Botanical Resources Report 2015 SW Oregon Mineral Withdrawal

Botanical Resources Report: Threatened, Endangered, Sensitive (TES) and Survey and Manage (SM) /Fungi; Invasive Plants; Botanical Areas, Research Natural Areas and Areas of Critical Environmental Concern

2015 Southwestern Oregon Mineral Withdrawal Rogue River-Siskiyou National Forest, Bureau of Land Management Medford and Coos Bay Districts

A hanging fen populated by along Pack Saddle Gulch, a tributary to the N. Fork Smith River

/s/ Clint Emerson Date: March 10, 2016 Clint Emerson, Rogue-River Siskiyou Forest Botanist /s/ Bryan Wender Date: March 10, 2016 Bryan Wender, Medford BLM District Botanist

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Botanical Resources

Introduction The Southwestern Oregon Watershed and Salmon Protection Act of 2015 (S. 346 and H.R. 682) was introduced to Congress on February 3, 2015, proposing to withdraw certain lands in Curry County and Josephine County, Oregon from all forms of mineral entry, appropriation, or disposal under public land laws, subject to valid existing rights. This proposed legislation includes federally owned land within the area depicted on two maps submitted with the draft legislation. The areas include approximately 5,216 acres of BLM-managed public domain and revested Oregon California Railroad lands (O&C), and 95,806 acres of National Forest System (NFS) lands. As a result of the legislative proposal, the Assistant Secretary of the Interior for Land and Minerals Management published a Notice of Proposed Withdrawal and Notification of Public Meetings in the Federal Register on June 29, 2015. The notice segregates for two years the described lands from settlement, sale, location, and entry under the public land laws, location and entry under the United States mining laws, and operation of the mineral and geothermal leasing laws. The purpose and need of the proposed 5-year temporary withdrawal is to maintain the current environmental baseline, relative to mining, mineral exploration and development, and geothermal energy development, while Congress considers legislation enacting a permanent withdrawal from mineral entry for the federal lands depicted on the official maps.

Proposed Action: 5-year Mineral Withdrawal The Forest Service and BLM propose a 5-year withdrawal from location and entry under the United States mining laws, and operation of the mineral and geothermal leasing laws for approximately 5,216 acres of BLM-managed public domain and revested Oregon California Railroad Grant lands and 95,806 acres of National Forest System lands in Josephine and Curry Counties. An additional 1,680 acres of non-federal lands included in the external boundaries of the maps would not be affected. Under withdrawal, no new mining claims may be located, mineral entry would be prohibited, and no mineral leasing is allowed. Withdrawal from operation under the mining and mineral leasing laws is subject to valid existing rights (VER). Existing mining claims may be developed after a minerals validity examination determines that a discovery of a valuable mineral deposit existed at the time of the segregation. No other land management activities are affected by withdrawal from mineral entry. The duration of the requested withdrawal is five years. At the end of this period, the BLM will reevaluate the withdrawal concerning the desirability and justification for extending the withdrawal for an additional period.

Alternative Action: 20-year Withdrawal In response to public input received during the 90-day comment period, we will analyze withdrawal for a 20-year period. This alternative is the same in detail as the proposed action, except for the extended time period.

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No Action: No Mineral Withdrawal Withdrawal from location and entry under the mining laws and operation of the mineral and geothermal leasing laws would not occur, and the current segregation would end with the Secretary’s decision.

New mining claims could be established, and proposed plans of operation and notices of intent could be submitted. The agencies would proceed with evaluating and authorizing previously submitted PoOs, subject to site-specific NEPA analysis including specified mitigations and project design criteria for mining and mineral development.

Suction-dredge operations could occur outside of the streams currently covered by the State of Oregon’s moratorium on motorized placer mining (Oregon Senate Bill 838, July 2013) and on all streams within the project area after the moratorium expires in January 2021.

Regulatory Framework

Threatened, Endangered and Sensitive Plants and Fungi Section 7 of the Endangered Species Act of 1973 provides the impetus for language in Forest Service Manual (FSM) sections 2670.31 and 2670.32 which outline objectives at a national level for the management of threatened, endangered and sensitive and fungi species on USFS lands. The objectives are explicit in their intent to inform forest level management plans leading to the following forest-wide standards and guidelines within the 1989 Siskiyou National Forest Land and Resource Management Plan (SLRMP) for plant species of conservation concern (see SLRMP IV 26-27, 37). SLRMP Standards and guidelines applicable at the project level include: 1. Monitor the effects of management activities on TES plant species. If the results of monitoring show a decline in species viability then, alter the management strategy. 2. Analyze the potential effects of all ground disturbing projects on TES plant species and habitat. Mitigate project effects to avoid a decline in species viability at the Forest level. 3. Map, record, and protect essential habitat for TES plant species. Species management guides should be prepared to address the effects of land management activities on local populations of TES at a broader scale, and to identify opportunities to enhance and develop habitat locally. Similarly, for lands managed by the Bureau of Land Management, the District Records of Decision (ROD) and Resource Management Plans (RMP) provide management direction relevant to the proposed action. Management direction provided in the Medford District ROD/RMP (BLM 1995a) includes: 1. Protect lands that have important resource values or substantial levels of investment by withdrawing them, where necessary, from the implementation of nondiscretionary public land and mineral laws (p. 49). 2. Manage for the conservation of Bureau Sensitive species and their habitats. Study, maintain, or restore community structure, species composition, and ecological processes of special status plant and animal habitat (p. 51). 3. Maintain, protect, or restore relevant and important values of Areas of Critical Environmental Concern (p. 56.)

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The Coos Bay District ROD/RMP also provides management direction to maintain, protect, or restore relevant and important values of Areas of Critical Environmental Concern (BLM 1995b, p. 38).

Survey and Manage Plants and Fungi The 1993 Final Supplemental Environmental Impact Statement (FSEIS) and 1994 Record of Decision for Amendments to Forest Service and Bureau of Land Management Planning Documents within the Range of the Northern Spotted Owl (also known as the Northwest Forest Plan (NWFP)) created the survey and manage standard and guideline for all land allocations on the west side of the Cascades in Oregon, Washington and northern California and east Cascade forests within the range of the northern spotted owl. The standard and guidelines were created to gain information that could help manage a set of lesser known and possibly rare taxa. Species of fungi, lichens, bryophytes and vascular plants were included to determine the status of their population viability. The original survey and manage provision of the NWFP was amended in 2001 and 2004, then it was completely removed in 2007. A recent settlement agreement to a lawsuit (Conservation Northwest, et al. v. Sherman, et al., No. 08-1067-JCC (W.D. Wash.)) reinstated the program to the 2001 species list and level of management. On December 17, 2009, the U.S. District Court for the Western District of Washington issued an order in Conservation Northwest, et al. v. Sherman, et al., No. 08-1067-JCC (W.D. Wash.), granting Plaintiffs’ motion for partial summary judgment and finding NEPA violations in the Final Supplemental to the 2004 Supplemental Environmental Impact Statement to Remove or Modify the Survey and Manage Mitigation Measure Standards and Guidelines (USDA and USDI, June 2007). In response, parties entered into settlement negotiations in April 2010, and the Court filed approval of the resulting Settlement Agreement on July 6, 2011. Projects that are within the range of the northern spotted owl are now subject to the survey and management standards and guidelines in the 2001 ROD, as modified by the 2003 annual species review.

Invasive Species Policy Management direction on this subject is given in the Siskiyou NF LRMP under forest-wide standards and guidelines item 12-6: "Control of Invasive Plants should be accomplished in cooperation with state, county, and private organizations through Weed Control Districts or Coordinated Resource Management Agreements. Preventive management is critical to an effective control program." In addition, this document incorporates by reference the specific standards and guidelines described in the Pacific Northwest Region Invasive Plant Program Preventing and Managing Invasive Plants Record of Decision and Final Environmental Impact Statement Volumes I-III, 2005. The decision document amends the Siskiyou NF LRMP to include an updated set of information on preventing and managing invasive plant species in Region 6. Invasive Species Management, Forest Service Manual 2900, Amendment No. 2900-2011-1, effective December 5, 2011 outlines the objectives and policy established by the USDA to manage and restore impacts to USFS lands caused by invasive species. The objectives outlined include: 1. Prevention 2. Early Detection and Rapid Response (EDRR)

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3. Control and Management 4. Restoration 5. Organizational Collaboration

On BLM lands, direction on noxious weeds is provided by the ROD/RMP for each district. Management direction includes: 1. Survey BLM-administered land for noxious weed infestations 2. Apply integrated pest management methods 3. Place priority on elimination or reduction of noxious weeds occurring within special areas.

Affected Environment This analysis considers three elements of the affected environment that relate to conservation of botanical resources within the withdrawal area landscape: A. Species of vascular plants, bryophytes (mosses and liverworts), lichens and fungi that are of conservation concern within Region 6 (Pacific Northwest) of the Forest Service and by the BLM - Oregon/Washington State Director. B. Species of vascular plants which have been documented to be invasive to native ecosystems by the Oregon Department of Agriculture (ODA). C. USFS Botanical and Research Natural Areas (RNA) and BLM ACECs/RNA’s that occur within the area covered by the withdrawal. The overarching goal when managing botanical resources is maintaining ecological integrity at the landscape and plant community scales, with the underlying assumption being that if an ecosystem is functioning well, the finer scale more rare and biodiverse species associated with it will be too. The Rogue River-Siskiyou National Forest (RRSNF) and Medford and Coos Bay BLM lands within the withdrawal area encompass many biodiverse ecosystems. This fact is exemplified by the high number of species of conservation concern found on lands these agencies manage in this portion of Oregon. Over 400 such plant (vascular plants, mosses, and liverworts), fungi and lichen species are either documented or suspected to occur. Species of conservation concern include federally endangered, sensitive, survey and manage and strategic listed plants and fungi. Both mineral withdrawal areas in this proposal are geographically placed within the Klamath- Siskiyou ecoregion, a subdivision of the California Floristic Province. The high amount of plant endemism in the region is tied to the potential for mineral resource use. The complex geology lends to high levels of usable minerals and creates harsh conditions, with heavy metal laden soils and very low amounts of nitrogen and phosphorous. These conditions lead to adaptive traits in plant species that eventually result in narrow endemism. The region has been recognized for many years as a hotspot of biodiversity in North America (Whittaker 1960, Kruckeberg 2002).

Species of Conservation Concern: TES, SM, Strategic There are two federally endangered plant species (McDonald’s rockcress, macdonaldiana and Cooks , Lomatium cookii) that occur within the boundary of the Rough and Ready/Baldface withdrawal area (RBWA). High potential exists for McDonald’s rockcress to be

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found within unsurveyed habitat within the RBWA. There is lower potential to find new populations of Cook’s lomatium because of the limited distribution of habitat within the RBWA. Seventeen sensitive species (16 vascular plants and one liverwort) are known to occur in the RBWA. Potential habitat for threatened or endangered plants in the Hunter Creek-Pistol River withdrawal area (HPWA) is absent, subsequently no populations have been found. There are three sensitive vascular plants and one liverwort species that occur within the HPWA. In addition, one plant species (Erigeron stanselliae, Veva’s erigeron) was recently described as new to science (Chambers 2011). It is currently listed as strategic, which is a category that focuses on rare or new species with limited information on habitat or distribution. Much more information has been gathered on this species over the past five years which has informed the decision to add the species to the sensitive plant list during the next iteration in 2017. Considering the rarity of the species and the potential for mining impacts, this species has been included in this affected environment and will undergo an effects determination similar to sensitive species. Habitat for sensitive listed fungi does not occur within areas that could undergo mineral extraction, therefore no further analysis will be conducted for these species. Fungi diversity is highest in mesic old growth forests with high levels of downed wood and high rates of decomposition. The ultramafic serpentine soils where mineral extraction could occur within the withdrawal areas do not provide high potential habitat for any fungi species on the R6 sensitive list. This is not to say that rare fungi could not occur on serpentine soils, but none of the currently sensitive listed species could be found within areas where mining claims occur. The five survey and manage (SM) fungi species that occur in the HPWA were found in densely forested areas with no mining potential. These fungi species have been included here to provide a comprehensive list of botanical resources occurring within the overall mineral withdrawal area. They are not included with the intention to conduct an in depth effects analysis.

Table 1. Species of concern currently inhabiting the 2015 SW Oregon Mineral Withdrawal area. Taxa # of sites1 Listing Habitat and Distribution Vascular Plants HP2 RB3 On barren to shrub covered ultramafic derived soils. Most often found in rock crevices of outcrops and steep barren slopes but occasionally found mixed with sclerophyllous vegetation within Jeffrey pine woodland. Elevational range from 500 to 4000 feet. Range is confined to the heavily serpentinized bands of soil (Josepine ophiolite) located in Arabis Federally maritime influenced SW Oregon and NW California. Curry, macdonaldiana 0 2 Endangered Josephine Counties, Oregon. Del Norte Co. with a disjunct on McDonald’s rockcress Red Mtn in Mendocino County, CA. There are a total of 4 extant populations known on the RRSNF at the current time, 2 of which occur within this mineral withdrawal proposal. The 4 sites on RRSNF lands are likely the only populations in Oregon. The California Native Plant Society (CNPS) shows 17 extant sites in California.

1 Number of individual sighting reports per species for each mineral withdrawal area. Generally this corresponds to meta-populations, but may represent sub-populations within a meta-population. 2 Hunter-Pistol 3 Rough and Ready-Baldface

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Dry rocky ridges and gravelly soils, often on serpentine. In several instances it is found on the summit and south aspects of SW Oregon coastal peaks such as Mt. Emily, Grassy Knob, Signal Buttes, especially where recent fire has occurred Arctostaphylos (Emerson 2010). In these instances it is found in shrub hispidula Sensitive 10 2 communities or sparse forest likely to be growing with Gasquet manzanita Arctostaphylos columbiana. Primarily in Curry Co. with one population in Douglas Co. and up to two populations in Josephine Co., OR; extending south through Del Norte and Humboldt Counties with a disjunct population in Sonoma Co., CA. Serpentine soil, dry rocky slopes. Low to middle elevations, often on Ceanothus cuneatus covered slopes or in open Calachortus howellii Sensitive 0 43 Jeffrey pine stands. Local endemic restricted to the Illinois Howell’s mariposa-lily River Valley in Josephine County, Oregon. 1,600 to 3,800 feet (mean = 3,800 feet). Known from many Dry, open serpentine slopes. Most populations occur in an area just east of I-5 between Sexton Mtn. and Merlin. howellii Sensitive 0 1 Scattered outlying populations occur in the Illinois Valley. Howell’s camas Narrow endemic in SW Oregon known from10-15 populations. Sites on the RRSNF occur around 1,600 feet. Epilobium oreganum Darlingtonia fens and other wet serpentine areas at low Grants Pass willow Sensitive 0 8 elevations. Josephine Co., OR; scattered through the Klamath herb Mts. southward down into the Sierra’s to Lake Tahoe, CA. Maritime and serpentine influenced Jeffrey pine savanna. In open gravelly areas free of competition and usually surrounded by dense patches of Ceanothus pumilus, Arctostaphylos nevadensis and other sclerophyllous vegetation. Very rare globally with only two meta-populations Erigeron stanselliae Strategic4 2 0 known. Four sub-populations have been mapped within the Veva’s erigeron main meta-population. The other meta-population is very small and contains no sub-populations. There are an estimated 5,000 to 10,000 individual plants. Known from two populations separated by about 5-6 miles, entirely within the currently proposed PH withdrawal area. Curry Co., Oregon. Erythronium howellii Open woods, often on serpentine or along ecotone’s. Illinois Sensitive 0 9 Howell’s fawn lily Valley OR south to Trinity Mts. in CA. Serpentine fens often inhabited by Darlingtonia californica, setigera also in seeps and springs on slopes at elevations below 3,800 Waldo gentian Sensitive 3 21 feet. Known from Curry and Josephine Counties, Oregon; Del

Norte bracteosa Wet meadows, rocky seeps, serpentine Darlingtonia fens at var. bracteosa Sensitive 0 18 lower elevations. Illinois Valley Josephine Co., OR. Narrow Large flower rush lily endemic. Wet meadows, rocky seeps, serpentine Darlingtonia fens at var. atropurpurea Sensitive 0 10 lower elevations. Illinois Valley Josephine Co., OR. purple rushlily

Wet meadows, oak savannahs, vernal pools on valley floors. Lomatium cookii Federally 0 3 Illinois Valley, Josephine Co., OR, and Agate Desert, Jackson Cook’s lomatium Endangered Co., OR.

4 This species will become listed as sensitive during the next iteration of the Region 6 species of conservation listing process.

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Lomatium engelmannii Gravelly serpentine slopes in coniferous forest and open areas Engelmann’s desert Sensitive 0 1 at mid to high elvations (3,000-6,000). Sisiyou Mts. Josephine parsley Co., OR; Siskiyou and Trinity Cos., CA.

Dry openings, edges of forest, open woods, on granitic and Lupinus tracyi metavolcanic soils at mid to high elevations. Known from a Sensitive 0 1 Tracy’s lupine few sites in the Siskiyou Mts of Curry and Josephine Cos., OR; Siskiyous in CA.

Rocky, open serpentine scrub forest, chaparral, woodlands Monardella purpurea and montane forest, 1,400-4,000ft. Curry, Jackson and serpentine coyote Sensitive 0 35 Josephine Cos., OR; to central CA in Coast Range and mint Klamath Mts.

Vernally moist depressions in heavy, poorly drained soils. Oak Perideridia and Pine woodlands at low to mid elevations in the Cascades, erythrorhiza Sensitive 0 1 serpentine habitats in the Siskiyous. Douglas, Klamath, red root yampah Josephine and Jackson Cos., OR.

Found on granitic and moderately serpentinized soils within parvifolia open coniferous forest and shrub fields at mid elevations. Sensitive 0 4 Siskiyou fairy bells Global distribution is from 2 meta-populations and 7 sub- populations in Oregon and extant at 6 locations in California. Fire and disturbance follower on serpentine soils, chaparral, conifer forest; 100–800 m., Klamath Range SW OR NW CA. Silene serpentinicola Known from 1 site in Oregon within the N. Fork Smith River Strategic 0 1 serpentine campion watershed portion of the withdrawal on state lands (Emerson 2013). Known from 30 sites in California but many are sub- populations. Endemic to a roughly 30 square mile area. Dry rocky serpentine slopes in open conifer/ hardwood forests howellii Sensitive 0 24 from 1000 to 4500 ft. SW OR, NW CA. Scattered individuals Howell’s jewelflower occur over large areas in parts of this landscape. Viola primulifolia ssp. Serpentine influenced Darlingtonia fens at lower elevations occidentalis Sensitive 3 29 (<2,000 feet). Curry and Josephine Counties., OR; Del Norte western bog violet Co., CA. Bryophytes Usually restricted to fens containing Sphagnum. Also found in Calypogeia serpentine influenced Darlingtonia fens growing among other sphagnicola Sensitive 1 1 liverworts (Sphagnum not present). Circumboreal and bipolar. bog liverwort In the Pacific Northwest, known from British Columbia, Washington, Montana, and Oregon. Fungi Fruits in humus or soil and matures above the surface of the Ramaria SM-B 1 0 ground. Associated with Abies spp., Pseudotsuga menziesii, celerivirescens and Tsuga heterophylla. PNW Endemic.

Fruits in humus or soil and matures above the surface of the Ramaria SM-B 1 0 ground. Associated with Abies spp., Pseudotsuga menziesii cyaneigranosa and Tsuga heterophylla. Endemic to the Pacific Northwest. Fruits in humus or soil and matures above the ground, Ramaria stuntzii SM-B 1 0 associated with Pinaceae spp. Endemic to the Pacific Northwest.

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Hypogeous to emergent, scattered to grouped associated with Pinaceae species particularly Pinus spp. Occurs in Sierra, Rhizopogon truncatus SM-D 1 0 Siskiyou, and Cascade mountains of northern California into the central Oregon Cascades, also from North Carolina to Nova Scotia. Totals (22 species) 20 148

McDonalds rockcress (Arabis macdonaldiana) USFWS Endangered Species The US Fish and Wildlife Service (USFWS) formally listed McDonald’s rock cress as endangered in 1978 (43 FR 44810, 28 September 1978). Critical habitat was never designated for this species, but if it had been, it is likely that much of the RBWA would qualify. A conservation recovery plan was signed in 1984 (USFWS 1984) and focused on the single type locality collection made on Red Mountain in 1902 in Mendocino County, California. Due to taxonomic ambiguity (Goforth 1983) about specimens collected in Del Norte and Curry County in 1980, the recovery plan considered only the populations at Red Mountain to be the endangered species and the others to represent a similar yet separate taxon that did not warrant the same status. Goforth’s taxonomic assessment was never published in a peer reviewed journal leaving the populations found in Del Norte and Curry Counties in flux. The USFWS chose to consider these northern populations to be the same species that is found on Red Mountain because of an inability to clearly differentiate the species leading to a “similarity of appearance case”5. More recently, botanist Linda Vorobik has completed a genetic analysis (Vorobik 2012) of the entire purple-flowered Arabis group that includes McDonald’s rockcress along with other endemic Arabis occurring in NW California and SW Oregon. Her analysis supports similar findings as Goforth, that the Red Mountain collection is a distinct species. However, the report Vorobik submitted to the USFWS has yet to be published in a peer reviewed journal either. In May 2013 the USFWS issued a 5-year review (USFWS 2013) for McDonald’s rockcress. This was the first review since the species was originally listed in 1978. The 5-year review references Vorobik’s recent genetic work, concluding once again that the only endangered plants are those residing on Red Mountain in Mendocino County, California. The decision to exclude Del Norte, Curry and Josephine County populations was rescinded in 2014 after the USFWS received substantial public and intergovernmental comments and questions about why the normal procedures for removing populations from endangered listing were not followed, such as waiting for a formal peer reviewed publication that has wide acceptance in the scientific community. To date, no peer reviewed publication has materialized, leading the RRSNF to determine that populations of McDonald’s rockcress on Forest Service lands in Curry and Josephine County Oregon represent a federally endangered plant species. Currently within the RBWA there are two relatively small populations of McDonald’s rockcress totaling ~60 individual plants (genets) and covering one quarter to three quarters of an acre of land. Due to the remote, inaccessible and rugged terrain within the RBWA, very little survey effort has occurred. The fact that only two small populations have been found does not accurately represent the probable extent of the species within this area. Based on what is known about habitat for the species, it is likely that there are several hundred (possibly thousands) acres of

5 The Secretary may, by regulation of commerce or taking, and to the extent he deems advisable, treat any species as an endangered species or threatened species even though it is not listed pursuant to section 4 of this Act if he finds that such species so closely resembles in appearance, at the point in question, a species which has been listed pursuant to such section that enforcement personnel would have substantial difficulty in attempting to differentiate between the listed and unlisted species.

9 Botanical Resources Report 2015 SW Oregon Mineral Withdrawal suitable habitat within the RBWA. However, in 2014 roughly 1,000 acres were surveyed, as part of the Cleopatra Mine Plan of Operations (PoO), with no new sites of McDonald’s rockcress being discovered, even though the species was already known in the area. Part of the reason no new sites were found may be because the survey area encompassed a broad flat ridge. The two sites known in the RBWA occur on steep faces within crevices of rock outcrops. This habitat type was mostly lacking in the Cleopatra survey area. The main threat outlined in the 1984 recovery plan was mining. Over 30 years later mining still remains the principle threat to the conservation of the species. Limiting factors to ecological elements and variables considered imperative for conservation of the species are not well understood. Suitable intact soils and substrate are likely the most important component for establishment and persistence of given populations. McDonald’s rockcress is a narrowly endemic, edaphically adapted species, making soil/substrate integrity a high priority for conservation. Mining presents the greatest risk due to actions that dig, displace and uproot vegetation and associated substrate. Many areas within the withdrawal area have undergone historic mining. These historically mined areas offer an opportunity to observe past impacts and the ability of these specific ecosystems to recover given a period of time (up to 100+ years in some areas). Anecdotal observations of past mining suggests that, due to the unique and fragile characteristics of the ultramafic influenced ecosystems within the withdrawal areas, recovery from past mining is either impossible or may take hundreds to possibly thousands of years. A threat more recently observed is the impact of increased density of knob cone pine (Pinus attenuata) at the type locality site on Red Mtn. in Mendocino County, California (USFWS 2013). Increased competition caused by fire exclusion poses a threat within populations that occur amongst forest and sclerophyll vegetation. The two populations within RBWA occur on rock outcrops nearly devoid of any other plant species. Fire exclusion may possibly be indirectly affecting the species through decreased dispersal, leading to genetically impoverished populations from excessive self-pollination, but information on dispersal mechanisms is lacking. The 1984 recovery plan for the species outlined these specific actions to assist with conservation: 1. Enforce existing laws and policies that assist in conservation of the species 2. Protect essential habitat a. Identify essential habitat i. Determine the stability of populations 1. Examine seed production, seedling survival and germination in the field 2. Examine pollinators and their habitat needs 3. Investigate plant animal interactions ii. Seek additional populations where habitat data can be collected b. Manage essential habitat i. Identify and evaluate protection alternatives ii. Determine authority for regulating mining in endangered species habitat iii. Evaluate and monitor threats from mining

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1. Determine portion of known range currently under mining claims 2. Determine extent of habitat likely to be affected if mining were to occur and the degree to which impacts would be realized iv. Develop and implement a management plan 3. Monitor agency compliance with the recovery plan 4. Enhance public awareness about the need to recover McDonald’s rockcress Based on currently available information very few of these actions have been implemented. The 5-year action plan released in 2013 discusses several efforts to monitor populations on Red Mtn. but nothing is mentioned about the northern populations in Del Norte, Curry and Josephine Counties. RRSNF monitoring for McDonald’s rockcress has periodically occurred over the past 25 years. Methods are coarse, with populations being revisited and then an exact or estimated census of individual plants (genets) taken. The data do not provide for statistical analysis of demographic population trends. Results include realizing that two of the occurrences in Curry County can no longer be located (Red Mountain, Curry Co. and 1107-220 road population). All other populations (four) have been relocated and censed within the past ten years.

Cook’s lomatium (Lomatium cookii) USFWS Endangered Species Cook’s lomatium was federally listed as endangered in 2002 (Federal Register 67:68004-68015). Critical habitat was designated in 2010 (Federal Register 75:42490-42570). Recovery actions were detailed in 2013 in the Recovery Plan for Rogue and Illinois Valley Vernal Pool and Wet Meadow Ecosystems (USFWS 2012). A perennial forb in the carrot family (), Cook’s lomatium grows 15-50 cm tall, from a slender, twisted taproot. Leaves are smooth, finely dissected, and strictly basal (growing directly above the taproot on the ground, not along the stems). One to four groups of clustered, pale yellow flowers produce boat-shaped fruits 8-13 mm long with thickened margins. The taproot can often branch at ground level to produce multiple stems. Flowering stems emerge from a rosette of leaves in late February, with flowers appearing in mid-march and blooming until mid- May. As with many Lomatium species, the earliest flowers are usually staminate, while the later umbels have both staminate and hermaphroditic flowers. The distribution of the species is disjunct, occurring in the Agate Desert of Jackson County on the edge of vernal pools and 40 miles to the southwest in the Illinois Valley in seasonally wet grassy meadows, oak woodlands, and serpentine meadow and shrub habitats. The species is known from 13 occurrences in the Agate Desert and 24 occurrences in the Illinois Valley. The largest occurrence is at French Flat ACEC which is estimated to have 132,615 plants (Pfingsten et al. 2012). No populations have ever been found between the Illinois Valley and Agate Desert populations either along the Rogue River or in alluvial areas along the lower Applegate River. Most of the habitat between these populations is on non-federal lands, and has been heavily modified by rural development. Undiscovered populations between the Agate Desert and the Illinois Valley occurrences are unlikely. The Illinois Valley sites are alluvial in nature within serpentine substrates and serpentine- influenced vegetation communities. Seasonally wet meadows are dominated by California oat- grass (Danthonia californica), typically occurring within Oregon white oak – ponderosa pine (Pinus ponderosa)/Jeffery pine (Pinus jeffreyi) savanna. An open shrub layer comprised of

11 Botanical Resources Report 2015 SW Oregon Mineral Withdrawal wedge-leaf ceanothus and manzanita is interspersed with native and introduced grasses and forbs. One Illinois Valley site occurs in an Oregon white oak savannah on shallow to moderate slopes. Cook’s lomatium and its critical habitat in the Illinois Valley are threatened by mining, rural development, illegal dumping, and recreational use. Several populations on BLM lands have been impacted by off-road vehicles and trash dumping. Placer gold mining has restricted available habitat of a population at French Flat and altered natural hydrologic patterns through the wet meadows. The 2012 Recovery Plan identifies actions to assist with protection and recovery of the species and its critical habitat: 1. Protect vernal pool and wet meadow habitat from loss, fragmentation, degradation, and incompatible uses. 2. Manage, monitor, and restore vernal pool and wet meadow habitat. 3. Conduct rangewide population status surveys. 4. Conduct research essential to the conservation of the species. 5. Enhance public awareness and participation in recovery of the species. 6. Develop post-listing monitoring plans. To date, several of the actions have been implemented on the Medford BLM District. French Flat ACEC, Rough and Ready ACEC, and Woodcock Bog RNA were designated as special management areas, in part, to protect this species and its habitat from incompatible uses. Two additional proposed ACECs, Reeves Creek and Waldo-Takilma, are currently in interim management status for protection of Cook’s lomatium. In 2014, Medford District also began implementing the Cook’s lomatium Habitat Management Project (BLM 2014) to improve habitat conditions and reduce impacts from off-road vehicles on 180 acres of critical habitat. To date, approximately 90 acres have been treated, including 25 acres in Rough and Ready ACEC, within the RBWA.

Narrow Endemics and Darlingtonia Fen Associates Nearly all the sensitive listed plants in the table above represent plant species with global ranges that are extremely narrow when compared to most vegetation on the landscape. The RBWA represents a considerably diverse area with probably the highest concentration of plant species of conservation concern in the state and possibly the country. Many factors combine to create this hotspot for biodiversity. Geology and soils play a huge role, and as already mentioned, create a potential conflict with conservation because of the potential mineral values attracting mining interest. Climate is another big factor because of the dramatic gradient from maritime influenced serpentine areas to arid rain shadowed valleys. The diversity in environmental variables and habitats, coupled with relict species from previous geologic times, has resulted in an endemic rich flora. Several species within this mineral withdrawal are known from very few sites globally. The most narrowly distributed of these endemic species include: 1. Camassia howellii (Howell’s camas); known from 10-15 populations worldwide 2. Erigeron stanselliae (Veva’s erigeron); known from 2 populations worldwide 3. Hastingia bracteosa var. purpurea (purple flowered rush lily); known from 21 populations worldwide

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4. Prosartes parvifolia (Siskiyou bells); known from 8 populations worldwide An exemplary example of niche-specific habitat is the serpentine fens that form on terraces above steep, narrow stream channels within some of the drainages in both withdrawal areas. Dominated by the insectivorous , Darlingtonia californica (pitcher plants or cobra lily), these ecosystems represent refugia for hydrophilic species within a harsh, dry landscape. The fens stay wet all season long while the surrounding landscape dries considerably for at least five months of the year. The consistent moisture in the soils creates anaerobic conditions that lead to little to low decomposition rates and high accumulation of organic matter in the form of deep mud or muck with very low nutrient content (Jules et al. 2011). Many species of conservation concern rely on these unique fen habitats: 1. Epilobium oreganum (Grants Pass willow herb) 2. (Mendocino gentian) 3. Hastingia bracteosa var. bracteosa (large flowered rush lily) 4. Hastingia bracteosa var. atropurpurea (purple flowered rush lily) 5. Viola primlifolia ssp. occidentalis (western bog violet) 6. Calypogeia sphagnicola (bog liverwort) The exact number of Darlingtonia fens within the withdrawal area is unknown. Based on the number of populations of these species it is estimated that there could be between twenty to thirty Darlingtonia fens within the subject area. Not all sites where these rare species occur can be considered Darlingtonia fens, as some represent small seeps or roadside drainages where water has accumulated due to hydrologic constraints. As with most types of habitat dispersed across a landscape, the ecological integrity for each site in relation to past impacts from mining and other human activities is variable. Generally speaking these fen habitats do not attract a lot of resource extraction attention because they lack suitability for mining, logging, or cattle grazing. Past impacts have mostly come from road building to access areas for the purpose of mining and logging. More recently, fire suppression activities have caused impacts, particularly during suppression of the Biscuit fire in 2002. Impacts during fire suppression have come from the construction of bull dozer created fire line that cut through existing fen habitat. Potential indirect effects from altering hydrologic regimes would be the greatest threat to these wetland ecosystems from mining. A conservation agreement (USFS 2006) and Draft Conservation Strategy (pending) were developed for five of the Darlingtonia fen associated species mentioned above. The documents outline goals and objectives for protecting these unique ecosystems and conducting monitoring to understand population trends of these rare plant species.

Survey and Manage Species Because the SM species are old-growth dependent, very few of these species have been found within the mineral withdrawal areas. The ecosystems within the withdrawal area do not support large contiguous patches of old growth Douglas-fir and western hemlock forests which comprise the primary habitat for most of the SM species on the list. The fungi species located within the HPWA were found in adjacent forest types where mineral exploration would never be feasible. Because of the lack of a nexus between SM species habitat and mineral exploration no further analysis will focus on this group of species. Essentially, modification to SM species and/or

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habitat would not occur within any proposed mineral extraction because the two features are ecologically and spatially mutually exclusive.

Invasive Plant Species Within the withdrawal areas, several invasive plant species are known to occur. Most of the species and sites are confined to the portions of subject lands that are not heavily influenced by ultramafic geologies. Like many native plants, invasive plant species cannot tolerate the high levels of iron, magnesium, and other heavy metals in the soils. One exception to this rule is the introduction of yellow tuft (Alyssum murale and A. corsicum). These species were intentionally introduced on ultramafic-derived soils for the purpose of phytomining. The hope was that these species would accumulate nickel laterite in their stems, roots and leaves and that the minerals could then be extracted later through processing. The idea failed, the company who brought in the Alyssum from eastern Europe and Turkey did a poor job of cleaning up the leftover plants, and some of them escaped into the wild. The plants are adapted to the harsh soil conditions in the , so they pose a serious threat to the many serpentine-endemic plants discussed above. On the RRSNF invasive plants are managed in cooperation with the Oregon Department of Agriculture (ODA). ODA has established a ranking system that helps to prioritize species and sites throughout the state.

Table 2. Invasive plant species inhabiting the 2015 SW Oregon Mineral Withdrawal area. ODA # of sites # of acres Invasive Plants Distribution/Invasiveness/Ecological Impacts List HP RB HP RB

Within Oregon this species is only found in Josephine County but is much more prevalent in California. It is an Aegilops triuncialis A & annual grass species with a high level of invasiveness 0 2 0 6 barbed goatgrass T (ODA 2010) rapidly taking over open grasslands, oak savanna and pastures. It is a state priority for eradication in order to prevent establishment in the rest of the state.

Within Oregon this species is only found in Josephine County. It has a high level of invasiveness (ODA 2008) Alyssum corsicum A & and can readily survive on the harsh red serpentine soils 0 5 0 48 yellowtuft T within the RBWA. At the present time the species is confined to the furthest eastern edge of the RBWA (see map) and efforts are being taken to eradicate the species. Within Oregon this species is only found in Josephine County. It has a high level of invasiveness (ODA 2008) Alyssum murale A & and can readily survive on the harsh red serpentine soils 0 83 0 600 yellowtuft T within the RBWA. At the present time the species is confined to the furthest eastern edge of the RBWA (see map) and efforts are being taken to eradicate the species. This species is widespread throughout SW Oregon after being introduced in the Umpqua basin around 40-50 years Centaurea debauxii ago as an erosion control. It has a moderate level of B* 1 40 .2 .3 meadow knapweed invasiveness especially in the xeric serpentine conditions within the withdrawal areas. Ecological impacts are high within natural meadows and open canopied areas.

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A widespread species that closely resembles starthistle but Centaurea melitensis is smaller in stature. This species is highly invasive but is B 0 1 0 .1 maltese starthistle already so widely distributed that controlling it is no longer feasible.

Yellow starthistle is a well-known annual invasive plant that occurs within xeric farm, range and open lands in Oregon Centaurea solstitialis along with several other western states. The species is B* 0 2 0 .08 yellow starthistle highly invasive in open settings such as pastures and natural meadows. It has an elevational limitation that keeps it from invading high mountain meadows.

A very invasive species in more arid regions of the state, spotted knapweed causes extensive ecological damage, Centaurea stoebe B & 0 2 0 .5 particularly in eastern Oregon and further east into the spotted knapweed T Rocky Mountains. Occurs only as a few scattered individuals in the RBWA.

Canada thistle favors invasion of wetlands and other moist seeps and springs within SW Oregon, though it will Cirsium arvense B* 5 0 4 0 establish nearly anywhere. It is a widespread perennial Canada thistle that is nearly naturalized throughout its range in the United States.

One of the more well-known invasive plants, a hearty shrub Cystisus scoparius that can take over areas post logging. It competes well B* 5 6 2 .9 Scotch broom with native early shrub species. It doesn’t do well in the mineral rich ultramafic soils within the withdrawal areas.

Genista Similar to Scotch broom but with less geographic monspessulana B* 3 0 .5 0 distribution and abundance. French broom

A medicinal invasive plant that can establish at higher elevation areas impacted with seasonal snow pack. This Hypericum species is widely distributed in the high Cascades of So. perforatum B* 0 1 0 8 Oregon but less widely distributed in the Siskiyou Mts. St. Johnswort Overall invasiveness is low to moderate on roadsides but can become an issue when it colonizes natural high elevation meadows and open forest. Tansy ragwort is widespread throughout western Oregon. It is highly toxic to livestock. Though it highly invasive in Senecio jacobae B* & 23 0 21 0 mesic conditions, the very arid and poor soil conditions tansy ragwort T within the withdrawal areas make it a very poor competitor with a low likelihood of expanding due to mining.

*Indicates species that are primarily controlled through biological methods (insect predation) The highest priority invasive species to be the most concerned about in relation to mining within the withdrawal areas are: 1. barbed goatgrass (Aegilops triuncialis); rationale: Very few sites exist in the state, it can colonize disturbed harsh soils/sites, and it has shown some ability to persist on partially serpentinized sites. 2. yellowtuft (Alyssum murale and A. corsicum); rationale: These are the most impactful species in relation to mining activities within ultramafic serpentinized soils. These

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species evolved in ultramafic conditions in Eurasia and spread profusely, setting thousands of seeds per plant. A concerted effort is underway in Oregon to eradicate this species from the Illinois Valley. 3. spotted knapweed (Centaurea stoebe); rationale: This species has shown some tolerance for colonizing serpentine soils, though it does not proliferate the way Alyssum does. Usually only a few scattered plants are found. The open nature of ultramafic adapted forest is a concern, since this species is a sun loving species.

USFS Research Natural Areas (RNA), Botanical Areas and BLM Areas of Critical Environmental Concern (ACEC) and RNAs The RBWA area contains one USFS RNA (Lemmingsworth Gulch), one BLM RNA (Woodcock Bog), and one BLM ACEC (Rough and Ready). It also contains two botanical areas (Rough and Ready Flat and Oregon Mountain) established in 1989 by the SLRMP. The HPWA contains one botanical area referred to as Red Flat Botanical Area and two ACECs referred to as Hunter Creek Bog and N. Fork Hunter Creek.

Table 3. RNA’s, ACEC’s and Botanical Areas within the 2015 SW Oregon Mineral Withdrawal area. Area Name Agency Year Size Purpose Coos Satisfy ONHP Coast Range Ecological Cell 13 (Port 721 Hunter Cr ACEC Bay 1995 Orford cedar on ultramafic soils); large, diverse acres BLM serpentine bog. Coos Satisfy ONHP Coast Range Special Species Cell 42 for N. Fork Hunter 1,925 Bay 1995 Gasquet manzanita; undisturbed old-growth Port Orford Cr. ACEC acres BLM Cedar stands; historic/prehistoric resources. Preserve a representative area that typifies important forest/shrub land, aquatic resources, rare geologies and Lemmingsworth 1,024 other natural situations that have special or unique RRSNF 1999 Gulch RNA acres characteristics of scientific interest or importance. Protect the extremely high concentration of endemic and rare plant species (USFS 1999). Oregon 2,706 Preserve large assemblages of serpentine endemic Mountain RRSNF 1989 acres plants. Botanical Area Red Flat 70 Preserve large assemblages of serpentine endemic RRSNF 1989 Botanical Area acres plants. Provide a buffer to the Hunter Creek Bog ACEC and Rough and 1,566 help stop OHV destruction in the area. Also preserve Ready Flat RRSNF 1989 acres individual serpentine endemic plants like Gasquet Botanical Area manzanita. Rough and Medford 1,164 Rare plants in serpentine alluvium and chaparral, 1994 Ready ACEC BLM acres knobcone and Jeffery pine. Woodcock Bog Medford 281 Hanging fen on ultramafic rock and soils, supporting rare 1994 RNA BLM acres plants and Port-Orford-cedar. 9,457 Total acres

The main purpose for establishing these special management areas was to better conserve the rare plant species that reside within the unique ecosystems that comprise these landscapes. The habitats that make up these management areas are rare at a global scale. To have this many

16 Botanical Resources Report 2015 SW Oregon Mineral Withdrawal special management areas within a given analysis area is unprecedented and is a testament to past realizations about the unique ecology of these mineral withdrawal areas. Potential impacts from mining in these areas include many of the same issues discussed in the sections above. The difference for these ecosystems is one of scale. These areas have been given special management status because of the assemblage of different rare species within them. As opposed to a single effect on one specific species, affects for these areas are considered based on the whole ecosystem and natural characters associated with them. Mechanisms for effects are likely the same but the scope and scale at which they occur at are considered broader.

Analysis Framework Analysis of the action alternatives (5-year and 20-year withdrawal) will display the effects of precluding mineral entry. Analysis of the no action alternative will display the general effects of these known activity areas being open to mineral entry, as contrasted with mineral entry being precluded. Specific details and effects of the proposed PoOs will not be analyzed. Site-specific mitigation measures are beyond the scope of this analysis. Analysis will focus primarily on 1. areas where proposed mineral plans of operation are under consideration at the time of segregation; 2. areas of suction dredge activity, as characterized by recent levels permitted by the State of Oregon; 3. the distribution of existing claims and the potential for resource conflicts (e.g. whether or not existing claims occur in areas with TES species, sensitive wetlands, popular recreation sites, or other high-value resources). Three proposed plans of operations (PoOs) for nickel laterite mining or exploration were submitted, but not yet approved, prior to segregation. Those PoOs include: RF-38 (location: T37S, R13W, Sec. 18, 19, 29-32; T37S, R14W, Sec. 13, 24, Willamette Meridian) Cleopatra (location: T41S, R10W, Sec. 5-8, 17, 18; T41S, R11W, Sec. 1, 12, Willamette Meridian) RnR (location: T40S, R9W, Sec. 8, 9, 21, 22, Willamette Meridian) Existing claims in the withdrawal areas total 234 lode and 45 placer claims. To date, no existing claims have been proven valid following the BLM’s validity examination process.

Environmental Consequences

Proposed Action – 5-year Withdrawal A 5-year withdrawal of mining in the proposed area will result in no effect to botanical resources. While it may appear self-evident that precluding mining, mineral exploration, and future claims within these areas would provide an overall benefit to the fragile and unique ecosystems that exist, the effect that would be realized to specific botanical resources can only be based on speculative determinations regarding future actions that may or may not occur. In addition, making site-specific determinations on botanical species for future mineral exploration is only speculative, with no way to predict effects within such a dynamic set of scenarios.

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The proposed action is administrative in nature and does not propose any specific ground disturbance, environmental changes, or non-speculative benefits or impacts to botanical resources. Potential negative and beneficial effects are too speculative in nature to be able to articulate in this analysis. We assume that existing claims are not likely to be able to undergo a validity examination within this 5-year period. It also seems likely that few, if any claims, would prove valid based on mineral values at the time of segregation and past trends.

Alternative Action – 20-year Withdrawal

Direct, Indirect, and Cumulative Effects An alternative is being presented to extend the amount of time to 20 years for congress to enact mineral withdrawal legislation. All the same assumptions from the effects analysis presented above under the 5-year withdrawal are the same for this alternative. Twenty years with no mining and no new claims may provide added protection to existing or yet to be found endangered or sensitive plant populations, but there is no way to determine specific effects. The same can be said for invasive plant species and special management areas (RNA’s and ACEC’s). The speculative nature of determining future claims does not afford the ability to make an accurate effects determination. While benefits to these resources may be realized during this 20-year period, there is not enough information at the current time to make a beneficial effects call. It is also more likely that existing claims could undergo a validity examination within this timeframe. Any claim that was proved valid would need to undergo site-specific NEPA analysis at the time of proposal.

No Action – No Withdrawal

Direct, Indirect, and Cumulative Effects The no action alternative would not withdraw these lands from potential future mining claims. This alternative is being analyzed in relation to potential direct, indirect and beneficial effects on the botanical resources outlined in the affected environment section.

The difference between the no action alternative and the two action alternatives is that mining and minerals exploration could occur, new claims could be staked, and new PoO’s submitted. When and where new claims might be staked or PoO’s submitted is entirely speculative.

The current environmental baseline does not represent ongoing negative or beneficial effects in relation to mining in this area. There are two PoO’s that are on hold pending a NEPA decision. The RF-38 PoO was analyzed in relation to botanical resources, with a resulting determination of no effect. The Cleopatra PoO is still in the process of being analyzed and may affect Howell’s jewelflower, but project design criteria would presumably be implemented to avoid direct negative effects. The current suction dredge mining claims pose no direct risk to TES plant species, because none of these species are known to occur within or on the immediate banks of streams or rivers within these areas. Based on the locations of existing suction dredge claims and permits, there is also no mechanism for indirect effects to TES plant species. Existing suction dredge mining activity occurs in stream channels that are lower in the watershed than known Darlingtonia fens, the only hydrologically affected TES plant habitat within these landscapes. Indirect effects to Darlingtonia fens could occur depending on location of future permits for mining within existing claims. However, site-specific NEPA analysis would need to be completed upon receipt of a PoO

18 Botanical Resources Report 2015 SW Oregon Mineral Withdrawal to mine. This would afford the agency a chance to assess the temporal and spatial impacts with regard to these unique wetland systems. Project design criteria would be recommended for avoiding any effects to Darlingtonia fens and the rare set of species that occupy them. Mining for nickel laterite poses the greater threat with regard to direct and indirect effects on TES plant species, because these types of mining may occur in upland conditions overlapping much of the habitat types with which these TES plants are associated. The two PoO’s that have been filed are exploratory in nature. A site-specific botanical analysis of the proposed drilling for test holes for the RF-38 project found no direct or indirect effects to TES plants. The small scale of the proposed test holes (<3” diameter) and the limited amount of disturbance caused by the equipment (handheld bore) were determined to be of a narrow enough scope to avoid effects. The Cleopatra exploratory project has been surveyed for TES plants within areas proposed for test drilling. Several scattered individual Howell’s jewelflower (Streptanthus howellii) plants were found throughout the area, but none were found in the direct footprint of proposed disturbance for individual test holes. Project design criteria would be put in place to ensure plants are avoided during navigation with handheld drill bores to test sites. That project was put on hold so a biological evaluation and NEPA analysis outlining specific areas to avoid within the project have not been completed. The RnR PoO submitted in 2011 has not been analyzed and is on hold due to legal encumbrance and the need for more information about the proposal to complete the environmental and economic analyses. The area estimated to be encompassed by the PoO has many sensitive plant populations present, but site-specific analysis is not possible until the PoO is amended to include information asked for by the agency. In the unlikely event that legal issues were resolved in favor of the plaintiff and if adequate information were provided, the NEPA would recommend project design criteria and mitigations that seek to protect sensitive plant species from direct and indirect effects caused by proposed mining. There are 234 lode claims within the two withdrawal areas. Lode claims have been mapped by the number of them per quarter section (in relation to township, range and section locations). One of the known populations of the endangered McDonald’s rockcress occurs within a quarter section area where six claims have been staked. Available spatial distribution of claims is not at a scale fine enough to determine whether any of the claim areas overlap with the small relatively finite (8 plants covering ~1/4 acre) population of McDonald’s rockcress. Future effects from lode mining to this population are impossible to determine and would only be speculative at this juncture. If in the future a PoO is submitted for exploration or mining within any of the existing lode claims, then a site-specific NEPA analysis will occur and determine the effects from the proposed actions. During this process recommendations are made in consultation with the USFWS for conserving populations of endangered species (in this case McDonald’s rockcress). Eight USFS R6 Sensitive plant species occur in quarter section areas with existing lode claims.

Table 4. TES plants that occur within quarter sections that have lode/placer claims Species # of ¼ sections # of Lode Claims Arabis macdonaldiana 1 6 Calachortus howellii 3 9 Erythronium howellii 1 1 Gentiana setigera 1 3 Lomatium engelmannii 1 3 Mondardella purpurea 3 4 Prosartes parvifolia 1 1

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Streptanthus howellii 9 107 Viola primulifolia var. occidentalis 2 5 21 133

Within the existing claim areas Streptanthus howellii has the highest potential to be impacted by current and future PoO’s, because the heart of the species range falls directly within this proposed withdrawal area. This species tends to be distributed across the landscape as individual plants or small clumps of plants that occur over large areas. This makes it difficult to categorize or map individual populations. Without mitigation through a NEPA process, there would be high potential for individuals or clumps of plants to be impacted by existing and future mining plans within existing claims. Nonetheless, there is little to no chance for an entire meta-population to be impacted in a way that would extirpate the population or lead the species being listed as threatened or endangered. The meta-populations encompass such large areas that it would likely be impossible for the footprint of a proposed mine to cover the whole population. To conclude, site-specific NEPA analysis is expected to protect Howell’s jewelflower, resulting in no impact, even if mining should occur under in the absence of withdrawal. Other species with a moderate potential for impacts to individual or sub-populations include Calachortus howellii, Erythronium howellii, Lomatium engelmannii, Monardella purpurea, and Prosartes parvifolia. These species occur exclusively in upland areas where high amounts of nickel laterite coincide. The moderate potential determination is based on the relatively small (when compared to Streptanthus howellii) number and size of sub-populations that overlap with existing claims. The potential for individual plants or populations to be impacted by future mining is proportionally small when considering the greater lansdscape. Site-specific NEPA in response to future PoO’s would allow a more accurate effects determination. Proposed project design criteria would presumably lead to no impact on these species under a future mining or minerals exploration scenario. Gentiana setigera and Viola primulifolia var. occidentalis occur in Darlingtonia fen ecosystems which do not provide potential for mineral extraction, hence there is no chance of mining activities causing direct effects to these species. Indirect effects from mining in adjacent areas is a potential, but there is no way to determine the chances of effects with such little information about future PoO’s within the existing claim areas. Site-specific NEPA would address potential conflicts caused by indirect effects in the form of hydrologic regime change. Proposed project design criteria would presumablylead to no impact on these species if mining were to occur in the future. In summary, the proposed action will result in no direct, indirect, cumulative, or beneficial effects to the endangered species (Arabis macdonaldiana and Lomatium cookii), nor to any of the sensitive plant species analyzed. Under this alternative a formal determination of NO EFFECT is made for McDonald’s rockcress (Arabis macdonaldiana) and Cook’s lomatium (Lomatium cookii). A determination of no impact is made for sensitive plant species. To reiterate, the rationale for these effects determinations is based on no ground disturbing activity being proposed. The proposed action is administrative in nature, and, even though minerals activity could occur based on VER, site specificity is lacking for making effects determinations for TES plant species. Site-specific NEPA in response to a PoO after the determination of a valid existing right would need to occur before an effects determination can be made in relation to effects from on- the-ground actions, whether they be positive or negative.

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Withdrawing these lands for the next five years while Congress considers legislation to permanently withdraw them may result in the protection of yet to be found populations of McDonald’s rockcress, Cook’s lomatium, and other sensitive plant species because, except for VER, mining and new claims will be precluded. The speculative and conditional nature of the previous statement does not allow determination of a beneficial effect for endangered or sensitive plant species.

Risk of Spreading Invasive Plant Species In general the two mineral withdrawal areas are not excessively weedy at the current time. This is due to the harsh soils that limit native and invasive species alike. Suction dredge mining presents little risk in relation to spreading invasive plant species because most disturbance occurs within the water and the limited disturbance on the bank is of limited scope and scale. None of the existing invasive species outlined in the affected environment section readily occur in the aquatic environment or in adjacent riparian systems. Similar to the endangered and sensitive native plant species discussed above, the largest threat of spreading invasive plants comes from mining for nickel laterite in upland ecosystems. Yellowtuft (Alyssum murale and A. corsicum) presents the greatest threat to these unique, ultramafic-adapted ecosystems. As discussed earlier, these particular invasive plant species can tolerate and thrive in soils with high levels of heavy metal because they evolved in similar settings in Eurasia. Potential mining in the RBWA poses the greatest threat to spread because of the current distribution of these invasive species in relation to active claims. In particular, the general estimated area of the RnR PoO coincides with lands occupied or adjacent to yellowtuft infestations. The level of potential risk to spreading yellowtuft depends heavily on the outcome of the RnR PoO and the subsequent NEPA analysis that would need to occur. A ¼ section with one current claim overlaps an area infested with yellowtuft. The yellowtuft occurs in a very small portion of the ¼ section. A site-specific effect call is impossible to make without knowing the extent of disturbance along with the transportation routes that are planned to be used by equipment. Prevention measures would be recommended, but, depending on the level and consistency of disturbance, there may be no way to keep yellowtuft from spreading into the withdrawal area. Another threatening invasive plant species is barbed goatgrass (Aegilops triuncialis). This species is very narrowly distributed at this point with the only populations in Oregon occurring adjacent to lands proposed for withdrawal in the Illinois Valley. There are no populations that occur within a ¼ section mapped area where existing mineral claims exist. ODA has consistently treated this species where it was found, but the amount of seed and nature of dispersal allow this plant to easily spread and colonize barren, dry ecosystems. Spotted knapweed (Centaurea stoebe) represents the final species that has potential to cause degradation to ecological integrity within the withdrawal area. Spotted knapweed has shown some ability to adapt to serpentine ecosystems. In general the populations that have been observed on serpentine have not spread or persisted in the way species like yellowtuft have. But compared with other invasive plants that occur within the withdrawal boundary, this species has some affinity to colonize and persist. Current existing claims have minimal to little overlap with known invasive plant infestations. The adjacent nature of the probable location for the RnR PoO to large populations of yellowtuft is a high risk situation with regard to further spreading that species. If, in spite of current legal encumbrances and lack of a fully developed plan, the RnR mine were ever developed, there would be a well-established vector and mechanism for invasion into the withdrawal area. During

21 Botanical Resources Report 2015 SW Oregon Mineral Withdrawal the NEPA process for the RnR PoO there would be site-specific and rigorous project design criteria recommended for abating the spread of yellowtuft into the withdrawal area. At this time, effects of the proposed action and the 20-year alternative cannot be determined in a site-specific manner, due to the administrative nature of these actions. The risk of spreading invasive plants could be reduced by precluding mining and future claims, but there is no measurable way to account for the level of risk reduction. Under no action, mining activity would increases the risk of spread, but there is no way to predict the future with regard to locations of invasive plants. There is very little risk that other species besides the three outlined above would increase from future mining, as mitigations insite-specific NEPA analysis would limit the potential for invasive species to spread.

Research Natural Areas, Areas of Environmental Concern and Botanical Areas A high concentration of special management areas occurs within the footprint of the proposed withdrawal area, due to the high level of ecological integrity and the uniqueness of the ecosystems at a regional and national scale. The RBWA encompasses five special management areas that represent a land base with one of the highest concentrations of rare and endemic plants in the United States. In the RBWA there is one ¼ section with one current mineral claim in the Oregon Mountain Botanical Area. On BLM lands the proposed West Fork Illinois River RNA coincides with three ¼ section areas that total 6 claims. The HPWA contains three special management areas that represent a unique maritime-influenced, ultramafic ecosystem with several endemic plant species. There is one ¼ section with three current mineral claims within the Red Flat Botanical Area, and three ¼ sections with a total of fourteen current mineral claims in the Hunter Creek Bog ACEC. The current claims have the potential to affect the integrity of all these special management areas, if mining were ever to occur there. The most at-risk area is the Hunter Creek Bog ACEC because of the large number (14) of potential claims. The Hunter Creek Bog ACEC was designated to protect the unique Darlingtonia fen and the surrounding ecosystems and hydrological regime that it encompasses. Mining has little to no potential to directly affect the bog/fen, but could indirectly impact associated hydrologic processes and ecological aspects that are tied to it. If, in the absence of withdrawal, a PoO is submitted for any of the current claims in RNA’s, ACEC’s and botanical areas, then a site-specific NEPA analysis would determine the effects and the needed project design criteria to reduce those effects.

Conclusion Without clearly documented ongoing effects to the existing baseline for botanical resources, the no action alternative results in no effect to endangered plant species, no impact to sensitive plant species, moderate risk of spreading invasive plants, and no impact to RNA and ACEC’s. The following table provides a comparison of environmental consequence determinations in relation to each alternative within this withdrawal area for botanical resources. The table articulates the conclusion that we currently lack enough information or site specificity to make negative or beneficial effects calls for botanical resources addressed in this report. Therefore, we determine that neither of the action alternatives, nor the no action alternative, will result in negative or beneficial effects to botanical resources. The current level of information results in a no effect/no impact determination for plant species of conservation concern, a moderate risk of invasive plant spread, and no impact to special management areas.

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Table 5. Summary of effects determinations and rationale for botanical resources No Action Alternative Proposed 5-Year Withdrawal 20-Year Withdrawal Botanical Effects Effects Effects Resource Rationale Rationale Rationale Determination Determination Determination No currently No currently No currently analyzed analyzed analyzed mechanism in mechanism in mechanism in place for negative place for place for effects. Future negative effects. negative effects. mechanisms for Endangered Potential for Potential for No Effect negative effects No Effect No Effect future beneficial future beneficial Plants possible, but too effects, but too effects, but too speculative in speculative in speculative in nature. Site-specific nature to nature to NEPA would need determine at this determine at this to analyze potential time. time. effects. Sensitive No Impact Same as above No Impact Same as above No Impact Same as above Plants Current baseline Ongoing Ongoing results in continued activities in these activities in these spread at a areas will areas will Invasive Moderate Moderate Moderate moderate level for continue to pose continue to pose Risk Risk Risk Plant Spread invasive plant a moderate risk a moderate risk species within this to spreading to spreading area. invasive plants. invasive plants. Beneficial Beneficial Current impacts will outcomes from outcomes from continue and are precluding new precluding new not measurable. claims within claims within New PoO’s these areas may these areas may RNA’s and proposed within No Impact No Impact occur. But a No Impact occur. But a ACEC’s areas that overlap clear clear RNA/ACEC will determination is determination is undergo site- speculative and speculative and specific NEPA not possible at not possible at analysis. this time. this time.

Literature Cited (BLM) United States Department of the Interior, Bureau of Land Management. 1995a. Final EIS and Record of Decision, Medford District Resource Management Plan. Medford District Office, Medford, Oregon.

(BLM) United States Department of the Interior, Bureau of Land Management. 1995b. Final EIS and Record of Decision, Coos Bay District Resource Management Plan. Coos Bay District Office, Coos Bay, Oregon.

(BLM). United States Department of the Interior, Bureau of Land Management. 2014. Final Decision Record, Cook’s Lomatium Habitat Management Project, Programmatic Integrated Vegetation Management Project, NEPA #DOI-BLM-OR-M000-2012-0001- EA. Medford District Office, Medford, Oregon.

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(BLM). United States Department of the Interior, Bureau of Land Management. 2015. Final Oregon and Washington State Director’s Special Status Species List. Oregon and Washington State Office, Portland, Oregon.

Chambers, K. 2011. A new species of Erigeron (Asteraceae) from Southwest Oregon. J. Bot. Res. Inst. Texas 5(2):415-419.

Emerson, C. 2010. Conservation Assessment for Gasquet manzanita (Arctostaphylos hispidula) within the State of Oregon. Interagency Special Status and Sensitive Species Program. Available online at: (http://www.fs.fed.us/r6/sfpnw/issssp/documents/planning-docs/ca-va-arctostaphylos- hispidula-2010-03.pdf)

Emerson, C. 2013. The Current Status of Serpentine Catchfly (Silene hookeri ssp. serpentinicola) in Oregon. Unpublished report prepared for the Rogue River-Siskiyou NF, Medford, Oregon.

Goforth, D. L. 1983. The and ecology of the Arabis blepharophylla complex of Northwestern California and Southwestern Oregon. Unpublished report prepared for Six Rivers National Forest, Eureka, California.

Jules, E.S., Ellison, A.M., Gotelli, N.J., Lillie, S., Meindl, G.A., Sanders, N.J. and Young, A.N. 2011. Influence of Fire on a Rare Plant Assemblage: A 5-Year Study of Darlingtonia Fens. American Journal of Botany 98(5): 801-811.

Kagan, J., Hoover, L., McRae, J., Rolle, W., Mousseaux, M., Mazzu, L., Friedman, S. 2006. Conservation Agreement for Hastingsia bracteosa, Hastingsia atropurpurea, Gentiana setigera, Epilobium oreganum, and Viola primulifolia ssp. occidentalis and serpentine Darlingtonia wetlands and fens from Southwestern Oregon and Northwestern California.

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Appendix A: Botanical Resource Maps

Figure 1. Distribution of the two endangered plant species known to occur in the RBWA

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Figure 2. Distribution of the seventeen sensitive plant species known to occur within the RBWA

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Figure 3. Distribution of the ten invasive plant species known to occur within the RBWA

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Figure 4. Distribution of RNA’s, ACEC’s and Botanical Areas within the RBWA

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Figure 5. Distribution of five sensitive plants and five survey and manage fungi within the HPWA

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Figure 6. Distribution of the six invasive plant species known to occur within the HPWA

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Figure 7. Distribution of ACEC and Botanical Areas within the HPWA

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