safety of all personnel involved, only law enforcement rangers or natural resource management
staff qualified to use firearms would be authorized to remove a clinically suspect deer. All
procedures for shooting, collecting samples, handling, cleanup, and storage of the deer are based
on information provided in “A National Park Service Manager’s Reference Book to
Understanding Chronic Wasting Disease, Version 4” (NPS 2007a). If the lethal removal
activities occur during periods of low visitor use, very few closures of fire roads or areas would
be needed. However, if activities take place during periods of moderate visitor use, areas in the
vicinity of firearm use would be closed to visitors for their safety. The safety measures
implemented under this alternative would ensure the safety of all visitors and Park staff. This
would result in a long-term, negligible, adverse impact.
Should CWD be detected in or near the Park, opportunistic and targeted surveillance may
increase, which could increase the impacts that result from these actions, but not substantially.
Samples for live CWD testing would only be taken when deer are being captured and collared in
the Park as part of other projects and would only be taken by qualified personnel. Therefore,
impacts on health and safety would be long-term, negligible, and adverse.
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Cumulative Impacts
Several past, present, and future actions would contribute to the cumulative impact on health and
safety of visitors and Park employees. Examples include vehicle-deer collisions, wildlife-human
conflict, aversive conditioning, recreational use, emergency response, criminal activity, vector
borne diseases, routine Park maintenance, and fire management duties. Positive outcomes that
serve to improve human health and safety include an improved Park radio system, an active
Parkwide Safety Committee, and development of safety plans, and relevant
educational/interpretive programs (e.g. Camping in Bear Country).
While there have been no reports of injuries from vehicle-deer collisions (there have been
collision injuries from people trying to avoid deer), the chance of such impacts would continue
(about 25 reported annually), with the intensity of impacts based on the severity of any injuries
sustained during a collision. However, no deer-vehicle fatalities have been reported to date. Park
personnel involved in animal relocation have the potential to be injured while handling animals
(e.g. bear, deer, raccoon, raptors, etc.). Being properly trained and qualified as well as following
standard operating protocols would minimize any impacts to long-term, minor, and adverse. Park
personnel involved in arduous field activities (e.g. fish electroshocking, wildland fire, Search and
Rescue) run the risk of injuries resulting from trips, slips, and falls, etc.; however, following
standard protocols would keep any adverse impacts at the long-term, minor to moderate levels.
Though there have been no injuries reported due to incidences of crime, some long-term,
negligible to minor, adverse impacts would continue. Impacts from past, present, and future
actions when combined with impacts from Alternative A would result in long-term, minor to
potentially moderate, adverse cumulative impacts. However, actions directly related to
Alternative A would have negligible contributions to impacts on human health and safety.
Conclusion
Opportunistic and targeted surveillance activities and potentially live testing employed under
Alternative A would result in long-term, negligible, adverse impacts on human health and safety.
Cumulative impacts on health and safety would be long-term, minor to potentially moderate and
adverse; however, Alternative A would contribute very little to any overall adverse impacts.
Alternative B: Enhanced Detection and Assessment, Including Lethal Removal for Testing
Specific Impacts to Human Health and Safety
Under Alternative B, enhanced opportunistic and targeted surveillance would be used for CWD
detection and could be supplemented with enhanced live testing and lethal removal of healthy
appearing deer for CWD testing under specific criteria. It is assumed that, under Alternative B, at
least 20 deer would be taken via enhanced opportunistic surveillance and one to two deer would
be taken annually with enhanced targeted surveillance. As described for Alternative A, taking
deer by enhanced opportunistic surveillance would result in long-term, negligible, adverse
impacts. The impacts from enhanced targeted surveillance would also be similar to those under
Alternative A and would be long-term, negligible, and adverse as long as standard operating
procedures are followed. Procedures include having only law enforcement rangers or select
natural resource management staff certified to use firearms to lethally remove suspect deer, and
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areas in the vicinity of firearms activity closed to visitors with the public being notified of the
closures.
Should CWD be detected in or near the Park, opportunities for opportunistic and targeted
surveillance may increase, which could increase the impacts that result from these actions, but
not substantially. Samples for enhanced live testing would be taken when deer are being captured
and collared in the Park as part of other projects and would only be taken by qualified personnel.
Therefore, impacts on health and safety would be long-term, negligible, and adverse.
Lethal removal of healthy appearing deer for CWD testing would involve a larger, more
sustained effort with a maximum of 300 deer removed for each new detection (up to three years
to meet sample size) and a maximum of 69 deer removed for assessment following the first
positive case within five miles of the Park. This may require more temporary area closures to
protect visitors if the activities were to take place during periods of moderate-low visitor use.
Because lethal removal of healthy appearing deer would be a larger, more intense effort
requiring additional people, authorized agents who are non-NPS personnel may be used to
supplement NPS personnel in the shooting of deer. Authorized agents could include other agency
personnel (e.g., APHIS) or contractors meeting specific requirements. To ensure that human
health and safety is not compromised, a contractor would be a fully insured business entity,
nonprofit group, or other entity engaged in wildlife management activities that include the direct
reduction with firearms and would be required to possess all necessary permits. Requirements for
all authorized agents would include a specific level of firearm proficiency and experience in the
use of firearms for wildlife removal. Training of authorized agents would include all actions
related to disposal and decontamination, and because prions are so difficult to decontaminate,
part of the training would be related to minimizing contact with infectious materials. It should be
noted again that there is no evidence to suggest that CWD is naturally transmissible to humans.
As with targeted surveillance, if closures are needed, the public would be notified of the closures,
where they are and when they would occur. These activities with all of their safety measures and
protocols would result in long-term, negligible to minor, adverse impacts.
Removal of deer for CWD detection and assessment under this alternative would decrease the
number of deer in some areas of the Park (e.g., Big Meadows, Skyline Drive) and potentially
decrease the likelihood of a collision between a deer and vehicle. However, as the deer
population rebounds over the years this benefit would be reduced. These actions would result in
short-term, negligible to minor, adverse impacts. Overall, all of the actions taken under
Alternative B would have long-term, negligible to minor, adverse impacts on health and safety.
Cumulative Impacts
The same past, present, and future adverse impacts from cumulative actions described for
Alternative A would also occur under Alternative B. The adverse impacts from actions taken
under Alternative B would contribute negligibly to the cumulative impacts; overall, cumulative
impacts would be long-term, minor to potentially moderate, and adverse.
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Conclusion
Opportunistic and targeted surveillance activities employed under Alternative B would result in
long-term, negligible, adverse impacts on health and safety, as would live testing; lethal removal
of healthy appearing deer for both detection and assessment would have negligible to minor,
adverse effects. Alternative B would have negligible contributions to cumulative impacts on
health and safety, which would be long-term, minor to potentially moderate, and adverse.
Alternative C: Enhanced Detection and Assessment but No Lethal Removal for Testing
Specific Impacts to Human Health and Safety
Detection and assessment activities under Alternative C would be the same as those described
under Alternative A—opportunistic and targeted surveillance and live testing, except that these
methods would be enhanced by having dedicated personnel. No lethal removal of healthy
appearing deer for CWD detection or assessment would occur. Therefore, the impacts of
Alternative C would be essentially the same as for Alternative A even when enhanced and would
result in long-term, negligible, adverse impacts on health and safety.
Cumulative Impacts
The same past, present, and future beneficial and adverse impacts from cumulative actions
described for alternatives A and B would also occur under Alternative C. The adverse impacts
from actions taken under Alternative C would contribute negligibly to the cumulative impacts;
however, cumulative impacts would be long-term, minor to potentially moderate, and adverse.
Conclusion
Enhanced opportunistic and targeted surveillance activities employed under Alternative C would
result in long-term, negligible, adverse impacts on human health and safety, as would enhanced
live testing. Alternative C would have negligible contributions to cumulative impacts on health
and safety, which would be long-term, minor to potentially moderate, and adverse.
Park Management and Operations
Park management and operations refers to the staff and budget available to protect and preserve
vital Park resources, provide for an effective visitor experience, provide for visitor protection,
and implement any selected plan.
The discussion of impacts to Park operations focuses on (1) the amount of staff available to
ensure visitor and employee safety; and (2) the ability of Park staff to protect and preserve
resources given current funding and staffing levels. It was assumed that under all alternatives the
Park’s annual budget would be increased to implement a particular alternative. However, this
funding is not guaranteed; each alternative discusses the impacts of receiving or not receiving
additional funding. Park staff knowledge was used to evaluate the impacts of each alternative,
and the evaluation is based on the description of Park operations presented in the Affected
Environment section. Definitions of impact levels are as follows:
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Negligible:
Minor:
Moderate:
Major:
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Park operations would not be affected.
Park operations would be affected, and the effect would be detectable, but current
levels of funding and staff would be adequate and other Park operations would
not be reduced.
Park operations would be affected, the effect would be readily apparent, and
increased staff and funding would be needed or other Park operations would have
to be reduced and/or priorities changed.
Park operations would be affected, the effect would be readily apparent, increased
staff and funding would be needed or other Park programs would have to be
eliminated.
Area of Analysis
The area of analysis, including the cumulative impacts analysis area, is limited to the lands
within the boundaries of the Park.
Impacts of the Alternatives
Alternative A: No Action (Continue Current Actions)
Specific Impacts to Park Management and Operations
Under this alternative, opportunistic and targeted surveillance for CWD would continue in the
Park and live testing would be conducted if deer were captured in the Park as part of another
project. No new CWD management actions would be taken, and information provided to visitors
and shared with other governmental entities would remain at levels similar to what occurs now.
To date, no deer have been removed using targeted surveillance and about 14 deer per year have
been removed opportunistically. For this plan, it is assumed that one deer would be taken
annually with targeted surveillance and 14 deer with opportunistic surveillance. This is not much
different from what has occurred previously at an annual cost of about $6,500, excluding carcass
disposal costs. Should CWD be detected in or near the Park, opportunistic and targeted
surveillance may increase, which could increase the impacts that result from these actions, but
not substantially. Given the current and anticipated level of activities under this alternative, there
would be minimal change in duties for the Park’s Natural and Cultural Resources Division, little
if any change in demand for the cultural resources or visitor services staff, and minimal effect on
the annual budget. Therefore, impacts to Park management and operations from the actions
under Alternative A would be long-term, negligible to minor, and adverse.
Cumulative Impacts
Many actions, plans, and programs place demands on Park staff and budget and contribute to
adverse cumulative effects on Park management and operations. These include the demand on
staff time and resources from normal daily operational duties, as well as special events such as
Resource Seminars and activities such as evening campfire programs and Wildflower and
Wilderness weekends. Management and handling of land acquisitions, permits, vandalism
mitigation, development of new visitor facilities, and development and oversight of visitor use
opportunities and interpretation programs all require staff time and money. Ongoing wildland
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fire management program needs also place demands on Park staff. These demands are expected
to continue into the future with continued high visitation and future planning needs related to
general deer management.
Therefore, the effects of all other actions that place demands on Park management and
operations, along with the expected demands of CWD management, would result in long-term,
moderate, adverse impacts to Park operations and management. Actions directly related to
Alternative A would have negligible to minor, adverse contributions to impacts on Park
management and operations.
Conclusion
Actions associated with opportunistic and targeted surveillance would have short-term,
negligible to minor, adverse impacts on Park management and operations. Alternative A would
have negligible contributions to cumulative impacts on Park management and operations, which
would be long-term, moderate, and adverse.
Alternative B: Enhanced Detection and Assessment, Including Lethal Removal for Testing
Specific Impacts to Park Management and Operations
Under Alternative B, enhanced opportunistic and targeted surveillance would be used for CWD
detection, and would be supplemented with enhanced live testing and lethal removal of healthy
appearing deer for CWD testing under specific criteria. As described for Alternative A, effects
on Park management and operations would be similar to those associated with current
surveillance work conducted in the Park. Under Alternative B, one-two deer would be taken
annually with targeted surveillance, and at least 20 deer would be tested annually with enhanced
opportunistic surveillance, with dedicated targeted surveillance having the most impact on costs.
Should CWD be detected in or near the Park, opportunistic and targeted surveillance would
increase, which could increase the impacts that result from these actions, but not substantially.
Samples for live CWD testing would also be taken when deer are being captured and collared in
the Park as part of other projects. Annual costs for enhanced targeted and opportunistic
surveillance are estimated at about $9,825, excluding carcass disposal costs. A reasonable
estimate for enhanced live-testing is strongly tied to where a CWD detection occurs and if there
are accessible deer capture locations that contain higher deer densities within the CWD sampling
area. Contingent on funding availability, estimates could range from $20,000 (25 deer) - $64,000
(80 deer) for one year of enhanced live-testing at the cost of $800 per deer. Therefore, impacts
on Park management and operations from these actions would have limited to short-term, minor,
adverse effects.
Lethal removal of healthy appearing deer would involve a larger, more sustained effort with a
maximum of 300 deer removed over three years for detection sampling. The demands on staff
and budget would increase, especially the need for natural resources staff and resource education
and visitor services. This effort would require additional staff support for training, testing,
contracting (if needed), coordination with the state, area closures or restrictions, and public
information, in addition to removal activities. Each “Detection” removal effort is estimated to
cost about $10,000 (40 deer at $250/deer) to $25,000 (100 deer at $250/deer) per year, so this
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could add up to approximately $30,000 (120 deer) to $75,000 (300 deer) over three years for
detection sampling, excluding carcass disposal costs (contingent on funding). Note: it is assumed
that the state will contribute 33% to 66% of the needed samples for detection under Alternative B
(where CWD is five-30 miles away) and that would greatly reduce the “upper end” cost of these
estimates to the Park. Lethal removal for an assessment action (cost of $250/deer) is estimated to
cost $10,000-17,500 per action in Year 1 (40-60 deer). If two positives are found within zero to
five miles of the Park simultaneously, the cost would be $20,000-$25,000 in Year 1 (80-100
deer). Impacts to Park management and operations would be short-term, minor, and adverse,
although the intensity (and Park budget impacts) would increase if detection or assessment
actions are implemented several times during the life of the plan.
Lethal removal of healthy deer as a detection or assessment tool could affect Park deer densities.
If lethal removal of healthy deer for detection or assessment is implemented, deer density would
be reduced in some areas of the Park (e.g., along portions of Skyline Drive). This reduction may
change the time staff spends on deer population monitoring—although that is not likely, given
the need for information on deer herd dynamics during the time of active CWD management.
This alternative would involve increased educational, interpretive, and management activities at
all times, and would therefore require additional funding and/or additional staff time to
implement these activities. Additional time would also be needed to answer public inquiries
about the actions taken. Costs for these efforts would depend on current staffing and level of
outreach needed and would vary over the life of the plan. These efforts would result in long- and
short-term, minor to moderate, adverse impacts to resource education and resource protection
staff.
Cumulative Impacts
The same past, present, and future impacts from cumulative actions described for Alternative A
would also occur under Alternative B. Alternative B would have negligible to moderate
contributions to impacts on Park management and operations from the actions proposed, with
more short-term effects rather than continuous adverse impacts. As a result, cumulative effects
on Park management and operations would remain long-term, moderate, and adverse.
Conclusion
Detection and assessment actions would have short- and long-term, negligible to moderate,
adverse impacts on Park management and operations, with more intense impacts related to the
lethal removal actions included in this alternative and the need for additional public education
and outreach. Cumulative effects on Park management and operations would be long-term,
moderate, and adverse.
Alternative C: Enhanced Detection and Assessment but No Lethal Removal for Testing
Specific Impacts to Park Management and Operations
Detection and assessment activities described under Alternative B—enhanced opportunistic and
targeted surveillance and enhanced live-testing, would also be available under Alternative C.
Alternative C, however, would not involve lethal removal of healthy appearing deer for CWD
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testing for detection or assessment. Therefore, impacts of Alternative C, even when enhanced,
would be similar to that described in Alternative A. The annual cost for this effort is estimated at
about $9,825, excluding carcass disposal costs. There would be a slight increase in demands on
staff and budget, especially for the natural resources staff, because of dedicated personnel needed
for these surveillance activities. Demands would include training, testing, coordination with the
state, and possible area closures or restrictions. A reasonable estimate for enhanced live-testing
costs is strongly tied to where a CWD detection occurs and if there are accessible deer capture
locations that contain ample deer densities within the sampling area. As such, estimates could
range from $20,000 (25 deer) - $64,000 (80 deer) for one year of enhanced live-testing at the
cost of $800 per deer. This alternative would also involve increased educational and interpretive
activities and would require additional funding and/or staff time to implement these activities.
Additional time would also be needed to answer public inquiries about the actions taken,
particularly any closures that may be needed. This would result in long- and short-term, minor,
adverse impacts to resource education and resource protection staff.
Cumulative Impacts
The same past, present, and future impacts from cumulative actions described for alternatives A
and B would also occur under Alternative C. Alternative C would have negligible to minor
contributions to impacts on Park management and operations from the actions proposed, with
more short-term effects rather than continuous adverse impacts. As a result, cumulative effects
on Park management and operations would be long-term, minor to moderate, and adverse.
Conclusion
Detection and assessment actions would have short- and long-term, negligible to minor, adverse
impacts on Park management and operations. Cumulative effects on Park management and
operations would be long-term, minor to moderate, and adverse.
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CONSULTATION AND COORDINATION
NPS DO #12 requires the NPS to make “diligent” efforts to involve the interested and affected
public in the NEPA process. This process, known as scoping, helps to determine the important
issues and eliminate those that are not; allocate assignments among the interdisciplinary team
members and/or other participating agencies; identify related projects and associated documents;
identify other permits, surveys, consultations, etc. required by other agencies; and create a
schedule that allows adequate time to prepare and distribute the environmental document for
public review and comment before a final decision is made. This chapter documents the scoping
and consultation that was incorporated into the planning process for this CWD Detection and
Assessment Plan/EA and includes the official list of recipients for the document.
BRIEF HISTORY OF SCOPING AND PUBLIC INVOLVEMENT
The Scoping Process
The NPS divides the scoping process into two parts: internal scoping and external or public
scoping. Internal scoping involved discussions among NPS personnel regarding the purpose of
and need for management actions, issues, management alternatives, mitigation measures, the
analysis boundary, appropriate level of documentation, available references and guidance, and
other related topics.
Public scoping is the early involvement of interested and affected public in the environmental
analysis process. The public scoping process helps ensure that people have an opportunity to
comment and contribute early in the decision-making process. For this planning document and
assessment, project information was distributed to individuals, agencies, and organizations early
in the scoping process, and people were given opportunities to express concerns or views and to
identify important issues or other alternatives.
Taken together, internal and public scoping are essential elements of the NEPA planning
process. The following sections describe the various ways scoping was conducted for this impact
statement.
Internal Scoping
The internal scoping process began on November 13, 2006. During a two-day meeting held in
the Park, NPS employees identified the purpose of and need for action, management objectives,
issues, and impact topics. NPS employees also discussed the CWD detection and assessment
option available to positively detect and estimate the prevalence of CWD in or near the Park. The
results of the meetings were captured in an Internal Scoping Report, which is now on file as part
of the administrative record.
A team of experts on CWD and deer management was also identified to provide scientific
expertise and technical input during the NEPA process. The Park established a Science Team to
provide input to this plan, as described in the Purpose of and Need for Action section. Comprised
of subject matter experts, the Science Team was chartered to advise and provide technical
recommendations to the NPS on matters regarding scientific data and analysis. The Team
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convened via conference calls, meeting six times over a five-month period. Topics of discussion
included existing conditions surrounding the Park; existing data and CWD monitoring; CWD
detection and assessment goals; approach to establishing action thresholds for detection and
assessment; and issues related to implementation of various actions. The purpose of the Science
Team discussions was to provide a technical framework for the development of action thresholds
and alternatives for the CWD detection and assessment plan. The Team also recommended
impact analysis techniques and various management options. Members of the Science Team are
listed with the document preparers in this chapter.
Agency Consultation
Park staff consulted with VDGIF Veterinarian and Deer Management Coordinator to obtain the
latest VDGIF CWD Surveillance Plans, Response Plans and CWD Surveillance Maps
throughout the three-year EA development process. We also had the VDGIF Deer Management
Coordinator review and comment on the EA.
Public Scoping
In addition to internal scoping within the NPS and with other public officials, public scoping for
the Plan/EA began in March 2007. Two consecutive public scoping meetings were held at
locations near the Park beginning with a presentation by the NPS and ending with an opportunity
for formal public comment. At the first meeting on March 28 in Penn Laird, three people signed
in and on March 29 at Madison, nine signed in, representing mostly private individuals at both
locations. The purpose of these meetings was to provide the public information about the disease
and the planning process and to solicit public input. Notices of the meetings were posted on the
NPS Planning, Environment, and Public Comment (PEPC) Website. Additionally, a newsletter
was mailed to the project’s preliminary mailing list of government agencies, organizations,
businesses, and individuals. The newsletter announced the public scoping meetings and
summarized the purpose, need, and objectives for the CWD plan/EA.
The comment period for the public scoping information ended on April 29, 2007. During this
time, all NPS scoping materials available at the meetings, including the newsletter, were posted
on the NPS PEPC Website for download. This provided another opportunity to review and
comment on the purpose, need, objectives, and preliminary alternatives, especially for those
stakeholders who could not attend the meetings.
The general theme of the public comments was how CWD may affect future deer hunting
opportunities in Virginia and how that would in turn affect local businesses (e.g. check stations,
taxidermists, hunting stores) and the local economy of the region.
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SCIENCE TEAM MEMBERS
Name
Joe Calzarette
Lindsey Donaldson
Ed Wenschhof
Andrew Banasik
Jim Atkinson
Michelle Batcheler
John Karish
Scott Bates
Title
Natural Resource Manager
Biological Science Technician
Chief, Natural Resources and Protection
Natural Resources Manager
Wildlife / Fisheries Biologist (former)
Wildlife Biologist
Chief Scientist (now I&M Coordinator)
Wildlife Biologist
Margaret Wild
Wildlife Veterinarian
Jenny Powers
Michael Mayer
Melissa (Behrent) Stedeford
Wildlife Veterinarian
Environmental Protection Specialist
(former)
Environmental Protection Specialist
George Timko
CWD Response Coordinator
Jonathan Sleeman
Wildlife Veterinarian
Nelson LaFon
Deer Project Coordinator
Bill McShea
Dan Niosi
Beth Kunkel
Deer Biologist
Environmental Scientist
Wildlife Biologist - Team Facilitator
Organization / Location
Antietam National Battlefield
Antietam National Battlefield
Antietam National Battlefield
Monacacy National Battlefield
Shenandoah National Park
NPS Northeast Region
NPS Northeast Region
NPS National Capital Region (NCR)
- Center for Urban Ecology
NPS Biological Resources
Management Division (BRMD)
NPS BRMD
NPS Environmental Quality
Division
NPS Environmental Quality
Division
Maryland Department of Natural
Resources
Virginia Department of Game and
Inland Fisheries
Virginia Department of Game and
Inland Fisheries
Smithsonian
Louis Berger Group
Kimley-Horn and Associates, Inc.
Additional information was also requested from state resource managers from West Virginia and
Pennsylvania respective to their CWD plans. These managers participated in at least one of the science
team calls.
LIST OF PREPARERS AND CONSULTANTS
Michele Batcheller, former Biologist, Northeast Region, National Park Service (retired)
Gordon Olson, former Division Chief of Natural and Cultural Resources, Shenandoah National
Park
Rolf Gubler, Biologist, Shenandoah National Park
Jenny Powers, Wildlife Veterinarian, Wildlife Health Team, National Park Service
Jacki Katzmire, Regional Environmental Coordinator, Northeast Region, National Park Service
Tom Flanagan, Environmental Protection Specialist, NPS Environmental Quality Division
Ryan Monello, Wildlife Biologist, Wildlife Health Team, National Park Service
Jeb Wofford, Wildife and Fisheries Biologist, Shenandoah National Park
Wendy Cass, Botanist, Shenandoah National Park
Jennifer Flynn, Deputy Superintendent, Shenandoah National Park
Martha Bogle, Superintendent, Shenandoah National Park
Karen Beck-Herzog, Management Assistant, Shenandoah National Park
Jim Schaberl, Division Chief of Natural and Cultural Resources, Shenandoah National Park
Sheila Colwell, Senior Natural Resources Program Manager, National Park Service
Nelson Lafon, Deer Mgt. Coordinator, Virginia Department of Game and Inland Fisheries
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LIST OF RECIPIENTS OF THE PLAN / ENVIRONMENTAL ASSESSMENT
Notice of this Plan/EA has been sent to the following agencies, organizations, and businesses, as
well as to other entities and individuals who requested a copy.

Area Congressional Delegates - A park news release including instructions on how to
access the document via PEPC

U.S. Forest Service – George Washington and Jefferson National Forests

Virginia Department of Game and Inland Fisheries

A park news release for all other interested parties
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Tribes in Managing Chronic Wasting Disease in Wild and Captive Cervids.
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Farnsworth, M. L., L. L. Wolfe, N. T. Hobbs, K. P. Burnham, E. S. Williams, D. M. Theobald,
M. M. Conner, and M. W. Miller. 2005. Human land use influences chronic wasting
disease prevalence in mule deer. Ecological Applications 15:119-126.
Grear, Daniel A., M. D.Samuel, J. A. Langenberg, and D. Keane. 2006 Demographic Patterns
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Gubler, R. 2004. White-tailed Deer Spotlight Counts in the Big Meadows Area - Annual Report
for 2004. Shenandoah National Park, Luray, Virginia.
Haskell, D. 1986. Deer Management Plan for Shenandoah National Park. Shenandoah National
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Johnson, C. J., K. E. Phillips, P. T. Schramm, D. McKenzie, J. Aiken, and J. Pedersen. 2006.
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Mathiason, C. K., J. G. Powers, S. J. Dahmes, D. A. Osborn, K.V. Miller, R. J. Warren, G. L.
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M. W. Miller, C. J. Sigurdson, G. C. Telling, and E. A. Hoover. 2006. Infectious Prions
in the Saliva and Blood of Deer with Chronic Wasting Disease. Science 314:133-136.
McShea, W. J. 2000. The influence of Acorn Crops on Annual Variation in Rodent and Bird
Populations. Ecology 81:228–38.
McShea, W. J., and J. H. Rappole. 2000. Managing the Abundance and Diversity of Breeding
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Miller, M. W., H. M. Swanson, L. L. Wolfe, F. G. Quartarone, S. L. Huwer, et al. (2008) Lions
and Prions and Deer Demise. PLoS ONE 3(12):e4019. doi:10.1371/journal.pone.0004019
Miller, M. W., E. S. Williams, N. T. Hobbs, and L. L. Wolfe. 2004. Environmental sources of
prion transmission in mule deer. Emerging Infectious Disease 10:1003–1006.
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Miller, M. W., and M. A. Wild. 2004. Epidemiology of chronic wasting disease in captive whitetailed and mule deer. Journal of Wildlife Diseases 40:320-327.
Miller, M. W., M. A. Wild, and E. S. Williams. 1998. Epidemiology of chronic wasting disease
in captive Rocky Mountain elk. Journal of Wildlife Diseases 34:532-538.
A Natural Heritage Inventory of Shenandoah National Park (Natural Heritage Technical Report
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Salman, M. D. 2003. Chronic wasting disease in deer and elk: scientific facts and findings.
Journal of Veterinary Medical Science 65:761-768.
Samuel, M. D., D. O. Joly, M. A. Wild, S. D. Wright, D. L. Otis, R. W. Werge, and M. W.
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Scanlon, J. J., and M. R. Vaughan. 1981. Population and behavioral ecology of white-tailed deer
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A. Spowart, K. I. O'Rourke, J. M. Miller, and P. A. Merz. 1997. Spongiform
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http://www.dgif.virginia.gov/wildlife/diseases/cwd/.
Walsh, P. D., and M. M. Miller. 2010. A weighted surveillance approach for detecting chronic
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Williams, E. S., and M. W. Miller. 2002. Chronic wasting disease in North American deer and
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Appendix A. Sample prevalence and sample weights for CWD surveillance.
This table was adapted from Walsh and Miller, 2010. It was developed from data collected from
free-ranging mule deer in Colorado. As specific information regarding eastern white-tailed deer
becomes available, we will substitute this with the best available information.
Deer Status
Suspect—female (targeted surveillance)
Suspect—male (targeted surveillance)
Mostly road-killed, either sex) (Opportunistic surveillance)
Lethally Removed Healthy appearing deer – Adult Male
Lethally Removed Healthy appearing deer – Adult Female
Lethally Removed Healthy appearing - Yearling Female
Lethally Removed Healthy appearing – Yearling Male
*these samples would only be collected under Alternative B.
123
Prevalence
Sample
Weights
Standard Error
of Weights
0.36
0.32
0.06
0.03*
0.02*
0.01*
0.01*
11.57
10.27
1.90
1.00*
0.58*
0.45*
0.25*
1.6
1.46
0.24
N/A
0.06
0.15
0.08
CWD Detection and Assessment Plan and EA
Shenandoah National Park
Appendix B. Deer Sampling Limits
11/16/2008
11/26/2010
by Mark Graham, NPS-BRMD
revised by Jenny Powers, NPS-BRMD
1. Chronic Wasting Disease (CWD) surveillance efforts can be divided between sampling for
detection and sampling for prevalence estimation (assessment of disease intensity) after
CWD has been detected. Because the NPS does not have control of sampling outside of the
Park and yet has a goal of sampling a statistically valid proportion of the population for
CWD detection, we will assume two scenarios, the first where the Park must supply all of the
samples and the second, and much more likely, that they Park supplies a proportion of
samples which can be calculated based on the total sampling area (SA), the total sample
level, the proportion of the area that includes SHEN, the SHEN deer density, and the deer
density in the SA outside of SHEN. All other potential scenarios will fall between these two.
L = Total samples needed from sampling area (#, see Table C.1)
S = sampling area (mi2)
a = area of Park inside the surveillance area (mi2)
d = deer density inside Park (#/mi2)
o = deer density outside of Park (#/mi2)
n = number of deer to be sampled in the Park (#)
ad = estimated number of Park deer in the surveillance area (#)
(S-a)o = estimated number of deer in the sampling area outside the Park (#)
number of deer to be sampled in the Park n
 L 
ad
S  a o  ad
{1.1}
2. The size of sampling area is key because it defines the limits of the biological population.
Because meaningful biological populations of free-ranging white-tailed deer are difficult if
not impossible to define, for purposes of this plan we have chosen to include deer within
counties adjacent to the Park as part of the Park population, acknowledging that those closest
to the Park are more likely to have interchange with the Park population most frequently. For
the purposes of the following example we have used a 79 square mile area (5 mile radius) as
the ‘sampling area’ (SA), however, it is quite likely that the SA will be much larger than this
given that sampling will include districts of the Park within 30 miles of a known index case
as well as adjacent counties. Thus, strictly defining the land mass for a SA will be
approached on a case by case basis and the following detection example is only for the
purposes of demonstration. The results presented here are conservative; in reality, the
sampling area and number of deer collected by the state may be higher and reduce the need
for Park sampling.
3. In estimating the proportion of deer that should be sampled from the Park, the density of deer
outside the Park was assumed to be 25 deer/mi2. The density of backcountry deer inside the
Park was also assumed to be 25 deer/mi2. Deer density in developed areas of the Park was
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Table B.1. Number of samples to be taken to detect the presence of CWD with a given
confidence if it occurs at a given prevalence. A sampling area of 79 mi2 is assumed and includes
55 mi2 of SHEN. If no samples are available within surrounding counties then 299 samples are
needed from SHEN at the 95/1 sampling level (Samuel et al. 2003).
Probability
of Detecting
One Positive
75%
80%
85%
90%
95%
99%
Prevalence
1%
1%
1%
5%
2%
1%
5%
2%
1%
5%
2%
1%
Total Samples
from
Sampling Area
138
160
189
46
114
230
59
149
299
91
229
458
Based on a
79 mi2 surveillance area*,
the Max Park contribution
if the VDGIF is sampling
outside of the Park
100
116
137
33
83
167
43
108
217
66
166
333
Yellow highlighting equals suggested sampling level
*Size of surveillance area is highly variable and will be determined cooperatively with the VDGIF,
therefore numbers given here are only for example purposes. In all likelihood, our surveillance area will
be much larger than 79 square miles and will include Park districts (within 30 miles) and adjacent
counties.
assumed to be 100 deer/mi2. Developed areas were estimated to be 5% of the Park area. The
total area of the Park was estimated to be 311 mi2. Thus the average Park deer density was
calculated to be 29 deer/ mi2 when a surveillance area includes developed areas or Skyline
Drive within the Park.
4. Accounting for the Big Meadows area at 150 deer/mi2 as part of an SA of 79 mi2, the average
deer density within the SA containing it would be 29.4 deer/mi2, which is not different
enough from 29 deer/mi2 to warrant special consideration. Hence, when calculating the
maximum deer samples that SHEN would need to contribute, 29 deer/mi2 was used as the
inside SHEN density, while 25 deer/mi2 was used as the outside of SHEN density.
5. Deer samples should be taken from within districts of the Park which are within 30 miles of a
known CWD case. Most likely a larger proportion of deer will be sampled from developed
areas compared to backcountry areas due to the greater density of deer in these areas, the
increased habituation of deer in developed areas, and easier access. Because higher deer
densities increase the risk factor of CWD amplification in the population, any decrease in
developed area densities due to sampling would be beneficial. Proportional sampling would
dictate that more deer be sampled from developed areas as well.
Detection Surveillance
6. Because exact SA cannot be determined at this time, to calculate the number of samples
required for detection surveillance efforts, a 5-mile radius circle was assumed, thereby
representing a 79-mi2 area. Using ArcGIS, 5-mile radius circles were plotted on maps of the
Park to determine the maximum area of the Park that could occur within the surveillance
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area. It was assumed that the Park would combine data with the state for detection and
prevalence estimation activities if it is available. In the second scenario where data from state
is not available, the numerical demand on the Park is greater. The maximum area of the Park
that would be included in the 79-mi2 area is about 55 mi2. To calculate sample contributions,
the deer density outside the Park was assumed to be 25 deer/mi2, and inside the Park an
average of 29 deer/mi2 was used. Confidence levels at given prevalence rates assumed
infinite-sized populations.
7. Because the purpose of detection surveillance is to detect the presence of CWD as early as
possible, it is recommended that sampling levels in Table C.1 are chosen based on assumed
prevalence levels of 1% rather than higher levels. A commonly used level, and the one
recommended here is to use the 95/1 confidence level. In other words, a 95% probability of
detecting one positive case if CWD occurs at 1% prevalence. This would require 217
samples from SHEN given a 79-mi2 SA that included 55 mi2 of SHEN.
Because CWD detection sampling is a resource intensive process the NPS often seeks to
maximize detection surveillance by applying appropriate weights to samples collected from
different classes of animals. For example, samples collected from animals hit by cars or
displaying clinical signs of CWD are more likely to test positive than those taken from the
general population of healthy appearing deer. A weighting system was recently published for
mule deer taken from the CWD endemic area of Colorado (Walsh and Miller 2010). While
weights for white-tailed deer are likely to be slightly different the relative value of each
sample is likely to be similar given that the clinical and pathological aspects of the disease
are similar in both species (Miller and Wild 2004).
8. If appropriate, we may use the weighting system put forward by Walsh and Miller (2010) to
maximize our CWD detection efforts. Once total sample size has been determined the
number can be met by collecting a variety of types of samples. Targeted surveillance samples
are weighted heaviest and fawns least. Sample size can be met by multiplying the weight by
number of samples taken of a given type and adding to reach total sample size. See Table
C.2.
Prevalence Estimation
9. For prevalence estimation sampling in response to CWD being detected, a 5-mi radius circle
would be mapped around the case, samples taken to estimate prevalence with an error of +/2% at 95% confidence.
10. Because the Park is not planning on participating in population reduction efforts in response
to CWD, prevalence estimates may continue even after CWD positive cases are found
beyond the initial case. As the number of cases detected increases, the error bars on the
prevalence estimate increase unless more samples are obtained. Table C.2 contains sample
numbers needed for 1-3 positive CWD cases with varying-sized confidence intervals.
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Table B.2. Sampling weights for CWD samples referenced to a healthy appearing male = 1.0.
Note: weighted sampling is only appropriate for detection activities not prevalence estimation
because we do not want a biased sample when estimating disease intensity.
Deer Status
Prevalence in
test population
Sample
Weights
Standard Error
of Weights
0.36
0.32
0.06
0.03*
0.02*
0.01*
0.01*
0.00
11.57
10.27
1.90
1.00*
0.58*
0.4*
0.25*
0.03
1.6
1.46
0.24
NA
0.06
0.15
0.08
0.03
Suspect—female (targeted surveillance)
Suspect—male (targeted surveillance)
Mostly road-killed, either sex) (Opportunistic surveillance)
Lethally Removed Healthy appearing deer – Adult Male
Lethally Removed Healthy appearing deer – Adult Female
Lethally Removed Healthy appearing - Yearling Female
Lethally Removed Healthy appearing – Yearling Male
Lethally Removed fawn
*these samples would only be collected under Alternative B.
Example: If over the period of 3 years SHEN collects 20 deer killed by cars or predators, one CWD suspect male, one CWD
suspect female, 40 lethally removed adult females and 50 lethally removed adult males the Park would reach a detection sample
size of 133. When pooled with an additional 166 adult male samples collected from surrounding counties and tested by the state,
sample size for the population will be achieved.
1.9 x 20 = 38
10.27 x 1 = 10.27
11.57 x 1 = 11.57
0.58 x 40 = 23.2
50 x 1 =
50
TOTAL = 133.04
Note: If weighted sampling increases the number of animals which must be removed, we will
instead use an unweighted sampling strategy where each adult deer accounts for a single sample.
Table B.3. Samples required to attain given confidence intervals and error sizes over varying
number of detected CWD positive cases. A sampling area of 79 mi2 is assumed to include 55 mi2
of SHEN. This represents the worst case scenario that requires the largest number of samples to
be taken from SHEN.
1+ CWD Case
Confidence
(%)
Error
(+/- %)
SA Total
Samples
2+ CWD Cases
SHEN
Samples
5
32
23
2
80
58
1
158
115
5
38
28
95
2
95
69
1
187
136
5
50
36
99
2
124
90
1
242
175
Green highlighting equals suggested sampling levels.
90
127
SA Total
Samples
45
112
219
54
133
259
70
174
334
3+ CWD Cases
SHEN
Samples
SA Total
Samples
SHEN
Samples
33
81
159
39
97
188
51
126
243
55
136
265
65
162
313
86
210
402
40
99
193
47
118
227
62
153
292