Biological Evaluation Sensitive Plants and Fungi Tahoe National Forest American River Ranger District Big Hope Fire Salvage and Restoration Project

Home , Dendrocollybia, Leucothoe davisiae, Lewisia, Packera layneae, Western North America

BIOLOGICAL EVALUATION SENSITIVE PLANTS AND FUNGI TAHOE NATIONAL FOREST AMERICAN RIVER RANGER DISTRICT BIG HOPE FIRE SALVAGE AND RESTORATION PROJECT

Prepared by:

KATHY VAN ZUUK Plant Ecologist/Botanist TNF Nonnative Invasive Plant Coordinator February 27, 2014

A Portion of the American Wildfire Area along Foresthill Divide Road

TABLE OF CONTENTS

Topic Page Executive Summary 4 Introduction 6 Consultation to Date 6 Current Management Direction 8 Alternative Descriptions 9 Existing Environment 11 Description of Affected Sensitive Species Habitat Effects Analysis and 20 Determinations Reasonably Foreseeable Actions/Time Frames for the Analysis/ List of 20 Assumptions

Effects to Species without potential habitat in the Project Area 22

• Lemmon’s milk-vetch, Astragalus lemmonii 22 • Modoc Plateau milk-vetch, Astragalus pulsiferae var. coronensis 22 • Sierra Valley Ivesia, Ivesia aperta var. aperta 22 • Dog Valley Ivesia, Ivesia aperta var. canina 23 • Plumas Ivesia, Ivesia sericoleuca 23 • Webber’s Ivesia, Ivesia webberi 23 • Wet-cliff Lewisia, Lewisia cantelovii 24 • Long-petaled Lewisia, Lewisia longipetala 24 • Follett’s mint, Monardella follettii 24 • Layne’s butterweed, Packera layneae 24 • White bark pine, Pinus albicaulis 25 • Sticky Pyrrocoma, Pyrrocoma lucida 25

Effects to Species with potential habitat in the Project Area 26

• Webber’s Milkvetch, Astragalus webberi 26 • Carson Range rock cress, Boechera rigidissima var. demota 27 • Triangle-lobe moonwort, Botrychium ascendens 27 • Scalloped moonwort, Botrychium crenulatum 27 • Common moonwort, Botrychium lunaria 27 • Mingan moonwort, Botrychium minganense 27 • Mountain moonwort, Botrychium montanum 28 • Bolander’s candle moss, Bruchia bolanderi 29 • Clustered Lady’s Slipper Orchid, Cypripedium fasciculatum 29 • Mountain Lady’s Slipper Orchid, Cypripedium montanum 30 • Starved Daisy, Erigeron miser 31 • Donner Pass Buckwheat, Eriogonum umbellatum var. torreyanum 31 • Butte Fritillary, Fritillaria eastwoodiae 31 • Blandow’s bog-moss, Helodium blandowii 31 • Santa Lucia Dwarf Rush, Juncus luciensis 32 • Hutchison’s Lewisia, Lewisia kelloggii subsp. hutchisonii 32 • Kellogg’s Lewisia, Lewisia kelloggii subsp. kelloggii 32 • Sawtoothed Lewisia, Lewisia serrata 34 • Broad-nerved hump-moss, Meesia uliginosa 34 • Elongate copper moss, Mielichhoferia elongata 35 • Aquatic lichen, Peltigera gowardii 35 • Closed-throated Beard-tongue, Penstemon personatus 35

TABLE OF CONTENTS (continued)

• Stebbins’ Phacelia, Phacelia stebbinsii 36 • Sierra blue grass, Poa sierrae 36 • Howell’s Tauschia, Tauschia howellii 37

Effects of the Alternatives to Rare Fungi 40

• Large Cudonia, Cudonia monticola 40 • Branched Collybia, Dendrocollybia racemosa 40 • Olive Phaeocollybia, Phaeocollybia olivacea 40 • Sowerbyella, Sowerbyella rhenana 40 Project File 47 Management Requirements 47

List of Tables Page Table 1 – Summary of Effects to Threatened and Sensitive Species 4 Table 2 – Tahoe National Forest Rare Plants and Fungi 7 Table 3 - Summary of the Big Hope Fire Salvage and Restoration Project Proposed 11 Actions Table 4 – Plant Communities within the American Wildfire Perimeter 11 Table 5 - Plants Observed in the 2012 Surveys 13 Table 6 – Plants Observed in Little Secret Meadow/Peatland/Fen 15 Table 7 – Vegetative Condition of Some of the Streams in the Project Area 16 Table 8 – Number of threatened & sensitive plant/fungi occurrences on the TNF 19 Table 9 – Information about TNF Poa sierrae Occurrences as of 7/17/13 36 Table 10 – Percentage of proposed units that burned with high/moderately-high severity 42 Table 11 – Rare Plant and Nonnative Invasive Plant Management Requirements 47

List of Figures Page Figure 1 – Edge of Secret Meadow/Fen - 10/17/13 16 Figure 2 – Water Hole at Stream near Beacroft Parking Area- 10/17/13 17 Figure 3 - Sceptridium multifidum in Secret Meadow - 10/17/13 28 Figure 4 - Lewisia kelloggii subsp. hutchisonii occurrence with dozer tracks 33 Figure 5 - Lewisia serrata plants within the American Wildfire Perimeter 34

List of Appendices Page Appendix A – Environmental analysis paragraphs 49 Appendix B – Additional Photos 51

Executive Summary BIOLOGICAL EVALUATION FOR BIG HOPE FIRE SALVAGE AND RESTORATION PROJECT Prepared by Kathy Van Zuuk February 27, 2014

The Proposed Action will: fell and remove trees on up to 3,443 acres of National Forest System lands within the American Wildfire perimeter utilizing ground based and/or aerial logging systems; fell and remove hazard trees on about 125 miles of roads and trails about 5,519 acres); and site prep, plant trees and do future release on about 7,295 acres. In addition about 125 miles of existing roads will be repaired/maintained and about 7 miles of temporary road constructed. The Project Area (defined as areas where ground disturbance is proposed) has elevations that range from about 2,500 to 7,000 feet. Rare plant and nonnative invasive plant surveys will be done in 2014 prior to Project operations. A small part of the Project Area was surveyed in 2012 as part of the Little Secret Project. No threatened, endangered, proposed (TEP), candidate (C), sensitive (S), or watchlist (W) plants were found in the 2012 surveys. The Project Area does not provide potential habitat for any TEPC species. Therefore, consultation with the USFWS is not required. Refer to the Project Biological Analysis (BA). Table 1 provides a summary of possible effects to sensitive species (also the federally threatened plant Packera layneae) from Project operations. Table 1 – Summary of Effects to Threatened and Sensitive Species

SPECIES HABITAT/ EFFECTS DETERMINATION AND/OR SURVEY DETECTIONS RESULTS ARE PRESENT Astragalus lemmonii N/A No effect. The Project Area is not located in sagebrush scrub and wet areas. Astragalus pulsiferae N/A No effect. The Project Area is not located on the var. coronensis eastside of the forest/Great Basin scrub. Astragalus webberi Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Boechera rigidissima Potential habitat is May effect but will not contribute to a trend for var. demota present. Federally listing as threatened or endangered. Botrychium ascendens Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Botrychium crenulatum Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Botrychium lunaria Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Botrychium minganense Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Botrychium montanum Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Bruchia bolanderi Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Cudonia monticola Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Cypripedium Potential habitat is May effect but will not contribute to a trend for fasciculatum present. Federally listing as threatened or endangered. Cypripedium montanum Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Dendrocollybia Potential habitat is May effect but will not contribute to a trend for racemosa present. Federally listing as threatened or endangered. Erigeron miser Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Eriogonum umbellatum Potential habitat is May effect but will not contribute to a trend for var. torreyanum present. Federally listing as threatened or endangered.

SPECIES HABITAT/ EFFECTS DETERMINATION AND/OR SURVEY DETECTIONS RESULTS ARE PRESENT Fritillaria eastwoodiae Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Helodium blandowii Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Ivesia aperta var. aperta N/A No effect. The Project Area is not located on the eastside of the Forest. Ivesia aperta var. canina N/A No effect. The Project Area is not located on the eastside of the Forest. Ivesia sericoleuca N/A No effect. The Project Area is not located on the eastside of the Forest. Ivesia webberi N/A No effect. The Project Area is not located on the eastside of the Forest. Juncus luciensis Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Lewisia cantelovii N/A No effect. The Project Area is not located within the Yuba River drainage system. Lewisia kelloggii subsp. Potential habitat is May effect but will not contribute to a trend for hutchisonii present. Federally listing as threatened or endangered. Lewisia kelloggii subsp. Potential habitat is May effect but will not contribute to a trend for kelloggii present. Federally listing as threatened or endangered. Lewisia longipetala N/A No effect. The Project Area is too low in elevation to provide potential habitat. Lewisia serrata Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Meesia uliginosa Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Mielichhoferia elongata N/A No effect. Implementation of the Project will not affect rock with copper/heavy metals. Monardella follettii N/A No effect. The Project Area does not contain serpentine soils/potential habitat. Packera layneae N/A No effect. The Project Area does not contain serpentine soils/potential habitat. Peltigera gowardii Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Penstemon personatus Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Phacelia stebbinsii Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Phaeocollybia olivacea Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Pinus albicaulis N/A No effect. No whitebark pine trees will be affected by implementation of the Project. Poa sierrae Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Pyrrocoma lucida N/A No effect. The Project Area is not located on the eastside of the Forest. Sowerbyella rhenana Potential habitat is May effect but will not contribute to a trend for present. Federally listing as threatened or endangered. Tauschia howellii Potential habitat is No effect. Implementation of the Project will not affect present. rocky talus slopes.

For information about this plant and fungus biological evaluation, contact:

Kathy Van Zuuk, Tahoe National Forest, 631 Coyote Street, Nevada City, California 95959, Phone: (530) 478-6243; E-mail: [email protected]

I. INTRODUCTION

The purpose of this Biological Evaluation is to document analysis of the potential effects of the Big Hope Fire Salvage and Restoration Project (the Project Area) on threatened, endangered, proposed and sensitive (TEPS) species of plants and fungi and/or their habitats. The species list includes the United States Department of Agriculture (USDA) Forest Service (FS) Region 5 Forester's Sensitive Species (updated in 2013). This Biological Evaluation (and the combined wildlife/fish/plant biological assessment document incorporated by reference) was prepared in accordance with FS Manual (FSM) direction 2672.42 and meets legal requirements set forth under Section 7 of the Endangered Species Act (ESA) of 1973, as amended, and implementing regulations [19 U.S.C. 1536 (c), 50 CFR 402.12 (f) and 402.14 (c)].

Potential habitat for TEPS species was identified within the Project Area using aerial photos, vegetation, soil, and elevation maps. Descriptions of the procedure used to conduct the potential habitat search are located at the Supervisors Office in the Tahoe National Forest Sensitive Plant Program Standards and Guidelines (Van Zuuk 2003 with ongoing updates). Table 2 lists all the FS sensitive species known or suspected to occur on the TNF as well as TEP and candidate plants. Table 2 provides a general description of their habitat, the USFWS listing status and California Native Plant Society (CNPS) status for each species. The status rating is provided to give the reader an indication of the rarity of the species within its’ known range of occurrence.

II. CONSULTATION TO DATE

The United States Fish and Wildlife Service (USFWS) is contacted every 90 days to obtain a current list of threatened, endangered, and proposed species that may be present on the TNF. The most recent list is available for review at the Supervisors Office (SO). The USFWS Candidate species, Ivesia webberi, has potential habitat on the eastside of the TNF. The Big Hope Fire Salvage and Restoration Project is located on the westside of the TNF and does not provide habitat for Ivesia webberi. The USFWS Candidate species Pinus albicaulis has also been reported from TNF system lands at high elevations. The Big Hope Fire Salvage and Restoration Project is located at elevations that are too low to support Pinus albicaulis. The Federally Threatened plant species, Packera layneae, is known to occur on TNF system lands on the American River Ranger District (ARRD). Packera layneae will not be impacted by implementation of the Project because the Project Area does not contain serpentinite soils – Packera layneae is considered a broad serpentine endemic. Therefore, consultation with the USFWS for plants is not required for this project.

Table 2 – List of Tahoe National Forest Rare Plants and Fungi

SPECIES STATUS STATUS HABITAT USFWS1 CNPS2 Astragalus lemmonii None 1B.2 4,265-7,220’, sagebrush scrub & wet areas Astragalus pulsiferae var. coronensis None 4.2 4,400-6,200 feet, Great Basin/sagebrush scrub, yellow pine forest Astragalus webberi None 1B.2 2,400-4,100’, dry openings in forest/shrubs Boechera rigidissima var. demota None 1B.3 5,900-6,600 feet, drainages, meadow edge, moist microsites in sandy/rocky soil Botrychium ascendens None 2.3 4,000 feet +, moist/riparian areas Botrychium crenulatum None 2.2 4,000 feet +, moist/riparian areas Botrychium lunaria None 2.3 4,000 feet +, moist/riparian areas Botrychium minganense None 2.2 4,000 feet +, moist/riparian areas Botrychium montanum None 2.1 4,000 feet+, moist/riparian areas Bruchia bolanderi None 2.2 3,800-9,500 feet, moist/riparian areas Cudonia monticola None None No elevation restriction, older-mixed conifer Cypripedium fasciculatum None 4.2 500-7,200 feet, mixed conifer Cypripedium montanum None 4.2 600-7,500 feet, mixed conifer Dendrocollybia racemosa None None No elevation restriction, older-mixed conifer Erigeron miser None 1B.3 6,200-7,500 feet and above, granite Eriogonum umbellatum var. None 1B.2 6,880-7,880 feet, unstable soils torreyanum Fritillaria eastwoodiae None 3.2 <4,900 feet, full to partial sun Helodium blandowii None 2.3 6,100 feet and above, subalpine wet areas Ivesia aperta var. aperta None 1B.2 4,500-7,500 feet, eastside meadows and Ivesia aperta var. canina None 1B.1 seasonal drainages Ivesia sericoleuca None 1B.2 Ivesia webberi Candidate 1B.1 Juncus luciensis None 1B.2 925-6,235 feet, wetlands, riparian Lewisia cantelovii None 1B.2 1,000-4,500 feet, westside, cliffs/outcrops, Lewisia kelloggii subsp. hutchisonii None 3.3 4800-7,000 feet, rocky open ridges Lewisia kelloggii subsp. kelloggii None None 5,000-9,000 feet, rocky open ridges Lewisia longipetala None 1B.3 8,300-9,500 feet, damp gravel Lewisia serrata None 1B.1 3,000-5,000 feet, westside, cliffs/outcrops Meesia uliginosa None 2.2 4,250-6,850 feet, wet areas, fens Mielichhoferia elongata None 2.2 1,600-4,300’, rock with copper/heavy metals Monardella follettii None 1B.2 2,000-6,500 feet, serpentine Packera layneae Threatened About 3,600, gabbro and serpentine Peltigera gowardii None None 1,150 to 7,000 feet in clear, cold water Penstemon personatus None 1B.2 4,500-6,500 feet, partial sun Phacelia stebbinsii None 1B.2 2,000-6,800 feet, westside openings Phaeocollybia olivacea None None No elevation restriction, older-mixed conifer Pinus albicaulis Candidate None Red fir/lodgepole/subalpine, 6,500 feet + Poa sierrae None 1B.3 Mixed conifer forest, 1,000-5,500 feet Pyrrocoma lucida None 1B.2 Below 6,000’, eastside meadows/alkali flats Sowerbyella rhenana None None No elevation restriction, older-mixed conifer Tauschia howellii None 1B.3 5,500-8,500 feet, subalpine.

2 http://cnps.site.aplus.net/cgi-bin/inv/inventory.cgi accessed 4/10/13 7

III. CURRENT MANAGEMENT DIRECTION

Current management direction that applies to the desired future conditions for TNF species of plants and fungi listed as threatened, endangered, proposed, and sensitive can be found in the following documents, filed at the SO office:

• Forest Service Manual and Handbooks (FSM/H) - 2670 • National Forest Management Act (NFMA) • Endangered Species Act (ESA) • National Environmental Policy Act (NEPA) • Tahoe National Forest (TNF) Land and Resource Management Plan (LRMP) as amended by the Sierra Nevada Forest Plan Amendment (SNFPA 2001), Final Supplemental Environmental Impact Statement (FEIS 2004). • Species-specific recovery plans (establish population goals for recovery) • Species management plans • Species management guides and/or conservation strategies • Regional forester policy and management direction

General FS direction for TEP and/or sensitive plants/fungi species is summarized below:

1. Assist States in achieving their goals for conservation of endemic species. 2. As part of the NEPA process, review programs and activities, through a Biological Evaluation, to determine their potential effect on sensitive species. 3. Avoid or minimize impacts to species whose viability has been identified as a concern. 4. If impacts cannot be avoided, analyze the significance of potential adverse effects on the population or its’ habitat within the area of concern and on the species as a whole. 5. Establish management objectives in cooperation with the States when a project on National Forest System (NFS) lands may have a significant effect on sensitive species population numbers or distribution. Establish objectives for Federal candidate species, in cooperation with the USFWS and the States. 6. Conduct field surveys for TEPS plant species early enough in project planning process that the project can be designed to conserve or enhance TEPS plants and their habitat (SNFPA ROD page 66, S&G #125). 7. Prohibit or mitigate ground-disturbing activities that adversely affect hydrologic processes that maintain water flow, water quality, or water temperature critical to sustaining fen ecosystems and plant species that depend on these ecosystems (SNFPA ROD page 65, S&G #118).

IV. ALTERNATIVE DESCRIPTIONS

Alternative 2 (No Action): Under Alternative 2 no management actions will be implemented. Commercial sized trees that were killed or severely damaged by the American Wildfire will not be salvaged and over 7,000 acres of NFS lands will not be site prepped, planted and/or released. The No Action Alternative would not preclude activities that have already been approved in this area or those being planned as separate projects.

Alternative 1 (Proposed Action): The following management activities are proposed (summarized in Table 3):

1. Salvage Fire-Killed Trees with Ground Based Equipment (about 3,008 acres): Salvage harvest fire-killed trees using ground-based equipment. Chainsaws and/or mechanical harvesters (tracked and/or rubber-tired equipment) will be used to fall commercial-sized fire-killed trees on slopes generally less than 30 percent. Fire-killed trees are burned trees that either (1) have no green needles or (2) meet the criteria of a 0.7 Probability of Mortality (Pm) in the Marking Guidelines for Fire-Injured Trees in California, Report # RO-11-01 (Smith and Cluck 2011). A major criterion used will be evidence of significant wood boring and bark beetle activity as detailed in Smith and Cluck (2011). Commercial-sized trees are a minimum of 12 inches diameter at breast height (dbh); however, the minimum diameter limit is expected to increase during project implementation to ensure harvest of sound, utilizable timber. Where economically feasible, non-commercial trees may be felled and left on site where needed to provide slope stability and to reduce overhead hazard to future reforestation efforts. Trees would be limbed and bucked into log segments prior to yarding to the landing. Ground-based rubber tires or tracked tractor-type equipment will be used to yard the log segments.

2. Salvage Fire Killed Trees with Aerial Logging Systems (about 435 acres): Salvage harvest fire-killed trees using an aerial logging system. These treatment areas are greater than 30 percent slope, and either cable or helicopter logging systems would minimize potential impacts on soil and water resources. Chainsaws will be used to fall commercial-sized, fire-killed trees within the treatment areas. Trees will be limbed and bucked into log segments prior to yarding. All activity generated fuel will be lopped and scattered within the treatment area.

3. Remove Trees Posing a Safety Hazard (along about 125 miles of roads and trails and at trailheads and recreation sites): Hazard trees will be removed along about 125 miles of roads and Forest Service designated recreation trails as well as at trailheads and other recreation sites (e.g., Beacroft Trailhead, Ford Point, Western States Trail, Loop 6 OHV Route) within the Project Area (totaling about 5,519 acres, of which about 2,249 acres overlap with salvage and tree planting areas). Hazard trees will be identified using the Hazard Tree Guidelines for Forest Service Facilities and Roads in the Pacific Southwest Region (Angwin et al. 2012). In addition, trees killed by the American Fire that could potentially pose a safety hazard will be identified using the fire mortality guidelines from Marking Guidelines for Fire-Injured Trees in California (Smith and Cluck 2011), with a Pm = 0.7 used to determine which trees will be expected to die within 5 years. Hazard trees (which could be either fire-killed or live trees) will have to be within striking distance of a road, trail, or other improvements and show a high failure potential. High failure potential is determined by the presence of significant defects such as, but not limited to, excessive lean, bole and root decay, bole cracks, severe burn injury to roots and/or bole, and dead tops. Potential hazard trees will be evaluated and rated for danger levels and designated for

harvest by marking crews with oversight from certified timber cruisers. Hazard trees with commercial value (generally greater than 10 inches dbh) may be commercially harvested. The limbs and tops of these cut trees will remain in the woods, and this material will be lopped and scattered on site. Sub-merchantable hazard trees could be felled and left on site.

4. Plant Trees in Burned Areas, Including Site Preparation and Future Release (about 7,295 acres): National Forest System (NFS) lands that experienced moderate to high vegetation burn severity effects will be hand planted with 1 and 2-year-old mixed conifer seedlings (emphasizing shade intolerant pines where appropriate). Planting strategies include variable spacing, cluster planting, and establishment of founder stands. Additionally, hardwoods will be retained and encouraged. Site preparation and future release are either done by hand or by utilizing mechanized equipment. In general, mechanized equipment is not permitted on slopes greater than 30 percent. About 445 acres will be prepared for planting by hand-cutting and piling/scattering re-sprouted shrubs. Up to 3,624 acres could receive mechanical site preparation (mechanical piling 1,148 acres and masticating 2,476 acres) prior to planting if deemed more efficient and cost-effective than hand cutting. Burned material within planting areas (standing and/or on the ground) may be lopped and scattered. About 3,226 acres will be planted without site preparation.

Manual release of competing vegetation may be done on all planted areas at 1 and 3 years after planting, or as needed within the first 5 years of planting. Manual release involves hand cutting (grubbing) competing vegetation within a five foot radius of planted seedlings. If it is deemed more efficient and cost-effective based on site conditions, mechanical release (generally masticating or pulling re-sprouted vegetation with an excavator that has a thumb bucket) may be used on 4,962 acres; the areas identified for potential mechanical site preparation above (3,624 acres) and on 1,199 acres that did not receive site preparation prior to planting.

5. Maintain the Necessary Road System to Manage the Project Area: In order to implement the proposed action and future management activities in the area, about 125 miles of existing National Forest Transportation System (NFTS) roads would be repaired and maintained as necessary. Activities may include grading, improving drainage features, laying gravel, replacing culverts, etc. Approximately 13 miles of Maintenance Level 1 (ML-1) roads (closed roads) road segments would be upgraded to Maintenance Level 2 (ML-2) roads (high-clearance vehicles) for administrative use only. About 7 miles of temporary roads would be constructed to implement the salvage logging operations, and then eliminated after project activities are complete. There would be no changes to the Motor Vehicle Use Map (MVUM).

Table 3 - Summary of the Big Hope Fire Salvage and Restoration Project Proposed Actions

Management Activity Acres Total Salvage Harvest 3,443 Tractor Salvage Harvest 3,008 Aerial Salvage Harvest 435 Roadside Hazard Tree Removal3 5,519 Total Tree Planting4 7,295 Tree Planting Areas With Mechanical Site Preparation and Release 3,624 Tree Planting Areas With Hand Site Preparation and Release 445 Tree Planting Areas With Mechanical Release Only 1,332 Tree Planting Areas With Hand Release Only 1,894 Total Footprint of Treatment Areas5 10,556

V. EXISTING ENVIRONMENT

The American Wildfire (wildfire) burned about 27,440 acres during a period of time from August 10 to August 29, 2013 (containment). Many trees along National Forest Transportation System (NFTS) and Placer County roads were structurally damaged by the wildfire and now pose safety and access hazards. Based on GIS mapping, the major plant communities within the wildfire area included: Douglas-fir, Jeffrey pine, chaparral, hardwood, Ponderosa pine and mixed conifer. Refer to Table 4 for an estimated acreage by plant community type (before it burned) within the American Wildfire perimeter.

Table 4 – Plant Communities within the American Wildfire Perimeter

Plant Community6 Acres Barren 225 Douglas-fir 1948 Jeffrey pine 1418 Lacustrine 1 Mixed chaparral 6 Montane chaparral 1296 Montane hardwood-conifer 1298 Montane hardwood 1848 Montane riparian 53 Perennial grassland 246 Ponderosa pine 1351 Sierran mixed conifer 17445 White fir 304

3 Roadside hazard tree removal overlaps 2,248 acres of the identified salvage harvest and planting areas. 4 The tree planting total includes 3,443 acres planned for planting within salvage harvest areas. 5 The total “footprint” acreage figure does not include overlap with other treatment areas. It represents the actual landscape footprint. 6 CWHR classification

Plant response to wildfire is a result of interaction of the severity of the fire and the characteristics of the plants that were burned (including resistance of the plant to the injury and its ability to recover) (Brown and Smith 2000). The recovering plant community is dependent on the plants that survived the wildfire intact, on the sprouts or suckers that grow from the base of buried plant parts of the top killed plants, and from seeds. Shrubs and other sprouting vegetation will provide the most significant source of postfire vegetation since their root systems run deep and are often protected from lethal temperatures. Once the above ground stem is removed (burned), roots are stimulated to send up new shoots. For example, bracken fern shoots were observed in the fire area within about a month after the wildfire was contained. Larger oaks (black/live oak between 12-24 inches DBH) will produce numerous sprouts from the root crowns. Herbaceous plants (forbs) will recover as long as the regenerative structures were not exposed to lethal temperatures. The depth of these regenerative structures below the soil surface will be the deciding factor. If shrubs become the dominant vegetation on a site that can produce trees, it will take more than 10 to 15 years or longer for trees to dominate the site (Mayer and Laudenslayer 1988). Succession is a dynamic process that moves in different directions dependent on the influence of periodic disturbance. Plant communities may never reach a stable end point (final climax state) because of these dynamic processes. In general terms, over time, all plant communities within the American Wildfire area are expected to recover along their respective post-fire successional trajectories with areas that burned with high intensity taking the longest amount of time to recover. Plant community recovery is based on site conditions, availability of seed, and other environmental factors such as timing and amount of precipitation. Forest communities vary greatly in the amount of time necessary to recover to a mature forest (Brown and Smith 2000).

The remaining burnt trees, logs and branches along with surviving vegetation (referred to as biological legacies) help the ecosystem to recover by retaining soil, providing nutrient inputs, favoring mutualistic plant-animal interactions, acting as seed traps, facilitating survival and population viability in disturbed areas, and promoting plant and animal recolonization by providing habitat features, substrate and food for many species (Leverkus et al. 2014). Leverkus et al. (2014) reports that burnt-wood management (such as that proposed under the Action Alternative affects plant communities in terms of species richness and diversity, percent cover, and species composition and abundance.

The wildfire perimeter contains known occurrences of the sensitive plant species: Lewisia serrata and Phacelia stebbinsii. The known occurrences of these plants burned with low intensity. Phacelia stebbinsii was dormant at the time of the wildfire and may increase in numbers in the future since it is an annual plant that does not compete well for soil nutrients and water with other plant species. A field visit (9/3/13) determined that Lewisia serrata plants were scorched but likely not killed. Two known occurrences of the sensitive plant Lewisia kelloggii subsp. hutchisonii are located within and adjacent to the wildfire perimeter. One occurrence was impacted by suppression activities but was not burned.

A small portion of the Big Hope Fire Salvage and Restoration Project Area (Project Area) was surveyed as part of the Little Secret project in June of 2012 (roughly all or most of units 20, 30, 38 and 39). Table 5 provides a list of plants observed in the 2012 surveys before those areas burned. Refer to the Little Secret project file for documentation of those surveys.

Table 5 - Plants Observed in the 2012 Surveys

Scientific Name Common Name Abies concolor White fir Acer macrophyllum Big leaf maple Achillea millefolium Yarrow Allium species Wild onion – dried Allium campanulatum Dusky onion Alnus tenuifolia Mountain alder Amelanchier species Serviceberry Apocynum androsaemifolium Dogbane Arctostaphylos patula Green-leaf manzanita Arctostaphylos viscida White-leaf manzanita Calocedrus decurrens Incense cedar Calochortus coeruleus Beavertail grass Calyptridium umbellatum Pussypaws Calystegia malacophylla Sierra morning glory Calystegia occidentalis subsp. occidentalis Western morning glory Castilleja species Paintbrush Ceanothus cordulatus Mountain whitethorn Ceanothus cuneatus Buck brush Ceanothus integerrimus Deer brush Ceanothus prostratus Mahala mat Chamaebatia foliolosa Bear clover Chimaphila menziesii Little prince’s pine Chondrilla juncea Skeleton weed Chrysolepis species Chinquapin Clarkia rhomboidea Diamond fairyfan Corallorhiza maculata Spotted coralroot Cordylanthus species Birds beak Collinsia parviflora Small flower blue-eyed Mary Cornus nuttallii Dogwood Cornus sericea Red osier dogwood Cuscuta species Dodder Delphinium species Larkspur Drymocallis glandulosa Gland cinquefoil Elymus elymoides Squirreltail grass Eriogonum species Buckwheat Eriogonum nudum Naked buckwheat Eriogonum umbellatum var. polyanthum Sulfur buckwheat Eriogonum umbellatum var. torreyanum Donner Pass buckwheat Eriophyllum lanatum var. achillaeoides Wooly sunflower Fragaria species Wild strawberry Galium aparine Stickywilly bed straw Galium porrigens Climbing bedstraw Goodyera oblongifolia Rattlesnake orchid Horkelia species Horkelia Hypericum perforatum Klamath weed Hypochaeris species Cats ear Iris species Wild iris Lilium species Lily Linanthus ciliatus Whisker brush Lotus species Lotus Lotus argophyllus var. fremontii Fremont’s silver lotus Lupinus species Lupine – no flowers/not fuzzy Luzula species Woodrush Mimulus guttatus Seep-spring monkeyflower Mimulus primuloides Primrose monkeyflower Mimulus torreyi Torrey’s monkeyflower

Scientific Name Common Name Monardella species Mint Nama lobbii Lobb’s fiddleleaf (Wooly Nama) Osmorhiza berteroi Sweet cicely Penstemon laetus Gay penstemon Pinus jeffreyi Jeffrey pine Pinus lambertiana Sugar pine Plagiobothrys species Popcorn flower Polygala cornuta Sierran milkwort Polytrichum species Moss Potentilla glandulosa Gland cinquefoil Prunus emarginata Bitter cherry Pseudotsuga menziesii Douglas-fir Pteridium aquilinum var. pubescens Bracken fern Pterospora andromedea Woodland pine drops Pyrola picta White-veined wintergreen Quercus kelloggii Black oak Quercus vaccinifolia Huckleberry oak Rhamnus species Coffee berry Ribes species Gooseberry – no flowers Ribes nevadense Sierra currant Ribes roezlii Sierra gooseberry Rubus leucodermis Whitebark raspberry Rubus parviflorus Thimbleberry Rumex acetosella Sheep sorrel Selaginella species Spikemoss Sequoiadendron giganteum Giant sequoia Smilacena racemosa False Solomon’s seal Spiraea densiflora Mountain spiraea Stellaria longipes Longstalk starwort Stephanomeria lactucina Wirelettuce Streptanthus tortuosus var. suffrutescens Jewel flower Symphoricarpos species Snowberry Triteleia ixioides subsp. anilina Golden stars/Pretty face Veratrum californicum Corn lily Viola lobata Pine violet Viola purpurea Mountain violet Viola sheltonii Fan violet Whitneya dealbata Whitneya

The 2012 surveys were focused on terrestrial habitats – not wetlands/riparian habitats, because no management activities were proposed in wetland/riparian habitats in the Little Secret Project. However, some of the Little Secret meadow/peatland/fen7 area plants were identified in a 2011 survey that was focused on meadow grasses. Refer to Table 6.

7 Little Secret peatland has not been tested to protocol to determine whether it has 40 cm of peat and is therefore a fen. 14

Table 6 – Plants Observed in Little Secret Meadow/Peatland/Fen

Scientific Name Common Name Agrostis pallens Seashore bentgrass Boykinia major Large boykinia Carex athrostachya Slenderbeak sedge Cornus species Dogwood Drepanocladus species Moss Drymocallis glandulosa Sticky cinquefoil Epilobium ciliatum subsp. ciliatum Willow weed Erigeron peregrinus Wandering daisy Glyceria elata Tall mannagrass Hosackia oblongifolia Streambank birdsfoot trefoil Hypericum anagalloides Tinker’s penny Juncus effusus subsp. pacificus Pacific rush Leafy liverwort In stream Leucothoe davisiae Sierra laurel – near stream Mimulus guttatus Seep-spring monkeyflower Mimulus primuloides Primrose monkeyflower Perideridia parishii Sierra yampah Philonotis species Moss Platanthera dilatata subsp. leucostachys Bog orchid - abundant Polystichum imbricans Narrowleaf swordfern Ptychostomum pacificum Moss – looks like Bryum Prunella vulgaris var. lanceolata Self-heal Sceptridium multifidum Grapefern – was Botrychium Senecio triangularis Arrowhead butterweed Viola species – no flowers Violet

In addition, some of the Project Area stream/road crossing areas were visited in October and November of 2013 to evaluate their existing condition. In general, 8 stream areas proposed for hazard tree removal in the Ford Hazard Tree Removal Project (crossed by the Foresthill Divide and American Hill roads) were visited. Table 7 provides a generalized description of the existing condition of the wetland/riparian vegetation in these 8 areas. These 8 stream areas all had some amount of water in them except the stream located along American Hill Road where the road crosses above Macedon Mine in section 2 (the 2nd stream crossing along American Hill Road as you travel that road away from the Foresthill Divide Road-south).

The sensitive species with potential habitat in the Project Area occur within aquatic/riparian, forest edge, older-forest, and high elevation opening plant communities. The Project Area does not have serpentine habitats or decomposed granite soils. Since the TNF sensitive plant and fungi species are known to occur in relatively specific habitats, they have been grouped by the types of plant community where they grow. This grouping provides a rough approximation of the type of plant community each species needs and allows for an evaluation of how the potential habitat is impacted by proposed actions. The following discussion groups all 40 sensitive species (and one threatened species) within plant communities and/or places them into a non- specific plant community group. A brief summary is provided that identifies whether a species has potential habitat within the Project Area (based on an in office review) and addresses why a particular species does not have potential habitat in the Project Area.

Table 7 – Vegetative Condition of 8 Streams/Road Crossings (Oct/Nov of 2013)

Name Comments Secret Meadow/Fen The wildfire burned up to the edge of this wet meadow/fen complex. The wetland/riparian area is still green. Most of the trees located next to the meadow/fen still show green leaves/needles. Refer to Figure 1. Stream near Beacroft The stream has a developed water hole. The wetland/riparian vegetation parking area associated with the stream burned almost 100%. The conifers that provided shade for the stream are all burned. Bracken fern, thimble berry, dogwood, dogbane, and bittercherry sprouting was observed. Refer to Figure 2. Stream near Skunk The wetland/riparian vegetation associated with the stream burned almost Spring/Ford Point area 100%. The conifers that provided shade for the stream are all burned. Water was flowing out of the culvert. Dogwood sprouts were observed. American Hill Road The wetland/riparian vegetation associated with the stream burned but some and the first stream riparian vegetation remains green – for example, portions of Sierra laurel crossing shrubs. The conifers that provided shade for the stream are all burned. Thimbleberry sprouts were observed. American Hill Road The wetland/riparian vegetation associated with the stream burned almost and the second stream 100%. The conifers that provided shade for the stream are all burned. crossing American Hill Road The wetland/riparian vegetation associated with the steam burned almost 100%. and the third stream A pool of water was observed on 11-26-13 in the stream above the American crossing-above Hill Road. The downhill portion of the stream was dry. Macedon Tunnel American Hill Road The wetland/riparian vegetation associated with the steam partially burned. The and the Little Secret stream is flowing well (11/26/13). Riparian vegetation that was not completely Canyon stream burned included some: alder, dogwood, Indian rhubarb (Darmera peltata), and crossing Sierra laurel (Leucothoe davisiae). Lots of rock with moss adjacent to stream. Stream slopes are steep. American Hill Road The wetland/riparian vegetation associated with the steam partially burned. The and the Secret Canyon stream is flowing well. Riparian vegetation that was not completely burned stream crossing included some: alder, dogwood, and Indian rhubarb. Lots of rock with moss. Stream slopes are steep. There is a seep above the road (about the 4 ½ mile post) that has Sedum spathulifolium growing on it.

Figure 1 – Edge of Secret Meadow/Peatland/Fen (10/17/13)

Figure 2 – Water Hole at Stream near Beacroft Parking Area (10/17/13)

Aquatic/riparian plant communities: For this analysis, aquatic/riparian plant communities include those found associated with: wet meadows, seeps, fens, vernally wet areas, riparian (streamside/lakeside/reservoir edges), wet/moist rock cliffs, and spring habitats. TNF sensitive species that occur in/are dependent on aquatic/riparian plant communities include: Astragalus lemmonii, Botrychium ascendens, Botrychium crenulatum, Botrychium lunaria, Botrychium minganense, Botrychium montanum, Bruchia bolanderi, Helodium blandowii, Ivesia aperta var. aperta, Ivesia aperta var. canina, Ivesia sericoleuca, Ivesia webberi, Juncus luciensis, Lewisia cantelovii, Lewisia serrata, Meesia uliginosa, Peltigera gowardii, and Pyrrocoma lucida.

The Project Area does not have potential habitat for: Astragalus lemmonii, Ivesia aperta var. aperta, Ivesia aperta var. canina, Ivesia sericoleuca, Ivesia webberi, and/or Pyrrocoma lucida. These plants are not known to grow on the westside of the Forest (they are found on the eastside of the Sierra Nevada crest).

Serpentine and/or heavy metal plant communities: Sensitive species that occur on serpentinite soils or copper/heavy metal soils include: Mielichhoferia elongata and Monardella follettii. The federally threatened species, Packera layneae also occurs on serpentine and/or gabbro soils. The Project Area does not contain serpentine plant communities. Therefore, the Project Area does not have habitat that would support Monardella follettii or Packera layneae.

Older forest plant communities: Sensitive species dependent on older forest plant communities include: Cudonia monticola, Dendrocollybia racemosa, Cypripedium fasciculatum, Cypripedium montanum, Phaeocollybia olivacea, and Sowerbyella rhenana. The Project Area has potential habitat for all of these species but that potential habitat has been altered by the wildfire.

Forested edges/openings: Forests of all ages contain openings and edges. Plants dependent on openings and edges within forested plant communities are not considered habitat specific. Openings and forest edges are constantly being created as trees and other vegetation dies, and lost as vegetation grows into them. Sensitive species with potential habitat within openings and in edge situations include: Astragalus pulsiferae var. coronensis, Astragalus webberi, Fritillaria eastwoodiae, Lewisia kelloggii subsp. hutchisonii, Lewisia kelloggii subsp. kelloggii, Penstemon personatus, Phacelia stebbinsii, and Poa sierrae. There are known occurrences of Lewisia kelloggii subsp. hutchisonii, Phacelia stebbinsii, and Poa sierrae adjacent to the Project Area on the ARRD.

The Project Area does not have potential habitat for Astragalus pulsiferae var. coronensis because it is only found in Great Basin scrub – it has potential habitat on the eastside of the forest.

High elevation openings and rocky areas: Species with potential habitat within high elevation openings/rocky areas include: Boechera rigidissima var. demota, Erigeron miser, Eriogonum umbellatum var. torreyanum, Lewisia longipetala, Pinus albicaulis, and Tauschia howellii. The Project Area contains potential habitat for Boechera rigidissima var. demota, Erigeron miser, Eriogonum umbellatum var. torreyanum, and Tauschia howellii. The Project is too low in elevation to provide habitat conditions for Lewisia longipetala. Many acres have been surveyed for Pinus albicaulis and it has not been found in the Project Area. In addition, the Project Area does not have red fir/lodgepole, subalpine plant communities. Refer to Table 4 – that shows the types of plant communities within the wildfire perimeter. Table 8 displays the number of occurrences of threatened, and sensitive plant/fungi species known to occur on TNF system lands.

Table 8 – Number of threatened & sensitive plant/fungi occurrences on the TNF by species8

Scientific Name TNF Known Estimated number of plants Occurrences Astragalus lemmonii None 0 Astragalus pulsiferae var. coronensis 1 300 Astragalus webberi None 0 Boechera rigidissima var. demota None 0 Botrychium ascendens 4 83 Botrychium crenulatum 9 470 Botrychium lunaria None 0 Botrychium minganense 1 5 Botrychium montanum None 0 Bruchia bolanderi 6 3700 Cudonia monticola 2 Unknown Cypripedium fasciculatum 8 585 Cypripedium montanum None None Dendrocollybia racemosa 2 Not estimated Erigeron miser 20 7,840 Eriogonum umbellatum var. 11 2,595 torreyanum Fritillaria eastwoodiae 8 1,600 Helodium blandowii None Number of moss plants not estimated Ivesia aperta var. aperta 6 10,280 Ivesia aperta var. canina None None Ivesia sericoleuca 29 73,170 Ivesia webberi None None Juncus luciensis 1 Number of rush plants not estimated Lewisia cantelovii 16 4,775 Lewisia kelloggii subsp. hutchisonii 17 2890 Lewisia kelloggii subsp. kelloggii 2 120 Lewisia longipetala 4 1,000 Lewisia serrata 5 60 Meesia uliginosa 23 3275 Mielichhoferia elongata None Number of moss plants not estimated Monardella follettii None None Packera layneae 1 100 Peltigera gowardii None None Penstemon personatus 2 1,000 Phacelia stebbinsii 20 Varies by year – this is an annual plant Phaeocollybia olivacea 3 Not estimated - most of the fungus is underground. Pinus albicaulis 3 Less than 200 Poa sierrae 6 5,000 Pyrrocoma lucida 13 46,000 Sowerbyella rhenana 1 Not estimated; most of the fungus is underground Tauschia howellii 2 1,000

8 The number of occurrences and number of plants/fungi is constantly changing as new information is obtained. 19

VI. DESCRIPTION OF AFFECTED SENSITIVE SPECIES HABITAT, EFFECTS ANALYSIS AND DETERMINATIONS

Information about each of the sensitive species known or suspected to occur on the TNF is generated within Region 5 and the adjacent Toiyabe NF as part of routine information sharing among agencies, organizations, and individuals dedicated to conservation of rare plants and fungi. New information about each of the sensitive species evaluated in this document is also shared routinely amongst botanists within the FS. In addition, the TNF works cooperatively with the California Department of Fish and Wildlife (CDFW) in development of the Natural Diversity Database, and with the California Native Plant Society (CNPS) to gather information about rare species. The TNF rare plant program document (with updates) and occurrence records provide more information about each of the sensitive species known or suspected to occur on the TNF. The existing/current condition summaries for sensitive species reflect the sum total of the effects of all past actions on those species since it is the current and best information available at this time. A baseline that accurately describes the number of species and population condition for each species before FS management (about 100 years) does not exist. Historic management activities on TNF system lands include: gold mining, gravel mining, hydroelectric development, land clearance, diversions of water for irrigation, land drainage, timber harvest, construction of roads/trails/railroads, urbanization, livestock grazing, ground water abstraction, and others. This long history of disturbance has contributed to the lack of an undisturbed reference for most sensitive species. Therefore, it is not possible to quantify how these past management activities have impacted sensitive species.

Reasonably foreseeable actions: It is reasonably foreseeable that manual treatment of NNIPs that have been treated in the past (before the area burned) will continue in the Analysis and Project Areas. Refer to the TNF NNIP Management Strategy and Action Plan for a list of sites that have had ongoing treatment. It is also reasonably foreseeable that salvage of fire killed trees will occur within the wildfire perimeter – both on NFS (Ford Hazard Tree Removal Project) and privately owned lands. Refer to the Project file for a list of timber harvest plans (THPs) that have been approved (for privately owned lands). Present and ongoing projects on NFS lands include: Hoedad, Ford, Biggie, Little Secret, and personal firewood collection.

Time frames for the analysis: Direct and indirect impacts are analyzed in the short term (about 1 to 5 years or less) and the long term (about 5 to 10 years).

Project Area: The Project Area is defined as the areas where Project operations will be implemented.

Analysis Area: The Analysis Area differs based on the species. For example, if a seed source is not known to occur on the same district as a proposed project, it is unlikely that the species will be found in the potential habitat within the Project, or have the opportunity to become established in the Project/Analysis Area. For range of occurrence, the Analysis Area is the TNF.

Assumptions: A number of assumptions were used in this analysis. They are listed below:

• Nonnative invasive plants (NNIPs) were introduced into the Project Area during wildfire suppression. Wildfire suppression equipment and personnel were staged at the old mill site in Foresthill. This site was/is heavily infested with yellow star thistle (YST), a highly invasive NNIP. Refer to the NNIP Burned Areas Emergency Burn (BAER) report for more information about the risk assessment for the wildfire area due to wildfire suppression activities. • Basiodiomycetes (which includes species in the genera Cudonia, Dendrocollybia, Phaeocollybia and Sowerbyella) are ectomycorrhizal (ECM) and the sensitive fungi – Dendrocollybia racemosa, Phaeocollybia olivacea and Sowerbyella rhenana are also ECM. These fungi have a broad host range including various members of the Pinaceae family (Douglas-fir, white fir, Jeffrey pine, etc.), and require living host trees. • Cudonia monticola, Dendrocollybia racemosa, Cypripedium fasciculatum and C. montanum, Phaeocollybia olivacea, and Sowerbyella rhenana are older forest dependent. Fire killed trees no longer support the mycorrhizal associations needed by these species. • Burned Area Emergency Rehab (BAER) NNIP surveys will aid in the detection of rare plants in the Project Area. • Rare plant surveys will occur during the time period when sensitive species can be identified. This time period varies by plant species and by climatic conditions for any given year. • Effects to rare fungi can be determined via effects to older forest habitat.

The following information provides a summary of what is known about Packera layneae (federally listed as threatened) and TNF sensitive species and provides an analysis of potential effects to each species through implementation of the alternatives.

Effects to Species without potential habitat in the Project Area: (Astragalus lemmonii, Astragalus pulsiferae var. coronensis, Ivesia aperta var. aperta, Ivesia aperta var. canina, Ivesia sericoleuca, Ivesia webberi, Lewisia cantelovii, Lewisia longipetala, Monardella follettii, Packera layneae, Pinus albicaulis, and/or Pyrrocoma lucida):

Astragalus lemmonii (Lemmon’s milk-vetch): This plant is known to occur in Great Basin scrub, meadows, seeps, marshes and swamps (usually found in wetlands but occasionally found in non-wetlands). It is known to occur at elevations between 4,200 and 7,200 feet. It is considered rare, threatened, or endangered in California and elsewhere (CNPS list 1B.2). Astragalus lemmonii is known from the Modoc Plateau, Sierra Nevada East and northern and central Sierra Nevada High Ecoregions in Mono, Lassen, Modoc, Plumas, Shasta, and Sierra Counties, as well as Nevada and Oregon. There are several historic collections from the Loyalton area and Sierra Valley. Most of the Loyalton and Sierra Valley area is privately owned lands that are near the TNF boundary. The trend for this plant is unknown. Threats include land conversion, pipeline construction, livestock grazing/trampling, windmill construction, powerlines construction and maintenance, and road construction/use.

Astragalus pulsiferae var. coronensis (Modoc Plateau milk-vetch): The varieties of Astragalus pulsiferae have been documented as occurring from the Modoc Plateau in Modoc and Lassen Counties, to Plumas County in California, and east to Washoe County, Nevada. The extent of A. p. var. coronensis has been found to be roughly within the same range as the other varieties except that it is found occurring on stiffer substrate (Barneby 1964). A new finding of A. p. var. coronensis extends the known range down to Sierra County just south of Loyalton, CA. The key characteristics that separate Astragalus pulsiferae var. coronensis from the other varieties have been described by Welsh et al. (2002) as having a superficial caudex with the stems foliose to the base with stipules all distinct and pods villosulous with the hairs 1-1.7 mm long. This variety is known to grow in sandy silt, friable at the surface, hard-packed beneath, among basalt cobble and gravel with juniper, sagebrush, bitterbrush and Jeffrey pine at 4,400 to 6,200 feet elevation. The known abundance of Astragalus pulsiferae varieties occurs on the Modoc National Forest (13 occurrences, totaling about 2,000 plants) and the Plumas National Forest (four occurrences totaling an estimated 1700 plants). The size of the most recently found occurrence on the Sierraville Ranger District of the TNF is about 300 plants. Additional occurrences on BLM and private lands bring the total number of known plants to over 15,000. Threats may include NNIP invasion, OHV activity, timber management activities, and road construction/use.

Ivesia aperta var. aperta (Sierra Valley Ivesia): I. aperta var. aperta is known from Plumas, Sierra, and Washoe and Storey Counties in California and Nevada. The majority of occurrences in California are located in the Sierra Valley area. Most of the known occurrences are located on private land. This plant is found at meadow edges, in ephemeral stream channels, in meadow flats, and on gentle, rocky up-slopes near springs. It occurs in sagebrush plant communities at the floor of the eastern Sierra Nevada’s. The hydrology of these habitats is easily changed, and they are prone to rapid erosion. This plant is assigned to the meadow/seep, vernally wet, and riparian woodland guilds. It appears to be in decline across its range. Reproduction does not appear to be occurring at levels that would maintain viability. Occurrences on private lands are threatened by habitat conversion, etc. The Tahoe, Plumas, and Humboldt-Toiyabe NFs have a conservation

strategy in place for management of this plant. The most commonly recommended management prescription calls for protection from direct and indirect impacts. Six occurrences have been reported to occur on the Tahoe NF, totaling less than about 10,000 plants.

Ivesia aperta var. canina (Dog Valley Ivesia): I. aperta var. canina is known only from the Dog Valley area, Humboldt-Toiyabe National Forest, in Sierra County. This location is about 2 miles from the eastern boundary of the TNF. The habitat for this plant appears to be similar to Sierra Valley Ivesia. The Humboldt-Toiyabe NF is currently in the process of developing a conservation agreement with the USFWS. This conservation agreement will outline management plans for keeping this plant from being listed as threatened or endangered. Some of the Sierra Valley Ivesia occurrences that are located on the PNF and the TNF may be Dog Valley Ivesia. This plant is assigned to the vernally wet guild. The trend appears to be down based on the need for a conservation agreement.

Ivesia sericoleuca (Plumas Ivesia): This plant is found in the vernally wet parts of meadows and alkali flats, and in vernal pools. These habitats are not widespread and are sensitive to changes in hydrology and to erosion. Ivesia sericoleuca is known to occur on NFS and private lands in Plumas, Placer, Sierra, and Nevada Counties. It is assigned to the meadow/seep and vernally wet guilds. This plant has a downward trend across its range due to lack of reproduction, and levels of disturbance that are occurring at known sites. The Tahoe, Plumas, and Humboldt- Toiyabe NFs have a conservation strategy in place for management of this plant. The most commonly recommended management prescription calls for protection from direct and indirect impacts for most vegetation management projects. Twenty-nine occurrences of this species have been reported as occurring on the Tahoe NF with numbers totaling to an estimated 73,170 plants.

Ivesia webberi (Webber's Ivesia): Ivesia webberi was listed as a candidate for federal listing by USFWS February 21, 1990. Another motion was made by the USFWS to propose the listing of Ivesia webberi as threatened and to designate critical habitat on August 2, 2013. Ivesia webberi is a low, spreading, perennial herb and is restricted to shallow, clay type soils derived from andesitic rock on mid-elevation flats, benches or terraces above moderately large valleys (Witham 2000). It has been found on open summits and ridge-tops, and in meadow areas on drier, raised hummocks. Its habitat is comprised of sparse to moderately dense vegetation usually dominated or co-dominated by Ivesia webberi and low sagebrush or squirreltail grass in association with a wide variety of dwarfed, or cushion-like perennial herbs. It is known from 15 occurrences clustered in seven general locations in Lassen, Plumas, and Sierra Counties, California, and in Douglas and Washoe Counties, Nevada.

Threats to these Ivesia species include: livestock grazing/trampling, road construction/maintenance, off-road vehicle activities/other dispersed recreation, mining, fire suppression activities (fire camps), prescribed fire, timber harvest, reservoir proposals, fuelwood gathering, target shooting, military practice camps, land exchange, wildlife introduction (turkeys), displacement by NNIPs, and any activity that changes the hydrology and/or increases erosion. Occurrences on private lands are also threatened by habitat conversion.

Lewisia cantelovii (wet-cliff Lewisia): This plant is known to grow on wet metamorphic and granitic rock cliffs and outcroppings in the Feather and Yuba River drainage systems in Plumas, Sierra, and Nevada Counties; and in Shasta County along the Sacramento River above Shasta Reservoir (Skinner and Pavlik 1994). This plant is typically associated with moss or club moss growing on rock formations within these river canyons. It is assigned to the riparian woodland and forest guilds. The trend for this plant appears to be stable overall with some occurrences showing declines due to poaching and/or herbivory by wildlife. Threats to this plant from management activities include construction and use of trails, mining, reservoir/hydroelectric development, prescribed fire, road maintenance, rock sources, plant collecting, and dispersed camping. Many of the 16 occurrences located on the TNF are in areas that are popular river recreation sites. The Eldorado, Plumas, Shasta Trinity, and Tahoe NFs completed a conservation strategy for this plant in 1997. The most commonly recommended management prescription calls for protection from direct and indirect impacts.

Lewisia longipetala (long-petaled Lewisia): This plant is endemic to the LTBMU, ENF, and TNF. It is known to occur in a narrow band of subalpine plant communities at the Sierra Nevada crest, west of Truckee and south to Desolation Wilderness in El Dorado, Fresno, Nevada, and Placer Counties (Halford 1992). The TNF occurrences are located at Basin Peak (northern extent) and two located above Pole Creek (southern extent). The habitat for this plant is the leeward (north to northeast) facing slopes or basins of the ridge-tops with high snow accumulations. Plants are most often found growing within gravelly snowmelt rivulets directly below snowbanks that persist late into the season. This plant is not assigned to a guild. The trend appears to be stable. Threats include ski area development; vegetation management; livestock grazing; trail development and use; and plant collection. Surveys thus far have identified four occurrences of Lewisia longipetala on the Tahoe NF totaling less than an estimated 1,000 plants.

Monardella follettii (Follett’s Monardella): The known distribution of this plant is from the Northern Sierra Nevada in Plumas and Nevada Counties (Skinner and Pavlik 1994). There are 6 known occurrences at this time, 4 located on NFS lands on the PNF, one occurrence located on private lands west of the TNF, and one on the LNF. This plant is known to grow on serpentine soils that are open and partially under a canopy in mixed-conifer forest. It is assigned to the Ultra-mafic outcrop (serpentine plant communities) guild. The trend is unknown. Threats include timber harvest and associated activities such as landing placement; road construction and maintenance; and fire suppression. Development is the major threat on private properties.

Packera layneae (Layne’s Butterweed): This USFWS-listed, threatened plant is found in serpentine or gabbro soils derived from ultra-mafic parent material specifically soil map units DUE, DUF, ISE, ISE5, ISF, RDE and RDG). Layne’s butterweed is known from several localities within the foothills of El Dorado, Tuolumne, and Yuba Counties and was recently discovered in Placer County just west of Sage Hill. The occurrence of Layne’s butterweed near Sage Hill covers about 12 acres on gabbro soil (DUE soil type only) at about 3,600 feet elevation, and includes about 100 plants in widely scattered clumps (Van Zuuk 2010). The American River Ranger District of the TNF is located outside the preserve system identified by the USFWS for this species in the Recovery Plan for Gabbro Soil Plants of the Central Sierra Nevada Foothills. Critical habitat has not been designated for this species.

Habitat requirements for this species and effects of vegetation management practices to its habitat are not fully known. This early seral species occurs in temporary openings in chaparral plant communities on gabbro/serpentine soils and “is eliminated as vegetation grows up around it” (Tarp 2002). Based on the associated plant community and management history of the local population of this species near Sage Hill, Layne’s butterweed appears adapted somewhat (this is unproven) to processes such as wildland fire that results in early seral vegetation.

Pinus albicaulis (Whitebark pine): Whitebark pine is usually found at high-elevations in western North America. About 44 percent of the species’ range occurs in the United States in Wyoming, Montana, Idaho, Nevada, California, Oregon and Washington. The rest of the species range occurs in British Columbia and Alberta, Canada. This is a slow growing, long-lived tree, with a life span of 500 or more years. Threats include habitat loss, mortality from white pine blister rust/mountain pine beetle, catastrophic fire, fire suppression, and environmental effects resulting from climate change. Whitebark pine is experiencing an overall long-term pattern of decline, even in areas originally thought to be mostly immune from the above listed threats (USFWS 2011). Millar et al. (2012) found that whitebark pine blister rust infection was unlikely to have been an important stress correlate in Californian whitebark pine to date. On a landscape scale the species appears to be in danger of extinction within 120 to 180 years (USFWS 2011). The Millar et al. paper (2012) suggested that the difference in growth between surviving whitebark pine trees and whitebark pine trees that died could indicate that stands have an adaptive genetic difference.

Pyrrocoma lucida (Sticky Pyrrocoma): This plant is found in meadows and alkali flats in Plumas, Sierra, and Yuba Counties. Occurrences are found on PNF and TNF and private lands. It is assigned to the meadow and seep, vernally wet, and riparian woodland guilds. The trend for this plant is that it appears to be in decline due to lack of reproduction. Sticky Pyrrocoma grows in habitats similar to Ivesia sericoleuca. These habitats have been reduced in number by a variety of activities. Most of the known occurrences are either unprotected on private land, are repeatedly grazed on NFS lands, and/or impacted by road management agencies during maintenance activities within road right-of-ways. Threats from management activities include livestock grazing, reservoir development, meadow restoration, off-road vehicle use, recreation activities, fire suppression camps, military camps, prescribed burning and other fuel treatments, timber harvest associated activities such as landings, fuelwood gathering, and land exchange.

The Project Area does not contain potential habitat for these plants because the Project is located on the westside of the forest (Astragalus lemmonii, Astragalus pulsiferae var. coronensis, Ivesia aperta var. aperta, Ivesia aperta var. canina, Ivesia sericoleuca, Ivesia webberi, and Pyrrocoma lucida), the Project elevation is too low (Lewisia longipetala), the Project Area does not contain serpentine soils (Monardella follettii and Packera layneae), white bark pine (Pinus albicaulis) does not occur on the ARRD at Project elevations, and/or the plant is only found in the Yuba River drainage system (Lewisia cantelovii). Therefore, implementation of either of the alternatives will not impact them and no further analysis is needed.

DETERMINATIONS: It is my determination that implementation of Alternatives 1 or 2 will not affect Astragalus lemmonii, Astragalus pulsiferae var. coronensis, Ivesia aperta var. aperta, Ivesia aperta var. canina, Ivesia sericoleuca, Ivesia webberi, Lewisia cantelovii, Lewisia longipetala, Monardella follettii, Pinus albicaulis, and/or Pyrrocoma lucida individuals and/or their habitats and is not likely to result in a trend toward Federal listing or loss of viability for these species within the planning area of the TNF. The Project Area does not provide potential habitat for them.

It is my determination that implementation of this Project will have no effect on Packera layneae or its designated critical habitat since the Project Area does not contain potential habitat for it (gabbro/serpentinite soils). The no effect determination includes an analysis of effects of other activities that could be interrelated9 or interdependent10 of the Project. There are no interrelated or interdependent actions.

Effects to Species with potential habitat in the Project Area: The Project Area has potential habitat for all of the following sensitive species: Astragalus webberi, Boechera rigidissima var. demota, Botrychium ascendens, Botrychium crenulatum, Botrychium lunaria, Botrychium minganense, Botrychium montanum, Bruchia bolanderi, Cudonia monticola, Cypripedium fasciculatum, Cypripedium montanum, Dendrocollybia racemosa, Erigeron miser, Eriogonum umbellatum var. torreyanum, Fritillaria eastwoodiae, Helodium blandowii, Juncus luciensis, Lewisia cantelovii, Lewisia kelloggii subsp. hutchisonii, Lewisia kelloggii subsp. kelloggii, Lewisia serrata, Meesia uliginosa, Peltigera gowardii, Penstemon personatus, Phacelia stebbinsii, Phaeocollybia olivacea, Poa sierrae, Sowerbyella rhenana, and Tauschia howellii. The following section provides information about the plant species followed by discussion of possible effects from implementation of the No Action and Action Alternatives. This is followed by a section that provides information about the rare fungi and a discussion of possible effects from alternative implementation.

Astragalus webberi (Webber's milk-vetch): This plant is a geographically restricted legume species that is known to occur in Plumas County. It has not been found in the TNF even though it was historically recorded as occurring in Sierra County in the Sierra Valley area. The Sierra Valley occurrence has not been relocated since it was first recorded by Lemmon and associates. It is possible that the historic collections by Lemmon and associates were collected in the Indian Valley area and not the Sierra Valley area (Barnaby 1964, Ikeda and Witzman 1989). The Plumas NF (PNF) reports that this species is not habitat specific. It grows in the general openings guild. It is one of the few members of the genus that is native to the west slope of the northern Sierra Nevada. Most of the known occurrences are along highways on cutbanks or just within the forest edge. This plant is declining in trend. Threats from management activities include road maintenance and construction, trash dumping, vehicle parking, reforestation, livestock grazing/trampling, and timber harvest. Fire information is incomplete for this plant. It is a perennial plant that is known to grow at fairly low elevations (4,100 feet and below) in dry openings, so it is likely that it would have been dormant at the time of the wildfire. Therefore it may have survived the wildfire.

9 Interrelated actions are those that are part of a larger action and depend on the larger action for their justification. 10 Interdependent actions are those that have no independent utility apart from the Project. 26

Boechera rigidissima var. demota (Carson Range rock cress): Most of the known occurrences of this plant are located within the state of Nevada on the Carson Range. Most occurrences are found on private lands and are not protected. There are only two occurrences known in California with no known occurrences on TNF system lands. The California occurrences are located near Martis Peak in Placer and Nevada Counties. This plant is considered a geographically restricted regional endemic that is only found from the Carson Range of the Sierra Nevada. It is known to grow in sandy and rocky soils or outcrops derived from granitic or volcanic materials mostly on moderate to steep northerly aspects, often in drainages/meadow edges/dry openings. The elevational range of known occurrences is between 7,500 and 8,500 feet. These habitats are generally considered subalpine habitats. Subalpine habitats are limited in distribution and are fragile, i.e. they have a short growing season and not much resilience to disturbance. The trend for this plant is unknown. Threats to this plant from management activities include development (urban/ski area/facilities); timber harvest; roads; recreation trail construction, maintenance, and use; off-road vehicle use; livestock grazing, firefighting/suppression activities; prescribed burning; and any activities that degrade air quality, cause erosion, or aid in illegal plant collection. Fire information about this species is incomplete. However, if it occurred within the Project/Analysis Areas before the wildfire, it is likely that it would have survived at least in seed form. Mustard species plants have very small seeds and it is likely that at least some seeds would have fallen into soil and rock crevices that did not heat to lethal temperatures.

Botrychium ascendens (Triangle-lobe moonwort): This moonwort is known to occur in Canada, Alaska, Nevada, California, and the Pacific Northwest. In California, it is known from Butte, El Dorado, Mono, Placer, Plumas, Nevada, Shasta and Tehama Counties. TNF occurrences are located in the Sagehen Creek area and in Duncan Peak Roadless area (Laeger 2002).

Botrychium crenulatum (Scalloped moonwort): This moonwort has the widest distribution of all the moonworts in the state of California, but is not common anywhere. It is limited to the western United States, scattered from California to Montana. In California, it is known to occur in Butte, Colusa, Los Angeles, Nevada, Modoc, Mono, Placer, Plumas, Tehama, Tulare, San Bernardino, Shasta and Sierra Counties. This moonwort is not known to occur on the TNF. Nine occurrences have been reported as occurring in numbers totaling to less than 500 plants.

Botrychium lunaria (Common moonwort): This moonwort is known to occur from Alaska to California, and in Arizona and the Great Lakes region. In California, it is known from Modoc, Mono, and Nevada Counties. It grows with many other species of Botrychium and occasionally hybridizes with them.

Botrychium minganense (Mingan moonwort): This moonwort is known to occur from Alaska throughout boreal Canada, southward into all of the western mountain states to Arizona, and eastward along the northern states to the Atlantic Canadian Provinces and New England. In California, it is known from Butte, Fresno, Modoc, Nevada, Plumas, Shasta and Tehama Counties. Only one occurrence has been reported on the Tahoe NF totaling to about five individuals.

Botrychium montanum (Mountain moonwort): This moonwort is known to occur from British Columbia, California, Montana, Oregon, and Washington. In California, it is known from Butte, Modoc, Nevada, Plumas, Shasta and Tehama Counties. It is known to occur on the TNF.

All of these Botrychium species are found under riparian shrubs/vegetation or near it. Trend is unknown and hard to determine because sporophytes do not appear above ground each year. Known occurrences of these Botrychium species are small (few individuals per occurrence) and the numbers of plants known to occur in California is low. Moderate to heavy soil disturbance is detrimental. A small amount of disturbance may be tolerated; but heavy disturbance will kill individuals. Threats include grazing/trampling by livestock and vehicle activity. Hot fires have been shown to be detrimental, especially if the soil conditions are very dry during the burn. Changes in hydrologic regime (from erosion, roads, grazing, etc.) are also considered threats. Surveys of potential habitats cannot guarantee that these Botrychium species are absent since the sporophyte does not appear above ground every year.

The Fire Effects Information System does not contain information about the effects of fire on Botrychium species. The Wildfire was considered a hot fire and soil conditions were very dry at the time of the wildfire. If Botrychium species existed in the potential habitat within the Project Area, they would have been toward the beginning of their reproductive cycle. This is based on observations of a related species, Sceptridium multifidum, observed in Little Secret meadow/peatland/fen on 10/17/13. Refer to Figure 3. Much of the potential habitat for Botrychium species (i.e. wetland/riparian vegetation associated with perennial water) burned in the wildfire. Fire can negatively affect populations of Botrychium if the burn is excessively hot and followed by dry years (Laeger 2002). Less intense fires may benefit Botrychium populations by reducing competition with other vegetation (Laeger 2002). If Botrychium species exist in the Project Area, it is possible that felling and/or removing burned conifers from the riparian buffer area could impact them.

Figure 3 - Sceptridium multifidum in Secret Meadow 10/17/13

It is expected (but unproven) that the portions of the Project Area that burned the hottest no longer have Botrychium species. The above ground portion of Botrychium species (if they existed in the Project Area and they put up sporophytes in 2013) would have burned and the plants would have been killed because hot fires when the soils are dry are likely to kill Botrychium plants. Units 9, 17-20, 40, 41, 65, 82, 94, and 110 have riparian buffers for perennial streams. Over 70% of units 17, 18, 20, 40, 41, 65, 94, and 110 burned with high/moderately high severity. Refer to Table 10.

Bruchia bolanderi (Bolander’s candle moss): This moss is endemic to California and Oregon (Christy and Wagner 1996). California populations are known from Fresno, Tehama, Madera, Mariposa, Nevada, Tuolumne, Tehama and Plumas counties (UC Berkeley Herbarium specimens, CNPS 2001). The California Native Plant Society (CNPS) considers this moss fairly endangered in California and rare outside of California (CNPS 2001). Bruchia bolanderi grows on moist soil, often along exposed edges of streams through meadows or in exposed and disturbed soils or under grasses; sometimes partially shaded by coniferous forests. It grows from about 4,000 to above 9,000 feet. The abundant production of spores provides ample dispersal opportunities. The species is opportunistic, taking advantage of disturbed sites and minimal competition from other vegetation (Christy and Wagner 1996). However, sporophytes are infrequently encountered in many California populations. The species is difficult to identify without a sporophyte. Trend is not determined. No population monitoring has occurred. This plant has been found on the TNF in six sites including, Castle Valley, Round Valley, and upper Lola Montez areas. Potential threats include direct impacts from management activities that directly damage the plants. How this moss responds to being burned is unknown. However, it is likely that if it exists within the Project/Analysis Areas, at least some of the moss plants would have been burned since on-the-ground observations by the author showed that other moss species had burned during the Wildfire.

Cypripedium fasciculatum (Clustered Lady's Slipper Orchid): This plant is known to occur in Butte, Del Norte, Humboldt, Nevada, Plumas, Santa Clara, Santa Cruz, Shasta, Sierra, Siskiyou, San Mateo, Tehama, Trinity, and Yuba Counties, and in the states of Colorado, Idaho, Montana, Oregon, Utah, Washington, and Wyoming. There are many occurrences, but most contain only a few plants. It is considered threatened in the States of Idaho and Washington and is a candidate for State listing in Oregon. This orchid is known to occur on the Mendocino, Six Rivers, Shasta- Trinity, Klamath, Lassen, Plumas, and Tahoe NFs. It is most often found on north facing slopes in mixed-conifer forests with canopy closure greater than 60 percent (Kaye and Cramer 2005). It is found at elevations that range from 600 to 5,800 feet. It is placed in the interior forest and gap phase guilds. Formal studies of the response of Cypripedium species to disturbance are limited. However, it has been noted that when the vegetative stems of this plant are damaged, the plant showed reduced vigor the following year (Phelps 1996). A mycorrhizal symbiont(s) that is only found in mid-to-late successional forest communities may be necessary for Cypripedium species viability (Seevers and Lang, 1998). This species may be limited by the distribution of its’ fungal partners (Shefferson et al. 2005). More than ½ of the populations of this species have fewer than 10 plants, which places the species at high risk. Population declines and losses of this species have been significant over the last two decades and population extinction has occurred at a high rate (44 to 55 percent) for small populations (Kaye and Cramer 2005). Trend appears to be down based on what is known about the complicated life history, which includes mycorrhizal

relationships, limited establishment factors, apparent intolerance to intense disturbance, and location (lands available to timber harvest). This orchid is sensitive to disturbances that damage their current year’s growth, rhizomes, soil surrounding their root systems, and forest canopy (too much light appears to negatively affect them. A conservation assessment was completed in 2005 to determine the conservation status of clustered lady’s slipper (Cypripedium fasciculatum) and Mountain lady’s slipper (C. montanum) in Region 5, California. Threats from management activities include nonnative invasive plant infestation, timber harvest activities, livestock grazing/trampling, catastrophic fire, fire suppression and fuels reduction activities including prescribed burning, off-road vehicle use, trail construction/use, illegal plant collection, mining, development, and any activity that would increase erosion.

Cypripedium montanum (Mountain lady-slipper orchid): The range of distribution for mountain lady slipper orchid includes many counties throughout California from Del Norte to Sierra County. It also occurs in 6 other western states. Its’ greatest abundance is in California is on the Klamath NF, but it is widely distributed throughout the National Forests of the Sierra Nevada except for the TNF (Kaye and Cramer 2005). The habitat for this plant is broad ranging from moist-conifer forests (Douglas-fir, white fir, mixed conifer) in partial shade (canopy closure is generally between 60 and 80 percent) to dry wooded slopes. It is most often found on north facing slopes in mixed conifer forests with canopy closure greater than 60 percent (Kaye and Cramer 2005). It is also known to occur in oak woodlands and riparian areas (along streams under or near dogwood). It is placed in the interior forest, riparian forest, and gap phase guilds. Cypripedium montanum grows at elevations ranging from 1,300-6,350 feet, with the majority of sites occurring between 2,500-4,000 feet. Aspect is primarily northerly, on slopes of 25 to 50 percent. More than ½ of the populations of this species have fewer than 10 plants, which places the species at high risk. Population declines and losses of this species have been significant over the last two decades and population extinction has occurred at a high rate (44 to 55 percent) for small populations (Kaye and Cramer 2005). Trend appears to be down based on what is known about the complicated life history, which includes mycorrhizal relationships, limited establishment factors, apparent intolerance to intense disturbance, and location (lands available to timber harvest). This orchid is sensitive to disturbances that damage their current year’s growth, rhizomes, soil surrounding their root systems, and forest canopy (too much light appears to negatively affect them. A conservation assessment was completed in 2005 to determine the conservation status of clustered lady’s slipper (Cypripedium fasciculatum) and Mountain lady’s slipper (C. montanum) in Region 5, California.

A small portion of the Project Area was surveyed in 2012 (Little Secret Project) and no Cypripedium species were found in the surveyed areas. The American Wildfire reduced the suitability of other areas that burned intensively since those areas are now considered unsuitable for these plants (they are sensitive to disturbances that damage their current year’s growth, rhizomes, soil surrounding their root systems, and forest canopy - too much light appears to negatively affect them). If they occurred in the Project Area before the American Wildfire, it is expected that those in areas that burned intensively were killed by the Wildfire (this is unproven). However, Cypripedium fasciculatum and/or Cypripedium montanum could have survived the Wildfire in areas of older forest that burned less intensively.

Erigeron miser (Starved daisy): This plant is known to occur in Nevada and Placer Counties. It is a localized endemic of rocky habitats. It grows in the clefts between granite outcrops at high elevations on the TNF. It is placed in the general outcrop guild. Most of the known occurrences appear to be stable. The habitats for this plant are limited and fragile, i.e. short growing season and not much resilience to disturbance. Currently all known occurrences are located in the Sierra Nevada Crest zone. The type locality is in the vicinity of Donner Summit. Threats to this plant include rock climbers, nonnative invasive plants, roads, off-road vehicles, plant collectors, rock collectors, and hydro/gas/transmission lines. Surveys thus far have identified 20 occurrences of Erigeron miser on the Tahoe NF totaling less than an estimated 8,000 plants. Fire information about this species is incomplete. However, if it occurred within the Project/Analysis Areas before the wildfire, it is likely that it would have survived. It grows in areas that have very little material to burn, i.e. the clefts of granite boulders.

Eriogonum umbellatum var. torreyanum (Donner Pass buckwheat): This plant is a perennial sub-shrub forming large prostrate mats with glabrous leaves. The current distribution of this buckwheat is a thin band along the eastern side of the Sierra Crest from Webber Mountain in the north to Silver Peak, just north of Squaw Valley in the south. Most plants occur in Placer and Nevada Counties, with 2 occurrences in Sierra County. The species is known from highly erosive volcanic soils (meiss) with sparse vegetation at 6,000 – 8,200 feet elevation in open subalpine habitats on shallow soil typically on steep east-facing slopes (Kan 1993). It occurs on the TNF where approximately 1,000 individual plants are scattered through 11 occurrences. Initial evaluation of trend indicates a lack of stability, i.e. decline. Threats include mining, ski area development, livestock grazing and trampling (sheep), timber harvest and related activities, and other development. Fire information about this species is incomplete. However, if it occurred within the Project/Analysis Areas before the wildfire, it is likely that it would have survived. It grows in areas that have very little material to burn.

Fritillaria eastwoodiae (Butte fritillary): The known range of this plant has historically been Shasta, Butte, Tehama, and Yuba Counties in five distinct stable population centers. It is found on unprotected private land and NFS lands mostly on the PNF. The majority of occurrences are known from locations that have not been disturbed. A small number of plants are known from areas that are expected to have experienced a light disturbance. This plant is known to grow in chaparral, mixed conifer, and ponderosa pine in open stands of timber on a variety of soils. Many of the flowers of the known F. eastwoodiae plants have only anthers present, thus seed production is not occurring in these plants. It is assigned to the gap phase guild. The trend for this plant is unknown. Threats include timber harvest, livestock grazing, off-road vehicle use, fire suppression, prescribed fire, and road construction. Fire information about this species is incomplete. However, if it occurred within the Project/Analysis Areas before the wildfire, it is likely that it would have survived. It would have been dormant at the time of the wildfire. Most of the plant is located underground in a bulb-like structure below depths of intensive soil heating.

Helodium blandowii (Blandow’s bog-moss): Helodium blandowii is known from Europe, Asia and across northern United States from New Jersey and Ohio west to California and Nevada, and northwards to Canada (Flowers 1973). In California, it is known from Kings Canyon National Park in Fresno County and from the Inyo and Klamath NFs. It is also known from the Mount Rose area on the Nevada side of Lake Tahoe, i.e. at Tahoe Meadows on the Toiyabe side of the LTBMU. It grows in wet meadows/seeps in subalpine coniferous forest and alpine lakes 31

(Flowers 1973). Trend is unknown. The two most critical factors affecting the abundance and distribution of species such as Helodium blandowii are hydrology and the nutrient concentration of incoming water. Threats include road/trail construction/maintenance/use. Fire information about this species is incomplete. However, if it occurred within the Project/Analysis Areas before the wildfire, it is likely that it would have survived. If fire occurred in its wetland habitat it is likely that it did not ‘cook’ seed and roots of plant species.

Juncus luciensis (Santa Lucia Dwarf Rush): This rush is known to occur in wet, sandy soils associated with seeps/meadows/vernal pools/streams/along roads (Sanger et al. 2012). Juncus luciensis is endemic to California, reported in the northeastern and southwestern parts of the state at elevations between 925 and 6,235 feet, in Lassen, Modoc, Monterey, Napa, Nevada, Placer (?), Plumas, Riverside, San Benito, San Diego, San Luis Obispo, San Benito, and Santa Barbara counties. There are currently 26 known occurrences of Juncus luciensis (CNDDB 2012). Of these, six are on the Plumas National Forest, two on the TNF, one on the Lassen National Forest, and four are expected to be on the Los Padres National Forest. Five occurrences are on lands owned by public or nonprofit entities other than the FS, and the remaining five are of uncertain ownership or privately owned. More than half of these occurrences were last reported more than twenty years ago. For most of them, information about location, associated species, and population size is limited at best, though a few of them report that J. luciensis was abundant at the site. However, this is an annual species, so numbers of occurrences and plants within the occurrence should be expected to vary from year-to-year. Threats to known occurrences are unknown. Since this plant is a wetland annual, it may be particularly vulnerable to disruptions in area hydrology and to disturbance during the growing season. Fire information about this species is incomplete. However, if it occurred within the Project/Analysis Areas before the wildfire, it is likely that it would have survived. Seeds would have been stored in the wet soils.

Lewisia kelloggii subsp. hutchisonii and subsp. kelloggii (Hutchison’s and Kellogg’s Lewisia): Lewisia kelloggii subsp. hutchisonii is known to occur in Butte, Plumas, Sierra, and Siskiyou Counties in openings above 5,200 feet. Lewisia kelloggii subsp. kelloggii is known from at least 25 locations in Plumas County southward to Madera County at elevations at or above 6,000 feet (Region 5 sensitive plant species evaluation form 12/2005). Lewisia kelloggii is a highly variable species with genetic variation strongly structured by geography (Wilson et al. 2004). It grows in open areas on excessively drained, coarse-textured, granitic and volcanic soils. Lewisia kelloggii populations in California appear to be reproductively isolated (Wilson et al. 2004). Trend is unknown. Threats include road maintenance, off highway vehicle use, and fuel reduction activities. Wilson and Hipkins (2001) recommend conserving the plants in each NF where it occurs due to the great isozyme variation seen in Lewisia kelloggii. Individual populations are highly differentiated. Surveys thus far have identified 17 occurrences of Lewisia kelloggii ssp. hutchisonii and two occurrences of Lewisia kelloggii ssp. kelloggii on the Tahoe NF totaling less than an estimated 3,000 plants.

Information about the effects of fire on Lewisia kelloggii subsp. hutchisonii and Lewisia kelloggii subsp. kelloggii is not available. However, the Fire Effects Information System provides information about the effects of fire on a closely related species, Lewisia rediviva (Howard 1993). Lewisia redivida (bitterroot) is considered a cool-season, low-growing, ephemeral, perennial forb – as are Lewisia kelloggii subsp. hutchisonii and Lewisia kelloggii subsp.

kelloggii. All three species have a short caudex with densely clustered succulent leaves at the caudex crown. In the Fire Effects Information System information, it states that “Fire during periods of active growth presumably top-kills bitterroot. Fires occurring during plant dormancy probably do not harm this geophyte.” The American Wildfire occurred while these plants would have been dormant.

Two known occurrences of Lewisia kelloggii subsp. hutchisonii are located within and adjacent to the American Wildfire. One occurrence was impacted by suppession activities but was not burned. Refer to Figure 4. Some of the Project Area was surveyed in 2012 for these plants and they were not found (Little Secret Project).

Figure 4 - Lewisia kelloggii subsp. hutchisonii occurrence with dozer tracks. Note the flagging around a rock that marks where the plants where within the open rocky area.

The Project Area contains patches of open, coarse-textured soils that may contain Lewisia kelloggii subsp. hutchisonii or Lewisia kelloggii subsp. kelloggii. These potential habitats will be surveyed in 2014 if access is available (sometimes the snow that covers these small open patches melts and the plants complete their life cycle before the roads and trails that provide access are free of snow). Known occurrences of Lewisia kelloggii subsp. hutchisonii that occur within the Analysis Area (but are not within the Project Area) will be monitored to determine the best times to survey for these plants. In 2013, the Lewisia kelloggii subsp. hutchisonii came up and was flowering in late May – about 1 ½ to 2 months before what is considered the ‘normal’ survey time. If occurrences are within the Project Area, it is likely that they were dormant at the time of the wildfire and survived the wildfire.

Lewisia serrata (saw-toothed Lewisia): The habitat for this plant is steep, metasedimentary bedrock outcrops in the American River watershed. Most plants are found in the inner gorges of perennial streams, although a few occurrences are found near seeps and intermittent streams. The factors responsible for the limited distribution of this plant have not been identified. Surveys thus far have identified 5 occurrences of Lewisia serrata on the Tahoe NF totaling less than an estimated 60 plants. This plant is assigned to the riparian woodland and forest guilds. Trend for this plant appears to be stable. Monitoring on the TNF and ENF has shown no declines except for those sites that have experienced poaching (illegal collection of plants). Threats are very similar to those listed under wet-cliff Lewisia. The Eldorado, Plumas, Shasta Trinity, and Tahoe NFs completed a conservation strategy for this plant in 1997. The most commonly recommended management prescription is for protection from direct and indirect impacts. There is a known occurrence of Lewisia serrata within the American Wildfire perimeter. A field visit (9/3/13) determined that some Lewisia serrata plants were scorched but not killed. Refer to Figure 5.

Figure 5 - Lewisia serrata plants within the American Wildfire Perimeter (Arrows point to Lewisia serrata plants.)

Meesia uliginosa (Broad-nerved hump-moss): The range for this moss is disjunct, but it is known to occur from Siskiyou County south to Tulare County. Populations of Meesia uliginosa are reported to be small and infrequently encountered. On the TNF this moss grows in permanently wet, primarily spring fed plant communities called fens. This moss is assigned to fen and meadow and seep guilds. The elevation range is about 4,250 to 6,850 feet. The trend is in decline since several historic sites have not been relocated and/or the habitat has been degraded. The TNF currently has 23 occurrences of Meesia uliginosa. The area covered by this moss is typically very small and the number of individuals per occurrence is impossible to determine. Threats to these Meesia moss species from management activities are any that change the hydrology of habitats; i.e. timber harvest, road construction, construction of fuel breaks, recreation activities, livestock grazing, etc. If this moss was present in the Project/Analysis Areas prior to the wildfire, it is likely that it survived since it grows in permanently wet,

primarily spring fed plant communities (fens). The only known peatland/fen in the Project/Analysis Areas, Little Secret, did not burn in the wildfire. Mielichhoferia elongata (Elongate copper moss): This moss is known from three disjunct areas in the State of California. It is known from Mariposa, Placer, Fresno, Tulare, Siskiyou, Humboldt, Trinity, and Santa Cruz Counties. Of the 41 known occurrences, only 14 are known to occur on NFS lands. This moss grows on metamorphic, sedimentary, limestone, granite, and serpentine rock outcrops that often contain copper or heavy metals and that are seasonally moist or less commonly on moist soil. Occurrences are generally small and isolated. Habitat is usually in foothill woodland areas dominated by oaks or chaparral and sometimes with scattered incense cedar, Douglas-fir, and ponderosa pine. It grows at elevations up to 4,300 feet. Trend is unknown. Threats include: road re-alignment, highway expansion, and mining. If this moss existed in the Project/Analysis Areas before the wildfire, it is likely that it would have survived since it grows on rock – areas that have very little material to burn.

Peltigera gowardii (aquatic jelly macrolichen): Peltigera gowardii is the western equivalent of Peltigera hydrothyria (Lendemer and O’Brien 2011). It is considered a western North America endemic extending from central/northern California northward to Oregon, Washington, and British Columbia with disjunct populations in Idaho and southern Alaska (Lendemer and O’Brien 2011). It grows on rock (usually large rocks and bedrock); in shade; in small, clear, cold streams and springs where it is submerged throughout most of the year (McCune et al. 2006, Glavich 2009 IN: Lendemer and O’Brien 2011). Its’ elevational range is about 1,150 to 7,000 feet. Although it has a broad distribution, its’ distribution is limited to isolated site clusters. It is considered rare throughout its’ Western range (McCune et al. 2006 IN: Lendemer and O’Brien 2011). Trend is unknown. Perennial water sources with little seasonal variation in water levels provide habitat. Threats include any management activity that would kill plants, change the shade component of the habitat, or reduce/damage water quality/clear water. If this macrolichen existed in the Project/Analysis Areas before the wildfire, it is likely that it would have survived since it grows in water.

Penstemon personatus (Closed-throated beardtongue): This plant is known to occur in Butte, Nevada, Plumas, and Sierra counties. There are three known occurrences on or near TNF lands in the YRRD. Two occurrences are known from the LNF. On the PNF, this species is known from two large population centers east and south of Bucks Lake with thousands of plants and five smaller occurrences, the smallest with less than 10 plants on the western half of the PNF. This plant is known to grow in westside mixed conifer and/or red fir plant communities. It is assigned to the gap phase and general opening guilds. The trend appears to be stable. This plant appears to tolerate limited disturbance that does not change the microhabitat. Threats from management activities include road construction and maintenance, timber harvest activities, timber site preparation and release, high intensity burn piles, livestock grazing, mining, and off- road vehicle use. It is expected Penstemon personatus would have survived the American Wildfire (if it occurred there) because it would have been in the process of going dormant at the time of the wildfire because FY 2013 was a very dry year. This would lessen the effects of the wildfire on plant tissues. Plant tissue that is metabolically inactive or dehydrated can withstand more heating than plant tissue that is metabolically active or hydrated (Whelan 1995, IN: DiTomaso and Johnson 2006).

Phacelia stebbinsii (Stebbins Phacelia): This plant is limited in distribution, i.e. the Rubicon and American River drainages. It is currently known to exist only within the greater boundaries of the TNF and ENF, with occurrences located on private and NFS lands. It is known to grow on a wide variety of soils. It is assigned to the gap phase and general outcrop guilds. On the ENF, the trend appears to be stable. On the TNF, the trend is unknown. Threats on the ENF are unlikely except for possible hydroelectric development due to remoteness of habitat. Threats on the TNF include mining; road and trail construction; and recreation activities such as fishing, off- road vehicle use, dispersed camping, hiking, and river access for swimming. There are known occurrences of Phacelia stebbinsii located within unit 104 and along the Western States Trail (WST) in the same general area (section 26). There is also a known occurrence in section 36 below unit 81. Units 104 and 81 are proposed for mechanical salvage harvest and mechanical release after tree planting. Unit 104 is also proposed for mechanical site prep. Information about the effects of fire on Phacelia stebbinsii is lacking. However, Phacelia stebbinsii would have already completed its life cycle by August. Seeds produced by this annual plant are small and may have survived the wildfire. The wildfire may have created conditions that benefit this and other annual plants by reducing competition for soil nutrients, water and sunlight from other vegetation.

Poa sierrae (Sierra bluegrass): This grass grows on shady, moist slopes in mixed conifer forest at elevations from about 1,000 to 5,500 feet. Poa sierrae is a California endemic. It is considered rare, threatened, or endangered in California and elsewhere (CNPS list 1B.3). It is known to occur in Butte, Madera, Nevada, Placer, Plumas, and Shasta counties. This grass was discovered on NFS lands on the ARRD in 2013 in areas adjacent to the wildfire. Refer to Table 9.

Table 9 – Information about TNF Poa sierrae Occurrences as of 7/17/13

Quadrangle Section Elevation Number of stems Area Occupied (feet) (Stems are connected underground) Michigan Bluff 16 4,145 1,000s Scattered in 1-2 acres Greek Store 23 4,074 1,000+ Scattered in about 1 acre Greek Store 24 4,819 1,000+ Scattered in about 3 acres Greek Store 15 4,480 100+ 50 by 50 foot area Greek Store 24 4,631 1,000s 150 by 50 foot area Greek Store 20 5,358 6 3.3 by 3.3 foot area

Information about the effects of fire on Poa sierrae is lacking. However, the Fire Effects Information System provides information about the effects of fire on a related species, Poa secunda (Howard 1997). This information is discussed to try to determine whether Poa sierrae could still exist in the Project Area even though the Project Area burned.

Poa secunda (Sandberg bluegrass) is a shallow-rooted, cool-season perennial bunchgrass. Poa sierrae is also a shallow-rooted, cool-season perennial grass. In the Fire Effects Information System information, it states that: “Sandberg bluegrass is generally unharmed by fire. It produces little litter, and its small bunch size and sparse litter reduces the amount of heat transferred to perennating buds in the soil.” (Howard 1997). Poa sierrae would have been dormant when the American Wildfire occurred. As stated above, the response of Poa sierrae to wildfire is also unknown. Based on field observations of 2013 discovered occurrences of Poa

sierrae, the amount of litter and duff associated with occurrences is higher than what is described for Poa secunda and perennating buds in the soil could have been killed. However, at least some of the known Poa sierrae occurrences are located in areas where the trees have fire scars (showing evidence that the area where the occurrence is located burned at some point).

Tauschia howellii (Howell’s Tauschia): This plant is found in subalpine coniferous forest and upper montane coniferous forest. It is known in California from only five occurrences. It is known to occur on the TNF in the Keystone Gap area. Trend is unknown, but it is a candidate for state listing in Oregon. Threats include recreational activities on steep, erosive slopes. Information about the effects of fire on Tauschia howellii is lacking. However, it is unlikely that Tauschia howellii plants would have been affected by the wildfire (if they occur in the Project/Analysis area) because they grow in habitats that have very little material to burn. The only known occurrence on the TNF is growing in a very steep, rocky/shale type of area.

ALL SPECIES LISTED ABOVE: Potential habitat will be surveyed prior to Project operations. Discovered rare plant occurrences (surveys for rare fungi are not done) will be buffered from disturbance by 50 feet or by a buffer distance that is developed on-the-ground for that specific occurrence. However, if hazard trees are located near where they are growing, and the hazard tree can only be felled into the rare plant occurrence, plants will be impacted. Therefore, the following analysis of possible effects focuses on the falling of a hazard tree into a rare plant occurrence. Since surveys were not done before the area burned, the analysis of effects assumes presence.

NO ACTION ALTERNATIVE (2): Implementation of Alternative 2 will not impact sensitive plant species because no Project operations will be implemented.

DETERMINATION: It is my determination that implementation of Alternative 2 will not affect Astragalus webberi, Boechera rigidissima var. demota, Botrychium ascendens, Botrychium crenulatum, Botrychium lunaria, Botrychium minganense, Botrychium montanum, Bruchia bolanderi, Cudonia monticola, Cypripedium fasciculatum, Cypripedium montanum, Dendrocollybia racemosa, Erigeron miser, Eriogonum umbellatum var. torreyanum, Fritillaria eastwoodiae, Helodium blandowii, Juncus luciensis, Lewisia kelloggii subsp. hutchisonii, Lewisia kelloggii subsp. kelloggii, Lewisia serrata, Meesia uliginosa, Mielichhoferia elongata, Peltigera gowardii, Penstemon personatus, Phacelia stebbinsii, Phaeocollybia olivacea, Poa sierrae, Sowerbyella rhenana, and Tauschia howellii individuals and/or their habitats and is not likely to result in a trend toward Federal listing or loss of viability for these species within the planning area of the TNF. No ground disturbing management activities will be implemented.

ACTION ALTERNATIVE (1): Implementation of Alternative 1 could affect sensitive plant species directly, indirectly, and cumulatively. It is not always possible to fall a hazard tree away from a rare plant occurrence due to the direction the tree is leaning and other considerations.

Direct: Falling hazard trees on top of rare plants will kill and/or injure those located directly under the bole of the hazard tree. Dragging the hazard tree out of the occurrence could also injure plants. If the hazard tree is left in place (required when hazard trees must be felled into peatlands/fens and/or when they cannot be fully suspended when they fall across streams); the rare plants located under the bole of the hazard tree will be killed. However, most of the plants

with potential habitat in the Project Area are perennial and have most of the plant underground. Therefore direct impacts to perennial species from dragging the hazard tree out of the occurrence are expected to injure (versus) kill individual plants.

Indirect: There is a small risk that felling and removing hazard trees will create small, site- specific changes in soil and water conditions within and/or adjacent to rare plant occurrences. Changes to the hydrology/microhabitat/soil erosion could kill and/or injure individual plants. However, implementation of soil and water best management practices are expected to insure hydrologic function and soil health are maintained. In addition, leaving the portion of the hazard tree that cannot be fully suspended when it falls across a stream also reduces the possibility of indirect impacts to the hydrology. Leaving the hazard tree when it must be felled into a peatland/fen reduces the risk of changed hydrology within those plant communities and provides a source of organic matter for those plant communities

Cumulative: These direct and indirect impacts add to the cumulative effects that plant communities have experienced on the Tahoe National Forest (TNF) from timber harvest, mining, grazing etc. However, the safety hazard that these trees (hazard trees) present must be mitigated. Felling hazard trees so that they fall away from wetland/riparian vegetation and rare species occurrences whenever possible reduces the risk of cumulative impacts from Project operations. Leaving a felled hazard tree within peatlands/fens also reduces the risk of cumulative impacts to plants dependent on peatlands/fens.

Historically, the amounts of wetland/riparian vegetation/plant community and older forest plant communities have been dramatically reduced across the country and to a lesser degree within the Project Area (through timber harvest, mining, water diversion, etc.). This is also true for the health of some of those plant communities, especially the wetland/riparian plant communities remaining within the Project Area. Implementation of Alternative 1 adds to the cumulative impacts that plant communities (and those plants dependent on them) – especially wetland/riparian plant communities - have experienced in the last century within the Project Area. Whenever possible, hazard trees will be felled away from rare plant occurrences and wetland/riparian plant communities to reduce the severity of possible impacts. In addition, impacts to riparian vegetation associated with perennial water are reduced since there is a 100 foot riparian buffer around perennial water sources that excludes equipment.

Rare plant habitats are also cumulatively affected when NNIPs are introduced and become well established. The Project Area has a high NNIP risk due to suppression activities. Project operations add to this risk by creating soil disturbances especially adjacent to roads where there are known NNIP infestations and where there is a high likelihood of NNIP introduction. Further disturbing the soil increases the risk that NNIP can become established more easily (without competition from sprouting or germinating native plants). Refer to the NNIP Risk Assessment Report for more information.

It is expected that very few instances will occur where hazard trees must be felled into rare plant occurrences (if any). Therefore, cumulative impacts are not considered significant.

DETERMINATION: It is my determination that implementation of Alternative 1 may affect Astragalus webberi, Boechera rigidissima var. demota, Botrychium ascendens, Botrychium crenulatum, Botrychium lunaria, Botrychium minganense, Botrychium montanum, Bruchia bolanderi, Cypripedium fasciculatum, Cypripedium montanum, Erigeron miser, Eriogonum umbellatum var. torreyanum, Fritillaria eastwoodiae, Helodium blandowii, Juncus luciensis, Lewisia kelloggii subsp. hutchisonii, Lewisia kelloggii subsp. kelloggii, Lewisia serrata, Meesia uliginosa, Mielichhoferia elongata, Peltigera gowardii, Penstemon personatus, Phacelia stebbinsii, Poa sierrae, and Tauschia howellii individuals and/or their habitats but is not likely to result in a trend toward Federal listing or loss of viability for these species within the planning area of the TNF.

This determination is based on many factors including: surveying the Project Area prior to Project operations and buffering rare plant occurrences from disturbance, falling hazard trees away from rare plant occurrences and riparian vegetation whenever possible, leaving the tree bole in place when it falls across a stream and can’t be fully suspended to remove it, leaving the hazard tree in the peatland/fen if it must be felled into that plant community, excluding equipment from riparian buffers, implementing best management practices for soil and water, and implementing the NNIP requirements for prevention, control, and eradication. In addition, there is a low likelihood that the following species will be found in the Project Area because a seed source for them does not exist on the ARRD: Astragalus webberi, Boechera rigidissima var. demota, Cypripedium fasciculatum, Cypripedium montanum, Erigeron miser, Eriogonum umbellatum var. torreyanum, Helodium blandowii, Juncus luciensis, Meesia uliginosa, Peltigera gowardii, Penstemon personatus, and Tauschia howellii.

If the Botrychium species occur in the Project Area they will be located within the riparian buffer areas and equipment is excluded from those areas, reducing possible impacts. Since impacts to streams/springs/seeps (areas where Bruchia bolanderi would grow) will be minimized by implementation of soil and water BMPs and by felling hazard trees away from riparian vegetation whenever possible, possible impacts to these plants will be minimal. In addition, reproductive material (seeds/spores) for Bruchia bolanderi - stored in the soil (if they exist in the Project Area) will still be viable and able to recolonize the Project Area. The burn severity in the Project Area probably killed the perennating buds of some Poa sierrae and possibly whole patches of this grass. Given that there is a low likelihood that this grass exists in the Project Area) and that there are thousands of known plants located relatively adjacent to the Project Area; possible impacts are not considered significant. Possible impacts to Lewisia kelloggii subsp. hutchisonii and Lewisia kelloggii subsp. kelloggii are not expected since these plants grow in openings – areas without trees. Lewisia serrata grows on rocks, frequently on steep canyon walls above streams; areas that will not be impacted by Project operations. Phacelia stebbinsii is an annual plant that grows in openings that could be affected by Project operations but the likelihood of having to fell a hazard tree into any rare plant occurrence is low.

Effects of the Alternatives on rare fungi:

Cudonia monticola (Large Cudonia): This fungus is common under conifers in northern California and the Pacific Northwest. It is considered endemic to northwestern North America and is known from northern Washington, the Cascade Range, mountains of southern Oregon. In California it is known to occur on the Coast Range, in the Klamath Mountains, and northern Sierras. It has been found on the TNF in the Yuba Pass area (YRRD). It is usually found in the spring or summer scattered or in dense groups, growing in humus, soil, and on rotting wood (Arora 1986). It is a basidiomycete that is a saprophyte-decomposer. It is assumed that it is ectomycorrhizal (ECM) and that it has a broad host range including various members of the Pinaceae family. It is an epigeous ECM that is probably located within the top few centimeters of the soil. It is generally found in mature, moist coniferous forests. It has no adaptations to desiccation from loss of humidity in its microclimate. General trends are unknown. Threats are evaluated in terms of negative impacts to the fungal mycelium and include any management activity that would significantly disturb the litter/duff/soil organics directly or indirectly. Ground-disturbing activities that reduce the amount of rotting wood and interrupt the addition of fresh wood to rot would impact this species. Other threats include activities that alter the humidity, light patterns and composition of its habitat.

Dendrocollybia racemosa (Branched Collybia): This is the only mushroom on the TNF known to have branches on the side of the stem. It is a small gray mushroom that is widespread in the Northern Hemisphere but is always locally rare. It grows on rotting or mummified remains of other mushrooms and sometimes in the leaf litter. On the TNF it is known to occur on the YRRD in the Skillman Campground and Bullards Bar areas. The type of fungus that Dendrocollybia racemosa grows on has not been identified other than Russula albonigra (Arora 1986) and Russula and Lactarius species (Vellinga 2014). Arora describes Russula albonigra as growing under both hardwoods and conifers. Vellinga (2014) did not expect Dendrocollybia to be in the wildfire area in 2014 since Russula and Lactarius species are not groups of fungi that are good colonizers and trees would not be established so that ectomycorrhizal formers could fruit.

Phaeocollybia olivacea (Olive Phaeocollybia): This basidiomycete is a mycorrhizal fungus that functions in nutrient cycling. It is a fall-fruiting mushroom that is known to grow in conifer and oak forests. It is endemic to the western United States from the central Oregon coast south to Santa Cruz County. On the TNF it is known to occur on the YRRD in the Hornswoggle Campground area near Bullard’s Bar Reservoir and along the Schoolhouse Trail near Schoolhouse Campground.

Sowerbyella rhenana (Sowerbyella): This fungus fruits’ (produces a mushroom) in the duff of moist and relatively undisturbed older-conifer forests (Castellano et al. 1999). On the TNF it is known to occur in the Schoolhouse Campground area on the YRRD. Threats at the local habitat scale include anything that affects (removes or alters) the substrate on which the fungi grow. Patch retention areas are recommended for these rare fungi along with retention of the woody substrate, forest floor litter, and the tree hosts within the retention patches. Studies suggest that the effects of prescribed fire on the below surface ectomycorrhizal fungal community vary with site conditions, soil composition, and annual weather conditions.

Discussion: Cudonia monticola, Phaeocollybia olivacea and Sowerbyella rhenana are ectomycorrhizal (ECM), and Dendrocollybia racemosa grows on ECM fungi. Cudonia monticola, Dendrocollybia racemosa, Phaeocollybia olivacea and Sowerbyella rhenana are considered epigeous (occur in the humus and litter versus below ground), and epigeous ECM fungi are found within the top few centimeters of soil. The underground portion of ECM fungi is called the mycelia. ECM mycelia play important roles in decomposition, nutrient recycling, and nutrient uptake by trees and shrubs (Harmon 1992, Maser et al. 1984, and North et al. 1997, IN: Roberts et al. 2004). The mushrooms are used as food for mammals and invertebrates (ibid).

Information about these fungi is incomplete. For example, spore dispersal distance, spore dispersal agents, and the viability of spores, are unknown. It is known that most fungal species do not fruit every year and the absence of a fruiting body does not mean that the species is not present. Studies have shown that fungal richness decreases rather rapidly from gap edge to gap opening indicating that the size of the opening may select for pioneer fungi and limit the distribution of those types of fungi that rely on older forests (Kranabetter et al. 1998) – i.e. openings beyond a certain threshold can lead to reductions in ECM species diversity. In one study (Durall et al. 1999), reductions occurred in openings as small as about 45 feet in diameter. Smaller openings retain a higher diversity of mycorrhizae as they have a greater perimeter to area ratio than larger cut blocks (Hagerman et al. 1999).

NO ACTION ALTERNATIVE (2): Implementation of Alternative 2 will not impact sensitive fungi species because no Project operations will be implemented. The remaining burnt trees, logs and branches along with surviving vegetation (referred to as biological legacies) will help the ecosystem to recover by retaining soil, providing nutrient inputs, favoring mutualistic plant- animal interactions, acting as seed traps, facilitating survival and population viability in disturbed areas, and promoting plant and animal recolonization by providing habitat features, substrate and food for many species (Leverkus et al. 2014). Leverkus et al. (2014) reports that burnt-wood management (such as that proposed under the Action Alternative affects plant communities in terms of species richness and diversity, percent cover, and species composition and abundance. However, it is likely that pioneer fungi will colonize the fire area until older forest conditions develop.

DETERMINATION: It is my determination that implementation of the No Action Alternative (2) will not affect Cudonia monticola, Dendrocollybia racemosa, Phaeocollybia olivacea and Sowerbyella rhenana individuals and/or their habitats and is not likely to result in a trend toward Federal listing or loss of viability for these species within the planning area of the TNF. No ground disturbing management activities will be implemented.

ACTION ALTERNATIVE: Implementation of the Action Alternative (1) may affect rare fungi directly, indirectly, and cumulatively.

Discussion: Living trees and shrubs provide the underground linkages for ECM fungi (Amaranthus and Perry 1994). Retaining canopy cover to reduce soil moisture loss, retention of host trees, retaining the largest trees with the greatest chance of being a host, reducing duff and litter loss, and restricting the size of regeneration openings to maintain fungal diversity within an opening, are all management options that can be used to increase fungal diversity when managing forested plant communities. The Project Area was burned and already has a lack of host trees, reduced soil moisture, reduced duff/litter, and essentially has large openings where all of the host trees were killed. About 2,092 acres of the proposed unit acres burned with high severity, 1,030 acres burned with low to moderate severity, and 311 acres burned with moderate to high severity. Table 10 provides an overview of the percentage of each proposed unit that burned in high or moderately high severity. About 16,584 acres of older forest burned in the 2013 wildfire. Table 10 also provides an indication of the percentage of each unit that was considered older forest prior to the 2013 wildfire. Even though fungal surveys have not occurred, it is unlikely that older forest fungi exist in the Project Area (Vellinga 2014). The Project Area had potential habitat for these fungi in older forest areas before it burned. It is expected (but unproven) that areas that still contain living trees (that are not separated by large openings/gaps) still have habitat conditions that would support these ECM fungi. These older forest unburned areas could provide the spores necessary for recolonization of the Project Area in the long term. Well established trees will be needed for the ECM to develop.

Table 10 - Percentage of proposed units that were older forest prior to the 2013 wildfire/that burned with high/moderately high severity

Unit Total % of unit that was % of unit that burned # acres11 older forest prior to the with high/moderately 2013 wildfire high severity 1 19 100% 37% 2 7 100% 43% 3 5 100% 36% 4 84 72% 25% 5 8 100% 38% 6 113 67% 87% 7 28 34% 100% 9 32 100% 31% 10 42 100% 69% 11 17 100% 82% 12 22 73% 68% 13 10 30% 90% 16 144 61% 100% 17 16 94% 100% 18 73 63% 92% 19 15 20% 53% 20 48 94% 71% 21 3 100% 67% 22 22 23% 82% 23 67 69% 100% 24 42 81% 100% 25 55 91% 100%

11 Numbers are rounded. 42

Unit Total % of unit that was % of unit that burned # acres12 older forest prior to the with high/moderately 2013 wildfire high severity 26 22 77% 100% 27 57 72% 79% 28 8 88% 88% 29 74 88% 72% 30 56 32% 80% 31 36 100% 97% 32 24 75% 63% 33 9 67% 44% 34 8 88% 75% 35 26 58% 96% 36 52 37% 81% 37 21 33% 52% 38 27 96% 85% 39 10 90% 20% 40 80 79% 88% 41 38 79% 97% 47 16 69% 81% 48 16 44% 94% 49 58 57% 85% 50 22 72% 68% 51 10 2% 90% 52 24 50% 80% 53 27 55% 82% 54 24 65% 92% 55 25 73% 64% 56 60 54% 92% 57 75 40% 72% 58 19 29% 53% 59 17 77% 94% 60 20 100% 100% 61 59 15% 75% 62 114 28% 93% 63 24 14% 83% 64 48 33% 60% 65 91 100% 97% 67 57 66% 79% 79 21 27% 38% 80 87 84% 53% 81 201 59% 80% 82 10 50% 50% 83 58 92% 83% 84 14 90% 86% 85 21 27% 76% 86 23 79% 48% 87 21 58% 48% 88 9 60% 55% 89 66 65% 73% 90 56 69% 54%

12 Numbers are rounded. 43

Unit Total % of unit that was % of unit that burned # acres13 older forest prior to the with high/moderately 2013 wildfire high severity 91 22 66% 68% 92 59 85% 56% 93 26 23% 85% 94 32 100% 100% 104 298 4% <1% 105 18 100% 39% 107 29 47% 59% 108 32 100% 40% 110 124 51% 82%

In addition, part of the Project proposal is to apply Borax to cut stumps. Application of borax to the stumps of cut trees within older forest areas could impact rare fungi directly, indirectly and cumulatively. However possible effects are considered unlikely due to a lack of host trees, reduced soil moisture, reduced duff/litter, and the large openings where all of the host trees were killed. Information about how Boron/Borax/Sporax may affect fungi is provided below:

Boron/Borax/Sporax: Sodium tetraborate decahydrate is the active ingredient of the chemical used by the Forest Service to treat annosum root disease. In areas where annosum root disease is a forest health issue (current policy recommends application to all cut stumps), it is applied directly to cut tree stump surfaces. A discussion of how this compound might affect non-target micro-organisms is provided here in an attempt to disclose possible impacts to rare fungi. The borax risk assessment can be found at: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml. A review of the risk assessment for the fungicide shows that exposure assessments were not conducted for soil micro-organisms. Therefore, the risk of exposure of these organisms cannot be characterized quantitatively. Since borax is used effectively in the control of fungi, adverse effects of environmental exposure to non-target micro-organisms is possible. However, given the methods in which Borax is applied, it appears unlikely that there would be widespread exposure (Bautista 2012 and Bakke 2012 – personal communications). This is unknown however. In summary, it is likely that rare fungi would be impacted, the extent of the impacts cannot be quantified, but it is expected that widespread exposure would not occur.

Boron – the agent of toxicologic concern in borax or Sporax occurs naturally making some exposure to boron unavoidable. Boron is considered an essential trace element for terrestrial plants but is toxic to terrestrial plants at high levels. The amount of boron required by terrestrial plants to produce optimal growth and development varies tremendously between species and even between strains of the same species (USDA FS 2006). Fungi are expected to not have a boron requirement (Lehto et al. 2010). However, Lehto et al. (2010) reported that increasing boron in the surface and near-surface soil horizons increased mycorrhizal colonization. Obligate mycorrhizal fungi such as Phaeocollybia olivacea, cannot complete their life cycle without a host plant. Since a host plant is needed for their growth, development and reproduction, it seems likely that these fungi would require the nutrient that is required by the host plant. This has not been proven at this time.

13 Numbers are rounded. 44

As noted previously, the American Wildfire greatly reduced the older forest character of the forests in the Project Area.

Direct: In this analysis, possible direct effects are primarily based on impacts to the above ground structures (mushrooms) as a proxy for the below ground mycelia. As mentioned above, Cudonia monticola, Dendrocollybia racemosa, Phaeocollybia olivacea, and Sowerbyella rhenana are expected to be older-forest dependent and the Project Area is no longer considered older forest. Since these fungi are fall fruiting, they would not have been present as mushrooms in August when the wildfire occurred. It is likely, however, that mycorrhizae (located in the duff and litter) were killed during the wildfire. Therefore, it is likely that these fungi did not survive the wildfire. However, there is a small possibility that these fungi are still present in the Project Area (specifically where large old trees are still alive); that they may be fruiting when the trees are felled and removed; and that they would be directly impacted. Direct impacts to above ground portions of these fungi could kill or injure the mushroom. Impacts to mushrooms are comparable to removing an apple from the tree – most of the species continues to live.

Indirect: In this analysis, possible indirect effects are primarily based on impacts to below ground mycelia. If mycelia survived the wildfire, they could be indirectly impacted through disruption the topsoil layer, reduction of leaf litter, reduction in soil shade/moisture, Borax application, and/or reduction in future soil organic material. If these fungi are present in the Project Area, the removal of large wood will impact them – especially over the long term. These indirect impacts are not expected to be significant since soil disturbances will be minimal and the Project Area is no longer considered suitable for them. As noted above, biological legacies will be reduced and surviving vegetation will be killed or injured. Rare fungi could be indirectly affected by less nutrient input to the soil from burnt trees; less plant and animal recolonization due to reductions in habitat features, substrate and food for many species; and greater drought stress due to changes in microhabitat caused by salvage logging. The indirect effects to rare fungi from reductions in biological legacies are not considered significant since it is unlikely that they survived the wildfire.

Cumulative: Project operations will cumulatively impact these fungi. Cumulative impacts are not considered significant because the Project Area burned - significantly reducing the older forest characteristics of the area and the habitat characteristics that these fungi require (such as host trees, litter and duff). Therefore, the Project Area currently contains very little potential habitat for these fungi making the risk of cumulative impacts from Project operations low. However, the following discussion provides information about possible cumulative impacts.

TNF older forests have experienced reductions in the numbers of large trees (that could act as hosts) through thinning, reductions in the amount of leaf litter/duff through fuel reduction activities, reductions in future large decomposed wood through thinning, and reductions in large down wood from fuel reduction activities (habitat components for older-forest dependent fungi). Some of the areas that burned in the Project Area were considered relatively undisturbed – they had not experienced thinning or other fuel reduction activities in perhaps a century. Since surveys were not done before the area burned, the analysis of effects assumes presence.

Management options for areas known to have these rare fungi and to help to maintain a diverse community of fungi across a landscape include: retaining mature trees and the forest floor integrity during timber harvest and mechanical site preparation; avoidance of high-intensity broadcast burns; and managing for coarse woody debris (Cushman and Huff 2007). The following discussion is provided to show how the components of the older forests in the Project Area were affected by the American Wildfire and how Project operations add cumulatively to a reduction in those components.

Reduction in host trees: The Project Area burned with high temperatures and many host trees are now dead or likely to die. Therefore, mycorrhizal connections with many host trees are broken. In general terms, the Project Area no longer contains older trees that would act as host trees.

Creation of openings: The American Wildfire created large openings (from a mycorrhizal point of view) when the trees were killed. In general terms, the Project Area no longer has potential habitat for these rare fungi since the openings between large trees is too big.

Reductions in Litter/duff and large down wood: The American Wildfire reduced the amount of litter/duff and large down wood in the Project Area. Project operations will reduce the amount of future large down wood when burnt trees are removed. Smaller size organic material may be added to the soil from tops and limbs of harvested trees and from smaller dead trees that fall at some future date.

Older forest retention patches: No older forest retention patches are proposed in the Project Area because they were burned in the American Wildfire.

Reduction in overstory canopy cover: The overstory canopy cover is gone. Reductions in overstory canopy (due to the wildfire) changed the thermal properties, humidity, and evapotranspiration (Luoma and Eberhart 2005). Removal of the dead trees further reduces the amount of soil shade but in a small way.

Nonnative invasive plant (NNIP) risk: The Project Area has a high NNIP risk due to suppression activities. Project operations add to this risk by creating soil disturbances adjacent to roads. Further disturbing the soil increases the risk that NNIP can become established more easily (without competition from sprouting or germinating native plants). NNIPs do not form the same mycorrhizal relationships as large trees.

DETERMINATION: It is my determination that implementation of the Action Alternative (1) may affect Cudonia monticola, Dendrocollybia racemosa, Phaeocollybia olivacea and Sowerbyella rhenana individuals and/or their habitats but is not likely to result in a trend toward Federal listing or loss of viability for these species within the planning area of the TNF. The Project Area burned - significantly reducing the older forest characteristics of the area and the habitat characteristics that these fungi require (such as host trees, litter and duff).

VII. PROJECT FILE

The following documents/maps were used during analysis of effects to threatened, endangered, proposed, and sensitive plant and fungi species. They are located in the project files and are included within this Biological Evaluation by reference. • Soil, vegetation, sensitive species occurrence, and project maps • Species occurrence records, e.g. habitat site reports • References • Survey records • GIS maps/layers • Little Secret project folder

VIII. MANAGEMENT REQUIREMENTS

Table 11 displays the management requirements that were designed to reduce possible negative impacts to rare plants and fungi.

Table 11 – Rare Species and Nonnative Invasive Plant Management Requirements

Area of Concern Management Requirement Designed to Responsible Persons Reduce or Prevent Undesirable Effect

Nonnative Plants - Clean all equipment that operates off roads before it District NNIP Coordinator, Prevention enters the Project Area if it is coming from areas Contract Specialist, and infested with nonnative invasive plants (NNIPs) Implementation Team (reference standard provision B6.35 Equipment Cleaning). Nonnative Plants - Clean equipment that is operating off roads before it District NNIP Coordinator, Prevention moves from an infested area within the Project to Contract Specialist, and another area (within or outside the Project Area). Implementation Team Nonnative Plants - Ensure that all plant material used for erosion District NNIP Coordinator, Prevention control and/or road maintenance is NNIP free Contract Specialist, and (including straw and mulches as well as propagative Implementation Team parts such as seed). Nonnative Plants - Survey all units prior to Project operations. If NNIP District NNIP Coordinator, Prevention infestations are found, avoid soil disturbance in Contract Specialist, and infested areas by buffering them by 50 feet until a Implementation Team determination has been made that the infestation is eradicated. Rare Plants - Survey all units prior to Project operations. If rare Zone botanist, Contract Conservation plants (TEP, sensitive, or watchlist) are discovered, Specialist, and buffer them from disturbance by 50 feet or by the Implementation Team recommended distance that was determined on-the- ground based on site conditions. Rare Plants - Leave all hazard trees in place when they must be Zone botanist, Contract Conservation felled into peatlands/fens. Specialist, and Implementation Team Rare Plants - Avoid disturbance to known sensitive plant Zone botanist, Contract Conservation occurrences within the Project/Analysis areas by Specialist, and buffering them by 50 feet. Implementation Team

Area of Concern Management Requirement Designed to Responsible Persons Reduce or Prevent Undesirable Effect

Watershed, Soils, and Establish a 100-foot “riparian buffer” zone along Planning Forester, Prep Aquatic Resources each side of perennial streams and special aquatic Forester, Sale Administrator, features, 50-foot “riparian buffer” along each side of and Riparian Specialist intermittent streams and establish a 25-foot “riparian buffer” zone along each side of ephemeral streams.

No harvest or ground based equipment is allowed in riparian buffers unless agreed to by a riparian specialist. Watershed, Soils and Under coordination with a riparian specialist, hazard Planning Forester, Prep Aquatic Resources trees within the riparian buffer will be felled to Forester, Sale Administrator, mitigate the hazard. They will be felled away from and Riparian Specialist the channel and other aquatic features to minimize disturbance of riparian vegetation. Hazard trees felled within the RCA may be removed by end- lining. End-lining is not permitted through riparian vegetation. Grooves and bare soil created by end- lining will be mitigated with hand-built water bars and/or slash placement. Slash in the RCA will be lopped and scattered (not to exceed 18”). Removal of trees across a perennial or intermittent stream will require full suspension across the entire riparian buffer. If full suspension cannot be obtained then the portion of the log that cannot be suspended will be left in the riparian buffer. Watershed, Soils, and No new landings or roads will be located within Planning Forester, Prep Aquatic Resources RCAs. Consult with a riparian specialist before Forester, Sale Administrator, using an existing skid trail, landing, or road located and Riparian Specialist within an RCA. Watershed, Soils, and Mechanical site preparation for reforestation may Planning Forester, Prep Aquatic Resources occur within RCAs, outside of the riparian buffer, Forester, Sale Administrator, when such operations do not result in detrimental Riparian Specialist, Soil soil compaction, meet soil moisture requirements, Scientist and maintain minimum effective soil cover of 50%.

Appendix A – Environmental Analysis paragraphs

Implementation of the Project will not affect the following sensitive (and threatened) species: Astragalus lemmonii, Astragalus pulsiferae var. coronensis, Ivesia aperta var. aperta, Ivesia aperta var. canina, Ivesia sericoleuca, Ivesia webberi, Lewisia cantelovii, Lewisia longipetala, Monardella follettii, Pinus albicaulis, and/or Pyrrocoma lucida. The Project Area does not contain potential habitat for these plants because the Project is located on the westside of the forest (Astragalus lemmonii, Astragalus pulsiferae var. coronensis, Ivesia aperta var. aperta, Ivesia aperta var. canina, Ivesia sericoleuca, Ivesia webberi, and Pyrrocoma lucida); the Project elevation is too low (Lewisia longipetala); the Project Area does not contain serpentine soils (Monardella follettii and Packera layneae); white bark pine (Pinus albicaulis) does not occur on the ARRD at Project elevations; and/or the plant is only found in the Yuba River drainage system (Lewisia cantelovii).

Implementation of the Project may affect the following sensitive plants: Astragalus webberi, Boechera rigidissima var. demota, Botrychium ascendens, Botrychium crenulatum, Botrychium lunaria, Botrychium minganense, Botrychium montanum, Bruchia bolanderi, Cypripedium fasciculatum, Cypripedium montanum, Erigeron miser, Eriogonum umbellatum var. torreyanum, Fritillaria eastwoodiae, Helodium blandowii, Juncus luciensis, Lewisia kelloggii subsp. hutchisonii, Lewisia kelloggii subsp. kelloggii, Lewisia serrata, Meesia uliginosa, Mielichhoferia elongata, Peltigera gowardii, Penstemon personatus, Phacelia stebbinsii, Poa sierrae, and Tauschia howellii individuals and/or their habitats but is not likely to result in a trend toward Federal listing or loss of viability for these species within the planning area of the TNF.

Area; possible impacts are not considered significant. Possible impacts to Lewisia kelloggii subsp. hutchisonii and Lewisia kelloggii subsp. kelloggii are not expected since these plants grow in openings – areas without trees. Lewisia serrata grows on rocks, frequently on steep canyon walls above streams; areas that will not be impacted by Project operations. Mielichhoferia elongata also grows on rocks – areas that will not be affected by Project operations. Fritillaria eastwoodiae and Phacelia stebbinsii both grow in areas that could be affected by Project operations but the likelihood of having to fell a hazard tree into any rare plant occurrence is low.

Implementation of the Project May affect the following sensitive fungi: Cudonia monticola, Dendrocollybia racemosa, Phaeocollybia olivacea and Sowerbyella rhenana individuals and/or their habitats but is not likely to result in a trend toward Federal listing or loss of viability for these species within the planning area of the TNF. These fungi are older forest dependent and the August wildfire significantly reduced the older forest conditions within the Project Area.

Appendix B – Additional Photos

Unnamed stream above Macedon Tunnel on American Hill road 11-26-13 Arrow points to pool of water

Little Secret Canyon 11-26-13 – blue arrow points to fire damaged trees

Slope above Little Secret Canyon stream 11-26-13 Showing the area adjacent to the American Hill road – arrow points to culvert.

Overview of Little Secret Canyon showing partial burn 11-26-13

Overview of Secret Canyon from the American Hill road. Arrows point to the road and the stream.

Sedum spathulifolium on rocks – uphill side of American Hill Road Secret Canyon stream area