TAMMY L. BELINSKY

Attorney at Law9544 Pine Forest Road

Copper Hill, Virginia 24079 mobile telephone (540)874-5798

telefax (540)929-9195email: tambel@hughes.net

May 30, 2015

Thomas Speaks, Forest Supervisor and Reviewing Officer USDA Forest ServiceGeorge Washington and Jefferson National Forests 5162 Valleypointe Parkway Roanoke Virginia 24019-3050via electronic mail to: objections-southern-georgewashington-jefferson@fs.fed.us

RE: Objection; Gilmore Hollow Vegetation Project

Dear Supervisor Speaks:

In accordance with 36 C.F.R. Part 218, this Objection is filed on behalf of Mr. and Mrs.Mike Reynolds, whose address is 301 Back Run Road, Natural Bridge Station, Virginia 24579,and whose telephone number is 540-291-1072. If the Forest Service feels a need to identify alead objector, Mr. Mike Reynolds is so designated.

Mike and Ginger Reynolds object to the logging of one tract included in the GilmoreHollow Vegetation Project, specifically Unit 4. Mike and Ginger Reynolds believe that theirobjections are best addressed by eliminating Unit 4 from the project.

Mr. Reynolds first voiced his concern in person in the Glenwood Pedlar District Rangeroffice. Mr. and Mrs. Reynolds submitted written comments on two occasions, and the ForestService staff visited the Reynolds property during the project analysis process. Unfortunately,the Reynolds’ concerns have been dismissed and the environmental assessment is inadequate toaddress their concerns.

The Gilmore Hollow Vegetation Project was authorized by District Ranger Lauren Stullof the Glenwood Pedlar Ranger District which district straddles both the George Washington andJefferson National Forests. The Gilmore Hollow Vegetation Project is on the Jefferson NationalForest.

Mr. and Mrs. Reynolds’ comments on the proposed project have been in regard to theincreased runoff, erosion, sedimentation, and the karst-geology-related impacts from loggingadjacent to their property. The Reynolds have explained the karst related impacts that they stillexperience on their property from an adjacent logging project that was executed within the last20 years. Mr. Reynolds hosted the Forest Service staff on his property and pointed out thesinkhole that he filled with two truckloads of gravel, which still spouts water to this day. Thestaff admitted that the Reynolds property is susceptible to runoff problems.

Supervisor SpeaksMay 30, 2015page two

Submitted herewith this letter of objection is a report prepared by a professionalhydrogeologist whose analysis confirms that the Reynolds have expressed valid concerns, andthat the Final Environmental Assessment (“Final EA”) for the project presents incomplete andinaccurate information that renders the Forest Service analysis invalid. Please see submittedherewith a report prepared by Pamela C. Dodds, PhD, Registered Professional Geologist, entitled“Hydrogeological Assessment of Michael E. Reynolds’ Property Rockbridge County, Virginia”. Dr. Dodds’ curriculum vitae is appended to her report.

As Dr. Dodds’ report indicates, the following statement in the introduction to the staff’sanalysis of the environmental impacts to physical resources is inadequate: “No project issuesrelated to minerals, geology or landform, or air quality was identified during the scoping process. No activities within any alternative would have significant direct, indirect or cumulative effectson these particular ecological components.” Final EA (undated), Chapter 3(B.), p 20. Unit 4 andthe Reynolds property are on the slopes of Cave Mountain. It is likely that Cave Mountain wasnamed for the karst and limestone geology that dominate Unit 4 and the Reynolds property. Thelegend on the relevant soils map in the Final EA (p 31) conceals the soils information. Beginning on page 5 and continuing onto page 6 of Dr. Dodds’ report, she explains, “Thestructural geologic history of the Arnold Valley area is very complex. . . . Sinkholes which haveformed in the Shady Dolomite are visible on the hillside adjacent to and within FS Unit 4 andalso in the lower areas near the forest edges on the Reynolds property.” The “project issuesrelated to minerals, geology and landform” are as plainly apparent, and the Reynolds’experiences with runoff, erosion, and sinkholes are the symptoms of those project issues.

Dr. Dodds describes the relationship between soils, geology, rainfall, runoff andgroundwater flow that explain the experiences and observations of the Reynolds with sinkholeformation on their property and scouring in the unnamed tributary to Elk Creek that runs throughthe Reynolds property. The staff met with Mr. Reynolds on the property and he showed them thelocation of the sinkhole that he filled. The staff presumably was aware of the soils and geologicconditions, and did not ask Mr. Reynolds about nearby caves or other sinkholes or discuss withhim his knowledge of the land upon which he grew up.

There is a visible limestone ledge and large sinkhole on the tract that was logged withinthe last 20 years just above the Reynolds’ home. It seems the staff visited the property for thesole purpose of informing the Reynolds that their property is prone to runoff. Had the staffactually been seeking information upon which to base the decision when they visited theReynolds property, they also would have learned that a well driller lost a drill bit in a cavernwhile drilling through limestone on the parcel of the property that was carved out for his sister. Mr. Reynolds also could have pointed out features on the National Forest that the Forest Servicehas overlooked.

Supervisor SpeaksMay 30, 2015page three

Forest Wide Standard (FW) 63 must be followed in Unit 4, just as it is being followed inunit 7, (Final EA, Chapter 2 (C.), p 15): “A minimum of 200 foot buffers are maintained aroundcave entrances, sinkholes, and cave collapse areas known to open into a cave’s drainage system.There are no soil-disturbing activities or harvest of trees within this buffer. Wider buffers areidentified through site-specific analysis when necessary to protect caves from potentialsubterranean and surface impacts. Perennial, intermittent, channeled ephemeral stream standardswill apply beyond the first 200 feet.” With springs and seeps also observed in Unit 4 as noted byDr. Dodds, there would little point in logging the unit after the buffer standards are applied.

Furthermore, there is a cave located on the National Forest near the bottom of Unit 4. Dr.Dodds was naturally curious because of the naming of Cave Mountain and so looked for cavelocation information as reported on pages 6 and 7 of her report. I am shocked at the failure of theForest Service to identify the cave on the National Forest. Mr. Reynolds knows the cave is therebecause it is the territory on which he was raised. Had the staff been truly interested in learningof the conditions that cause the problems about which the Reynolds complain, Mr. Reynoldscould have shared his knowledge. Again, Dr. Dodds’ report describes the interrelationshipsbetween the soils, geology, hydrology, and land disturbance and the risk of such disturbance inthis particular environment to the conditions in the cave.

Forest Wide Standard FW-65 recognizes the risk to caves and prescribes that“Management activities within any area draining to a cave are limited if they may affect the cave ecosystem through sedimentation, soil sterilization, the addition of nutrients or other chemicals(including pesticides and fertilizer), or if they change the cave’s natural hydrology ormicroclimate.” Revised Land and Resource Management Plan for the Jefferson National Forest(“Revised Plan”) 2004, p 2-20. The necessary analysis has not been performed to know whetherlogging directly above the cave may affect the cave, but based on the Reynolds’ personalexperience on their property, there’s a safe bet that logging above it will affect the cave.

Caves are considered Rare Communities in the Revised Land and Resource ManagementPlan for the Jefferson National Forest. 2004 Revised Plan, p 2-19. Goals 10 and 11 of theRevised Plan call for the maintenance, restoration and protection of significant and potentiallysignificant caves in accordance with federal law. This seems the perfect opportunity for theForest Service to evaluate this cave in accordance with Objective 11.01 of the Revised Plan (p 2-19). Furthermore, there is no information in regard to whether the cave supports populations ofIndiana Bats, and if so, whether other aspects of the project must be evaluated in accordance withthe standards for the protection of bat habitat.

Mr. Reynolds has lived on the same property for sixty-one years. He knows when thesinkholes and water runoff problems started, and it was after the adjacent logging that occurredwithin the last 20 years. The soil and geologic conditions in that area are why there is NationalForest in Arnold Valley. The Final EA accounts for the logging history in the area and the Forest

Supervisor SpeaksMay 30, 2015page four

Service should not need to be reminded that the purpose of the Weeks Act was to restore the forests for the purposes of watershed protection. The Reynolds property and the downstreamimpacts of logging in that area are a prime example of the need to heed the purpose of the WeeksAct.

Despite the Reynolds’ reports of water runoff issues that persist to this day since the lastadjacent logging project, the staff failed to include that logging project in any of the effectsanalyses that begin on page 20 of the Final EA (undated).

Finally, the staff’s analysis in regard to the suitability of using uneven aged managementrings hollow with Mr. Reynolds. He has lived on that parcel of property in one home or anotherall of his life and lived there when the Forest Service harvested in the vicinity of Unit 4 using uneven aged management. Uneven aged management appeared to work just fine, and might evenbe the reason that the trees in Unit 4 are so desirable, and it caused less runoff problems on theReynolds property than the logging that occurred within the last 20 years.

One of the staff’s comments about uneven aged management questions the success ofregeneration. The staff has not objectively evaluated the condition of the forest that was loggedwithin the last 20 years. There may never be any timber of any value in the stands around theReynolds property, or at least not enough to justify another logging project at public expense. The copice regeneration is weak, the trees appear undernourished, and until ailanthus is avaluable timber product there’s no value in the result of the last shelterwood cut. A better use ofpublic resources would be to hand-thin the stands that were cut last time and remove theailanthus that is taking over nearly every logged site in Arnold Valley. Excluding uneven agedmanagement based on the success of regeneration is meaningless in the context of the result ofthe last, adjacent shelterwood cut. Moreover, logging Unit 4 violates FW-87 by encouraging thespread of the ailanthus that came in with the last logging project.

The staff justifies the plan objective of harvesting timber as follows: “Forest productsderived from commercial timber sales contribute to the social and economic well-being of thepeople living in the areas and help maintain a way of life long associated with the area.” FinalEA (undated), Chapter 2 (B) (2), p. 12. The analysis completely disregards Mr. Reynolds’observations and experiences on the property in which he has resided all of his life, and therebyfails to account for his social and economic well-being and the maintenance of his way of lifewith which he has been associated for all of his sixty-one years.

The Reynolds respectfully request a meeting with you in accordance with 36 C.F.R. §218.11 to discuss resolution, and suggest that the project site is the best location for such ameeting to observe the geologic features that are the basis for their concerns.

Supervisor SpeaksMay 30, 2015page five

On behalf of Mike and Ginger Reynolds,

Sincerely,

Tammy L. Belinsky

Enclosure

HYDROGEOLOGICAL ASSESSMENT OF MICHAEL E. REYNOLDS’ PROPERTY

ROCKBRIDGE COUNTY, VIRGINIA

By

PAMELA C. DODDS, Ph.D. Registered Professional Geologist

May 27, 2015

TABLE OF CONTENTS PAGE

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 Description of the Study Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4 Geology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Soils . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Surface Water and Groundwater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Timbering Operations and Hydrologic Computations . . . . . . . . . . . . . . . . . . . . .11 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 LIST OF FIGURES Figure 1 - Study Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Figure 2 - The Geology of the Cave Mountain Area . . . . . . . . . . . . . . . . . . . . . . 5 Figure 3 - Sinkhole development in limestone or dolostone. . . . . . . . . . . . . . . . . 6 Figure 4 - Excerpt from “Selected Karst Features of the Central Valley

and Ridge Province, Virginia” . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . 7 Figure 5 - NRCS soils map for the study area . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 LIST OF TABLES Table 1 - Computations for stormwater discharge. . . . . . . . . . . . . . . . . . . . . . . 14

HYDROGEOLOGICAL ASSESSMENT OF MICHAEL E. REYNOLDS’ PROPERTY

ROCKBRIDGE COUNTY, VIRGINIA

By PAMELA C. DODDS, Ph. D.,

Registered Professional Geologist EXECUTIVE SUMMARY A hydrogeological assessment of Michael E. Reynolds’ property (Reynolds property), located in Rockbridge County, Virginia, was conducted to characterize the hydrogeologic conditions and determine impacts on water resources from timbering operations proposed as Unit 4 on adjacent property, at a higher elevation, owned by the USDA Forest Service (FS). Timbering operations were conducted within the past 20 years on FS property adjacent to Unit 4. Since that time, Mr. Michael E. Reynolds has observed sinkhole formation on the timbered FS property and has also observed increased sinkhole development and increased erosion on his property. Mr. Reynolds is concerned that if Unit 4 is timbered, there will be even further sinkhole development and greater erosion on his property. The Reynolds property is located within the watershed of an unnamed tributary to Elk Creek, and is underlain by karst terrain with sinkholes, springs, and at least one documented cave entrance. The adjacent FS Unit 4 property proposed for timbering is situated on steep slopes and is also within the watershed of the unnamed tributary to Elk Creek. Seeps and springs of headwater areas of the unnamed tributary are located on the FS property. The adjacent FS Unit 4 property is mostly underlain by karst terrain with sinkholes; however, the upper portion of Unit 4 is underlain by sandstone. Because timbering operations would be detrimental to springs and seeps of the headwater areas, detrimental to groundwater, detrimental to the underlying karst and nearby caves, and detrimental to water quality of the unnamed stream on the Reynolds property and to Elk Creek, the land comprising Unit 4 is best suited to remain under the current woodland ground cover. The hydrogeological assessment presented herein was based on 1) observations made during the site visit on May 11, 2015; 2) published scientific data for the site; and 3) calculations made to determine stormwater discharge quantities under various conditions. The hydrogeological study includes hydrological computations to determine the amount of stormwater discharge resulting from a 1-hour,10-year storm event and also from a 1-hour, 2-year storm event on three specific ground cover conditions for the watershed delineated within the study area. The first set of computations considers a completely undeveloped, woodlands ground cover. The second set of computations considers a 10 percent impervious ground cover, with the remaining cover of woodlands, because the U.S. Environmental Protection Agency recognizes that stormwater discharge from a 10 percent impervious ground cover results in degradation to the water resources within the watershed.

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The third set of computations considers the ground cover resulting from timbering operations on the FS Unit 4 property, in addition to the existing ground cover. The stormwater discharge for a 10 percent impervious cover serves as a threshold discharge to evaluate the stormwater discharge from development within the delineated watershed. A comparison of the stormwater discharge resulting from a 10 percent impervious area and that of existing and proposed developed areas within the delineated watershed indicates that timbering operations will result in negative impacts to the water resources. Elk Creek has been recognized as a stockable trout fishery. While impacts of direct sedimentation from timbering operations on Unit 4 may decrease within 3 years, the increased stormwater discharge from the deforested ground cover will cause stream bank erosion downstream. Stream bank erosion of the unnamed tributary on the Reynolds and of Elk Creek will release additional sediments to these surface waters, causing embeddedness and damage to aquatic habitats. The increased stormwater discharge will also result in decreased groundwater recharge, changing groundwater flow conditions and the base level flow to the unnamed tributary and to Elk Creek. Changes in groundwater flow would change the cave environment, causing harm to cave dwelling organisms, in violation of the Virginia Cave Protection Act. It is explained in the EA that timbering operations will increase soil acidity. This increase in soil acidity will cause greater dissolution of the underlying limestone and dolomite, resulting in more sedimentation in the bedrock voids such that more sediment will be introduced through springs to the unnamed tributary and Elk Creek. Also, greater sedimentation in the bedrock voids will change the groundwater flow conditions and the base level flow to the unnamed tributary and to Elk Creek. It is recommended that the FS exclude Unit 4 from timbering operations because of the negative impacts that will result to surface and groundwater resources. Negative impacts include: 1) increased stormwater discharge that will cause stream bank erosion and sedimentation in the unnamed tributary and Elk Creek; 2) decreased groundwater recharge; 3) changes in groundwater flow in the karst area underlying the Reynolds property and Unit 4, including cave locations which are protected by the Virginia Cave Protection Act; 4) reduced base level groundwater flow to the unnamed tributary on the Reynolds property and Elk Creek; 5) increased soil acidity which will increase dissolution of the karst area underlying the Reynolds property and Unit 4; 6) decreased base cations and increased acidity to Elk Creek; and 7) decreased tree canopy which will damage habitats of insect larvae in seeps and springs of the headwaters of the unnamed tributary.

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INTRODUCTION Unit 4 should not be subject to timbering operations. The FS has proposed timbering of the area designated Unit 4 of the Gilmore Hollow Vegetation Project, which is located on the Glenwood Ranger District of the George Washington National Forest in Rockbridge and Botetourt Counties, Virginia. The Environmental Assessment (EA) for this project, prepared by the FS in compliance with the National Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations, provides direct, indirect, and cumulative environmental impacts that would result from the implementation of the proposed action and other alternatives. Information for the hydrogeological assessment provided herein draws freely from the information provided in the EA with references shown in parentheses as EA and page number (p.). Unit 4 consists of 19 acres (EA, p.3) located adjacent to and uphill from the Reynolds property. This FS property is located on the north slope of Cave Mountain. The FS, in its EA, p.3, has characterized Unit 4 as consisting mostly of yellow poplar, white oak, and red oak, with a stand age of 99 years. The proposed regeneration method for Unit 4 is described as coppice with reserves (EA, p.3), in which 85% of the timber would be cut with the expectation that regeneration would come from stump sprouts (EA, p.1-2). Because Mr. Reynolds has observed sinkhole formation on FS property adjacent to Unit 4 that was timbered within the past 20 years and because Mr. Reynolds observed increased sinkhole formation and erosion on his property since those timbering operations, he is concerned that if Unit 4 is timbered, there will be even further sinkhole development and greater erosion on his property. The Reynolds property is located within the watershed of an unnamed tributary to Elk Creek. The FS property designated as Unit 4 is located adjacent to a portion of the Reynolds property and is upslope from the Reynolds property. Unit 4 is also located in the watershed of the unnamed tributary to Elk Creek. Headwater areas to the unnamed tributary are located on Unit 4. The Reynolds property and the lower portion of Unit 4 are underlain by carbonate rocks. The uppermost portion of Unit 4 is underlain by non-carbonate rocks. Sinkholes were observed on within the areas of Unit 4 underlain by carbonates. Seeps and springs occur in the lower portion of Unit 4, indicating a hydraulic connection to the headwater areas. Seeps and springs were also observed on the Reynolds property close to the lower edge of Unit 4 and also within the unnamed tributary located on the Reynolds property. One documented cave is located at the base of Cave Mountain, just east of the study area. Another cave has been reported on the other side of the unnamed tributary. Included in the hydrogeological study presented herein are descriptions of the geology and soils of the area, discussions of the groundwater and stream water resources of the area, delineation of the impacted watershed encompassing the Reynolds property and Unit 4, and three sets of hydrologic computations of stormwater discharge assuming 1) a completely forested area; 2) a 10 percent impervious area; and 3) the conditions resulting from timbering of Unit 4.

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DESCRIPTION OF THE STUDY AREA The study area (Figure 1) consists of property owned by Michael E. Reynolds (Reynolds property) and property owned by the FS, designated as Unit 4. An unnamed tributary to Elk Creek is located on the Reynolds property. This unnamed tributary is a first-order stream, the watershed of which encompasses the Reynolds property and Unit 4. The study area extends in latitude from approximately 37 degrees 35 minutes North to 37 degrees 35 minutes 40 seconds North and in longitude from approximately -79 degrees 31 minutes 18 seconds West to -79 degrees 30 minutes 33 seconds West. The Reynolds property has a dwelling and outbuildings on the western portion of the property, but consists mostly of pasture areas extending along the unnamed tributary. Several seeps and springs were observed issuing from Unit 4 and also from adjacent areas on the Reynolds property. Additionally, seeps and springs were located along the unnamed tributary. Sinkholes were observed on Unit 4 within the area underlain by carbonate rock and also on the Reynolds property, which is entirely underlain by carbonate rock.

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Figure 1. Study Area.

N

GEOLOGY The structural geologic history of the Arnold Valley area is very complex. Thrust faulting has caused older geologic units to become displaced over the younger geologic units. Such is the case for the study area. The Reynolds property is underlain by the Shady Dolomite of Cambrian geologic age. The FS Unit 4 property is underlain by sandstone of the Erwin Formation, also of Cambrian geologic age; however, the Shady Dolomite is stratigraphically younger than the Erwin Formation. Thrust faulting caused the older Erwin Formation to be displaced over the younger Shady Dolomite. Cave Mountain, shown on the geologic map in Figure 2, is bounded by thrust faults and exhibits many fractures in the bedrock. The Shady Dolomite underlying the Reynolds property extends as a unit beneath the surficial Erwin Formation of Cave Mountain. The Shady Dolomite bedrock dips to the northwest beneath the fractured, faulted sandstone of the Erwin Formation. Figure 2. The geology of the Cave Mountain area, excerpted from the “Geologic Map of the Arnold Valley Quadrangle, Virginia”, in the “Geology of the Natural Bridge, Sugarloaf Mountain, Buchanan, and Arnold Valley Quadrangles, Virginia”, by Edgar W. Spencer, Report of Investigations 13, Virginia Division of Mineral Resources, 1968. The approximate location of the Reynolds property is outlined in blue. The approximate location of the FS Unit 4 property is outlined in black. The approximate location of the watershed is outlined in green. The Shady Dolomite and Erwin Formation are indicated by the specified patterns. The thrust faults are indicated by a dashed line with a “T”.

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The Shady Dolomite consists of finely laminated dolomite, which is calcium magnesium carbonate, and of massive limestone, which is calcium carbonate. Because precipitation is slightly acidic (dilute carbonic acid) due to the presence of carbon dioxide in the atmosphere, it is able to dissolve limestone and dolomite. Fractures in the Shady Dolomite facilitate the downward movement of the acidic precipitation, in addition to the acidity supplied by the soils of both the Erwin Formation and the Shady Dolomite. The acidic water dissolves the carbonate bedrock as it moves downward, creating interconnected cavities or voids in the bedrock. Sinkholes which have formed in the Shady Dolomite are visible on the hillside adjacent to and within FS Unit 4 and also in the lower areas near the forest edges on the Reynolds property. These sinkholes were not identified in the EA. Sinkholes form where surficial soil and rock fragments migrate downward into voids created by acidic water, as illustrated in Figure 3. Mr. Michael E. Reynolds, owner of the Reynolds property, has reported filling in a sinkhole that formed near the forest edge below the designated Unit 4 area. The sinkhole was large enough that he was required to save one of his calves which had fallen into the sinkhole. Additionally, he observed water issuing upward from the sinkhole, reaching a height of approximately 2 feet above the sinkhole. Figure 3. Sinkhole development in limestone or dolostone, excerpted

from Jennings, J.N., 1985, Karst geomorphology: Oxford, Basil Blackwell Ltd.,

293 p. A cave is present at the base of Cave Mountain (Figure 4), southeast of the Reynolds property and just east of the FS Unit 4 property. In the EA (p.15), it is stated that in accordance with Forest Wide Standard (FW) 63, there must be a minimum of 200 foot buffers maintained around cave entrances and sinkholes, and that wider buffers are specified through site-specific analysis when

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necessary to protect caves from potential subterranean and surface impacts. It is stated in the EA (p.82) that the project area is not within 2 miles of any caves which are hibernacula. However, the cave near Unit 4 was evidently not investigated because there is no mention of it in the EA. Additionally, there is no mention of determining the location of caves in the karst area underlying and near Unit 4 which could serve as bat hibernacula. The Virginia Cave Protection Act, “§ 10.1-1006. Disturbance of naturally occurring organisms; scientific collecting permits; penalties”, is violated when the natural cave environment is disturbed in a way that causes harm to naturally occurring cave organisms. A change in the groundwater flow, or the introduction of groundwater into a cave that normally doesn’t have groundwater flow, results in disturbing the natural cave environment. This, in turn, can cause harm to the naturally occurring cave organisms. It should be noted that in the EA (p.13), there were specific actions required to protect Indiana Bat roosts. The owner of the Reynolds property also reported another cave located near his property. When a well was being drilled for the residence of Mr. Reynolds’ sister, located between Mr. Reynolds’ property and County Route 781, the well driller lost a drilling pipe, indicative of a void in the rock. The well driller stated there is a cave beneath the residence.

Figure 4. Excerpt from “Selected Karst Features of the Central Valley and Ridge Province, Virginia”, by David A. Hubbard, Jr., 1988, Publication 83, Virginia Division of Mineral Resources. The cave located near the base of Cave Mountain is shown as a red triangle and designated as “Location of cave”. Numbers refer to specific lithologies. The number “1” indicates an area of limestone and dolomite. The number “6” indicates non-carbonate rocks.

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Location of cave

SOILS The current soil survey for Rockbridge County must be accessed on the NRCS website:http://www.nrcs.usda.gov/wps/portal/nrcs/surveylist/soils/survey/state/?stateId=WV . The map showing the soils designations is available on the NRCS website by manually locating the “Area of Interest” (AOI) and subsequently researching the soils descriptions. Figure 5 provides the AOI map generated for Unit 4 and the Reynolds property on the NRCS website.

Figure 5 – NRCS soils map for the study area, showing numbers for soils designations and also soil rating polygons. The approximate locations for Unit 4 and the Reynolds property are outlined in dark gray. Notice the northwest portion of Unit 4 is rated moderate and the remainder is rated severe. The EA (p.30-32) provides the soils descriptions and number designations for Unit 4 as Keener loam, 15 to 35 percent slopes (826D); Marbleyard, very cobbly sandy loam, 35 to 60 percent slopes, rubbly (846ES); and Marbleyard very cobbly sandy loam, 35 to 60 percent slopes, very stony (846E). Unit 4 is shown

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on the EA map (p.31) as extending northward into another soils description area, but the map legend covers the soils number. The AOI map presented herein reveals that soils within this undescribed area are shown as Keener loam, 3 to 15 percent slopes, very stony (826C). The NRCS provides erosion hazards ratings, which are included in Figure 5 by color designations. The lowermost slopes with 826C soils (3 to 15 percent slopes) have a slight erosion hazard. There is only a small area with these soils and slopes in Unit 4. The northwest portion of Unit 4, with 826D soils (15 to 35 percent slopes), have a moderate erosion hazard. The uppermost and eastern portions of Unit 4, with 846E and 846ES soils (35 to 60 percent slopes), have a severe erosion hazard. It should be noted that the FS states specifically that ground based harvest systems are limited to slopes not exceeding 35% (EA, p.33). However, Table 1 (EA, p.3) states the logging system for Unit 4 is ground based (skidder). SURFACE WATER AND GROUNDWATER Surface water and groundwater will be negatively impacted if the proposed timbering on Unit 4 is conducted. Negative impacts identified by the FS include 1) sedimentation that will degrade the water quality of streams and harm aquatic habitats; 2) increased stormwater runoff that will increase surface water runoff in adjacent properties; and 3) The following issues were identified in the FS request for scoping comments (EA, p.20): 1) “Timber harvesting and temporary road construction will degrade the water quality of the streams in the area by an increase in sedimentation.”; and 2) “Timber Harvesting will result in increased runoff onto adjacent private ownership causing problems with farming and access.” The FS describes Elk Creek, into which the unnamed tributary on the Reynolds property flows, as being of beneficial use as a stockable trout fishery. With respect to riparian and water resource issues, the FS identified riparian areas in the vicinity of harvest areas (beginning on EA, p.21), including areas associated with seeps and springs, that would be protected. However, the seeps and springs adjacent to Unit 4 were not identified, even though the protection area for seeps and springs is described as being the same as that for riparian areas of perennial springs: “100 feet (core area) plus extended area (based on slope)”. Also, the riparian area of the first-order stream on the Reynolds property, which is an unnamed tributary to Elk Creek, was not identified as being close enough to Unit 4. However, it will be impacted by increased stormwater runoff, as described in the EA on p.27. The FS provides in its scope of analysis for these issues that “The Gilmore Hollow project is located in the watersheds of Elk Creek, Back Run, Gilmore Hollow, Sprouts Run, and North Creek.” The unnamed tributary on the Reynolds property which flows into Elk Creek is identified in the listing of tributaries. This unnamed tributary is located downslope and adjacent to Unit 4 on the map of the Gilmore Hollow Vegetation Project Alternative 2-Modified Proposed Action (Map 1 of 2) in Appendix A of the EA, as

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well as on the Arnold Valley USGS 7.5-minute quadrangle, the geologic map in the Report of Investigations 13 (Division of Mineral Resources), and the Natural Resources Conservation Service (NRCS) soils maps. Because of the close proximity of Unit 4 to the unnamed tributary on the Reynolds property and also because Unit 4 is partially within the same karst terrain in the watershed for the unnamed tributary, it is logical to deduce that there will be negative impacts to the unnamed tributary due to the proposed timbering project. During the site visit on May 11, 2015 to the Reynolds property, numerous seeps and springs were observed in the karst terrain in ravines in the lower forested areas and also directly into the unnamed tributary on the property. A notably large spring, indicated as “Big Spring” on Figure 1, was reported by the property owner to have been considered for development by the county as a public water source, was observed in the lower portion of the property. The general climate pattern in the study area causes moist air masses to move mostly from west to east across Virginia, condensing to form precipitation as the air masses rise over the mountains. The forested ridges intercept the rainfall, allowing the rain to fall gently to the land surface. Surface runoff is thereby reduced and the rain is thus allowed to penetrate the ground to recharge groundwater. The water table, which refers to the groundwater surface, fluctuates depending on the amount of precipitation penetrating the ground. It is reported in the Draft Virginia Stormwater Management Handbook, 2nd Edition, 2013 that in Virginia, there has been an increase in the frequency of extreme precipitation events since 1948, along with an increase in the intensity and duration of drought periods. The result is that soil moisture is being depleted, annual groundwater recharge is decreasing, and runoff from hardened dry soil surfaces is increasing. Stream water and groundwater form one integral unit. When streamwater is low, due to droughts or ineffective stormwater management, groundwater continues to supply water as a sustaining base flow to the streams to support aquatic organisms. The observed trend of decreased groundwater recharge indicates there is less groundwater available to supply a sustaining base flow to the streams. In its document, “Sustainability of Ground-Water Resources”, the USGS emphasizes “Groundwater is not a renewable resource”. To understand this statement requires an understanding of the global water budget and also an understanding that groundwater and surface water are connected as one integral system. The global water budget, or hydrological cycle, consists of precipitation, evaporation, and condensation. It is important to recognize, however, that the hydrological cycle over the ocean (covering approximately three-quarters of the earth) is essentially separate from the hydrological cycle over the continents. Dennis Hartmann, in his book “Global Physical Climatology”, provides an excellent explanation of the global water budget. Through time, there has been a delicate balance of the amount of precipitation transferred to the continents from the hydrological cycle over the oceans and the amount of surface water flowing

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into the ocean. When groundwater recharge is reduced and streamflow into the oceans is increased, a situation is created where there is no longer a balance: when streamflow to the oceans exceeds the amount of precipitation from the oceans back onto the continents, the water in the continental hydrological cycle is lost forever. Because the Reynolds property and the lower portion of Unit 4 are underlain by dolomite and limestone and because there are nearby caves, there are special concerns about the interconnection between surface water and groundwater in the study area. As explained in the publication, “Select Karst Features of the Valley and Ridge Province, Virginia” (by David A. Hubbard, Jr., 1988, Publication 83, Virginia Division of Mineral Resources), there is a loss of buoyancy when the soils overlying karst areas are desaturated. Extreme fluctuations in the water table caused by periods of intense precipitation alternating with periods of drought result in subsidence and sinkhole collapse due to the loss of buoyancy. Additionally, underground sedimentation increases during times of a low water table, such that the sediments migrate downward into the voids. When the water table subsequently fluctuates to higher levels, the sediments cause turbidity in the groundwater, which increases the sediment load in down-gradient springs. Deposition of sediment within the karst aquifer also results in a reduction of the groundwater storage capacity, resulting in less sustaining base flow to streams during times of low stream levels. TIMBERING IMPACTS AND HYDROLOGIC COMPUTATIONS Impacts of timbering operations are explained in detail in the EA on pages 36-39. Detrimental impacts include 1) soil compaction; 2) soil erosion; 3) reduction of water storage by trees; 4) loss of protective tree canopy shading with subsequent higher temperature fluctuations in headwater areas; and 5) increased soil acidification. These negative impacts are considered below. Soil Compaction and Soil Erosion It is stated in the EA (p.36) that soil compaction causes increased water runoff. This results in increased erosion. It is also stated in the EA (p.36) that loss of tree canopy causes soils to be exposed to increased raindrop impact and increased overland water flow, both of which result in increased erosion. Whereas the erosion caused by soil compaction and increased raindrop impact is predicted by the FS to last only as much as 3 years, there is no consideration given to the impacts of increased stormwater discharge to downstream areas. When stormwater discharge increases, there is a subsequent increase in water quantity and water velocity, which causes erosion of stream banks downstream. The stream bank erosion releases sediment into the stream, with the result of negative impacts to aquatic organisms and to aquatic habitats.

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The FS, on p.25 of the EA, provides in “Table 3.1 Potential Sediment Production (tons) by Alternative” estimates of direct sedimentation to streams, resulting from timbering operations. Also, statements (EA, p.25) are provided that, “Sediment is not expected to have any long-term cumulative effect. Short-term increases in sediment, both in suspension and as bedload, are not expected to have any effect on channel condition.” These statements do not include the embeddedness of sediments in the channel. Embeddedness increases when smaller-sized sediments, such as sand, silt, and clay, are deposited in openings of larger-sized sediments, such as gravel and cobbles. Aquatic organisms use the openings among gravel and cobbles as habitat. When the smaller-sized sediments fill the spaces among the gravel and cobbles, aquatic habitats are destroyed. In the river continuum concept, aquatic organisms in the headwaters and upper reaches of a river or stream constitute functionality within the food-chain of the river or stream. There will be cumulative impacts from sedimentation in the stream due to embeddedness and destruction of aquatic habitats. The EA (p.25) includes statements about direct sedimentation to the streams, but does not include the concern about increased stormwater discharge, which will cause stream bank erosion, and thus sedimentation, downstream of the disturbed timbering area. The U.S. Environmental Protection Agency recognizes that stormwater discharge from a 10 percent impervious ground cover results in degradation to the water resources within the watershed. The stormwater discharge resulting from a 10 percent impervious cover within a watershed serves as a threshold discharge to evaluate the stormwater discharge from the ground cover resulting from timbering operations within the delineated watershed (Figure 1). A comparison of the stormwater discharge resulting from a 10 percent impervious area and that of existing ground covers and the proposed timbering area within the delineated watershed indicates that timbering of Unit 4 will result in negative impacts to the water resources. Table 1 provides hydrologic computations for the watershed of the first-order unnamed tributary on the Reynolds property. The Reynolds property and Unit 4 are within the delineated watershed, which is approximately 157 acres. A comparison of the stormwater discharge resulting from a 10 percent impervious area and that of existing and the proposed timbering area Unit 4 within the delineated watershed indicates that timbering operations in Unit 4 will result in negative impacts to the water resources. The Rational Method is appropriate for determining stormwater discharge in drainage basins up to 200 acres, as recommended in the Virginia Department of Transportation Drainage Manual, 2002 (Drainage Manual). The equation used in the Rational Method is: “Q = CiA”, where “Q” is the stormwater discharge in cubic feet per second (cfs), “C” is the runoff coefficient designated for differing ground covers, “i” is the rainfall intensity, and “A” is the drainage area in acres.

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Runoff coefficient values represent an empirical, dimensionless ratio between rainfall and runoff. Rational Method runoff coefficients in the Drainage Manual are provided not only for ground cover, but also for percent slope. The Rational Method runoff coefficient is 0.30 for woodlands cover where the percent slope exceeds 6 percent, which is the case for the delineated watershed. The coefficient value selected as appropriate for Unit 4 after timbering operations is 0.70, taking into account the steep slopes and the soils compacted by heavy equipment. The value selected for impervious areas is 0.80 because this would be equivalent to the less sloping area developed for industrial and commercial use. The value selected for the pastures adjacent to the unnamed tributary, which approximates the area of the Reynolds property, is 0.35 because of the lower slope percents. The Drainage Manual uses the following equation for average rainfall intensity: i=B/(tc + D)E. These values are derived from intensity-duration-frequency curves (IDF) provided by the National Oceanic and Atmospheric Administration (NOAA). The Drainage Manual presents a table of B, D, and E factors that provides values to be used in the equation for every county in Virginia. The B, D, and E factors change according to a return storm event. Computations were performed for a 2-year, 1-hour storm event and a 10-year, 1-hour storm event, selected to determine the rainfall intensity value in Rockbridge County from the B, D, and E factor table. The values were used in the rainfall intensity equation to determine that the average rainfall intensity for a 2-year, 1-hour storm event is 1.23 inches per hour (in/hr) and for a 10-year, 1-hour storm event is 1.85 inches per hour (in/hr). The watershed for the unnamed tributary to Elk Creek was delineated using the Terrain Navigator Pro topographic map software. Tools provided in this software allow the acreage to be determined for delineated areas. The acreage for Unit 4 was provided as approximately 19 acres in the EA (p.3) and was plotted on maps provided herein based on map provided in the EA as “Appendix A, Gilmore Hollow Vegetation Project, Alternative 2-Modified Proposed Action (Map 1 of 2)”. The approximate location and acreage of the Reynolds property on maps herein are based on deed plats of the Reynolds property provided by Rockbridge County. Computations for each ground cover set are provided in Table 1. A comparison of the discharge using a ten percent impervious ground cover area to that using the post-construction ground covers indicates that the stormwater discharge after timbering operations of Unit 4 is equal to that of the discharge using a ten percent impervious ground cover. Therefore, the timbering operations on Unit 4 would cause negative impacts to the watershed.

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Table 1 – Computations for stormwater discharge. Stormwater Discharge (Q) Calculations

Computations for weighted C

Computations of CiA for 1-hour, 10-year event: with i = 1.85 in/hr

Computations of CiA for 1-hour, 2-year event: with i = 1.23 in/hr

Stormwater Q for woodlands cover (C = 0.30) of the 157 acres

0.30 x 1.85 x 157 = 87.135 cfs

0.30 x 1.23 x 157 = 57.93 cfs

Stormwater Q for weighted C with 15.7 acres of 10% impervious area cover (C = 0.80) and the remainder of woodlands (106.3 acres) and pasture cover (35 acres with C = 0.35)

[(0.80 x 15.7) + (0.30 x 106.3) + (0.35 x 35]/157 = 0.36

0.36 x 1.85 x 157 = 104.56 cfs

0.36 x 1.23 x 157 = 69.52 cfs

Stormwater Q for weighted C with ground cover after proposed deforestation (C = 0.70 for 19 acres) and the remainder of woodlands (103 acres) and pasture (35 acres).

[(0.70 x 19) +( 0.30 x 103) + (0.35 x 35]/157 = 0.36

0.36 x 1.85 x 157 = 104.56 cfs

0.36 x 1.23 x 157 = 69.52 cfs

Reduction of Water Storage by Trees The EA (p.27 and 36) mentions evapotranspiration of trees with respect to the impacts on soil moisture due to deforestation. It is stated that evapotranspiration is expected to return to pre-deforestation conditions within 10 years after the timbering operations are conducted. The EA does not mention the water storage function of trees with respect to climate change. Trees can store hundreds of gallons of water which is released to the atmosphere by evapotranspiration. In the “Dynamics of Transpiration, Sap Flow, and Use of Stored Water in Tropical Forest Canopy Trees” (by Frederick C. Meinzer, Shelley A. James, Guillermo Goldstein; 2004; Tree Physiology 24, 901–909), it is stated that, “Stomatal coordination of vapor and liquid phase resistances played a key role in limiting stored water use to a nearly constant fraction of total daily water use.” Water vapor constitutes the largest percentage of greenhouse gases (https://www.ncdc.noaa.gov/monitoring-references/faq/greenhouse-gases.php). While it is certainly not the only regulatory factor of the amount of water vapor in the atmosphere, evapotranspiration is a factor in the regulation of the amount of water vapor in the atmosphere.

Loss of Protective Tree Canopy Shading In “The River Continuum Concept” (by Vannote, R.L., G. W. Minshall, K.W. Cummins, J.R. Sedell, and C.E. Cushing. 1980. Canadian Journal of Fisheries and Aquatic Sciences 37:130-137), tree canopy shading in headwater areas is shown to be essential for aquatic organisms at the base of the river-continuum food chain to survive. In the headwater areas, consisting of springs and seeps, of first-order streams, such as the unnamed tributary on the Reynolds property,

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specific insect larvae function to break down detritus in shaded areas within forests. These insect larvae, mostly caddisflies which are defined as shredders, require adequate moisture and shaded areas that provide cooler temperatures. The EA (p.36) indicates that timbering operations would destroy tree canopy, which would not be restored for up to 10 years. Such destruction of the caddisfly habitat would have cumulative negative impacts on the unnamed tributary on the Reynolds property and also on the Elk River into which the unnamed tributary flows. Increased Soil Acidification In the EA (p.38-39), modeling is used to determine the potential increase or decrease in the acid neutralizing effect of streams exposed to atmospheric acid deposition. It is stated that, “No soil chemistry data are available for the project area, so the percent base saturation is unknown.” The referenced models are detailed in “Effects of climate, land management, and sulfur deposition on soil base cation supply in National Forest in the Southern Appalachian Mountains”, by McDonnell T.C., Sullivan T.J., Cosby B.J., Jackson W.A., and Elliott K.J. 2013. Water Air Soil Pollution 224: 1733. In this publication, it is stated that when timber operations result in removal of the trees, the source of base cations is removed and the result is greater acidification of the soil and groundwater. The negative impacts of this process are: 1) the introduction of greater acidity to the underlying limestone, which will result in accelerated dissolution of the limestone, causing a change in the groundwater characteristics; and 2) greater acid groundwater will introduce more acidic water during times of base level flow to the unnamed tributary and to Elk Creek. An increase in the groundwater flowing through the underlying limestone will result in more numerous sinkholes and a change to the environmental conditions within nearby caves. More acidic base level flow to streams will create conditions that are not conducive for a trout fishery. Because Elk Creek has been identified as suitable for a stockable trout fishery, this would be a lasting negative environmental impact to Elk Creek. Trout require calcium in order to reproduce. CONCLUSION Based on 1) observations made during the site visit on May 11, 2015; 2) a study of published scientific data for the site; and 3) calculations determining stormwater discharge quantities under various conditions, Unit 4 should be not be subject to timbering operations. Timbering operations were conducted within the past 20 years on FS property adjacent to Unit 4. Since that time, Mr. Reynolds observed sinkhole formation on the timbered FS property and has also observed increased sinkhole development and increased erosion on his property. Mr. Reynolds is concerned that if Unit 4 is timbered, there will be even further sinkhole development and greater erosion on his property. Results of the

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hydrogeological study of the watershed encompassing the proposed FS Unit 4 deforestation, the Reynolds property, and the unnamed tributary to Elk Creek indicate there will be negative impacts from timbering operations in Unit 4. The Reynolds property and most of Unit 4 are underlain by the Shady limestone, which consists of limestone and dolomite bedrock. Shady limestone bedrock consists predominantly of calcium carbonate (limestone) and calcium magnesium carbonate (dolomite). Within the delineated watershed, the soils overlying the Shady limestone exhibit numerous seeps, springs, and sinkholes. Additionally, there are nearby caves which have formed in the Shady limestone. Groundwater flow through the Shady limestone maintains the cave environments and also provides base level flow to the unnamed tributary and to Elk Creek during times of low water. Timbering operations in Unit 4 will result in increased acidity of the groundwater, which will increase the acidity of Elk Creek, with the result of harming trout reproduction. Elk Creek has been recognized as a stockable trout fishery. Increased acidity in the groundwater will also cause a change in the associated cave environments, potentially harming cave life. This would be a violation of the Virginia Cave Protection Act. The increased groundwater acidity would cause more dissolution of the limestone, creating more sinkholes and allowing more sedimentation within the voids within the limestone. Increased sediment in the voids would be transported to the streams by springs, causing additional sedimentation within the unnamed tributary and also within Elk Creek, further degrading aquatic habitat conditions by increased embeddedness. Hydrologic computations demonstrate that the watershed encompassing the proposed FS Unit 4 deforestation, the Reynolds property, and the unnamed tributary to Elk Creek will be negatively impacted by timbering operations within Unit 4 because the increase in stormwater discharge will result in stream bank erosion and sedimentation within the unnamed tributary and within Elk Creek. Increased surface water discharge also results in decreased groundwater recharge. Negative impacts to groundwater base flow to the unnamed tributary and to Elk Creek would result from decreased groundwater recharge. In summary, it is recommended that the FS exclude Unit 4 from timbering operations because of the negative impacts that will result to surface and groundwater resources. Negative impacts include: 1) increased stormwater discharge that will cause stream bank erosion and sedimentation in the unnamed tributary and Elk Creek; 2) decreased groundwater recharge; 3) changes in groundwater flow in the karst area underlying the Reynolds property and Unit 4, including cave locations which are protected by the Virginia Cave Protection Act; 4) reduced base level groundwater flow to the unnamed tributary on the Reynolds property and Elk Creek; 5) increased soil acidity which will increase dissolution of the karst area underlying the Reynolds property and Unit 4; 6) decreased base cations and increased acidity to Elk Creek; and 7) decreased tree canopy which will damage habitats of insect larvae in seeps and springs of the headwaters of the unnamed tributary.

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Curriculum vitae for

Pamela Crowson Dodds, Ph.D., R.P.G. P.O. Box 217

Montrose, WV 26283 (304) 823-1095

My education includes a bachelor’s degree in Geology and a doctoral degree in Marine Science (specializing in Marine Geology), both from the College of William and Mary in Williamsburg, VA. I have a Credential in Ground Water Science from Ohio State University and I am a Registered Professional Geologist. I have held teaching positions at the high school level and at the college level, and have taught geology and hydrogeology workshops and classes to state and federal environmental employees and participants in the West Virginia Master Naturalist classes. As a Senior Geologist for the Virginia Department of Environmental Quality (1997-1999), I determined direction of groundwater flow and the pollution impacts to surface water and groundwater at petroleum release sites and evaluated corrective actions conducted where petroleum releases occurred. At sites where the Commonwealth of Virginia assumed responsibility for the pollution release investigation and corrective action implementation, I managed the site investigations for the Southwest Regional Office of the Virginia Department of Environmental Quality (DEQ). This included project oversight from contract initiation through closure. As a Senior Geologist and Project Manager for the Environmental Department at S&ME, Inc. (Blountville, TN, 1992-1997), I conducted geology and groundwater investigations. I supervised technicians, drill crews, geologists, and subcontractors. The investigations were conducted in order to obtain permits for landfill sites and to satisfy regulatory requirements for corrective actions at petroleum release sites. My duties also included conducting geophysical investigations using seismic, electrical resistivity, and ground penetrating radar techniques. I conducted numerous environmental assessments for real estate transactions. I also conducted wetlands delineations and preparation of wetlands mitigation permits. As the District Geologist for the Virginia Department of Transportation (1985-1992), my job duties included obtaining and interpreting geologic data from fieldwork and review of drilling information in order to provide foundation recommendations for bridge and road construction. My duties included supervision of the drill crew and design of asphalt and concrete pavements for highway projects. Accomplishments included preliminary foundation investigations for interstate bridges and successful cleanup of leaking underground gasoline storage tanks and site closure at numerous VDOT facilities. While earning my doctoral degree at the College of William and Mary, I worked as a graduate assistant on several grant-funded projects. My work duties included measuring tidal current velocities and tidal fluctuations at tidal inlets; land surveying to determine the geometry and morphology of numerous tidal inlets; determining pollution susceptibilities of drainage basins using data from surface water flow parameters,

hydrographs, and chemical analyses; developing a predictive model for shoreline erosion during hurricanes based on calculations of wave bottom orbital velocities resulting from various wind velocities and directions; performing sediment size and water quality analyses on samples from the Chesapeake Bay and James River; conducting multivariate statistical analyses for validation of sediment laboratory quality control measures; reconnaissance mapping of surficial geologic materials in Virginia, North Carolina, and Utah for publication of USGS Quaternary geologic maps; teaching Introductory Geology laboratory classes at the College of William and Mary; and serving as a Sea Grant intern in the Department of Commerce and Resources, Virginia. EDUCATION: College of William and Mary Williamsburg, VA 23185 Ph.D., 1984 Major: Marine Science (Marine Geology) College of William and Mary Williamsburg, VA 23185 B.A., 1972 Major: Geology Flint Hill Preparatory Fairfax, VA High School Diploma, 1968 JOB-RELATED TRAINING COURSES: 2007: Certified Volunteer Stream Monitor, West Virginia (Dept. of Environmental

Protection) 2006: Certified Master Naturalist, West Virginia (Dept. of Natural Resources) 1996: Karst Hydrology, Western Kentucky University 1996: Global Positioning Systems (GPS) for Geographic Information Systems

(GIS) applications, seminar conducted by Duncan-Parnell/Trimble 1995: Safe Drinking Water Teleconference, sponsored by the American Water

Works Association 1992-1998: OSHA Hazardous Waste Site Supervisor training with annual

updates 1990: Credential in Ground Water Science, Ohio State University JOB-RELATED LICENSE: Registered Professional Geologist: TN #2529 PROFESSIONAL ORGANIZATION West Virginia Academy of Sciences