United States Department of Agriculture

Forest Service

April, 2018

Draft Botanical Resources and Non-native Invasive Plant Report

Seiad-Horse Risk Reduction Project

Happy Camp/Oak Knoll Ranger District, Klamath National Forest Siskiyou County, California

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Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Contents

Biological Assessment of Threatened, Endangered, Proposed, and Candidate Botanical Species ...... 3 Introduction ...... 3 Current Policy and Management Direction ...... 3 Methodology ...... 3 Preliminary Botanical Review ...... 4 Other Relevant Mandatory Disclosures ...... 4 Analysis Indicators ...... 4 Measures ...... 4 Spatial and Temporal Bounding of Analysis Area ...... 4 Affected Environment ...... 5 Environmental Consequences ...... 6 Comparison of Alternatives ...... 7 Compliance with law, regulation, policy, and the Forest Plan ...... 7 Biological Evaluation for Sensitive Species ...... 8 Introduction ...... 8 Current Policy and Management Direction ...... 8 Methodology ...... 8 Analysis Indicators ...... 9 Measures ...... 10 Spatial and Temporal Bounding of Analysis Area ...... 10 Affected Environment ...... 10 Species Accounts ...... 11 Environmental Consequences ...... 15 Alternative 1 ...... 15 Alternative 2 ...... 17 Alternative 3 ...... 24 Comparison of Alternatives ...... 26 Compliance with law, regulation, policy, and the Forest Plan ...... 27 Determination of Effects ...... 27 Alternative 1 ...... 27 Alternative 2 ...... 27 Alternative 3 ...... 27 Review of Survey and manage Botanical Species...... 29 Introduction ...... 29 Current Policy and Management Direction ...... 29 Methodology ...... 30 Preliminary Botanical Review ...... 31 Summary of Findings ...... 31 Unique Botanical Areas of Concern ...... 33 Non-native Invasive Plant Risk Assessment ...... 34 Introduction ...... 34 Methodology ...... 34 Analysis Indicators ...... 37 Measures ...... 37 Spatial and Temporal Bounding of Analysis Area ...... 37 Affected Environment ...... 37 Environmental Consequences ...... 40

i Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Alternative 1 ...... 40 Alternative 2 ...... 42 Direct and Indirect Effects ...... 42 Mitigation Measures ...... 46 Alternative 3 ...... 47 Cumulative Effects ...... 47 Comparison of Alternatives ...... 47 Compliance with law, regulation, policy, and the Forest Plan ...... 48 Literature Cited ...... 49 Appendix A-1 ...... 51 Ramaria stuntzii ...... 55 Appendix A-2 ...... 59 Appendix A-3 ...... 73 Appendix B: Noxious Weed and Nonnative Invasive Plant List ...... 81

List of Tables Table 1: List of botanical species that may be present in the project area obtained from the USFWS IPaC website on January 25, 2018...... 3

Table 2: Comparison of effects to TEPC populations by the proposed action alternatives...... 7

Table 3: Region 5 botanical sensitive species with known populations or suitable habitat present within the project boundary...... 10

Table 4: Additional sensitive species with un-surveyed suitable habitat within the Project area...... 13

Table 5: Effects of Alternatives on trends in sensitive species habitat condition in the Project area...... 26

Table 6: Requirements for survey and manage categories...... 29

Table 7: Known Populations of Survey and Manage Botanical Species in the Project Area ...... 31

Table 8: Known populations of NNIS within the Project area...... 38

Table 9: Number of known NNIS populations and acres that may be affected by Alternative 2 project activities...... 43

Table 10: Comparison of Alternatives by risk elements and overall direct/indirect risk of establishing, introducing or spreading NNIS in the project area...... 47

ii Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Biological Assessment of Threatened, Endangered, Proposed, and Candidate Botanical Species

Introduction The purpose of this Biological Assessment (BA) is to evaluate the Seiad Horse Risk Reduction Project (Project) to determine its effects on threatened, endangered, proposed or candidate plant species. This BA is prepared in accordance with the legal requirements set forth under Section 7 of the Endangered Species Act [19 U.S.C. 1536 (c)], and follows the standards established in Forest Service Manual direction (FSM 2672.42).

Current Policy and Management Direction Section 7 of the Endangered Species Act of 1973, as amended, and Forest Service policy (FSM 2670) direct Federal agencies to ensure that any action authorized, funded, or permitted by such agencies is not likely to jeopardize the continued existence of species listed, or proposed to be listed as endangered or threatened by the U.S. Fish and Wildlife Service (USDA 2005).

Methodology The likelihood that the continued existence of threatened, endangered, proposed, or candidate plant (TEPC) populations will be jeopardized by this project will be evaluated by determining the number of existing populations within the project boundary and the number and degree to which those populations will be negatively affected by the proposed action. To determine which species are known to occur, or may potentially occur, within the project boundaries, the following resources were consulted: • The U.S. Fish and Wildlife Service Information for Planning and Conservation (IPaC) website was used to generate a list of TEPC species that may occur in the Project area (Consultation Code: 08EYRE00-2018-SLI-0053); • California Natural Diversity Database species occurrence list for all 7.5 quadrangles that intersect the project area; • Klamath National Forest species occurrence records (Natural Resource Inventory System Database), survey records, and site visit records from within the project boundary; • Project Preliminary Botanical Review (Appendix A); and • Rapid Assessment of Vegetation Condition after Wildfire (RAVG). • Existing Vegetation (eVeg, CalVeg) spatial data layers

Table 1: List of botanical species that may be present in the project area obtained from the USFWS IPaC website on January 25, 2018.

Scientific Name Common Name Status Critical Habitat Astragalus applegatei Applegate's milk-vetch Endangered None designated Chamaesyce hooveri Hoover’s spurge Threatened Outside project area Fritillaria gentneri Gentner's fritillary Endangered None designated Orcuttia tenuis Slender Orcutt grass Threatened Outside project area

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Pinus albicaulis whitebark pine Candidate None designated *Arabis macdonaldiana Preston Peak rockcress Endangered None designated?? *A. macdonaldiana was not included in the list of possible species obtained from USFW; however, pre-field habitat analysis indicated that some suitable habitat may be possible, so it will be included in this report.

Preliminary Botanical Review An office preliminary review was conducted to determine if the project area is within the range of any listed TEPC species (Table 1), and if suitable habitat is present within the proposed project area (Appendix A). Aerial photographs, RAVG data, Existing Vegetation model data, treatment unit selection criteria, site visits, and species distribution information were used to determine if suitable habitat for TEPC species is present within treatment units. During the preliminary botanical review, the proposed project area was determined to contain no documented occurrences or critical habitat for the TEPC species identified in Table 1. Suitable habitat was not located for Astragalus applegatei, Chamaesyce hooveri, Orcuttia tenuis, Fritillaria gentneri or Pinus albicaulis within the project area during preliminary review. However, suitable habitat for Arabis macdonaldiana was determined to be present in portions of the Project area. This determination triggered the need for field surveys of identified suitable habitat for previously undocumented A. macdonaldiana populations. Intuitive controlled surveys would be conducted during appropriate times for identification (Summer 2018) within Township 47 North, Range 11 West, Sections 7 and 8. Survey areas were determined by comparing potentially suitable habitat with RAVG data and treatment unit location. If populations of A. macdonaliana are located during field surveys, the populations and surrounding habitat will be protected.

Other Relevant Mandatory Disclosures Consultation to Date: A list of all federally listed Threatened, Endangered, Proposed, or Candidate species which might occur on the Klamath National Forest was acquired from the U.S. Fish and Wildlife Service on January 25, 2018 (USFWS 2018). No consultation was necessary.

Analysis Indicators The indicator for effects of the alternatives on TEPC species is the likelihood of jeopardizing the continued existence of TEPC species populations.

Measures Events that may jeopardize the continued existence of TEPC species populations include: • Those that result in a loss of suitable habitat in areas where a TEPC species is known or thought to occur; commonly quantified in land surface area. • Those that result in a loss of individuals or sub-populations of a TEPC species.

Spatial and Temporal Bounding of Analysis Area

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Because no populations of TEPC species are known to occur in or near the project area, the project area will serve as the geographical bounds for short term, long term, and cumulative effects analysis for TEPC species. All potential disturbance and effects to TEPC species from this project would occur within this boundary. Additionally, effects from other present and foreseeable activities will interact with effects of the proposed project only within the project area. The temporal bounding for TEPC species will be less than five years for the short-term effects, and greater than five years for long term effects. Temporal bounds were chosen to account for species recovery and seed dormancy requirements.

Affected Environment The proposed project area encompasses 10,867 acres, within the Seiad Creek and Horse Creek Watersheds. Some private land parcels occur within the project area but the majority of the area is owned by the U.S. Forest Service. The area has a history of mining, sheep and cattle grazing in the higher elevations, and timber harvest across the entire area. Elevations within the analysis area range from 1,920 feet near the mouth of Panther Gulch to 6200 feet at Copper Butte on the Siskiyou Crest. Vegetative cover in the analysis area includes Douglas-fir and Klamath mixed conifer forest, montane hardwood, chaparral, riparian shrub and hardwood, riparian meadow, and some oak woodland. Prior to the 2017 Abney Fire, the project area contained about 28% mid to mature mixed conifer forest habitat and approximately 58 percent early seral forest. Shrub- dominated habitat made up approximately 12% of the area, while hardwoods and herbaceous cover each made up less than 1%. The 2017 Abney Fire burned a large portion of the project area at all fire severities, with approximately 63% experiencing moderate to high severity. The fire resulted in significantly reduced habitat quality for large portions of existing mid- late seral habitat. Approximately a third of mid-late seral forests in the project area burned at moderate to high severity resulting in a functional ‘loss’ of these habitats. These mortality rates are based on RAVG data, using the following assumptions: • Areas characterized by high severity burns experienced 75 percent or greater vegetation mortality, loss of canopy and understory cover, and loss of duff layers and large woody debris; • Areas characterized by moderate severity burns experienced 50 to 75 percent vegetation mortality, substantial reduction in canopy and understory cover, and substantial reduction of duff layers and large woody debris; and • Areas characterized by no or low severity burns experienced 0 to 50 percent vegetation mortality and a reduction in fuel loading. Modification of the forest structure and composition as a result of fire intensity, duration, and suppression efforts has had a profound effect on microclimate characteristics such as air temperature, relative humidity, and soil temperature and moisture. This could, in turn, adversely impact certain native plant communities. In moderate and high burn severity areas, microclimate characteristics commonly associated with habitat for species of concern have likely been lost. However, areas that experienced no or low burn severity provide refugia for native species, and act as a seed source for natural regeneration through the many phases of post-fire succession.

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The area contains two botanical Special Interest Areas, the Baker Cypress Botanical Area, and the Cook and Green Botanical Area. While the former was designated primarily to protect the endemic Baker’s cypress, both areas contain a very high diversity of native species – many of which are rare or endemic to this bioregion. The northern boundary of the project area is part of the Siskiyou Crest, which is an important geographic feature which, through a combination of topography, geology and climate, is thought to have functioned as a bio-connectivity corridor and refugia for plants and animals for millennia. The high rate of both paleo-endemic and neo- endemic species in this region supports this theory. The northwestern portion of the project area, west of the East Fork of Seiad Creek, is predominantly composed of ultramafic soils derived from serpentinite and peridotite. This area, in particular, contains a high diversity of plant species, including the endemic Baker’s cypress. The Cook and Green botanical area occupies the eastern side of a pass in the Siskiyou Crest, on metasedimentary-derived soils. It is known for its extremely high plant diversity, and is thought to contain 300 or more plant species, many of which are rare. Brewer’s spruce and Pacific silver fir are known to occur in this area. Affected TEPC Plant Communities McDonald’s rock-cress - Arabis macdonaldiana: a perennial herbaceous member of the Brassicaceae (mustard family), is characterized by lavender or crimson-purple flowers and a deep green rosette of broadly spatulate (spoon-shaped) leaves from which the short flowering stems arise. Arabis macdonaldiana occurs in soils derived from ultramafic parent material, containing high levels of heavy metals and low levels of nutrients. Its habitat ranges from barren gravel slopes to open scrub and pine woodlands. In our area it appears to be restricted to high elevation (>5000 ft) rocky barren slopes. The majority of the distribution occurs within designated wilderness area. Originally discovered at Red Mountain, Mendocino County, the taxonomic treatment of the species was revised in 1993 to include populations of purple- flowered rock-cress located near the Oregon border. Since 1993, the species was thought to occur in Mendocino, Del Norte, and the very western portion of Siskiyou counties in California, and the very southern portion of Curry County in Oregon. However, recent genetic work indicates that the populations in our area may be an undocumented species or sub-species of A. aculeolata. Within the project area, suitable habitat for A. macdonaldiana may occur along or north and east the 47N80 (Bee Camp) road. This area is characterized by ultramafic soils and rocky peridotite scree, with sparse vegetation.

Environmental Consequences No populations of federally listed Threatened, Endangered, Proposed, or Candidate plant species have been recorded in botanical records or identified in previous surveys within the Project area. If populations of A. macdonaldiana are discovered in the project area, occurrences and their surrounding habitat will be protected. Alternative 1: The no-action alternative would have no direct or indirect effect on Arabis macdonaldiana. This species typically occurs on rocky serpentine outcrops which are otherwise barren or very sparsely vegetated. Fire effects from the 2017 Abney Fire were unlikely to have altered site or micro-site conditions significantly, and natural vegetation recovery in suitable habitat for A. macdonaldiana would be expected to be sparse – unlikely to contribute to future high-severity fire.

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Alternatives 2 and 3: Two project activities, hazard tree removal and underburning, are proposed within areas identified as potentially suitable habitat for A. macdonaldiana. If any populations of A. macdonaldiana are discovered in the project area, the occurrences and surrounding suitable habitat would be excluded from project activities pending further environmental review and consultation with the U.S. Fish and Wildlife Service (USFWS). There would be no direct or indirect effects to A. macdonaldiana under Alternative 2 or 3.

Determination of Effects It is my determination that the Seiad Horse Risk Reduction Project will not affect Arabis macdonaldiana, Astragalus applegatei, Chamaesyce hooveri, Fritillaria gentneri, Orcuttia tenuis, or Pinus albicaulis.

Comparison of Alternatives

Table 2: Comparison of effects to TEPC populations by the proposed action alternatives.

Indicator Alternative 1 Alternative 2 Alternative 3

TEPC No Effect No Effect No Effect Populations

Compliance with law, regulation, policy, and the Forest Plan The Seiad Horse Risk Reduction Project complies with section 7 of the Endangered Species Act of 1973, as amended, and Forest Service Policy (FSM 2670) in the preparation of a Biological Assessment and the disclosure that the project will have no effects to TEPC species.

7 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Biological Evaluation for Sensitive Species

Introduction The purpose of this Biological Evaluation is to evaluate the Seiad Horse Risk Reduction Project (Project) in sufficient detail to determine its effects on sensitive plant species. This Biological Evaluation (BE) is prepared in accordance with the standards and guidelines established by Forest Service Manual direction (FSM 2672.42). The US Forest Service Region 5 Regional Forester has listed plants for which there is a concern for species viability as sensitive. Sensitive plants are those species which may occur in few to large numbers in a small localized area, or which may occur in a wide geographical area but in few numbers in restricted specialized habitats. Forty seven sensitive plants species are known, or thought likely to occur on the Klamath National Forest (USDA 2013). This BE addresses those species.

Current Policy and Management Direction Forest Service Policy (FSM 2670) directs Federal agencies to ensure that any action authorized, funded, or permitted by such agencies is not likely to jeopardize the continued existence of species listed as sensitive by the Regional Forester, or to cause a trend to federal listing for species listed as sensitive (USDA 2005). Forest-wide Standards and Guidelines have been developed that direct the management of sensitive plant species to ensure maintenance of reproducing, self-sustaining populations and to prevent the need for the species to become listed as threatened or endangered (USDA 1995). In the event that surveys cannot be conducted, Forest-wide Standards and Guidelines state that the project area should be assessed for the presence and condition of sensitive species habitat (USDA 1995).

Methodology An office preliminary field review was conducted to determine if the Seiad Horse Risk Reduction Project area contains any sensitive species populations and if suitable habitat is present within the proposed project area (Appendix A). Aerial photographs, RAVG data, Existing Vegetation (EVeg) spatial data, treatment unit selection criteria, site visits, prior project analyses, and species distribution information were used to determine if suitable habitat for Sensitive species is present within treatment units. To determine which species are known to occur or may potentially occur within the project boundaries the following resources were consulted: • Region 5 list of Sensitive species that may occur on the Klamath National Forest (USDA 2013); • California Natural Diversity Database (CNNDB) species occurrence list for all 7.5 quadrangles that intersect the project area; • Klamath National Forest species occurrence records (Natural Resource Inventory System Database), survey records, and site visit records from within the project area;

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• Rogue River-Siskiyou National Forest species occurrence records (Natural Resource Inventory System Database), survey records, and site visit records from within or adjacent to the project area; • Project Preliminary Field Review (Appendix A); • Existing Vegetation (eVeg) spatial data layers; and • Rapid Assessment of Vegetation Condition after Wildfire (RAVG) data. Field surveys for undiscovered populations of sensitive botanical species would be conducted using intuitive controlled survey methods. Monitoring to evaluate the status of known populations within project activity areas would be conducted in the spring and summer of 2018; during appropriate times for identification. A detailed list of sensitive species that may potentially occur in the project area can be found in Appendix A. Due to the ephemeral appearance of fruiting structures, the hazardous condition of the Project area, and the expedited time frame of the Seiad Horse Risk Reduction Project, surveys for sensitive fungal species are not practical. Sensitive fungi habitat in the Project area will be protected through the incorporation of project design features associated with Forest Plan Standards and Guidelines for the aquatic conservation strategy and woody material retention associated with wildlife habitat and soil stability and productivity. Because surveys and monitoring have not been completed, this analysis is based entirely on the records reviewed during the preliminary field review as well as from field checks that were conducted prior to completion of this document. Un-surveyed habitats which are suitable for sensitive species (determined during pre-field analysis) are analyzed based on the possible effects of the Project on habitat presence and condition (USFS 1994, S&G 6-8). Without complete data, certain assumptions must be made during analysis. These assumptions are that: • Populations of Sensitive plant species, associated with forest habitats, located in areas burned at moderate-to-high intensity, as indicated by RAVG data and salvage and site preparation and planting unit selection criteria, are assumed to be extirpated; • Areas burned at moderate-high intensity, as indicated by RAVG data and salvage unit criteria, are no longer expected to support viable populations of Sensitive species identified to potentially occur in forested habitats in the project area. For sensitive species that are also listed under Survey and Manage as category A or C (pre- disturbance surveys required) or B (equivalent effort surveys required for habitat disturbing activities), survey protocols will adhere to Northwest Forest Plan standards (2001 ROD, Pechman exemptions). Additional field checks may be performed for species in areas excepted or exempted from survey under Survey and Manage.

Analysis Indicators The effects of the proposed actions on sensitive species are compared using the following indicator: Trend of sensitive species population viability, or habitat condition, measured as increasing, declining, or static.

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Measures Trends in sensitive species populations are measured both in terms of the number of populations on the Klamath National Forest and the number of individuals in a population, or, in the case of un-surveyed areas, the amount and condition of suitable habitat. Trends can be characterized as increasing, declining or static.

Spatial and Temporal Bounding of Analysis Area The project area will serve as the geographical bounds for effects analysis of sensitive species. All potential disturbance and effects to sensitive species from this project will occur within this boundary. Additionally, effects from other present and foreseeable activities will interact with effects of the proposed project only within the project area. Temporal bounding for sensitive species will be less than five years for the short-term effects and greater than five years for long term effects. Temporal bounds were chosen to account for species recovery and seed dormancy requirements.

Affected Environment The general affected environment for analysis of sensitive species is identical to that identified in the Botanical Biological Assessment for TEPC species in this Project. Affected Sensitive Species Pre-field analyses determined that the project area contains documented occurrences of four sensitive plant species and suitable habitat for an additional 13 species (Table 3). Of these, Cypripedium fasciculatum, Cypripedium montanum and Phaeocollybia olivacea, and Eucephalus vialis are protected under both sensitive and survey and manage guidelines and will be addressed in both reports.

Table 3: Region 5 botanical sensitive species with known populations or suitable habitat present within the project boundary.

Present on Present In Scientific Name Common Name Status KNF Project Area State and Arabis McDonald’s Federal Yes No macdonaldiana rockcress Endangered, Sensitive Sensitive, S&M Buxbaumia viridis green bug moss No No E Sensitive, S&M Cudonia monticola None No No B Cypripedium clustered ladies Sensitive, S&M Yes No* fasciculatum slipper C Cypripedium mountain ladies Sensitive, S&M Yes Yes montanum slipper C Dendrocollybia Sensitive, S&M None No No racemosa B

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Draba carnosula Mt. Shasta draba Sensitive Yes No Klamath Mt. Eriogonum hirtellum Sensitive Yes No buckwheat Eriogonum ursinum Blushing wild Sensitive Yes No var. erubescens buckwheat Erythronium Henderson’s fawn Sensitive Yes No hendersonii lily Sensitive, S&M Eucephalus vialis Wayside aster No No A Fissidens brook pocket Sensitive No No aphelotaxifolius moss Mielichhoferia elongate copper Sensitive No No elongata moss Howell’s Yes Pedicularis howellii Sensitive Yes lousewort Phaeocollybia olive Sensitive, S&M Yes Yes olivacea phaeocollybia B Tauschia howellii Howell’s Tauschia Sensitive Yes No Thermopsis robusta robust false lupine Sensitive Yes No

Species Accounts Species with known populations in the Project area: Clustered lady’s slipper and mountain lady’s slipper - Cypripedium fasciculatum and Cypripedium montanum (Due to their similarities these species will be described and analyzed together). These species are perennial orchids found scattered throughout the Northwestern US. They arise in early spring from a shallow rhizome and die back by late summer. On the Klamath National Forest, C. fasciculatum and C. montanum populations occur in the understory of mixed conifer forests and are present in a variety of soil types. The majority of populations are located in moist sites on northern aspects with sufficient canopy cover to provide filtered light to the forest floor. On the Klamath National Forest, C. fasciculatum and C. montanum populations range from 1,650 to 5,600 feet. C. fasciculatum and C. montanum require mycorrhizal association with a fungus for germination and growth (Shefferson et al. 2005, Kaye and Cramer 2005). Cypripedium seeds lack endosperm and thus cannot provide food to the developing embryo. Instead, this genus relies on an epi- parasitic relationship with a mycorrhizal fungus to gain nutrients (Kaye and Cramer 2005). The genus Cypripedium has been found to almost exclusively associate with a specific mycorrhizal family, the Tulasnellaceae (Shefferson et al. 2007). Cypripedium species also lack a hard seed coat and therefore do not bank seeds in the soil. C. fasciculatum and C. montanum populations do not typically survive any fire in which the duff layer is consumed. Additionally, mechanical disturbance of the rhizome is generally fatal. Surveys on the Forest for C. fasciculatum and C. montanum have been on-going since 1980. Prior to the 2017 Abney Fire, there were 159 C. fasciculatum populations and 135 C. montanum populations known to occur forest-wide, two of these are located within the project boundary. The only population of C. fasciculatum known to occur in the project area is presumed extirpated

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as a result of the fire; subsequently, there are no remaining known populations of C. fasciculatum located within the Project area (Table 3). However, the one population of C. montanum located in the project area is still assumed viable. Howell’s lousewort – Pedicularis howellii: Pedicularis howellii is an endemic perennial herb that is restricted to the Siskiyou Mountains of northern California and southern Oregon at elevations between 5,000 and 6,000 feet. It typically occurs in mixed conifer forests dominated by white or red fir with Quercus sadleriana as the primary understory component. It is most often found where there are openings in the forest canopy, such as near the forest edge, or by streams or roads. P. howellii is believed to form hemiparisitic root associations with other plants and cannot survive long without a host plant (Macior 1986). This species relies on insects for pollination, and has specifically co-evolved with bumblebees (Macior 1986). There were 28 known P. howellii populations located on the Forest prior to the 2017 Abney Fire, 4 of which are located in the project area. One population is now presumed extirpated as a result of the fire; subsequently, 3 populations are still located within the Project area (Table 3).

Phaeocollybia olivacea: Phaeocollybia olivacea is an ectomycorrhizal fungi species that fruits in clustered to gregarious (in arcs) patterns during autumn in mixed or coniferous forests. See the Fungi section below for more details regarding this species ecology and habitat needs. There were 29 known P. olivacea populations located on the Forest prior to the 2017 Abney Fire, 4 of which are located within the project area. None of these populations were presumed to be extirpated by the 2017 Abney fire (Table 3).

Additional Species with Suitable Habitat Present: In addition to the species discussed above, suitable habitat for four bryophytes and two fungi species occurs in portions of the project area (Table 4). Bryophytes: No Sensitive bryophyte species are known to occur within the Project area, however suitable habitat is present for 4 species (Table 4). Shade and moisture requirements necessary for most sensitive bryophyte species were lost in areas that burned at moderate to high severity during the 2017 Abney Fire. Suitable habitat for sensitive bryophyte species may be present within areas characterized by no or low burn severity. The four bryophytes species assumed to be present in the project area occupy habitats which are primarily riparian or associated with wet areas such as springs or wetlands (Table 4). Fungi: Pre-field analysis determined that there is suitable habitat for three sensitive fungi species in the project area (Appendix A), one of which, Phaeocollybia olivacea, occurs in the project area (see above). Ectomycorrhizal fungi species: Ectomycorrhizal fungi, such as P. olivacea, are dependent upon the habitat elements that support the species and their vascular plant hosts throughout their life cycles. These fungi are obligate symbiotic organisms and cannot survive without their host species. The vulnerability of ectomycorrhizal fungi is linked to that of the symbiotic partner and

12 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project subsequently anything that threatens its forest habitat will also threaten the continued survival of ectomycorrhizal fungal populations. Habitat components necessary for ectomycorrhizal fungi, as described above, may have been destroyed during the 2017 fire season. Without obligate host trees, ectomycorrhizal fungi cannot survive. Upon the death of their host tree, ectomycorrhizal fungi may produce a flush of sporocarps in a last attempt at reproduction, however; without the continued supply of nutrients from its host the mycelial body of the fungus will not persist. Saprophytic fungi species: Saprophytic species obtain nutrients through the decomposition of dead organic matter. These fungi species are dependent upon adequate amounts of detritus such as leaves, needles, limbs, large woody debris, or even dead animal carcasses to provide a substrate and supply a continuous source of nutrients. These species are not dependent upon specific vascular plant hosts, but may require adequate canopy coverage to retain moisture levels sufficient to support them. According to the best available information, suitable habitat for the saprophytic species Cudonia monticola, and Dendrocollybia racemosa is present in the project area.

Table 1: Additional sensitive species with un-surveyed suitable habitat within the Project area. Life- Species Habitat form Arabis Ultramafic soils, from 3900-7200 feet, also rocky granite VA macdonaldiana opening in Jeffrey pine. Restricted to logs or stumps with high water content in late Buxbaumia BR stages of decay, on humus and occasionally on mineral soil, in viridis cool, perennially moist spots from 3,500-5000 feet. Generally found in mature, moist coniferous forests. It occurs on Cudonia litter of the forest floor where it feeds on dead and decaying FU monticola organic material. With spruce, white fir and Douglas-fir; under conifers. In mixed forests with coast live oak, tanoak and Douglas-fir. In Dendrocollybia moss bed along streams. Parasitic. Solitary or in small groups on FU racemosa the decayed remains of decayed mushrooms, or in duff of mixed hardwood-conifer woods. This species inhabits rocky ultramafic or granodiorite slopes and Draba VA cliffs above 6,000 feet within red fir and subalpine forests in the carnosula Klamath Mountains. (known from 5200 ft in Red Buttes) Eriogonum Restricted to bald serpentine outcrops or gravelly slopes and VA hirtellum ridges from 2000 to 5500 feet in elevation. Eriogonum Habitat on the Klamath N.F. consists of north facing rocky ridge ursinum var. VA tops, in openings within montane shrub communities at 5,300 to erubescens 6,200 feet on non-ultramafic metamorphics.

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Oak woodland and mixed conifer forest in openings or filtered Erythronium hendersonii VA sunlight from 900 to 5200 feet elevation.

Found in coniferous forests from 500'-3150', typically on dry Eucephalus upland sites dominated by Doug-fir, in canopy gaps and forest vialis VA edge habitat, roadsides.

Grows on wet soil, humus and rocks along narrow streams and Fissidens in the vicinity of small waterfalls, and in damp or wet crevices of BR aphelotaxifolius cliffs. It is not expected in areas where peak flows wash mosses away. Sea level to 6300 feet. Grows on metamorphic, sedimentary, limestone, granite and Mielichhoferia serpentine rock outcrops that often contain copper or other heavy BR elongata metals and that are seasonally moist or less commonly on moist soil. Grows from sea level to 3550 feet Openings within subalpine and upper montane coniferous forest Tauschia with Abies, and Tsuga sp. from 5500 to 8300 feet in elevation, howellii VA on decomposed granitic soils on ridge tops and upper slopes.

Openings, along ridge lines, lower montane forest, roadsides Thermopsis <4500 ft. Occurs in openings of Douglas-fir dominated and VA robusta mixed evergreen forests including previously disturbed sites.

Lifeform: VA = Vascular, BR = Bryophyte, LI = Lichen

14 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Environmental Consequences Ground disturbance and alterations of the light, moisture, and nutrient regimes within suitable sensitive plant habitats can affect sensitive plants, bryophytes, lichens and fungi. These effects can take two forms; either the actual destruction of individuals in a population, (direct effect) or the adverse modification of suitable habitat considered critical to maintenance of viable populations (indirect effect). No direct or indirect effect to undocumented sensitive plants associated with forested habitats is expected as the result of any proposed Alternative in areas that experienced moderate to high burn severity, as they are assumed to have been extirpated and habitat destroyed – see assumptions in Methodology section. Effects of actions proposed outside of moderate to high severity burned areas are disclosed below.

Alternative 1 Under the Alternative 1, no treatments are proposed. Alternative 1 provides reviewers a baseline to compare the magnitude of environmental effects of doing nothing versus the action alternatives.

Direct and Indirect Effects There would be no direct effects to sensitive plant species from this alternative. For sensitive species associated with forested habitats, indirect effects would occur in the form of continued habitat loss as living trees, which were weakened but not killed by the 2017 Abney Fire, succumb to insect attack or climate stress over a period of 1 to 2 years, creating an existing condition of short-term habitat loss. In the long term, habitat would begin to recover at pace with natural forest regeneration. Mixed severity fires in the forests of the Klamath Mountains create a patchwork or mosaic pattern of habitat that fosters and promotes high levels of biodiversity. Native plant species in this region are adapted to the stochastic effects of mixed severity or low intensity fire. Natural vegetative succession follows patterns of habitat suitability and microsite conditions based on the landform, climatic patterns, soils and hydrology. Furthermore, in certain fire adapted or fire resistant habitats such as oak savannah, montane meadows and rocky ridgelines, fire generally has a positive effect on the sensitive species associated with those habitats by removing competition and shade, and providing a pulse of nutrients (Skinner et al., 2006). In the above scenarios, natural succession (no action) may be the most effective means of protecting sensitive plants and allowing their habitats to recover. Under a no action alternative, less priority and funding would be given to invasive plant treatments near sensitive plant populations or habitat in the project area. This would increase the risk of damage to sensitive plant sites or destruction of suitable habitat by invasive plant species. However, a no action alternative would have no associated risk of spreading invasive plants species beyond their current distribution, unlike the action alternatives. See the Non Native Invasive Plants report for more details. Species Accounts

15 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Clustered and mountain lady’s slipper - Cypripedium fasciculatum and C. montanum: Under Alternative 1 there would be no direct effect to C. fasciculatum or C. montanum populations or habitat within the Seiad Horse Risk Reduction Project area from management activities. Indirect effects to suitable habitat and re-sprouting populations may occur. Accumulation of fallen dead trees would create heavy fuel loads which predispose areas to high burn intensities and durations during the next fire event, thereby damaging plants which survive falling trees, and subjecting the habitat to more adverse effects during future wildfires. In the short term, until natural vegetation re-sprouts and stabilizes slopes, erosion and earth flows could indirectly dampen the ability of sites to recover. Howell’s lousewort - Pedicularis howellii: Due to this species association with high-elevation partially forested areas and its relationship with host-species which are typically fire-adapted shrub species, a no-action alternative would have no direct effect to extant populations, while indirectly there may be a beneficial effect from natural regeneration of host species. Phaeocollybia olivaceae – There would be no direct effect to this species. P. olivaceae rely on the presence of a live host trees for their continued existence. Under a no action alternative, forest re-establishment in severely burned areas would occur naturally, over a longer timeframe than that expected in areas proposed to be treated and planted. This would have a negative effect on the short term, but negligible long term effect. No action in areas with live trees would be expected to have a positive indirect effect to ectomycorrhizal fungi in the short term, and no effect in the long term. Fissidens aphelotaxifolius and Buxbaumia viridis – There would be no direct effect to these species. Riparian-associated sensitive bryophyte habitat impacted by the Abney Fire would recover naturally over an undetermined amount of time. The presence of standing and down large dead trees in and near the riparian zone would contribute to current and future habitat development. However, there would also be potential for accumulation of dense fuels, creating a possibility of future high-severity wildfire. Mielichhoferia elongata – Due to this species preferred habitat of seasonally wet, rocky areas, a no-action alternative would have no direct effect and would be unlikely to have an indirect effect. Cudonia monticola and Dendrocollybia racemosa – There would be no direct effect to these species. The retention of dead trees would have a beneficial effect to sensitive saprophytic fungi – by providing abundant substrate for colonization. However, heavy fuel loading from the accumulation of dead snags, dense undergrowth regeneration, and debris from the Abney Fire may have an indirect negative effect on potential habitat by creating conditions conducive to high severity wildfire in the future which would consume substrate and woody materials necessary for survival. Arabis macdonaldiana, Draba carnosula and Eriogonum hirtellum: Due to these species affinity to very harsh, barren serpentine habitats, a no-action alternative would have no direct effect and would be unlikely to have any indirect effect. Blushing wild buckwheat – Eriogonum ursinum var. erubescens: Due to this species affinity to open rocky ridges, a no-action alternative would have no direct effect and would be unlikely to have any indirect effect.

16 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Henderson’s fawn lily – Erythronium hendersonii; and Wayside aster – Eucephalus vialis: Due to these species affinity to forest and forest openings, a no-action alternative might allow additional loss of habitat, in the long term, due to vegetation type conversion to shrub/chaparral species. However, suitable habitat which experienced low fire severity was likely improved, at least in the short-term, and would allow for the persistence of any populations present. Tauschia howellii - Due to the high-elevation sparse sub-alpine habitat this species prefers, a no- action alternative would have no direct effect and would be unlikely to have any indirect effect. Thermopsis robusta – Due to this species affinity for disturbed areas and openings within forested environments, a no-action alternative would have no direct effect. Indirectly, a no-action alternative may allow vegetation type conversion away from forest to chaparral/shrub, causing a loss of habitat.

Cumulative Effects All activities and factors listed in Appendix B of the Seiad Horse Risk Reduction Project Environmental Assessment may have additional effects to sensitive botanical species populations in the project area when added to Alternative 1. On-going and future foreseeable Forest projects have been and will be evaluated for effects to sensitive botanical species. The implementation of project design features structured to protect the viability of sensitive botanical species would limit the effects of on-going and future foreseeable Forest projects on these populations. It is expected that because of these past evaluations and inclusion of project design features, cumulative effects from Forest projects would have a neutral effect on population viability trends for Sensitive species. Projects on private lands are not required to protect Sensitive botanical species, and subsequently actions on private lands may lead to a localized downward trend in population viability for sensitive species located therein. If that is the case, on-going and future foreseeable projects on private lands would have a declining cumulative effect on population viability trends for Sensitive species. However, without knowing how many species and/or populations are present, how many may be effected, and how project activities will affect habitat conditions it is difficult to determine how potential effects from private actions would cumulatively influence population viability trends.

Alternative 2 See the Seiad Horse Risk Reduction Environmental Analysis for a detailed description of the activities proposed under Alternative 2. In summary activities proposed are;

1. Roadside Hazard Tree Removal 2. Fuels Reduction adjacent to Private Property 3. Salvage Logging with Site Preparation and Planting (site prep and plant) 4. Site Preparation with Planting (without salvage) 5. Underburning 6. Developing and Maintaining Fuel Management Zone 7. Large Woody Debris Placement in Horse Creek

17 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Direct and Indirect Effects For all sensitive species populations and habitats discussed below, there is a risk of negative effects from invasive plant introduction by project activities under this alternative. Species at greater risk are those that prefer open-canopy forested or rocky habitats or disturbed areas, generally at lower elevations below 5000 feet. See the Non-native Invasive Species Risk Assessment for this project for more details regarding the risk of invasive plant spread.

Species Accounts Clustered and mountain lady’s slipper - Cypripedium fasciculatum and C. montanum – One population of C. fasciculatum, now assumed extirpated, was located within an area proposed for underburning in (T47N R11W S17). One populations of C. montanum is located within an area proposed for underburning in (T47N R11W S27). Prior to implementation, all suitable habitat for these species which falls within proposed activity areas will be surveyed. Suitable habitat is present in the following proposed activity areas: • Roadside Hazard Tree Removal: This activity along the 46N50, 47N25Y, 47N70, 47N67, 47N82, 47N83, 47N70A, and 47N80 roads has some potential to affect habitat, and individuals or populations if present, by direct mechanical damage or indirectly through ground disturbance related to tree removal. Canopy alteration is not expected to be a significant factor – due to pre-existing fire effects. PDFs are expected to prevent or minimize effects to populations of these species, if they are located in this activity area. Some effects may be unavoidable. This activity may cause a short term decline in habitat condition and any populations located during surveys, but in the long term habitat suitability and the viability of any populations located would be static; as soils and associated vegetation recover. • Fuels Reduction adjacent to Private Property (T47N R11W Sections 26 and 27): This activity will not directly affect individuals or populations of these species. Indirect effects would be tied largely to the health of associated vegetation or changes to the microclimate such as light, temperature, and humidity regimes. PDFs are expected to minimize negative effects to these species in this activity area. There is expected to be a long-term, indirect benefit to C. fasciculatum and C. montanum populations and suitable habitat by reducing excessive fuel loading and the potential for a future high severity wildfire. • Underburning (T47N R11W Sections 8, 9, 13, 14, 16, 17, 20, 21, 24, 25, 26, 27, 28, 33, and 34): This activity has some potential to affect individuals or populations by direct damage from flames and heat. Indirectly, fire may affect these species habitat by alterations to associated mycorrhizae or its host vegetation, or by altering canopy structure affecting humidity and shade regimes. Prescribed underburns typically burn at intensities that are low enough to avoid damaging below ground bulbs. C. fasciculatum and C. montanum populations on the Forest have been documented to be able to resprout the year after a low- intensity underburn when the population’s habitat is maintained. PDFs specifying the need for low-intensity backing fire in known locations where these species occur will diminish the potential for effects. In the long term this activity is expected to have a positive effect on the condition of these species habitat, leading to a static or increasing trend.

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• Large Woody Debris Placement in Horse Creek: No effect is expected to these species, directly or indirectly, as this activity will occur within or very near to the active stream channel.

Howell’s lousewort - Pedicularis howellii: Two known populations of this species occur in proposed underburn areas. One of these two populations is presumed extirpated from the 2017 Abney Fire. Prior to implementation, all suitable habitat for this species that falls within proposed activity areas will be surveyed. Suitable habitat for this species occurs in the following proposed activity areas: • Roadside Hazard Tree Removal: This activity along the 47N80, 48N20, 47N89, and 47N26 roads has some potential to affect habitat, and individuals or populations if present, by direct mechanical damage, or indirectly through ground disturbance related to tree removal. Canopy alteration is not expected to be a significant factor – due to pre- existing fire effects. PDFs are expected to prevent or minimize effects to these species in this activity area. Some effects may be unavoidable. This activity may have a minor short term negative effect, causing a short term declining trend in the number of individuals and/or the amount and condition of habitat; however in the long term this trend is expected to be static – as populations and habitat recover. • Underburning (T47N R11W Sections 8, 9, 10, 15, 16, and 22): This activity has some potential to affect habitat, and individuals or populations if present, by direct damage from flames and heat. Indirectly, fire may affect these species by alterations to associated mycorrhizae or its host vegetation, or by altering canopy structure. PDFs specifying the need for low-intensity backing fire in known locations where these species occur will diminish the potential for effects. In the short term this activity may have cause a minor declining trend in individuals and/or habitat condition; however, in the long term this activity is expected to have a positive effect on the condition of these species habitat, leading to a static or increasing trend. • Fuel Management Zone (T47N R11W Sections 10 and 15): Fuels treatments and fuel break maintenance would be expected to have no direct effect on populations of P. howellii, due to protections put in place per the PDFs of this analysis (Botany 1). Indirectly this activity may affect associated host vegetation; however, avoidance zones implemented via PDFs would largely protect vegetation within the site scale.

Phaeocollybia olivacea: Four populations of the ectomycorrhizal fungi species P. olivacea are known to occur in the project area (T47N R 11W Sections 26 and 27) and highly suitable habitat for this species exists in proposed activity areas primarily in the southeast portion of the project area. Project design features – such as higher retention standards for large living trees - developed to protect soil and forest health would provide protection to populations from direct and indirect effects; however, without flag and avoid protection, activities outside of medium to high burn severity areas may cause a short term loss or decline in habitat viability through impacts to fruiting bodies and mycelia. Suitable habitat for ectomycorrhizal fungi requires the presence of live host trees because these species are obligate symbionts. Indirect effects would occur as a result of the removal of living host trees which provide shade, nutrient and growth

19 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

substrate for fungi. These indirect effects may result in a short term decline in habitat condition or population viability where the species is present. Tree planting prescriptions in salvage and site prep and plant units would indirectly benefit ectomycorrhizal fungi habitat in the long term by increasing the speed at which conifers are re-established. This would cause an increasing trend in habitat condition through the creation and restoration of suitable habitat. Suitable habitat for this species occurs in the following proposed activity areas: • Roadside Hazard Tree Removal • Fuels Reduction adjacent to Private Property • Underburning • Large Woody Debris Placement in Horse Creek Fissidens aphelotaxifolius and Buxbaumia viridis: No populations of these moss species are known to occur in the project area; however, suitable habitat is likely present in or adjacent to streams in the project area. PDFs designed to protect streams and riparian areas are expected to protect habitat and populations. No direct effect would be expected to these species, while minor indirect effects to habitat may occur as a result of alterations to the canopy (in the case of hazard tree removal). Mielichhoferia elongata: No populations of this moss species are known to occur in the project area. Due to its preferred habitat, moist, rocky outcrops, this bryophyte would not be expected to be affected by proposed activities. Insufficient data is available to model or map highly suitable habitat for this species in the project area, however, it is unlikely that project activities would have significant impacts to its preferred habitat. Any suitable un-surveyed habitat located during field visit would be flagged for avoidance if deemed necessary. Cudonia monticola and Dendrocollybia racemosa: No populations of these fungi species are known to occur in the project area; however, suitable habitat for this species exists in proposed activity areas primarily in the southeast portion of the project area. Project design features associated with Aquatic Conservation Standards, soil stability and productivity, or retention of large woody debris and snags would protect or create areas of suitable habitat for saprophytic fungi. However, without flag and avoid protection, activities outside of medium to high burn severity areas may directly or indirectly cause a short term loss or decline in habitat condition or population viability through impacts to fruiting bodies and mycelia. Saprophytic fungi live in and feed on downed wood, detritus, and duff accumulated on the forest floor. Although, these species are not dependent upon specific vascular plant hosts, they require adequate canopy cover to retain sufficient moisture levels. Fuel reduction treatments would decrease the likelihood of another high severity fire event. Therefore, treatments would cause a long-term increasing trend in habitat condition through the maintenance and protection of the remaining suitable habitat. Suitable habitat for this species occurs in the following proposed activity areas: • Roadside Hazard Tree Removal • Fuels Reduction adjacent to Private Property • Underburning • Large Woody Debris Placement in Horse Creek

20 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Arabis macdonaldiana, Draba carnosula and Eriogonum hirtellum: No populations of these vascular plants are known to occur in the project area. Suitable habitat for these species is limited to the northwest corner of the project area, in the area proposed for hazard tree removal along the 47N80 (Bee Camp) Road. Surveys for these species will be completed prior to implementation of the project. Any populations of these species located during surveys will be flagged for avoidance. As a result, there would be no direct effects to these species. Indirectly, alterations of shade regime or canopy structure as a result of removing hazards or felling and leaving trees near populations may have a minor effect, but is not expected to cause a loss of individuals or declining trend in habitat condition. Blushing wild buckwheat – Eriogonum ursinum var. erubescens: No populations of this vascular plant species are known to occur in the project area. Suitable habitat for this species within the project boundary is limited to the ridgeline which proceeds south from Copper Butte through Sections 10, 15, and 22 (T47 R11W). Prior to implementation, all suitable habitat for this species that falls within proposed activity areas will be surveyed. All populations located will be flagged for avoidance, per the project design features (PDFs) of this project (See EA). Activities proposed within suitable habitat for this species are: • Roadside Hazard Tree Removal: This proposed activity occurs in suitable habitat for E. ursinum var. erubescens along the 47N26 and 47N89 roads. Activities may directly affect habitat via mechanical damage to individuals, and indirectly via ground disturbance; however, PDFs are expected to prevent or minimize effects to this species’ habitat in this activity area. This activity may have a minor short term negative effect, causing a short term declining trend in the condition of habitat; however in the long term this trend is expected to be static. • Fuel Management Zone: The area of this proposed activity covers the majority of suitable habitat for E. ursinum var. erubescens within the project area. Fuels treatments and fuel break maintenance would have some small potential to disturb habitat through mechanical impacts and soil effects from pile burning. Indirect beneficial effects may result from the removal of brush and competing vegetation around populations. Trends in habitat condition would remain static or have a slight downward trend in the short term, and be static or slightly increasing in the long term. • Salvage Logging with Site Preparation and Planting: Proposed units 35, 38, 39 fall within suitable habitat for E. ursinum var. erubescens. Ground-based and skyline logging may directly affect habitat for this species via ground disturbance. If populations of this species are located in the project area, areas of suitable habitat would be excluded from site prep and plant activities, as these activities would result in a long term declining trend in habitat condition. This activity may result in a short term declining trend in habitat condition. In the long term, the effects of logging would be expected to result in static trend in habitat condition. • Site Prep and Plant: A proposed site-prep-and-plant unit is located in the SE corner of section 15 (T47N R11W) between the 47N26 and 47N89 roads. The portion of this unit that occurs on the rocky ridgeline is within suitable habitat for E. ursinum var. rubescens. If populations of the species are located in or near this area, all suitable habitat will be buffered and excluded from proposed site prep and plant activities, consequently this activity will not directly or indirectly effect E. ursinum var. erubescens.

21 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

• Underburning: This activity has some potential to affect individuals or populations directly via damage from flames and heat; however, due to the preferred sparse rocky habitat of this species, and PDFs designed to protect populations if located, these effects are expected to be minimal. Indirectly, fire may have a positive effect on habitat by maintaining an open canopy and removing encroaching vegetation. This activity would have a static effect on habitat condition trend in the short term and a slight increasing effect in the long term.

Henderson’s fawn lily – Erythronium hendersonii: Suitable habitat for this species occurs in the project area, primarily in the southern portion, at lower elevations. Prior to implementation, field checks will be performed to determine if suitable habitat exists for the species within proposed activity areas. All suitable habitat will be surveyed prior to implementation, and any populations located will be protected via PDFs. Activities proposed within suitable habitat for this species are: • Roadside Hazard Tree Removal: This activity on roads 47N05YD, 48N20, 46N50, 47N25Y, 47N70, 47N74, 47N74A may overlap with suitable habitat for E. hendersonii. Activities have some potential to affect habitat, and individuals or populations if present, by direct mechanical damage, or indirectly through ground disturbance related to tree removal. Canopy alteration is not expected to be a significant factor – due to pre-existing fire effects. PDFs are expected to prevent or minimize effects to any populations located in this activity area. Some effects may be unavoidable. This activity may have a minor short term negative effect, causing a short term declining trend on the condition of habitat; however in the long term this trend is expected to be static. • Fuels Reduction adjacent to Private Property (T47N R11W Section 26): No direct effects are expected to populations or individuals as a result of this activity. Effects to habitat may occur as a result of changes to associated vegetation. Ultimately this activity is expected to have a beneficial effect to the species’ habitat, by maintaining an open understory and mixed-species canopy. This activity would have a static effect on habitat condition trend in the short term and a slight increasing effect in the long term. • Salvage Logging with Site Preparation and Planting (T47N R11W Sections 12, 20 and 21): Proposed units 93 and 9 fall within potentially suitable habitat for E. hendersonii. No direct effects are expected to E. hendersonii individuals as a result of this activity. This activity may negatively affect habitat through ground disturbance and alterations to canopy structure, and may result in a short term declining trend in habitat condition. In the long term, this activity would have a static effect on the habitat condition trend. • Underburning (T47N R11W Sections 16, 20, 21, 22, 26, 27, 28 and 29): This activity has some potential to affect habitat through impacts to soils and associated vegetation from flames and heat. PDFs specifying the need for low-intensity backing fire in known locations where these species occur will diminish the potential for effects. Wayside aster – Eucephalus vialis: Due to the wide range of habitats this species is known to occupy, much of the project area which experienced little to light fire severity is considered potentially suitable habitat. Prior to implementation, surveys will be performed in areas considered to be most likely to contain populations. Some direct effects to individuals or habitat

22 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

may be unavoidable in areas proposed for salvage logging, hazard tree removal, fuels reduction, fuel break and underburning; however, all of these activities are expected to have an indirect neutral or beneficial effect to E. vialis habitat. Beneficial effects would be those that promote or maintain a conifer or mixed-species forested environment with an open understory. The proposed activities would cause a short term declining trend in habitat condition, but would be expected to cause a long term increasing trend.

Howell’s tauschia - Tauschia howellii: Suitable habitat for this species occurs in the project area above 5500 feet elevation. Prior to implementation, all suitable habitat for this species that falls within proposed activity areas will be surveyed. Suitable habitat for this species occurs in the following proposed activity areas: • Roadside Hazard Tree Removal: This activity along the 47N89 road has some potential to affect habitat by ground disturbance related to tree removal. Canopy alteration is not expected to be a significant factor – due to pre-existing fire effects. This activity may have a minor short term negative effect, causing a short term declining trend on the condition of habitat; however in the long term this trend is expected to be static. • Salvage logging with site preparation and planting: Suitable habitat for T. howellii may occur in proposed salvage units 35 and 36. This activity may negatively affect habitat via ground disturbance. Alterations to canopy structure would have the potential for both positive and negative effects, as T. howellii prefers forested openings. Planting, post- logging would be expected to restore suitable habitat in the long-term. This activity may have short term negative effects, causing a short term declining trend on the condition of habitat; however in the long term this trend is expected to be static. • Underburning (T47N R11W Sections 9, 10 and 15): This activity would be expected to have a beneficial effect on T. howellii habitat by maintaining forested openings and a relatively open understory. This would result in a static or increasing trend in habitat condition in both the short and long term. • Fuel Management Zone (T47N R11W Sections 10 and 15): Fuels treatments and fuel break maintenance would be expected to have a beneficial effect on T. howellii habitat by maintaining forested openings and a relatively open understory. This would result in a static or increasing trend in habitat condition in both the short and long term. Robust false-lupine - Thermopsis robusta: Potentially suitable habitat for this species occurs in the project area, primarily in the southern portion, at lower elevations below 4500 feet elevation. Prior to implementation, field checks will be performed to determine if suitable habitat exists for the species within proposed activity areas. All suitable habitat will be surveyed prior to implementation, and any populations located will be managed for protection or beneficial effects. Because this species has an affinity for ground-disturbance and early-seral conditions, in some cases avoidance protocols may be inappropriate. Activities proposed within potentially suitable habitat for this species are: • Roadside Hazard Tree Removal: All locations for this activity occurring below 4500 feet elevation and in areas with low to no fire severity are considered potentially suitable habitat. Activities may directly affect the species via mechanical damage to individuals, and indirectly via ground disturbance in or near individuals. Due to this species’ affinity

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for disturbed areas and openings, these activities would be expected to ultimately have a beneficial effect. This activity may have short term neutral or positive effect, causing a short term static or increasing trend on the condition of habitat. In the long term, habitat condition trend is expected to be static. • Fuels Reduction adjacent to Private Property (T47N R11W Section 26): While this activity is not ground-disturbing, alterations to understory vegetation would potentially improve habitat conditions for T. robusta. Ultimately this activity is expected to have a beneficial effect to the species, by maintaining an open understory and mixed-species canopy. This activity may create a short term increasing trend in habitat condition. In the long term, this trend is expected to be static. • Salvage Logging with Site Preparation and Planting (T47N R11W Sections 12, 20, 21 and 26): Ground disturbance and changes in canopy structure as a result of this activity would be expected to have a beneficial effect on T. robusta habitat. If populations are located, some ground disturbance in or near populations may be allowed or even encouraged, as this species thrives in disturbed areas. This activity would create an increasing trend in habitat condition in the short and long term. • Underburning: This proposed activity would be expected to have a beneficial effect on T. robusta habitat by maintaining forested openings and a relatively open understory. This would result in a static or increasing trend in habitat condition in both the short and long term.

Cumulative Effects All activities and factors listed in Appendix B of the Seiad Horse Risk Reduction Project Environmental Assessment could have additional effects to sensitive botanical species populations in the project area when added to Alternative 2 or 3. Sensitive species viability and persistence may be both beneficially and negatively affected by cumulative Forest projects. Project design features have been or will be incorporated into all on-going and future foreseeable Forest projects to limit negative effects on population viability trends. Consequently, the cumulative effect of Forest projects on Sensitive species would be expected to cause a short-term declining trend in population viability as individuals are lost, but would create a long-term increasing trend in population viability from the beneficial impacts of management activities on suitable habitat (i.e. fuel treatments, habitat creation). Projects on private lands are not required to protect Sensitive botanical species, and subsequently actions on private lands may lead to a localized downward trend in population viability for these species. If that is the case, on-going and future foreseeable projects on private lands would have a declining cumulative effect on population viability trends for Sensitive species. However, without knowing how many species and/or populations are present, how many may be effected, and how project activities will affect habitat conditions it is difficult to determine how potential effects from private actions would cumulatively influence population viability trends.

Alternative 3

Direct and Indirect Effects Effects would be identical to those disclosed under Alternative 2 with the exception of:

24 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

• Roadside hazard reduction: Removal of 2 miles of hazard reduction on the 47N80 (Bee Camp) road would result in a slightly lower risk of direct effect to habitat or populations (if located) in that area. For Arabis macdonaldiana, Draba carnosula and Eriogonum hirtellum, this alternative would remove all project-related risks to these species – as the area removed is the only suitable habitat in the project area. • Salvage Logging with Site Preparation and Planting: The removal of units and temporary roads in sections 10 and 15 would result in a lower risk of direct effect to habitat or populations (if located) in those areas. Areas excluded from all activities would be expected to have identical effects to those identified in the no-action alternative. Compared to Alternative 2, this alternative would be more beneficial to sensitive plants and their habitats in the area near the Siskiyou Crest, generally above 5500 feet elevation, as it would allow natural succession in a mixed-severity burned environment without disturbance or interference from management activities. • Fuel Break: The expansion of the fuel break in sections 10 and 15 would somewhat increase the risk of direct effects to habitat or populations (if located) in that area. However, as noted in the species accounts in Alternative 2, some of the effects of this action would be beneficial to sensitive plants and their habitats.

Cumulative Effects All activities and factors listed in Appendix C of the Seiad Horse Risk Reduction Project Environmental Assessment could have additional effects to sensitive botanical species populations in the project area when added to Alternative 3. Sensitive species viability and persistence may be both beneficially and negatively affected by cumulative Forest projects. Project design features have been or will be incorporated into all on-going and future foreseeable Forest projects to limit negative effects on population viability trends. Consequently, the cumulative effect of Forest projects on Sensitive species would be expected to cause a short-term declining trend in population viability as individuals are lost, but would create a long-term increasing trend in population viability from the beneficial impacts of management activities on suitable habitat (i.e. fuel treatments, habitat creation). Projects on private lands are not required to protect Sensitive botanical species, and subsequently actions on private lands may lead to a localized downward trend in population viability for these species. If that is the case, on-going and future foreseeable projects on private lands would have a declining cumulative effect on population viability trends for Sensitive species. However, without knowing how many species and/or populations are present, how many may be effected, and how project activities will affect habitat conditions it is difficult to determine how potential effects from private actions would cumulatively influence population viability trends.

25 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Comparison of Alternatives

Table 5: Effects of Alternatives on trends in sensitive species habitat condition in the Project area.

Sensitive Plant Population Alternative 1 Alternative 2 Alternative 3 Viability Trend Cypripedium Short term declining, Short term declining, Short term declining, fasciculatum long term static. long term static. long term static. Cypripedium Short term declining, Short term declining, Short term declining, montanum long term static. long term static. long term static. Pedicularis Short term declining, Short term declining, Short term declining, howellii long term static long term static. long term static. Phaeocollybia Short term declining, Short term declining, Short term declining, olivacea long term static. long term static. long term static. Buxbaumia Static Static Static viridis Fissidens Static Static Static aphelotaxifolius Mielichhoferia Static Static Static elongata Cudonia Short term static, long Short term declining, Short term declining, monticola term increasing. long term increasing. long term increasing. Dendrocollybia Short term static, long Short term declining, Short term declining, racemosa term increasing. long term increasing. long term increasing. Arabis Static Static Static macdonaldiana Draba carnosula Static Static Static Eriogonum Static Static Static hirtellum Eriogonum Short term Short term decreasing, ursinum var. Static decreasing, long term long term static or erubescens static or increasing. increasing. Erythronium Short term Short term decreasing, Short term decreasing, hendersonii decreasing, long term long term static or long term static. static or increasing. increasing.

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Sensitive Plant Population Alternative 1 Alternative 2 Alternative 3 Viability Trend Eucephalus vialis Short term Short term decreasing, Short term decreasing, decreasing, long term long term static or long term static. static or increasing. increasing. Tauschia howellii Short term Static decreasing, Long Static term static. Thermopsis Short term Short term increasing, Short term increasing, robusta increasing, long term long term static. long term static. static.

Compliance with law, regulation, policy, and the Forest Plan The Seiad Horse Risk Reduction Project complies with section 7 of the Endangered Species Act of 1973, as amended, in the preparation of a Biological Evaluation; Forest Service Policy (FSM 2670), and Klamath National Forest Plan Standards and Guidelines for Sensitive plant species have been met by managing populations for viability where possible.

Determination of Effects

Alternative 1 Under the no action alternative it is my determination that the Seiad Horse Risk Reduction Project will not affect the Sensitive plant species: Cypripedium fasciculatum, Cypripedium montanum, Pedicularis howellii, Phaeocollybia olivacea, Buxbaumia viridis, Fissidens aphelotaxifolius, Mielichhoferia elongata, Cudonia monticola, Dendrocollybia racemosa, Arabis macdonaldiana, Draba carnosula, Eriogonum hirtellum, Eriogonum ursinum var. erubescens, Erythronium hendersonii, Eucephalus vialis, Tauschia howellii and Thermopsis robusta.

Alternative 2 Under alternative 2 it is my determination that the Seiad Horse Risk Reduction Project may affect individuals, but is not likely to result in a trend toward federal listing or a loss of viability for the Sensitive plant species: Cypripedium fasciculatum, Cypripedium montanum, Pedicularis howellii, Phaeocollybia olivacea, Buxbaumia viridis, Fissidens aphelotaxifolius, Mielichhoferia elongata, Cudonia monticola, Dendrocollybia racemosa, Arabis macdonaldiana, Draba carnosula, Eriogonum hirtellum, Eriogonum ursinum var. erubescens, Erythronium hendersonii, Eucephalus vialis, Tauschia howellii and Thermopsis robusta.

Alternative 3 Under alternative 3 it is my determination that the Seiad Horse Risk Reduction Project may affect individuals, but is not likely to result in a trend toward federal listing or a loss of viability for the Sensitive plant species: Cypripedium fasciculatum, Cypripedium montanum,

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Pedicularis howellii, Phaeocollybia olivacea, Buxbaumia viridis, Fissidens aphelotaxifolius, Mielichhoferia elongata, Cudonia monticola, Dendrocollybia racemosa, Arabis macdonaldiana, Draba carnosula, Eriogonum hirtellum, Eriogonum ursinum var. erubescens, Erythronium hendersonii, Eucephalus vialis, Tauschia howellii and Thermopsis robusta.

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Review of Survey and manage Botanical Species

Introduction The purpose of this review is to analyze the Seiad Horse Risk Reduction Project (Project) in sufficient detail to ensure that it is in compliance with the Northwest Forest Plan requirements for Survey and Manage botanical species.

Current Policy and Management Direction The Bureau of Land Management and Forest Service have adopted standards and guidelines for the management of habitat for late-successional and old-growth forest related species within the range of the northern spotted owl, commonly known as the Northwest Forest Plan (NWFP). The NWFP includes measures for management of known sites, site-specific pre-habitat disturbing surveys, and/or landscape scale surveys for about 400 rare and/or isolated species. The standards and guidelines for these mitigation measures are known as survey and manage (SM). The most recent survey and manage direction (USDA 2014b) directs Agencies to follow the 2001 Record of Decision (ROD) for Amendments to the Survey and manage, Protection Buffer, and other Mitigation Measure Standards and Guidelines (USDA/USDI 2001), and the December 2003 species list (USDA/USDI 2003), except for the red tree vole which remains a Category C. Category descriptions are provided in the table (Table 6) below.

Table 6: Requirements for survey and manage categories. Category Relative Pre- Manage all known Strategic surveys Rarity disturbance sites surveys A Rare Yes Yes Yes, not required for B Rare No/Eq. Effort* Yes Yes, NEPA requirement C Uncommon Yes High-priority only Yes, not required for D Uncommon No High-priority only Yes, not required for E Rare No Yes Yes, not required for F Uncommon No No Yes, not required for

*If Strategic Surveys are not completed, Equivalent Effort surveys are required. To be in compliance with the 2001 ROD, projects in old-growth forest types must have pre- disturbance (practical) surveys conducted if the activity is potentially considered to be habitat- disturbing (Category A and C), and known and high-priority sites must be managed to protect persistence. “Habitat-disturbing activities are defined as those disturbances likely to have a significant negative impact on the species’ habitat, its life cycle, microclimate, or life support requirements” (USDA/USDI 2001 – Standards and Guidelines, p.22). Species-specific standards and guidelines, survey protocols, and management recommendations from the Northwest Forest Plan are identified below under species effects analysis, if applicable.

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Survey and manage requires Strategic or Equivalent Effort surveys be conducted for Category B species if habitat disturbing projects are occurring in old growth forest. Strategic surveys are large-scale studies performed across the administrative area to detect locations, distribution, and abundance of Category B species. If Strategic surveys have not been completed within the specified timeframe, Equivalent Effort surveys are required. Equivalent Effort surveys are pre- disturbance surveys that follow established protocols, similar to practical surveys. Currently, Strategic Surveys for Category B fungi are not considered complete in California and therefore Equivalent Effort surveys are required for habitat disturbing projects occurring in old growth forest (USDA/USDI 2001 Standards and Guidelines pp 21-30, Van Norman, K. and R. Huff. 2012). In 2006, Judge Pechman established four project categories that are exempt from SM Standards and Guidelines for pre-disturbance surveys and management of known sites. These project types include: A. Thinning projects in stands younger than 80 years old; B. Replacing culverts on roads that are in use and part of the road system, and removing culverts if the road is temporary or to be decommissioned; C. Riparian and stream improvement projects where the riparian work is riparian planting, obtaining material for placing in-stream, and road or trail decommissioning; and floodplain reconstruction, or removal of channel diversions; and D. The portions of projects involving hazardous fuel treatments where prescribed fire is applied. Any portions of a hazardous fuel treatment project involving commercial logging will remain subject to the survey and manage requirements except for thinning of stands younger than 80 years old under subparagraph (a) of this paragraph. Additionally, pre-disturbance surveys are not required for routine maintenance of improvements and existing structures including pulling ditches, clearing encroaching vegetation, managing existing seed orchards and falling hazard trees (USDA/USDI 2001, Standards and Guidelines, pg. 22).

Methodology To determine which species are known to occur or may potentially occur within the project boundaries the following resources were consulted: • Survey and manage species list from the 2003 Record of Decision (ROD) for Amendments to the Survey and manage, Protection Buffer, and other Mitigation Measure Standards and Guidelines (USDA/USDI 2003); • Klamath National Forest species occurrence records (Natural Resource Inventory Database), survey records, and site visit records from within the project boundary; • Klamath National Forest survey and manage strategic survey records (pending); • California Natural Diversity Database (CDNNB) • Existing Vegetation (EVeg) spatial data; and • Rapid Assessment of Vegetation Condition after Wildfire (RAVG) data.

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Preliminary Botanical Review An office preliminary field review was conducted to determine if the Seiad Horse Risk Reduction Project area contains any survey and manage populations and if suitable habitat is present within the proposed project area (Appendix A). During the preliminary botanical review, the proposed project area was determined to contain 11 Survey and manage species which are listed below in Table 7.

Table 7: Known Populations of Survey and Manage Botanical Species in the Project Area POPULATION SPECIES Category NUMBER(S)

Cypripedium fasciculatum C 1 Cypripedium montanum C 1 Phaeocollybia olivacea E (In California) 4 Ptilidium californicum A (In California) 1 2 Cantharellus subalbidus D

Phaeocollybia californica B 2 Phaeocollybia fallax D 1 Phaeocollybia kaufmanii D 1 Phaeocollybia piceae B 3 Ramaria rubrievanescens B 1 Ramaria rubripermanens B (In California) 1

Pre-disturbance surveys will be conducted for Category A and C species in project activity units where known sites and suitable habitat are still present, except for those occurring in activity areas which are excepted or exempted per the 2001 ROD or Pechman exemptions. Known occurrences of Category A, B and E species assumed to be extant within the Project area and high-priority populations of Category C and D species will be protected for continued persistence at the site. Protection measures will include flagging and avoiding extant populations and nearby suitable habitat in order to maintain necessary habitat characteristics. A preliminary habitat review based on aerial imagery, existing vegetation (EVeg) spatial data, RAVG data, and limited ground-truthing was conducted to determine if portions of the project area meet the required features to trigger equivalent effort surveys for category B species. Based on this review, it was determined that Category B fungi equivalent effort surveys are not necessary within the project area because habitat disturbing activities will not be occurring in stands defined as old growth.

Summary of Findings A botanical assessment for Survey and manage vascular plant, bryophyte, lichen, and fungi, species has been completed for the Seiad Horse Risk Reduction Project (Appendix A). The project complies with the 2001 Record of Decision and Standards and Guidelines for Amendments to the Survey and manage, Protection Buffer, and other Mitigation Measure

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Standards and Guidelines by managing all known sites of SM species in the project area that are not otherwise exempt, and by conducting required pre-disturbance surveys.

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Unique Botanical Areas of Concern • Cook and Green Botanical Area occupies 700 acres and contains a mosaic of plant communities. It is considered to be the dividing line between the eastern and western Siskiyou Mountain Range. This area has a phenomenal concentration of native plant species, one of the richest areas in California, with possibly as many as 300 species present. Alternatives 2 and 3 of this Project propose underburning and hazard tree removal within this SIA. Underburning would occur throughout the entirety of the SIA, while hazard tree removal would occur along the 48N20 Road where it borders the SIA. Pre-disturbance surveys for federally protected botanical species would be conducted prior to Project implementation. Project design features would minimize negative effects to protected botanical species and their habitat. Appropriately timed underburning would be expected to promote botanical diversity, and protect the SIA from near-future high-severity fire effects. Project design features for hazard tree removal would ensure that adequate coarse woody debris and large wood is retained on the landscape to maintain or promote plant biodiversity. The area would be monitored for invasive plant species and any populations of such would be prioritized for treatment. The proposed action under Alternatives 2 and 3 would not alter or damage the unique characteristics for which this SIA was established. • Baker Cypress Botanical Area is located approximately four miles northeast of the town of Seiad Valley, California. This area contains a stand of rare Baker Cypress (Hesperocyparis bakeri). Part of the area was burned in the 1987 fires which triggered the germination of cypress cones and seeds lying in the soil for years. The hundreds of seedlings now growing there made this the healthiest stand of Baker cypress on the Forest. The 2017 Abney Fire re-burned the majority of the botanical area and has stimulated a new cohort of seedlings. The ultramafic soils in the area also support a number of other rare plant species. Alternatives 2 and 3 of this Project propose underburning which overlaps this SIA on approximately six acres along the prominent ridgeline in section 17 (T47N R11W). However, underburning is not expected to take place in this portion of the SIA for up to fifteen years (PDF Botany 9), in order to allow the new cohort of Baker cypress which was stimulated by the Abney Fire to reach cone-producing maturity. The proposed action under Alternatives 2 and 3 would not alter or damage the unique characteristics for which this SIA was established, and is likely to promote the health of remaining Baker cypress stands by stimulating germination and eliminating competing vegetation.

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Non-native Invasive Plant Risk Assessment

Introduction This weed risk assessment analyzes the effects of the proposed project on Klamath National Forest listed non-native invasive species (NNIS) within the project area boundaries. The Klamath National Forest has placed a high priority on management of NNIS, which includes reducing introduction and spread of NNIS on the Forest (USDA 2011). The purpose of this document is to evaluate the Seiad Horse Risk Reduction Project (Project) in sufficient detail to determine its effects on NNIS. This risk assessment follows the standards established by Forest Service Manual 2900 direction (USDA 2011). Current Policy and Management Direction The Forest Plan includes Forest-wide Standards and Guidelines for vegetative management that call for all silvicultural practices to consider how to best prevent introducing noxious or alien weeds. (USDA 1995) Forest Service Manual 2900 Invasive Species Management (USDA 2011) includes a policy statement calling for a risk assessment for noxious weeds to be completed for every project. Specifically the manual states: • Determine the risk of introducing, establishing, or spreading invasive species associated with any proposed action, as an integral component of project planning and analysis, and where necessary provide for alternatives or mitigation measures to reduce or eliminate that risk prior to project approval (FSM 2903-4).

• Use contract and permit clauses to require that the activities of contractors and permittees are conducted to prevent and control the introduction, establishment, and spread of aquatic and terrestrial invasive species. For example, where determined to be appropriate, use agreement clauses to require contractors or permittees to meet Forest Service- approved vehicle and equipment cleaning requirements/standards prior to using the vehicle or equipment in the National Forest System (FSM 2903-5).

Forest Service Manual 2900 Invasive Species Management (USDA 2011) also includes Executive Order #13112 which directs Federal agencies to: • Identify actions that may affect the status of invasive species.

• Use relevant programs and authorities to: (a) prevent the introduction of invasive species; (b) detect and respond rapidly to and control populations in a cost effective and environmentally sound manner; (c) monitor; (d) restore; (e) research; and (f) promote public education on invasive species within administrative budgetary limits.

• Not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species.

Methodology

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The California Department of Food and Agriculture, and the Siskiyou County Department of Agriculture manage NNIS by use of the same list and risk rating criteria (CDFA 2010). The Klamath National Forest Noxious Weed and Non-native Invasive Plant List (Appendix B) includes 45 priority weeds from the State and County lists that are known or expected to occur on the Klamath National Forest. Based on inventories and current understanding of species’ ranges, a total of 30 high priority NNIS are on the list (USDA 2013b). In addition, there are 15 species of moderate and low priorities also included on the list that may be addressed in projects if those species are a problem locally. This list is used for resource management and decision- making, and is subject to change to reflect new information. To determine which NNIS are located within the project area the following resources were consulted: • Klamath National Forest Noxious Weed and Non-native Invasive Plant List (Appendix B).

• Klamath National Forest species occurrences records (Natural Resource Inventory Database - Invasive Species Survey and Inventory Application).

• Klamath National Forest NNIS treatment records (Forest Service Activity Tracking System database).

• Klamath National Forest non-native invasive species treatment database

Inventory and Mapping The Forest Service has developed national standards and protocols for the inventory, monitoring, and mapping of invasive plants (USDA 2013c). NRM – TESP/IS (Invasive Species Survey and Inventory Application) and NRM-FACTS (Forest Activity Tracking System) are the databases of record for all survey and inventory data, and treatment and treatment monitoring activities for all invasive species management activities on the forest. These databases were used for information on NNIS sites that are currently mapped within or adjacent to the project area. Annual weed inventories are conducted throughout the Forest on a rotating basis across landscapes. If new invaders are discovered, they are mapped and a treatment plan is created based on priority and program capacity.

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Risk Assessment The invasive species risk assessment was developed to standardize the process for determining the risk of introducing or spreading noxious weeds associated with a project. For projects having a moderate to high risk of introducing or spreading noxious weeds, the project decision document must identify noxious weed control measures that must be undertaken during project implementation (FSM 2903.04). Risk of weed spread within the Project area is evaluated using the following five risk factors: • Known populations of NNIS within the Project area.

• Vulnerability of the Project area to NNIS invasion.

• Possible non-Project related vectors that may contribute to NNIS spread.

• The amount of habitat alteration expected to result from Project activities.

• Increased vectors as a result of Project implementation.

The risk analysis of introducing or spreading NNIS with the proposed activities are generally described as very low, low, moderate, high, or very high, with the following definitions: • Very low: no measurable effect on existing NNIS infestations or susceptible habitat.

• Low: existing NNIS infestations and/or susceptible habitat not likely affected.

• Moderate: existing NNIS infestations or susceptible habitat affected, with the potential for expansion into un-infested areas and/or establishment of new invaders.

• High: existing NNIS infestations and/or susceptible habitat affected, with a high likelihood of expansion into un-infested areas and/or establishment of new invaders.

• Very High: existing NNIS infestations and/or susceptible habitat affected. Expansion or establishment of new invaders in un-infested areas is a certainty

If the above criteria are applied to areas that contain resources which would be put at risk by the presence of invasive plant species (i.e. wilderness character, sensitive plant site, special interest area) then the risk rating determined above may be increased by one level. A risk analysis was conducted based on current distribution of NNIS in habitats similar to those found in the proposed treatment areas and on the types of proposed project activities. The estimation of risk of NNIS spread and introduction of new NNIS invaders from the proposed activity is based on peer-reviewed literature, experience in the project area and on similar sites on the Forest, and professional judgment. Effects of proposed actions on NNIS spread are based on the amount of canopy removal, on the predicted amount of soil and/or understory vegetation disturbance, and on the predicted effectiveness of the project design features in each alternative. Proposed actions with greater

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disturbance of existing vegetation and with greater soil disturbance would have a higher risk of NNIS spread.

Analysis Indicators The effects of alternatives on non-native invasive species are compared using the following indicator: • The risk of introducing and/or spreading non-native invasive species.

Measures Risk of introduction or spread of NNIS can be characterized qualitatively as very low, low, medium, high, or very high.

Spatial and Temporal Bounding of Analysis Area Determination of the geographic bound of the risk analysis area for weeds considered the extent of currently documented weed infestations and likely seed dispersal distances. Transport of weed seeds into or out of the project area is possible, with occasional transport over long distances (such as on vehicles). However, it would be difficult to predict the extent of such long-distance dispersal. It is likely that most seeds of noxious weeds would fall close to the parent plant. In addition, road systems and lands adjacent to the project area have noxious weed infestations similar in composition and distribution to those in the project area, so transport of weed seeds to these lands from the project area would have little additional impact. For these reasons, the effects analysis area for noxious weeds includes the project area and the main haul route to the project area. The temporal bounding for species of concern will be less than five years for the short-term effects and greater than five years for long-term effects. Temporal boundings were chosen to account for seed germination and dormancy characteristics, as well as to account for the difficulty in identifying biennial and perennial vegetative life stages (rosettes).

Affected Environment The analysis area contains a mix of private and federal lands, all of which were affected by the 2017 Abney Fire. For a general description of the vegetative condition and fire impacts on the area, see the Affected Environment portion of the BA for TEPC species. While NNIS populations are largely accounted for on federal land or road right of ways, those on private are mostly unknown. Five non-native invasive species are present within the project area. Of these, three are considered to be high priority and two are considered to be moderate priority on the Forest. A list of NNIS species, their Forest priority, number of populations, and infested acres in the project area are displayed below in Table 8. Burned Area Emergency Restoration (BAER) surveys and monitoring will be ongoing during the field season of 2018 which will aim to document any spread of NNIS as a result of the Abney Fire suppression efforts. Of particular concern are NNIS propagules that may have been introduced from outside the analysis area, such as from the incident command post. No NNIS infestations are documented on haul routes for two road miles beyond the project boundary, however it is still possible that undocumented infestations occur along these roads.

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Affected Non-native Invasive Species

Species Accounts

Table 8: Known populations of NNIS within the Project area.

Forest Scientific Name Populations Total Acreage Priority

Centaurea diffusa High 1 0.1 Centaurea maculosa* High 2 0.85 Centaurea solstitialis* Moderate 2 0.6 Cytisus scoparius High 1 1.5 Isatis tinctoria* Moderate 1 0.2

*Due to incomplete surveys, numbers are likely higher.

Centaurea diffusa – diffuse knapweed Centaurea diffusa is a Category A species and a high priority for the Forest. It is a biennial to short-lived tap-rooted perennial. It is native to south-eastern Europe, and was likely introduced through contaminated crop seeds. It readily outcompetes native plants not only by being more tolerant to conditions such as drought, but also through allelopathy – excreting a chemical that inhibits root growth of other plants. It can be mistaken for spotted knapweed, but diffuse knapweed plants are shorter, stiffer, prickly and more of a grey-green color (AISC, 2014). Centaurea diffusa spreads through the sexual production of seeds. Main dispersal is through animal and human transport of the barbed seed heads. Dispersal can also be enhanced through soil and water movement. All treatments for this species are manual hand-pulling, and given the limited number of infestations known, it is a high priority species for treatment. There are 15 sites on the Forest, and one site in the project area with a total of 0.1 infested acres (Table 8).

Centaurea maculosa – spotted knapweed This species is a short-lived (up to 9 years) perennial forb that forms a deep tap-root from a basal rosette, and produces multiple stems. The taxonomy of this species in North America has seen many changes, and the name used here, C. maculosa, is a synomym for C. biebersteinii and C. stoebe ssp. micranthos. Centaurea maculosa was discovered to be a problem on the Forest in 1997, and since then, control efforts have been on-going with some significant successes. However, this species can disperse via multiple vectors and there are still occasions where infestations are discovered for the first time, particularly in areas of mixed land ownerships where ground disturbance has been significant. Centaurea maculosa reproduces solely through the sexual production of seeds. An individual plant can produce as many as 40,000 (DiTomaso and Healy, 2007), although production is variable depending on site condition, plant age, herbivory, and seed predation. Seeds can remain viable in the soil for more than 15 years (personal communication, Knight, M., 2015). Seed

38 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project dispersal is primarily facilitated by human activities: roads, machinery, contaminated hay, recreation; but can also be spread quite quickly on animals, birds and through waterways and wind. Centaurea maculosa is highly adaptable, and can be found in multiple habitats, the common denominator being disturbance. The species is difficult to see unless it is flowering, which occurs late in the season, usually July-October. Since the taproot is so deep-seated, fire in not likely to kill this species, or kill seeds in the seed bank, making it one of the first plants to come back after fire. This is exactly what was observed in the Salmon Fire of 2013, where dormant seed beds of C. maculosa were stimulated to germinate post fire. Centaurea maculosa is an A-rated pest and a high priority species on the Forest. Most spotted knapweed infestations on the Forest are being actively controlled by hand-pulling. This method, if applied consistently, can be effective control as long as revisits are conducted regularly to capture re-sprouting individuals. There are currently 112 sites on the Forest, with two sites occurring in the project area for a total of 0.85 infested acres (Table 8). Centaurea solstitialis – yellow starthistle

This species is an annual to biennial plant that grows up to two meters tall and has multiple branched stems with many flower heads subtended by spiny bracts. Plants reproduce by seed, with large plants producing as many as 75,000 seeds. Centaurea solstitialis was originally introduced into California from the Mediterranean region around 1850 and currently infests approximately 20 million acres in California. Plants occur in open, disturbed areas such as roadsides, burns, and logged areas, and can spread rapidly into habitats with open canopies such as grasslands and oak woodlands (DiTomaso and Healy 2007). Seeds are dispersed by wind, water, birds and mammals, and human activities via numerous vector pathways. Of particular concern is the potential for spread from contaminated straw, hence the requirement for certified weed free straw to be used. Seeds can remain viable in the soil for up to ten years (MSU 2001), however successfrul treatment regimens where seed set is avoided, have been observed to make great progress in three to four years. Centaurea solstitialis is a C-rated pest, and a moderate priority for the Forest (USDA 2013b) due to its widespread occurrence. Over 124 infestations have been identified on the Forest. Of those, two are known to occur within the Project area for a total infested acreage of 0.6 acres (Table 8). Cytisus scoparius – Scotch broom

This species is an aggressive woody shrub in the pea family. It is very difficult to control because of its prodigious seed production and long-lived seed bank. One, medium-sized shrub can produce over 12,000 seeds per year which remain viable in the soil for 30 years, and possibly longer depending on site conditions. (Zouhar 2005) Additionally, it is highly flammable, carries fire into the tree canopy, and increases the frequency and intensity of fire (Bossard 1991). Cytisus scoparius reproduces from seed and has the ability to sprout from the root crown following damage or destruction of above ground portions. Seeds are produced in legumes which forcibly eject seeds an average distance of 3 feet as they dry. (Zouhar 2005) C. scoparius seeds also contain elaiosomes that attract ants who gather the seeds and carry them back to their nest.

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(Bossard 1991) Subsequently, C. scoparius bushes are often found in abundance around ant nests. Because the seeds are smooth, they are not typically dispersed on the fur of wildlife or livestock, but may be transported by waterways, vehicles and equipment. Plants can re-sprout from the root crown following cutting, freezing, or fire. After fire, a flush of new seedlings is produced in areas with an existing seed bank (Zouhar 2005). Although the California Department of Food and Agriculture (CDFA) gives C. scoparius a C- rating for the state, it is a high priority species on the Forest. There are currently 125 populations of C. scoparius mapped on the Forest, with one population occurring in the Project area for a total of 1.5 infested acres (Table 8). Isatis tinctoria – dyer’s woad This species is a winter annual, biennial or short-lived perennial, and is widespread and expanding on the Forest and throughout Siskiyou County. It is difficult to eradicate due to its robust tap root, ability to resprout from the root crown following injury, and prolific seed production. The species has shown no elevation limits and forms large, dense colonies that have the potential to displace desirable native plant species. Areas subjected to disturbance, whether fire, flood, or human made, are highly susceptible to invasion by this species. Re-sprouting will occur from the taproot near the crown of the plant for several years if it is mechanically injured, although in some cases on the Forest, mowing with weed-eaters has been an effective control mechanism where the infestation is too large to hand-pull. Isatis tinctoria primarily spreads through seed production; however it will resprout from the taproot near the crown of the plant for several years following mechanical injury. (CDFA 2016) An average plant will typically produce 250 to 500 seeds per year. (CDFA 2016) Seeds are dispersed by vehicles along roadways, along waterways and by animals through ingestion. The seeds usually fall close to the parent plant, but wind can disperse seeds farther. (CDFA 2016) Fire will top kill existing plants, but not kill underground portions of the plant. Post-fire conditions may allow plants to spread more rapidly (Zouhar 2009), largely due to lack of competition from other plants and the existing seed bank which is not affected by fire, especially fast-moving fire. Isatis tinctoria is a C-rated pest species and a moderate priority species on the Forest. Isatis tinctoria is a common invasive found throughout the Forest with over 239 populations identified on the Forest. Of these, one population is in the Project area for a total of 0.2 infested acres (Table 8).

Environmental Consequences

Alternative 1

Direct and Indirect Effects Under Alternative 1, the no-action alternative, less priority would be given to the documentation and treatment of NNIS populations in the analysis area in both the short and long term. Currently, the risk of introduction and spread for NNIS is moderate due to the effects of the 2017 Abney Fire which significantly increased the area’s vulnerability. The Project area is assumed to be in a state of upward trend in infestations, due to fire suppression activities. Existing levels of use of the project area are relatively low, with the most significant being logging operations on

40 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

private land, and traffic along the Seiad Creek Road and Pacific Crest Trail. It is possible and likely that fire suppression efforts during the Abney Fire spread invasive plants within the project area. The effects of suppression-related seed dispersal will not be immediately evident for the sake of this analysis. This is an on-going process that has not been fully documented yet. BAER NNIS monitoring and treatments would occur in the burned area, but may fail to detect biennial or perennial species within the first year post-fire. Known NNIS There are five NNIS known to occur in the Project area infesting a total of 3.25 acres. Three of these species are ranked as High priority and two are Moderate. Under Alternative 1, areas which currently have NNIS infestations would continue to support these species, providing seed sources for dispersal into adjacent areas. The High priority species Centaurea maculosa and C. diffusa occur in areas of low expected traffic volume, while the Moderate priority species C. solstitialis and Isatis tinctoria occur in higher traffic areas, such as the Seiad Creek Rd. The Cytisus scoparius population is thought to be mostly controlled, though it will be monitored. BAER surveys and treatments would attempt to suppress these populations for the first year post- fire. Areas burned at high severity and/or disturbed by fire suppression or private logging activities will be highly vulnerable to invasion. Under Alternative 1 there would be a moderate risk of spread of these species in the Project area over the short term and this risk is likely to remain moderate over the long term. Habitat Vulnerability The Project area is highly vulnerable to the invasion of NNIS particularly in areas where severe fire intensity removed the majority of vegetation and duff layers that normally compete with and impede the establishment of invasive species. Bare ground has no buffer from invasion by introduced species, and functionally has higher nutritional availability due to the ash layer which provides a flush of nitrogen. Removal of forest canopy has also greatly increased the risk of NNIS invasion, as most NNIS species are shade intolerant. In the short term, early seral and edge-effect vegetation patterns would maintain a high-to-moderate vulnerability to NNIS invasion, while in the long term, areas that progress toward a forested state would have a reduced vulnerability while shrub-dominated or sparse areas would remain at a moderate to high risk level. Habitat within the Project area is very vulnerable and thus has a high risk of NNIS invasion in the short term, and a moderate risk over the long term. Non Project Dependent Vectors Non-native invasive species populations may be indirectly introduced and/or spread from non- project dependent vectors, such as public traffic (foot, vehicle, and equestrian), wind, birds, and mammals. Cattle grazing has some potential to spread invasive species in the eastern half of the project area. Additionally, logging occurring on private lands in the project area has the potential to introduce and spread NNIS as the private sector is not required to implement weed prevention measures. Vehicle traffic is relatively low in the project area, with the exception of Seiad Creek Road. The private land within the project boundary does have active timber operations. Known high- priority NNIS sites only occur along low-traffic routes. Non-project dependent vectors present a moderate risk of spreading and establishing NNIS in the short and long term.

41 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Habitat Alteration Expected as a Result of the Project No habitat alteration would occur as a result of project activities under a no action alternative. This risk factor does not apply to Alternative 1. Increased Vectors as a Result of Project Implementation Implementation of the No Action Alternative would not result in increased NNIS vectors as a result of Project implementation, and thus this risk factor does not apply to Alternative 1.

Summary of Indirect Effects Indirectly, some populations of NNIS may continue un-discovered in the project area without the emphasis for surveys treatments and monitoring that accompanies project implementation. BAER surveys and Forest invasives management would be expected to discover and, to some degree, treat many, but perhaps not all of these populations.

Cumulative Effects Alternative 1 will not have any direct effects on NNIS risk, and thus will not have cumulative effects.

Alternative 2 For a description of this alternative please see the Proposed Action section of the Seiad Horse Risk Reduction Project Environmental Assessment.

Direct and Indirect Effects Known Noxious Weeds present and adjacent Populations of five species occur within or adjacent to activities proposed under Alternative 2 (Table 9). Because Centaurea diffusa, Centaurea maculosa, Centaurea solstitialis, Cytisus scoparius, and Isatis tinctoria are located in activity units and along access or haul routes there is potential for spread through the disturbance of existing populations, activation of seed banks, and transport on equipment and vehicles. The High priority species C. maculosa and C. diffusa occur in or adjacent to areas proposed for salvage logging, underburning, site prep and plant, and hazard tree removal. Risk of spreading known NNIS species under Alternative 2 is high, in the short term where they overlap with the zone of effect for proposed activities. In the long term, the risk would be expected to decrease to moderate.

42 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Table 9: Number of known NNIS populations and acres that may be affected by Alternative 2 project activities.

Infested Road(s) (if Unit Scientific Name Activity Populations Acreage applicable) Number(s)

Centaurea maculosa Roadside Hazard Removal, Site Prep and 47N89, Salvage: 6, Plant, Salvage 47N89Y 39 Logging, Existing Landing 2 0.85 Centaurea solstitialis Salvage Logging, Roadside 46N50, Salvage: 31 Hazard 47N67 Removal, New Landing. 2 0.6 Centaurea diffusa Underburning, Site Prep and 47N76 Plant, Hazard Tree Removal 1 0.1 Cytisus scoparius Roadside 46N50, Hazard Removal 1 1.5 47N87.2 Isatis tinctoria Roadside Hazard 48N20 Removal 1 0.17 Habitat Vulnerability The Project area had major habitat disturbance due to the 2017 Abney Fire and subsequent suppression efforts. The loss of under- and over-story canopy cover, competing vegetation, and duff layers during these fires, as well as the disturbance to soils related to fire suppression activities has created a highly vulnerable environment for colonization and spread of non-native invasive species by removing barriers to establishment. The risk associated with habitat vulnerability under Alternative 2 is identical to that identified under Alternative 1, as it is a baseline condition. That is, high in the short term, moderate in the long term. Non-project Dependent Vectors Same as Alternative 1. Habitat Alteration Expected as a Result of Project Implementation Areas that burned at high - moderate severity are already highly susceptible to weed invasion because shade and duff layers, which typically provide a barrier to weed establishment, have been lost. Therefore, project activities are not expected to increase invasion potential through the removal of canopy cover or duff layers in these areas. Units with planned site preparation and planting activities will likely re-establish canopy cover at a quicker rate than those under a no-

43 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

action alternative. As canopy cover is re-established the potential risk and persistence of NNIS infestations is expected to decline. The maintenance, reconstruction, and creation of landings and temporary roads can contribute to the spread of NNIS infestations (Merriam et al. 2004). Infestations that may be impacted by landings, road construction and maintenance activities are displayed in Table 9. Soil disturbing activities, such as skidding/yarding or grading, may spread existing weed infestations and activate existing noxious weed seed banks. Any project activities that contribute to the movement of soils contaminated with NNIS propagules will contribute to the spread of infestations. Stockpiles of crushed aggregates can also be infested with NNIS which are easily spread during use of these stockpiles. Equipment carrying contaminated soils can contribute to long-distance dispersal by depositing seeds along haul routes and into stream crossings. Water- tenders may also spread NNIS propagules through waterways when filling their tanks, allowing new infestations to establish downstream. Species adapted to open disturbed sites will be primary colonizers in most units. Following establishment, NNIS infestations are extremely difficult to eradicate and alter native vegetation and soil structure. Given the chance to expand, NNIS infestations will displace native vegetative communities, fragmenting sensitive plant and animal habitat (Scott and Pratini 1995). Large infestations of NNIS, such as Cytisus scoparius and Centaurea solstitialis, alter fire behavior by changing vegetative communities, decreasing soil moisture, and increasing flammable fuels (Keeley et al. 2011). These changes to fire behavior will predispose Forest areas to burn more frequently and at higher intensities (DiTomaso and Healy 2007). Despite the disturbance already present in the Project area as a result of the 2017 Abney Fire, the risk for introduction and spread of NNIS infestations by project activities in the short term is very high, due in a large part to the proposed temporary road construction as well as the scope and intensity of the ground-disturbing project work proposed. In the long term, planting, natural revegetation, monitoring, and treatment of NNIS populations would reduce this risk to moderate to high. Increased vectors as a result of Project implementation New road construction is one of the primary contributors to noxious weed invasion (Merriam et al. 2004). The construction of new roads increases vehicular access, which can increase the risk of new introduction by vehicles. New temporary road construction and existing road reconstruction is planned in this project; however these roads will be closed and stabilized after use. Quickly closing and stabilizing roads, seeding with native grasses where necessary, and mulching with weed free straw would reduce the likelihood that the new temporary roads would become vectors for NNIS spread. Most introduced NNIS do not compete well in the presence of heavy mulch layers and where natives quickly establish vegetative cover. There would be an overall short-term increase in vectors due to Project activities. Project design features and mitigation measures would diminish these effects. Overall, this represents a high risk for introduction of NNIS. In the long term, risk associated with an increase in vectors would reduce to moderate.

Cumulative Effects All activities and factors listed in Appendix B of the Project Environmental Assessment may cumulatively affect the proliferation of NNIS infestations, especially projects on private lands

44 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

that are not required to mitigate the spread of NNIS infestations. On-going and future foreseeable Forest projects have been or will be evaluated for the risk of introduction and spread of NNIS infestations. Project design features have been or will be incorporated into Forest projects to limit their effects on the spread and introduction of NNIS infestations. The five risk factors combined have a high potential for NNIS introduction and spread within the project area for Alternative 2, due to the high level of ground disturbing activities and increased vectors. Project design features and mitigation measures are designed to reduce or minimize these effects; however the risk would remain high due to the pre-existing condition. On-going and future foreseeable projects would also implement mitigation measures aimed at reducing NNIS introduction and spread. Unfortunately, project design features cannot eliminate risk and it is expected that new NNIS infestations would still become established in spite of these mitigation measures. Consequently, the cumulative risk of NNIS introduction and spread from Forest projects would increase, resulting in a continued risk rating of high. There is one grazing allotment that overlaps treatment units and may contribute to the long- distance dispersal of NNIS infestations in the project area. Livestock mainly transport NNIS propagules on their fur or through ingestion. Many NNIS have barbed or prickly seeds that readily adhere to animal fur and may potentially be transported long-distance and/or fall off in areas that are currently weed-free. Since many NNIS seeds can pass through the stomach unaffected, ingested seeds may also introduce NNIS to new areas once they are expelled. The added cumulative effects of grazing to Alternative 2 would likely increase the risk of NNIS introduction and spread. Projects on private lands are not required to mitigate for the spread and/or introduction of NNIS species which could also increase negative cumulative effects to NNIS populations and subsequently raise the risk rating. The BAER team analyzed the project area and prescribed emergency treatments to help limit the introduction and spread of NNIS from the 2017 Abney Fire and suppression activities. Emergency treatments will take place in the first year following the fires (2018) and will include additional surveys for NNIS within the fire footprints and contingency areas as well as subsequent hand removal of newly located infestations. These treatments will help control the introduction and spread of annual NNIS species, such as Centaurea solstitialis. Unfortunately, biennial and perennial species that have a rosette life stage are difficult to locate in the first year because of their short stature, and may not be found during these surveys. The Forest Noxious Weed Detection and Treatment program would also continue to survey for and treat new populations that may be introduced or spread onto Forest lands through on-going and future foreseeable Forest and Private land projects; however, the cumulative risk for the introduction and spread of NNIS would remain high due to the highly vulnerable condition of the habitat.

Overall Level of Risk for the Project The project area is already moderately susceptible to NNIS infestation regardless of Project activities due to NNIS infestations already present, the vulnerability of the Project area from the Abney Fire, and the moderate recreational, industrial and livestock use of the Project area. In this alternative, the five risk factors combined have a higher potential for NNIS introduction and spread within the Project area when compared to the No Action Alternative, due to the higher level of ground disturbing activities and increased vectors. Project design features and mitigation measures would reduce these effects; however the risk would remain high due to the pre-existing condition. Continuation of the existing Forest weed monitoring and treatment program would

45 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

detect any new high-priority weed sites that may become established within the project area. Quickly treating these sites will limit new NNIS establishment. Additionally, BAER inventories and treatments of NNIS spread from fire activities within the project area would help constrain NNIS introduction and spread.

Mitigation Measures Resource protection measures have been developed to reduce the risk of NNIS introduction and spread in this Project. These include:

• Washing heavy equipment prior to and following off-road activities in the Project area; • Equipment and vehicle exclusion from high priority and large NNIS infestations within the Project area; • Management of infestations occurring on landings to prevent the spread of contaminated soils; • Requiring the use of State certified weed free materials; and • Requiring the inspection of materials for which certification does not exist.

These mitigation measures are accepted weed prevention practices developed by public land management agencies and university cooperative extension offices and promoted by weed management organization across the nation (Sheley et al. 2002, USDA 2013c). The above measures include those required in Forest Service Manual for activities related to timber harvest and roads (FSM 2903).

46 Botany Invasives Resource Report Seiad-Horse Risk Reduction Project

Alternative 3 For a description of this alternative please see the Proposed Action section of the Seiad Horse Risk Reduction Project Environmental Assessment.

Direct and Indirect Effects Direct, indirect, and cumulative effects from this alternative on the risk of spread and introduction of NNIS infestations would be identical to Alternative 2 with the following exceptions: Reduction in the scope and intensity of project activities will directly reduce the risk of introducing or establishing NNIS associated with those activities. The elimination of salvage units and associated landings and temporary roads within one mile of the main ridge (Siskiyou crest) reduces the disturbance footprint of the project when compared to Alternative 2. The majority of the known NNIS populations in the project area are located in the lower elevations. Elimination of the units and temporary roads within one mile of the crest reduces the risk of vectoring NNIS propagules to these higher elevation sites; however, it should be noted that many of the NNIS identified in the project would not survive or thrive at the higher elevation of the crest. Dyer’s woad is known to invade the high elevation habitats of the crest, and some members of the knapweed and thistle groups – such as spotted knapweed - may be able to invade and persist in those habitats as well. While the risk of introduction and/or spread of non-native invasive plant species associated with this alternative would be lower than that of Alternative 2, it still remains high.

Cumulative Effects Cumulative effects for this Alternative would similar to those identified in Alternative 2; however, removal of salvage units within one mile of the crest significantly reduces NNIS cumulative risks associated with those features. Cumulative risk from cattle grazing and public recreation combined with project activities would be lower under this alternative, particularly near the crest where units would be dropped. This would decrease the risk factors related to habitat alteration and project-related vectors. While cumulative risk of introduction, establishment and/or spread of non-native invasive plant species associated with this Alternative would be lower than that of Alternative 2, it still remains High.

Comparison of Alternatives

Table 10: Comparison of Alternatives by risk elements and overall direct/indirect risk of establishing, introducing or spreading NNIS in the project area.

Alternative 1 Alternative 2 Alternative 3 Risk Factor Short Long Short Long Short Long Term Term Term Term Term Term 1. Known Moderate Moderate High Moderate High Moderate Noxious Weeds

47 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Alternative 1 Alternative 2 Alternative 3 Risk Factor Short Long Short Long Short Long Term Term Term Term Term Term 2. Habitat High Moderate High Moderate High Moderate Vulnerability 3. Non-project Moderat dependent Moderate Moderate Moderate Moderate Moderate e Vectors 4. Habitat Alteration Very Moderate Very Moderate NA NA Expected as a High to High High to High result of Project 5. Increased Vectors as a NA NA High Moderate High Moderate result of Project Implementation

Moderate Low High Moderate High Moderate Overall direct/indirect risk

Moderate High High

Compliance with law, regulation, policy, and the Forest Plan Forest Service Manual 2900 and Forest Plan Standards and Guidelines require that all projects be evaluated for the risk of noxious weed introduction and spread as a result of project activities. In addition, projects must be designed to reduce the risk of weed introduction or spread. In the action alternatives, Project Design Features have been incorporated which are expected to reduce the risk of weed introduction or spread. Forest Plan Standards and Guidelines and Manual direction will be met.

48 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Literature Cited Alberta Invasive Species Council (AISC), 2014. Diffuse Knapweed species fact sheet. Web published; abinvasives.com

Bossard, C.C., Randall, J.M., and Hoshovsky, M.C. 1991. Invasive plants of California’s wildlands. University of California Press. Pgs. 145-150.

CDFA 2016 - Encycloweedia Datasheets by California Department of Food and Agriculture. Available at https://www.cdfa.ca.gov/plant/ipc/encycloweedia/weedinfo/isatis.htm (accessed December 2016)

DiTomaso, J.M. and Healy E.A. 2007.Weeds of California and other Western states. Volume 1 and 2. University of California Agriculture and Natural Resources. Pgs. 235-249, -477, 497-499, 511- 515, 752-762, 1592-1595.

Kaye, T.N. and Cramer, J.R. 2005. Conservation Assessment for Cypripedium fasciculatum and Cypripedium montanum. USDA Forest Service, Region 5. Institute for Applied Ecology, Corvallis, Oregon.

Keeley, J.E., Pausas, J.G., Rundel, P.W., Bond, W.J., and Bradstock, R.A. 2011. Fire as an evolutionary pressure shaping plant traits. Trends Plant Sci. 16:406–11. Macior, L.W. Pollination ecology and endemic adaptation of Pedicularis howelii Gray (Scrophulariaceae). Plant Species Biol., 1 (1986), pp. 163-172

Merriam, K.E., McGinnis, T.W., and Keeley, J.E., 2004. The role of fire and fire management in the invasion of nonnative plants. Park Science, 22(2): 32-33.

Scott, T.A. and Pratini, N. 1995. Habitat fragmentation: the sum of the pieces is less than the whole. California Agriculture 49(6):56.

Shefferson, R.P., Weiß, M., Kull, T., and Taylors, D.L. 2005. High specificity generally characterized mycorrhizal association in rare lady’s slipper orchids, genus Cypripedium. Molecular Ecology 14: 613-626.

Shefferson, R.P, Taylor, D.L., Weiß, M., Garnica, S., McCormick, M.K., Adams, S., Gray, H.M., McFarland, J.W., Kull, T., Tali, K., Yukawa, T., Kawahara, T., Miyoshi, K., and Lee, Y-I. 2007. The evolutionary history of mycorrhizal specificity among Lady’s Slipper orchids. Evolution 61(6): 1380-1390.

Sheley, R., Manoukian, M., and Marks, G. 2002. Preventing noxious weed invasion, MONTGUIDE MT 199517 AG 8/2002. Montana State University Extension Service. Bozeman, MT. 3 pp.

Skinner, Carl N., Taylor, Alan H., Agee, James K. 2006. Klamath Mountains bioregion. In: Sugihara, Neil G., Van Wagtendonk, Jan W., Shaffer, Kevin E., Fites-Kaufman, Joann, Thode, Andrea E. (eds.) Fire in California’s ecosystems.170-194.

USDA Forest Service. 1995. Forest Plan 2010 Amendment. . Klamath National Forest.

USDA Forest Service. 2005. Forest Service Manual: Wildlife, Fish and Sensitive Plant Management (Section 2670).

49 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

USDA Forest Service. 2011. Forest Service Manual 2900, Invasive Species Management. USFS. Washington, DC. December, 2011.

USDA Forest Service. 2013. Federally listed and Sensitive Plant Species. Klamath National Forest, July, 2013.

USDA Forest Service. 2013b. Klamath National Forest Noxious Weed and Nonnative Invasive Plant List. March 29, 2013.

USDA Forest Service. 2013c. National Strategic Framework for Invasive Species Management. FS-1017. August 2013.

USDA Forest Service 2014b. Direction Regarding the Survey & Manage Standards and Guidelines: Letter to Forest Supervisors within the Northwest Forest Plan Area. May 13, 2014.

USDA Forest Service 2017a (Appendix A of this document). Botanical Pre-field Review of Proposed Projects and Results of Preliminary Field Review- Appendix A-1, A-2, A-3. Seiad Horse Risk Reduction Project. Klamath National Forest.

USDA Forest Service and USDI Bureau of Land Management. 2001. Record of Decision and Standards and Guidelines for Amendments to the Survey & Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines in Forest Service and Bureau of Land Management Planning Documents within the Range of the Northern Spotted Owl.

USDA Forest Service and USDI Bureau of Land Management. IM-OR-2004-034 – Annual Species Review - 2003. Attachment 2 – Table 1.1 Survey & Manage Species Category Assignment.

US Fish and Wildlife Service. 2018 (USFWS 2018). List of Threatened, Endangered, Proposed or Candidate species which might occur on the Klamath National Forest.

Zouhar, K. 2005. Cytisus scoparius, C. striatus. In: Fire Effects Information System, [Online]. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory (Producer). Available: http://www.fs.fed.us/database/feis/

Zouhar, K. 2009. Isatis tinctoria. In: Fire Effects Information System, [Online]. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory (Producer). Available: http://www.fs.fed.us/database/feis/

50 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Appendix A-1

Pr oj ect Name: Seiad Horse Risk Reduction and Forest Protection Project Date: February 6, 2018 Prepared by: D avi d Bowden Manage All Known Sites and Manage High Priority Sites This Table includes all plant species included in Survey and Manage Category Assignment that are listed as Category B, D, or E. (December 2003 list, but with January 2001 ROD category assignment for the Red Tree Vole)

TAXA GROUP Known site Equivalent- Species Categor y present in E f f or t sur veys Note: Wher e taxon has mor e than one name i ndi cated, f i r st name i s 2003 pr oj ect required* * current accepted name, second one (in parentheses) is name used in NWFP. FUNGI 8/9 Acanthophysium farlowii (Aleurodiscus farlowii) B No N Albatrellus avellaneus B No N5/9

No N5/9 Albatrellus caeruleoporus B 3 Albatrellus ellisii B No N 3 Albatrellus flettii, In Washington and California B No N 8/9 Alpova alexsmithii B No N 3 Alpova olivaceotinctus B No N Arcangeliella camphorata (Arcangeliella sp. nov. #Trappe 12382; No B N8/9 Arcangeliella sp. nov. #Trappe 12359) 3 Arcangeliella crassa B No N 3 Arcangeliella lactarioides B No N 8/9 Asterophora lycoperdoides B No N 8/9 Asterophora parasitica B No N 3 Baeospora myriadophylla B No N 8/9 Balsamia nigrens (Balsamia nigra) B No N 3 Boletus haematinus B No N N3 Boletus pulcherrimus B No No N3 Bondarzewia mesenterica (Bondarzewia montana) B N6 Cantharellus subalbidus, In Washington and California D Y es 5/9 Catathelasma ventricosa B No N 6 NChalciporus piperatus (Boletus piperatus) D No N 5/9 Chamonixia caespitosa (Chamonixia pacifica sp. nov. #Trappe #12768) B No N 3 Choiromyces alveolatus B No N 5/9 Choiromyces venosus B No N 3 Chroogomphus loculatus B No N 5/9 Chrysomphalina grossula B No N 3 Clavariadelphus ligula B No N N3 Clavariadelphus occidentalis (Clavariadelphus pistillaris) B Y es 8/9 Clavariadelphus sachalinensi, Oregon, Washington B No N 3 Clavariadelphus subfastigiatus B No N Clavariadelphus truncatus (syn. Clavariadelphus borealis) D No N6

51 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

TAXA GROUP Known site Equivalent- Species Categor y present in E f f or t sur veys Note: Wher e taxon has mor e than one name i ndi cated, f i r st name i s 2003 pr oj ect required* * current accepted name, second one (in parentheses) is name used in NWFP . 8/9 Clavulina castanopes v. lignicola (Clavulina ornatipes) B No N 3 Clitocybe senilis B No N Clitocybe subditopoda B No N3 6 Collybia bakerensis F No N 5/9 Cordyceps ophioglossoides B No N 8/9 Cortinarius barlowensis (syn. Cortinarius azureus) B No N 8/9 Cortinarius boulderensis B No N 3 Cortinarius cyanites B No N 8/9 Cortinarius depauperatus (Cortinarius spilomeus) B No N 3 Cortinarius magnivelatus B No N 3 Cortinarius olympianus B No N 8/9 Cortinarius speciosissimus (Cortinarius rainierensis) B No N 8/9 Cortinarius tabularis B No N 8/9 Cortinarius umidicola (Cortinarius canabarba) B No N 5/9 Cortinarius valgus B No N 8/9 Cortinarius variipes B No N 3 Cortinarius verrucisporus B No N 8 Cortinarius wiebeae B No N 3 Cudonia monticola B No N 8/9 Cyphellostereum laeve B No N 3 Dendrocollybia racemosa (Collybia racemosa) B No N 5,9 Dermocybe humboldtensis B No N 8/9 Destuntzi a fusca B No N 5/9 Destuntzia rubra B No N 8/9 Dichostereum boreale (Dichostereum granulosum) B No N 8/9 Elaphomyces anthracinus B No N 8/9 Elaphomyces subviscidus B No N 8/9 Endogone acrogena B No N 8/9 Endogone oregonensis B No N 5/9 Entoloma nitidum (Rhodocybe nitida) B No N 3 Fayodia bisphaerigera (Fayodia gracilipes) B No N 8/9 Fevansia aurantiaca (Alpova sp. nov. # Trappe 1966) (Alpova aurantiaca) B No N 5/9 Galerina cerina B No N No N6 Galerina heterocystis E No N6 Galerina sphagnicola E 8/9 Gastroboletus imbellus B No N 8/9 Gastroboletus ruber B No N 3 Gastroboletus subalpinus B No N 3 Gastroboletus turbinatus B No N Gastroboletus vividus (Gastroboletus sp. nov. #Trappe 2897; Gastroboletus N3 B No sp. nov. #Trappe 7515) 6 Gastrosuillus amaranthii (Gastrosuillus sp. nov. #Trappe 9608) E No N Gastrosuillus umbrinus (Gastroboletus sp. nov. #Trappe 7516) B No N3

52 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

TAXA GROUP Known site Equivalent- Species Categor y present in E f f or t sur veys Note: Wher e taxon has mor e than one name i ndi cated, f i r st name i s 2003 pr oj ect required* * current accepted name, second one (in parentheses) is name used in NWFP . 3 Gautieria magnicellaris B No N 3 Gautieria otthii B No N 3 Gelatinodiscus flavidus B No N 5/9 Glomus radiatum B No N 3 Gomphus bonarii B No N 6 Gomphus clavatus F No N 6 Gomphus kauffmanii E No N Gymnomyces abi eti s (Gymnomyces sp. nov. #Trappe 1690, 1706, 1710; N3 Gymnomyces sp. nov. #Trappe 4703, 5576; Gymnomyces sp. nov. #Trappe No B 5052; Gymnomyces sp. nov. #Trappe 7545; Martellia sp. nov. #Tr appe 1700; Martellia sp. nov. #Trappe 311; Martellia sp. nov. #Trappe 5903) 8/9 Gymnomyces nondistincta (Martellia sp. nov. #Trappe 649) B No N 3 Gymnopilus punctifolius, In California B No N 3 Gyromitra californica B No N 8/9 Hebeloma olympianum (Hebeloma olympiana) B No N 8/9 Helvella crassitunicata B No N 8/9 Helvella elastica B No N 3 Hydnotrya inordinata (Hydnotrya sp. nov. #Trappe 787, 792) B No N 8/9 Hydnotrya subnix (Hydnotrya subnix sp. nov. #Trappe 1861) B No N 5/9 Hydropus marginellus (Mycena marginella) B No N 3 Hygrophorus caeruleus B No N 8/9 Hygrophorus karstenii B No N 5/9 Hygrophorus vernalis B No N 5/9 Hypomyces luteovirens B No N 3 Leucogaster citrinus B No N 3 Leucogaster microsporus B No N 5,9 Macowanites chlorinosmus B No N 8/9 Macowanites lymanensis B No N 8/9 Macowanites mollis B No N 3 Marasmius applanatipes B No N 3 Martellia fragrans B No N 8/9 Martellia idahoensis B No N 3 Mycena hudsoniana B No N 6 Mycena overholtsii D No N 3 Mycena quinaultensis B No N 3 Mycena tenax B No N 3 Mythicomyces corneipes B No N 8/9 Neolentinus adhaerens B No N 5/9 Neolentinus kauffmanii B No N 3 Nivatogastrium nubigenum B No N 8/9 Octavianina cyanescens (Octavianina sp. nov. #Trappe 7502) B No N 8/9 Octavianina macrospora B No N Octavianina papyracea B No N5,9

53 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

TAXA GROUP Known site Equivalent- Species Categor y present in E f f or t sur veys Note: Wher e taxon has mor e than one name i ndi cated, f i r st name i s 2003 pr oj ect required* * current accepted name, second one (in parentheses) is name used in NWFP . 6 Otidea leporina D No N 5/9 Otidea smithii B No N 6 Phaeocollybia attenuata D No N 3 Phaeocollybia californica B Y es N 8/9 Phaeocollybia dissiliens B No N 6 Phaeocollybia fallax D Y es N 3 Phaeocollybia gregaria B No N 6 Phaeocollybia kauffmanii D Y es N 6 Phaeocollybia olivacea, In Oregon F No N 6 Phaeocollybia olivacea, In Washington and California E Y es N 8/9 Phaeocollybia oregonensis (syn. Phaeocollybia carmanahensis) B No N 3 Phaeocollybia piceae B Y es N 3 Phaeocollybia pseudofestiva B No N 3 Phaeocollybia scatesiae B No N 3 Phaeocollybia sipei B No N 3 Phaeocollybia spadicea B No N 3 Phellodon atratus (Phellodon atratum) B No N 5,9 Pholiota albivelata B No N 5/9 Podostroma alutaceum B No N 8/9 Polyozellus multiplex B No N 8/9 Pseudaleuria quinaultiana B No N 3 Ramaria abietina B No N 3 Ramaria amyloidea B No N 3 Ramaria araiospora B No N 3 Ramaria aurantiisiccescens B No N 3 Ramaria botryis var . aurantiiramosa B No N 3 Ramar i a cel er i vi r escens B No N 3 Ramaria claviramulata B No N 5/9 Ramaria concolor f. marrii B No N 8/9 Ramaria concolor f. tsugina B No N Ramaria conjunctipes var . sparsiramosa (Ramaria fasciculata var . No N3 B sparsiramosa) 3 Ramaria coulterae B No N 3 Ramaria cyaneigranosa B No N 3 Ramaria gelatiniaurantia B No N 3 Ramaria gracilis B No N 8 Ramaria hilaris var . olympiana B No N 3 Ramaria largentii B No N 8/9 Ramaria lorithamnus B No N 3 Ramaria maculatipes B No N 5/9 Ramaria rainierensis B No N 5/9 Ramaria rubella var . blanda B No N Ramaria rubribrunnescens B No N5/9

54 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

TAXA GROUP Known site Equivalent- Species Categor y present in E f f or t sur veys Note: Wher e taxon has mor e than one name i ndi cated, f i r st name i s 2003 pr oj ect required* * current accepted name, second one (in parentheses) is name used in NWFP . 3 Ramaria rubrievanescens B Y es N 3 Ramaria rubripermanens, In Washington and California B Y es N 6 Ramaria rubripermanens, In Oregon D No N 3 Ramaria spinulosa var . diminutiva (Ramaria spinulosa) B No N 3 Ramaria stuntzii B No N 8/9 Ramaria suecica B No N 3 Ramaria thiersii B No N 5/9 Ramaria verlotensis B No N 8/9 Rhizopogon abietis B No N 8/9 Rhizopogon atroviolaceus B No N 3 Rhizopogon brunneiniger B No N 8/9 Rhizopogon chamaleontinus (Rhizopogon sp. nov. #Trappe 9432) B No N 8/9 Rhizopogon ellipsosporus (Alpova sp. nov. # Trappe 9730) B No N 3 Rhizopogon evadens var . subalpinus B No N 8/9 Rhizopogon exiguus B No N 3 Rhizopogon flavofibrillosus B No N 8/9 Rhizopogon inquinatus B No N 6 Rhizopogon truncatus D No N 3 Rhodocybe speciosa B No N 5/9 Rickenella swartzii (Rickenella setipes) B No N 3 Russula mustelina B No N 3 Sarcodon fuscoindicus B No N 3 Sedecula pulvinata B No N 3 Sowerbyella rhenana (Aleuria rhenana) B No N 6 Spar assi s cr i spa D No N 3 Spathularia flavida B No N 3 Stagnicola perplexa B No N Thaxterogaster pavelekii (Thaxterogaster sp. nov. #Trappe 4867, 6242, No B N8/9 7427, 7962, 8520) 6 Tr emi scus hel vel l oi des D No N 3 Tricholoma venenatum B No N 3 Tricholomopsis fulvescens B No N 3 Tuber asa (Tuber sp. nov. #Trappe 2302) B No N 8/9 Tuber pacificum (Tuber sp. nov. #Trappe 12493) B No N 6 Tylopilus porphyrosporus (Tylopilus pseudoscaber) D No N LICHENS 2 Bryoria subcana (syn. Alectoria subcana) B No N 6 Buellia oidalea E No N 1 Calicium abietinum B No N 6 Calicium adspersum E No N 6 Cetr el i a cetr ar i oi des E *** N 1 Chaenotheca chrysocephala B No N Chaenotheca ferruginea B No N1

55 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

TAXA GROUP Known site Equivalent- Species Categor y present in E f f or t sur veys Note: Wher e taxon has mor e than one name i ndi cated, f i r st name i s 2003 pr oj ect required* * current accepted name, second one (in parentheses) is name used in NWFP . 6 Chaenotheca subroscida E No N Chaenothecopsis pusilla (syn. Chaenothecopsis subpusilla, Calcium E No N6 asikkalense, Calcium floerkei, Calcium pusillum, Calcium subpusillum) Col l ema ni gr escens In WA and OR, except in Oregon Klamath F *** N6 Physiographic Province 6 Dendriscocaulon intricatulum, In CA E No N 6 Dermatocarpon luridum E No N 6 Fuscopannaria saubinetii (Pannaria saubinetii) E *** N 6 Heterodermia sitchensis E No N 6 Hypogymnia vittata (Hypogymnia vittiata) E No N 6 Hypotrachyna revoluta (syn. Parmelia revoluta) E No N 6 Leptogium burnetiaw var. hirsutum E No N 6 Leptogium rivale E No N 6 Leptogium teretiusculum E No N 1 Microcalicium arenarium B No N Nephroma bellum, I n OR: K l amath, Wi l l amette V al l ey, Easter n Cascades; No WA ; Wester n Cascaades (outsi de GPNF), Easter n Cascades, Ol ympi c E N6 Peninsula Physiogrpahic Provinces 6 Nephroma isidiosum E No N 6 Pannaria rubiginosa E No N 6 Peltigera pacifica E No N 6 Platismatia lacunose, al l except OR CR E No N 6 Stenocybe clavata E No N 2 Tholurna dissimilis, south of Columbia River B No N 2 Usnea hesperina E No N 6 Usnea longissima, In OR except Curry, Josephine, & Jackson Counties F No N

BRYOPHYTES 6 Brotherella roellii E No N 6 Buxbaumia viridis, In CA E No N 1 Diplophyllum plicatum B No N 6 Herbertus aduncus E No N 1 Iwatsukiella leucotricha B No N 2 Kurzia makinoana B No N 2 Marsupella emarginata v. aquatica B No N 2 Orthodontium gracile B No N 2 Racomitrium aquaticum E No N 1 Rhizomnium nudum, In OR B No N 2 Tr i tomar i a exsecti for mi s B No N 1 Tritomaria quinquedentata B No N

VASCULAR PLANTS Arceuthobium tsugense mertensianae, In Washington only F *** N6 Notes:

56 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

* Adapted from 2003 ROD with the addition of newer taxonomic names. This list contains those species that are not listed as Category A&C, which require pre-disturbance surveys. This list is known as the “manage known sites” table. **Strategic surveys are considered complete in California for all S&M fungi (USDA 2014). *** Category F species require only strategic surveys, and are included in this list only for reference. 1 Strategic survey requirements have been met (USDA/USDI 2006). 2 Species is not known or suspected to occur on Klamath National Forest (USDA 2008). 3 Ground disturbing activities will not occur in stands defined as old-growth (USDA/USDI 2001, Standards and Guidelines p.79). 4 Proposed project falls within four project types exempt from 2001 ROD requirements (USDA 2006). 5 There is no habitat for these species on KNF lands. They are found in hypercoastal areas in redwood, Sitka spruce, western hemlock, or other forest types not present on the Klamath N.F. (USDA 2002, 2010, Attachment C, 2014, Christy and Wagner 1996, Sharnoff 2014). 6 Equivalent Effort surveys apply only to Category B species.

8 Species not documented in CA. (USDA 2002, 2010, 2011a, 2011b, Christy and Wagner 1996, Sharnoff 2014) 9 Strategic survey requirements have been met in CA. (USDA 2011a, 2011b, 2014). Description of Categories: A: Manage All Known Sites; Pre-disturbance surveys required; Strategic Surveys. B: Manage All Known Sites; Strategic Surveys. C: Manage High Priority Sites; Pre-disturbance surveys required; Strategic Surveys. D: Manage High Priority Sites; Strategic Surveys. E: Manage All Known Sites; Strategic Surveys. F: Strategic Surveys.

References:

Christy, John A., and Wagner, David H. 1996. Guide for the identification of rare, threatened or sensitive bryophytes in the range of the Northern Spotted Owl, Western Washington, Western Oregon, and Northwestern California. Eugene District, USDI Bureau of Land Management; Siuslaw National Forest, USDA Forest Service; The Nature Conservancy; and the Northwest Botanical Institute. Magney, David. 1996. Preliminary List of Rare California Lichens. Unpublished document on file, Supervisor’s Office, Klamath National Forest, Yreka, CA. Sharnoff, Stephen. 2014. A field guide to California Lichens. Yale University Press, New Haven, CT and London. USDA Forest Service. 2002. Lichen Survey Summary for Survey and Manage Species. David Magney and others. Unpublished document on file, Supervisor’s Office, Klamath National Forest, Yreka, CA. USDA Forest Service 2006. Stipulation and (Proposed) Order RE: Injunction. Hon. Marsha J. Pechman, U.S. District Court Western District of Washington at Seattle, October 11, 2006. Case 2:04-cv-00844-MJP. Unpublished document on file, Supervisor’s Office, Klamath National Forest, Yreka, CA. USDA Forest Service 2008. Category B species Known or Suspected to occur on KNF. Karen West, January 29, 2008. Unpublished document on file, Supervisor’s Office, Klamath National Forest, Yreka, CA. USDA Forest Service 2010. Summary of findings pertaining to the Status of Strategic Surveys for Fungi in the Northern Province: Briefing for the Province Resources Board, and Attachment A-C. Lisa Hoover & Julie Nelson, June 25, 2010. Unpublished documents on file, Supervisor’s Office, Klamath National Forest, Yreka, CA. USDA Forest Service 2011a. Survey and manage Category B Fungi Species: Completion of Strategic Surveys. Lisa Hoover, February 7, 2011. Unpublished documents on file, Supervisor’s Office, Klamath National Forest, Yreka, CA.

57 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

USDA Forest Service 2011b. Status of Strategic Surveys for Fungi in the Northern Province: Briefing for the Province Resources Board. Lisa Hoover, February 7, 2011. Unpublished documents on file, Supervisor’s Office, Klamath National Forest, Yreka, CA. USDA Forest Service. 2014. Draft Species Decision for 2014 Strategic Surveys. Erin Rentz. Unpublished documents on file, Supervisor’s Office, Klamath National Forest, Yreka, CA. USDA Forest Service and USDI Bureau of Land Management. January 2001. Record of Decision for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines in Forest Service and Bureau of Land Management Planning Documents Within the Range of the Northern Spotted Owl. http://www.reo.gov/library/reports/RODjan01.pdf USDA Forest Service and USDI Bureau of Land Management. 2003. Implementation of 2003 Survey and Manage Annual Species Review. FS-Memorandum. BLM – Instruction Memorandum No. OR-2004-034. December 19, 2003. USDA Forest Service and USDI Bureau of Land Management 2006. Category B Species where Strategic Surveys are Considered Complete. FS-Memorandum. BLM – Instruction Memorandum No. OR-2006. March 24, 2006. http://www.blm.gov/or/plans/surveyandmanage/files/02- categoryb_lichens_bryophytes.pdf

58 Botany Invasives Resource Report Seiad-Horse Risk Reduction Project

Appendix A-2

Project: Seiad Horse Risk Reduction Project Name: David Bowden Date February 6, 2018 This form serves to track special management plants listed by the Klamath National Forest through the pre-field analysis process. Species considered in this document are those in category assignment A or C included in the2003 Survey and Manage ROD (USDA/USDI 2003), and those species listed as Threatened, Endangered, Proposed, or Sensitive on the Klamath (USDA 2013).

Completion of this form certifies that pre-field evaluation procedures are in compliance with species survey protocols.

Survey and Manage: survey protocol will be triggered if column 1 is "yes" and if any of columns 2,3,4, or 5 (both parts) is "yes". Sensitive Plants: Regional botanical survey protocol is triggered if column 1 is "yes" and if either column 2 or 5 (both parts) is "yes".

Vascular Plants: (1) (5) If the species is Project within known assumed to be or suspected range and present, do the types there is probability of of actions proposed (2) (4) suitable habitat w/in R5 Sensitive, Survey in this project have Known (3) Known project area Species Federal & State and the potential to site exists Known site site exists Survey Scientific name Rare, Manage directly or indirectly in exists in in protocol Common name Threatened, Category impact this species proposed 5th field adjacent triggered**

Endangered 2003 or alter its habitat project watershed 5th field Known or Suitable conditions (TES) or area watershed Suspected Habitat significantly Range negatively affect species/habitat (S&M)? Arabis macdonaldiana State, Federal Yes Yes N N N Yes Yes McDonald's rock Endangered cress Astragalus applegatei Federal Yes N N N N N N Applegate’s milk- Endangered vetch Bensoniella R5 Sensitive (not A No N N oregana on KNF list) N N N N (in CA) bensoniella CA Rare

59 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

(1) (5) If the species is Project within known assumed to be or suspected range and present, do the types there is probability of of actions proposed (2) (4) suitable habitat w/in R5 Sensitive, Survey in this project have Known (3) Known project area Species Federal & State and the potential to site exists Known site site exists Survey Scientific name Rare, Manage directly or indirectly in exists in in protocol Common name Threatened, Category impact this species proposed 5th field adjacent triggered**

Endangered 2003 or alter its habitat project watershed 5th field Known or Suitable conditions (TES) or area watershed Suspected Habitat significantly Range negatively affect species/habitat (S&M)? Botrychium crenulatum N N N Sensitive N N Yes Yes scalloped moonwort Botrychium lunaria N N N Sensitive N N Yes Yes common mooonwort Botrychium A minganense N N N Sensitive (in OR & N N Yes Yes Mingan CA) moonwort Botrychium montanum N N Sensitive A N N N Yes Yes mountain grape- fern Botrychium pinnatum N N N Sensitive N N Yes Yes northwest moonwort Botrychium pumicola N N N Sensitive N N N N Crater Lake grape-fern Calochortus greenei Yes N N Sensitive N N N N Green's mariposa- lily 60 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

(1) (5) If the species is Project within known assumed to be or suspected range and present, do the types there is probability of of actions proposed (2) (4) suitable habitat w/in R5 Sensitive, Survey in this project have Known (3) Known project area Species Federal & State and the potential to site exists Known site site exists Survey Scientific name Rare, Manage directly or indirectly in exists in in protocol Common name Threatened, Category impact this species proposed 5th field adjacent triggered**

Endangered 2003 or alter its habitat project watershed 5th field Known or Suitable conditions (TES) or area watershed Suspected Habitat significantly Range negatively affect species/habitat (S&M)? Calochortus Sensitive, persistens Yes N N CA Rare, N N N N Siskiyou Federal Candidate mariposa-lily Campanula Yes N N wilkinsiana Sensitive N N Yes No Wilkin's harebell Chaenactis Yes N N suffrutescens Sensitive N N N Yes Shasta chaenactis Chamaesyce Federally N N N hooveri Hoover’s N N N N Threatened spurge Coptis asplenifolia n/a N N A N N N N spleenwort- leaved goldthread Coptis trifolia n/a N N threeleaflet A N N N N goldthread Corydalis aquae- gelidae N N N A N N Yes N cold-water corydalis

61 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

(1) (5) If the species is Project within known assumed to be or suspected range and present, do the types there is probability of of actions proposed (2) (4) suitable habitat w/in R5 Sensitive, Survey in this project have Known (3) Known project area Species Federal & State and the potential to site exists Known site site exists Survey Scientific name Rare, Manage directly or indirectly in exists in in protocol Common name Threatened, Category impact this species proposed 5th field adjacent triggered**

Endangered 2003 or alter its habitat project watershed 5th field Known or Suitable conditions (TES) or area watershed Suspected Habitat significantly Range negatively affect species/habitat (S&M)? Cypripedium fasciculatum Yes Sensitive C Yes Yes Yes Yes Yes Yes clustered lady's slipper Cypripedium montanum Yes Sensitive C Yes Yes Yes Yes Yes Yes montain lady slipper Draba carnosula Sensitive Yes N Yes N Yes Yes Yes Mt. Shasta draba Epilobium N N N oreganum Sensitive N N Yes N Oregon fireweed Eriogonum alpinum N N N Sensitive N N N N Trinity buckwheat Eriogonum hirtellum Yes N Yes Sensitive Yes Yes Yes Yes Klamath Mtn. buckwheat Eriogonum ursinum var. N Yes erubescens Sensitive Yes Yes Yes Yes Yes blushing wild buckwheat

62 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

(1) (5) If the species is Project within known assumed to be or suspected range and present, do the types there is probability of of actions proposed (2) (4) suitable habitat w/in R5 Sensitive, Survey in this project have Known (3) Known project area Species Federal & State and the potential to site exists Known site site exists Survey Scientific name Rare, Manage directly or indirectly in exists in in protocol Common name Threatened, Category impact this species proposed 5th field adjacent triggered**

Endangered 2003 or alter its habitat project watershed 5th field Known or Suitable conditions (TES) or area watershed Suspected Habitat significantly Range negatively affect species/habitat (S&M)? Erythronium hendersonii Yes N Sensitive Yes N Yes Yes Yes Henderson’s fawn lily Eucephalus vialis Yes N (Aster) Sensitive A N N Yes Yes Yes wayside aster Frasera umpquaensis Yes N Sensitive N N N N N clustered green- gentian Fritillaria State, gentneri Yes N Federal N N N N N Gentner mission- Endangered bells Galium C n/a N Kamtschaticum N N N N N WA and OR Boreal bedstraw Horkelia hendersonii Yes N Sensitive Yes Yes Yes Yes Yes Henderson's horkelia Ivesia pickeringii Yes N Sensitive N N N N N Pickering's ivesia

63 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

(1) (5) If the species is Project within known assumed to be or suspected range and present, do the types there is probability of of actions proposed (2) (4) suitable habitat w/in R5 Sensitive, Survey in this project have Known (3) Known project area Species Federal & State and the potential to site exists Known site site exists Survey Scientific name Rare, Manage directly or indirectly in exists in in protocol Common name Threatened, Category impact this species proposed 5th field adjacent triggered**

Endangered 2003 or alter its habitat project watershed 5th field Known or Suitable conditions (TES) or area watershed Suspected Habitat significantly Range negatively affect species/habitat (S&M)? Lupinus aridus var. ashlandensis Yes N Yes Sensitive N N Yes Yes Mt. Ashland lupine Mimulus evanescens Yes N Sensitive N N N N N ephemeral monkey flower Minuartia stolonifera Yes N Sensitive N N N N N Scott Mtn. sandwort Orcuttia tenuis Federal Yes N slender Orcutt N N N N N Threatened grass Parnassia cirrata var. intermedia Yes N N Sensitive N N N N fringed grass-of- parnassus Pedicularis howellii Yes Yes Yes Sensitive Yes Yes Yes Yes Howell's lousewort Phacelia cookei Yes N N Sensitive N N N N Cooke's phacelia

64 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

(1) (5) If the species is Project within known assumed to be or suspected range and present, do the types there is probability of of actions proposed (2) (4) suitable habitat w/in R5 Sensitive, Survey in this project have Known (3) Known project area Species Federal & State and the potential to site exists Known site site exists Survey Scientific name Rare, Manage directly or indirectly in exists in in protocol Common name Threatened, Category impact this species proposed 5th field adjacent triggered**

Endangered 2003 or alter its habitat project watershed 5th field Known or Suitable conditions (TES) or area watershed Suspected Habitat significantly Range negatively affect species/habitat (S&M)? Phacelia greenei Yes N N Scott Valley Sensitive N Yes N N phacelia Phacelia N N N inundata Sensitive N N N N playa phacelia State, Phlox hirsuta Yes N N Federal N N N N Yreka phlox Endangered Pinus albicaulis Sensitive, Federal Yes N Yes N Yes Yes No Whitebark pine Candidate Platanthera orbiculata var. orbiculata Yes N N C N N N N (Habenaria) large round- leaved orchid Polemonium N N N chartaceum Sensitive N N N N Mason’s sky pilot Polemonium N N N pulcherrimum Sensitive N N N N var. shastense Raillardella N N N pringlei Sensitive N N N N showy raillardella

65 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

(1) (5) If the species is Project within known assumed to be or suspected range and present, do the types there is probability of of actions proposed (2) (4) suitable habitat w/in R5 Sensitive, Survey in this project have Known (3) Known project area Species Federal & State and the potential to site exists Known site site exists Survey Scientific name Rare, Manage directly or indirectly in exists in in protocol Common name Threatened, Category impact this species proposed 5th field adjacent triggered**

Endangered 2003 or alter its habitat project watershed 5th field Known or Suitable conditions (TES) or area watershed Suspected Habitat significantly Range negatively affect species/habitat (S&M)? Rorippa columbiae Yes N N Sensitive N N N N Columbia yellow cress Tauschia howellii Yes N Yes Sensitive N Yes Yes Yes Howell's tauschia Thermopsis robusta Yes N Yes Sensitive N Yes Yes Yes robust false lupine

66 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project Bryophytes

(1) (5) If the species is Project w/in known or assumed to be present, suspected range and there do the types of actions (4) is probability of suitable Species proposed in this project (2) habitat w/in project area R5 Sensitive, Survey and (3) Known site have the potential to Known site Survey Scientific name Federal & State Manage Known site exists in directly or indirectly exists in protocol Common name Rare, Threatened, Category exists in 5th adjacent 5th impact this species or proposed triggered** Endangered 2003 field watershed field Known or alter its habitat project area Suitable watershed Suspected conditions (TES) or Habitat significantly negatively Range affect species/habitat (S&M)? E (pre- Buxbaumia viridis disturbance Sensitive Yes N N N Yes Yes Yes green bug moss surveys not required) Fissidens aphelotaxifolius Sensitive Yes N N N Yes Yes Yes brook pocket moss Helodium blandowii Sensitive N N N N N N N Blandow’s bog moss Meesia uliginosa broad-nerved Sensitive N N N N N N N hump-moss Mielichhoferia elongata Sensitive Yes N N N Yes Yes Yes elongate copper moss Ptilidium A (in CA californicum Yes N Yes Yes Yes Yes Yes only) Pacific fuzzwort

67 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

(1) (5) If the species is Project w/in known or assumed to be present, suspected range and there do the types of actions (4) is probability of suitable Species proposed in this project (2) habitat w/in project area R5 Sensitive, Survey and (3) Known site have the potential to Known site Survey Scientific name Federal & State Manage Known site exists in directly or indirectly exists in protocol Common name Rare, Threatened, Category exists in 5th adjacent 5th impact this species or proposed triggered** Endangered 2003 field watershed field Known or alter its habitat project area Suitable watershed Suspected conditions (TES) or Habitat significantly negatively Range affect species/habitat (S&M)? Schistostega pennata A Yes N N N Yes Yes Yes cat's eyes moss Tetraphis geniculata A No N N N N N N bent-kneed four- tooth moss

Fungi

(1) (5) If the species is Project w/in known or assumed to be present, suspected range and there do the types of actions (4) is probability of suitable Species R5 Sensitive, proposed in this project (2) habitat w/in project area Survey and Known site Federal & State have the potential to Known site (3) Survey Scientific name Manage exists in Rare, directly or indirectly exists in protocol Common name Category Known site adjacent 5th Threatened, impact this species or proposed exists in 5th triggered** 2003 field Known or Endangered alter its habitat project area field watershed Suitable watershed Suspected conditions (TES) or Habitat significantly negatively Range affect species/habitat (S&M)? Boletus pulcherrimus Sensitive B N N N N Yes N N

68 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

(1) (5) If the species is Project w/in known or assumed to be present, suspected range and there do the types of actions (4) is probability of suitable Species R5 Sensitive, proposed in this project (2) habitat w/in project area Survey and Known site Federal & State have the potential to Known site (3) Survey Scientific name Manage exists in Rare, directly or indirectly exists in protocol Common name Category Known site adjacent 5th Threatened, impact this species or proposed exists in 5th triggered** 2003 field Known or Endangered alter its habitat project area field watershed Suitable watershed Suspected conditions (TES) or Habitat significantly negatively Range affect species/habitat (S&M)? Bridgeoporus R5 Sensitive nobilissimus A N N N N N N N (not KNF listed) noble polypore Cudonia monticola Sensitive B Yes N N N Yes Yes Yes Dendrocollybia racemosa (Collybia Sensitive B Yes N N N Yes Yes Yes racemosa)

Phaeocollybia E (in CA) Sensitive Yes Yes Yes Yes Yes Yes Yes olivacea F (in OR)

Tricholomopsis Sensitive B N N N N N N N fulvescens

69 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project Lichens

(1) (5) If the species is Project within known assumed to be or suspected range and present, do the types there is probability of (4) of actions proposed (2) suitable habitat w/in Survey Known R5 Sensitive, in this project have Known (3) project area Species and site exists Federal & the potential to site exists Known site Survey Scientific name Manage in State Rare, directly or indirectly in exists in 5th protocol Common name Categor adjacent Threatened, impact this species or proposed field triggered** y 5th field Endangered alter its habitat project watershed Known or 2003 watershe Suitable conditions (TES) or area Suspected d Habitat significantly Range negatively affect species/habitat (S&M)? Bryoria N pseudocapillaris A Y N N N N N Horse hiar lichen Bryoria spiralifera Y N N A N N N N Spiral horse hair lichen Dendriscocaulon Yes N Yes A N N Yes Yes intricatulum Hypogymnia duplicata Yes N N C N N N N duplicate pore lichen Leptogium Y N N A N N N N cyanescens Lobaria linita var. A n/a N N tenuoir (in WA, N N N N lung lichen OR) Lobaria oregana A Y N N Oregon lung N N N N (in CA) lichen Nephroma Y N N C N N Y N occultum Niebla cephalota N N N A N N N N niebla lichen 70 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

(1) (5) If the species is Project within known assumed to be or suspected range and present, do the types there is probability of (4) of actions proposed (2) suitable habitat w/in Survey Known R5 Sensitive, in this project have Known (3) project area Species and site exists Federal & the potential to site exists Known site Survey Scientific name Manage in State Rare, directly or indirectly in exists in 5th protocol Common name Categor adjacent Threatened, impact this species or proposed field triggered** y 5th field Endangered alter its habitat project watershed Known or 2003 watershe Suitable conditions (TES) or area Suspected d Habitat significantly Range negatively affect species/habitat (S&M)? Peltigera gowardii N N Sensitive N N Yes Yes N veined water lichen Pseudocyphellaria Y N N A N N N N perpetua Pseudocyphellaria Y N N A N N N N rainierensis Teloschistes Y N N flavicans A N N N N teloschistes lichen Sensitive (but Usnea longissima Yes N N not on KNF A N N Y N beard lichen list) ** Determination of need for a survey for Sensitive and Survey and Manage species is made by the line officer, incorporating recommendations made by the botanist, and considers the probability of the species being present on the project site, and the probability that the project would cause a significant negative effect on the species habitat or the persistence of the species at the site. References: USDA Forest Service and USDI Bureau of Land Management. 1997. Survey Protocols for Survey and Manage Component 2 Bryophytes. Version 2.0. December 11, 1997. http://www.blm.gov/or/plans/surveyandmanage/SP/Bryophytes/memo.html USDA Forest Service and USDI Bureau of Land Management. 1998. Survey Protocols for Component 2 Lichens. Version 2.0. March 12, 1998. http://www.blm.gov/or/plans/surveyandmanage/SP/Lichens/intro.html USDA Forest Service and USDI Bureau of Land Management. 1998. Survey Protocols for Bridgeoporus nobilissimus Fungi. Version 2.0. Hibler & O'Dell, September 17, 1998. http://www.blm.gov/or/plans/surveyandmanage/SP/Fungi/m98103.htm

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USDA Forest Service and USDI Bureau of Land Management. 1998. Survey Protocols for Survey & Mangage Strategy 2 Vascular Plants. Version 2.0. Whiteaker et al. (January 20, 1999 transmittal). http://www.blm.gov/or/plans/surveyandmanage/SP/VascularPlants/imor99-26.htm USDA Forest Service and USDI Bureau of Land Management. 1999. Survey Protocols for Protection Buffer Bryophytes. Version 2.0. December 3, 1999. http://www.blm.gov/or/plans/surveyandmanage/SP/Bryophytes/PBBryophytes/m2000-017.htm. USDA Forest Service and USDI Bureau of Land Management. 1999. Survey Protocols for Seven Survey and Manage and Protection Buffer Fungi. Version 1.3. December 9, 1999. http://www.blm.gov/or/plans/surveyandmanage/SP/Fungi/PBFungi/m2000-018.htm USDA Forest Service and USDI Bureau of Land Management. 2002. Survey Protocols for Category A&C Lichens. Version 2.0 September 2002. (October 18, 2002 transmittal date). http://www.blm.gov/or/plans/surveyandmanage/SP/Lichens/20021018/IM_OR_2003_004.htm USDA Forest Service and USDI Bureau of Land Management. 2003. Survey Protocols for Category A & C Lichens. Version 2.1. June 9, 2003. http://www.blm.gov/or/plans/surveyandmanage/SP/Lichens/20030609/IM-OR-2003-078.htm USDA Forest Service and USDI Bureau of Land Management. 2003b. 2003 Amendment to the Survey Protocol for Category A & C Lichens. Version 2.1 Amendment. September, 2003. http://www.blm.gov/or/plans/surveyandmanage/SP/Lichens/20030922/IM-OR-2003-078_Change- 1_Lichens_Survey_Protocol_%20V2.1Addendum.pdf USDA Forest Service. 2005. Forest Service Manual: Wildlife, Fish, and Sensitive Plant Management (section 2670). O:\NFS\Klamath\Program\2600SensitivePlantsMgmt\SO\2620PlantsPlng\PlanningDirection\Draft_Manual\Dec 2009 Draft USDA Forest Service 2013a. Interim Direction for Survey and Manage. Pacific Southwest Region, Regional Office. June 19, 2013. USDA Forest Service 2013b. 2670: Sensitive Plant Species. Klamath National Forest. July 2013. O:\NFS\Klamath\Program\2600SensitivePlantsMgmt\SO\2670PlantsTES\Lists\CurrentOfficialKNFlists USDA Forest Service and USDI Bureau of Land Management. January 2001. Record of Decision for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines in Forest Service and Bureau of Land Management Planning Documents Within the Range of the Northern Spotted Owl. Standards and Guidelines, Table 1-1, pp. 41-51. http://www.reo.gov/library/reports/RODjan01.pdf USDA Forest Service and USDI Bureau of Land Management. 2003. Implementation of 2003 Survey and Manage Annual Species Review. FS-Memorandum. BLM – Instruction Memorandum No. OR-2004-034. December 19, 2003. USDA Forest Service and USDI Bureau of Land Management 2008. Survey Protocol for Bridgeoporus nobilissimus. Version 3.0. Hibler & O'Dell, June 2008. http://www.blm.gov/or/plans/surveyandmanage/SP-Forms/inv-sp-fu-brno-ver3-2008-06.pdf

72 Botany Invasives Resource Report Seiad-Horse Risk Reduction Project

Appendix A-3 Botanical Pre-field Review of Proposed Projects

And Results of Preliminary Field Review

PROJECT: Seiad Horse Risk RANGER DISTRICT: Happy Camp/Oak Reduction and Knoll Forest Protection Project USGS QUAD(S): Dutch Creek, COMPARTMENTS(S): Horse Creek LOCATION: The Project is located within the Seiad Creek-Klamath River and Horse Creek-Klamath River 5th field watersheds. The Project is about five miles North to Northeast of Seiad Valley, California, in Siskiyou County: Township 47 North, Range 11 West, Sections 8-28, 33, and 35, Mount Diablo Meridian. Elevation ranges from 2,000 to 6,000 feet.

EVALUATED BY: David Bowden TITLE: District Botanist DATE: 2/6/2018 RESOURCES CONSULTED: GIS and NRIS layers/Atlas (KNF Survey and Manage) GIS and NRIS layers/Atlas (KNF TES species) Aerial photos – Google Earth Fire Severity Mapping (RAVG) Timber type GIS layer – Existing Vegetation (EVeg) Botany program survey records: Horse Heli EIS, Johnny Oneil EIS, Coho Ponds EA, Horse Creek Ecosystem Analysis, Horse Creek Community Protection and Restoration Project. Other Databases/maps – CNNDB, Calflora The objective of this pre-field is to determine if known sites are present in, or in the vicinity of, the proposed project area and to determine if potential suitable habitat for these species exists in the proposed project area. The species addressed in this document include species listed as Threatened, Endangered, Sensitive, Survey and Manage (pre-project surveys required, Appendix A-2) and Survey and Manage (manage known/high priority sites, Appendix A-1). RESULTS OF BOTANICAL PREFIELD REVIEW ANALYSIS FLOWCHART: (See attached Appendix A-2)  Step 1: Survey Protocol triggered for following species: (from an evaluation of known vegetative conditions within the project area prior to conducting a field survey, using currently available information such as known population sites, past botanical surveys

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adjacent to the project area, botanist’s personal knowledge, past vegetation mapping, EUI and Ecology program data, etc.) Vascular Plants Bryophytes Fungi Lichens Arabis macdonaldiana Buxbaumia viridis Cudonia monticola Dendriscocaulon Cypripedium fasciculatum Fissidens aphelotaxifolius Dendrocollybia racemosa intriculatum Cypripedium montanum Ptilidium californicum Phaeocollybia olivacea Draba carnosula Schistostega pennata Eriogonum hirtellum Eriogonum ursinum var. erubescens Erythronium hendersonii Eucephalis vialis Horkelia hendersonii Lupinus aridus var. ashlandensis Pedicularis howellii Pinus albicaulis Tauschia howellii Thermopsis robusta  Step 2: Known Sites Of 1) Sensitive, and 2) Survey and Manage Category A&C from Step 1 list: (pre-project surveys required) SPECIES STATUS POPULATION NUMBER(S) Cypripedium fasciculatum Sensitive, S&M Category C 1 Cypripedium montanum Sensitive, S&M Category C 1 Pedicularis howellii Sensitive 4 Phaocollybia olivacea Sensitive, S&M Category B 4 Ptilidium californicum S&M Category A (in CA only) 1  Step 3: Description of Suitable Habitat for Sensitive/Survey and Manage Category A&C Species: (from Step 1 list) SPECIES STATUS HABITAT Arabis State, Federally Ultramafic soils, from 3900-7200 ft, also rocky granite macdonaldiana Endangered opening in Jeffrey pine.

Cypripedium Sensitive, S&M Variable, many types of coniferous and hardwood fasciculatum Category C forest, most commonly from 1650-5600 ft. in CA.

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SPECIES STATUS HABITAT Cypripedium Sensitive, S&M Variable, many types of coniferous and hardwood montanum Category C forest, most commonly from 1650-5600 ft. in CA.

Buxbaumia Sensitive, S&M Restricted to logs or stumps with high water content in viridis Category E late stages of decay, on humus and occasionally on mineral soil, in cool, perennially moist spots from 3,500-5000 feet.

Cudonia Sensitive, S&M Generally found in mature, moist coniferous forests. It monticola Category B occurs on litter of the forest floor where it feeds on dead and decaying organic material. With spruce, white fir and Douglas-fir; under conifers.

Dendriscocaulon Survey and Variable. The nearest populations, in Josephine and intriculatum Manage A Jackson Co., Oregon, occur on black, white, and live oak as well as tan-oak, in stands with a substantial conifer component. Generally known for humid or wet- climate zones – the Southern Oregon populations indicate possible habitat in this project area.

In mixed forests with coast live oak, tanoak and Sensitive, Douglas-fir. In moss bed along streams. Parasitic. Dendrocollybia Survey and Solitary or in small groups on the decayed remains of racemosa Manage decayed mushrooms, or in duff of mixed hardwood- Category B conifer woods.

Draba carnosula Sensitive This species inhabits rocky ultramafic or granodiorite slopes and cliffs above 6,000 feet within red fir and subalpine forests in the Klamath Mountains. (known from 5200 ft in Red Buttes)

Eriogonum Sensitive Restricted to bald serpentine outcrops or gravelly slopes hirtellum and ridges from 2000 to 5500 feet in elevation.

Eriogonum Sensitive Habitat on the Klamath N.F. consists of north facing ursinum var. rocky ridge tops, in openings within montane shrub erubescens communities at 5,300 to 6,200 feet on non-ultramafic metamorphics.

Erythronium Sensitive Oak woodland and mixed conifer forest in openings or hendersonii filtered sunlight from 900 to 5200 ft elevation.

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SPECIES STATUS HABITAT Eucephalis vialis Sensitive Found in coniferous forests from 500'-3150', typically on dry upland sites dominated by Doug-fir, in canopy gaps and forest edge habitat, roadsides.

Grows on wet soil, humus and rocks along narrow streams and in the vicinity of small waterfalls, and in Fissidens Sensitive damp or wet crevices of cliffs. It is not expected in aphelotaxifolius areas where peak flows wash mosses away. Sea level to 6300 feet.

Horkelia Sensitive, Dry, open, gravelly slopes and ridges on DG, openings hendersonii Under in red fir forest, from 6700-7500 ft' Conservation Agreement Lupinus aridus Sensitive, Siskiyou Crest, open, rocky ridge tops on sandy var. ashlandensis Under decomposed granitic soils, above 6000 feet elevation. Conservation Agreement Pedicularis Sensitive Edges of openings, or in shade within conifer forests. howellii 4,000-6,500 ft.

Pinus albicaulis Sensitive, Cold, windy, high elevation or high latitude sites. On Federal the KNF mainly restricted to high elevation ridge tops. Candidate Generally above 6500 feet, near tree-line.

Ptilidium Survey and Found on late-successional or old-growth conifer trees, californicum Manage A on bark at the base of standing trees or recently fallen logs. From 1,275 to 5,725 feet in elevation.

Tauschia howellii Sensitive Openings within subalpine and upper montane coniferous forest with Abies, and Tsuga sp. from 5500 to 8300 feet in elevation, on decomposed granitic soils on ridge tops and upper slopes.

Thermopsis Sensitive Openings, along ridge lines, lower montane forest, robusta roadsides <4500 ft. Occurs in openings of Douglas-fir dominated and mixed evergreen forests including previously disturbed sites.

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 Step 4: Preliminary Field Review: (Document if preliminary field review does not reveal suitable habitat, in which case no further protocol surveys are needed) Name: David Bowden – District Botanist Date: February, 2018 Preliminary Field Review Results: High severity burn impacts from the 2017 Abney Fires have altered a very large portion of the project area; resulting in changed habitat conditions compared to those currently represented by vegetation models such as Existing Vegetation (EVeg). In moderate (50-74%) to high (75-100%) soil burn severity areas, the pre-existing habitat is assumed to have been destroyed. For some species, low (25-49%) severity effects may have significantly altered habitat to an uninhabitable state. Because the project entails a range of activities, suitable habitat is considered only for those activities that occur in areas of zero-to-low burn severity – with the exception of species that are known to occur in very rocky or sparsely vegetated habitats. Of the approximately 3599 acres proposed for project activities (excluding prescribed burning), 2843 acres (79%) experienced moderate or high burn severity during the 2017 Abney Fire. Of the remaining 756 acres, 591 (16%) experienced low severity and 165 (4.5%) experience none to very little burn severity. In general, the habitats potentially occupied by TESP plant species within the project area are; a) sub-alpine and upper montane environments near or on the Siskiyou Crest, generally above 5000 feet, b) riparian areas including seeps and springs, c) non old-growth variable- aged mixed conifer and hardwood forest below 5000 feet elevation, including disturbed areas d) late successional or old-growth conifer forest, and e) sparse rocky ridgelines extending up to 6200 feet elevation. The field review revealed habitat for the following species: Vascular Plants Bryophytes Fungi Lichens Arabis macdonaldiana Buxbaumia viridis Cudonia monticola Dendriscocaulon Cypripedium fasciculatum Fissidens aphelotaxifolius Dendrocollybia racemosa intriculatum Cypripedium montanum Ptilidium californicum Phaeocollybia olivacea Draba carnosula Schistostega pennata Eriogonum hirtellum Eriogonum ursinum var. erubescens Erythronium hendersonii Eucephalis vialis Pedicularis howellii Pinus albicaulis Tauschia howellii Thermopsis robusta

The field review did not locate any suitable habitat for these species for which the survey protocol was triggered:

77 Botanical Resources and Invasive Plants Seiad-Horse Risk Reduction Project

Vascular Plants Bryophytes Fungi Lichens Horkelia hendersonii Lupinus aridus var. ashlandensis Pinus albicaulis For Survey and Manage Category A&C species: Field surveys are not required if reported sites do not exist in the proposed ground disturbing activity area or in the vicinity, if the project area is not within known or suspected range of the species, or if it is determined that suitable habitat for the target species is not likely to exist in the proposed project area. Furthermore, some of the proposed project activities fall into excepted or exempted categories which do not require pre-disturbance surveys; hazard tree removal (IM OR- 2002-033), thinning in stands less than 80 years old, culvert replacement, riparian planting and/or in-stream wood placement, and prescribed burning. For Threatened, Endangered, and Sensitive species: Field surveys are not required for species for which it is determined that the proposed ground disturbing activity: 1) will not impact populations or alter habitat conditions, or 2) for which the project area is not within the known or suspected range, or 3) for which there is no suitable habitat. Documentation of the prefield review is complete at this step for those species that do not meet the above criteria.  Step 5: Field Survey Required For The Following Species:

SPECIES APPROXIMATE DATES Arabis macdonaldiana June-July 2018 Cypripedium fasciculatum April-July 2018 Cypripedium montanum April-July 2018 Dendriscocaulon intriculatum April-September 2018 Draba carnosula June-July 2018 Eriogonum hirtellum July-September 2018 Eriogonum ursinum var. erubescens July-September 2018 Erythronium hendersonii March-May 2018 Eucephalis vialis May-August 2018 Horkelia hendersonii June-September 2018 Pedicularis howellii June to August 2018 Ptilidium californicum March-September 2018 Tauschia howellii May-September 2018 Thermopsis robusta May-September 2018 Previous Field Surveys of This Project Area: General area: Horse Creek Community Protection and Forest Restoration Project, Horse Heli EIS and Johnny ONeil EIS surveys were done in general area.

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Previous survey adequate for this project: Yes, in the areas where they overlap. MANAGE ALL KNOWN SITES and MANAGE HIGH PRIORITY SITES:  Step 6: Known Sites of Species of Interest Category B, D, &E Plant Species (Manage Known Sites) Within the Project Area (see attached Appendix A-1):

POPULATION SPECIES STATUS NUMBER(S) Cantharellus subalbidus S&M Category D 2 Phaeocollybia californica S&M Category B 2 Phaeocollybia fallax S&M Category D 1 Phaeocollybia kaufmanii S&M Category D 1 Phaeocollybia olivacea S&M Category E 4 Phaeocollybia piceae S&M Category B 3 Ramaria rubrievanescens S&M Category B 1 Ramaria rubripermanens S&M Category B (In California) 1

• Step 7: Comments, Other Botanical Elements of Concern (i.e. invasive species): In anticipation of species list changes, additional species that are currently considered Sensitive by the Rogue-Siskiyou National Forest in Region 6 should be considered in this analysis and surveyed for. These species include Epilobium siskiyouense, and Saussurea americana. Others to consider for further analysis are as follows: Bruchia bolanderi, Bryum calobryoides, Castilleja schizotricha, Erigeron cervinus, Eriogonum diclinum, Poa rhizomata, and Saxifragopsis fragarioides. Surveys for Invasive Species have been completed for much of the project area due to overlapping projects and BAER work. Unsurveyed roads and high-cattle-traffic areas should be surveyed for invasive plants prior to project implementation. There is an ongoing risk that many invasives were spread by firefighters during the Gap and Abney Fires that have not been detected yet. The area will need to be monitored. High priority invasive plant species for detection and eradication in the project are are houndstongue (Cynoglossum officinale) and spotted knapweed (Centaurea maculosa), as well as dyer’s woad (Isatis tinctoria) where it occurs near the Siskiyou Crest. Description of S&M Categories: A: Manage All Known Sites; Pre-disturbance surveys required; Strategic Surveys. B: Manage All Known Sites; Strategic Surveys. C: Manage High Priority Sites; Pre-disturbance surveys required; Strategic Surveys. D: Manage High Priority Sites; Strategic Surveys. E: Manage All Known Sites; Strategic Surveys. F: Strategic Surveys. References:

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USDA Forest Service 2013. 2670: Federally listed and Sensitive Plant Species. Klamath National Forest. July, 2013. USDA Forest Service 2014a. Threatened, Endangered and Sensitive Plant Species, Klamath National Forest. TES_habitats_2014.doc. Species, habitat, distribution and rarity, and management sensitivity. January 2014. USDA Forest Service 2014b. Survey and Manage Plant Species. Klamath National Forest. S+mCatA- C_Habitats03Dec2014.xlsx. Species, habitat, range, survey protocols, and management sensitivity. December 2014. USDA Forest Service and USDI Bureau of Land Management. January 2001. Record of Decision for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines in Forest Service and Bureau of Land Management Planning Documents Within the Range of the Northern Spotted Owl. USDA Forest Service and USDI Bureau of Land Management 2003. Implementation of 2003 Survey and Manage Annual Species Review. FS-Memorandum; BLM – Instruction Memorandum No. OR-2004-034. December 19, 2003. USDA Forest Service and USDI Bureau of Land Management 2014. Regions 5 and 6. Direction Regarding the Survey and Manage Standards and Guidelines. May 13, 2014. Enclosures: Enclosure 1-NEPA Language; Enclosure 2 Table 1-1, January 2001; Enclosure 3 Table 1-1, December 2003 with Red Tree Vole

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Appendix B: Noxious Weed and Nonnative Invasive Plant List

Scientific Name Plant KNF CDFA Cal-IPC (Jepson, 2012) Code Common Name(s) Priority Rating Rating Family Acroptilon repens (L.) DC. ACRE3 Russian knapweed High B Moderate Asteraceae

Ailanthus altissima AIAL Tree of Heaven Mod. C Moderate Simaroubaceae

Bromus tectorum L. BRTE Cheat Grass Low None High Poaceae

Buddleja davidii Franchet BUDA2 Butterfly bush Mod. None None Buddlejaceae

Cardaria draba (L.) Heart-podded hoary Desv. CADR cress Whitetop Mod. B Moderate Brassicaceae Cardaria chalapensis (L.) CACH Moderate Hand.-Maz 10 Lens-podded Whitetop Mod. B ♦ Brassicaceae Cardaria pubescens (C.A. Mey) Jarmol. CAPU6 Hairy whitetop High B Limited Brassicaceae Carduus acanthoides L. subsp. acanthoides CAAC Plumeless thistle High A Limited Asteraceae

Carduus nutans L. CANU4 Musk thistle High A Moderate Asteraceae Carduus pycnocephalus L. subsp. pycnocephalus CAPY2 Italian thistle High C Moderate Asteraceae Diffuse knapweed, Centaurea diffusa Lam. CEDI3 white knapweed High A Moderate Asteraceae

Centaurea maculosa CEMA4 Lam. CESTM Spotted knapweed High A High Asteraceae

Centaurea melitensis L. CEME2 Malta starthistle High None Moderate Asteraceae CEPR2 Centaurea pratensis Moderate Thuill. CENI3 Meadow knapweed High A ♦ Asteraceae

Centaurea solstitialis L. CESO3 Yellow starthistle Mod. C High Asteraceae CESQ Centaurea squarrosa Willd. CEVIS2 Squarrose knapweed High A Moderate Asteraceae Rush skeleton weed, Chondrilla juncea L. CHJU hogbite High A Moderate Asteraceae Cirsium arvense (L.) Scop. CIAR4 Canada thistle Mod. B Moderate Asteraceae

Cirsium vulgare CIVU Bull thistle Low C Moderate Asteraceae

Conium maculatum L. COMA2 Poison hemlock Low None Moderate Apiaceae Cynoglossum officinale L. CYOF Houndstongue High None Moderate Boraginaceae Cytisus scoparius (L.) Link. CYSC4 Scotch Broom High C High Fabaceae

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Euphorbia esula L. EUES Leafy spurge High A High♦ Euphorbiaceae Euphorbia oblongata Grisb. EUOB4 Oblong spurge High B Limited Euphorbiaceae

Foeniculum vulgare Mill. FOVU4 Fennel High None High Apiaceae

Genista monspessulana (L.) L. Johnson GEMO2 French broom High C High Fabaceae Klamath weed, St. Hypericum perforatum L. HYPE John's wort Low C Moderate Hypericaceae Dyer's woad, Marlahan Isatis tinctoria L. ISTI mustard Mod. B Moderate Brassicaceae

Lathyrus latifolius L. LALA4 Sweet pea Low None None Fabaceae Perennial Pepperweed, tall Lepidium latifolium L. LELA2 whitetop High B High Brassicaceae

Linaria dalmatica (L.) P. Schropulariacea Mill ssp. Dalmatica LIDAD Dalmatian toadflax High A Moderate e

Lythrum salicaria L. LYSA2 Purple Loosestrife High B High Lythraceae

MEAL2, White Sweetclover, Melilotus spp. MEOF Yellow Sweetclover Low None None Fabaceae Myriophyllum spicatum L. MYSP2 Eurasian milfoil High None High Haloragaceae Onopordum acanthium Scotch thistle, L. ONAC Cottonthistle High A High Asteraceae Onopordum tauricum Taurian thistle, Bull Willd. ONTA cottonthistle High A None Asteraceae Polygonum cuspidatum Moderate Sieb. & Zucc. POCU6 Japanese knotweed High B ♦ Polygonaceae

Potentilla recta L. PORE5 Sulphur cinquefoil High A None Rosaceae

Rubus discolor RUDI2 Himalayan blackberry Low None None Rosaceae

Salvia aethiopis L. SAAE Mediterranean sage High B Limited Lamiaceae

Sonchus arvensis SOAR2 Perennial Sow-thistle High A None Asteraceae

Spartium junceum SPJU2 Spanish Broom High C High Fabaceae Taenaiatherum caputmedusae TACA8 Medusahead Low C High Poaceae

Tamarix parviflora TAPA4 Tamarisk High B High Tamaricaceae

Tribulus terrestris TRTE Puncture vine High C None Zygophyllaceae

Total number of species: 45. KNF Priorities: High = 30; Moderate = 7; Low = 8. Number of species known to occur on: FS lands = 39; Within Siskiyou County = 44

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CDFA Non-rated = 10; Cal-IPC Non-rated = 8. Note: Knapweed taxonomy is in a state of flux. Additional plant codes listed represent generally accepted synonyms.

Note: Klamath National Forest boundary includes lands in Oregon on the Dutchman Peak, Siskiyou Peak and Mt. Ashland quadrangles. Projects in these areas also address ODA list, referenced below.

Pest Ratings:

Klamath National Forest (KNF) Priority:

High: These species are currently either limited in distribution, highly invasive, or not present on the KNF. Treatment may vary by location.

Moderate: These species are generally common, and are treated on a case by case basis depending on location (Wilderness and Research Natural Area (RNA) increase the priority for treatment).

Low: These species are either widespread throughout the KNF, or are not considered to be highly invasive in our area. Usually not treated unless located in a high priority area, such as Wilderness or RNA.

California Dept. of Food and Agriculture (CDFA):

A: Eradication, containment, rejection, or other holding action at State-County level. Quarantine interceptions to be rejected or treated at any point in the State.

B: Species more widespread. Eradication, containment, control, or other holding action at the discretion of the County Ag. Commissioner.

C: Species very widespread. State endorsed holding action and eradication only when found in a nursery; action to retard spread outside of nurseries at the discretion of the commissioner; reject only when found in a crop seed for planting or at the discretion of the County Ag. Commissioner.

Q: Temporary "A" action outside of nurseries at the state-county level pending determination of a permanent rating. Species on List 2, "Federal Noxious Weed Regulation" are given an automatic "Q" rating when evaluated in California.

California Invasive Plant Council (Cal-IPC):

High: These species have severe ecological impacts on physical processes, plant and animal communities, and vegetation structure. Their reproductive biology and other attributes are conducive to moderate to high rates of dispersal and establishment. Most are widely distributed ecologically.

Moderate: These species have substantial and apparent—but generally not severe—ecological impacts on physical processes, plant and animal communities, and vegetation structure. Their reproductive biology and other attributes are conducive to moderate to high rates of dispersal, though establishment is generally dependent upon ecological disturbance. Ecological amplitude and distribution may range from limited to widespread.

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Limited: These species are invasive but their ecological impacts are minor on a statewide level or there was not enough information to justify a higher score. Their reproductive biology and other attributes result in low to moderate rates of invasiveness. Ecological amplitude and distribution are generally limited, but these species may be locally persistent and problematic.

♦ = Alert

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